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Review of Draft Clearwater Subbasin Plan (November 2003 version)
February 6, 2004 | document ISRP 2004-4
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Summary
In November 2003, the Council accepted delivery of the 2003
Draft Clearwater Subbasin Plan, a revision of the November 2002 Draft
Clearwater Subbasin Plan produced in response to an ISRP review of the
2002 document (ISRP 2003-3). The 2003 Draft
Clearwater Subbasin Plan is intended to guide future fish and wildlife
projects in the Clearwater River subbasin of Idaho. It represents a major
new step in the Council's Fish and Wildlife Program as it is the first
of approximately 60 forthcoming subbasin plan to be submitted since the
Council called (in 2000) for development of subbasin plans to guide
implementation of its Fish and Wildlife Program. Development of subbasin
plans is part of the Council's Amendment process for the 2000 Fish and
Wildlife Program (FWP).
The November 2003 Draft Clearwater Subbasin Plan is an improvement over
the 2002 draft in that it is better organized and starts to link findings
from the assessment and inventory into the management plan. It is more
readable and cross-referenced than the earlier draft. However, it does not
differ substantively from the 2002 draft; thus, many of the ISRP's major
concerns with that plan's shortcomings remain. The 2003 revised plan did
not build on the detailed comments provided by the ISRP in its review of
the 2002 draft. The 2003 Subbasin Plan remains largely a ?plan to create
a plan?. Nevertheless, the ISRP recognizes that this initial Subbasin
Plan and the ISRP review of it will be scrutinized as a model for subbasin
plans that are still in development and are to be submitted later in 2004.
We encourage planners to recognize the strengths of the Clearwater
Subbasin Plan, as well as the ISRP's criticisms of it.
The November 2003 Draft Clearwater Subbasin Plan and its development
process have several laudable characteristics:
- Clearwater subbasin planners organized an aggressive effort to draft
a subbasin plan and submit it ahead of schedule;
- the Clearwater Policy Advisory Committee (PAC) brought diverse
public and private subbasin interests together for subbasin planning;
- planners attempted to establish specific fisheries, wildlife, and
terrestrial goals, such as anadromous adult return objectives;
- the planners attempted to include socioeconomic factors to inform
long-range planning, and
- the initial portion of the Clearwater assessment describes the
subbasin setting and its general environmental conditions thoroughly
and well, and will provide a rich source of reference material for
people working in this subbasin for years to come.
However, the 2003 Draft Clearwater Subbasin Plan does not constitute a
scientifically justified subbasin plan. It does not clearly set forth and
scientifically justify the desired direction for the subbasin, nor does it
describe a prioritized problem-solving approach to restoration and
protection. The Management Plan does not adequately link the
characteristics of the ecosystems (described in the Assessment) and how
those characteristics will be managed (actively or passively) with current
activities in the basin (the Inventory) or with the abundance,
productivity, and diversity of organisms. It also does not adequately
discuss how habitats develop and are maintained by physical and biological
processes. Finally, the plan is weak in addressing adaptive and
experimental ecosystem-based management and how they would be applied in
the Clearwater Subbasin.
These shortcomings have resulted in a subbasin plan that does not
identify a prioritized set of strategies and actions that is derived from
its Assessment and Inventory. Consequently, the plan provides little
decision-making guidance for planners and managers at immediate or
longer-term time scales. Thus, subbasin planners still must provide such a
prioritization before the next project selection process in order to
justify ongoing projects and identify new needed actions, or
subbasin/regional administrators will be forced to impose their own
prioritization on projects proposed for funding in the Clearwater
Subbasin.
The ISRP believes that the most important points we make concern:
- the need to adequately use available information,
- the need to clearly link the Assessment, the Inventory, and the
analysis of information in these two documents to the resulting
Management Plan, and
- the need to carry the planning process to scientifically justified,
integrated, and prioritized conclusions in the form of realistic
priorities for achievable "next steps" for managing the
subbasin's fish and wildlife resources.
This last step should be obviously drawn from explicit consideration of
alternative possible actions and should show explicit use of, and
consistency with, the Fish and Wildlife Program.
Despite the highly critical nature of this review, the ISRP believes
that subbasin planners will be able to prepare subbasin plans that
adequately meet the Council's expectations for completeness and
scientific soundness, even given the constraints on available time and
funding. Subbasin planners should focus their efforts on the three points
above in order to produce adequate subbasin plans within the time
remaining available to them this spring.
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