Declining water quality and risks to endangered species are not “low impact.”

Recently, the Deschutes River Alliance officially opposed Pelton Round Butte Hydroelectric Project’s (PRB) Low Impact recertification by the Low Impact Hydropower Institute (LIHI).

DRA objected to the low-impact recertification because PRB fails to comply with water quality and threatened and endangered species protection. Failure to comply with either of these criteria alone is enough to prevent recertification. In addition to these shortcomings, there are serious concerns that PRB’s operation results in significant methane emissions. Before certifying the PRB Project as low impact, LIHI must ensure that the facility is not emitting these potent greenhouse gasses and negatively impacting global warming. Considering these shortcomings, we oppose any action to recertify PRB as a low-impact facility. 

The certification is awarded and managed by LIHI, a non-profit organization that was started in 1999. LIHI’s stated purpose is to set criteria and conduct a program to certify hydropower facilities that are low-impact, and make information about the impacts of hydropower available to the public. LIHI certifies hydroelectric facilities across the county and annual fees and application fees from the hydropower companies are the primary income sources for LIHI.

Certificate term ranges from 10 to 15 years and during that time, the facility is also subject to annual compliance reviews, mid-term reviews in some cases, and a recertification review at the end of the certificate term. The previous certification was influenced by the Oregon Department of Environmental Quality and the Oregon Department of Fish and Wildlife, public-funded state agencies whose purpose is to protect water quality and aquatic life. Despite the declining water quality in the lower Deschutes River and the ongoing threats to trout, steelhead, and salmon, DRA is not expecting any objection by DEQ or ODFW and the recertification will likely be approved.

Criteria

The Certified Low Impact hydropower projects or facilities must meet eight specific science-based environmental, cultural, and recreational criteria established by the LIHI:

1) Ecological flow regimes that support healthy habitats – Goal: Flow regimes in riverine reaches that are affected by the facility support habitat and other conditions suitable for healthy fish and wildlife resources

2) Water quality supportive of fish and wildlife resources and human use – Goal: Water quality is protected in water bodies directly affected by the facility, including downstream reaches, bypassed reaches, and impoundments above dams and diversions

3) Safe, timely and effective upstream fish passage – Goal: Safe, timely and effective upstream passage of migratory fish so that they can successfully complete their life cycles and maintain healthy populations in areas affected by the facility.

4) Safe, timely and effective downstream fish passage – Goal: Safe, timely and effective downstream passage of migratory fish. For riverine (resident) fish, the facility minimizes loss of fish from reservoirs and upstream river reaches affected by facility operations. Migratory species can successfully complete their life cycles and maintain healthy populations in the areas affected by the facility.

5) Protection, mitigation and enhancement of the soils, vegetation, and ecosystem functions in the watershed – Goal: Sufficient action has been taken to protect, mitigate and enhance the condition of soils, vegetation and ecosystem functions on shoreline and watershed lands associated with the facility.

6) Protection of threatened and endangered species – Goal: The facility does not negatively impact federal or state listed species. Facilities shall not have caused or contributed in a demonstrable way to the extirpation of a listed species. However, a facility that is making significant efforts to reintroduce an extirpated species may pass this criterion.

7) Protection of impacts on cultural and historic resources – Goal: The facility does not unnecessarily impact cultural or historic resources that are associated with the facility’s lands and waters, including resources important to local indigenous populations, such as Native Americans.

8) Recreation access is provided without fee or charge – Goal: Recreation activities on lands and waters controlled by the facility are accommodated and the facility provides recreational access to its associated land and waters without fee or charge.

Water quality and endangered species issues

The clearest instance of the significant impacts stemming from PRB operations is the water quality. The stated goal is to ensure water quality is protected in water bodies directly affected by the facility, which includes downstream waters. The standard further clarifies that if any water body affected by the facility has been defined as being water quality limited … the applicant must demonstrate that the facility has not contributed to the impairment in that water body. The lower Deschutes River temperatures are warmer both overall and for a longer period of time, dissolved oxygen (DO) levels do not support native fish’s biological needs, and the river’s pH levels exceed basin standards.

This decline in water quality is directly attributable to the installation and operation of the Selective Water Withdrawal (SWW) tower at Round Butte Dam. After more than a decade of operations and attempted adaptive management to avoid making minor changes to improve water quality, the PRB is not a Low Impact facility and it is unclear if the SWW tower will ever be able to meet the conditions promised by the operators when the project was relicensed to generate power. 

PRB’s negative impact to threatened and endangered species has roots back to when the dam was built and blocked off hundreds of miles of historically-used spawning and rearing grounds. Although the SWW tower installation was designed to improve opportunities for the currently listed bull trout and steelhead below and above PRB, the decline in water quality, and more than a decade of reintroduction efforts for these fish, as well as salmon species, the runs have essentially remained stagnant and far below sustainable, self-supporting, or harvestable runs. As a result, LIHI cannot recertify Pelton Round Butte as a Low Impact facility.

