The Problem With the Water Quality Data in the PGE Lower Deschutes River Report by R2 Consultants

Pic 1 R2 Report

The above report (published in March of this year), as noted in prior DRA blog posts, was of a two-year study of the lower Deschutes River. The purpose of the report was to determine the magnitude of biological changes in the river due to the implementation of surface water withdrawal at Round Butte Dam. A baseline study was conducted in 1999-2001, which Portland General Electric (PGE) summarized in a report published in 2002.

Both studies were contracted and paid for by PGE and were a requirement of the Federal Energy Regulatory Commission license to operate the Pelton-Round Butte dams.

The water quality data from the most recent study can be found on pages 47 and 48 of the 2014-2015 report. The results document violations of the basin and statewide water quality standards in both years of the study. The most egregious violations were of the pH standard as established in Oregon Administrative Rules (OARs) 340-041-0021 and 340-041-0135. The Deschutes Basin Standard for pH is a maximum pH of 8.5. A pH of 7.0 is neutral (neither acid nor alkaline, greater than 7 is alkaline).

The authors attempt to diminish these violations by noting on page 46 of the report that, “Regarding the unusually high pH measurements taken in Spring 2015, since these are uniformly high, even in the reference sites, it is highly likely that the meter we used was off in its calibration. Therefore, any in situ measurements taken should be considered preliminary at best, and compared to official measurements taken by PGE or agencies.”

There are many problems with this statement.

R2 Resource Consultants are self-proclaimed experts in water quality monitoring and modeling, so one has to wonder how and why they would be unable to produce accurate water quality data? Why would they have calibration problems? If their equipment wasn’t functioning properly, why wouldn’t they use backup pH measuring equipment? If they didn’t have backup equipment, why couldn’t they borrow equipment or have it shipped in via overnight express? The pH measurement problems they most specifically refer to occurred over several days in April of 2015. That should have been enough time to correct any equipment problems.

There were also very high pH measurements in the three days of sampling in April/May of 2014 (10 out of 12 lower Deschutes River sites were above the 8.5 pH water quality standard). Were their instruments faulty then too?

Or is this an attempt to discard and disregard data that are indicative of water quality problems?

There is another potential reason that the high pH values were recorded during spring sampling in both years. When algae bloom, it increases pH. It does this by absorbing CO2 from water to conduct photosynthesis. The by-products of photosynthesis are sugar and oxygen. Notably, the dissolved oxygen levels on the dates of the high pH levels were also high, with dissolved oxygen saturation levels reaching up to 138%. This occurs when there is excessive algal growth.

We have noted extensive algae growth in the lower river this year, starting in February. We have also recorded pH levels of greater than 9 in April and May 2016.

Algae, early March 2016. One mile below Pelton-Round Butte Reregulating Dam.

Algae, early March 2016. One mile below Pelton-Round Butte Reregulating Dam.

Algae, late March 2016. One mile below Pelton-Round Butte Reregulating Dam.

Algae, late March 2016. One mile below Pelton-Round Butte Reregulating Dam.

We are troubled by the lack of explanation for R2’s “calibration problem(s).” It is standard procedure to have a quality control plan that includes details for meter calibration and procedures if they fail calibration. At the DRA, we maintain a log for each instrument we own. Recorded in each of these logs are the calibration dates, times and results. All instruments are calibrated before each day of water quality sampling. We carry backup equipment.

In the case of our in-river dwelling data instrument, once a month we perform “field audits” where we cross check the data it produces with independent meters and manual techniques. We cross check the performance of our meters.

We have such a stringent quality control program because two of our field staff worked for the Oregon Department of Environmental Quality (ODEQ) for decades, doing water quality work. We exercise the same quality control methodology that ODEQ uses. We would suggest that PGE require the same of contractors doing water quality work.

DRA water quality staff at work:

Larry Marxer measuring dissolved oxygen in river water, using the Winkler method.

Larry Marxer measuring dissolved oxygen in river water, using the Winkler method.

Rick Hafele doing water quality measurements on Lake Billy Chinook.

Rick Hafele doing water quality measurements on Lake Billy Chinook.

Greg McMillan going old school on water quality measurements in 1979 (when old school was just school, or maybe pre-school).

Greg McMillan going old school on water quality measurements in 1979 (when old school was just school, or maybe pre-school).

Deschutes River Alliance: Cooler, cleaner H2O for the lower Deschutes River. 

