June 27, 2019 To: U.S. Army Corps of Engineers, Portland Region From: Clinton Begley, Executive Director - Long Tom Watershed Council As Executive Director of the Long Tom Watershed Council I submit this letter as comment for myself, in my professional capacity, for the purposes of scoping for the Environmental Impact Statement for the Willamette Valley System Operations and Maintenance. The The Long Tom Watershed Council serves to improve water quality and watershed condition in the Long Tom River basin through education, coordination, consultation, and cooperation among all interests, using the collective wisdom and voluntary action of our community members. The Long Tom Watershed Council (The Council) works in a unique niche - our voluntary and non- regulatory approach allows us to reflect the values of our watershed through a community of practice to enhance and restore the lands and waters in our shared home. This work depends upon a culture of neighbors-helping-neighbors to work across differences to make this a healthier place for everyone. As such, we work in close partnership with private landowners and public agencies alike in both the Long Tom Watershed, and the main stem of the Willamette River. This modus operandi is important context to acknowledge both The Council’s strengths as a regional participant in this work among partners (including strong and positive partnership with the Army Corps), and also the limitations upon our collective ability to achieve ecological uplift given the initial conditions of anthropogenic hydrologic processes within which we operate. It is my hope that through the scoping phase of the Willamette Valley Project Environmental Impact Statement, the USACE will consider the following initial conditions and limiting factors to ecological uplift in our service area, and throughout the basin: Invasive species: while the origins and vectors for non-native invasive species are numerous and manifold, current conditions on some USACE lands in and around Fern Ridge Reservoir (Fisher Butte access for example) are dominated by invasive plant species like reed canary grass. These “anchors” for invasive species limit biodiversity of the surrounding systems and threaten nearby and adjacent work to restore rare wetlands and wet prairie to the detriment of numerous target endangered and threatened aquatic and terrestrial species like streaked horned lark, red legged frog, etc. Invasive species control inclusive of considering the impacts of dam operations upon seasonality of growth and preferential control methods etc. should be considered. Side Channel Reconnection/ Enhancement Opportunities: In the straightened and shortened channel of the Long Tom river below Fern Ridge dam, numerous historic side channels exist in various states of connectivity to the main channel as a result of how the channel was intentionally designed, deteriorating infrastructure, and/or natural processes. Opportunities exist to improve and restore habitat function in the lower Long Tom, while supporting the flood risk mitigation mission of the Fern Ridge project. Check Dam/ Drop Structure Review: Below Fern Ridge reservoir, three check dams attenuate the grade of the river to support the function of the straightened channel. These dams are barriers to resident native fish movement throughout the system and into tributaries, as well as to fluvial and anadromous fish from the Willamette. These structures are significant limiting factors to the health of our native fish including coastal cutthroat trout that are year round residents with numerous life histories in the watershed, and juvenile spring Chinook salmon that historically used the Long Tom as important rearing habitat and that are still present seasonally below the downstream most drop-structure in the city of Monroe. Fern Ridge Reservoir Fish Passage: Disagreement exists about the benefits and drawbacks of providing fish passage around Fern Ridge reservoir. Considerations including the harm in facilitating the movement of non-native fish above dam v.s. the benefits of providing greater connectivity for native species throughout the system is unclear. I would encourage an evaluation of the merits of providing both upstream and downstream fish passage at Fern Ridge. Floodplain Restoration as a Risk Mitigation Opportunity: I would encourage a thorough evaluation of the opportunities to address critical concerns of flood risk mitigation in balance with the opportunities and complimentary needs for floodplain habitat restoration. The EIS should include taking a critical look at the current paradigm to approaching flood risk management, in contrast with a cutting-edge view of the ecosystem services provided by a healthy and intentionally connected / inundated floodplain, and the efficacy in addressing both missions of flood control and habitat enhancement simultaneously. Ecological Flows: The Council encourages USACE to examine flow operations that protect infrastructure while balancing water quality and habitat needs for native species. Partnership Funding: The Corps should, where appropriate, seek to expand the opportunities for public/private partnership to leverage technical expertise and community engagement capacities of local partners, and simplify the process through which local Army Corps staff can direct discretionary funding to address critical needs and capitalize upon partnership opportunities locally. Tribal Engagement & Traditional Ecological Knowledge: The EIS should evaluate the role of Tribal governments, and indigenous knowledge holders in stewardship. While it is understood that guidelines exist for how and when recognized Tribes must be engaged in consultation for Corps operations and projects, it is less clear what opportunities and mechanisms exist to leverage and support the involvement of Native people in stewardship through public engagement and local contracting. Opportunities to support the efforts of indigenous peoples, through partnerships and support funding, should be evaluated. Specifically, the Corps should explore how its ecological mission for biodiversity and mitigating the impacts of Corps infrastructure can be strengthened through cultural diversity and the knowledge and skills held by Native peoples. The Council is also a member of the Willamette Mainstem Anchor Habitat Working Group (AHWG), a partnership of 16 Willamette Valley organizations committed to protecting and restoring ecosystem function. The AHWG works to support the vision laid out in the Willamette Restoration Strategy (2001). The vision aspires to attain “a dynamic balance between diverse human and ecological needs” and creating a place where “basin residents can live in healthy watersheds with functioning floodplains and habitats supporting a diversity of native species.” Each member of the AHWG plays a distinct role in achieving long-term restoration, conservation and stewardship along the historic meander and current channel of the Willamette River and its major tributaries. The AHWG collectively works to sustain and enhance seasonally important resources for native fish. This goal is accomplished, where feasible, through various means such as reforestation of floodplain forests, controlling priority invasive aquatic weeds, reconnecting the river to its floodplain, and enhancing and creating off-channel habitat. The Long Tom Watershed Council and AHWG have prioritized these activities because they are of ecological importance to economically and culturally significant ESA-listed salmonids and other native fish species of concern. This work also supports improved water quality, retention of floodwaters, and groundwater recharge while supporting habitats for a wide range of aquatic and terrestrial native species critical to the overall health of the Willamette Valley ecosystem. AHWG partners have been working for more than ten years along the Willamette River and its tributaries. It has made significant progress thanks to the collective efforts of agencies, organizations, and individuals. Much work remains and success can only occur with this continued regional collaboration. The Council encourages the USACE to incorporate in its scope evaluation how its operations can support creating a place where “basin resident can live in healthy watersheds with functioning floodplains and habitats supporting a diversity of native species.” There are many competing interests, and it will be incumbent upon the Corps to balance all those interests while maintaining strong, collaborative relationships with its partners. The Council encourages USACE to examine opportunities in its Willamette Bank Protection Program for revetments to be removed or modified where ecological benefits can be achieved with low risk to infrastructure. Identifying areas where river processes such as erosion and deposition can be restored will increase overall river health. Increasing the extent and duration of floodplain and off-channel habitats helps reduce the intensity, severity, and frequency of flooding, with short and long-term benefits for infrastructure located in harm’s way, and reduced costs to the state and federal governments in the long term. The USACE can also examine how it can develop a process to work with landowners when a revetment fails to determine if alternatives exist to replacement or reinforcement of the existing revetment. Local partners including the Long Tom Watershed Council exist to work with USACE and landowners if these situations arise. Thank you for the opportunity