Exhibit (C)
Fish Passage Waiver for Ochoco Irrigation District’s Proposed Hydroelectric Project on Bowman Dam, Crooked River
Supplemental Public Correspondence received as of September 30, 2020 Lisa Kingsley
From: Comcast
Follow Up Flag: Follow up Flag Status: Completed
Categories: Forwarded to Fish
I am writing to ask you to deny the requested fish passage waiver on the Crooked River Bowman Dam. Reconnecting the Crooked River is critical to reviving abundant, wild fish in the Deschutes Basin. Establishing fish passage at Bowman Dam would provide connectivity for redband trout below the dam with 498 miles of habitat above the dam. It would also provide key connectivity to 63 miles of steelhead trout habitat and 53 miles of historic spawning and rearing habitat for spring Chinook salmon, both of which are actively being reintroduced to the upper Deschutes basin. As a fly fisher with one eleven year old fly fishing daughter and thirteen year old fly fishing son, I would like them to have a better environment to fish and explore. Habitat is the key to successful fisheries, and connectivity of river systems is imperative to wild trout.
Thank you for your consideration.
Sean Brady Lisa Kingsley
From: garth wyatt
To whom it may concern,
Please find the attached comments regarding the decision to issue a fish passage waiver to the City of Prineville and Ochoco Irrigation District for the installation of a turbine at Bowman Dam. Thank you for the opportunity to comment.
Garth Wyatt Oregon City, Or Oregon Fish and Wildlife Commission
Re: Comments on the Bowman Dam fish passage waiver request
ODFW Commission,
I am writing today on behalf of myself as a concerned citizen regarding the recommendation to not issue a fish passage waiver at Bowman Dam to Ochoco Irrigation District and the City of Prineville.
I’ll start by stating that my personal feelings are the only way we recover fish is to re-establish connectivity to their former habitat. I’ve always been a proponent of fish passage projects in lieu of mitigation where feasible and logical. As an angler who grew up in Madras fishing the Crooked River the decision to issue or not issue a fish passage waiver is of concern to me. Initially I was fully supportive of ODFW’s recommendation to not issue a fish passage waiver but as I reviewed the relevant documents, I found this to be a complex and unique situation that warrants further review. My thoughts are as follows:
1. Bowman Dam has caused elevated total dissolved gas (nitrogen) and gas bubble disease (GBD) has been documented in fish downstream of the dam. This appears to be primarily driven by design of the flow release structure and stilling well. Upon my review I found GBD has been documented by Nesbit (2010) and noted by ODFW (2016) to be possibly the most serious problem caused by high discharge in the Crooked River affecting all life stages in any given year. 2. The Bureau of Reclamation stated installing a turbine and Howell-Bunger valve would be a viable option to reduce TDG supersaturation and therefore improve environmental conditions for fish in the Crooked River. The prepared documents in support of the of the project indicate the proposed installation of a turbine runner will improve water quality by reducing TDG. It seems apparent that by lowering the percentage of flow traveling through routes that result in plunging flow you would reduce GBD thereby reducing mortality in fish downstream of the dam during spring runoff (especially during high runoff years). While high runoff years occur infrequently, TDG reductions should decrease oscillations in recruitment of redband trout, Chinook, and steelhead downstream of Bowman Dam. Stabilizing the trout fishery and enhancing the reintroduction program. In summary the benefits of granting the waiver should achieve TDG reductions, fish passage/screening on Ochoco Creek, and increases to invertebrate production, water temperature reduction, and potential increase in suitable spawning habitat (proposed gravel augmentation program). The recommendation of full fish passage (denial of the wavier) will likely result in the benefits not being realized in light of: a. The cost of installing fish passage would vastly exceed the anticipated revenue generated from the proposed hydropower facility (3 MW). The notion that an entity like the city of Prineville and Ochoco Irrigation District could afford a 50- 100-million-dollar purpose designed fish passage system and annual operating costs of such a program based on the anticipated revenue and rate base (irrigation revenue) of the area doesn’t appear realistic. 3. The dam will still be there regardless of whether the fish passage waiver is issued. This is a unique situation where the dam owner (BOR) is not the one applying for a hydropower unit. If the waiver isn’t granted the project is likely dead and so are the anticipated benefits for the foreseeable future. Given the BOR is not legally obligated to install fish passage at Bowman Dam it appears as though we’ll be in status quo for an undetermined amount of time. In this case it appears that an all (passage) or nothing (no issuance of a waiver) is going to result in a loss of a great opportunity to improve the environmental conditions on the Crooked River. One final thought, if the waiver is granted and the unit is installed the associated FERC license will have a sunset date. Should the reintroduction effort flourish in the decades to come fish passage can be pursued when the FERC license expires. In my opinion the current status of the reintroduction program does not warrant access to the upper Crooked River (i.e. passage upstream of Bowman) and resident/reintroduced fish production appears to be limited by water quality/quantity (flow regime/spring runoff/winter flow) rather than total available habitat. This is likely a once in a lifetime opportunity to do something meaningful to address a critical (albeit variable) bottleneck to fish production. I would urge the Commission to consider these comments and grant the passage waiver to prevent losing a valuable opportunity to achieve an ecological uplift for the Crooked River basin.
Thank you for the opportunity to comment,
Garth Wyatt
Oregon City, Oregon
Sources: https://www.dfw.state.or.us/fish/local_fisheries/deschutes/docs/Crooked_River_Summary_Repor t_2016_FINAL_REPORT.PDF https://ir.library.oregonstate.edu/downloads/t435gj42b Lisa Kingsley
From: Kris Nelson
Dear Commissioners:
By now isn’t it clear that fish passage at Bowman Dam is essential to the health of the Crooked River and its wild, native fish?
Thank you,
Kris Nelson 633 NE 68th Ave. Portland, OR 97213 503.318.0223
Sent from Mail for Windows 10
Lisa Kingsley
From: The Edgars
Fish passage at Bowman Dam is essential to the health of the Crooked River and its wild, native fish. The commission should push hard to keep a fish passage on this river.
Sincerely, Barrett Edgar PO Box 210 Wedderburn. OR 97491 Lisa Kingsley
From: Kim Freeman
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I support ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I am encouraged by ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your time.
Sincerely, Kim Freeman 6954 se yamhill street Portland, OR 97215
1 Lisa Kingsley
From: Dale Madden
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you. That would increase the number of fish that travel by the back of my house and help the economy of Wasco county along with Maupin.
Thank you for your consideration.
