17 August 1998
Oregon Department of Environmental Quality
Attn: Roger Wood
Water Quality Division
811 SW 6th Ave.
Portland, OR 97204
Dear Mr. Wood:
The Oregon Chapter of the American Fisheries Society (ORAFS) appreciates the opportunity to comment on the Water Quality Management Plan (WQMP) for streams within the planning area of the South Steens Allotment Management Plan (SSAMP) and the Catlow Conservation Agreement(CCA) that do not meet water quality standards.
ORAFS is a volunteer organization of professionals in fisheries and aquatic sciences. We have over 500 members in Oregon, representing a diverse mix of scientists in federal, state, and tribal agencies, higher education, and in the private sector. A principal part of our Chapter mission is promoting the application of sound science in the conservation and management of fisheries and aquatic resources.
The WQMP is a description of the changes in water quality expected from implementation of the SSAMP and the CCA; it is not an action plan that sets out the actions to be taken to achieve the expected results. The SSAMP and CCA are incorporated into the WQMP only by reference. Consequently, the WQMP lacks a conceptual discussion on which to base its predicted changes in water quality criteria. The WQMP would be significantly strengthened if it were to summarize the conceptual and evidentiary bases for the expected changes in water quality from implementation of the SSAMP and the CCA.
We are concerned that the monitoring plan proposed likely will not allow clear determination of the success or failure resulting from CCA and SSAMP implementation. Changes in land use practices with the intent of improving aquatic and upland habitat conditions are essentially an ecological experiment. We concur with the admonitions made in the South Steens Total Maximum Daily Load (TMDL) document that the SSWQMP assumes linear relationships between passage of time, changes in habitat indicators and resulting changes in water quality parameters. We also agree that short term weather patterns or other factors can confound the evaluation of long-term habitat change resulting from land use changes. Therefore, the monitoring program must be sufficiently intensive and extensive to allow distinctions between long-term change and confounding factors to be made. The WQMP addresses only those streams currently on the Oregon DEQ proposed Section 303(d) list. For habitat changes resulting from altered land use practices to be evaluated, unaffected reference streams not on the 303(d) list and/or unaffected by the SSAMP and CCA should also be monitored. We note that Fish Creek, a tributary to the Donner und Blitzen River, is not on the list of streams addressed by the WQMP. Assuming this stream is not on the DEQ 303(d) list, we suggest it be considered for monitoring as an unaffected reference stream. The monitoring program must also cover the full extent of each stream for evaluations to be made with confidence. Private lands comprise a considerable fraction of the streams covered in this plan; however, the monitoring plan presented for the SSAMP in Appendix 4 seems to address only BLM lands. Monitoring of private lands is not specifically addressed.
There appears to be a significant mis-match between the objectives presented in Table 17 and the SSAMP Monitoring Plan presented in Appendix 4. For example, Table 17 calls for streams to exhibit a downward trend in 3 year moving averages of 7 day average daily maximum temperatures (hereafter 7 day average temperatures) by the year 2000. However, the SSAMP monitoring plan (Appendix 4) calls for annual temperature monitoring only in Wild and Scenic River segments, and only every three to five years in Catlow Valley streams. If temperature monitoring begins in 1998, then only three years of temperature data can be collected through the year 2000. Consequently, only one three year average could be calculated by the year 2000, and thus it will be logically impossible to show a declining trend in moving three year averages by the year 2000. Temperature monitoring every three to five years on other streams will not produce the needed three year averages, as comparison of measures taken at three to five year intervals is not directly comparable to trends in moving averages. And, as previously noted, the scope of the monitoring seems too narrow relative to the desired breadth of the conclusions to be reached. We have similar concerns for the ability of the monitoring plan presented to allow evaluation of progress toward other water quality parameters as well.
The SSWQMP – and the related land management measures of the SSAMP and the CCA – are examples of the type of collaborative approach toward management and conservation between private landowners and governmental agencies that is sorely needed. It is this type of effort which must be built upon and expanded if we are to realize improved habitat conditions throughout arid regions of the western states. However, these efforts can serve as a guide to other efforts only if they have credibility, and if there is agreement among the participants as to the direction and magnitude of habitat changes resulting from changed land-use patterns. This credibility and agreement can only come about if the monitoring plan speaks directly to the expectations and questions associated with implementation of the SSAMP and the CCA.
ORAFS encourages DEQ to work with BLM and the private landowners of the Catlow Valley to turn these three plans into a clear experiment on the effects of collaborative change in land-use practices. If done well, these efforts could serve as a template for other such efforts throughout the arid regions of the west. We also encourage DEQ and the other agencies involved to constitute an independent scientific review team, along the lines of the IMST developed under Governor Kitzhaber’s Oregon Plan, which can provide guidance to ensure that the data collected through monitoring will be sufficiently intensive and extensive to answer the questions raised by the experimental approaches.
We appreciate the opportunity to comment on the SSWQMP.
Hal Weeks, President for the Executive Committee
c. Paula Burgess, Governor’s Office, State Capitol