Gregor Auble

Midcontinent Ecological Science Center, Biological Resources Division, US Geological Survey

Fort Collins, CO

Comment: ...section on AEAM comes across as 11th hour waffling... I believe adaptive management is the wisest and most intellectually honest approach.... it should be a central element of flow and geomorphic management...

Response: Adaptive management is recommended as requested. While uncertainties always exist when utilizing the scientific method, the TRFE Report presents recommendations believed necessary to restore and maintain the Trinity River anadromous fishery, based on the best available scientific information combined with the professional expertise of a diverse group of scientists and engineers from various federal, tribal and state agencies. The Report does recommend the implementation of an adaptive management strategy aimed to alleviate any remaining uncertainties and to ensure continuous scientific study to verify the success of the restoration goals.

Comment : None of the critical elements of adaptive management are presented in this Section: No causally based prediction about how the system will respond to the flow recommendation and other proposed actions; no measurement scheme for quantifying system response; and no mechanism for revising the management recommendation and causal predictions.

Response:

Comment : There is not even any sense of whether you are proposing adaptive management in the sense of real-time adjustments of reservoir releases to meet monitored downstream targets (e.g., temperature) or in the sense of trying the flow recommendation for ten years until continued declining populations force a reconsideration. There is nothing in this chapter that suggests adaptive management will be effectively employed on the Trinity River and the general implication is that it will continue to be involed without being taken seriously.

Response:

Michael Belchik

Yurok Tribal Fisheries Program

Klamath, CA

Comment : pp1-3 Adaptive management needs more detail, etc....

Response:

Raymond D. Hart

Department of Water Resources

Sacramento, CA

Comment : The data presented do not definitively support any specific flow schedule that would correct declining fish and wildlife populations in the basin... Therefore we agree with the recommendation that any actions adopted be carried out using an adaptive management approach.

Response: Adaptive management is recommended as requested.

William L. Jackson

Water Resources Division, National Park Service

Fort Collins, CO

Comment: Would it make nay sense to stage the implementation of recommendations in this chapter so that the adaptive management program would have a basis for determining which components of the proposed package of management actions resulted in which aspects of the fishery response and, conversely, which actions were ineffective in achieving objectives?

Response: Testing of hypotheses specific to expectations relating to the recommendations is planned as part of the AEAM. The implementation will be approached in phases which allow full opportunity for hypothesis testing.

Thomas E. Lisle

Redwood Sciences Laboratory, US Forest Service

Arcata, CA

Comment : Adaptive management, whereby progress toward physical and biological goals is monitored, is certainly appropriate here, since consequences of changed flow regimes are difficult to predict and there is much at stake where water flows. Strategies for adaptive management are only outlined here. I hope this does not forebode the usual inadequate post-project monitoring. Because of the uncertainty in many aspects of this plan, I can guarantee that important adjustments will need to be made in the next decade. I am concerned that the new flow regime will be implemented without future adjustment until ultimate failure occurs or water users mounting a campaign will face little opposition backed by scientific evidence. I believe monitoring justifies more attention than the document gives it. What are the most critical ( most important. Least understood ) predicted consequences of the new flow regime to monitor? What is the appropriate time frame? I fear hat if adaptive management is not pursued as aggressively as were the evaluations presented here, the ultimate goals of the new flow regime will not be met.

Response:

Frank Michny/ Kenneth Lentz

Environmental Affairs Division, Bureau of Reclamation

Sacramento, CA

Comment : The Adaptive Environmental Assessment and Management section currently does not read like a planned part of the document. Text previously provided by Stalnaker and Wittler should be included and the entire section should better relate to the other parts of the document.

Response:

Comment: ...the report should begin with a full and complete discussion of specific measurable goals and associated objectives.....Also included should be a strategy which leads to the accomplishment of the objectives. This strategy should embrace adaptive management, and the discussion should identify such techniques and actions.