Sincerely, Dale Madden 702 Deschutes River rd Maupin, OR 97037
2 Lisa Kingsley
From: Kathleen Roche
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I am an ecologist and resident of Oregon. I live near the subject Crooked River, I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage. Restoring our fish populations is critical to maintaining functioning ecosystems that we all rely on,
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Kathleen Roche 63255 Stonewood Dr Bend, OR 97701
3 Lisa Kingsley
From: Cooper Morrow
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I commend you for your commitment to ensuring that Oregon’s fish passage laws are upheld and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application, which offered less than 4 miles of habitat improvement, did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Cooper Morrow 1090 NE Hobbs CT Bend, OR 97701
4 Lisa Kingsley
From: STEVEN Kaser
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
YOU FOLKS BETTER LISTEN TO THE ODFW ON THIS ONE! EVEN ALLOWING THIS BEFORE YOU UNCHANGED AFTER DENYING IT THE FIRST TIME TELLS YOU ALL YOU NEED TO KNOW.
IT DOESNT TAKE MUCH COMMON SENSE TO SEE WHATS GOING ON HERE.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied FOR GOOD THIS TIME!
Sincerely, STEVEN Kaser 502 Lewis St Silverton, OR 97381
5 Lisa Kingsley
From: David Hohler
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced. I am a staunch supporter of fish passage over man made barriers and the access to lost habitat that it provides. I don't believe that OID has made a good faith effort to mitigate the continued loss of passage.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I strongly support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, David Hohler 3147 NW Norwood Dr Corvallis, OR 97330
6 Lisa Kingsley
From: Jeffry Gottfried
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
For the past 45 years, I have witnessed the degradation of fish populations and habitat on the Crooked River due largely to the Irrigation District' s water management that has put alfalfa ahead of fish and wildlife habitat.
I urge the Fish and Wildlife Commission to take advantage of this once in a lifetime opportunity to greatly improve fish and wildlife habitat on the Crooked by insisting on fish passage at Bowman Dam. This action will bring salmon and steelhead to the upper river, resulting in a huge influx of fish and wildlife food from the sea to the high desert.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Sincerely, Jeffry Gottfried 7040 SW 84th Ave Portland, OR 97223
7 Lisa Kingsley
From: Gail Sabbadini
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I am a retired biologist and I support ODFW’s denial of the waiver of a fish passage for the Bowman Dam. The decline of the fisheries of the Deschutes watershed and particularly of the Crooked River basin must be prevented from further degradation and reversed to allow natural fish migratory routes to be restored.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Gail Sabbadini 3174 NW Quiet River Ln. Bend, OR 97703
8 Lisa Kingsley
From: Antar Pushkara
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Antar Pushkara 85091 Larson Rd Eugene, OR 97405
9 Lisa Kingsley
From: David Heller
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage. This occurred after careful consideration of the the project details and proposed mitigation.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied. This is a balanced group with diverse interests and their recommendations are carefully and objectively arrived upon.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, David Heller 3335 NE 32ND AVE PORTLAND, OR 97212
10 Lisa Kingsley
From: Mike Kasberger
Please accept the attached testimony for this Fridays Commission meeting. This letter is concerning EXHIBIT C: BOWMAN DAM HYDROELECTRIC PROJECT FISH PASSAGE WAIVER.
Mike Kasberger | Assistant City Engineer
To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet. 387 NE 3rd St | Prineville, OR 97754 Tel: 541.447.5627 | Ext: 1126 Email: [email protected]
To help protect your To help protect your To help protect your privacy, Microsoft Office privacy, Microsoft Office privacy, Microsoft Office prevented au tomatic prevented au tomatic prevented au tomatic download of this picture download of this picture download of this picture from the Internet. from the Internet. from the Internet. Facebook Twitter YouTube Where the Future Meets the Frontier cityofprineville.com
The information transmitted, including attachments, is intended only for the person(s) or entity to which it is addressed and may contain confidential and/or privileged material. Messages and attachments sent to and from this address are from a public entity and may be subject to disclosure under Oregon public records law. If you received this in error, please contact the sender and destroy any copies of this information.
11 Lisa Kingsley
From: Bruce at Ochoco Irrigation
Please update the attached testimony for this Fridays Commission meeting. The previous version had a minor scanning error.
This letter is regarding Exhibit C: Bowman Dam Hydro
Sincerely,
Bruce Scanlon Ochoco Irrigation District 1001 NW Deer St. Prineville, OR 97754 541.447.6449
From: Mike Kasberger Sent: Monday, October 05, 2020 4:07 PM To: [email protected]; [email protected] Cc: Steve Uffelman
Please accept the attached testimony for this Fridays Commission meeting. This letter is concerning EXHIBIT C: BOWMAN DAM HYDROELECTRIC PROJECT FISH PASSAGE WAIVER.
Mike Kasberger | Assistant City Engineer
387 NE 3rd St | Prineville, OR 97754 Tel: 541.447.5627 | Ext: 1126 Email: [email protected]
20
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The information transmitted, including attachments, is intended only for the person(s) or entity to which it is addressed and may contain confidential and/or privileged material. Messages and attachments sent to and from this address are from a public entity and may be subject to disclosure under Oregon public records law. If you received this in error, please contact the sender and destroy any copies of this information.
21
Chair Wahl Commissioner Labhart Commissioner Spelbrink Commissioner Wolley Commissioner Hatfield-Hyde Commissioner Zarnowitz
October 5, 2020
Dear Chair Wahl and members of the Oregon Fish and Wildlife Commission, As leaders of Crook County, we are writing to urge you to grant Ochoco Irrigation District’s (OID) request for a Fish Passage Waiver at Bowman Dam on the Crooked River. OID, in cooperation with the City of Prineville and Crook County, secured a preliminary permit from the Federal Energy Regulatory Commission (FERC) in December 2016 for installation of a small-scale hydroelectric power plant at Bowman Dam. OID is pursuing the project to provide carbon-free electricity for the entire region, improve irrigation district operations and maintenance, provide a long-term revenue source to finance additional infrastructure modernization, and enhance fish habitat and water quality conditions in the Crooked River (benefits summary attached). The proposed hydropower project will not have adverse effects on the environment, and the hydroelectric turbine will opportunistically generate power in concert with existing water operations. Nevertheless, Oregon state law requires that modifications to existing artificial obstructions without fish passage must either include fish passage or receive a passage waiver from the Fish and Wildlife Commission. These laws were written for the purpose of protecting Oregon’s fisheries resources from projects that could otherwise harm fish. Because our proposed project will benefit fish and water quality, we were initially unsure whether a waiver was necessary. However, the Oregon Department of Fish and Wildlife (ODFW) advised us that a waiver was needed. Therefore, OID engaged the waiver application process in good faith that ODFW would work collaboratively with us on a viable path forward. On May 7, 2020, OID submitted a complete Fish Passage Waiver application to ODFW after more than two years of effort to define a set of conservation measures that met the waiver requirements. This effort involved numerous meetings and conference calls with ODFW staff, as well as other agencies and NGOs. The final application included plans to improve fish habitat and water quality by funding four high-priority restoration projects downstream of Bowman Dam, lending support to salmon and steelhead reintroduction efforts within the Crooked River basin (see attached summary). Benefits of OID’s proposal were acknowledged by the U.S. Fish and Wildlife Service and National Marine Fisheries Service, the federal entities responsible for the recovery of ESA-listed fish (see attached agency support letters). On June 26, 2020, despite the project’s notable benefits, ODFW’s Fish Passage Task Force made their recommendation to deny the waiver. The Task Force concluded that OID proposed insufficient conservation measures. This decision was made in accordance with ODFW’s Net Benefits Analysis, which we contend does not reflect best available science and misrepresents current conditions in the Upper Crooked River basin (see attached site photos). In-depth analyses provided in our waiver application relied on roughly 50 miles of available habitat data in the upper Crooked River basin, as well as multiple assessments conducted downstream of Bowman Dam. Our application and supporting documents demonstrate that OID’s proposal exceeds the standard for a net benefit to fish. Unfortunately, ODFW staff produced a Net Benefits Analysis that largely ignored our findings, contradicted previous agency evaluations (see attached table), and did not use best available data. In concert with ODFW’s analysis, members of the Task Force greatly exaggerated the prospective benefits of passage at Bowman Dam, requesting that OID establish a cash conservation fund in addition to the proposed conservation projects. We believe the waiver application process should objectively weigh the benefits of passage against the proposed mitigation projects, and it is our understanding that ODFW staff and the Fish Passage Task Force are required to use biological measures to evaluate a project's merits and formulate recommendations to the Fish and Wildlife Commission. However, the Task Force’s recommendation appeared to yield to political pressures rather than biological reasoning. ODFW and members of the Task Force have attempted to levee as much conservation funding as possible from the applicants without establishing scientifically credible criteria for the amount of mitigation requested. We understand ODFW’s desire to secure funding for as much restoration work as possible, but the Department’s approach to the Net Benefits Analysis deviated from the statutory requirement to examine benefits under current conditions. There were additional policy decisions made during the waiver application process that further encumbered our waiver application. For example, ODFW recognizes that water quality conditions downstream of Bowman Dam have been compromised for decades by high concentrations of dissolved gas, which is known to cause injury and mortality to fish in the lower Crooked River. Indeed, ODFW’s local area staff recommended modifications to Bowman Dam in 2016 to decrease dissolved gas levels in the Crooked River1. While installing the hydropower turbine, OID proposes to include two valves designed to dissipate entrained gas in the stilling basin below the dam at a cost of approximately two million dollars. When ODFW learned about this component of the project, OID was informed that improvements to water quality would not be included in the fish benefits analysis for the passage waiver because water quality changes fall under the jurisdiction of the Department of Environmental Quality. The statewide passage priority list provides another example of an ODFW policy that negatively influenced our passage waiver application. Shortly after OID received a preliminary permit from
1 From Hodgson and Porter (2016): "Making changes to the current discharge regime and outlet structure of the dam will benefit fish populations in the Crooked River. This will improve the likelihood of successful steelhead and Chinook salmon reintroduction and maintain a healthy and abundant redband trout population." FERC, Bowman Dam moved up ODFW’s Fish Passage Priority List from #534 (out of 589) in 2013 to #15 (out of 588) in 2019. Changing Bowman Dam from a low priority to a high priority passage barrier compounded the difficulty of achieving a favorable recommendation for a waiver from the Fish Passage Task Force. OID was disappointed to learn that these changes were the result of new methods for defining the passage priority list. We later learned that, much like the Department’s Net Benefit’s Analysis, the passage priority analysis published in 2019 did not accurately assess habitat conditions upstream of Bowman Dam, and largely relied on assumed historic distributions of fish, instead of evaluating current conditions. Fish passage at Bowman Dam would be technically difficult and cost prohibitive. The proposed hydroelectric project could not feasibly generate enough revenue to fund construction and operation of passage facilities. Therefore, a passage waiver is necessary for this project to proceed. ODFW and the Fish Passage Task Force requested additional conservation funds, but we are unable to provide additional funding beyond the amounts proposed in the waiver application due to the small amount of profit anticipated for this project. Furthermore, the amount of fish conservation investment proposed by OID far exceeds the amounts previously offered by waiver applicants for small-scale hydropower projects. Altogether, our community in Crook County has invested considerable effort and more than $500,000 over the past five years to pursue this project. We hope the Commission will carefully consider the merits of our proposal and help us move forward with a project that is good for the environment and our local economy.
Thank you for your consideration.
Sincerely,
Bruce Scanlon, Manager, Ochoco Irrigation District Steve Forrester, Manager, City of Prineville Brian Barney, Commissioner, Crook County
Attachments: 1. Bowman Dam Hydroelectric Project Benefit Summary 2. Summary Table of Incongruencies between ODFW’s Net Benefit Analysis and ODFW’s Technical Reports 3. Upper Crooked River Basin Site Visit Summary 4. Letters of support from the National Marine Fisheries Service and U.S. Fish and Wildlife Service BOWMAN DAM HYDROELECTRIC PROJECT PROJECT BENEFIT SUMMARY 16 June 2020
• No Negative Effects. The proposed project will not adversely affect the environment or native migratory fish (NMF) populations in the Crooked River basin. Project construction is expected to be low-impact, and, once completed, the hydroelectric turbines will opportunistically generate
power in concert with existing water operations. As a result, the project will not negatively affect
ramping rates, flow fluctuations, channel scour, sedimentation, or fish entrainment.
• Improve Control of Flow Releases. The proposed project will include modifications to Bowman Dam that will allow the operator to implement a broader, more sophisticated array of flow release strategies for fish and wildlife enhancement. U.S. Fish & Wildlife Service and National Marine Fishery Service consider these modifications to be a high priority for the Crooked River basin as they are expected to facilitate implementation of proposed ramping rates to reduce the potential for stranding of NMF. • Improve Water Quality. The proposed project will replace the current outlet works at Bowman Dam with Howell Bunger valves, which will alter the angle of released water and reduce total dissolved gas (TDG) saturation.
• Reduce Gas Bubble Disease. Elevated TDG can cause gas bubble disease (GBD) and lead to injury or mortality of NMF. ODFW has reported that 28-85% of Redband Trout and Mountain Whitefish below Bowman Dam have displayed signs of GBD following high spring flows. The project is expected to decrease mortality of Redband Trout due to GBD by more than 300 fish per mile in the Crooked River between Bowman Dam and Prineville. • Restore Coarse Substrates. Passive gravel augmentation downstream of Bowman Dam is expected to restore the supply of coarse sediments that was lost with the construction of the dam. This measure will improve spawning habitat for Chinook Salmon, Steelhead Trout, Redband Trout and Mountain Whitefish in a 14-mile section of river downstream of Bowman Dam. Gravel augmentation is also likely to improve the production and diversity of benthic invertebrates.
• Improve Fish Passage. Ochoco Irrigation District (OID) will fund the implementation of a passage project at Prineville Golf Club in Ochoco Creek, which will provide NMF with access to
an additional 2.5 miles of habitat. This reach contains the highest quality habitat for Steelhead and
Redband Trout currently found in the lower Ochoco Creek.
• Habitat Restoration. OID will fund $200,000 in habitat restoration at Ochoco Preserve. This measure will help to restore river channel and riparian habitat on approximately 1 mile of the Crooked River, 0.4 mile of McKay Creek, and 0.4 mile of Ochoco Creek, as well as upland and wetland habitat on the 185-acre preserve. Restoration of Ochoco Preserve is considered an important step towards the reintroduction of salmon and steelhead in the Crooked River basin. • Renewable Energy. Electricity generated at Bowman Dam will provide local communities in Crook County with a consistent source of renewable energy and ensure long-term sustainability.
• Support Water Conservation. A portion of the revenue generated by the project will be used by OID to support water conservation projects and water quality improvements throughout the Crooked River basin.
SUMMARY TABLE OF INCONGRUENCIES BETWEEN ODFW'S NET BENEFIT ANALYSIS AND CURRENT CONDITIONS
Net Benefit Analysis Stream Current Conditions Assumptions "From a fisheries perspective, Camp Creek is no longer inhabited by 12 mi Redband salmonids and given the habitat and water quality conditions Camp Creek Trout Habitat throughout the watershed it is not likely they will be present in the foreseeable future." (Brett Hodgson, ODFW Biologist, 2004) "Low abundance of, and poor quality, spawning gravel combined with high summer temperatures, low flows, and high turbidity limit trout South Fork 21 mi Redband natural production potential. […] Electroshocking surveys in the South Crooked River Trout Habitat Fork Crooked River from 1993, 1994 and 1995 failed to capture any juvenile salmonids, suggesting that there is no natural production." (Crooked River Basin Plan 1996) "In the lower North Fork Crooked River, below the confluence with Deep Creek, redband trout comprise less than 1% of the population. North Fork 9 mi of Redband This is likely due to increasingly poor water quality characteristics Crooked River Trout Habitat including low summer flows, high water temperatures and turbidity, and poor riparian conditions." (Crooked River Basin Plan 1996) "Redband trout were very sparse in the mainstem Crooked River above 53 mi of Redband Prineville Reservoir, where habitat is characterized by a deeply incised Crooked River Trout Habitat stream channel, very low summer flows, and high water temperatures." (Redband Trout Investigations in the Crooked River Basin 2007)
"Redband trout abundance is depressed in Bear Creek because of poor 29 mi of Redband Bear Creek riparian conditions, low flows and high summer water temperatures." Trout Habitat (Crooked River Basin Plan 1996) "Summer flows on the mainstem [Beaver Creek] and lower tributaries range from 0 to 5 cfs with numerous irrigation dams diverting much of the flow throughout the private lands.[…] as flows decline due to 21 mi of Redband Beaver Creek irrigation withdrawal, and summer water temperatures increase, Trout Habitat nongame species such as largescale sucker, northern squawfish, and chiselmouth comprise the vast bulk of fish biomass." (Crooked River Basin Plan 1996) "Most of these populations have been fragmented and isolated due to Small 319 mi of Redband physical and water temperature barriers. […] Many of the small Tributaries Trout Habitat tributary streams are intermittent or ephemeral and provide extremely limited or seasonal habitat for trout." (Crooked River Basin Plan 1996) "Summer flow is routinely below 5 cfs with stream temperatures in the Crooked River 63 mi of Steelhead mid 80s. Suitable steelhead production areas are fragmented are largely & Beaver Habitat disconnected from viable migration and rearing areas." (Oregon Creek Steelhead Recovery Plan 2010)
PO Box 744 Boring, OR 97009 503-663-3697
Fisheries and Aquatic Toxicology Research mthoodenvironmental.com
Upper Crooked River Basin Site Visit
Mount Hood Environmental & Crooked River Watershed Council
Location: Post, Oregon
Date: 9/23/2020
Time: 10:00 AM – 4:00 PM
Participants: Ian Courter, Sean Gibbs, and Chris Gannon
The purpose of our trip was to document fish habitat conditions in the upper Crooked River basin. We focused our attention on the mainstem Crooked River and its largest tributaries, including North Fork Crooked River, South Fork Crooked River, Beaver Creek, and Camp Creek because these streams were believed to have historically supported the most productive fishery habitats in the basin1. Additionally, the Oregon Department of Fish and Wildlife stated in their Net Benefits Analysis that these streams would support Redband Trout Oncorhynchus mykiss, Chinook Salmon O. tshawytscha, and steelhead trout O. mykiss if passage were provided at Bowman Dam. In summary, we found that large portions of the upper Crooked River basin are either unsuitable for, or inaccessible to native migratory fish under current conditions. Most stream reaches lacked flow and consisted of residual pools with dense aquatic vegetation and notable amounts of algae (Figures 1 – 9). Livestock grazing has resulted in eroded banks and poor riparian conditions throughout much of the basin. Fish species observed included dace Rhinichthys spp. and nonnative Smallmouth Bass Micropterus dolomieu. Many residual pools did not appear to be occupied by fish. These observations are supported by analysis of available habitat data2 and are consistent with the existing literature.
1 Stuart, A.M., Grover, D., Nelson, T.K. and Thiesfeld, S.L., 2007. Redband trout investigations in the Crooked River basin. Redband trout: resilience and challenge in a changing landscape. Oregon Chapter, American Fisheries Society, Corvallis, pp.76-91.
2 Mount Hood Environmental. 2020. Assessment of Native Migratory Fish Habitat in the Upper Crooked River Subbasin. Technical Report Prepared for Ochoco Irrigation District, City of Prineville, and Crook County. 29 pp.
Crooked River . NF Crooked Beaver Cr
Camp Cr.
SF Crooked
Figure 1. Upstream view of mainstem Crooked River above Prineville Reservoir (RM 85.5). Much of the channel was completely dry, with only a few small residual pools.
Page 2 of 10
Crooked River . NF Crooked Beaver Cr
Camp Cr.
SF Crooked
Figure 2. Upstream (top) and downstream (bottom) view of Crooked River along Highway 380 (RM 90). This stream reach consisted of disconnected residual pools with dense aquatic vegetation and algae.
Page 3 of 10
. Crooked River NF Crooked
Beaver Cr
Camp Cr.
SF Crooked
Figure 3. Upstream (top) and downstream (bottom) view of North Fork Crooked River near its confluence with the Crooked River. We observed less than 2 cfs of active flow, which was insufficient to provide upstream passage for migratory fishes. Several subadult Smallmouth Bass were observed below bridge.
Page 4 of 10
. Crooked River NF Crooked
Beaver Cr
Camp Cr.
SF Crooked
Figure 4. Upstream (top) and downstream (bottom) view of Camp Creek at Highway 380 bridge (RM 1). Flow was not observable. Aquatic vegetation was very dense and algae was present in most residual pools.
Page 5 of 10
Crooked River . NF Crooked Beaver Cr
Camp Cr.
SF Crooked
Figure 5. Natural barrier (top) on Camp Creek and channel immediately upstream of barrier (bottom), RM 8. In their Net Benefit Analysis, ODFW assumed there were 21 miles of Redband Trout habitat available upstream of this impassable barrier.
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Crooked River . NF Crooked Beaver Cr
Camp Cr.
SF Crooked
Figure 6. Downstream view of Twin Buttes Dam on the Crooked River (RM 133). This dam appeared to be a complete barrier for migratory fishes.
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Crooked River . NF Crooked Beaver Cr
Camp Cr.
SF Crooked
Figure 7. Upstream (top) and downstream (bottom) view of South Fork Crooked River at Highway 380 bridge (RM 0.3). Flow was not observable and aquatic vegetation was dense.
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. Crooked River NF Crooked
Beaver Cr
Camp Cr.
SF Crooked
Figure 8. Upstream views of Beaver Creek (RM 6) near Paulina, OR. As with many other sites, flow was not observable. Aquatic vegetation was very dense and algae was present in long, residual pools.
Page 9 of 10
. Crooked River NF Crooked
Beaver Cr
Camp Cr.
SF Crooked
Figure 9. Upstream (top) and downstream (bottom) view of Beaver Creek at bridge on Beaver Creek Road (RM 14). No observable flow, only disconnected residual pools with dense aquatic vegetation and algae
Page 10 of 10 UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE West Coast Region 304 S. Water Street, Suite 201 Ellensburg, Washington 98926-3617
June 22, 2020
Ted Wise East Region Hydropower Program Coordinator Oregon Department of Fish and Wildlife 61374 Parrell Road Bend, Oregon 97702
Re: Oregon Department of Fish and Wildlife Benefit Analysis for the Bowman Dam Fish Passage Waiver Application
Dear Mr. Wise:
The National Marine Fisheries Service (NMFS) has reviewed the Oregon Department of Fish and Wildlife’s (ODFW) Benefit Analysis, dated June 1, 2020. The Benefit Analysis pertains to the Ochoco Irrigation District’s (OID) proposed Bowman Dam Hydroelectric Project and application to the State of Oregon for a fish passage waiver.
Bowman Dam is located on the Crooked River roughly 20 miles south of the City of Prineville in Crook County, Oregon. The dam is owned by the U.S. Bureau of Reclamation and was originally authorized for flood control and irrigation. The dam, completed in 1961, does not include any hydropower or fish passage facilities. The OID is seeking to install a 3-megawatt hydropower facility at the downstream toe of the dam. The proposed project would require modifications to the dam’s intake gates and spillway.
Oregon Revised Statue (ORS) 509.585 requires that modifications to existing dams without fish passage must provide passage, or in lieu of passage provide mitigation that results in an equal or greater value to fish passage. The ODFW’s benefits analysis concluded that the conservation measures proposed by OID do not result in a net benefit to native migratory species and are therefore recommending to its Commission that OID’s fish passage waiver request be denied. It is our understanding that ODFW will continue to pursue mitigation options with OID.
NMFS supports and values ODFW’s substantial efforts to fulfill its obligations under ORS 509.585. Furthermore, ODFW must address the needs of both anadromous and resident fish species. Our comments are provided in the context of the biological needs of anadromous fish. We believe that the mitigation and enhancement measures proposed by OID (discussed below) do provide conservation benefits for anadromous fish. We expect that OID would abandon the proposed project if fish passage is required and therefore these benefits would not be realized.
2
Ochoco Irrigation District Conservation Measures
Gravel Augmentation: The OID proposes to initially add 500 cubic yards of gravel to the Crooked River below Bowman Dam. The gravel would be of suitable size for both resident and anadromous fish spawning. The OID would monitor the movement of this gravel for the first 3 years and every 5 years afterword. Gravel would be replenished when needed and OID proposes to coordinate with ODFW on the augmentation program.
Gravel augmentation could be a significant benefit to reintroduced anadromous fish species, but we agree that this measure needs more refinement. We note that the normal transport of gravel from upstream sources is entirely blocked by the dam which has existed since 1961.
Ochoco Creek Passage: The OID proposes to give the Crooked River Watershed Council $90,500 in funds to install a fish passage structure on a diversion at about river mile 9 on Ochoco Creek. The diversion belongs to the Prineville Golf Club. Passage at this diversion would provide an additional 2.25 miles of habitat and has been a priority for anadromous fish reintroduction.
Ochoco Preserve: The OID also proposes to provide approximately $200,000 for further habitat restoration work at the Ochoco Preserve. This is a 185-acre property acquired by the Deschutes Land Trust in 2017 that includes about 0.9 miles of Crooked River riparian habitat and is located between the Ochoco and McKay Creek confluences with the Crooked River. While OID has not proposed any specific restoration action, this is a significant contribution and can be matched with other funds to complete meaningful restoration in the Crooked River and Ochoco and McKay Creeks.
Total Dissolved Gas: The OID proposes to include in its hydropower plant design a method to reduce total dissolved gas (TDG). Several studies have shown that the Oregon state standard for TDG of 110 percent saturation is exceeded starting at flows of 600 cubic feet per second (cfs), and have been observed to be as high as 122 percent saturation at flows of 1,500 cfs and above. This condition can persist for several miles downstream of Bowman Dam and there is no meaningful way for resident and anadromous fish species to escape supersaturation except to move miles downstream. The ODFW has observed gas bubble disease in resident fish species after high flow events.
We appreciate that ODFW cannot consider this measure in its net benefit analysis since meeting Oregon water quality standards would be a normal requirement under the state’s Clean Water Act section 401 certification. Moreover, OID’s ability to reduce TDG through the hydropower plant is qualitative as no design has been developed. Nevertheless, the problem is a creation of the dam and the proposed hydropower plant could help lessen the impact of TDG. The opportunity to reduce TGD may not be realized should the project be abandoned.
Flow Control
The existing flow release gates are manually operated which requires OID staff to make a 40- mile roundtrip from Prineville to make flow adjustments every time irrigation water is called for
3 and again when it is called to be turned down or off. These roundtrips are also made when releases of uncontracted fish and wildlife water are increased and again when reduced. Furthermore, changes to release volumes can only occur in large increments precluding the ability to ramp flows up or down at a rate that is protective of both resident and anadromous fish species.
The proposed hydropower plant is expected to eliminate these problems by automating the gates and providing the means for fine-scale adjustments to the flow rate. This would be protective of fish that seek cover in off channel habitat or rear along the edges of the river.
Habitat above Bowman Dam
ODFW estimates that upstream passage at Bowman Dam would provide access to about 63 miles of steelhead and 53 miles of spring-run Chinook salmon habitat. A recent evaluation1 of anadromous fish habitat above Bowman Dam was conducted using Oregon’s Aquatic Inventory Project (AIP) and HabRate. This study assessed quality of potential habitat for steelhead and spring-run Chinook salmon.
HabRate predicted that 81.1 percent (43.5 miles) of streams with steelhead spawn-to-emergence habitat is in poor condition, 11.3 percent (5.6 miles) is in fair condition, and just 0.6 percent (0.3 miles) is in good condition. Likewise, spawn-to-emergence habitat spring-run Chinook salmon was predicted to be poor in 81.1 percent (43.5 miles), fair in 10.6 percent (5.2 miles) and good in only 1.4 percent (0.7 miles). HabRate did predict that habitat for juvenile rearing was good to fair for steelhead and spring-run Chinook salmon. The authors noted that HabRate could only be applied in areas where AIP data were available and that those data were collected between 1993 and 2003. Habitat restoration work has occurred in the upper basin since the AIP data were collected.
While ODFW notes that there are many miles of stream above Bowman Dam, most of the good quality habitat may be upstream of natural barriers. Also, the Crooked River above Bowman Dam experiences extreme low flow during the summer and fall.
Fish Passage
The OID evaluated several fish passage concepts and estimated costs for both upstream and downstream passage at Bowman Dam.2 We will not repeat the concepts evaluated in this study but it concluded that upstream passage, either with a ladder or trap and haul facility, could be achieved at a cost of 2 to 5 million dollars. Six concepts were considered for downstream passage and estimated costs ran from $50 million to $120 million. A 3-megawatt project cannot support these costs.
1 Assessment of native migratory fish habitat in the upper Crooked River basin. Mt. Hood Environmental technical report. March 11, 2020. 2 Fish passage feasibility assessment, Bowman Dam Hydroelectric Project (FERC No. 14791). R2 Resource Consultants, Inc. April 2020.
4
We believe that the proposed Bowman Dam Hydroelectric Project does provide needed measures to support the ongoing reintroduction of steelhead and spring-run Chinook salmon. We are concerned that OID would have no choice but to abandon the project if passage is required and that the proposed measures would never be achieved. We do support further discussion between OID and ODFW to reach an agreement on conservation measures.
Thank you for the opportunity to review and comment on ODFW’s net benefit analysis. Should you have any questions, please contact Scott Carlon at (503) 231-2379 or by email ([email protected]).
Sincerely,
F. Dale Bambrick, Chief Columbia Basin Branch Interior Columbia Basin Office
cc: Ken Homolka – ODFW, Salem Peter Lickwar – USFWS, Bend
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Bend Field Office 63095 Deschutes Market Road Bend, Oregon 97701 Phone: (541) 383-7146 FAX: (541) 383-7638
Reply To: 7455.015 File Name: Bowman Dam OID Passage Waiver TS Number: 20-431 TAILS: 13420-2010-CPA-0614
June 22, 2020
Mr. Ted Wise 61374 Parrell Road Bend, Oregon 97702
Dear Mr. Wise:
The Fish and Wildlife Service (Service) has reviewed the Oregon Department of Fish and Wildlife’s (ODFW) June 1, 2020, letter regarding the Ochoco Irrigation District’s (OID) proposed Bowman Dam Hydro Project. On May 1, 2020, the OID applied for a fish passage waiver from the ODFW in order to proceed with their proposed hydro project. The ODFW has recommended denying OID’s request for a waiver based on their determination that the OID’s proposed in-lieu of fish passage measures do not provide a net benefit to native migratory fish (NMF).
The Service supports the ODFW’s efforts to improve fish passage at dams which are receiving retro-fitted hydropower facilities. Based on recent discussions with the ODFW it is our understanding that there may still be a path forward that meets the State’s mitigation requirement and is also acceptable to the OID. We encourage the ODFW and OID to work together to reach an agreement that will allow the proposed project to proceed. We believe that the OID’s proposed hydro provides several important conservation benefits, which are discussed below.
1. OID's proposed mitigation will provide conservation benefits to the Crooked River and its tributaries
The OID’s waiver application proposed several mitigation measures, including reductions to Total Dissolved Gas (TDG), gravel augmentation, a $90,000 contribution to fish passage on Ochoco Creek, and a $200,000 contribution to the Ochoco Creek Preserve. The adverse effects of high TDG levels to NMF in the Crooked River have been a concern for a number of years. The BOR’s September, 2018, “Arthur R. Bowman Dam Total Dissolved Gas Literature Review and Analysis” assessed the possible benefits of a hydropower facility in reducing TDG. While it
INTERIOR REGION 9 COLUMBIA–PACIFIC NORTHWEST
Idaho, Montana*, Oregon*, Washington *PARTIAL
2 did not provide quantitative information regarding possible TDG reduction, its qualitative conclusion was that the proposed hydro facility should reduce TDG levels below the dam. This reduction will come from passing a portion of Bowman Dam’s releases through the proposed hydro project turbine, and from OID’s proposed replacement of the dam’s existing outlet works with Howell Bunger bypass valves. The report also suggested that TDG could be further reduced by constructing flow deflectors to reduce the plunge depth of flow releases.
However, ODFW denied the hydro project’s TDG benefits because the fish passage waiver net benefit analysis cannot include any activity that is already a requirement of another permit or process. In this case, TDG reduction is already required for the proposed project by the ODEQ to meet state 401 water quality certification. The Service notes that the dam’s TDG issues are entirely the result of the BOR’s flow releases at the dam.
2. OID's proposed automation and improvements to Bowman Dam's flow release controls will provide improved ramping rates and overall flow management
The dam’s existing flow release mechanism uses manual controls that are nearly sixty years old. This reduces the dam operator’s ability to manage and adjust flow releases from contracted irrigation storage, uncontracted fish and wildlife storage, and to respond to rapid seasonal increases in inflow to Prineville Reservoir. The existing controls do not permit dam operators to make smaller scale adjustments to flow releases, and thus to implement ramping rate adjustments that would help protect native fish species. It is also difficult to make timely adjustments to flow releases, since OID staff must make a 40-mile, one-hour-long round trip from Prineville to adjust flows.
3. The proposed project will not impede or adversely affect any future upstream or downstream fish passage facilities.
Other parties will still be able to pursue fish passage at Bowman Dam if OID constructs their hydro project. Also, there are no other parties competing with OID for the right to construct hydro facilities at the dam. It appears to the Service that all parties would benefit from the proposed project if an agreement can be reached that meets the ODFW’s mitigation requirements.
The Service believes that the proposed Bowman Dam hydro project will provide significant and needed measures to protect native fish species, including redband trout, steelhead, spring chinook, and bull trout. We strongly support the ODFW and OID’s continued efforts to reach an agreement which both parties find acceptable. Please contact Peter Lickwar on my staff at 541- 382-6146 if you have any questions or would like to discuss this issue.
Sincerely,
Bridget Moran Field Supervisor
3 cc: Mr. Scott Carlon, NOAA Fisheries Mr. Mike Harrington, Oregon Department of Fish and Wildlife Mr. Peter Lickwar, U.S. Fish and Wildlife Service
Lisa Kingsley
From: Dalton Miller-Jones
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
Central Oregon Basin Study Work Group that includes over 40 water resources stake holders,the Deschutes River Alliance, the Coalition for the Deschutes, along with the recreational and sport fishing organizations are ALL OPPOSED to waiving the fish passage requirements at the Bowman Dam. The Fish passage requirement was an integral part of earlier efforts to conserve both water and fisheries in the Crooked River.
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration. Dalton Miller‐Jones 54914 Tamarack Rd Bend, OR 97707 Respectfully Submitted,
Sincerely, Dalton Miller‐Jones 54914 Tamarack Rd Bend, OR 97707
12 Lisa Kingsley
From: Judith Li
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I am aware that the Bowman Dam is the highest priority fish passage barrier in the Deschutes watershed. Therefore, your decision on this waiver application is critical for protecting the remarkable migratory fish in this basin.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Judith Li 1228 nw Overlook Corvallis, OR 97330
13 Lisa Kingsley
From: Nancy Nichols
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
My thanks go out to ODFW for its work to ensuring that Oregon’s fish passage laws are upheld for the Crooked River.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application did not provide sufficient mitigation to warrant waiver of Oregon’s fish passage requirements. With 500 miles of upstream fish habitat blocked, 4 miles of habitat improvement is a drop in the bucket as mitigation.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
Please deny Ochoco Irrigation District’s fish passage waiver request.
Thank you for your consideration.
Sincerely, Nancy Nichols 93849 Deadwood Creek Rd Deadwood, OR 97430
14 Lisa Kingsley
From: Corinne Sherton
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
It's past time that fish passage to the upstream reaches of the North and South Forks of the Crooked River and Beaver Creek be restored. I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Corinne Sherton 2213 Thrush Ct SE Salem, OR 97306
15 Lisa Kingsley
From: Delores Porch
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I thank ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Delores Porch 1212 34TH AVE SE, Apt 63 Albany, OR 97322
16 Lisa Kingsley
From: June Mohler Mitman
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
This is especially important to me, because some of my family live near the Crooked River, and we often enjoy hikes and visits nearby. We want to see that salmon, other native fish and freshwater invertebrates have a better chance to return to their historic habitats. Dams should not be built without provisions to allow native fish to continue to freely access to their upstream habitats.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, June Mohler Mitman 1000 SE Bay Blvd. No. 248 Newport, OR 97365
17 Lisa Kingsley
From: Walt Mintkeski
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I am greatful to ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application (which offered less than 4 miles of habitat improvement) did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements. Those requirements, which I strongly support, would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied, and I request that you deny Ochoco Irrigation District’s fish passage waiver request.
Thank you for this opportunity to comment.
Sincerely, Walt Mintkeski 6815 SE 31st Ave Portland, OR 97202
18 Lisa Kingsley
From: E. William Laing
Dear Oregon Fish and Wildlife Commission,
TO: Oregon Fish and Wildlife Commission Please uphold Oregon’s fish passage laws to insure the health of the Crooked river. I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage. I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied. I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you. Thank you for your consideration. E. William Laing Email: [email protected]
Sincerely, E. William Laing 1552 River Loop 1 Eugene, OR 97404
19 Lisa Kingsley
From: Donna Steadman
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
The laws regulating fish ladders were put in place for a very good reason. I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration.
Sincerely, Donna Steadman 7770 SW Kingfisher Way Portland, OR 97224
22 Supplemental Public Correspondence Received as of October 7, 2020
Exhibit C
Subject: Fish Passage Waiver for Ochoco Irrigation District’s Proposed Hydroelectric Project on Bowman Dam, Crooked River. (Attached) 67 individuals submitted the attached comment.(List Attached) Lisa Kingsley
From: David Row
Dear Oregon Fish and Wildlife Commission,
Dear Oregon Fish and Wildlife Commission:
I would like to relay four points in the above referenced matter:
I applaud ODFW for its commitment to ensuring that Oregon’s fish passage laws are upheld, and that the health of the Crooked River is advanced.
I support ODFW’s determination that Ochoco Irrigation District’s fish passage waiver application that offered less than 4 miles of habitat improvement did not provide enough mitigation to warrant the waiver of Oregon’s fish passage requirements that would open up 500 miles of upstream fish passage.
I support the Fish Passage Task Force’s recommendation that the fish passage waiver be denied.
I respectfully request that you deny Ochoco Irrigation District’s fish passage waiver request that is before you.
Thank you for your consideration and hard work on this!
