-.

MEMORANDUM

6* TO: Water Resources Commission WATER n FROM: Director . . RESOURCES ...... DE.PA R,T M E NT ...... , ' :. ' SUBJECT: , , ' . ' ' . .

Water ~esourcesCommission meeting

Recluest for approval of Sandv River scenic waterway flows for Diack findings

Background-

The Scenic Waterway Flow Assessment was first presented to the Commission at its May 31, 1991 meeting. Clackamas County officials and citizens asked that the Commission delay action on the recommended flows. These parties were concerned that approval of the flows would hinder efforts to resolve water rights issues in the Hoodland corridor. The Commission agreed to delay action until its August 23 meeting, contingent upon development of a work plan by Clackamas County specifying how water rights issues might be resolved. At the August 23, 1991 meeting, Clackamas County presented a work plan and requested additional time to begin implementation. The Commission granted the request and deferred action on the recommended flows until its January 31, 1992 meeting.

Discussion

Since August, staff has met with Clackamas County officials, interested citizens, and basin water purveyors. Staff compiled water rights information and matched it to county assessor maps. This information was provided to.. the County. The County and interested citizens, with assistance from the Department as needed, continue to work on water supply solutions in the basin. However, no additional information on scenic waterway flows for the Sandy River has been submitted to the Department since the August meeting. Staff believes the flow recommendations as presented in the May assessment represent the best information available on flows which would support scenic waterway values. Because the Commission has previously received and reviewed the assessment, it is not attached to this report.

3850 Portlancl Rd NE Salem, OR 97310 (503) 378-373') FAX (503) 378-S1.30 WRC Agenda Item I January 31,1992 Page 2

In summary, for each scenic waterway reach, the assessment identifies a range of flows which support current recreational uses and fish and wildlife habitat.

.... . ,Str.eamflows, fish needs, recreation. flows. and recommended scenic waterway

' flows are displayed in Attachment 1. The recommended flows on the Sandy, . . Scenic Waterway section exceed the average monthly flows in June, July, August and September. It will be difficult for the Commission to make findings to allow additional use when flows are usually less than the levels identified to protect scenic waterway uses.

Summation

The Commission has provided eight additional months for concerned parties to develop or identify better information on flows that would support scenic waterway values in the Sandy River. No better additional information has been identified. Staff has recommended flows that will support recreation, fish and wildlife in the Sandy River Scenic Waterway. Maintenance of these flows affords a substantial level of protection to scenic waterway values. Use of these flow levels for Diack findings may affect the nature and extent of future water uses and development in some areas of the basin. Approving use of identified flows will allow the Commission to make decisions regarding pending applications and future water rights. Identification of these flows may be a first step in finding alternatives to meet water supply needs of the area.

Director's Recommendations

Staff recommends that the Commission approve the Sandy River Scenic Waterway Flow Assessment and the use of the recommended scenic waterway flows in Attachment 1 for making findings on water rights applications pursuant to the Diack decision.

Attachments:

1) Flow Table for Sandy River Scenic Waterway

Rick Bastasch 378-8455, ex 238 January 17,1992 Attachment 1

Flow Data for the Sandy River State Scenic Waterway t, Mean Monthly Flow (cfs)

Average Average Flow for Dodge - Wa~erResource Recommended Natural Flow' FishJ Dabney Commission Scenic Waleway Flow1 Boa~ingFlow Findings' Flows Range4

January 3335 3098 1900 1200-3000 1900 1900

February 3379 3028 1900 1200-3000 1900 1900

h4arch 2714 294 1 2000 1200-3000 2000 2000

April 3455 3535 2000 1200-3000 2000 2000 - - - 3254 2873 2000 1200-3000 2000

June 1914 1636 1400 June 1-15 I500 1200-3000

Jelly 952 779 8001400 700 + Not addressed - - - - Augu.\t 606 499 400 550-650 Not addressed 550 II I I I I I 550-650 I Not addressed 1 550 Oc~obsr 83 2 97 1 650 700 + Not addressed 700

Novclnbcr 2567 3088 1500 ' 1200-3000 1500 1700

'~vera~eNatural Flow is calculated by the WRD in the Water Availnbilty Study

7' -The average flow is the 50 percent exceedance mean monthly flow value as estimated by Water Resources Dept. Tliesr: flows take stream regulation into account.

3~ish!lows Dec-May based on habitat study conducted by BEAK Consultants,l985. June-Nov flows recolnlnended by ODFW.

4~oatingflow ranges identified in WKCC, 1988, River Tours by Carren, and by river experts.

'water Raourccs Colnmission findings for the City 01. Portland hydroelectric permit a,>~~lica~ion MEMORANDUM s)

bTO Water Resources Commission WATER FROM: Director RESOURCES SUBJECT: Agenda Item J, May 31,1991 DEPARTMENT Water Resources Commission meeting -forval of Clackamas and Sandv River scenic waterwav flows for Dlack findin~g

The Clackamas and Sandy Scenic Waterway Assessment is the fourth in a series of reports on st~earnfIowsthat support recreation, fish and wildlife uses in state scenic waterways. The Commission has identified flows for scenic waterway purposes in the Deschutes, John Day and Klamath River basins. Flows supporting current recreation, fish and wildlife uses on the Clackamas and Sandy River Scenic Waterways are shown in Attachment 1. The Scenic Waterway flow assessment report is Attachment 2. The Commission has directed staff to hold public meetings in basins affected by scenic waterway flow assessments. Staff held a public workshop on April 16, 199 1 in Oregon City. The Depamnent also sponsored an interagency briefing to review the assessment process . and discuss any issues and concerns. Representatives of the U.S. Forest Service, Bureau of Land Management, State Parks and Recreation Department. Oregon Department of Fish and Wildlife, Clackmas County, and Portland Water Bureau attended. Other agency h~ interest was high because pan of the Clackamas Scenic Waterway and the entire Sandy Scenic Waterway are also designated national wild and scenic rivers. The National Forest and the Salem District of the Bureau of Land Management are formulating management plans for the national wild and scenic rivers. Agency and public comments were used in developing the assessment. Fish. recreation, and recommended scenic waterway flow figures were revised based on additional information obtained since the draft was dismbuted. An analysis of public comments can be found in Attachment 3. Written comments comprise Attachment 4. There are many issues dealing with the Sandy River that are related to the Scenic Wa~erway.Clackamas County estimates many of the 7,500 residents in the Hoodland corridor operae without benefit of water rights or outside terms of permits. The County also projects the area's population may soon grow to 20,000. The County and residents are very concerned that actions taken by the Commission may preclude citizens from obtaining water rights for existing uses and may adversely affect future economic development. Their concern has resulted in two initiatives to address water supply questions in the basin. First, Hoodland area residents have submitted a petition to amend the Sandy Basin Program (presented to the Commission as Agenda Item K). Second, House Joint Resolution 6 1 has been introduced which would create a Hoodland Area Water Supply Task Force. The task force would include representatives from the County, the Depamnent, the Health Division, special districts and citizen planning organizations who would attempt to identify options for meeting the area's water supply needs. In addition, there is also a bill under consideration (HB 2677) which would allow outright domestic and livestock uses in and upstream from scenic waterways. WRC Agenda Item J May 31. 1991 Page 2 Discussion In accordance with the Diack decision, before issuing new water rights, the Commission must find that recreation, fish and wildlife uses in downstream scenic waterways will not be impaired. The assessment provides information on flow ranges that suppon scenic waterway uses and values. This information is intended to assist the Commission in making Diack findings. There are 14 groundwater, 7 reservoir, and 9 surface water use applications in the two basins. These have been held in abeyance pending determination of scenic waterway flows. The Oregon Department of Fish and Wildlife has also applied for 20 instream water rights in the two basins. The flows for recreation, fish and wildlife in the two scenic waterways vary by use and season. The major flowdependent uses are recreation and fisheries. Flows supporting existing levels of recreation were identified through literature review and interviews with expens. Flows identified for fish life were taken from Oregon Department of Fish and Wildlife studies, consultants, established instream water rights, or instream water right applications. Evaluation a) Public Comment

The public was concerned about a number of issues. Major issues included whether or not . the process represented rule-making, data adequacy, propriety of flow identification methodology. compatibility with county land use plans, the effect of unexercised water rights on scenic waterway flows, and impacts of scenic waterway flow protection on illegal users and future development. These and other comments are addressed in Attachment 3. b) Scenic Waterway Flows In general, for each scenic waterway section, the assessment identifies a range of flows which support current recreational uses and fish and wildlife habitat. Sueamflows, fish needs, recreation flow and recommended scenic waterway flows are &splayed in Attachment 1.

Average monthly flows are greater than recommended scenic waterway flows in the upper mainstem and the South Fork sections of the Clackamas River Scenic Waterway. On the lower Clackamas, the average monthly flows are greater than recommended flows all months but August, when the recommended flow is the average. The recommended flows on the Sandy Scenic Waterway section exceed the average monthly flows in June, July, August and September. It will be difficult for the Commission to make appropriate findings when flows are usually less than the levels identified to protect scenic waterway uses. No scenic waterway flows have been identified for the North Fork Clackamas River because no information was available on flows for recreation, fish and wildlife. Until information is available, it will be difficult to make any Diack findings, and therefore issue water rights, in this subbasin. However, because of the remote, forested character of the subbasin, little future water demand is likely. - WRC Agenda Irem J May 31,1991 Page 3

L Staff has identified flows needed to suppon recreation, fish and wildlife in the Clackamas and Sandy River Scenic Waterways. Maintenance of these flows affords a substantial level of protection to scenic waterway values. Use of these flow levels for Diack findings may affect the nature and extent of future water uses and development in some areas of the two basins. Approving use of identified flows will allow the Commission to make decisions regarding pending applications and future water rights. Identification of these flows may be a fust step in finding alternatives to meet water supply needs of the area. Director's Recommendatim Staff recommends that the Commission approve the Clackamas and Sandy Rivers Scenic Waterways Assessment and the use of the recommended scenic waterway flows in Attachment 1 for making fmdings on water rights applications pursuant to the Diack decision. Attachments: 1) Flow Tables for Scenic Waterways 2) Draft Clackamas and Sandy River Scenic Waterway Assessment 3) Public Comment Analysis 4) Written Comments

Bill FujiiIAdarn Sussman 378-8455 ex 286 May 14,1991 Attachment 1 Agenda Item J Page 1 of 7

BIG BOTTOM SECTION Table 1. Olallie Lake (RM 82.5) to The Collawash River (RM 56.8)

Flow Data for the Clackamas River State Scenic Waterway (Gaged flows measured at Big Bottom RM 65.1)

Mean Monthly Flow (cfs)

Avenge Avenge Flow for 7 Miles Above Rcsommcndcd Nrrunl nod Fish' Flow' Boating Flow Rangeb

Jrnury 632 632 240 I Feb~ary

April 620 620 240

June 1-15 360R40 360-1 120

Ocrohcr 192 I 2 92 I 240 I

I~verageNatural Flow is calculated by the WRD in the Water Availabilty Study

2The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department.

'Flows for fish are based on flows needed for fish and aquatic life and fish habitat abovc gage # 2080 at Big Bottom (RM 65.1) as recommended by ODFW. bv 4Boating flow range for this section was identified in WKCC, 1988, and based on readings at Three Lynx 9.3 miles below the run. Three Lynx flows were adjusted by WRD to reflect flows at Big Bottom gage (RM 65.1). Identified season of use is November through June 15. Attachment 1 Agenda Item J Page 2 of 7

COLLA WASH SECTION Table 2. Collawash River (RM 56.8) to Three Lynx (RM 47.5)

Flow data for the Clackamas River Scenic Waterway

Mean monthly flow (cfs)

- -

Avenge Avenge Flow for Collawrrh- Recommended Nr~unl Flod Firh' Thrcc Lynx Scenic Waleway Flow' Boating Flow Flows Range'

January 2953 2953 640 1000-3000 1000

February 2981 298 1 640 1000-3000 1000

March 2329 23 29 640 1000-3000 1000

April 2674 2674 640 1000-3000 1000

May 2740 2740 640 1000-3000 1000

June 1709 1709 640 June 1-15 10001640 1000-3000

July 943 943 400 400

August 781 78 1 400 400

Scplcmher 79 1 79 1 4001640 4001640

Octohcr 1026 1026 640 640

November 2130 2130 640 10003000 1000

December 295 1 295 1 640 1000-3000 1000

'~verageNatural Flow is calculated by the WRD in the Water Availabilty Study

6The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department.

7 Flo~lsfor fish are based on an instream water right.

'Boating flow range identified in WKCC, 1988. Flow values in the guidebook are based on the gage at Three Lynx (RM 47.5). Identified season of use is November through June 15. Attachment 1 Agenda Item J Page 3 of 7 b TIiREE LYNX SECTION Table 3. Three Lynx (RM 47.5) to the North Fork Reservoir.

Flow data for the Clackamas River Scenic Waterway, (Gaged flows measured at Three Lynx, top of reach)

Mean monthly flow (cfs)

Avenge Avenge Flow for Thrre Lynx- Recommended Natunl Flow1* Fish" N.F. Scenic Waterway Flow* Reservoir ROWS bting Flow Range"

Jr nur ry 2953 2953 640 1022-1 1,467 2000

Febma~y 298 1 2981 640 1022-11,467 2000

March 2329 23 29 640 1022-11.467 2000

April 2674 2674 640 1022-11.467 2000

May 2740 2740 640 1022-1 1,467 2000 June 1709 1709 400 750 + 75 0 July 943 943 400 750 + 750

Augus~ 78 1 78 1 400 750+ 750

September 79 1 79 1 4001640 750 + 750

October 1026 1026 640 750 + 750

November 2130 2130 640 1022-1 1.467 2000

Deccmher 295 1 295 1 640 1022- 1 1.467 2000

9A~e~ageNatural Flow is calculated by the WRD in the Water Availabilty Study

'The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department.

"Flows for fish are based on an insrream water right. b 12Boatingflow range identified in Willametre Kayak and Canoe Club (WKCC), 1988 and the "Clackamas River Whitewater Srudy" (Shelby er. a1.,1988). Flow values are based on the gage at Three Lynx (RM 47.5). Identified season of use is year round. Attachment 1 Agenda Item J Page 4 of 7

LOWER CLACKAMAS SECTION Table 4. River Mill Dam (RM 23.3) to Carver (RM 8).

Flow Data for the Clackamas River State Scenic Waterway (Gaged flows measured 0.2 miles below River Mill Dam).

Mean Monthly Flow (cfs)

Avenge Avenge Flow for Mclver- Recommended Nalunl low" Rch" CIlver Scenic Flow" Boating Flow Waterway Range" Flows

January 4237 4403 800 850-3 190 loo0

February 4324 4110 800 850-3 190 loo0

March 3246 3297 800 850-3190 loo0 April 3515 3458 Ern. 850-3 190 lo00

May 3367 3402 800 850-3 190 loo0

June 2078 2058 650 850-3190 loo0

July 1142 1 100 650 890-1 100 loo0

Augur1 92 1 890 650 890-1 100 890

September 943 972 650/800 890-1 I00 890

Octoher 1356 1307 800 1000-3085 loo0

Novemher 3039 298 1 800 1000-3085 loo0

December 4245 4355 800 850-3 190 1000

"Average Natural Flow is calculated by the WRD in the Water Availabilty Study

''The average flow is a 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. These flows take into account regulation activities.

''Flows for fish are based on flows needed for fish and aquatic life and fish habitat, as recommended by ODFW.

I6Boating flow ranges and seasons of use identified by Clackamas County Depuly Jacobs, Sergeant Baker, Stale Marine Board, WKCC 1988, and in Oregon River Tours. Attachment 1 Agenda Item J Page 5 of 7

SOUTH FORK SECTION Table 5. South Fork Clackamas River, RM 4 to confluence with Mainstem RM 0 (34.6)

Mean Monthly Flow (cfs)

Avenge Avenge Flow for Boating Recommended Nahlml Flow" Fishn Row Range Scenic Walcnvay flow8' flown

January 190 190 75 NIAw 75

February 190 190 75 N/A 75

March 140 140 75 NIA 75

"~verageNatural Flow is calculated by the WRD in the Water Availabilty Study

"The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. Flow values were estimated using a ratio of the Roaring River (RM 43.7), a gaged stream, to the South Fork, a non-gaged stream.

'9Flows for fish are based on flows needed for fish and aquatic life and fish habiht as recommended by ODFW.

20N/A signifies that there is no boating use identified on the South Fork Clackamas River. Attachment 1 Agenda Item J Page 6 of 7

NORTIi FORK SECTION Table 6. North Fork Clackamas River, source to North Fork Reservoir RM 0 (31.6).

Mean Monthly Flow (cfs)

Flow data on fish, recreation, and wildlife are not available. Because sufficient flow information does not exist, a scenic waterway flow recommendation cannot be made.

21~verageNatural flow is calculated by the WRD Water Availabiltiy study

22Theaverage flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. Flow values were estimated using a ratio of the Roaring River (RM 43.7), a gaged stream, to the North Fork, a non-gaged river.

23 * signifies that flows needed to support fish and wildlife are not available.

24N/~signifies that there is no boating use identified on the North Fork Clackamas. Attachment I Agenda Item J Page 7 of 7 rable 7. Flow Data for the Sandy River State Scenic Waterway Mean Monthly Flow (cfs)

Avenge Avenge Flow for Dodge - Water Relource Recommended Natunl FloG Flshn Dabncy Commission Scenic Waterway no* bting Flow Finding? Flows R.ngen

lanuy 3335 3098 1900 1200-3000 1900 1900

Feb~ary 3379 3028 1900 1200-3000 1900 1900

March 2714 2941 2000 120-3000 2000 2000

Apnl 3455 3535 2000 1200-3000 2000 2000

May 3254 2873 2000 1200-3000 2000 2000

June 1914 1636 1400 June 1-15 1500 170011500 1200-3000

July 952 779 8001400 700 + Not addressed 800/700

Augus~ 606 499 400 550-650 Nor addressed 550

.Seplember 5 42 478 500 550-650 Not addressed 550 - Oclobcr 832 97 1 650 700 + Not addressed 700 bernbcr 2567 3088 1 500 1200-3000 1 500 1700

Dccember 3704 3376 IS00 l2W-3000 1500 1700 -

2'~vcragc Natural Flow is calculated by the WRD in the Watcr Availabilly Study

26~hcavcrage flow is thc 50 percent cxcdancc mean monthly flow value as estimated by Watcr Resources Dsp! Thcsc flows lakc stream regulation into account

27~~~hflows Dcc-May based on habitat study conducted by BEAK Consulun!s,1985. June-Nov flows rccommcnd~.J by ODFW

b 2h~oatingflow ranges identified in WKCC, 1988, Oregon River Tours by Garrcn, and by rivsr erpcns

"~alcr Resources Comtnission find~ngsfar thc CI!~of Podand hydroclcc!ric pcnni! rppl~ccl!inn ATTACHMENT 2

DRAFT

CLACKAMAS RIVER SCENIC WATERWAY SANDY SCENIC WATERWAY FLOW NEEDS ASSESSMENT

OREGON WATER RESOURCES DEPARTMENT

MAY 31, 1991 SECTION I INTRODUCTION

A) PURPOSE

In 1988, the Oregon State Supreme Court (Diack vs. City of Ponland) ruled that before authorizing a diversion of water from within or above a Scenic Waterway, the Water Resources Commission must find that the requirements of the Scenic Waterways Act are met. The principal requirement is that the free-flowing character of these waters must be maintained in quantities necessary for recreation, fish and wildlife. This report analyzes the instream flow requirements for scenic watenvay values within the Clackarnas River Scenic Watenvay and the Sandy River Scenic Waterway.

This assessment identifies flow requirements to support current scenic waterway uses. Recommended scenic waterway flows, if approved, will be utilized by the Water Resources Commission to make findings on future and pending water permit applications within or above the scenic watenvay. Additional water pennits may be granted if findings can be made that additional water use would maintain flows in quantities necessary for recreation, fish, and wildlife. Any water permit application would, however, be subject to all other regulations and statutory limitations.

Section Description Date and Method of Designation Lower Clackarnas River Mill Dam to Carver 1975 Legislature

Upper Clackamas Ollalie Lake Scenic Area to North 1988 initiative Fork Reservoir

North Fork Clackamas River Headwaters to North Fork 1988 initiative Reservoir

South Fork Clackamas hver River mile 4 to Confluence with 1988 initiative Mainstem Clackamas

Sandy River Dodge Park to Dabney Park 1973 Governor's designation Inrroducrion 5-3 1-9 1

B) METHOD FOR IDENTIFYING SCENIC WATERWAY FLOW REQUIREMENTS

1) RECREATION The method used to determine the quantity of water for recreation is based on current activities and uses. Recreational use of the scenic waterways was broken down into flow-dependent and flow- related uses. Flowdependent activities must have a certain volume andlor velocity to occur and may cease when there is too much or too little flow. Examples of this type of activity include boating, angling, and swimming. Flow-related activities are those that are enhanced by the presence of water but could occur without a specific flow such as camping, hiking sightseeing, and picnicking. This assessment focuses on flow dependent activities. Angling, aesthetic needs, swimming, and wading are assumed to be met by fish habitat flows.

Descriptions of recreation and flow needs found in agency reports, guidebooks and through interviews with river experts, river users, and recreation resource specialists were used to determine flow ranges. Major data sources for flow dependent activity needs (boating) were found in the Willamette Kayaking and Canoe Club's &ggv Sneakers, Ore~onRiver Tours by John Garren, and the "1988 Clackamas River Whitewater Study" (OSU). Extensive background information and identification of flow related uses came from river resource assessments by the Mt. Hood National Forest, and the Salem District of the Bureau of Land Management (BLM). Water Resources Department staff also use comments and information from staff of other agencies, and the general public.

The objective in identifying recreational flows is to preserve the existing range of major recreational uses. Each flow dependent recreational use known to occur in a river reach is identified, along with a flow range in which the use takes place. For each use, when possible, the flow below which a use experience would significantly degrade is identified. For example, the major attraction to the upper mainstem Clackamas fiver is a specific river feature (rapid) utilized mainly by kayakers known as "Bob's Hole." Through interviews with river experts, it was determined that flows below 2000 cfs at this feature would "significantly degrade" the Class 111-IV boating experience currently available during its season of use. If there is no documentation on when degradation would begin, the customary flow level at which the activity now occurs is'used.

These point-of-degradation flow levels for major uses within a reach are then compared. The highest flow of the most sensitive use is selected to represent the recommended average recreation flow for the month. This flow not only preserves the most flow sensitive of the major uses, but assures protection of other uses as well. In some cases, opportunistic, or specialized uses which depend on infrequent flow conditions may not be protected. However, flows for such activities would be available as peak flows under the average protected for other uses. bv2) FISH AND WILDLIFE HABITAT In most cases, values provided by the Oregon Department of Fish and Wildlife (ODFW) are used for fish and wildlife flows. Generally, this is the only source for identifying fish habitat needs. Some of the flows are current or proposed instream water rights. Some flows recommended by ODFW for the Clackamas River Scenic Waterway are flows identified in the "Basin Investigation of the Lower Willamette Basin" (Oregon State Game Commission, 1964). Flows in the Clackamas drainage were developed using the Oregon Method, sometimes known as Thompson's Usable Width Method. This method takes into account different fish species, age classes, and life cycles. The flows for the Sandy Scenic Waterway &e based on the Instream Flow Incremental Method (IFIM). This is a multi-transect computer model of fish habitat needs based on the physical habitat system. This method was developed by the U.S. Fish and Wildlife Service. ODFW maintains that fish habitat flows are sufficient to provide for wildlife needs within the scenic waterways.

3) RECOMMENDED SCENIC WATERWAY FLOWS Fish habitat flows have been recommended by ODFW or determined by specific studies. In most cases, flows needed for wildlife purposes are provided by flows identified for fish habitat. Therefore, identifying a flow that best supports existing recreation is a major focus of the assessment.

Once recreation flows are identified, they are compared to fish flows. The higher of the two is selected as the overall scenic waterway flow. This protects fishlife and current recreation activities. In situations where recreation flow data do not exist, flows necessary to support fish and wildlife will be the recommended scenic waterway flow. If no flow data exist for fish habitat or recreation, no findings can be made to recommended scenic waterway flows. DRAFT SANDY AND CLACKAMAS RIVER STATE SCENIC WATERWAY FLOW ASSESSMENT

CLACKAMAS RIVER

Introduction The Clackamas River scenic waterway includes four river sections (Figure 1). The upper mainstem runs from the Olallie Lake Scenic Area Boundary to the North Fork Reservoir (47.5 miles), and the lower mainstem section from River Mill Dam to Carver (15.3 miles). The South Fork section starts at river mile 4 (RM 4) and runs to its confluence with the mainstem. The North Fork section runs 12 miles from its source to its confluence with the mainstem at the North Fork Reservoir. The lower mainstem was designated a state scenic waterway in 1975. The upper mainstem, the North Fork, and the South Fork were designated scenic waterways in 1988.

From its headwaters to Big Cliff (RM 34.8), the Clackamas is a national wild and scenic river managed by the Mt. Hood National Forest. This designation overlaps the upper mainstem section of the state scenic waterway.

Environmental Setting/Background The Clackamas River begins at an elevation of 6000 feet near Olallie Butte in the Mt. Hood National Forest. The river flows northwest 83 miles from its source to its confluence with the Willamette River at Gladstone (RM 24). It drains approximately 934 square miles of the northeastern comer of the Willamette Basin, and runs through Clackamas and Marion Counties.

Forested land comprises approximately 85 percent of the basin's land area. Economically, timber is the most important industry in Clackamas County. Agricultural lands make up approximately 12 percent of the Clackamas drainage and are mostly in the lower one-third of the basin. Agriculture is second in economic importance to Clackamas County. Principal crops are berries and tree fruits, field crops, and livestock (ODFW, 1990a).

The river's proximity to urban areas such as Portland, West Linn, Oregon City, and Estacada, and easy access to the river via Highway 224, result in large numbers of river visitors and users.

The river flows through glacial deposits and volcanic rock of the Western Cascade Sequence and the High Cascade Volcanics (USFS, 1990~).The Clackamas is a geologically young river, making occasional channel changes, downcutting, and following a steep gradient. Average gradient is 16.4 feet per mile from the U.S. Forest Service boundary to the Willamette River. Figure 1 Clackamas Basin Scenic waterway,^

I I

- lev Major tributaries of the Clackamas include Clear Creek, Deep Creek, Eagle Creek, Roaring River, Fish Creek, Collawash River, and Oak Grove Fork.

There are three dams on the mainstem: North Fork (RM 30), Casaderio Diversion and Faraday Powerhouse (RM 26), and River Mill (RM 23). Other dams are located on the Oak Grove Fork at Harriet Lake and at Timothy Lake. There are no dams within the scenic waterway segment. All six dams are owned by Portland General Electric.

Section I Upper Mainstem Clackamas River

I) ENVIRONMENTAL SE'ITING

A) LocationIBackground The upper mainstem section of the Clackamas begins on the west slope of the Cascade Mountains between Mount Hood and Mount Jefferson. This 47.5 mile stretch ends at river mile 35 at the North Fork Reservoir. Major tributaries to this section are Collawash River (RM 56.8), Oak Grove Fork (RM 53), Roaring River (RM 43.7), and Fish Creek (RM 41.3). Due to tributary contributions and distinct changes in the character of the river, &he upper mainstem was divided into three subsections for purposes of this assessment: the Big Bottom Section (Olallie Lake Scenic Area Boundary (RM 82.5) to the Collawash River; the Collawash b section (Collawash River to Three Lynx (RM 47.5); and the Three Lynx section (Three Lynx to North Fork Reservoir (RM 23.3) (Figure 1). All three subsections are entirely within the Mount Hood National Forest. The upper mainstem was designated a scenic waterway and a wild and scenic river in 1988. The Parks and Recreation Department have recently proposed an interim river classification of "Scenic River Area" for the entire section due its accessibility by road and its largely undeveloped nature.

B) Topography The Big Bottom and Collawash subsections of the upper mainstem are generally rugged. The river and its tributaries flow along geologic fault lines and are divided from each other by steep ridges. The Big Bottom area (RM 66), an important reach of the mainstem for fish production, is a U-shaped glacial valley.

C) Vegemtion The upper reaches of the upper mainstem are surrounded by true fir and lodgepole pine forests, scattered hardwood and shrub communities, and non-forested meadows. Below approximately 3,500 feet in elevation, Douglas-fir and western hemlock predominate. There are isolated patches of western red cedar associated with moist sites. Hardwood forest patches, dominated by species such as cottonwood, alder, and vine maple occur throughout the drainage.

Two areas within the river corridor have been recognized by the Mt. Hood National Forest as "old-growth viewing areas": the Alder Flat Trail, and the Riverside National Recreation Trail. Corydalis aquae-gelidae, (cold water corydalis) a plant species that is listed as sensitive by the U.S. Forest Service and therefore subject to special management by the Forest Service, and as Upper Mainsrem Clackamas River 5-31-91 a candidate species for federal listing as threatened, has been found along the river and its tributaries (USFS, 1990~).Specific flow needs to support this species are unavailable.

According to a 1990 USFS Resource Assessment of the Clackamas River, Big Bottom (RM 66) is considered to be a unique ecological area. It is an excellent example of the historic plant communities along the river. Old-growth forests and cold water corydalis are found there. This area provides wide habitat diversity, which in turn supports a diversity of plant species (USFS, 1990~).

D) Hydrology The mean monthly minimum, maximum, and average flows for the three subsections of the upper mainstem section of the Clackamas are presented in Tables 1, 2, and 3. The minimum and maximum flows are the lowest and highest mean monthly flows, based on mean daily discharges for the period of record (USGS, 1990). Average flow is the 50 percent exceedance mean monthly streamflow as estimated by the Water Resources Department in the 1991 "Water Availability Study" (WRD, 1991). The percent exceedance is the percent a given mean monthly flow is met or exceeded. For a 50 percent exceedance flow, flows are met or exceeded half the time, or one out of two years.

The highest flow ever recorded for the Big Bottom section (headwaters to the Collawash River) was 11,200 cubic feet per second (cfs), recorded on December 22, 1964. The lowest flow was 184 cfs on September 12, 1942. The highest recorded flow from the Collawash and Three Lynx sections (Collawash River to the North Fork Reservoir) was 68,200 cfs December 22, 1964. The lowest flow was 275 cfs on September 23, 1987 (USGS,1990).

Highest average mean monthly flows for the three sections of the upper mainstem typically occur from December through February with a second peak following the snowmelt in April and May. The highest average flow for the upper section (headwaters to Collawash River) is 687 cfs in May. For the sections below the Collawash River, highest average flows occurs in February at 2981 cfs. Lowest average flows for the Big Bottom section is 261 cfs in September and 781 cfs in August for the two lower sections.

11) RECREATION Due to its proximity to the Portland metropolitan area, the Clackamas River draws large numbers of river visitors annually.

A) Flow Related Activities Flow related recreational activities include: biking, hiking, picnicking, camping, hunting, photography, and scenic viewing. Sightseeing and driving for pleasure are some of the most popular activities in the Clackamas River corridor. Many scenic attractions and river related activities such as whitewater boating are easily observed and photographed from the road (USFS, 1990~). Upper Mainsfem Clackamas River 5-31-91 (r*. - Trails adiacent to the river attract recreationists. The Riverside National Recreation trail, a 4.6 mile traii, and the 7 mile Clackamas River trail run parallel to the upper mainstem Clackamas. Trail termini for the Riverside trail are located in Riverside and Rainbow campgrounds and at Fish Creek and Indian Henry campgrounds for the Clackamas trail. The trails are heavily used throughout the year for hiking and river access. The Riverside trail has been identified by the Forest Service as an old-growth viewing area. No data are available on the intensity of these uses.

Several developed campgrounds and dispersed campsites are located along the river. Developed campgrounds (those with running water and flush toilets) are typically closed from November through May. During the summer months, these campgrounds are full every weekend, and experience a 15 percent occupancy during the week (USFS, 1990a).

B) Flow De~endentActivities Flow dependent activities include swimming, angling, and boating including canoes, kayaks, and rafts.

1) BOATING The Clackamas River contains at least 50 miles of "runnable" whitewater utilized by a wide * range of boaters. Whitewater boating is one of the most rapidly growing recreational activities along the river (Shelby el. al, 1988; USFS, 1990~).According to Forest Service records, the b season of highest use on the upper mainstem is spring (USFS, 1990~).The upper mainstem Clackamas has Class I11 to VI rapids. Given that the upper mainstem has three distinct sections, boating uses, flows, and seasons of use are addressed separately below.

a) BIG BOITOM SECTION-(HEADWATERS TO COLLAWASH) The only boating flow range identified in the upper section (headwaters to Collawash River) was identified in Soggv Sneakers Guide to Oregon Rivers (WKCC,1988). The guide describes a boating run in this section as 7 miles of entertaining Class 111 rapids. Flow ranges for this run, seven miles above the Collawash River to Riverside Campground (RIM 56) just below confluence, are displayed in Table 1. Because the flow values in the guidebook were based on USGS gage #2095 at Three Lynx (9.3 miles below the boating area), Three Lynx flows were adjusted by the Water Resources Department to reflect flows at Big Bottom, USGS gage # 2080 (RM 65.1). This gage is approximately 3 river miles above the boating reach. This stretch of river is narrow and rocky and is normally used by experienced kayakers (WKCC,1988). An additional attraction to this section is Austin Hot Springs located 2.5 miles above the Collawash confluence. The season of use identified in the guidebook for this reach is during the rainy months and snowmelt period (Nov-May). According toThom Powell, Oregon Kayak and Canoe Club Safety Chair and Kayak Instructor who has been using the river for 12 years, this Class I11 section is boatable in winter, spring, and early summer. Powell states that in a typical year, the river can be boated into the first half of June (Thorn Powell, personal communication). Upper Mainstem Clackamas River 5-31-91 b) COLLAWASH SECTION-(COLLAWASH RIVER TO THREE LYNX) From the Collawash River to Three Lynx, the river contains Class IV-VI rapids. This run, characterized by narrow slots and tight turns, is normally run only by experienced kayakers. This run has the most remote character since the highway does not dominate the scenery (USFS, 199Ck). Approximately 5 miles below the Collawash put-in is a mandatory portage (at any flow) around the Class VI "Killer Fang" rapids. A range of flows needed to support boating activities in this section has been identified in the &ggv Sneakers Guide to Oregon Rivers (WKCC, 1988). These flows are displayed in Table 2. The guidebook identifies the season of use as November through May. Thom Powell states that this mostly Class N section is runnable in winter, spring, and early summer (into the first half of June in a typical year) (Thom Powell, personal communication).

C) THREE LYNX SECTION-THREE LYNX TO NORTH FORK RESERVOIR The section between Three Lynx and the North Fork Reservoir contains Class I11 and IV rapids. This section has become one of the most popular day-use whitewater runs in Oregon. Peak use is in April and May (Shelby et. al, 1988). A special attraction of this run is a feature called "Bob's Hole," where an arrangement of rocks creates a series of waves and eddies prized by kayakers wanting to hone their skills (WKCC, 1988). According to Willamette Canoe and Kayak Club President and Director of Benton County Parks, Jerry Davis; Mark Brunson, Project Manager for the 1988 "Clackamas River Whitewater Study;" and Alder Creek Kayak Supply owner Cindy Scherrer Bob's Hole is the "major attraction" to this section of river. All three of these river experts stated that at flows below 2000 cfs Bob's Hole becomes dangerous and discourages most boaters from running it (personal communication, Jerry Davis; Mark Brunson; and Cindy Scherrer). Although boaters are known to float Bob's Hole at flows below 2000 cfs, these river experts felt that this was the flow below which the "Bob's Hole Experience" would be significantly degraded.

Bob's Hole Rodeo and the Northwest Rafting Associations's Whitewater Festival are two events which occur on this section each May. These events draw recreationists from as far away as California and Idaho. The Rodeo features a slalom course for the 50-60 kayakers who participate. Sponsors of the event, the Oregon Canoe and Kayak Club, plan the event so that a flow range of 2000-3000 cfs is available for the event (Thorn Powell, personal communication). Approximately 300 spectators attend the rodeo. The Whitewater festival, sponsored by Northwest Rafters Association, features raft races, food, and information booths.

The range of flows necessary to support boating on this section were identified in The Soggy Sneakers Guide to Oregon Rivers (WKCC, 1988), a study conducted by Oregon State University (OSU) in 1988, and interviews with river experts. Boating flows are displayed in Table 3. The flow identified in &ggv Sneakers (WKCC, 1988) is 750 cfs and above with a year round season of use. This general flow range and year-round season of use reflect the guidebook's attempt to recommend flows for a wide variety of boaters with different expectations and levels of skill.

The study completed by OSU provides information on patterns of use, seasons of use, preferred flows, and types of vessels used for the Three Lynx to North Fork Reservoir section. 'br Upper Mainsrem Clackamas River 5-31-91 A survey sample was obtained by contacting boaters at the most commonly used launch sites on this section on 19 dates between February and July 1988. Those contacted were asked to participate in a mail-out survey. Results from the 309 responses showed that the majority of boating visits to this section are single day trips made on weekends. Although the boating season on the Clackamas peaks during April and May, survey respondents reported using the river during every month of the year. August and September were the least preferred months. Some boaters surveyed reported making as many as 50 trips to the river in a year, and the average number of visits for the 309 boaters surveyed was 6.6. Boating is usually the sole purpose of a Clackamas visit. The study found that rafts are the most popular type of boat, while 40 percent of boaters use a hard shell or inflatable kayak.

Seventyeight percent surveyed said they normally check river flows by reading the daily newspaper or calling the River Forecast Center in Portland. Boaters who normally check on river flows were asked which flows they considered to be the optimum, minimum, and maximum levels for boating. The average optimum flow was 2,958 cfs, the average minimum flow 1,305 cfs, and the average maximum boatable flow was 9,605 cfs, although some boaters said that no flow is too high.

Flow preferences were somewhat related to the type of boat use. Kayakers, who are best able to operate with low or high water, reported the widest range of suitable conditions. They listed an average minimum of 1,022 cfs, an optimum of 2,604 cfs, and a maximum of 11,467 cfs. For respondents who use rafts, the average minimum flow was 1,624 cfs, while the optimum was 3,328 cfs and the maximum was 8,681 cfs.

The study found that not all boaters check the flow prior to visiting the river, and that some are willing to visit the river when flows are below the average minimum acceptable level. Seventeen percent of the respondents boated the Clackamas in July 1988, and 10 percent boated in August, even though flows never averaged more than 930 cfs during those months. This suggests that the composition of the boater population changes during the course of the year. Late season boaters (those who do not prefer to boat earlier than May or later than October) were found to have lower involvement levels in whitewater boating, less boating experience, and preferred a more casual, relaxed experience. Good weather and fishing are important to this group rather than a whitewater experience. The majority of those surveyed were early season boaters (those who do not prefer to boat from June through October). The reason this group did not prefer to boat June through October was due mainly to the fact that optimum boating flows are typically not available. These respondents have a higher commitment to whitewater recreation, are more likely to belong to whitewater clubs, and are likely to rate whitewater boating as their favorite outdoor activity. A third group indicated they would boat in both the early and late seasons.

The range of boating flows displayed in Table 3 takes into account the flows necessary to support the variety of boating uses and seasons identified in WvSneakers, the OSU study, & and interviews with river experts. A flow range of 1022-11,467 cfs November through May reflects the range of flows identified for the "early season" whitewater boaters. It is during this period that river experts identified a flow of 2000 cfs, the flow necessary to support the use of Upper Mainsrem Clackamas River 5-31-91

Bob's Hole (a major river attraction). For June through October, the flow of 750 cfs and above (identified in &gv Sneakers) supports the "late season," casual boaters. No specific data on the intensity of these flow dependent activities are available.

2) ANGLING Due to the diversity of fish species, angling on the upper mainstem Clackamas is a year round activity. Trout season, which generally runs from May 25 through October 31, is probably the time of heaviest angling use. Steelhead angling is open all year. Typically, the upper mainstem is closed to adult salmon angling January 1 to March 31 and August 16 to December 31 (ODFW,1991). According to estimated steelhead catch records, steelhead are caught every month of the year on the upper mainstem. Peak catches occur June through November. Winter steelhead are harvested from December through April. Summer steelhead are harvested in the upper mainstem from March through the following February. Estimated salmon catches average 157 fish with the peak occumng in July (ODFW, 1990a).

3) SWIMMING Swimming has been identified as a flow dependent use, however, no specific data are available on its flow needs or intensity.

111) FISH AND WILDLIFE A) Wildlife The Clackamas River comdor supports numerous wildlife species. Several species of raptors, including osprey, bald eagles (a federally listed threatened species), and the peregrine falcon, (a federally listed endangered species) have been sighted within the comdor. The 1990 Mt. Hood National Forest Final Environmental Impact Statement describes portions of the upper mainstem corridor as "potential bald eagle and peregrine falcon recovery areas." The Northern Spotted Owl, also a threatened species, may nest in the corridor. The river also provides a linkage between spotted owl habitat in other locations, and the comdor is a major dispersal route for juvenile spotted owls. Pi.leated woodpeckers and pine marten are also known to use the river comdor. The red legged frog, a candidate sensitive species, has been located by field reconnaissance in this reach (USFS,1990a).

Most of the Clackamas River comdor is considered critical big game winter range for both and deer. Big Bottom is an important part of this winter range. There is also a population of Roosevelt elk that winter in the Clackamas River Drainage.

B) Fishlife Spring chinook salmon, coho salmon, and steelhead trout use the upper mainstem of the Clackamas for spawning, rearing, and adult holding. Resident cutthroat trout and wild and hatchery origin rainbow trout are also found in the upper mainstem.

Spring chinook runs in the Clackamas consist of both natural and hatchery produced fish. Clackamas Fish Hatchery, located in Mclver State Park (RM 23) is the only hatchery in the sub- basin producing spring chinook. The native spring chinook are one of only two historic runs left in the Willamette Basin. Adult spring chinook migrate through the upper mainsten) between Upper Mainrrem Clackamas River 5-31-91 L May and September. The migration peaks in June, July, and September. Spawning occurs in the upper mainstem from the head of North Fork Reservoir upstream to Big Bottom (RM 64 to RM 68). The fish also spawn in many of the tributaries of the Clackamas River including Cub Creek, Fish Creek, the Collawash River, and Pinhead Creek. Peak downstream migration for the smolts, based on counts over North Fork Dam, occurs April through May and October through November.

Two stocks of coho salmon, distinguished primarily by the timing of the adult run and spawning, occur in the upper mainstem. Early runs are from hatchery stock which migrate in the fall and spawn in October and November. Coho hatchery production has taken place at Eagle Creek National Fish Hatchery (RM 13 on Eagle Creek) since 1957. Late-run coho, which are endemic to the Clackamas, are a genetically unique stock in the Columbia River Basin, and is the last significant population of wild, native coho in the Columbia River system (USFS, 1990a). Late- run coho migrate from December through February, and spawn in February and March. Peak downstream migration of coho salmon occurs in May and June.

Endemic winter steelhead and hatchery produced winter steelhead are both found in the Clackamas River system. The majority of winter steelhead migrate upstream in May. Over the last 30 years, the number of returning winter steelhead has decreased by about 50 percent. - Current run size averages slightly less than 1300 fish (USFS, 1990a).

It is believed that summer s~eelheadare not native to the Clackamas River. Summer steelhead released in the Clackamas sub-basin are reared at Gnat Creek Fish Hatchery. Most summer steelhead pass the North Fork Dam from May to October. The run peaks in June and July and spawning occurs in late fall or winter. The estimated average run of summer steelhead from 1984 to 1987 was about 8,500 fish (ODFW, 1990a).

Endemic cutthroat trout are the primary resident fish in the Clackamas River. Two rainbow trout populations are present: a wild population isolated in various parts of the basin, and a hatchery population which is primarily found in the mainstem. Through a major stocking program run by the State of Oregon, a large number of catch-and-keep fish are released throughout the river (USFS,1990c). Habitat is present in the river for bull trout, although no confirmed information about this species is currently available for the Clackamas River. Bull trout are an endemic species currently listed as a Forest Service, Pacific Northwest Region, sensitive species. They were once found in the Clackamas drainage and there is a high probability that they are still present (Jay Massey, ODFW, personal communication).

The flows needed to support fish in the upper mainstern are displayed in Tables 1, 2, and 3. Flows for the Big Bottom section (headwaters to Collawash) are the flows recommended by thc Oregon Department of Fish and Wildlife (ODFW) (Table 1). These flows are based on the USGS gage #2080 at Big Bottom (RM 65.1) and have been extended to the Collawash River approximately 10 river miles downstream. Fish flows from below the Collawash River to Threc Lynx (Table 2) and Three Lynx to the North Fork Reservoir (Table 3) are based on an instreall water right. ODFW considers these flows to best represent wildlife needs unless otller information becomes available which indicates otherwise. Upper Maimrenl Clackamas River

FLOW DEPENDENT USES AND VALUES THREE LYNX TO NORTH FORK RESERVOIR "THREE LYNX SECTION"

USE FLOW RANGE SEASON OF USE INTENSITY OF (cfs) USE Angling - all year - Drift Boat - - - Canoe 750+ June-Oct - (Class 11) Kayak- 1,022- 11,467 Nov-May - Whi tewater Canoe (Class 111-IV) Kayak 750 + June-Oct (Class 11) Raft 1,624-8,681 Nov-May - (Class 111-IV) Raft 750+ June-Oct - (Class 11) Swimming - May-Oct - Fish & 640 Sept 15-May Wildlife 400 June-Sept 15 I

C) Recommended Scenic Waterway Flows The recommended scenic waterway flows for the Big Bottom section (Olallie Lake to Collawash River) are a combination of fish habitat flows and minimum flows for boating (Table 1). November through June 15 a flow of 360 cfs provides the flows needed to support identified boating activities. This flow also provides approximately 120 cfs above the flows needed to suppon fish and wildlife (240 cfs). From June 15 through October, when boating ceases to be the predominant use, flows for fish recommended by ODFW are the recommended scenic waterway flows. Recommended scenic waterway flows are exceeded by the average flow all months.

For the Collawash section (Collawash River to Three Lynx) recommended scenic waterway flows are a combination of fish habitat flows and minimum flows for boating (Table 2). November through Junc 15, flows of 1000 cfs allows identified boating activities to continue and provide flows above an instream water right to support fish and wildlife habitat. From Junc 15 Upper Mainsrcm Clackamas River b through October, when boating ceases to be the predominant use, the instream water right (fish habitat flow) is the recommended scenic waterway flow. Recommended scenic waterway flows are exceeded by average flows each month.

The recommended scenic waterway flows for the Three Lynx section (Three Lynx to North Fork Reservoir) (Table 3) are flows identified for whitewater boating. These flows provide for the current range of boating activities while also providing flows above the established instream water right. November through May, a flow of 2000 cfs was identified by river experts as the minimum flow for Bob's Hole, a major recreational attraction to the Three Lynx section. A recommended scenic waterway flow of 2000 cfs during these months provides kayakers and rafters the opportunity to experience Class Ill-IV rapids (the major winter time use of the river) and protects lower flows used by novice Class I1 boaters. A flow of 750 cfs and above June through October maintains flows for the late season/casual Class D[ boaters who are the predominant summer-time recreationist. Recommended scenic waterway flows are exceeded by average monthly flows throughout the year. LUpper Maimfern Clackamas River BIG BOTTOM SECTION Table 1. Olallie Lake (RM 82.5) to The Collawash River (RM 56.8)

Flow Data for the Clackamas River State Scenic Waterway (Gaged flows measured at Big Bottom RM 65.1)

Mean Monthly Flow (cfs)

Minimum Maximum Avenge Flow for 7 Miles Above Reeommcnded Flow' Flow Flow'

Boating Flow &nge4

January 245 1450 632

February 250 1240 647

March 33 1 896 510

316 1110 620

1une 243 1170 472 240 June 1-15 3601240 360-1 120

207 488 293 150 150

November 208 976 473

December 225 1510 625

'Minimum and maximum flows are the lowest and highest recorded mean monthly flours measured at gage #2080, Clackamas River at Big Bottom from 1920-1970 (USGS, 1990).

'The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department.

'Flows for fish are based on flows needed for fish and aquatic life and fish habitat above gage # 2080 at Big Bottom (RM 65.1) as recommended by ODFW. These values have been extended to the Collawash River (RM 56.8). \ 4Boating flow range for this section was identified in WKCC, 1988, and based on readings at Three Lynx 9.3 miles below the run. Three Lynx flows were adjusted by WRD to reflcc~ flows at Big Bottom gage (RM 65.1). Identified season of use is November through June 15. Upper Mainstem Clackamas River

COLLAWASI1 SECTION Table 2. Collawash River (RM 56.8) to Three Lynx (RM 47.5)

Flow data for the Clackamas River Scenic Waterway

Mean monthly flow (cfs)

Minimum Maximum Avenge Flow for Collawash- Recommended Flow' Flow Flow' Fish' Thru Lynx Scenic Waterway Boating Flow Flows Range'

January 739 7160 2953 640 1000-3000 lo00

February 734 6210 2981 640 1000-3000 loo0

March 1310 6560 2329 640 1000-3000 loo0

April 1180 4480 2674 640 1000-3000 loo0

May 1070 5550 2740 640 1000-3000 loo0

June 725 4880 1709 640 June 1-15 10001640 1000-3000

July 603 1780 943 400 400

Aug1161 578 987 78 1 400 400

September 577 1240 79 1 4001640 4001640

October 605 2510 1026 640 640

November 5 73 4350 2130 640 1000-3000 loo0

Decernbcr 786 8270 295 1 640 1000-3000 loo0

'Minimum and maximum flows are the lowest and highest recorded mean monthly flows measured at gage #2095, Clackamas River above Three Lynx, 19 12-1987 (USGS, 1990).

The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Deparlment.

'Flows for fish are based on an instream water right.

"eating flow range identified in WKCC, 1988. Flow values in the guidebook are based on the gage at Three Lynx (RM 47.5). Identified season of use is November through June 15. Uppcr Mainrtcn~ Clackamas River 14 TIJREE LYNX SECTION Table 3. Three Lynx (RM 47.5) to the North Fork Reservoir.

Flow data for the Clackamas River Scenic Waterway, (Gaged flows measured at Three Lynx, top of reach)

Mean monthly flow (cfs)

Minimum Mmximum Avenge Flow for Three Lynx- Rccommcnded "OW 1 Flow'o 1 Fish" 1 N.F. I ScenicW~tcway 1 Reservoir Flows Boating Flow RangeU I LJmnum y Fsbnuty

July

11 October 1 605 II Novemher 573 I 4350 2130 1 640 1022- 1 1.467 December 786 1 8270 295 1 I 640 1022- 1 1,467 Zoo0

9Minimum and maximum flows are the lowest and highest recorded mean monthly flows measured at gage #2095, Clackamas River above Three Lynx, 1912-1987 (USGS, 1990).

'?he average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department.

"Flows for fish are based on an instream water right

I2Boating flow range identified in WKCC, 1988 and the "Clackamas River Whitewatcr Study" (Shelby et. a,. ,1988). Flow values are based on the gage at Three Lynx (RM 47.5). Identified season of use is year round. r' * Section I1:Lower Mainstem Clackamas River

I) ENVIRONMENTAL SE'ITING

A) The lower mainstem section of the Clackamas River runs from River Mill Dam (RM 23.3) to Carver (RM 8). Any place on this reach is only an hour drive from Portland. Other nearby urban areas include Estacada, just north of the reach, and Sandy, 7 miles northeast. Major tributaries include Eagle Creek (RM 16.7), Deep Creek (RM 12.2), and Clear Creek (RM 8.2) (Figure 2).

This section of the scenic waterway is classified as a "Recreational River Areawbecause of the semi-developed, rurallpastord nature of the river segment.

B) TODO- This section of the river flows through a broad, large, wooded valley bounded by high benches of forest and farmland and occasional vertical walls of sedimentary gravel deposits.

' ' C) Ve~etation The Clackamas County Comprehensive Plan classifies approximately 70 percent of the lower mainstem river corridor as forest land. The remainder is zoned for agriculture, open space, and residential development. Coniferous species such as Douglas fir, grand fir, western red cedar, C' and white fir dominate. Maple, cottonwood, ash and alder are also widespread. The riverbank has a mixed deciduouslconifer forest cover of moderate height trees (50-80 feet average). The undergrowth is dense brush including scotch broom, blackberry and other similar species (OPRD, 1985).

D) Hvdrology The upper part of the lower mainstem is a swiftly flowing river with large drops and several standing waves. The lower section has frequent minor rapids and, during low flows, well-defined channels containing boulders and low limbs which extend from the banks. The minimum, maximum and average mean monthly flows on the lower mainstem section of the Clackamas are listed in Table 4. The minimum and maximum flows are the lowest and highest mean monthly flows, based on mean daily discharge, for the period of record (1959-1987). Average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department (WRD, 1991).

Flooding occurs annually, usually during winter months. The highest recorded flow 86,900 cfs (USGS gage #2100 at Estacada) occurred in December of 1964 (USGS, 1990).

11) RECREATION Due to its proximity to urban centers, high scenic quality, and abundance of fish, the lower mainstem Clackamas River draws large numbers of river users. Lower Clackamas Section of the Clackamas River Scenic Waterway

- - Lower Mainsrem Clackamas River

I *A) Flow Related Activities Flow related activities include: camping, hiking, picnicking, nature studying, and scenery viewing.

This section of the scenic waterway includes two state and two county parks. Barton County Park and McIver State Park provide camping facilities. Bonnie Lure State Park has no developed facilities and provides only walk-in river access. The community of Carver provides a boating access site, although the parking lot and restrooms serve day user$ who fish, swim, and sunbathe. According to a 1985 report by the State Parks and Recreation Department, annual use at McIver State Park is 144,000 user days and 6,000 camper nights. Annual use at Barton County Park is about 200,000 user days and 8,000 camper nights (OPRD, 1985).

B) Flow Dependent Activities Flow dependent recreational opportunities on the lower mainstem include boating, fishing, and swimming.

1) BOATING Boating uses identified are power boats, canoes, kayaks, innertubes, and rafts. Unlike the upper mainstem, the lower mainstem flows mostly through private land, and public access is limited to a few county and state parks. Major boating facilities (i.e. paved ramps) are located at Barton, Mclver, and Carver parks. wd a) Power Boats Power boats are used for both fishing and sightseeing tours. Jet boats utilize the river from its mouth to about 5 miles below River Mill Dam. Most power boat use occurs during the fishing season. According to Clackamas County Sheriff Deputy Richard Jacobs, who has been patrolling the lower river for 13 years, power boat use typically occurs from the last few days of November (Thanksgiving) until the first week in July. From Thanksgiving (typically the opening of winter steelhead season) through March, jet boats are used in the winter steelhead fishery. March through June, jet boats are used while fishing for spring chinook. According to Deputy Jacobs, between Carver and Barton Park, the most popular power boating area, approximately 100-125 jet boats can be found on the river weekend days. Heavy use occurs on hot, early summer days. In an average year, low water and poor fishing bring an end to the power boating season by the first week in July.

Flows necessary to support power boating were identified by Deputy Jacobs as well as the Oregon State Marine Board. Both sources stated that flows between 1 foot to 3 feet on the Estacada gage, converted to 850 to 3190 cfs by the Water Resources Department, was the optimum range of flows necessary to support power boat activities. Below these flows, most jet boating cannot occur. Both sources agreed that with flows as little as 0.3 feet on the Estacada gage, converted to 570 cfs by the Water Resources Department, these activities could take place, however, only with extreme caution. Some commercial boat rental/shuttle services and guiding services operate on the river. Lolver Maimten1 Clackamas River 5-31-91 b)Non-Power Boats This section of the river contains Class 11+ rapids. Whitewater boating flows and season of use have been identified for this section in the ~gvSo Sneakers Guide to Oreeon Rivers (WKCC, 1988), and Ore~onRiver Tours by John Garren. Sergeant Richard Baker, also a Clackamas County Sheriff who patrols the lower mainstem, and Deputy Jacobs were able to estimate intensity, season of use, and flow needs for flatwater boating.

The flows identified in the &ggv Sneakers guide are based on a gage 0.2 miles below River Mill Dam. The guide recommends a flow of 1000 cfs and aboveto boat this reach. The season of use identified is year round.

Boating flow ranges identified in Oreeon River Tours are for "intermediate or semi-skilled boaters." These flows were based on a gage in Clackamas, 3.2 miles below the scenic waterway, and adjusted by Water Resources Department to reflect measurements at USGS gage #2100 just below River Mill Dam. The adjusted flows were estimated to be approximately 1000- 3085 cfs. Season of use recommended by Garren is October 1 to November 15, and March 15 to July 15.

Non-power boating use, according to Clackamas County Deputy Jacobs and Sergeant Baker, is heaviest from early July through the first half of September. The uses they identified were mainly rafters. However, a small number of drift boats and canoes use the river during the summer. They estimate that, during an average year, there are approximately 200 crafts floating the river on weekdays and over 1000 on weekends. The heaviest concentration of use is between Barton Park and Carver. Although some rapids may still be available for kayakers to "play inn (e.g., "The Minefield" just below McIver Park), the predominant use July through September is flatwater boating. The majority of these boaters are on the river to experience a relaxing float down the river (personal communication, Deputy Jacobs; Sergeant Baker).

Sergeant Baker and Deputy Jacobs were also able to provide information on flows needed to support "flatwater boaters." From their several years experience on the river, both stated that from July until mid-September, the flows that are "typically available" are necessary to support this activity. ~tlowsuch flows, Sergeant Baker stated, "the increased hazard from exposed rocks combined with mandatory portages, the pleasure of floating the lower mainstem would decrease to the point where it would no longer be used." Sergeant Baker pointed out that with lower than average summer flows, sharp river bends east of Carver would require long portages. Further, the "rock garden" below McIver Park would become extremely dangerous or impassable.

Boating flows displayed in Table 4 combine identified boating flow ranges and seasons of use for whitewater boating, flatwater boating, and for power boats from Mclver Park (RM 21.7) to Carver. The flow range of 1 foot to three feet at the Estacada gage (850-3190 cfs as converted by the Water Resources Department) December through June was identified by Deputy Jacobs and the Marine Board. For July through September, the flow range is that necessa'ry to support flatwater boating (the predominant use) as identified by Sergeant Baker and Deputy Jacobs. For this period the flow range is 890-1100 cfs. This range was determined by using the lowest (890 cfs) and highest (1 100 cfs) average summer month flows. The October and Noven~berflow Lower Mainrrern Clackamas River 5-31-91

+kinge come from the flows identified in the two whitewater guides (1000-3085 cfs). The year round season of use is based on information from both guidebooks, Deputy Jacobs, and Sergeant Baker.

2) ANGLING Trout season on the lower mainstem generally runs from the end of May through October. Salmon and steelhead angling are open year-round. Hatchery winter steelhead provide angling opportunities from December through February. Native winter steelhead are harvested March and April. Summer steelhead provide angling opportunities in the lower Clackamas as early as March; the run peaks June and July. Estimated catch numbers for all steelhead show that steelhead are harvested year-round with peaks in December and January. Coho fishing takes place October through December and chinook fishing occurs in spring months. Salmon catches occur throughout the year and, according to ODFW estimated catch records, harvest peaks occur in May (ODFW, 1990a).

A 1985 report by the State Parks and Recreation Department found that approximately 41,800 angler days per year occurred on the lower mainstem Clackamas. Heaviest use occurred from December to May during the steelhead-salmon runs, with the most use on weekends. The study found that bank anglers concentrated around public parks and roadways.

3) SWIMMING Swimming has been identified as a flow dependent use, however, no specific data are available on the intensity or flow needs of this use.

111) FISH AND WILDLIFE A) Wildlife The lower mainstem, because of its abundant vegetation, variety of topography, scattered development, and high water quality, provides excellent habitat for fish and wildlife. Sightings of deer, osprey, great blue heron, ducks, and other wild birds and animals are common (OPRD, 1985).

B) Fishlife Anadromous fish in this reach include winter and summer steelhead, spring and fall chinook, native late-run coho, and hatchery supported coho. Both the spring and fall chinook are known to spawn in the lower mainstem below River Mill Dam. Hatcheries located at Mclver State Park and Eagle Creek support the fishery. Sea run cutthroat and hatchery rainbow trout are also found on the lower mainstem.

Flows to support fish and aquatic life and fish habitat for the lower mainstem have been recommended by the Oregon Department of Fish and Wildlife (ODFW). These flows are displayed in Table 4. Until further information becomes available, ODFW considers these flows to represent wildlife needs. Lower Mainsr em Clackamas River 5-31-9 1

IV) FLOW ANALYSIS A) Data Sources Data for whitewater boating flows and seasons of use come from the &ggv Sneakers guide and Oregon River Tours. Power boating flow data and seasons of use were provided by Clackamas County Sheriff Deputy Richard Jacobs, Sergeant Baker, as well as the Oregon State Marine Board. Deputy Jacobs and Sergeant Baker also identified season of use, flow needs, and intensity of flatwater boating.

Flows for fish and wildlife in the lower mainstem Clackamas River are flows recommended by ODFW to support fish and aquatic life and fish habitat. Lower Mainsfem Clackmar River b~)b-J b~)b-J The following activities and flow ranges summarize the data given above.

FLOW DEPENDENT USES AND VALUES RIVER MILL DAM TO CARVER I. USE FLOW RANGE SEASON OF USE INTENSITY OF (cfs) USE Angling - all year 41,800 angler days (1985) Drift Boat 1000-3085 all year - Canoe 1000+ all year - (WKCC, 1988) I Canoe 1000-3085 Oct. 1-Nov 15 - (Garren) (estimated) Mar. 15-July 15 Kayak lOOO+ all year - (WKCC,1988) Kayak 1000-3085 Oct 1-Nov IS - (G arren) (estimated) Mar. 15-July 15 Raft 1OOO+ all year - (WKCC, 1988) Raft 1000-3085 Oct 1-Nov 15 - (Garren) (estimated) Mar. 15-July 15

Power boats 850-3 190 Nov 28-July 7 100- 125 boats (1-3 feet) weekend day (estimate) Flatwater Boating 890-1 100 July-Sept 200 weekday (All) (Avg. flow) 1OOO weekend (estimate) Swimming - - Fish & Wildlife 800 Sept 15-May N/A 65 0 June-Sept 15 Lower Mainrtem Clackamas River 5-31-91

C) Recommended Scenic Waterway Flows The recommended scenic waterway flows displayed in Table 4 are the flows needed to support the current range of boating activities. These flows are above the flows needed to support fish and wildlife recommended by ODFW. The lower mainstem is used by a wide range of users with different flow needs, and seasons of use. Flows of 1000 cfs, October through June, are needed to support current boating activities (power and non-power) which have minimum flow needs ranging from 850-1000 cfs. For July, a recommended scenic waterway flow of 1000 cfs supports the flatwater and whitewater activities identified. October through July, recommended scenic waterway flows (1000 cfs) exceeds the flows necessary to support fish and wildlife.

For the months of August and September, the recommended scenic waterway flow is 890 cfs. This is the lowest average flow during the summer that will support the predominant use, flatwater boating. River experts have identified the average flow during summer (July through September) as the flow necessary to support flatwater boating. The summer flow is below the minimum for whitewater boating. However, from interviews with river experts, whitewater boating is limited in August and September. This flow will also maintain fish and wildlife needs.

CONCLUSION Recommended scenic waterway flows are equal to, or exceeded by average monthly flows in all months. Lower Mainsrem Clackamas River b I LOWER CLACKAMAS SECTION ''1 able 4. River Mill Dam (RM 23.3) to Carver (RM 8).

Flow Data for the Clackamas River State Scenic Waterway (Gaged flows measured 0.2 miles below River Mill Dam).

Mean Monthly Flow (cfs)

Minimum Maximum Avenge Flow for Mclver- Recommended Flow" Flow FIOW" Fish" Carver Scenic Boating Flow Waknway Range" Flows

January 1040 8820 4403 800 85@3 190 1000

February 977 8940 41 10 800 85@3 190 1000

March 2210 8920 3297 800 85@3 190 1000

April 1870 5180 3458 800 850-3190 1000

May 1800 6400 3402 800 85&3 190 lo00

June 1140 5140 205 8 650 85&3 190 lo00

July 80 1 2020 1 100 650 890-1100 loo0

~gusr 660 I210 890 650 89&1100 890 0*J Seplember 664 1600 972 6501800 89&1100 890

Oc~oher 76 7 2710 1307 800 1000-3085 loo0

Novemher 1270 6260 2981 800 1000-3085 loo0

December 1030 ll2OO 4355 800 850-3 190 1000

I3~inimumand maximum flows are the lowest and highest recorded mean monthly flows recorded at gage #2100, Clackamas River 0.2 miles below River Mill Dam, from 1959-1987, after the completion of North Fork Dam (USGS,1990).

"The average flow is a 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. These flows take into account regulation activities.

'-'Flows for fish are based on flows needed for fish and aquatic life and fish habitat, as recommended by ODFW.

*b I6Boating flow ranges and seasons of use identified by Clackamas County Deputy Jacobs, Sergeant Baker, State Marine Board, WKCC 1988, and in Oregon River Tours. %h.V 91 Section 1II:South Fork Clackamas River

I) ENVIRONMENTAL SETTING

A) Jmation/Back~round The South Fork of the Clackamas River flows 8.4 miles from its headwaters near Helen Lake to its confluence with the mainstem Clackamas at river mile 34.6. The South Fork is lmted 9 miles southeast of Estacada, and approximately 40 miles from Portland. From its mouth to river mile 4, the South Fork is designated a scenic waterway (Figure 3).

This section of the Clackamas scenic waterway currently does not have a classification or management plan established by the Parks and Recreation Department. Parks has proposed an interim "Scenic River Area" classification that will be in effect until a river management plan is adopted. This classification applies to areas accessible by road but largely undeveloped except for agriculture and grazing.

B) Topo~raphy The lower section of the South Fork flows through a narrow canyon with large rock outcrops and cliffs. A 100 foot waterfall, which blocks anadromous fish runs, is located in this lower segment at river mile 0.7.

*-C) Hydrology here are no flow gages on the South Fork Clackamas. The only specific flow data for this reach are 8 miscellaneous flow measurements from 191 1-1952. The average flows displayed in Table 5 are estimated by the Water Resources Department. This estimate was obtained using gaged flow records from a nearby stream with similar characteristics, the Roaring River.

Based on Water Resource Department estimates, highest average flows occur December through February at approximately 190 cfs. Lowest average flows occur July through September with the lowest being 40 cfs.

11) RECREATION Recreational use along the South Fork is very low due to limited public access. Opportunities to develop new recreational facilities are few because of this limited access and steep topography, (especially in the lower section). Current use is limited to hiking to the river on an existing trail. The old Oregon City Waterworks is located near the mouth of the river. It was once used to divert drinking water to Oregon City, and now provides river visitors a unique recreational opportunity.

A) Flow Related Activities Identified flow related activities are hiking and scenic viewing. -----

I Ruorwir - h Section of the Clackamas River ;- - - - -

------J I I MT. HOOD I I IW I L---A I I I ------+ ------

NATIONAL FOREST

------A

I I ULISD(P an 4

- Sourh Fork Clackarnus River 5-31-91 d bB) Flow Dependent Activities To date, angling is the only flow dependent activity identified. Angling access is limited to hiking to the river on an existing trail, and is almost exclusively conducted by local anglers. Fishing quality is not considered high, and therefore fishing pressure is low (USFS, 1990b). No specific data on intensity and season of use are available. However, trout season, which generally runs from the end of May through October, is probably the season of heaviest use.

111) FISH AND WILDLIFE A) Wildlife The South Fork comdor provides some habitat for the Northern Spotted Owl, a federally listed threatened species. Riparian areas along the river are limited in size and distribution. Vegetation generally consists of homogeneous, younger aged stands with limited diversity for big game species (USFS, 1990b).

Corydalis aquae-gelidae, (cold water corydalis), has been identified at isolated locations within the river comdor (USFS, 1990b). The Forest Service recognizes this plant as a sensitive species which requires special management to prevent classification by federal and state agencies as threatened and endangered. The U.S.' Fish and Wildlife Service classifies the cold water corydalis as a candidate species for federal listing as threatened or endangered.

B) Fishlife The South Fork, according to a "Wild and Scenic River Eligibility1 Suitability" study conducted *a recently by the U.S. Forest Service, provides moderate to low quality habitat for resident fish. The study concluded there is a small resident rainbow and cutthroat trout population above the falls at river mile 0.7. Below the falls, spring chinook, winter and summer steelhead, fall run coho, and late winter run coho are found. The winter coho are a rare native stock of salmon originally found throughout the Columbia River drainage but now limited to the Clackamas River and its tributaries (USFS, 1990a).

Flows needed to support fish and aquatic life and fish habitat for the South Fork have been recommended by ODFW. These flows are displayed in Table 5. ODFW considers these flows to represent wildlife needs, until further information becomes available. South Fork Clacka~nasRiver

IV) FLOW ANALYSIS

A) Pata Sources Data sources for the South Fork Clackamas River are few. Flows recommended by ODFW for fish and wildlife habitat are the only available data. General background information came from a 1990 "USFS EligibilityfSuitability Studywof the South Fork, and the 1990 "Mt. Hood National Forest Land and Resource Management Plan."

B) Flow Dependent Use and Value Summary The following activities and flow ranges present the data given above.

IDENTIFIED FLOW DEPENDENT USES AND VALUES - SOUTH FORK CLACKAMAS RIVER USE FLOW RANGE SEASON OF USE INTENSITY OF (cfs) USE Angling - May 25-0ct. 31 - (general IY) Fish & Wildlife 75 Nov-May N/ A 50 June 1-15 30 June 16-30 25 July 1-15 20 July 16-31 15 Aug-Oct 15 20 Oct 16-31

C) Recommended Scenic Waterway Flows Fish and wildlife are the only flow dependent uses identified. Therefore, the recommended scenic waterway flow for the South Fork is the flow recommended for fish and wildlife habitat by ODFW. For every month the average flow exceeds the scenic waterway flow (Table 5). South Fork Clackamas River SL*. #' SOUTH FORK SECTION Table 5. South Fork Clackamas River, RM 4 to confluence with Mainstern RM 0 (34.6)

Mean Monthly Flow (cfs) t Minimum Maumum Avenge Flow for Boating Recommended Flow Flow Flow" Rrh" Flow Range Scenic Watcnvay Flows

January 190 75 NIA" 75

Febnrary 190 75 NIA 75

March 140 75 NIA 75

April 170 75 NIA 75

May 170 75 NIA 75

June 100 50130 NIA 50130

July 50 25/20 N /A 25RO

August 40 IS NIA I5

September 40 15 NIA 15 , ~ober 60 15/20 NIA 151~0 130 75 NI A 75

Decemher 190 75 NIA 75

"The average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. Flow values were estimated using a ratio of the Roaring River (RM 43.7). a gaged stream, to the South Fork, a non-gaged stream.

''Flows for fish are based on flows needed for fish and aquatic life and fish habitat as recommended by ODFW. &- I9N/~signifies that there is no boating use identified on the South Fork Clackamas River. b d Section 1V:North Fork Clackamas River

I) ENVIRONMENTAL SE?TING

A) Location The North Fork Clackamas River flows 12 miles from its headwaters near the base of Squaw Mountain to its confluence with the mainstem at river mile 31.6 (Figure 4). The scenic watenvay designation includes this entire reach. The North Fork is located approximately 6 miles southeast of Estacada, an hour drive from the Portland metropolitan area.

This section of the scenic waterway does not yet have a classification or management plan by the Parks and Recreation Department. Parks has proposed an interim "Scenic River Area" classification to be in effect until a river management plan is adopted. This classification applies to areas accessible by road but largely undeveloped except for agriculture and grazing.

B) To-w~raphy The North Fork flows through a broad canyon with moderately steep slopes. There are some cliffs and rock outcroppings along the river. The lower portion of the North Fork flows through private land that has been extensively logged throughout much of the corridor.

C) Hydrolo~y There are no flow gages on the North Fork Clackamas. The only specific flow data identified *' for this reach are 10 miscellaneous flow measurements from 1912-1952. The average flows displayed in Table 6 are flows estimated by the Water Resources Department using gaged flows from the Roaring River, a nearby stream with similar characteristics. Highest estimated average flows on the North Fork occur December through February, with the highest being approximately 220 cfs. Lowest average flows occur July through September with a lowest flow of 50 cfs.

11) RECREATION There are few existing opportunities for recreational activities on the river. With the lower 2.7 miles of the Segment in private ownership, public access to this portion of the river is very limited.

A) Flow Related Activities identified flow related activities are camping and hiking. These uses occur in the spring and summer months. Most of the use is by local residents (USFS,1990b). No specific data are available on intensity of these uses.

B) Flow Dependent Activities Angling is the only flow dependent activity identified. No specific data on season and intensity of use are available. However, heaviest period of use is probably during trout season, which generally occurs from the end of May through October. Figure 4 North Fork Section of the Clackamas River Scenic Waterway

NATIONAL FOREST North Fork Clackamas River 'Cv rr 111) FISH AND WILDLIFE A) Wildlife The area around the river provides some pockets of old growth habitat important to the Northern Spotted Owl, a federally listed endangered species. However, these pockets are isolated and do not supply all the biological needs of the species. The majority of the area is homogeneous younger-stand common throughout the region.

There is potential habitat for Corydalis aquae-gelidae (cold water corydalis) a sensitive plant species. Extensive surveys for the plant have not yet been done, and it is therefore currently unknown if the plant is present in the river comdor (USFS.1990b).

B) Fishlife There is a waterfall, 0.7 miles upstream from the lower end of the segment, that blocks anadromous fish passage. Above the falls, there is a population of cutthroat and rainbow trout. Below the falls, there are late winter run coho, a rare native stock of salmon.

There are no data available on flows for fish and wildlife in the North Fork.

IV) FLOW ANALYSIS

A) Data Sources wH Although flow dependent activities such as angling and fish and wildlife habitat were identified, there are no specific data on flow needs for these uses. Background information used to identify these uses came from the "USFS 1990 Wild and Scenic Eligibility/Suitability Study," and the "1990 Mt. Hood National Forest Land and Resource Management Plan FEIS." North Fork Cluckamas River B) Flow Dependent Use and Value Summary The following activities and flow ranges were identified from the data given above.

FLOW DEPENDENT USES AND VALUES NORTH FORK CLACKAMAS RIVER USE FLOW RANGE SEASON OF USE INTENSITY OF (cfs) USE Angling - May 25-0ct 31 - (general 1y ) Fish & Wildlife - - -

C) Recommended Scenic Waterwav Flows There is insufficient information to recommend a scenic waterway flow on the North Fork Clackamas River. Flow data to support the identified uses: angling and fish and wildlife habitat are not available. Until more information on flow needs becomes available, findings for scenic waterway flows cannot be made (Table 6). Norfh Fork Clackamas River b il NORTH FORK SECTION fable 6. North Fork Clackamas River, source to North Fork Reservoir RM 0 (31.6).

Mean Monthly Flow (cfs)

1 Minimum Maximum Avenge Flow for Boating Flow Recommended Flow Flow Flod" Fish Range Scenic Wakwry ~OWB

January 220 .rl NIAP

February 220 NIA

March 170 NIA

April 190 NIA

May 200 NIA

June 120 NI A

July 60 NIA

Aogusr 50 NlA

Sep~ember 50 NIA

p~ober 70 NIA # * November 100 NIA December 220 . NIA - Flow data on fish, recreation, and wildlife are not available. Because sufficient flow information does nor exist, a scenic waterway flow recommendation cannot be made.

'?he average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Department. Flow values were estimated using a ratio of the Roaring River (RM 43.7), a gaged stream, to the North Fork, a non-gaged river.

" * signifies lhar flows needed lo support fish and wildlife are not available. '&I. "N/A signifies that there is no boaring use idenrificd on the North Fork Clackamas. 4 'Ir. SANDY RIVER STATE SCENIC WATERWAY

Introduction The Sandy River was designated a State Scenic Waterway by Oregon's governor in 1972. The designated segment includes the 12.5 mile section from Bull Run River (RM 18.5) to Stark Sbeet Bridge at (RM 6) (Figures 5 and 6). The upper 3.8 mile portion, from Dodge Park to Indian John Island, was classified by the State Parks and Recreation Department as a "Natural River Area," due to its undeveloped, and generally pristine condition; The lower 8.7 miles to Dabney State Park was classified as a "Scenic River Area" due to its undeveloped and natural character. This segment of river was designated a Wild and Scenic River by Congress in 1988.

Background The Sandy River is located near Portland, on &he west side of the Cascade Range. The river heads at the base of Reid Glacier on Mt. Hood. It is the only major river on the west side of the Cascades that is glacial in origin and character. It drains an area 586 square miles in size and empties into the Columbia River near Troutdale, Oregon. Upper tributaries include the Muddy Fork, Zig Zag, Clear Fork, and Salmon Rivers which drain portions of the Mt. Hood National Forest and join near the towns of Brightwood and Zig Zag. Major tributaries in the scenic reach enter from the northeastern side of the river, and includes Bull Run River,(at the - upper end of the reach), Walker, Trout, Gordon, Buck, Big, and Smith Creeks (WRD, 1989).

.*id Approximately 45 percent (1,700 acres) of the land within the 112 mile wide scenic waterway corridor is currently in public ownership and administered by the state, county or federal governments. The Nature Conservancy and three "summer" camps own about 700 acres of land between them within the corridor. The remainder, or about 1,300 acres, are privately owned (BLM, 1991). This scenic waterway flows through Clackamas and Multnomah counties.

There are 4 dams in the Sandy basin including Marmot Diversion Dam (RM 30), the Little Sandy Diversion Dam, and the Portland municipal supply dams on the Bull Run River. The Bull Run River is Portland's major municipal water source. There are no dams within the scenic waterway segment.

I) ENVIRONMENTAL SETTING

A) Location The Sandy hver is located close to the Portland metropolitan area, and is about a 20 minute drive from Portland. Other nearby urban areas include Sandy, Troutdale, Gresham, Wood Village and Fairview.

B) Topography The upper reaches of the Sandy River and its tributaries flow through mountainous terrain and fall 1,600 feet in the first 13 miles. The upper river is characterized by narrow chutes and boulder-choked channels. The middle portion of the river, from confluence with Zig Zag River L (RM 42) to Marmot Dam (RM 30), flows through a wider river valley with a moderate gradient. Figure 5 Sandy Basin Scenic Waterways Figure 6 Sandy River Sandy River Scenic Waterway

Below Marmot Dam, the river descends into nmow box canyons with a moderate to steep gradient of over 40 feet per mile.

The lower 12.5 mile segment of the scenic waterway includes the 800-foot deep Sandy River Gorge. At the gorge's lower end, the Sandy meanders through two large "oxbows" and begins to widen, having large gravel bars, shallow riffles, and few rapids. The river below Dabney Park has a low gradient and is surrounded by rolling hills and pasture (BLM, 1991).

C) Vepetation Within the 12.5 mile designated segment, diverse environmental factors have created a wide range of habitats. This is due, in part, to a number of varied physiographic conditions including the river's location and a distinctive cold air drainage pattern.

Vegetative habitat in the upper elevations consists of poorly drained bogs and meadows. Below the upper timberline, mountain hemlock, subalpine fir, lodgepole pine, and Pacific silver fir are common. In the gorge area, western hemlock, and western red cedar are found mixed with red alder, big leaf maple, dogwood and shrubs (Oregon grape, salal, and blackberry). On benches above the river there is a plant community dominated by black cottonwoods. Springs and seeps produce wet areas where Oregon ash, big leaf maple, and lush herbaceous growth occur. Sandbars near the river contain willow communities.

According to a 1983 study by State Parks, three rare and endangered plant species have been found in the Sandy Gorge: nodding onion, Columbia River Willow, and giant trillium. Also, the area between Oxbow Regional Park and Dabney State Park is a historical range for the Larkspur, a Review Listed Species on the Oregon Natural Heritage Data Base List (BLM,1990).

D) Hvdrology Annual precipitation in the Sandy River Basin ranges from 110 inches at the source to 40 inches near the mouth. Greatest precipitation occurs between November and January, the least in July and August. Mt. Hood sustains a snowpack year-round, which provides water storage over the winter and supplements flows in the summer. Spring snowmelt has a major impact on the flow regime in the Sandy, demonstrated by the high spring and early summer flows displayed in Table 7.

The minimum, maximum and average mean monthly flows for the reach are displayed in Table 7. The minimum and maximum flows are the lowest and highest mean monthly flows, based on mean daily discharge, for the period of record (1931-1961). This data comes from the Statistical Summary of Streamflow Data in Oregon (USGS, 1990). Average flow is the 50 percent exceedance mean monthly flow value as estimated by the Water Resources Departmen1 (WRD,1991).

The lowest flows occur in August and September, with the average monthly flow fur September being 478 cfs. Highest average flows usually occur between November and May. The highest Sandy River Scenic Waterway 5-3 1-91 taverage monthly flow is 3376 cfs in December. The maximum discharge of record was 84,400 cfs on December 22, 1964. The minimum discharge of 45 cfs was recorded on September 26, 1962.

LI) RECREATION The river's proximity to Portland, combined with its near pristine condition, restrictions on motorized boating, easily accessible parks and river oriented facilities, make it a popular and unique recreational resource within the region.

The recreational importance of this segment of the Sandy River is supported by numerous documents, studies and guidebooks. Federal, state and county agencies, including the Parks and Recreation Department, the Oregon Department of Fish and Wildlife, Northwest Power Planning Council, Multnomah and Clackamas Counties' Parks and Recreation Departments, have long recognized the recreational and regional importance of the Sandy River Gorge (BLM, 1991). The existence of several large youth camps, river oriented special eventslfestivals and consistently high visitor use estimates also demonstrate the area's popularity and importance as a regional recreation resource.

A) Recreational AccessIUsel and Facilities The river in the upper segment is accessible, for the most part, only by foot or boat. Public road access to the river is limited to Dodge Park, located at the confluence of the Bull Run and Sandy Rivers (RM 18.5). The 342 acre park is owned and operated by the Portland Water w4 Bureau.

The lower segment of the river, below Indian John Island (RM 15), is accessible by road at several locations. About six miles below Dodge Park is Oxbow Regional Park. It is managed by Multnomah County on land owned by the county, Oregon Department of Fish and Wildlife, and the Bureau of Land Management. This 1,000 acre park and natural area offers a wide range of recreational opportunities, programs and facilities. Contiguous park lands provide public access to the river for about a three mile segment. Multnomah County Parks and Recreation Department offers a number of interpretive and nature programs at Oxbow Park. It also conducts several regional special events each year, including the popular Salmon Festival in the first week of October. This event has drawn an average of 7000-8000 participants a year over the last few years (Jim Lind, personal communication).

The State Parks and Recreation Department manages Dabney Park which is located at the downstream end of the designated segment. This park has 136 forested acres with parking, sanitation and picnicking facilities as well as a boat launch and recovery area. Additional access is provided by the Historic Columbia River Highway which crosses the river at the Stark Street Bridge and parallels the Sandy River on the east bank for about 112 mile, passing through Dabney Park.

A number of privately owned areas within the river corridor also offer extensive public outdoor recreational opportunities. Three privately owned camps offer services and facilities to several organizations and user groups with some of these camps occasionally open to the public. Sandy River Scenic Waterway 5-31-91

RECREATIONAL USE Estimates on the intensity of recreational use has been compiled from several sources. These sources include Oxbow Park, Multnomah County, local river outfitting operations, fishing and boat rental businesses, Oregon Department of Fish and Wildlife, organized camps, Oregon Department of Parks and Recreation, the Portland Water Bureau and the Pacific Northwest Outdoor Recreation Consumption Projection Study: Oregon Project.

Land based activities, including bank fishing and other day and night activities (e.g., overnight camping), account for the majority of the recreational use within the designated river conidor. Multnomah County Park and Recreation Department estimates that approximately 250,000 people visited Oxbow Park in 1990 (Multnomah County Parks, 1991). Oxbow Park user demographic surveys show that only a small percentage (3%)of park visitors are from out-of- state (except Vancouver, WA.). Over 75% of the visitors travel to the park from beyond the immediate east Multnomah County area in which the park is located, mostly originating from Portland and areas south and west of the city. Dabney Park visitation for 1989 exceeded 330,000 persons (Howard 1990). Other estimated land based recreation visitor days include use of Dodge Park (90,000 est.), the organized youth camps (75,000 combined est.), BLM lands (4,000 est.) and The Nature Conservancy (5,000 est.) (BLM, 1991).

B) -s Flow related activities identified include hiking, nature studying, horseback riding, bicycling, hunting, jogging, picnicking, camping, sightseeing, and pleasure driving. Although general data on visitation to recreational sites are available, only estimates on the intensity of the uses are available.

NATURE STUDY The Sandy River comdor offers regionally and nationally significant opportunities for nature study, research, and natural history interpretation. The area has been used extensively by local organizations, schools, and colleges for study and research. The three youth camps, parks and natural areas are visited by a variety of public and private schools and organizations throughout the year for field trips, environmental studies, and personal growth programs.

The Nature Conservancy owns over 450 acres of land divided into 6 parcels along the river. These parcels are located adjacent to 400 acres of protected BLM lands (Area of Critical Environmental Concern), along about 5 miles of shoreline. These areas are used for nature study and scientific research and are open to the public by foot access only. The American Hellenic Education Center, located near the Stark Street bridge, provides nature study programs for approximately 5000-6000 people per year (Gus Kriara, personal communication). During the fall and spring, the Multnomah Educational Service District operates a school at the YMCA Camp Collins, located approximately two miles below Oxbow Park. The school operates for 10 weeks with approximately 90 students each week and 30 staff. Study of the Sandy River and its habitat is the major focus of their curriculum (Kim Bose, Site Director Camp Collins, personal communication). Sandy River Scenic Watenvay 5-31-91

B C) Flow Dependent Activities Identified flow dependent activities include bank and boat angling, boating such as drift boating, rafting, canoeing, kayaking and innertubeing, swimming, and wildlife viewing.

1) ANGLING The Sandy River is widely recognized for its steelhead and salmon sport fishing. Ease of access, proximity to Portland, and the generally good fishing have made this river one of the most popular sport fisheries in the northwest. The Sandy, below Marmot Dam, consistently ranks as one of the better anadromous sport fisheries in the state and is considered the best winter steelhead fishery for Oregon tributaries of the Columbia River (ODFW, 1990b). The average sport catch for 1975-1984 was over 8,000 fish a year. This was the largest winter steelhead catch of Oregon's Columbia River tributaries. The annual sport catch of spring chinook averaged over 800 fish between 1976-1986; this ranked among the top punch card locations in the Columbia Basin. Also, over 7,500 salmon and steelhead tags were returned for the Sandy in 1989 (BLM, 1991).

ODFW estimated that about 30,000 angling days occurred annually in 1970 on the lower Sandy. Fishing use has more than doubled since 1970 with over 70,000 angler days occurring on the lower river for anadromous fish in 1988. Angling may exceed 100,000 angler days each year for all species (Massey 1990; BLM 199 1; ODFW punchcard data 1985-1989).

Trout season on the scenic waterway is generally from the end of May through October. Steelhead season is year-round, but all native fish are required to be released February through May 25. Salmon angling is typically allowed year round except from July 15 to August 31 (ODFW,1991). According to ODFW estimated catch records, salmon catches peak in September and October, and steelhead December through February. According to Charlie Cieko, Director of Multnomah County Parks, salmon and steelhead angling generally occurs between early September and mid-June. Peak angling pressure is between December 15 and January 31. Lightest angling activity occurs July and August. According to Cieko, 45% of visitation to Oxbow Park occurs between October and April (approximately 112,000 visitors). These visitors are generally there for angling purposes only (Charlie Cieko, personal communicatioh). Another important recreational fishing activity in the lower Sandy River is dipping for smelt (eulachons), although runs do not occur every year.

2) BOATING Boating uses identified include drift boats, rafts, canoes, kayaks, and innertubes. Motor boats are not allowed on the scenic waterway.

The Sandy River is considered one of the most convenient day trips for boaters in the region, especially for novice boaters (Garren 1976). The upper half of the scenic waterway (Dodge to Oxbow Park) is a swiftly flowing river with several pools, drops, and standing waves. With sufficient flows, this section is considered a Class 11 + whitewater run. In the lower portion, (Oxbow to Dabney Park), there are a few rapids and a number of riffles. This is a mild run and is a favorite among summer-time recreationists (WKCC.1988). The lower portion of the scenic waterway is also heavily used by anglers in drift boats and other vessels. Commercial river use Sarldy River Scenic Waterway 5-31-9 1 is limited to a few operations and businesses, most of which are related to angling. Given that the scenic waterway has two distinct sections, boating uses, flows, and seasons are addressed separately below. a) DODGE PARK TO OXBOW PARK From Dodge to Oxbow Park, the river is described as a Class 11+ whitewater run with several drops and many surfing waves (WKCC, 1988). In Oregon River Tours, Garren states that for those who put-in at Dodge Park, an "expert" run can be expected. "Pipeline Rapids," just below Dodge Park, is the first of six major rapids in this section. There are a total of eleven rapids. During periods of high average monthly flows (November through May), this section is typically floated only by experienced kayakers, rafters, and drift boaters. During summer months, this section is used for "water play."

According to UYSneakers (WKCC,1988), the season of use on the river is the rainy and snowmelt season (November through May). The guide states that this portion of the river is best to run in the spring, but that it is "runnable" typically through July. Flows recommended by the guide are 1200-3000 cfs. Oregon River Tours recommends running the Sandy below Dodge Park from April through mid-June and from October through mid-November. The flows recommended in this guide are 1500-3000 cfs; however, the author states that advance scouting of "Pipeline Rapids" for the correct river stage is advised.

According to Dick Edgely, owner of River Trails Inc., which has provided rental boats and float trips on the Sandy since 1970, the season of use on the upper section is typically from the beginning of the rainy season into mid-June. According to Edgely, once flows drop below 1200 cfs, exposed rocks will damage equipment and make for a bumpy, unsafe ride down the rapids. Typically, he states, by mid-June most boaters put in at Oxbow Park (Dick Edgely, personal communication).

Charlie Cieko, Director of Multnomah County Parks, believes that the flows identified in the boating guidebooks are inaccurate. Cieko, who has made approximately 50 trips down the river, stated that, "based on my experience on this segment, 1700 cfs is the lowest flow that allows reasonable navigability for a typical white water raft or drift boat." He stated that flows in the spring are dependent on snow pack, rainfall and temperature. He believes flows adequate for boating may last into July, and adequate flows are only sporadically available in the month October.

These experts agree that during low flow months, several of the rapids in this section are impassable due to exposed rocks, and so most boaters put in at Oxbow Park. However, some recreational boaters still float stretches of the river between Dodge and Oxbow Parks. According to Cieko, "a substantial amount of boating occurs on the river during all months of the year." When it rains and when necessary flows are available, opportunistic whitewater boaters will float the river. During summer months, when flows are below 1200 cfs, recreationists in innertubes and rafts will use portions of this section for "water play." (Charlie Cieko, personal communication). Sandy River Scenic Waterway 5-31-91

*A study conducted in 1979 (Wood),estimated an average of 100 persons per weekend day and 66 persons per week day floated this section of the river during June and July. Total boating use on the Dodge to Oxbow Park segment for the summer of 1979 (14 weeks) was about 7,500 persons (Wood,1979). An estimate, incorporating winter and spring kayakinglboating use indicates about 10,000 boating days each year at the 1979 use level (Schemer, 1990). Current recreational boating use estimates for the Dodge to Oxbow section indicates approximately 17,000 to 18,000 persons in 1990 (BLM, 1991).

b) OXBOW TO DABNEY The segment of the Sandy located between Oxbow and Dabney Parks is used heavily by boaters throughout the entire year (personal communication, Charlie Cieko). The lower half of the scenic waterway (Oxbow to Dabney Park) has few rapids and a number of riffles. No rapids are more difficult than Class I+. This mild run is a favorite among rafters for summer outings. Beginning kayak classes use the Oxbow Park area frequently and, in fact, this portion of the river is the most frequently floated section of river in the state (WKCC,1988).

From mid-November through May, drift boats are the predominant craft on the river. Angling is the primary purpose of these trips. During summer months (July through September), as temperatures warm, canoes and inflatable craft become predominant with general "water play" replacing angling as the primary purpose (personal communication, Charlie Cieko).

In October, use of the river shifts from "water play activities" to salmon viewing and salmon angling. During this month, the majority of river usen come to observe salmon spawning in shallow gravels. It is during this month that Oxbow Park sponsors the Salmon Festival, an event that draws approximately 7000 participants. Salmon viewing from both the bank and boats combined with angling for fall chinook and early-run coho are the major river uses during October.

The Songv Sneakers guide states that the season of use from Oxbow to Dabney Park is during rainy and snowmelt periods. However, the book also states "that this is a favorite float for summer outings." The recommended flows for this stretch of river are 700 cfs and above.

Oregon River Tours does not give a specific flow for the lower portion of the river; rather it recommends 1500-3000 cfs April through mid-June, and October through mid-November for the entire river (upper and lower reaches).

Although both Sneakers and Oregon River Tours do not specifically recommend summer as the season of use on the lower Sandy River, interviews with river users and experts @ark directors, rangers and summer camp directors) indicate that the river is used heavily during the summer. An example of this summer use was provided by Kim Bose, Site Director of the YMCA Camp Collins. According to Bose, from mid-June through August approximately 700 adults and 1300 children float the river from Oxbow Park to the camp (approximately 2 miles). She states that typically, by mid-July, the flow is too low for rafting and that the predominant use is flatwater innertubeing. Sandy River Scenic Waterway 5-31-91 Estimates of the flow needs for summer-time use of the river were suggested by Charlie Cieko, Director of Multnomah County Parks. According to Cieko, lower flows from late July into September can necessitate dragging or carrying a boat over broad, shallow areas. He states, flows of 550-650 cfs probably provides 'adequate draft for passage of typical summer craft.

Based on observations by Oxbow and Dabney Park personnel, it is estimated that use during the last year exceeded over 1000 persons per day during high use summer weekends. During the winter of 1987-88 (December through February), Oxbow Park persoanel observed an average of 16 fishing boats launching from Oxbow Boat Ramp each weekend day, with a peak of over 50 boats per day at the height of winter steelhead season (Multnomah County, 1990).

Applying a conservative annual growth rate of 5 percent a year, the combined boating use estimates for the entire scenic waterway may exceed 30,000-40,000 boating visits a year (BLM, 1991).

BOATING FLOWS The boating flows displayed in Table 7 combine the boating flow ranges and seasons of use identified by the guidebooks, river experts, and river users. For November through mid-June, the flow range of 1200-3000 cfs was identified in mySneakers for the Dodge to Oxbow Park run. However, river experts have identified 1700 cfs as the flow at which the river is "generally navigable." Although the guidebook states that the season of use for this run can typically extend through July, interviews with river experts, as well as the shorter season of use identified in Oregon River. Tours identified a mid-June end of whitewater season. Although whitewater boating flows may be sporadically available later than mid-June, this is typically not the case. A flow range of 1200-3000 cfs will support identified boating flows and season of use on the upper reach, as well as protect the minimum flow of 700 cfs on the lower reach.

In the month of July, the major use of this section of the river shifts to canoe and raft use. A flow of 700 cfs and above, identified in will support these predominant uses. Boating uses in August and September were identified to be innertubes and other waterplay crafts. Flows to support these activities (550-650 cfs) were recommended by Charlie Cieko, Director of Multnomah County Park.

Orerron River Tours, identifies whitewater boating on the Dodge to Oxbow Park during the month of October. However, it was determined that flows to support whitewater boating on the upper reach are only sporadically available during this month. The predominant uses of the river during October were identified as the viewing of salmon spawning, both from bank and boat, and angling below Oxbow Park (Charlie Cieko, personal communication). Boating flows needed to support the predominant uses (wildlife viewing and angling) are the flows identified in !&gy Sneakers for the Oxbow to Dabney reach. The guide recommends a flow of 700 cfs and above.

3) SWIMMING No data are available on intensity or flow needs for this use. However, according to the Director of the American Hellenic Education Center, the cold temperature of the river discourages most people from swimming (Gus Kriara, personal communication). Charlie Cieko Sandy River Scenic Waterway 5-31-91 b states "swimming and wading are popular activities throughout the scenic waterway during summer months when flows are typically lower and water temperatures warmer."

4) FISH AM) WILDLIFE A) Wildlife The scenic waterway comdor provides natural habitat for otter, mink, beaver, , and blacktail deer. There are occasional sightings of elk, , and black bear. Rare and endangered species found along the river include bald eagles, osprey, and three kinds of amphibians (OPRD, 1983).

B) Fishlife Fish habitat within the Sandy River is considered good to excellent (ODFW, 1990b). The cold water and good spawning habitat provide ideal conditions for fish species such as chinook and coho salmon, steelhead, and other trout. Tributaries to the mainstem, including Gordon and Trout Creeks, provide important additional spawning habitat. The cold water also limits the types and numbers of non-game fish such as dace, Pacific lamprey, and sculpins.

The Sandy River system exhibits a relatively large number of anadromous species in comparison with other rivers in the region. This partly due to the river's location below the restrictions and impacts on anadromous fish created by large Columbia River dams and water projects. According to the "Sandy River Subbasin Plan" drafted by ODFW in cooperation with the Northwest Power Planning Council, estimates of annual adult fish returns into the Sandy system are: 9,600 winter steelhead; 4,000-6,000 summer steelhead; 1,200 fall chinook; 1,300 spring chinook; and 12,840 early winter coho. Numbers of late winter coho are unknown (ODFW, 1990b; BLM, 199 1). The following species descriptions come from the Subbasin Plan.

Winter steelhead are present throughout the subbasin and are probably the most popular game fish on the Sandy River. The winter run consists of native late-run wild winter steelhead and hatchery supplemented Big Creek and Eagle Creek stocks. The mainstem and tributaries above Marmot Dam provide natural spawning and rearing habitat up to impassable barriers. Some natural spawning also occurs below Marmot Dam. Harvest takes place primarily in the mainstem below Marmot Dam.

Summer steelhead are an introduced race in the basin. This has created a new spring and summer steelhead catch that is becoming popular with anglers.

Two stocks of fall chinook are found in the Sandy River: the early spawning tule stock and the native Sandy River late-spawning stock. The tule stock are a Lower Columbia River Hatchery stock which is present in the Sandy as strays from other systems. No fall chinook have been released into the Sandy System since 1976. Fall chinook are found mainly in the mainstem and tributaries below Marmot Dam. The native Sandy stock and the tule stock both reproduce naturally in the lower Sandy.

Spring chinook were native to the Sandy River and were collected as brood stock for the first hatcheries on the Sandy at the turn of the century. The population suffered major declines and Sandy River Scenic Waterway 5-3 1-91 was nearly lost due to construction of Marmot Dam, low flows, and lack of screening for power generation. Since the 1960's, natural production of spring chinook has been supplemented by '-, hatchery releases of Willamette stock smolts. Screening of the Marmot diversion canal, minimum instream flows, and habitat enhancement have helped to rebuild naturally producing populations. Spring chinook spawn in the lower ends of the Bull Run and Little Sandy Rivers, in the mainstem above Cedar Creek, and in the upper tributaries.

Early-returning coho salmon in the Sandy are produced in the Sandy Hatchery. They also reproduce naturally in numerous tributaries and in the upper mainstem. Wild late-run coho are native to small streams in the Sandy subbasin. They once spawned and reared in nearly every tributary of the subbasin, and in the upper mainstem. At present, naturally produced late-run coho are nearly extinct in the tributaries of the Sandy River.

Presently, two hatcheries operate and are producing fish in the basin. One hatchery, run by Mt. Hood Community College, is strictly for educational rather than production purposes. The Sandy River Hatchery, built in 1950, is located 1.5 miles north of the town of Sandy just above Clear Creek. The hatchery raises strictly early-run coho (ODFW, 1990b).

Resident cold water species that inhabit the river include: Pacific lamprey, suckers, northern - chiselmouth, northern squawfish, dace, carp, sculpin, smelt, and mountain whitefish.

Flows needed to support fish and aquatic life and fish habitat for the Sandy River Scenic Waterway are displayed in Table 7. The flows for December through May are based on a fish habitat study conducted by BEAK consultants in 1985. This study, prompted by a City of Portland hydroelectric application to divert water from the river, identified flows necessary to maintain fish habitat. The fish flows in Table 7 @=-May) reflect Water Resource Commission findings on the application. Flows to support fish and wildlife from June through November were recommended by Oregon Department of Fish and Wildlife in March 1991 (Table 7). Sandy River Scenic Wazenvay 5-31-91

@ -IV) FLOW ANALYSIS p-2 A) p-2 Data for boating flows and season of use came from several sources. The whitewater boating guidebooks SoggY Sneakers and Oregon River Tours were used. Also, interviews with river users such as the owner of Oregon River Trails Inc., the Site Director of the YMCA Camp Collins, and river experts such as Multnomah County Parks Director, Oxbow Park employees, and BLM Sandy River Resource Specialists helped to identify flows, uses, and season of use.

Extensive background information and specific data on flow related uses appear in the "1991 Draft Resource Assessment, Sandy Wild and Scenic and State Scenic Waterway" conducted by the BLM. Additional background information came from the " 1983 Sandy River Gorge Study" by OPRD, and from the "1990 Sandy Sub-basin Salmon and Steelhead Production Plan" by ODFW and the Northwest Power Planning Council.

Recommended flows for fish and wildlife for December through May are based on a fish habitat study conducted for the City of Portland by BEAK consultants in 1985. Fish flows for June through November are flows recommended by ODFW. Sandy River Scenic Waterway 5-31-9 1

B) Flow Dependent Use and Value Summary The following activities and flow ranges were identified from the data given above. FLOW DEPENDENT USES AND VALUES SANDY RIVER SCENIC WATERWAY

USE FLOW RANGE (cfs) SEASON OF USE INTENSITY OF USE

Angling - all year 100,000 angler days (at. 1988)

Drift Boat 700-3000 Oct-June 15 16-50 boats +peak= per weekend Nov-May day (st. 1990)

Whitewater 1200-3000 Nov-May CanoelKayak WCC) (Dodge-Oxbow) 1500-3000 April-June 15 (Garren) Oct-Nov 15

Open Canoe- 700 + Nov-May Kayak (WKCC) (WKCC) (Oxbow-Dabney) Oct-July (River experts)

Whitewater Raft 1200-3000 NOV-May (Dodge-Oxbow) (WKCC) April-June 15 1500-3000 Oct-NOV15 (Garren)

Flatwater Raft 700 + Nov-May (Oxbow-Dabney) (WKCC) (WKCC) 550-650 all year (her experts) (River experts)

Boating 700-3000 all year 30,00040,000 (all) (BLM estimate) Swimming July-Sept

Fish & Wildlife 1500 Dec N/A 1900 Jan-Feb 2000 Mar-May 1400 June 8001400 July 400 A~E 500 Sepl 650 Oc I 1500 N ov Sandy River Scenic Waterway 5-31-91 r *c) Recommended Scenic Waterway Flows The recommended scenic waterway flows displayed in Table 7 incorporate the Water Resource Commission findings for a City of Portland hydroelectric permit application, fish habitat flows, and flow needs to support identified boating us&.

The recommended scenic waterway flows for November through June are based on Water Resource Commission findings for a City of Portland hydroelectric application. In the findings, the commission determined that stream flows of 1500 cfs in December, 1900 in January and F&ruary, and 2000 for March through May are "required for protection of salmon and steelhead habitat and will also benefit other aquatic life, wildlife, and recreation uses on the Sandy River." As part of the same findings, the commission also determined "that a flow of 1500 cfs would provide protection for whitewater boating and angling during the period when such use is most prevalent and not otherwise limited by naturally occurring low flows." The months of November and June were found to be two such months.

The recommended scenic waterway flow for November, December and the first half of June, however, are 200 cfs higher (1700 cfs v. 1500) than previously adopted by the commission. This 1700 cfs was identified by river experts'who believe that 1700 cfs was the flow necessary to allow "general navigability" of the Dodge to Oxbow reach. This 1700 cfs flow was identified - as the flow at which the most sensitive use experience (whitewater boating) would be seriously degraded. During the last half of June, when whitewater boating diminishes as a predominant use, the recommended scenic waterway flow is 1500 cfs, the flow previously adopted by the commission. November through June, the recommended scenic waterway flows are the flows necessary to support fishlife and allow the current boating uses to continue. Recommended scenic waterway flows November through May are exceeded by average monthly flows. In June, the recommended scenic waterway flow exceeds the average monthly flow by approximately 70 cfs the first half of the month (1636 cfs average v. 1700 cfs). Flows for whitewater boating however would still be available as peak flows during this period. The recommended scenic waterway flow is exceeded by the average monthly flow for the second half of June.

The recommended scenic waterway flow of 800 cfs for the first half of July, is the flow needed to support fishlife. A flow of 700 cfs for the second half of the month was identified in Sneakers as necessary for the predominant uses: Class I canoeing, rafting and kayaking. Recommended scenic waterway flows for July meet flows recommended for fishlife and current boating activities. In the first half of July, the average monthly flow is exceeded by the recommended scenic waterway flow (fish habitat flow). In the last half of July, the average flow exceeds the recommended scenic waterway flow.

August and September recommended scenic waterway flows are the flows identified for summer- time, flatwater boating and "water play" (550 cfs). This flow exceeds the flow recommended by ODFW to support fishlife during these months. In both months the recommended scenic waterway flow exceeds the monthly average flow.

The recommended scenic waterway flow for the month of October is the flow identified in Soggy Sneakers that supports boating activities on the Oxbow to Dabney reach (700 cfs and Sandy River Scenic Warenvay 5-31-91 above). Although flows for whitewater boating can occur sporadically following October rains, it was determined that salmon viewing and angling on the lower river were the predominant uses. Given these predominant uses, the recommended scenic waterway flow is 700 cfs. This flow does not preclude the opportunity to whitewater boat below Dodge Park following a heavy rain. The flow is above the flow recommended by ODFW to support fishlife, and is exceeded by the monthly average flow.

CONCLUSION: The recommended scenic waterway flows October through May and the second half of both June and July are exceeded by the average mean monthly flow. The first half of June and July, and all of August and September, average flows are below recommended scenic waterway flows. Sandy River Scenic Waienvay b J Table 7. Flow Data for the Sandy River State Scenic Waterway Mean Monthlv Flow (cfs)

Minimum Maximum Avenge Flow for Dodge - Water Resoume Rccommcndcd Rod' Flow no* Fichu Drbney Comrnirilon Scenic Waterway Boating Flow Rndingc" Flows Rrnacll Jrnurry 79 1 8950 I 3098 1900 I 1200-3000 1900 I900 11 R I

11 August 1 322 1 713 1 499 1 400 1 550650 1 Noc addressed 1 550 11 September 358 1950 1 478 500 550450 Noc addrerscd 550 11 326 1 4090 1 97 1 1 650 I 700 + Not addressed

Dcccmber 99 1 1 9440 I 3376 1 IS00 1200-3000 I 1500 I 1700

23~inimurnand maximum flows arc the lowest and highest rccorded mean montllly flows measured at gage # 1425 Below BuU Run 1931-1961.

24~hervcragc flow is thc 50 percenl cxcccdancc mean monthly flow value as estimated by Water Rcsourccs Drp These flows rake stream regulation into account.

"~ish flows Dee-May based on habitat study conducted by BEAK Consultants.1985. June-Nov flows recommcndc~i by ODFN'.

)G 26~oarln::flow ranges idcntificd in WKCC. 1988. Orcgnn R~vcrTours by Garrcn, and hy rlver cnpcns

*'water Resnurc~sComm~ssion findmgs for LIWCity of Podland hydroclcc~riclwrrru! rl,pl~caIrt,n REFERENCES

Baker, Richard. 1991. Sergeant, Clackamas County Sheriffs Department, Oregon City, OR. Telephone conversation with Adam Sussman, WRD, Salem, OR. April. 'crrr 6eak Consultants, Inc. 1985. "Sandy River Instream Flow Study for the City of Portland." Report prepared for the Portland Water Bureau, Portland, OR.

Brunson, Mark. 1991. Project Manager, " 1988 Clackamas River Whitewater Study." Oregon State University, Corvallis, OR. Conversation with Adam Sussman, WRD, Salem, OR. May.

Davis, Jerry. 1991. President, Willamette Canoe and Kayak Club; Director, Benton County Parks Department. Conversation with Adam Sussman, WRD, Salem, OR. April.

Diock er al. v. Ciry of Portland er al. 1988. Oregon Supreme Court decision, 306 OR 287.

Edgely, Dick. 1991. Owner and operator of River Trails, Inc. Troutdale, OR. Telephone conversation with Adam Sussman, WRD, Salem, OR. April.

Garren, John. 1976. Oregon River Tours. Touchstone Press: Beaverton, OR.

Jacobs, Richard. 199 1. Deputy, Clackamas County Sheriffs Department, Oregon City, OR. Telephone conversations with Adam Sussman, WRD, OR. April.

Kriara, Gus. 1991. Manager, Greek Orthodox Church Camp, Sandy River. Telephone conversations with Adam Sussman, WRD, Salem, OR. April.

6Jim. 1991. Park Manager, Oxbow Regional Park, Sandy River. Telephone conversations with Adam Sussman, WRD, OR. April.

Massey, Jay. 199 1. Regional Biologist, Oregon Department of Fish and Wildlife, Clackamas, OR. Telephone conversations with Adam Sussman, WRD, Salem, OR. March.

Multnomah County Parks and Recreation Department. 1991 "Oxbow Park Yearly Visitation Comparison. "

8 Oregon Department of Fish and Wildlife. 1991. "Oregon Sport Fishing Regulations for Fin Fish, Shellfish, Bt~llfrogs,and Marine Invertebrates." Portland, OR.

ODFW Columbia Basin System Planning. 1990a. Public Review Draft: "Clackamas River1 Willamette River Subbasin Salmon and Steelhead Plan." Portland, OR.

ODFW Columbia Basin System Planning. 1990b. "Sandy River Subbbasin Salmon and Steelhead Production." Portland, OR.

Oregon Department of Transportation State Parks and Recreation Division Scenic Waterway Program. 1985. "Clackamas River Scenic Waterway Management Program and Background Report."

&on State Game Commission. 1964. "Lower Willamette Basin Investigation Report. The Fish and Wildlife Resources of the Lower Willamette Basin and Their Water Use Requirements." 3regon State Game Commission. 1970. "Basin Investigations Special Report No. 2: An Outline of Fishery Problems Associated with Hydroelectric and Municipal Developments on the Sandy River."

Oregon State Parks. 1983. "Multnomah and Clackamas Counties Sandy River Gorge Study."

Oregon State University Department of Forest Resources. 1988. " 1988 Clackamas River Whitewater Study." Corvallis, OR.

Oregon Watter Resources Department. 1989. "Scenic Waterways and Wild and Scenic Reaches of the Clackamas River Drainage: A Water Resources Summary." Salem, OR. I OWRD. 1989. "Scenic Waterways and Wild and Scenic Reaches of the Sandy River: A Water Resources Summary." Salem, OR.

OWRD. 1991. "Water Availability for Oregon Rivers and Streams." Salem, OR.

Powell, Thom. 1991. Saftey Chair, Oregon Canoe and Kayak Club. Oregon City, OR. Telephone conversations with Bill Fujii and Adam Sussman, WRD, Salem, OR. April.

Scherrer, Cindy. 1991. Owner, Alder Creek Kayak Supply. Sandy, OR. Conversation with Adam Sussman, WRD, Salem, OR. April.

United States Department of Agriculture Forest Service. 1990a. "Environmental Assessment for Road 46 Reconstruction, Clackamas Ranger District, Mt. Hood National Forest." Estacada, OR.

USDA Forest Service. 1990b. "Appendix E--Wild and Scenic River Eligibility Studies and Suitability Study for East Fork Hood River."

USDA Forest Service, Oregon State Department of Parks and Recreation 1990c. "Resource Assessment for the Clackamas River. "

USD A Forest Service. 1990d. "Final Environmental Impact Statement:Land and Resource Management Plan Mt. Hood National Forest."

United States Department of the Interior Bureau of Land Managementloregon State Parks and Recreation Department State Scenic Waterways Program. 1991. Draft Resource Assessment: "Sandy Wild and Scenic River and State Scenic Waterway." Salem, OR.

Unites States Geological Survey Open-File Report 90-1 18 with Oregon Water Resources Department. 1990. Statistical Summaries of Streamflow data in Oreeon: v, 1--Monthlv and Annual Streamflow. and Flow-duration Values. Portland, OR.

Willamette Kayak and Canoe Club. 1988. &ggv Sneakers: Guide to Oregon Rivers. WKCC: Corvallis, OR.

Wood, Nancy. 1979. "Human Use of the Sandy River Gorge." Red College: Portland, OR. Analysis of Public Conlmenls 1. Comment: The scenic waterway flow assessment process is rule-making and subject d to the Administrative Procedures Act. Response: The assessments are not administrative rules. The assessments compile data and present information to the Water Resources Commission for use in making findings on pending and future water rights applications in and upstream fiom scenic waterways. The flows identified in the assessments represent one element of data among many that must be considered by the WRC or Department before water rights can be issued. In this sense, the flow figures are no different from information on consistency with basin programs, water availability, or impacts on vested rights -- 'all of which are weighed before issuing a water right. In addition, the flows identified for scenic waterway purposes are not inviolable standards which by themselves compel the Cornrnission to approve or deny applications. Rather, they are flows below which Commission findings of no impact would Ix subject to increasing uncertajnty absent additional data or documentation. The Commission could approve applications even if flows were to drop below the identified levels, if it could be demonstrated that a net benefit would accrue to the scenic waterway from such a water use. Thus the flows are neither regulations or standards, but data intended to guide the Commission in developing fmdings. 2. Comment: The data used in the flow assessment are inadequate. Response: Staff believes the flow information used in the assessment is the best available. The breadth and quality of these data is as good as any used for previous assessments or likely to be available for future assessments. Data sources were numerous and varied. They included studies from the Bureau of Land Management, a river-user survey conducted by Oregon State University, documentation from experienced river ' users, published guide books, and results of an instream flow incremental method (IFIM) study. Generally, the availability of information on levels of recreation use was not as high, with estimates of use more common that actual counts of river users. 3. Comment: The flow assessment method is inappropriate or flawed. Response: The method, which was presented to and approved by the Commission last summer, is based on the use of existing, available information. It relies on literature review, data-sharing from resource management agencies, published information from commercial sources, interviews with experts, and public input. It does not, nor was it intended to generate new information. The method is consistent with that developed and recommended by the state Parks and Rrcreation Department. It is similar to approaches used by a number of other states, including Idaho. Where new information becomes available through new, more detailed studies, the Commission may adjust the identified flow levels accordingly. The method represents the most credible effon given the Department's available resources. 4. Comment: The identified flows are not realistic.

Response: All the flows fall within the range of flows that are known to occur. In addition, in the great majority of cases, the recommended levels are less than monthly average flows. Agenda Item J, Attachment 3: Analysis of Comments WRC Meeting: May 31, 1991 Page 2

5. Comment: The flows are incompatible with Clackamas County's comprehensive land use plan. Response: There is no evidence that the data presented in the assessment are incompatible with Clackamas County's plan. Even in those months where direct appropriation from surface sources may be limited, there are a number of options available to meet the area's future water demands. These options include use of groundwater, storage, transfers, formation of regional water authorities, or purchase from municipal or other suppliers. 6. Comment: The public involvement process was inadequate. It did not provide sufficient time for input, appropriate access to the Commission, or the opportunity to review the frnal document. Response: At the October 26, 1990 meeting, the Commission directed staff to hold public workshops as part of the assessment development process. The objectives of the workshops were to foster better communication and obtain new data for use in flow identification. The schedule was moved back to accommodate this level of public involvement. For the Sandy and Clackamas scenic waterways, staff held two separate meetings to achieve the public involvement objectives -- one designed specifically for other agencies and one for the general public. Staff is continuing to explore ways to improve the public involvement process. For example, for this assessment, an "open-house" workshop was held throughout an afternoon and an evening to encourage more one-on-one contact between agency staff and the public. Staff welcomes suggestions to improve the existing process. Expanding public involvement opportunities to allow information input during development of a draft, comment on a completed draft, and comment on a final would extend the schedule beyond the 1991 - 1993 biennium and require additional resources. 7. Comment: Approval of the Sandy River scenic waterway flows should be post- poned to allow refinement or further collection of data. Response: Staff believes the data used in identifying flows are the best available. Obtaining additional data would require substantial efforts to conduct detailed studes. There is no assurance that these studies, such as IFIMs, will result in better information on recreational flow requirements. The limited resources available for the flow assessment program requires a choice between additional efforts in the Sandy basin and completing flow studies of other scenic waterways. Commission approval of the flow figures would represent a first step toward finding solutions to water supply problems in the Sandy basin. The flows would help define the playing field for further discussions between the Department and interested parties regarding water management options. 8. Comment: The assessment improperly confines consideration of "recreation" to flow needs for water-based recreation. The assessment should recognize the benefits of all recreational activity related to scenic waterways, including camping, recreational developments, and tourism. Response: The flow assessment considered both instream and out-of-stream recreational needs. The flow-dependent recreation activities identified in the assessment are the most sensitive to flow levels. The identified flows were selected to maintain the currerir quality and quantiry of recreation, fish and wildlife uses within scenic waterways. The Commission is required to prorect sueamflow needed to support recreation -- not all recreation supponcd by streamflow. Agenda Item J, Attachment 3: Analysis of Comments WRC Meeting: May 3 1, 1991 . Page 3 9. Comment: The effect of unexercised water rights belonging to the cities of Portland and Sandy on the Sandy River scenic waterway is of far greater impon than any effect from M relatively small present and future uses in the basin. It is unfair that by exercising their water rights, cities could drastically reduce the amount of water flowing in the scenic waterway, while basin residents who would use relatively small quantities of water are made subject to rigorous controls to protect the scenic waterway. Response: There may be legal issues regarding the relationship between the Bull Run reservation and the Scenic Waterway Act. However, resolution of these issues is beyond the scope of the assessment. The right to water is established specifically in statute for the City of Portland and in accordance with general water law for the City of Sandy. The assessment effort is neither designed or empowered to overturn water rights established under state law. 10. Comment: The assessment does not solve the problem of dealing with those upstream water users who do not have a water right. Response: The assessment's sole objective is to identify flow requirements for recreation, fish and wildlife in scenic waterways, not to address water law enforcement issues. By identifying flows needed in scenic waterways, the assessment establishes the boundaries of whatever enforcement problems may persist in the affected basins. Staff discussed the problem of illegal use with the Commission when the Sandy Basin program was adopted. As noted to the Commission at that time, the Depamnent expects to commit staff resources exploring water supply options with affected pames during the upcoming biennium. 11. Comment: The Department should not employ a 50 percent exceedance probability / flow in its scenic waterway assessment. Response: The recommended flows were not developed from a flow-frequency analysis, but from an assessment of what flow is required to support recreation, fish, and wildlife. The fifty-percent exceedance mean was displayed in the report only to describe in general terms the flow character of the streams. This measure of the average approximates what river users generally experience. The fifty-percent exceedance mean in the assessment should not be confused with a permitting standard on water availability. Statistically-based water availability standards are proposed in the draft Willamette Basin program and may be addressed in the development of the statewide policy on water allocation. The flow assessment, however, does not establish or imply what measure of existing flow should be used to determine if identified recreation, fish and wildlife flows are met. The assessment simply identifies the recreation, fish and wildlife flows. Agenda Item J

Attachment 4

1. Letter from Arch W. Diadc, M.D.

2. Letter from Oregon Department of Fish & Wildlife

3. Letter from Oregon State Marine Board

4. Letter from Regna Merritt

5. Letter from Alberta Gerould

6. Letter from David Butt

7. Facsimile from Clackamas County, Dept. of Transportation t Development

8. Facsimile from Portland General Electric Co.

9. Facsimile from Kohnstamm Pacific

10. Letter from YMCA Camp Collins

11. Facsimile from Stoel Rives Boley Jones & Grey wd 12. Letter from Maryanne Hill

13. Facsimile from Multnomah County Oregon

14. Letter from Louise F. Dollowitch

15. Letter from Arch W. Diack, M.D.

16. Letter from Oregon Rivers Council

17. Memorandum from Oregon State University SANDY i;ATER PLOW NEEDS: A QUESTION TO BE STUDIED WD PREPARED FOR l~dbolderin t-he lovely Sandy River Gorge for 50 years, I have spent a good ime stud ng the needs, and defending -threats'against the Sandy River. O* B aY opposition Ire become use to rising in anger, and organizing to moves that were ~uslynot in the best environmental int.erests of the watershed. Later, when the e Wild and Scenic river designation had been accopplished, these protests have ,hued -- I really don't know of any other law that has stirred more attempts sock it out than this one. From logging thru divermion ahtempts to tributary ~ingfor minipower to sewage disposal- - a good many of these were granted in ttr of the stated responsibi1it.y for Dha Scenic Waterway. I rise again to pose slatively simple question that MUST BE FACED, and has not yet been considered. question, simply put, is " how sarosanct an the exclusive rights of the g of Portland for the entire waters of the Bullrun Watershed?" he Bullrun it's tributary the Little sandy). This waterright was granted only to the city domestic use at the turn of the century, when instream ri@ts and appreciation the environment wzs rarely if ever considered. It was thought to be an everlastixg ribute of the new growing Pacific Northwest which could never be threatened. are nos at a point where things are very different. . . We are struggling to ntain our natural heritage, specifically in this case the Sandy River with it's -A, scenic wilderness, and once abundant fishery. The USGS has water pages placed along the river and I have only quated the rdings from: A. one above Marmot Dam on the Sandy; B. one placed just below Bullrun headgate which registers the amouht of water allowed by the Portlad ter bureau to escape down t.he regular Bullrun channel ( after fullfilling their ~mestic~~needs which are directed into the pipelines that feed the City and ttelite comities. C. the volume taken into the pipeline; 1). A guap below e confluence of the Bullrun and the Sandy, right above the entrance to the gorge Id and scenic stretch. This is best shoun on a rough map showing relative relations volvad' and why I think they are potentially i'mportant.

/.. -..- - . ,/-----.' .' -- -. -*.- .-, ..- _ ___.- '.. .-

'4 *'\ . - 21' b4zwawJv Y

-3 .-,\ -----...& .- , , _CI___I .-- - _. &--.Y-~E-~-~,,~ The question it raises is very important,for as we all know, Portllnd and the Wetw lmunltg is on a new growth run, and it's water supply will undoubtedly incressc. SOIT: Can t.he water bureau tightcn the screws to whereI hem is NO WATER flowing ( the Bullrun channel? For now, this is probably no threat, but in the future

,ow soon?) it must certainly be faced as a possibility; and 1 warn you, 111 he Portland. Water bureau is no friend of the Scenic Glat.eraays - they have ursued us through the State Supreme Court trying to divert some of the Bullrun scapement to generate electricity. As the figures now stand t.he smzll amount now llowed to pass into the scenic waterway adds 355 of t.he volume flow of the lower * -q andy, while if ALL of the water pushed through the pipelines at present were . .--.A L! * S :., J , dded back into the Bullrun it would increase the Sandy River by 80%. . . L.*.J.- .. b R .,..<:I

In t.he &aft Resource Assesemmt entitled "Sandy Mild and Scenic ~iver;~:,.,-r~- -,&:%;.-! . . ..-. ._._____,_.- .-- ---.--.--.. ' -.... . ::. . -______-- ' . .-.---.------_.____... .Ad 6 2<. --. & .& T- -nd State Scenic Haterway"fl~.40,~~3, it mentions these water rights and say5": , , .. 1 ! ,LC-,/. ,:.. " : y .; #. .hey arb "listed in table. 4." But there is 80 TABLE 4:- Why this was ommited --- .- . -/ _ ._ ... ' 5:x-2 4 : s a puzzle, The notice of the public meeting today has a discourging statement ..---__-. then water uses are being seriously discussed. Para. 1, p.2, stat.es " the studies io not in any way chznge regulations relating to the protection of existing rater rights,

It seems to me under the circumstances, that due caution should be taken regarding ;his potential threat. to the integrity of the Hi'id and Scenic Waterways plans xfore a final approval is reached. I cannot believe that any waterright is sancrosanct beyond it's day of best usefulness. I think the water bureau should 3e required to re-examine it's rights under present day standards, and get down to planning for a future increase in its water supply. By this, 1 do not think that nore "deep" wells, which already show contaminati- should be substituted for 3 much closer look at making better use of Portland's supurb watershed; such m increasing its resevoirs and protecting the surrounding catchment forest rrom fu&ther deforest-ation and pollution. I urge the citizens of this district of Oregon to support legislation to nake this possible.

Arch. W. Diack, M.D. 3386 S.W. Fairmount Blvd Portland, OR 97201 2, p;j '"rR';:$$?fr.$.j ,,.- i$ , ? ,i! ,6 b :b* sCu 6J L, " March 19, 1991 ;, ;, 1, , ;.,, a: !', 1 7 . 2, ! DEPARTMENT OF 1,. . . FISH AND Mr. Bill Fujii ATE)^ fi~~cs?;;~-f.DW - ,-p .-.r I WILDLIFE Resource Management Division SALEI..'?,c:-r c.d..* Water Resources Department 3850 Portland Road NE Salem, OR 97310 Subject: Streamf low recommendations for fish in the lower Sandy River, OR

Dear Bill : The Water Resources Department (WRD) has requested the Oregon Department of Fish and Wildlife (ODFW) to make recommendations for streamflows required in the lower Sandy River to support fish resources. The WRD will use ODFW's recommendations in establishing flow requirements for recreation, fish and wildlife in the Sandy River Scenic Waterway. ODFW staff has evaluated available information and developed the attached flow recommendations (Table 1). A previous study on the Sandy River developed recommendations >r a portion of the year using a No-Net-Loss criterion (Beak ory985). These recommendations were developed from habitat exceedence analysis derived from habitat simulations based on the Instream Flow Incremental Methodology. In that analysis, flows were selected that resulted in no or very little (less than 5 percent) reduction in available habitat during each month of interest over a 20 year period of synthesized daily flow record (1961 - 1980). A separate analysis was performed for each month of interest for each of the 20 years. Recommendations were developed for the months of December through May (shaded portions of Table 1.)

In response ko the WRD request for flow recommendations for the missing months, ODFW has performed a habitat exceedence analysis for the months of June through November using methods similar to the 1985 analysis. The present analysis is based on habitat exceedence over all months in a 5 year period of gaged mean daily flow records (1985 - 1990). The principal difference in these analyses is that the ODFW analysis lumps all months (all Junes 1985-90, all Julys 1985- 90, ... etc) together in a single analysis, rather than performing a separate analysis for each month in each year Mr. Bill Fujii March 19, 1991 Page 2

(June 1985, June 1986, . .. etc.) . The effect of this difference in approach is that the ODFW method is somewhat less sensitive to short term flow changes (less protective of the fish habitat) and annual variation in water abundance. Results of present and previous analyses compared to median and 90 percent exceedence flows show that the required flows for fish are equal to or less than the median flow for all months except June and July (Table 1 and Figure 1). ODFW believes requiring flows that appear to be higher than the median June and July flows are justified for several reasons. First, the flows are necessary to protect incubating steelhead eggs deposited by spawning in prior months. Second, the habitat analysis is based on highly detailed and carefully conducted IFIM studies and true incremental analysis. Third, the flow records on which the analysis is based contain a number of biases and vagaries which widens the uncertainty of these statistical reflections of norms and extremes. Biases and vagaries which I am aware of are: 1) the gaged flow records reflect an unknown amount of upstream withdrawals (both legal and illegal), and thus do not necessarily represent natural flows, 2) the median flow is likely less than the mean monthly flow, 3) flow records on which the Beak analysis is based are pre-1966 data, synthesized to reflect current operations of PGE1s Bull Run hydro project and the CityRs water supply and hydro projects, and 4) the post-1984 gaged period of record is short (5 years) and is generally reflective of a dry hydrologic cycle that is probably not indicative of the full range of flows that occur in the Sandy River. Please call me at 229-5410, ext. 437 if you have questions regarding this analysis or want to discuss the recommendations. Sincerely,

Richard L. Kruger Hydropower and Water Projects Coordinator Habitat Conservation Division

Attachments c: Amin Wahib, WRD, Salem Audrey Simmons, Waterwatch Figure 1. Flow exceedence ranges for Sandy River stream flows and recommended required flows for fish.

Month

1985-90 Data: 0 90 % Exceedence v 50 % Exceedencnce Beak Flow Data: 90 % Exceedence 50 % Exceedence - Required Flow for Fish

April 12, 1991 r-' '~%tfTy;.-( .1 ~iilFujii ..,, .. ,. P~eationCoordinator -. Scenic Waterway Flow Assessment A?Rl [i:!;J; STATE Water Resources Department MARINE !*V?.l-!lS4 !.i;-L.L.& , ,,, ,- -. L, p :, 3850 Portland Road N. E. -. *Lf - nfic:cDttj Salem, OR 97310 ~.-.-te. BOARD

Dear Bill: We have reviewed the draft flow assessment for the Sandy and Clackamas Scenic Waterways. The table on page 14 needs to be changed to add power boating as an existing flow-dependent use on the Lower Mainstem Clackamas. The needed flow levels for this activity will have to be interpretedfrom the following gauge readings below River Mill dam: Optimum flow = 1 foot to 3 feet Minimum Flow = 0.3 foot to 0.9 foot The data presented below are taken from Statewide Boating Surveys conducted since 1978. These figures are based on responses given by randomly selected registered boaters. The results indicate the days of boat use and activities associated with boat use that occurred for entire- Clackamas River within Clackamas County for the years surveyed. Survey Year Total Dl Fishing Cruising Skiiw

The follo~?ingstate laws and Marine Board rules affect boating activity on the Clackalnas River: 830.135 (2) 10 mph speed limit on North Fork Reservoir to 2.3 n~ilcsabove the dam 250-20-033 (1) (a) no jet boats 2.3 miles atwve the North Fork dam. 250-21-641) (4 j no jet skis on Willamette tributaries

In reviewing the Sandy assessment, we do 1101 have any information to add. Iiowcver, tl~e following Marine Board rules apply to the Sandy River: 250-30-030 (I) (fl no motors from Dodge Park dowl~strean~to Dabney Slate Park. 250-21-040 (8) no personal watercraft. I hope this information is helpful to you in determining flows for these Scenic Waterways. If we can be of any further assista~lce,plcasc don't hcsitatc to call.

Sincerely

30(X) hlarhct St NI. t3); Salcn~,01: 97310 (503) 37s-8587 FAX 37s-45q7 3319 NW Franklln Court Portland, Oregon 97210 16 April 1991

Bill Fujii and Adam Susman Scenic Watervay Flov Assessment Water Resource Department 3850 Portland Road N.E. Salem, Oregon 97310

Dear Sirs, I vish to contribute information regarding streamflov needs in the Sandy River scenic waterway. I plan to attend the Open House meeting in order to evaluate the accuracy and completeness of the information gathered to date. I would also like to be mailed a copy of scenic vatervay information regarding both the Sandy and Clackamas drainages. Having folloved the development of the Sandy Basin Plan and noted its consideration of the significance of the Bull Run and Little Sandy vatersheds, I was surprised to see no mention of municipal vatershed usage in your brochure. Certainly the pre- existing rights of the City Of Portland to the vaters of the Little Sandy must be addressed in any consideration of ~streamflov,particularly at a time vhen the City is evaluating nev sources in anticipation of a vater shortage. And certainly the Water Resources Department needs to address the municipal use of the Little Sandy by the City of Sandy, as recommended in the most recent version of the Sandy Basin Plan. Any evaluation of permit applications for future upstream vater uses by the City of Sandy, business interests or individuals should be made vithin the context of the possibility that the City of Portland may choose to utilize its rights to that vater. The Water Resources Department has a fine opportunity to study the USGS records on streamflov of the Little Sandy and to evaluate the impact of municipal usage of this vatershed on the streamflov of the Sandy River. I hope that this type of information vill be available at tonight's meeting. If this information has not been developed, I request that it be developed by staff and then considered by the Commission this spr inq.

Sincerely, &P-- ~eqvMerritt 3438 NE Davis St. Yortland, OR, 97232 April 20, 1491

,- .....-.- --.-...3 ,. - '; !. :. , , ' - '.., <'." - .. .. _I. , . ,; r-.IC . . . . . _. ... b <-: .,,.-....L .'a - -' -.. . Nr. Bill Fujii Oregon water Resources Depertment 3850 Portland Road, NE Salem, Oregon, 97310 Dear Mr. Fujii: Thank you for holding an Open House on April 16th, on Little Sandy Scenic Area recreation, fish and vdildlife. Here are my written comments. RECREATION - THE BARLOH TRAIL The Forest Service has been given $100,000. to develop the Barlow Trail for its Centennial. Two things that threaten the trzil that are Forest Service responsibility are: 1. The timber sale at Olive 3 is clearly visible from the site of the Old Barlow Trail. 2. There is soon to be another timber cut at Olive 1, which will be only 120 feet below the Barlow Trail in altitude, 200 feet in distance. Pictures of the view from the Old Barlov~ Trail, of Olive 3, alresdy cut, and Olive 1, to be cut, are attached to this letter. Also attached are mays showing how close these cuts come to the Old Barlow Trail. '4v I have walked this section of the Old Barlon Trail, and it follows the ridge up from the present highway. What good does it do to spend money to reconstruct old toll gates, when the natural setting of the Old Barlow Trail is losing its wilderness quality unSer the same manaeer?

PISIJ Alu'D TU2BIDITY Olive and Homestead's methods of clearcuts and overstory removal by tractor or skyline kill small trees and chew up the forest floor. Cable harvest is a system of dragging the logs across the forest floor, both ends touching the ground. Skyline is a system of dragcing the trees so that one end drags on the ground. Both systems make the runoff water turbid. I have heard (dater Boards zsk the Forest Service for fi~ureson turbidity, and the Sellrice could produce none. As far as I know, they have no 3lans to monitor for turbidity in any of the Little Sandy logging operations. Gerould

Homestead 11 is es?ecially preczrious for turbidity. This unit, which climbs Aschofl' Butte's south side for 1,000 feet, gains 560 feet in altitude. The weather at this 3200-3760 foot elevation is rough on reforestztion, and \&:ill certzinly affect the turbidity of the runoff v~ater. It will be bad for fish and wildlife. The Homestead section of Little Snndy has now 2,265 acres of old growth. The sale calls for cuttinc 84 acres of that. They plan to cut 20 trees per acre, 2nd the rest in five years. These trees are over 250 years old. The American nation cherishes its encient trees as national treasures, and there is lelyislation pending to save them.

As these trees toolc 250 and more years to be what they are, I fil?ure thet to sustain this acreage of ancient trees, only nine per year of the 2,265 acres should ever be cut over the next 250 years. Otherwise, it wouldn't be a true sustained yield. Put another wa:;, as there is only less than 574 of the original old crotvth in available land left, the Forest Service and the BUiI ought to wait 238 years to cut its rightful share of the old growth trees, and then go on z 400 year rotation system.

ki; LVSiJ AND AnlPLE SUPl'LY OF ';':ATE3 IN TIIE 1,ITTLZ SAKDY SCjiI-JIC A-IEA

There is no thin^ like a stand of ancient Pacific Northr~es: trees for slieer volume of biomass, 2nd nothing like thzt bio~lass for storing vrater and lettin:: it fl01.i to streams stezdilg and cvcnly, just lovely for the fish.

In the 11omestead sale, 84 acres of ancient Douzlas Fir will be cut. These are trees suitable for spotted owls and other wildlife, and this sale is sure to have its effect on them.

A s~nallbut typical example ol' ivh3.t a bad effect on \~~ildllfelo,y.=in,n; xccess ro~ldr,c;ln hi~ve, is a bc:ir lure I found and ~hotograahedon the Olive 4-4 locpinc rozd. Some "hunter" hnd placed :In old trash can next to a bl? tree to hold :: clilcken in, so he could lure and shoot z bear. iie hzd built e platform in a nearby tree t~ shoot the bear from.

;,/A1? 2;: 4tIGiiTS znclosed with this letter is one dated July 5, 1!

b I 2.9 distressed that ar5~;mentsover ~hohzs the wzter rights to Little Sandy datershed arc allov~edto cloud the issue of preservine, it for future water, fish and i-lildlife use. It is as if no one claims the water rights for fear of being held responsible for stznding up and saving it for its acknowledged best use. The main need here is for all the agencies involved to cooperate to stop the Little Sandy timber harvests. Sincerely yours,

Alberta Gerould IAichael S. Zdrincton, Porest Suyervisor CC: Congressman Les Au Coin David Brower May or Bud Clark l

,T1 ,,-u- ,:> OLJ 51;It1,O';i T-I.L.IL Vie::; of Olive 3 Cut n,..L:,O more viaj.blc iulits ?:ill be cut before 1392 0 33) m':12 TR :'; I L VIXYI Oi' OLIVE 1 from the T3AIL

Skyline Removal, as done at the Little Sky unit, in the heights above the Little Szndy River. One end of the log will be dragged alol~gthe forest floor in this systeln of 118rvest. OLIVE UNIT 3. OVhXSTORY RE~~oVAL/TRACTOR This is what you saw from the ridge where the Old Barlow Trail goes.

OLIVS UiiIT 5. OVEXSTOHY ~~EMovAL/THAcTOR. Note the old growth trees. OLT'JE UIiIT @ Access iioad TEE B2A-F: T,I!!i-iZ P.15:3 PLAT703':Yi OLIVE UrlIT 4A O\IZitS;';'OR'f REl4OVkL / SKYLIIJE ... ,'hat. you v!ongt see.. . CLEARCUT CABLE As wtll be in Homestead units 4 and 12, total 59 acres. These pictures of clearcut/cable harvesting were taken on Larch Mountain's Grin cut. Homestead's Units 4 and 12 will be clearcut/ cable harvested. Water Resources Department

1178 CHEMEKETA STREET N.E., SALEM, OREGON 97310 PHONE 378-3739 March 8, 1977

Joseph 1. Miller Jr. 52815 East Marmont Road Sandy, Oregon 97055

Dear Mr. Miller: . Though we have the planning capabi 1ity to ascertain current and future water needs, we would rely on the city of Portland to provide the most current data. Generally speaking the cities are capable of forecasting their future needs more readily than a state agency. ORS chapter 538.420 grants Portland exclusive right to the waters of Bull Run and Little Sandy Rivers. Unless the statutory restriction were amended, the Water Resources Department could not grant water rights for the b beneficial use of the waters of Little Sandy River. Sincerely,

I Director JES/DAL :jvm

FOR REFEI7tb:CE USE -ONLY Bull Run Interest Group Open File # -~------c

Page 1 I EXHIBlT NO. 1 L THIS AGREEMENT, madc ancl entered into this 30th day of March, A. D. 1911, znveen the Mount Hood Rallway dnd Power Company, a corporation organized and iisting undeq ancl pursuant to the general laws of the Srate of Oregon, hereinafter ?ferred to ad the Moullt tlood Company, and the Clry of Por tldnd, a municipal core. >rationof the Slate of Orcgon, hereinafter called thc City. I WITNESSETH, that \fiereas, said Mount Hood Colnpany owns the right to di- rrt and oppr priatc, for lighting, power and manufacturing purposes, the waters f the Little Sandy9 River in said State of Oregon, and,

WHEREAS,I in coursc of time it may occur that sald Clty will require a portion I f said water7 for nlunicipal and domestic purposes witllin said City, for the use of :s inhabitantg; i NOW THEREFORE, in consideration of the sum of One and No/OO ($1.00) lollars to it paid, the rcccipr of which is hereby acknowledged, and othcr valuable onsideration: the said Mount Hmd Company for itself, its successors and assigns, ereby consents and agrees that said City may, whenever ir dcems necessary so to 0, erect, construct and maintain, at a point or points above the present intake of he said ~ounlHood Cun~pnnyin said Little Sandy River, a rcscrvoir or reservoirs :,r tlv- storage of the flood waters of said river, reserving l~o\vevcr,to the Mount ioo&bornpany, its succcssors and assigns, the natural flow of said Little Sdndy ti ver as herc'inafter proviclcd.

The ~ofntHood Company further contracts, covenants and agrees. for the :onsidcration,aforesaid that it will and its successors ontl assigns shall, wl~enever :dlled upon by the said City so to do, contribute ancl pay onc-lid11 (1/2) of the cost I ind expense of constructing such reservoir or reservoirs; Pro\tlded howcver, thar aid Mount ~iodCompany shall not be required to pay r greater sum than Fifty rhousand ($50,000.U0j Dollars. .. It is further c&tracted and agreed, on tlie part ui sa~dMo~~nt Hood CompdnyD ~liatthe City Gill l~avethe f~rstriglit to the use of all waters so stored or ilnpuntled by means of such rcscrvoir or rcscrvoirs, proviclcd howcvcl, thar such use by rhc Cily.shall not intcrlere with 111c tlsc ancl appropri;ciiorl 01 the h'lounr Hood Company, its successors anrl assigns, of rile natural flow of said rlvcr as distinguished fro111 [he flow during floods or fr csl~ets. It is furrllcr tlndcr stooil ~ndagrcctl that such re- servoir or reservoirs arc to be so constructcd as to allow rhc watcrs of said stream lo flow through lllc same in order that said 1vatcr.s sliall be kepi ires11 and suitable for doiiicstic purpscs. Page 1

EXHIBIT NO. 1

THIS AGREEMENT, made antl enterecl into this 30th day of March, A. D. 1911, .hVeen thc Mount Hood Ra~lwayand Power Company, a corporation organized and :isling under ancl pursuant to thc general laws of the State of Oregon, hereinafter !ferred to as the Mount tlood Conlpany, and the C~tyof Portland, a municipal core- *ration of the State of Orcpn, hereinafter called the City.

WITNESSETH, that \Vhercns, said Mount Hood Co~npanyowns the rlght to di- 2rt and appropriate, for light~ng,power and manufacturing purposes, the watcrs f the Little Sandy River in said State of Oregon, and,

WHEREAS, in coursc of time it may occur that said Cily will requlre a portion d said watcrs for municipal and domestic purposes w~tlrinsaid City, for tlre use of s inhabitants;

NOW THEREFORE, in consideration of the sum of One and No/OO ($1.00) bllars to it paid, the rcccipt of which is hereby acknowledged, and othcr valuablc snsideration, the suicl Mount thod Company for itself, its successors and assigns, krcby collscnts and ap-ccs t11;1[ said City may, whenever ir tlccms necessary so to D, erect, construct and maintain, at a point or points above [Ire present intake of iie said Mount Hoot1 Company in said Little Sandy River, a rcsc-rvoir or reservoirs or the storage of the flood waters of said river, reserving however, to the Mounr good Company, its succcssors and assigns, the natural flow of said Little Sdndy :i ver as hercinaftel. provitlccl.

The Mount Hood Company further contracts, cove~iantsand agrces, for the :onsideration aforesaid that it will and its successors and asslgns ~11311,~11enever :allcd upon by the said City so to tlo, contribute ant1 pdy one-lldlf (1/2) of 111~cost ~ndexpense of construciing such reservoir or reservoirs; Prov~dedhowcver, that ;aid Mount Hood Company sllal 1 not be required to pay a greater sum than Fifty rhousand ($50,000.00j. Dollars. - It is further contracted antl agreed, on the part of sa~dMount Hood Compdny, liat thc City will Iiavc [lie f~rstri$t lo the use of all \vdlcrs SO stored or impuncled )y means of such rcscrvoir or rcscrvoirs, providcd howcvcl, that such use by the =ity.shall not inicrfcre with ll~c11sc ancl appropris~io~~of the Mount Hood Company, ts successors and assigns, of 11lc natur~lflow of sad river as distinpishctl fro~ll he flow during floods or fresllets. It is furtller ~lndcrstoodand agrcecl that such re- servoir or reservoirs arc to be so constructed as to allow thc watcrs of said slrcaln o flow througli the same in ordcr that said waters shall be kept frcsli and suitdblc- or do~l~esticpurpscs.

.I/...,#, .t/.,!t"..fi,. It.., I,#,,,/,.." 'I'

David 8utt P.O. 80x 235 Gov't. Camp, Ore., 97028

April 24,1991

' ;-,, Water Resources Department L...... - ' ;.'" : 3850 Portland Road N.E. 4. ;, :-,.. .L:. Salem, Oregon, 97310 k2g 6, .. - , a .'? - t' .:;, RE: Sandy River Scenic Waterflow Needs a . .7~9 r?~: .. '* I -...... Dear Department members:

I wish to thank you for the opportunity to comment on your proposals for the Sandy River. The preliminarily proposed flow levels contained in the draft of (4-12-91) are neither realistic or attainable thru current technology, The proposed October flow of 1500 cfs while the average flows historically yield 832 cfs is not within the capability of the basin to supply if all uses were curtailed,

It was quite apparent at the open house meeting that your agency is using the most expansive interpretation of the regulations to interpret your responsibility in protecting the scenic rivers, There appears to

* be a zealous effort to eliminate any further use of the waters from the upper Sandy Basin for any purpose. This strict interpretation appears to run counter to not only the letter but also the spirit of current and b past plans and regulations. The desire and the requirement to protect flows in the scenic basin for fish and wildlife and recreation is noble and proper, yet it is not clear to me that in this case that recreational flows are essential to preserving the river's attributes that resulted in its inclusion into the state scenic system.

I understand that of the 12-5 miles of river included in the State Scenic System that 3.8 miles from Dodge Park to Indian John Island is managed under a Natural River Classification and the rest as Scenic River. Neither of these Classifications would appear to require recreational use and both would appear to warrant carefully planned programs to assure that recreational use does not degrade the characteristics that caused the river to be included into the scenic system. It is evident that the massive flows required for the types of recreation considered in the draft of (4-12-91) can only be achieved when the weather conditions create them. Just as skiers can ski only when there is snow, water users that require high volumes of water must wait until the runoff from the basin increase. The October Flows in particular do not reflect that the first half of the month is generally much drier than the last, this is reflected in the streamflows that PGE must maintain below the Marmot Dam. The October flows for the river should be set at those recommended for fish, (650) cfs.

In evaluating the flows there is not sufficient data or dialogue to understand what upper basin uses were considered. It should be noted rqv that all current flows reflect the existing situation where many users may not have rights. Additionally this stream has not gone thru the adjudication process to clearly define what use could be made by exlsting rights. The compatibility with current comprehensive plans, plans on National Forest Lands should also be fully examined before any final flows are decided,

I would also be remiss if I failed to point out that the out of basin diversions from the Bull Run River pose the greatest threat to even the minimum fish flows in the future. It has not been demonstrated that there is even a measurable threat to these flows by the uses contemplated in the upper basin, yet these diversions appear to be totally unregulated- If it is truly the intent of your agency to protect the flows for fish and wildlife and recreation then this issue needs to be addressed. The Mt. Hood Unit Plan of 1977 contains statement to the effect that the Upper Sandy Basin could supplya population of 60,000 with less than a 4% reduction of surface flows, given the current comprehensive plans and estimates from Clackamas i County the total build-out of this area would more realistically result in a population of (19,000) - If this use were entirely consumptive this would require approximately (5 cfs). It is clear that the flows at Dodge Park would not be increased or decreased sufficiently to provide either recreational or fish flows.

An additional consideration that your agency needs to evaluate looking at the big picture is what effect your proposals would have regionally on the economics of the State. At the open house it was clear that the staff felt that they could not consider the impacts of this action upon millions of visitors who use the area in the upper basin. The new Forest Plan Projects huge demands into the future, yet this proposal for flows is being purposely blinded to this future need.

It is time to put the brakes on this process and gather accurate information and come up with some solution that will be workable and long lasting- The flows as proposed will do nothing less than cause undue economic hardship to areas that cannot possibly harm the flows in the scenic portion of the river, while the main use that can cause damage continues and grows with little or no constraint. Out of Basin diversions should be evaluated to see if conservation could help these flows, and the possibility of returning some of these diversions after use should be addressed.

I thank you again and look forward to a plan that is practical and

CC Gail Achterman Water Resource Commission Clackamas County Senator Hatf ield Representative Kopetskj Representative Wyden State Representative Shiprack i,QCK -CO DTD 503-650-3418

FACSIMILE TRANSMISSION COVER SHEET

DATE : TO: DEPARTMENT:

FAX NUMBER:

FROM ;

COMPANY : CLACKAMAS COUNTY - D.T. D.

FAX NUMBER:

TOTAL PAGES, including this cover sheet: 3 -

COMMENTS : -%.iCX-'CD. ---. L( \u {H~(-4-'pi- -- COUNTY Department of Transportailon (L, Development

April 26, 1991 -

Bill Fujli Oregon Hater Resources Dept. 3850 Port1and Road N.E. Salem, OR 97310

SUBJECT: DRAFT SANDY AND CLACKES RIVER STATE SCENIC WATERWAY FLOW ~MTE I am wrfting to you for the purpose of submlttlng comments on the Draft Sand and Clackan~as River State Scenic Waterway Flow Assessment. Clackamas --it-- ounty appreciates the attention the Cleckamas and Sandy Rlvers have received as we consider these rivers valuable resources that deserve sound management. We support your objective in establ fshing an accurate appraisal of these rivers to help with sensible management decislons.

Clackamas County is concerned with thl s assessment, particularly in regards to theSandyRlver. UateravallabilltyIntheHoodlandcorrldorcouldbe substantially impacted by this flow assessment. Therefore, we are requesting your agency to work diligently towards producing an accurate representation of the flow needs for the variety of river uses.

Our office Is unclear as to what the purpose, goals, and objectives are for this assessment and how this assessment will be used. Is it Intended to establish minimum stream flows as Identified under OAR 690-77-010(11)? Is it Intended to identify the availabll lty of surplus waters as deflned in OAR 690- 11-010(32)? Will It be used as a measure to identify unappropriated water available as defined In OAR 690.77.010(20)? It was explafned to me at your April 11 aorkshop at the Oregon City Senior Center that this flow assessment would be used for "in-house" purposes. 1s this document intended to be used to review water rights applications? The ftnal draft must make clear the purpose of the flow assessment. Should thts flow assessment be Intended as an accurate representation of the minimum perennial stream flows, it is imperative these flows be substantiated by reliable evidence.

The Sandy River flow assessment is of great interest to us because of the water availability problems we have encountered In the Hoodland area. Inaccurate or incomplete information on which such an assessment Is based could create a conslderable hardshlp In resolving the Hoodland problem. It is our position that the information base you are using to establish these minimum flows Is insufficient. The draft assessment provfdes very little evidence to support the prelin~lnaryscenic waterway flows you have identlfled for the summer and fall months in Table 7 on page 31. Specifically, the

902 Xbernefhy Road Oregon C~ly.OR 97045-1100 (503)655-8521 FAX 650-3351 .RCK CO DTD

8111 Fujii Page 2 April 26, 1991

monthof October is particularly disturbing because the prel ImCnary scenic waterway flows are being set at a boating flow range level. The flow assessment states on page 27 "No reliable data exists concerning boating use on the rfver below Oxbow Park," yet it is clear the boating flow range for October is what is being used as the preliminary scenic waterway flow for that month.

than-coincidental ; however, it Is very disturbing that this Information would be used out of context. The BLM study uses information identical to yours; however, the BLM findings indicated this data was lnsufflcient and unreliable. It states on page 24: "Data Needs and Further Research

A corn rehenslve recreation use study would help determine accurate overa !1 use, recreation use patterns and demographics, facility and access needs, recreation use trends, potential conflCcts and user preferences. A study would help guide recreation planning and management by determining baseline criteria and standards for the application of the "Llmi ts of Acceptable Change" plannlng process. In addition, minimum In-stream flows needed to maintaln existinq recreation

---

Our office agrees with thls conclusion that this information Is insufficient to determine flows for the management of in-stream water resources.

To conclude, Clackamas County has not been convinced there is sufficient evidence to provide an accurate flow assessment for the establishment of minimum stream flows.0ur primary concern is the Sandy Rlver because of the perceived water deficiency In this basin. Because the preliminary scenic waterway flows represent little water is available and wlll influence the issuance of water rights for other uses, it is imparative these flows are based on reliable evidence. Reliance on BLM's assessment is unwarranted as a basfs for establishlng minimum stream flows. Our offlce would like to encourage the Water Resources Department to conduct further research on the flow assessment in order to achieve an accurate and rellable document. This is particularly important should this flow assessment be relied upon when considering the issuance of water rlghts.

John Borge, Planner Plannfng and Economic Development Division WAX MEMORANDUM

Portland General Electric Company Hydro Production Support Department Three World Trade Center, 3WTC-BR 121 S.W. Salmon Street, Portland, Oregon 97204 - TO: Adam Susman COMPANY/LOCATION: Water Resource Dept., Salem

FAX PHONE NO: 1-378-8130 CONFIRMATION PHONE NO: 1-378-8455, ext 286 FROM: G.W. Hackett PHONE NO: (503) 464-8005 FAX NO: (503) 464-2233 DATE: April 30, 1991 ALTERNATE FAX: (503) 464-7157 II-~~-I-I--P~P=~ESS~UEE~E=====~~=L+CCE~~C=~E=~~~GG=G====~L~===-== NUMBER OF PAGES INCLVDZNG COVER SHEET: 2 R.C.No. 191

SUBJECT: PGE COMMENTS ON 4/12/91 DRAFT; SANDY AND CLACKAMAS RIVER STATE SCENIC WATERWAY FLOW ASSESSMENT

. Portland General Electric Co. appreciates this opportunity to provide comments on the subject draft. Even though you have provided verbal assurances that this document will not impact our xrrent water rights and hydro operations, we feel a number of blarlficntions and revisions should be incorporated as follows:

%a@ 2, Paragraph 2, Revise to read: There are three dams on the mainstem: North Fork (RM 3O), Casaderio Diversion and Faraday Powerhouse (FtM 26), and River Mil1 (RM 23). Other dams are located on the Oak Grove Fork forming Harriet Lake and Timothy Lake. There are no dams within the scenic waterway segment. All six dams are owned by the Portland General Electric Company. Due to natural flows, water level fluctuations are common and warning signs are posted at various points along the river.

Pagc - 2-3, Dl Hydrolosv: As references are made to flows in this and other sections of the draft (including tables), the specific USGS gauge numbers, and gauge locations should be provided to ellirninate confusion.

Paqc 7, A\ Fish Life: The last two sentences should be deleted; Wune- Frout , z iiw-tke+wed-ife-ofa-etit40l~ed ~&he3+atine+ishe-~+this- t.+n?-Eitdangered-6pecies4et. ,? s~~tatus~~ epeieai~--to-be-com~~-d4*+tme~The coho wl~ich are endangered are not connected to the Willamette or its &tributaries. Rather the endangered coho are related to tlie Snake River. Coho on the Clachamas are doing quite well. FAX MEMO, April 29, 1991, Page 2

EQqe 10. 11. 12, 18, 22, 26, end 35; Tables: Each of these tables should have the following note tied to the *'Preliminary Scenic Waterway Flowsttheading; Scenic Waterway Flows are not created by releases from dams and are subject to and controlled by the current and natural run-of-the river flows. Scenic Waterway flows are also junior and subject to river flows as defined within Federal and State Hydro Lioenses, and Oregon State Water Rights.

?acre- 24, IIn Fish and Wildlife aould read: ...the Northern Spotted Owl, a federally listed threatened species. However,...

Pase 31, 21 Boatina: It is our understanding that during low flows, there are areas below Dodge Park which become very dangerous with rapids in the 4+ category. At higher flows boating is safer and as described in the existing text. This concludes our comments. Please call if you have questions or desire clarification. Thank You,

c. Don Miller Ron Darkes Julie Keil Don Clark Bob Hall Jeff Kohnstamm President

April 29, 1991

Water Resources Department 3850 Portland Rd. N.E. Salem, OR 97310

ATTN: Recreation Coordinator

This letter is intended to address concerns that have arisen in the w~ke of the Sandy River Basin Water Plan (Draft), dated 4/12/91.

Those of us who have lived and worked on Mt. Hood have strived to work with the state of Oregon, the federal government, and Clackamas County to create a sensible community development plan for the Hoodland corridor. The county, at great expense, has invested in sewer systems for Government Camp and Hoodland that exceed current demand but that will handle our current plan for growth at full build-out. Our community is small and is not wealthy. It has been a grass roots effort to create a development plan which is sensitive to the local environment and which compliments our tremendous recreational resource, the greater Mt. Hood area. b At the same time, the state has drafted a water plan for the Sandy River Basin that contradicts and nullifies all previous planning. This plan, because of water law, would restrict water use upstream from the designated "Wi 1d and Scenic River Area ," effectively handcuffing our urban renewal district, recently formed in Government Camp.

I understand the law and your obligation to uphold it. However, in this cdse, it is not only senseless, but detrimental to an entire community. Compounding the ludicrousness of this regulation is th&t our use of water on the mountain is non-consumptive, meaning thdt the water goes back into the river sys:em long before it reaches the designated "Wild and Scenic River." We virtually have no effect on the riverflow. Portland's use and sale of its rights affects stream flows. We at the mountain are being held accountable for something over which we have no control.

Upon meeting with the water resources staff and reviewing the draft of the water flow assessment, it is evident to me that the staff was under pressure to hurry the plan through, that the data was not supported by any references, and that the plan was hastily ccmpi led, with several errors (such as the flow assessment chart missing the month of December). Our community desires to resolve the water issues as much as anyone, but we feel astonished that such an important issue, with huge consequences to our livelihoods a~tdlifestyles, is being forced upon us within a short time frame based on weak and shoddy research and documentation. glr

Post Olfrcc Box 8 Covanmcnt Camp. Oregon 97028 (503)272-3422 Water Resources Department 2 April 29, 1991

Another point with which I take great issue is the method for establishing recommended river flows. For example, the plan is recommending a flow of 1500 cfs on the Sandy River in October. History shows that the average flow is 832 cfs in October, when there is low snow melt-off, and often little rain. Subsequently, the flow can be relatively low compared with other months.

Designation of "wild and scenic river" requires considering first wildlife and recreation users primarily. The water resources staff looked to boaters for input and got the response that 1500 cfs would be good for boating. This is the flow that is being recommended by the plan, but it is obviously unrealistic. To base water use limitations upstream on logic such as this is absurd. I could relate the same thinking to my business, which is skiing. Just because a recreationalist wants to ski in October does not mean there will be snow to do it on.

The awful irony of this situation is that the Wild and Scenic Rivers Act was intended to protect rivers, among other things, for recreationalists. Adopting the Sandy River Basin Plan in its current form would destroy the infrastructure intended to support those who engage in recreation.

I urge you to adopt a plan that uses sensible logic in coordinating with current state and local development plans and thinking.

Sincerely,

Jeff Kohnstamm President, Kohnstam Pacific Corp. 3001 S.E. Oxbow Parkway - Gresham, Oregon 97080 (503)663-5813 22 ~prit1991 Adam Sussman Water Resource bepattment 3858 Portland Road N*B. Salem, ot 97318 Dear Ht. Sussman,

! enjoyed talking to you on Thursday Aptil 10, 1991 and am pleased to be able to provide tbe information you requested coricetning the usage of the Sandy River and its' bank by Camp collins. YMCA Camp collinil hae owned 138 acres of land since 1926 on-the lowet sandy Rivet. ?his includes one and a half miles of shore land. We are locat&d on the 12.5 mile section of the river (~)'-b i$ classified fkderally a6 a recreational tiver and a c4onent of the Federal Wild C scenic River Act. In 1972 the covetnor of the state Otegon designated the Sandy River as a State Scenic Watervay. Under the Oregon Scenic Waterway Management Plan tOPRb 1999) we atd managed by both state and federal jurisdiction which 11, mdinstteamed into the scenic Waterways Progtam of the OrCgan Stake Patks and ~ecreationbepattment. The bouadaty fat thin management ptogram is 1/4 mile from the ordinary bigh watet matk on eitbct side a£ the river, buting out suatmcrt tamp ~essionswhich tun id-June through August, the tivet and crater botlhdary lands are used heavily. tie have apptoriaiat&ly 1300 childten attending camp each sumkt and a weekly staff a£ 70 adults. fhe activities we schedule on tbe tiver include but ate not limited to; tafting, canoeing, innettubing, animal absetvationb hatute studies, overnight campsuts, hotse trail tides, hikee, games, and campfire progtams. hany of these activities ate dependent an the river level. As an example tiver rafting can ahly be done thtaugh mid-July as the watet level is too low to be c~nsideteda safe activity. Outing the fall 8fid spting the nultnomah Bducational Service Disttict opetates an outdoat School at our site. they are here for 18 weeks ~ithappto~i~ately 90 students each week and 38 staff. The Sandy River and it's habitat ate a major part of their curtlculum. her Etlih is the site bitectot far camp Collins, He will be mailing you specifics tegarding their eutticulum needs. We ptovidc? accesg to tiahetren In accordance with an agteement have ulth the county and the patks department. t would estimate kt at during fishing season ue have 25 to 50 fisherman a day using our bankg. A branch of the YMCA of Columb~a-W~llamette An agency 01 Ihe Un~ledWay Page 2

In conclusion, let me state that the Sandy River is a key component of our program. It would be benificial to our program to increase the water flow during the summer seasoo. Please call me if you have any questions or concerns, Sincerely, ,

, Kim Bossem Site Director XHCA Camp Collins cc Jerry Ba1ser;CEO YMCA of Columbia-Uillamette A1 Waddell; Board Chair YHCA Camp Collins Bob Ratcliffe; BLH Sandy River Plaooing Group STOEL RIVES BOLEY JONES&GREY ATTORNI IS AT Law SUITE 2300 STANDARD INSURANCE CENTEF: 900S\V FIFTH AVENUE PORTLAND. ORECON97204-I268 Trlrphortr (5031 224.3180 Trlrco~~irr(503) 220-2480 Cnhlr La ~qpnrl Zlrr 703455 Wr~lrr'sD~rrct Dm1 Nvmbrr

April 29, 1991

Mr. Bill Fujii Scenic Waterway Flow Assessment Water Resources Department 3850 Portland Road NE Salem, Oregon 97310 Re: Draft Sandy and Clackamas River State Scenic

Dear Mr. Fujii: We represent the Government Camp Recreation Association (~~Associationw).Association members are domestic and commercial water users in the upper Sandy River Basin interested in promoting recreation on Mt. Hood. The Oregon Water Resources Department ("WRDW) has prepared and made available for public review and comment a Draft Sandy and Clackamas River State Scenic Waterway Flow Assessment dated April 12, 1991 ("Draft Flow Assessmentm). On behalf of the Association, we submit the following, written comments concerning the Draft Flow Assessment. These comments were previously presented orally to WRD staff members Rick Bastiach, Adam Sussman, Tom Kline and you at a public meeting on Sandy and Clackamas River scenic waterways in Oregon City on April 16, 1991. The Draft Flow Assessment will have a profound impact on life in and the future development of the upper Sandy River Basin. The proposed flows are substantial and constitute a serious barrier to future development. As such, the proposed flows are in direct conflict with Clackamas County's approved land use and economic development plan. The proposed flows are not only incompatible with the County's comprehensive plan but in part exceed physical availability. For example, the proposed October scenic waterway flow of 1500 cfs is far in excess of the average flow of 832 cfs. The Draft Flow Assessment fails to adequately describe the data and resources which the WRD relied upon in L the preliminary scenic water way flows. The draft also STOEL RIVES BOLEY JONES O GREY

Oregon Water Resources Department April 29, 1991 Page 2

concedes that the existing data is inadequate. At page 29 it reads, tt[c]omprehensive data on recreation use levels and recreational use patterns for the Sandy River is'not currently a~ailable.~~In addition, at page 30, it is even admitted that qt[n]o reliable data exists concerning boating use on the river below Oxbow Park."

At the April 16 meeting WRC staff members stated that the WRC does not intend to adopt the draft Flow Assessment as a rule or an instream water right for these flow levels. Instead, the staff indicated that the purpose of preparing the scenic waterway flow assessment was to provide the WRD with an internal guideline for use in reviewing applications for instream flows by state agencies or applications for water right permits by private applicants. The WRD is entitled to develop such a general policy. If, however, the flows are used to make decisions concerning individual applications for water . rights, the "policytqmust be adopted in the form of a rule, adopted after notice of rule making, a public hearing and the opportunity for comment are provided. Alternatively, these flows can be part of an application for instream water rights by individual state agencies. The WRD is not, however, permitted under Oregon law to use informal guidelines to review individual applications for water rights. The Draft Flow Assessment contains no explanation or analysis of what constitutes recreational use for purposes of establishing these flows. The draft also fails to recognize or even evaluate the need for parks and camps in the Sandy River Scenic Waterway to have water available for these facilities. This is both surprising and a serious shortcoming since the draft itself acknowledges that "land based activities, including bank fishing account for the maioritv of the recreational use of the designated river stretch.It There is also no consideration of water needed for supportive recreation facilities within the Sandy River basin, much of which is important for recreation. The Association strongly urges the Department to postpone final consideration and adoption of the draft assessment until adequate data has been collected, analyzed and presented for public review and comment. The Association is mindful of the fact that the Water Resources Department is charged with establishing scenic waterway flows in basin throughout the state. There is, however, no reasonable justification for conducting this process in a hurried manner STOEL RIVES BOLEY JONES(9 GREY

I Oregon Water Resources Department April 29, 1991 Page 3

based on what Water Resources Department staff members acknowledge is an inadequate factual basis. Thank you for providing the opportunity to comment on the Draft Sandy River Scenic Waterway Flow ~ssessment. Sincerely yours,

GLA:CRH:hm cc: Ms. Lorna Stickel Mr. William Young raane EJ- .i PO Box 27 Goveramcnt Camp, 01 97028 (503) 212-3281

'Nater Resources Dep t. 3850 Portland Rd. N.E. Salem, OR 973 10

RE: SANDY RIVER SCENIC & RECRUNALWATER FI-OW PROPOD LEVELS

I appreciate the opportunity to comment on your draft proposal of 4/ 1219 1.

I do not believe the stream flow data the Department is using to be the best available. A moE malistic time frame which would assure a credible determination of realistic cfs is critical.

The department appears to be rushing forward with an extremely restrictive plan which would stop any use of waters in the upper basin. I wonder what upper basin uses were considered, if any. Certainly current land use plans, Clackamas County and USFS,need to be addressed as do tbDeconomic impacts of the region and the State of Oregon. No agency shldbe allowed to operate in a vacuum.

Please keep in mind that the Mt. Hood Unit Plan projects less than 4% water consumption if we had a Mt. Hood corridor population of 60,000. Present population is not even one tenth of that! The PortaInd Metropolitin Area has 100%water consumrnption - not a drop goes back into the Sandy Basin. Portland is the cause of low flows, certainly not the upper basin. A plan for conservation in the Portland Metro Area needs to be addressed. . Flows set at those necessary for fish ate realistic. The June and October proposed flows need to be in alignment with the rest of the months to follow this balance. Most recreation is seasonal. Recreation in the lower Sandy Basin can be enjoyed when flows allow.

Most sincerely, A

~ar~inneHill BOARD OF COUNTY COMMISSIONERS DEPARTMENT OF ENVIRONMENTAL SERVICES GLADYSMCCOY .CHAIR OF THE BOARD PARKS SERVICES DIMSON PAULINE ANDERSON DISTRICT 1 COMMISSIONER 1620 S.E. 1WTU AVE. GARY HANSEN DISTRICT 2 COMMISSIONER PORTLAND. OREGON 97233 RICK 8AUMAN OlSTRlCT 3 COMMISSIONER (503) 268-5050 SHARRON KEUM DlSTRlCT 4 COMMISSIONER

FACSlUE TRANSMISSION CoVERT

DATE: 5////4/

TO: &I-/! GI/,.. 1 378~c/33 Name / FAX Number

FROM : el&5&0 Name

248-5050 / 248-332 1 Tel ephone Number FAX Number

SUBJECT: &Ad 15v!a/kf&~7

COMMENTS :

'#' pages to follow (excluding this sheet)

Department of Environmental Services-Yeon Shops fAX No. 15_15Q31 248-3371.

Please use this number for buslness transmission purposes. only. No advertiring, please. Jf you have dtfflcuities wlth this transmlsslon, please call (503) 248-5050. cs OEPARTMENT OF ENVIRONMENTAL SERVlCES OLAOYS McCOY CHAIR OF THE BOARD PARKS SERVICES ONISION PAUUNE ANDERSON DtSTRICT 1 COMMISSONER 1620 S.E. 1OOTH AM. GARY HANSEN DISTRICT 2 COMMISSIONER PORTLAND. OREGON 97233 RICK BAUMAN DISTRICT 3 COMMISSIONER (503) 248-5050 SHARRON KEUM DISTRICT 4 COMMISSIONER

May 1, 1991

Water Resources Corn1 sslon C/O Mr. 8111 FuJ11 Water Resources Dept . 3850 Portland Road, NE Salem, OR 97310 Dear Commlss~oners: On behalf of Multnomah County, I want to express our appreclatlon for thls - opportunity to submlt comments on the draft Scenlc Waterway flow assessment for the Sandy Rlver. bDesplte the fact that the Sandy Is widely recognized for tts fish. wlldllfe and recreatlonal values, It Is apparent that hard data, crltical to the determlnatlon of necessary flows, 1s not avallable at thls tlme. Thls Is a serlous concern whtch calls Into questlon the credl blllty of some recommendations made In the draft. Whlle we are mindful of your intent to set Scenlc Waterway flows as soon as possible, It 1s not In the publlc Interest to support a proposal whlch lacks a sol ld data base. SpecIflc areas whlch lack solld data Include boatlng and angllng. The only sources 11sted In the draft for boatIng flows are two guide books, "Soggy Sneakersn and "Oregon River Tours," No sources have been clted for angllng and subsequently no flow range has been proposed. Several observations come to mlnd related to boatlng:

a) A substantial amount of boatlng occurs on the Sandy Rlver during all months of the year. Excerpted portlons of both books regarding "season of use" are wrong.

b) For the determlnatlon of appropriate flows, the Sandy needs to be broken lnto two sectlons - Dodge Park to Oxbow Park and Oxbow Park to Dabney Park. Dlfferent characterlstlcs of the rlver and Its canyon dlctate the need for the dlstlnctlon. May 1, 1991 Page 2

C) Excerpts from "Soggy Sneakers" and "Oregon River Tours" whlch suggest the segment between Dodge Park and Oxbow Park 1 s navlgable at flows of 1200 - 1500 cfs are Inaccurate for the most common craft - Inflatable rafts - as well as drift boats and most llkely canoes. Based on my boatlng experlence on thl s segment (approximately 50 trIp~), 1700 cfs Is the lowest flow whlch allows reasonable navlgablllty for a typlcal whI te water raft or drlft boat. Flows of 2300 to 2800 cfs are I deal . Season of use on thls segment 1s strlctly flow related. Spring flows are dependent on snow pack, preclpltatlon and temperature. Flows adequate for boatlng commonly last into early July. Drought years can curtall flows much earller. In any event, light use continues through the summer months by small lnflatables general ly associated HIth water play. Adequate flows are only sporadlcal ly available In the month of October. Wlnter flows fluctuate wldely as a result of freezlng level and preclpltatlon. Boatlng use durlng the wlnter months appears to be Increasing. This 1s probably I nf l uenced by technologl cal advances In equl pment and the conventence of thls boating opportunlty. d) The segment of the Sandy located between Oxbow and Dabney Parks 1 s heavl ly utlllzed by boaters throughout the entire year. Drlft boats are the predoml nant craft from mld-November through May. Angl lng ls typl cal ly the prtmary purpose of most trips. As temperatures warm, canoes and Inflatable craft become predominate wI th general "water play" replacing angllng as the prlmary purpose. The gentler gradlent of thls segment makes It Ideal for novlce boaters In a wlde range of flows. Lower flows In late July, August and September can necessl tate dragglng or carrylng boat over broad, shallow areas. Flows of 550 - 650 cfs probably provide adequate draft for passage of typlcal "summer" craft. Slgnlf lcantly higher flows are necessary for larger craft such as drift boats. Addltlonal comments regardlng the draft assessment lnclude the followlng: a) Angllng for salmon and steelhead 1s llkely the most common recreatlonal actlvlty tn the study area. Flows greatly Influence angltng actlvlty and qulte posslbly success rates. Hlgher flows (2,000 - 3,000 cfs) allow for angll ng pressure to be spread over a greater area. It 1 s general ly accepted that anadrornous fl sh migrate on freshets wlth Ideal angllng condltlons occurrtng as the water drops and beglns to clear. Wyage I*3 lggl

Angling occurs in all months of the year wlth the lightest actfvlty In July and August. Salmon and steelhead angl I ng generally occurs between early September and mld-June wfth pressure peaklng between December 15 and January 31. Staff at Oxbow Park is gatherlng data whlch may be useful In determlnlng approprlate flows for angl I ng. Observations suggest that flows for malntalnlng flsh Ilfe are not consistent wlth angllng flows. However, hlgher flows assocfated wl th angl lng are not 19kely detrlmental to spawnlng or rearing.

Specles present In the Sandy Basln Include: Fall chlnook (early and late varletles); wlnter steelhead; coho salmon (early and late varletles); summer steelhead; sprlng chlnook and sea run cutthroat trout. Varlous lffe stages of these salmonlds are present In the study area during all months of the year. b) Swimmlng and wading are popular actlvttles throughout the study area during the summer months when flows are typlcally lower and water temperatures warmer. Flow Influences thls actlvlty to the extent that water quallty Is malntalned and beaches are exposed.

C) "Maintenance flows" are not addressed In the draft. These hlgh wlnter flows play a crltical role In flushlng sedlments, movement of large woody debrls, provldlnp channel divers1 ty and malntafnlng beach areas. All of these functlons are dl rectly related to the long-term protection of flsh, wlldllfe and recreatlon values. d) "Average Flows" as llsted In Column 3 In Table 7 are cause for great concern. These flows are based on a "SOX exceedance" of monthly mean flows. It Is our understanding that 80% exceedance flows have been utlllzed In other flow assessments. A1 though I am unclear about the rationale for utll lzlng the slgnlficantly more 11 beral 50% exceedance flgures, It Is evldent that these flgures glve an Inaccurate and ml sleadlng Impresslon of surplus water aval lab1 1 lty In a1 1 months. It 1s unllkely that Scenic Rlver Statutes or the Supreme Court Intended to protect adequate flows for flsh, wlldllfe and recreatlon only 50% of the tlrne. I urge the commlsslon to reject thls approach and replace It wlth the 902 exceedance flow Informatlon whlch has been developed by Beak Consultants and Oregon Department of Flsh and Hl Id11 fe. These flgures have been based on dally flow records whlch provlde a far more accurate data base than monthly mean f1,ows.

It should also be noted that all flow lnformatlon Is blased by unknown amounts of water withdrawn (both legal and Illegal) above the study segment. Assessment of these withdrawals Is recommended. May 1, 1991 Page 4

It Is my hope that the above Information Is useful in determining flows whlch are both adequate and defendable. The data contained In the draft assessment 1s not adequate for maklng an informed decision. Multnomah County Parks Servlces Is wllllng to assf st Water Resources In the collectlon of addltlonal data as necessary. In the interim, I would recommend that actlon on this Issue be delayed. Again, thank you for the opportunl ty to comment.

Charles Clecko Director, Parks Services DIv! slon

cc: Bob Doppelt, ORC 81 11 Hutchl son Arch Dlack Bob Radcliff, BLM DATE: April 29, 1991 8 TO: Bill Fujii or Adam Susman L Scenic Waterway Flow Assessment Water Resources Department 3850 Portland Road N.E. Salem. OR 97310 FROM: Louise F. Dollowitch 36021 S.E. Lusted Rd. Boring, OR 97009 RE: Notice of Public Meeting on Sandy and Clackamas Rivers Scenic Waterway Flow Needs I wish to express my opinion that I do not want any activity on the Sandy River that woubdiminish the flow of water. I reside above Indian John Island on the Sandy River and do not wish to have this Sandy River put into any industrial or commercial or residential development that would despoil or limit the flow of the river. Thank you.

36021 SoE. Lusted Rd- (Multnomah County) Boring, OR 97009 Arch Id. Ilisck, PI. I.). 3:306 SW L'rtirmount Ylvd. Pot-tland 01- 97201

6bw 4 /2Y/lYt31 Mr. Bill Fu'a.~i Oregon Water resources Depnrt,mc:rlt 3850 Portland Rood h'. I-:. Salem, OR 97310

Dear Bill:

I erdoyed saying hello to you the other week down in Oregon City. I certainly hope the Water Resources Board will come up with some workable solution to the Sandy watershed allotment syatem t.hat is fair to both the City duellers who require drinking water, and those thousands and thousands who want to preserve the Wilderness and fishery so close to the ntetro area where ro-st, relaxation, and enjoyment can be found and which above almost everythung else should be preserved to identify F'ortland as an ideoal place to live wherr our grandchildren g~'ow UP - Related to this . I am writimg in strong support of the let.ter written you by Qlberta Gouid on April 21 re the absolute senseless plans for developing the historical Barlow Trail and at the Sam? tima clear c:utt~ng large tracts of maaestic old growth in tho Little Sandy watershed. bTheir announced plans are so rediculousl y unhinged to reason and recognitiorr of the true marti n8 of restoring a national landmark of great importance and at the same time also planning -by the same Forest Service -to allow ruthless dsstruct.ion of old growth timber in the adjascent Little Sandy in clear view of the Very Bar-low Trail they were allotted SlO(3.000 to develop for the Centenni a1.

i-iou cualbersonre and disconnected can a single Bureau get? And the Portland Wst-er Bureau goes right allong with big Brother USFS or1 this --talk about the S8L slop- this is a parallel! in reprehenni Ole "action for the public good".

I I-rope t.tre Oregon Water Reoouces Board takes 6 very good look at this arid i'inally s~tt.3esdown to decide wtlet is ~Fcrosanct,wllat IllIST b preserved For. the future, and what is prudent to harvest a~rdut~st is prudent to conserve. The future needs for river watersheds: brow to cons.=rve them and malie bettor use of our alraiablc nuppl y; a1,d wt~i~tto wisely decide to preserve perpetually f'or- the good of all 01' us, would be a wonderful decision for your board t.o make and and would be uelcnmad by nlmost c-vcry iiregonian. Si 11r:urcl y, THEOREGON RIVERSCOUNCIL PO. Box 309 Eugene, Oregon 97440 503-345-0119

Bill Fujii Water Resources Department hlAY Ci 1;53 3850 Portland Rd NE : , r,-Lr.., . 97310 Salem OR !-.. >. .:: ...-.; 5-; ,,,* Cir;,E$o~y May 1 1991 nrm Dear Bill, ck Venturn This letter conveys the comments of the Oregon Rivers Council on the draft Sandy and Clackamas State Scenic Waterway Flow be?x Assessment, dated 4-12-91. The Rivers Council requests timely Anuta notification of comment deadlines for subsequent and similar. ur DF knkel instream flow processes. ;my 8 Jensen Considerable sustained and serious interest may be expected re1 Mason t Niemi on water related issues in the Sandy basin. We strongly encourage Cter Paquet the Department to conduct a fully professional unhurried process, ces Petersen with thorough public involvement. Spencer 4-12-91 ISORY BOARD The document is an incomplete working draft, and the Rivers Council submits these comments only as partial comments, pending a complete draft. This is particularly important given .leer Bish rb' r. ma ~krrnan that important sections of the analysis are missing altogether, . Chouinard e.g. *'Flow Analysis" [see p.321. This is the heart of the Sandy itch Diack yard Hansel1 analysis, and no appropriate comment is possible until this Jensen section is complete. Johnson tan Kerans Lazar Nevertheless we offer the following preliminary comments: a Leopld e Marks As noted, the flow analysis is incomplete. The note p. 34 Mattson Nath states that the analysis will be based "on flows displayed in ry Russell Table 7". Since flows displayed in table 7 are incomplete and Bob Straub unsupported the basis for the analysis is open to serious Thmp Vetterlein 'question. shna Wilson No justification is provided for selecting BEAK research flows for the Sandy, nor for the preference of those flows over ODFW flow.

December flows are missing altogether. [see p. 351.

The use of 50% exceedance flows is not jusWied. The Diack decision mandates protection of flows, not occasional protection of flows.

The draft states that. "Comprehensive data is not available ..." and then makes no provision for obtaining that data. Conclusions must not be drawn, and cannot be supported, in the absence of data. [see p 291.

The final assessment of Sandy flows will be the basis of consequential decisions. We look forward to the.opportunity to comment on a completed draft based on comprehensive data.

pq~'*Bob Dopp t ~xecutiveDirector THEOWN RIVERSCOUNCIL PO. Box 309 Eugene, Oregon 97440 503-345-0119

c l~lrector Bill Fujii P' 'L Water Resources Department oFWfWKXZS 3850 Portland Rd NE L Salem OR 97310 ;eys Hay 1 1991

Dear Bill,

This letter conveys the comments of the Oregon Rivers Council on the draft Sandy and Clackamas State Scenic Waterway Flow Assessment, date 4-12-91. The Rivers 't Council requests timely notification of comment deadlines for subsequent and ~uta similar instream flow processes. Dye nkel noy Considerable sustained and serious interest may be expected on water related tnsen issues in the Sandy basin. We strongly encourage the Department to conduct a l Mason Jiemi fully professional unhurried process, with thorough public involvement. tr Paquet s Petersen The 4-12-91 document is an incomplete working draft, and the Rivers Council tncer submits these comments only as partial comments, pending a complete draft. This ;ORY BOARD is particularly important given that important sections of the analysis are missing altogether, e.g. "Flow Analysis" p.32. This is the heart of the Sandy analysis, and no appropriate comment is possible until this section is complete.

Nevertheless we offer the following preliminary comments: ch Diack d Hand msen As noted, the flow analysis is incomplete. The note p. 34 states that the ohnwn 7". n Kerans analysis will be based "on flows displayed in Table Since flows displayed in uar table 7 are incomplete and unsupported the basis for the analysis is open to imopold serious question. Marks attson lath No justification is provided for selecting BEAK research flows for the Sandy, Russell nor for the preference of those flows over ODFW flow. ob Straub hrwp etkrlein December flows are missing altogether. p. 35. ina Wilson The use of 50% exceedance flows is not justified. The Diack decision mandates protection of flows, not occasional protection of flows.

The draft states that "Comprehensive data is not available ..." and then makes no provision for obtaining that data. Conclusions must not be drawn, and cannot be supported, in the absence of data. p 29.

Executive Director

Printed on 100% sccyclrd, unOlcachd pn7,cr ' k,.. OREGON STATE UNIVERSITY .. k- ;: ,. ( 1 f . 2~ *-- ,, ;::;! >1; < 2,, COLLEGE OF FORESTRY ...-8.Te Frequency Distribution optimum flow (all boaters) Frequency Distribution Optimum flow (by boater type) 35% , I

Cubic feetlsec. - Kayakers --.-a--- Rafters Frequency Distribution optimum flow (by preferred season)

Cubic feetjsec.

- November-May -----. May-October -----.-.Year-round