Response: the report has been re-written to address these comments: specific measurable goals, the associated objectives, and specifics of the adaptive management program (AEAM) are now included in Chapter 8.

Comment: Adaptive management practices should be developed to evaluate the effectiveness of flows exceeding 8,500 cfs....(SALMOD) can be useful for forecasting, simulation, and comparison, with adjustment as appropriate for adaptive management.

Response: The AEAM will directly address the effectiveness of all high flow releases, including those at and above 8,500 cfs. Also, SALMOD is being considered for use as recommended by this reviewer.

Comment: Adaptive management techniques should be considered which include not only stepwise implementation of flow levels, but also of non-flow recommendations, such as mechanical rehabilitation of the river channel.

Response: The AEAM program will be implemented to address non-flow as well as flow recommendations.

Comment : Text should be expanded to at leat present an outline for restoration strategy. Information that Stalnaker and Wittler developed for Adaptive Environmental Management should be incorporated here.

Response: The restoration strategy has been described in Chapter 8. AEAM text developed by Stalnaker and Wittler has been incorporated in Chapter 8.4 and Appendixes "N" and "O" .

Duncan Patten

Department of Plant Biology, Arizona State University

Tempe, AZ

Comment : ....The document has a strong commitment to Adaptive Management. This should ensure that all components of the riverine ecosystem will contribute to a dynamic whole.

Response:

Timothy J. Randle

Sedimentation and River Hydraulics Group, US Bureau of Reclamation

Denver, CO

Comment : Although the flow recommendations are fairly specific about magnitude, timing and duration, many of these specific details may have to be changed in the future to actually achieve the desired managment objectives (adaptive management). ....Future study plans should be given priority to funding additional investigations of the physical system.

Response: Priorities for hypothesis testing will be set through the AEAM program. The specifics referred to in these comments will be directly addressed by the AEAM team.

Comment :

An adaptive management program likely will be essential to achieve any of the river restoration goals. The very brief description added to the end of chapter 6 fails to mentions several critcal points.... Adaptive management must develop and include mangement goals for all resources (e.g. irrigation, flood control, dam safety, fish, wildlife, vegetation, etc). ...Success of the program will depend on getting all of the stakeholders involved in the process and on manageing for all resources....These resources management goals must be focused and measurable. ... Monitoring should be used to determine if resource management goals are being met. If goals are not being met, then research can be used to determine why they are not being met.

Response: The AEAM write-up now includes specific reference to several points made by the commentor in Section 8.4.-
8.4.2.3.

Don Reck

National Marine Fisheries Service

Eureka, CA

Comment : Perhaps adding some recent references i n the literature to adaptive management would be appropriate. For example, Castleberry et al. (1996) "...join others in recommending the approach of adaptive management." But perhaps selective references/citations would not be desirable and, and a complete discussion of relevant literature would be too bulky (?).

Response:

Ronald Rempel/ Robert McAllister

California Department of Fish and Game

Sacramento, CA

Comment : Recommended flows are insufficient and would not restore the river... to pre-project conditions. Therefore we recommend the flow regimes... be implemented on an interim basis.

Response: The implementation of the flow regimes is recommended on an interim basis. Refinements tot the release schedules will be made on the basis of findings through the AEAM process.

Jack Stanford

Flathead Lake Biological Station, University of Montana

Polson, MT

Comment : The report end s with the usual obligatory bow to adaptive management and monitoring, but it provides no substance. A flow regime should not be considered well substantiated until it is clear that the managers know how they are going to measure success or failure and what process is going to be used to aplly the new knowledge (from monitoring) to refine the effectiveness of flows (e.g. see Stanford and Poole 1996). This report falls flat in that regard. Salmon and steelhead population dynamics are essential measures of success or railure of reregulation, but they should not be exclusive measures of success of revised flow regime; other measures, such as nearshore algae and invertebrate populations, likely will provide better inferences of the recovery of ecosystem attributes in the short term than the fish (see Stanford et al. 1996).

Response: