pH Violations in the Lower Deschutes River: Why it’s Happening, and Why it Matters

Round Butte Dam and the Selective Water Withdrawal Tower.

There’s been a great deal of focus on how Selective Water Withdrawal (SWW) operations at Pelton Round Butte have impacted temperatures in the lower Deschutes River. It’s hard not to focus on temperature: it’s something we can easily sense and monitor, and increased spring and summer temperatures have led to some alarming changes in the lower river these last few years.

But to understand the full extent of the ecological changes occurring in the lower river, there’s another criteria that’s perhaps even more important: hydrogen ion concentration, better known as pH. pH levels in the lower Deschutes River have increased dramatically since SWW operations began, and discharges from the Pelton Round Butte complex have routinely violated Oregon’s pH standard. Why is this happening, and how are these increased pH levels impacting the lower Deschutes River?

What is pH?

pH is a numeric scale used to indicate the acidity or basicity of a water-based solution. Pure water is neutral, with a pH of 7 standard units (SU). Solutions with a pH above 7 SU are basic (alkaline), and solutions with a pH below 7 SU are acidic. pH is measured on a logarithmic scale, meaning that a pH of 9 is ten times more alkaline than a pH of 8.

In freshwater systems like the Deschutes River, high pH levels are often the result of increased photosynthetic activity. This is because photosynthesis lowers the dissolved CO2 concentration in the water, which in turn reduces the carbonic acid concentration, which raises pH. As a result, high pH levels are a useful indicator of excessive algal growth and nutrient enrichment in freshwater systems.

Post-SWW Violations of Oregon’s pH Standard

Oregon’s water quality standard for pH in the Deschutes Basin is a minimum of 6.5 and maximum of 8.5 SU. This standard is designed to protect aquatic life from the harmful effects of water that is too acidic or too alkaline. While a pH above 8.5 is not lethal to aquatic life, it does not provide adequate protection; pH levels above 9.0 have been found to cause stress responses in rainbow trout, including sluggish movement, reduced feeding, and ammonia intoxication. High pH also indicates excessive algal growth in the river. The water quality certification for the Pelton Round Butte Complex mandates that discharges from the Project fall within this 6.5-8.5 range, to ensure that Project discharges comply with Oregon’s pH standard and that aquatic life in the lower river is adequately protected.

Since SWW operations began, Project discharges have routinely exceeded the 8.5 maximum standard. In 2016 alone, PGE’s own data show 140 days that pH levels rose above 8.5 at the Reregulating Dam tailrace.

While these numbers are alarming, downstream the problem appears to be even worse. In 2016, the DRA operated a data sonde one mile below the Reregulating Dam, collecting hourly readings for several water quality parameters, including pH, from February through November. Data collected at this site are summarized and analyzed in the DRA’s 2016 Lower Deschutes River Water Quality Report.

The pH data collected at this downstream sampling site are truly concerning. Of the 279 days sampled, 234 days had some pH measurements that exceeded the upper pH standard of 8.5. 120 of these days had pH measurements recorded above 9.0, and pH levels did not drop below 8.5 throughout April, May, and June. pH rose above 9.5 (remember, 10 times more alkaline than a pH of 8.5, and a hundred more times alkaline than a pH of 7.5) on two occasions: July 12 and October 14.

It makes sense that pH levels one mile downstream would be even higher than those in the Reregulating Dam tailrace. Increased algal growth in the river below the Project is increasing the amount of photosynthesis occurring in the river—this increased photosynthesis, in turn, continues to drive up pH levels downstream.

What do These Violations Mean, and Why are They Happening?

These newly elevated pH levels in the lower Deschutes River raise two important questions. First, what do these highly alkaline levels mean for the ecology of the lower river? As indicated above, in freshwater systems high pH levels are a strong indicator of excessive algal growth caused by nutrient enrichment. This will come as no surprise to anyone who has seen (or slipped on) the now-omnipresent nuisance algae blanketing the lower river’s rocks for much of the year. And such a high level of sustained pH poses definite stress and health risks to aquatic life including salmon, steelhead, and resident native trout.

Algae on rocks, one mile below the Pelton Reregulating Dam.

The next question that must be asked is: why is this happening? What is responsible for these elevated levels of pH? The only realistic answer appears to be the commencement of SWW operations.

