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Peer Review of White Papers Prepared in 2006 for the Hydraulic Project Approval Habitat Conservation Plan: Small-Scale Mineral Prospecting Overwater Structures and Non-Structural Pilings Bank Protection/Stabilization Water Crossings

Category: Habitat - Habitat Conservation Plans

Date Published: December 28, 2007

Number of Pages: 392

Author(s): Duane E. Phinney, PH2 Consulting Services LLC


In 2006 and 2007, WDFW contracted with Anchor Environmental, Herrera Environmental Consultants, Jones & Stokes Associates, and R2 Resource Consultants to develop a series of “white papers” documenting the state of the science on a range of topics related to HPAs. The original white papers were peer-reviewed by a panel of experts outside of WDFW.

In developing the white papers, the consultants were working under specific time, scope, and cost constraints established by WDFW. These constraints were designed to further WDFW's specific goal of building a scientific foundation for a Habitat Conservation Plan for hydraulic projects that receive HPAs.

The white papers provide a solid scientific foundation upon which to build conservation measures for avoiding potential impacts, but they are not an exhaustive review of every potential impact of hydraulic projects. Rather, they reflect WDFW’s goal of establishing a solid scientific foundation for the HCP with limited time and financial resources.

Despite these constraints, WDFW is confident that a large proportion of the current scientific literature has been incorporated into the white papers. As WDFW continues to develop the Habitat Conservation Plan, we will also continue to assess new science, fill data gaps, and listen to the advice of scientists and hydraulic project construction specialists.

Subsequent to receiving the white papers, WDFW worked with another consultant and 31 peer reviewers to evaluate the thoroughness of the literature review and recommendations that the white papers provided. The reviewers were drawn from federal agencies, other state agencies, tribes, and businesses. Each reviewer had expertise in the type of construction project that was discussed in the white paper being reviewed. Peer reviewers were informed that the reason for developing the white papers was to ensure that WDFW uses best available science in developing the HCP, but reviewers were not involved in developing the scope of work or the contract for the white papers. As a result, many peer reviewers’ comments reflected an incomplete knowledge of the constraints under which the consultants were working, and were therefore not necessary valid criticisms of the work. Peer review summary reports were developed by an independent consultant, and are available below. These reports include a synopsis of the review, reviewers’ written comments, and the outcome of discussions with peer reviewers.

WDFW did not exercise any editorial control over the content of the peer review reports, and made no attempt to exclude any comments from the reports available below based on their validity with respect to the constraints under which the consultants were working.


The Washington Department of Fish and Wildlife has the responsibility to "preserve, protect, perpetuate, and manage" the fish, wildlife, and shellfish resources of the state, including their habitat. The state Hydraulic Project Approval authority (RCW 77.55), administered by WDFW, is the primary tool for protecting and managing fish and shellfish habitat. The Hydraulic Project Approval authority requires that any work that will "use, obstruct, divert, or change the natural flow or bed" of state waters, saltwater or freshwater, must be conducted under the terms of a permit (Hydraulic Project Approval or HPA) issued by WDFW.

In order to assure the HPA program is in compliance with the Endangered Species Act (ESA) WDFW is developing a Habitat Conservation Plan (HCP). As part of the HCP development process, WDFW commissioned the development of four white papers in 2006 to summarize the state of the science relative to five hydraulic project types: Small-Scale Mineral Prospecting and Mining, Overwater Structures and Non-Structural Pilings, Bank Protection/Stabilization, and Water Crossings. To assure that these white papers are accurate and complete, WDFW commissioned PH2 Consulting Services LLC to coordinate a peer review of each one. The results of that peer review are the subject of this paper.

Five to seven experts in each topic were selected to conduct the review. Upon receipt of all comments, those for each white paper were combined and provided to each reviewer of that white paper. A meeting was convened for each white paper after reviewers had time to review the comments of other reviewers. Discussion of important topics for each white paper at these post-review meetings elicited additional comments.

Major issues the reviewers raised for the white papers are:

  • Inadequate editing to assure consistency within and between white papers,
  • Lack of consistent format, leading to variable and incomplete treatment of the various topics,
  • Lack of a clear link between the subject activity of each paper and effects on potentially covered species,
  • Inadequate treatment of operation and maintenance impacts,
  • Lack of definition and inconsistent use of key term,
  • Lack of definition and inconsistent treatment of cumulative impacts,
  • Differential treatment of saltwater and freshwater aspects of the various impact mechanisms, and
  • Inadequate presentation of recommended mitigation measures.