Methane emissions behind dams

Emerging science is bringing a new impact of hydroelectric dam operations to the attention of operators, regulators, and conservationists – methane emissions. Research out of Washington State University shows that hydropower reservoirs are a major source of human-caused methane emissions. Studies of dams in Oregon and Washington have found that reservoirs with high chlorophyll-a levels have heightened methane production and are likely to have significant methane emissions.

Globally, reservoir-originating methane emissions are a top-6 source of methane – on par with biomass and biofuel burning or global rice cultivation. PRB’s reservoirs seem to fit the necessary conditions to be considered a significant emitter of methane. Its two largest reservoirs – Lake Billy Chinook and Lake Simtustus have such high chlorophyll-a levels that they are listed as impaired in a DEQ report submitted to the EPA. While this emerging issue and its impacts do not neatly fit neatly into any current review criteria, LIHI should seriously consider the resulting impacts from methane emissions before facilities like PRB receive a low-impact certification.  

Collectively, these issues would seriously call into question any low-impact certification for the PRB and we encouraged LIHI to reject the recertification of the Pelton Round Butte Hydroelectric Project as a Low Impact Facility.

You can read our letter here – https://lowimpacthydro.org/wp-content/uploads/2023/01/Deschutes-River-Alliance-Comment-Letter-Pelton-Round-Butte-Recertification-Application-2023.pdf

You can learn about The Pelton Round Butte’s Low Impact recertification here https://lowimpacthydro.org/lihi-certificate-25-pelton-round-butte-project-oregon/ 

You can learn more about LIHI here https://lowimpacthydro.org/

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

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Finish 2022 By Supporting DRA Science And The River You Love

If you want to make a difference in the water quality issues facing the lower Deschutes River, make an end-of-the-year donation to the Deschutes River Alliance.

Nearly a decade ago, after a group of concerned guides and anglers experienced extreme changes on the lower Deschutes River they formed the Deschutes River Alliance. Led by the best available science the DRA has advocated for the river. The DRA continues to be the only organization advocating for improved water quality on the lower Deschutes River.

In the past year, that advocacy has included being a voice for protecting aquatic life across the state of Oregon via DEQ’s aquatic life rulemaking process and pressuring the Oregon Environmental Quality Commission to take on action on the issues facing the lower Deschutes River. You can read more about those efforts in our year-end recap.

DRA is the only organization raising the alarm about the pH levels in the lower Deschutes River. Our 2022 data shows that yet again the levels have been dangerously high and in violation of the standards set by the state. 

In addition, the DRA is the only NGO advocating for cooler water in the river to protect spring Chinook Salmon. The current operations of the Pelton Round Butte Hydroelectric project and the resulting temperature profile creates a lethal environment for this important wild fish.  

DRA is expanding our data collection in 2023. We are raising $80,000 for the equipment, software, and support to add another monitoring station in Maupin and upgrade all our stations to allow for the real-time transmission of water quality data to our website. 

The additional monitoring station and real-time data will also help us highlight the ongoing water quality issues, create more frequent reports on the river’s health, and expand our comprehensive annual water quality report. Next spring when you get ready to head out for a day of fishing you will be able to get information about the river from that day – water temperature and fishing reports will give you an edge when choosing which flies to bring.

To those who have already donated to the DRA this year, we say “Thank You!” If you haven’t we encourage you to donate to the DRA as we continue to advocate for cooler, cleaner H2O for the lower Deschutes River.

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

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Only the DRA is Advocating for Tower Changes Spring Chinook Need

Now more than ever, the Deschutes River Alliance is the strongest voice of the lower Deschutes River and the only organization fighting for tower changes that improve water quality and benefit native fish in the lower Deschutes River.

For the past six months, I have represented DRA in a stakeholder process convened by the owners of the Pelton Round Butte Hydroelectric project and the Selective Water Withdrawal (SWW) Tower that releases water into the lower Deschutes River.

This stakeholder group includes the operators, state agencies and organizations focused on native fish and water quality, with the premise “to identify cold water release scenarios that could be modeled for the lower river,” and benefit native fish.

At the November meeting, I asked the operators of the dam complex to test a scenario, outlined in their own water quality study, that would improve water quality in the lower Deschutes River. The suggestion was met with silence. Other attendees instead chose to assert that current operations, and the temperature profile, benefit aquatic life – a false assertion that risks the survival of the iconic wild spring Chinook salmon from poor water quality and the deadly Ceratanova shasta parasite.