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The Troubling Loss of Antocha Crane Flies

By Greg McMillan and Rick Hafele

Antocha Crane Fly. Photo by Rick Hafele.

Antocha crane fly. Photo by Rick Hafele.

Antocha is just one genus of the family Tipulidae, a group well known as crane flies. As crane flies go Antocha is rather small, and while most crane fly larvae live in slow moving or stagnant water with silty or muddy substrate (some are also terrestrial), Antocha larvae prefer riffle areas of streams with clean cobble substrate. This little crane fly is found throughout North America, including most if not all of the streams in the Deschutes watershed. Until recently it was one of the insects of the lower Deschutes River that appeared every summer in moderate to large numbers. Whether trout found it of interest could be debated, but its presence was one of those reminders that summer had arrived on the lower Deschutes – but no longer.

Rick Hafele and Greg McMillan first noted the absence of Antocha crane flies in the lower Deschutes River in July of 2013. Until that time these dipterids had been abundant in the lower Deschutes River. By the summer of 2013 other species of aquatic insects had also been observed to be in decline, but Antocha just seemed to have disappeared.

We waited until 2014 to confirm our 2013 observations regarding the missing Antocha before saying anything publicly. We reported our observations here in our blog, and then through the observations of others in our 2014 Lower Deschutes River Macroinvertebrate Hatch Activity Survey Results. Our reports regarding the missing crane flies were initially met with little interest, if not skepticism, by resource management agencies and the Pelton-Round Butte Dam operators, but then confirmed by the R2 Resources Interim Report in the Portland General Electric Aquatic Macroinvertebrate and Periphyton Study. The final report from that study also notes that the disappearance of the crane flies in the lower Deschutes River occurred after the inception of selective water withdrawal at Round Butte Dam.

Antocha crane flies mating and laying eggs in the lower Deschutes River before surface water withdrawal began at Round Butte Dam. Photo by John Hazel.

Antocha crane flies mating and laying eggs in the lower Deschutes River before surface water withdrawal began at Round Butte Dam. Photo by John Hazel.

The final report from the PGE Lower Deschutes Aquatic Macroinvertebrate and Periphyton Study also mentions studies done on the Crooked River and Middle Deschutes (Vinson, 2005; and Vinson and Dinger, 2007; Reports prepared for U.S. Department of the Interior, Bureau of Land Management, National Aquatic Monitoring Center) that showed declines in Antocha populations in those rivers. It is worth noting that those studies were done in the years prior to implementation of surface water withdrawal from Lake Billy Chinook at Round Butte Dam in late 2009.

The PGE study concludes that:

“… Antocha crane flies were widely distributed in pre-SWW samples above and below the project but nearly absent post-SWW from nearly all sites including the Deschutes and Crooked Rivers upstream from the project. Significant numbers were observed post-SWW only in the Metolius River, a unique spring-dominated system with minimal development compared to the Crooked and Deschutes systems. Most likely, this change is a result of a broader environmental pattern as opposed to project-related effect. It is unknown whether this pattern represents normal annual variability or a longer term (sic) trend. However, this observation highlights the value of the upstream study sites in distinguishing project from non-project changes.” (Final Report, Lower Deschutes River Macroinvertebrate and Periphyton Study, R2 Resource Consultants, 2016, page 100.)

That conclusion seems to be hastily arrived at, and appears to us to be biased towards exonerating dam operations as a contributor to the disappearance of Antocha in the lower river. Yes, studies show that Antocha crane flies have nearly disappeared from the Crooked and Deschutes rivers above the project, and that decline happened prior to surface water withdrawal from Round Butte Dam. Even though the loss of Antocha is still evident a decade after it was first reported, the PGE report suggests that this could be due to “annual variability.”

The study’s authors go on to suggest that the only other alternative is that this is due to a “broader environmental pattern.” Yet they state that the Antocha population is intact in the Metolius River.

In another aquatic invertebrate study of Whychus Creek, Antocha was found to be present from 2005-2014 (Mazzacano, Effectiveness Monitoring in Whychus Creek; Benthic Macroinvertebrate Communities in 2005, 2009, and 2011-2014, The Xerces Society for Invertebrate Conservation, page 58).

Whychus Creek is a tributary to the Middle Deschutes River. The confluence of Whychus Creek and the Middle Deschutes River is about three miles above Lake Billy Chinook. A great deal of habitat restoration work has taken place in Whychus Creek in recent years thanks to the work of groups like the Deschutes Land Trust, the Upper Deschutes Watershed Council, Trout Unlimited, and others. The Portland General Electric Pelton Fund, along with other sources, has provided funding for this work.