Before SWW operations began in December 2009, discharges from the Pelton Round Butte Project did exceed Oregon’s pH standard from time to time. But these exceedances were relatively rare: PGE and the Confederated Tribes of Warm Springs, in their 2001 application for the Project’s water quality certification, identified only one instance between 1994 and 1999 where pH below the Reregulating Dam exceeded 8.5. In 2007-2009, the three years immediately before SWW operations began, PGE’s water quality reports show far fewer violations of the 8.5 standard.

Further, Oregon DEQ data collected at the Warm Springs Bridge from 2005-2015 show an immediate and sustained increase in exceedances of the 8.5 standard upon commencement of SWW operations.

Clearly, surface water releases through the SWW tower have had a significant impact on pH levels in the lower Deschutes River. This surface water originates in the Crooked River, the warmest of the three tributaries that enter Lake Billy Chinook, and the tributary with the highest nutrient concentration. As a result, more surface water release means more nutrients are transferred to the lower Deschutes River. This in turn has triggered a significant increase in the growth of periphyton algae in the lower river, which has increased photosynthesis, and pH levels along with it.

The encouraging news about these harmful pH levels is that the solution is right in front of us. To lower pH to levels that are again safe for the river’s aquatic life, the Project operators can significantly increase the percentage of water drawn from the bottom of Lake Billy Chinook. Doing so would slow the Project’s nutrient transfer to the lower river; this would be beneficial not only for pH, but also for the health and diversity of the lower river’s aquatic insect populations and the fish and wildlife that depend on them.

The Pelton Round Butte Project’s current pH violations are at the root of our Clean Water Act lawsuit against Portland General Electric. We’ll be working diligently this year to ensure that these violations—and their resulting ecological impacts—are addressed.


Wagner, E.J., T. Bosakowski & S. Intelmann (1997). Combined Effects of Temperature and High pH on Mortality and the Stress Response of Rainbow Trout after Stocking. Transactions of the American Fisheries Society. 126:985-998.

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How Healthy Are Lower Deschutes River Redband Trout? Read Steve Pribyl’s Letter to ODFW.

Lower Deschutes River redband trout. Photo by Brian O’Keefe.

Last week Steve Pribyl, retired ODFW biologist on the lower Deschutes River and DRA board member, sent a letter to ODFW Director Curt Melcher and to each member of the Oregon Fish and Wildlife Commission. The letter responds to recent ODFW assertions regarding the health and abundance of the lower Deschutes River redband trout population. Steve points out several critical misstatements from the agency that misrepresent the results of recent ODFW resident trout surveys. That letter can be read here.

As a brief summary, ODFW has performed electrofishing on the lower Deschutes River each April from 2014-2017 to capture and measure redband trout. After this year’s survey, an ODFW Field Report claimed there “is no indication the population has been adversely effected [sic]” by Selective Water Withdrawal operations, and that “Deschutes redband appeared to be in good abundance based on how easily [sic] they were to catch during this year’s monitoring.” SWW supporters have taken these statements and cited them repeatedly as evidence that the lower Deschutes redband trout population is as healthy and abundant as ever.

Obviously, we are all hopeful that the redband trout population below Pelton-Round Butte is healthy and abundant. However, as Steve explains, there is simply no way to know this based on the ODFW surveys performed to this point. These surveys have all been conducted to collect information on a few metrics, on a limited sample of trout, in only a few locations, at one point in time. This sampling is not designed to, nor is it capable of, estimating trout abundance and overall population health in the 100 miles of the lower Deschutes River. In fact, a 2016 ODFW field report specifically qualified the ability of these studies to assess trout abundance, stating “Abundance will not be evaluated due to the difficulty of accurately estimating trout abundance in large productive rivers like the Deschutes.”

Steve spent 20 years of his 30-year ODFW career on the lower Deschutes River, and performed many of the surveys that ODFW now claims to be “replicating.” In his view, ODFW’s statements on trout population health and abundance are extremely misleading, and are simply not supported by the survey data collected. We are disappointed that ODFW is making such unsupported statements, which are now being repeated by various Deschutes Basin stakeholders. And it is unfortunate that ODFW has not implemented adequate pre- and post-Selective Water Withdrawal monitoring studies to truly evaluate the population health of redband trout in the lower Deschutes River.