Sincerely, David Row 6136 N. Superior St. Portland, OR 97203
1 FROM SUBJECT RECEIVED SIZE C... MENTION Date: Monday David Row Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 11:34 AM 19 KB Dear Oregon Fish and Wildlife Commission, Meghan Planchon Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 12:29 PM 19 KB Dear Oregon Fish and Wildlife Commission, Meghan Planchon Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 12:29 PM 19 KB Dear Oregon Fish and Wildlife Commission, Neil Brandt Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:05 PM 19 KB Dear Oregon Fish and Wildlife Commission, Neil Brandt Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:19 PM 20 KB Dear Oregon Fish and Wildlife Commission, Katherine Goeddel Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:30 PM 19 KB Dear Oregon Fish and Wildlife Commission, Eileen Sherry Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:32 PM 20 KB Dear Oregon Fish and Wildlife Commission, Jeff Pokorny Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:35 PM 20 KB Dear Oregon Fish and Wildlife Commission, Dan Robinhold Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:39 PM 19 KB Dear Oregon Fish and Wildlife Commission, michael mcavoy Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:41 PM 19 KB Dear Oregon Fish and Wildlife Commission, John Borden Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:44 PM 20 KB Dear Oregon Fish and Wildlife Commission, Bruce Anderson Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:47 PM 20 KB Dear Oregon Fish and Wildlife Commission, Phil Fulton Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:48 PM 19 KB Dear Oregon Fish and Wildlife Commission, Christopher Pond Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:53 PM 20 KB Dear Oregon Fish and Wildlife Commission, Kyan Bartel Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:55 PM 20 KB Dear Oregon Fish and Wildlife Commission, Marilyn Stinnett Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 1:59 PM 20 KB Dear Oregon Fish and Wildlife Commission, Sherry Brainerd Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:05 PM 20 KB Dear Oregon Fish and Wildlife Commission, Gloria and Bob Ziller Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:21 PM 19 KB Dear Oregon Fish and Wildlife Commission, Mike Brinkley Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:21 PM 19 KB Dear Oregon Fish and Wildlife Commission, Ruel Brumitt Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:23 PM 19 KB Dear Oregon Fish and Wildlife Commission, Marc Peters Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:28 PM 19 KB Dear Oregon Fish and Wildlife Commission, Mike Sawyer Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:32 PM 19 KB Dear Oregon Fish and Wildlife Commission, Don McCartney Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:35 PM 18 KB Dear Oregon Fish and Wildlife Commission, JOHN Holing Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:36 PM 18 KB Dear Oregon Fish and Wildlife Commission, Jane McCleery Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:37 PM 20 KB Dear Oregon Fish and Wildlife Commission, Fred Pendergast Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:40 PM 20 KB Dear Oregon Fish and Wildlife Commission, John Frewing Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:48 PM 19 KB Dear Oregon Fish and Wildlife Commission, Gerald Honl Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:52 PM 19 KB Dear Oregon Fish and Wildlife Commission,
Lisa Kingsley 1 10/7/2020 1:41 PM FROM SUBJECT RECEIVED SIZE C... MENTION Jeff Scroggin Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:57 PM 19 KB Dear Oregon Fish and Wildlife Commission, Sara Pokorny Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 2:58 PM 19 KB Dear Oregon Fish and Wildlife Commission, Edward House Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:08 PM 19 KB Dear Oregon Fish and Wildlife Commission, Gerald Brown Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:12 PM 19 KB Dear Oregon Fish and Wildlife Commission, Lawrence Nagel Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:26 PM 19 KB Dear Oregon Fish and Wildlife Commission, David Thomas Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:32 PM 19 KB Dear Oregon Fish and Wildlife Commission, Jacalyn Kreitzer Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:35 PM 19 KB Dear Oregon Fish and Wildlife Commission, Marilyn Berling Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:35 PM 19 KB Dear Oregon Fish and Wildlife Commission, Paul Martinsen Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:40 PM 19 KB Dear Oregon Fish and Wildlife Commission, Steve Sheehy Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 3:59 PM 19 KB Dear Oregon Fish and Wildlife Commission, Glenn Short Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 4:33 PM 19 KB Dear Oregon Fish and Wildlife Commission, Jeffrey Evershed Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 4:37 PM 19 KB Dear Oregon Fish and Wildlife Commission, Lyn Bonyhadi Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 4:45 PM 19 KB Dear Oregon Fish and Wildlife Commission, Wendy Holzman Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:11 PM 19 KB Dear Oregon Fish and Wildlife Commission, Lee and Marilyn Re... Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:14 PM 19 KB Dear Oregon Fish and Wildlife Commission, John Hamilton Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:17 PM 19 KB Dear Oregon Fish and Wildlife Commission, Mark Davis Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:44 PM 19 KB Dear Oregon Fish and Wildlife Commission, James Cox Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:55 PM 19 KB Dear Oregon Fish and Wildlife Commission, Joel Ophoff Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 5:56 PM 19 KB Dear Oregon Fish and Wildlife Commission, stan chesshir Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 6:14 PM 17 KB Dear Oregon Fish and Wildlife Commission, Mitchell Harris Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 6:46 PM 19 KB Dear Oregon Fish and Wildlife Commission, Stephen Goetz Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 7:05 PM 19 KB Dear Oregon Fish and Wildlife Commission, Seth Isenberg Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 8:17 PM 19 KB Dear Oregon Fish and Wildlife Commission, jim miller Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 8:34 PM 18 KB Dear Oregon Fish and Wildlife Commission, Kevin Quinn Bowman Dam Fish Passage Waiver, Agenda Ite... Mon 10/5/2020 9:51 PM 19 KB Dear Oregon Fish and Wildlife Commission, Date: Yesterday David Andruss Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 6:44 AM 19 KB Dear Oregon Fish and Wildlife Commission, Marianne Nelson Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 7:27 AM 19 KB Dear Oregon Fish and Wildlife Commission, Sonja Nisson Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 8:00 AM 19 KB Dear Oregon Fish and Wildlife Commission,
Lisa Kingsley 2 10/7/2020 1:41 PM FROM SUBJECT RECEIVED SIZE C... MENTION William Mosser Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 8:03 AM 19 KB Dear Oregon Fish and Wildlife Commission, Jen Matthews Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 8:08 AM 19 KB Dear Oregon Fish and Wildlife Commission, Merry Ann Moore Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 8:10 AM 19 KB Dear Oregon Fish and Wildlife Commission, Bob Bumstead Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 8:54 AM 19 KB Dear Oregon Fish and Wildlife Commission, Bryan Mullaney Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 9:29 AM 19 KB Dear Oregon Fish and Wildlife Commission, Andrew Chione Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 11:40 AM 19 KB Dear Oregon Fish and Wildlife Commission, John Keyser Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 2:20 PM 19 KB Dear Oregon Fish and Wildlife Commission, Paul Riedmiller Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 5:03 PM 19 KB Dear Oregon Fish and Wildlife Commission, Colleen Weiler Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 7:30 PM 18 KB Dear Oregon Fish and Wildlife Commission, Karen St Louis Bowman Dam Fish Passage Waiver, Agenda Ite... Tue 10/6/2020 10:01 PM 18 KB Dear Oregon Fish and Wildlife Commission, Date: Today Jerrold Martisak Bowman Dam Fish Passage Waiver, Agenda Ite... Wed 10/7/2020 8:52 AM 18 KB Dear Oregon Fish and Wildlife Commission,
Lisa Kingsley 3 10/7/2020 1:41 PM