So in at least two other streams the Antocha populations are intact. It would be interesting to look at other streams in the basin to see what the status of Antocha is. We believe it was very hasty and preemptive to draw the conclusion that this is due to a “broader environmental pattern” when only limited data is available from other streams.

Basin studies show that the Middle Deschutes and Crooked rivers have large anthropogenic influences due to population centers and agricultural runoff. That in turn results in higher levels of nutrients that lead to algae growth. As noted in our 2015 Lower Deschutes River Macroinvertebrate Hatch Activity Survey Results, Antocha crane flies lay eggs in the splash zone of river rocks. Stalked diatom algae, which have become common in the lower Deschutes River since implementation of surface water withdrawal from Lake Billy Chinook, form a barrier to the bare rock Antocha seem to favor for reproduction in the lower Deschutes River. This probably makes egg laying impossible.

Stalked diatom algae covering splash zone of rocks in lower Deschutes River. Photo by Greg McMillan.

Stalked diatom algae covering splash zone of rocks in lower Deschutes River. Photo by Greg McMillan.

From mid-November until late May the water discharged from the Pelton-Round Butte Hydroelectric Project consists of 100% surface water draw from Lake Billy Chinook. Even during summer and fall months, there is a minimum of 35% surface water draw (Pelton Round Butte Project, FERC No. 2030, Water Quality Report, 2015). We know that for much of the year, surface water in the forebay of Round Butte Dam consists primarily of water from the Crooked and Middle Deschutes rivers (Deschutes River Alliance 2015 Water Quality Report and unpublished data from 2016, pending publication in 2017).

Given that Antocha crane flies disappeared from the Crooked and Middle Deschutes rivers prior to the institution of surface water withdrawal, and surface water withdrawal is heavily influenced by the water quality of these rivers, we believe that there is another hypothesis for the massive decline of Antocha in the lower Deschutes River. We propose that the causative agent of Antocha decline in those rivers is now being passed down into the lower Deschutes River as a consequence of surface water withdrawal at Round Butte Dam.

That cause could be any, or a combination, of several possible agents.

The first is the nutrients in surface water withdrawal at Round Butte Dam fueling the stalked diatom proliferation in the lower river, which is denying access to clean rock surfaces necessary for Antocha mating and egg-laying.

The second possible cause is that a pesticide or other agent entering the Crooked and Middle Deschutes Rivers is being transferred downstream in surface water from Lake Billy Chinook.

Antocha crane flies have also been found to be susceptible to parasitic infestations (International Review of Hydrobiology, Vol. 92. Issue 4-5, pg. 545-553, August 2007). This raises a host of issues that could possibly be related to the ecological changes brought by surface water withdrawal from Lake Billy Chinook. A parasite could have been transported to the lower river via surface water withdrawal at Round Butte Dam, or water conditions changed by surface water withdrawal, could now be favoring a parasite that has possibly infected Antocha.

How important is the disappearance of Antocha crane flies? That is hard to tell. However their disappearance from the lower Deschutes River, and the Crooked and Middle Deschutes rivers, should be taken as an indication of an ecological change. Their disappearance warrants deeper investigation and not just casual dismissal of a phenomenon that could be indicative of a larger ecological problem.

Deschutes River Alliance: Cooler, cleaner H2O for the lower Deschutes River. 

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DRA Audit Results — by Greg McMillan and Rick Trout

Photo by David Moskowitz

Here at the DRA, our audit firm, McDonald-Jacobs, performed a review of our finances following our first full year of operation.   We did this for several reasons. First, it is important to our board, our donors, and our constituents that we operate Deschutes River Alliance according to the highest financial standards as well as observing all laws and regulations governing nonprofit organizations. Second, as a new organization our board wanted to ensure that we have done everything necessary to create a fiscally sound and responsible organization that will have the financial strength to continue performance of our mission. Third, we want our donors to know how their money is being used. We are taking the unusual step of posting the financial and organizational review on our website. You can find it there under our “reports” tab. We believe we owe not just a debt of thanks and gratitude to our donors, but we also owe it to you to responsibly use your donations. We don’t want to just ask you to trust us with your donations, we want to prove we are using those donations responsibly. And we hope you’ll continue to support us.