The reintroduction steelhead and spring Chinook was a key requirement for the relicensing of the Pelton Round Butte Hydroelectric project and the impetus for the (SWW) tower. The tower was sold as a way to collect salmon and steelhead smolts migrating downstream through Lake Billy Chinook (LBC) during the spring. Since the smolts migrate in the upper water column of LBC, the flow to the tower’s surface inlet would attract the smolts and they would be funneled into a collection facility near the tower inlet. This surface water is also warmer and the majority comes from the Crooked River, which has the poorest water quality of the three main tributaries feeding LBC. As a result, when the majority of water flowing into the lower Deschutes River is from the surface, it is both warmer and the poorest quality water.

History of C. shasta

Although C. shasta has always existed in the lower Deschutes River, as has its aquatic worm host organism, C. shasta was not thought to be a significant problem. However, very high pre-spawning mortality of wild adult spring Chinook in the Warm Springs River starting in 2014 was a sign that C. shasta was becoming a serious problem. Studies have found that both juvenile and adult Deschutes River Chinook were dying prematurely, with C. shasta the suspected cause.

Prior to the SWW tower operations, water released into the lower Deschutes River was primarily from the bottom of LBC and was cooler and cleaner. The SWW tower introduced the warmer, poorer quality surface water over a much longer period of time, including the winter, and both PGE’s data, as well as DRA’s data, show very large increases in the number of host worms and parasite. 

Lifecycle of the Ceratanova shasta parasite https://microbiology.oregonstate.edu/deschutes-river

Infection of salmon by C. shasta occurs at levels of 10 spores/liter of river water. Research by Oregon State University and the Oregon Department of Fish and Wildlife have measured spore counts many times that amount in the lower Deschutes River as far downstream as the Oak Springs area during the spring months. This implies that downstream migrating juvenile spring Chinook smolts as well as upstream migrating adults are exposed to C. shasta at lethal levels. 

In studies using juveniles caged in the lower Deschutes River, as many as 87% of some groups showed infection and subsequent high mortality by C. shasta. The prevalence of infection and subsequent mortality increased with increasing water temperature, clearly suggesting that warmer water in the spring during juvenile spring Chinook outmigration is an important mortality factor effecting the survival of these fish.

The adult spring Chinook migrate up the lower Deschutes River during spring are exposed to C. shasta infection and mortality as well as an increased pre-spawning mortality throughout their range.

Risks to Wild Spring Chinook

The wild spring Chinook are especially at risk. More than 40 years of research has established that a spawning population between 1,000 and 1,300 adults is needed to maintain a healthy population of these fish. The same research shows that nearly all wild spring Chinook in the Deschutes use the Warm Spring River for spawning and juvenile rearing. A barrier dam and trap at Warm Springs National Fish Hatchery makes it possible to accurately count upstream migrating adults with precision and later spawning ground counts can later measure the success of these adults which makes it possible to monitor pre-spawning mortality.

A common measure of pre-spawning mortality in anadromous fish including spring Chinook, is the number of fish it takes to construct one successful redd or spawning bed.  A fish/redd ratio of between 3 and 4 is commonly believed to indicate acceptable pre-spawning mortality.  In fact, the long-term data set below shows that prior to increased water temperature and nutrient input (and subsequent increases in the host organism for C. shasta and spore counts) that 4 adults/redd was the average.  After SWW tower operation started in 2010, however, the number of adults required to construct one redd shot up to in some cases over 20 adults/per redd.  This strongly suggests a seriously high adult pre-spawning mortality and it is very likely, based on the timing of this change alone that SWW tower operation is the cause of C. shasta infection of adults on their way to the spawning grounds in the Warm Springs River.

Fish per redd in WSR basin, 1977 – 2018. From Confederated Tribes of the Warm Springs Reservation Estimation of the Effective Number of Breeders for Warm Springs River Spring Chinook Salmon – Broodyears 2015 and 2016. Authors: Peter F. Galbreath and Ilana Janowitz-Koch
https://critfc.org/wp-content/uploads/2021/08/18-04.pdf

It should come as little surprise that the number of wild adult spring Chinook returning to the Deschutes has plunged to record low levels recently. Adult counts at the Warm Springs National Hatchery have fallen to a small fraction of the minimum target number of 1,000 and both sport angling and tribal harvest at Sherars Falls have been severely constrained due to low returns. In fact, wild spring Chinook returns have been so low that a significant portion of the wild adults have been kept and spawned at the hatchery as an emergency measure against the extinction of the population. 

The current plight of the wild spring Chinook in the lower Deschutes is another and very serious example of the damage that current SWW tower operations are doing to the river. It is difficult for DRA to accept that other stakeholders will not support our well-reasoned and thoughtful call for operational changes in SWW operation that would benefit not only spring Chinook but all native fishes in the lower Deschutes.

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

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