Photo by David Moskowitz

DRA Files Comments on Pelton-Round Butte “Low Impact” Re-certification – by Greg McMillan

Deschutes River Alliance Files Comments in Low Impact Hydropower Institute Proceeding

Regarding Re-certification of the Pelton-Round Butte Project as a Low Impact Facility

Photo by Greg McMillan

Pelton Dam. Photo by Greg McMillan

On January 6, 2015, the Deschutes River Alliance (DRA) filed comments opposing the re-certification of the Pelton-Round Butte Dam Complex as a low impact hydroelectric operation. The Low Impact Hydropower Institute (LIHI) certifies dams that meet stringent standards for the production of clean renewable energy. Utility companies that obtain this certification are considered to meet state requirements for inclusion of clean energy in their power production portfolios. Utility companies that obtain this certification may also market higher priced “clean energy” packages to consumers (such as Portland General Electric’s “Green Source” package). LIHI certification guarantees that a dam operation has minimal impact on the river it’s located on, as well as the attendant fish and wildlife.

The basis for our position are the ongoing violations of Statewide Water Quality Standards and the requirements of the Water Quality Management and Monitoring Plan that are part of the operating license for the Pelton-Round Butte Project, which is owned by Portland General Electric and the Confederated Tribes of the Warm Springs Reservation.

We identified three matters in support of our opposition to the application:

  • A failure to meet the dissolved oxygen standard;
  • A failure to meet the pH standard; and
  • A failure to meet the nuisance phytoplankton requirements.

Our complete comments to LIHI are posted on our website.

We did not take this action without serious deliberation and consideration of its implications. We have discussed these issues with representatives of PGE for nearly two years. Despite evidence from us, and PGE’s own consultants, there has been no admission of problems in the lower Deschutes River. No plan has been presented to us, or to any government agency that we are aware of, to correct the problems we’ve identified. To date we have not seen evidence that PGE intends to act on these issues and feel compelled to take this step in the interest of the health of our river.

Our Year End Donor Report – Thank you for your Support!


2014 End of Year Report

The Deschutes River Alliance is pleased to announce the publication of our first Year End Donor Report.

One purpose of the Year End Report is to note our accomplishments since our inception in August 2013, particularly highlighting our 2014 Science Investigation and Work Plan.  The main purpose is to recognize our donors who generously supported the DRA in our first year.

You can view the report here.

The Report also has a message from DRA Board President Greg McMillan, a description of the scientific foundation for the DRA, our major accomplishments, a summary of our objectives for 2015, and a 2014 financial summary.  There is also a list of DRA donors who contributed to our work in 2013 and 2014 (through early November).

We are extremely grateful for your support in our first year of existence.

Since the publication of this Year End Report, the DRA has received additional support from many individuals whose names may not be on the Report, but are found on our website here.

If you have not donated before, now is a perfect time to support the DRA and our 2015 Science and Advocacy Work!

This is also the final few weeks to join the Founding Circle. The Founding Circle will be a permanent recognition of DRA supporters who donate $1,000 or more before January 1st.

Again, thank you for your support and best wishes for a healthy and productive 2015.

Warmly, and on behalf of the entire Board of Directors,


Greg McMillan

Board President

WHY IT MATTERS by Greg McMillan

The lower Deschutes River is monitored and managed by a complex ménage of government agencies, the Confederated Tribes of Warm Springs, and of course Portland General Electric.

So what does a group like the DRA have to add to the mix? Primarily this: we spend a lot of time in the lower river. Not on it, but in it. We wade it, we fish it, we float it, and we camp on it. And as anglers, we tend to pay attention. We also love it. It’s not just a river represented as numbers on spreadsheets indicating water quality results, flows, or biological inventories.

Instead, it’s part of our souls. Not one of my fishing friends and partners would ever trade the memories and experiences they acquired on the lower Deschutes for anything.

Photo by David Moskowitz

Photo by David Moskowitz

I personally grew up on the banks of the Deschutes. Having grown up in Bend, the river literally ran through my upbringing. My first kiss was on the banks of the Deschutes (seventh grade, the young lady and I snuck out of the Tower Theater, where our parents believed us to be, and we made out in Drake Park). My first near-death experience was in the Deschutes at the age of 19. My first casts with a fly rod, were of course on the Deschutes (at the age of 12). First fish on a fly? Also on the Deschutes. Learning about the complex web of life in a river, of course that happened on the Deschutes. First steelhead, well where else?

Photo by David Moskowitz

Photo by David Moskowitz

A group of friends and I did what I believe was the first paddle raft descent of lower Benham Falls in 1984. I don’t know of anyone having repeated that, in retrospect, foolhardy adventure. All I have to do is close my eyes and I can see that day as clearly as if it was yesterday. What an exciting day that was! It was a once in a lifetime experience to be sure.

I have two friends who have died, and whose ashes were scattered in the lower Deschutes River. Mine will probably be scattered there too.

Since I started fishing the lower river, I’ve lived in half of a dozen different cities or towns, and at least ten different houses, held multiple jobs, and had more than my share of girlfriends. That adds up to a lot of change. So in my life, the constant, the touchstone, has been the lower river canyon. When I launch from a boat ramp in my drift boat, there is always a sense of the canyon walls welcoming me back home. I feel more like myself there than anywhere else.

Photo by David Moskowitz

Photo by David Moskowitz

No scientific study can quantify any of this. But we have to do science to protect our river. No one else has the exact same connection to the river we do. Especially not government agencies, although I have fishing friends at agencies who love the river as much as any of us do. But they are often handcuffed by a lack of agency will, bureaucratic barriers, lack of funding, or conflicting agendas. So it’s up to us to care for a river we love. And we have to do that through science and advocacy.

In the words of Jeff Johnson, an adventure-seeking sailor and surfer who re-traces Yvon Chouinard’s epic 1968 trip to Patagonia:

“If you love a place you have a duty to protect it.  And to love a place you must know it first.”

Photo by Robert Sheley

Photo by Robert Sheley

So, why us? Why can’t agencies and others be blindly entrusted with protecting the river we love? Because they sometimes don’t care about it in quite the same way we do. Too many in responsible positions see the river as numbers on a spreadsheet. It’s a job. It’s projects and studies. It’s reports that always seem to need completion. It’s revenue. It’s regulations that need to be complied with or enforced. It’s megawatts of energy production.

To me, and my friends, the Deschutes River is home. And its loss would be unbearable to us.


Thank you for your continued support for the Deschutes River Alliance.

Greg McMillan

President of the Board



Where Have All the Crane Flies Gone?

Antocha crane flies have been a staple of summertime on the lower Deschutes all of the years I’ve fished the lower river. And that’s a lot of years (measurable in decades). I’d say how many years, but it would make me feel old, very old. Not as old as some of my friends and fellow anglers, but old.

Photo by Dave Hughes

An Antocha crane fly occupying its place in nature.

These small flies (of the order Diptera, family Tipulidae) are most typically seen perched on rocks in river water, occupying the wet surface of the rock where air and water meet. They are frequently seen to be doing push-ups as they mate and lay eggs. They are made available to fish when wave action sometimes washes them off of the rocks they occupy. I often imitated these flies with a size 16 or 18 pink bodied compara-dun, which simultaneously imitated pale morning duns, which hatched concurrently with the annual appearance of crane flies on the lower Deschutes.

Three years ago these small dipterids began to disappear on the lower Deschutes. It was one of the events that turned out to be a harbinger of things to come. This past summer, only two individual crane fly sightings (of one crane fly each) were reported to the DRA’s Rick Hafele through guide and angler-generated hatch observations. I personally spent nearly sixty days on the river doing fieldwork this summer, and saw none. In the past, I saw them by the thousands, perhaps even hundreds of thousands. At their peak activity, they literally rimmed wet river rocks that had any exposed surface above the water line.

We believe that their disappearance is linked to the nuisance algae that have so pervasively spread in the lower river. This photo demonstrates why:

Photo by Greg McMillan

Algae-rimmed rocks on the Deschutes.  Photo by Greg McMillan

Note that the water line is covered with algae. In the first picture, the rock surface is clean. In the second, algae obscure the wet rock surfaces. We are currently hypothesizing that the algae prevent the crane flies from either being able to occupy these rocky surfaces, prevent egg laying , or alter egg survival. We do know that the timing of the appearance of these nuisance algae is in line with the loss of crane fly populations in the lower Deschutes.

How important is this loss of Antocha crane flies? No one knows. But rarely is the unintended loss of a benign species a good sign.   We know that other aquatic insects have declined in numbers. Our aquatic insect hatch database confirms this (last years report, from our initial pilot study, can be found here).

In another month or so we will have the results of our water quality-monitoring project ready for release. The data are currently undergoing statistical analysis, and once this is complete, report writing will begin. Algae growth and proliferation like we are seeing in the lower Deschutes the past three to four years is a consequence of a change in water quality, specifically nutrient loading.

Watch this website and blog for news on what we found.

Greg McMillan