Lower Deschutes River Redband trout. Photo by Brian O’Keefe.

It is also unfortunate that such detailed studies were not mandated during the Pelton-Round Butte FERC relicensing process. At that time, ODFW had the authority to recommend various licensing conditions related to fish and wildlife. The agency did in fact recommend several such conditions, which were largely incorporated into the final FERC license. However, ODFW did not recommend that the licensees (PGE and the Confederated Tribes of Warm Springs) perform any type of baseline redband trout monitoring in the lower river, or any post-SWW follow-up monitoring to assess changes in population health and abundance below the Project. This was a missed opportunity: rather than requiring the licensees to monitor and assess redband health populations, any such studies must now be funded and performed by ODFW. The redband studies performed so far seem designed to minimize cost and staff time, rather than to make detailed, accurate assessments about the trout population.

We think it is also worth mentioning that in ODFW’s post-SWW reports on redband trout health, the agency has failed to mention the black spot disease epidemic currently being observed in the lower river. Any discussion of fish health in the lower Deschutes River right now must include the infections being regularly observed in caught fish. Given the high numbers of Black Spot-infected fish observed by anglers these last two years, it is highly unlikely that ODFW has failed to observe the disease in their surveys.

The ventral surface of a redband trout with black spot disease, caught in the lower Deschutes River in late April 2017. Photo by Jamey Mitchell.

In sum, it seems that native redband trout in the lower river have become a lower priority for the management agencies—and the Pelton-Round Butte licensees—than the salmon and steelhead being planted above the Project. This is truly unfortunate, as the lower river trout population is an incredible native resident resource, and much of the year is what draws anglers and others to the lower Deschutes River.

We urge you to read Steve’s letter.

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The DRA Position on Fish Reintroduction in the Deschutes Basin

Fish captured at Selective Water Withdrawal Tower being prepared for truck transportation around the three dams at the Pelton-Round Butte Hydroelectric Complex. Photo by Greg McMillan.

Fish captured at Selective Water Withdrawal Tower being prepared for truck transportation around the three dams at the Pelton-Round Butte Hydroelectric Complex. Photo by Greg McMillan.

A Portland General Electric (PGE) spokesperson recently stated that the Deschutes River Alliance is opposed to the reintroduction of salmon and steelhead above the Pelton-Round Butte Dam Complex. Here is the quote: “They [the DRA] want to go back to status quo prior to the selective water withdrawal system, and essentially to abandon the reintroduction effort for salmon and steelhead above the dams.”  The statement was made in the August 24, 2016 edition of The Source newspaper.

We are not sure what the PGE spokesperson was basing that information on. We have never stated that we want to “abandon the reintroduction effort.” His statement was erroneous and misleading. The DRA has regularly asserted our support for fish reintroduction – on our blog, at public events, and in various publicly disseminated documents.

The Deschutes River Alliance does support fish reintroduction as long as it doesn’t take place in violation of the Clean Water Act, or degrade the ecology of the lower Deschutes River and tributaries above the Pelton-Round Butte Dam Complex.

However, if the fish reintroduction goals are not attainable without serious negative consequences to other valuable resources, then the value of fish reintroduction needs to be reassessed. Unfortunately, what the PGE representative might have been trying to say is that PGE can only conduct fish reintroduction with the methods being currently employed. We believe that demonstrates a lack of willingness to adapt to conditions as they are. The concept of “adaptive management” is written into the dam license documents. To date all adaptive management efforts have been directed at reducing the water quality requirements for dam operation. Nothing has been changed; the goals have only been set lower. It is time to adopt alternatives that protect water quality while holding promise for even higher rates of fish reintroduction success.

Fish capture facility at the Selective Water Withdrawal Tower. Photo by Greg McMillan.

Fish capture facility at the Selective Water Withdrawal Tower. Photo by Greg McMillan.

At the present time, fish reintroduction efforts based on surface water withdrawal at the Pelton-Round Butte Complex are consistently violating the Clean Water Act. That is the basis of our lawsuit against PGE, an action we do not take lightly or without extensive research, analysis and careful consideration.

Further, selective water withdrawal and the resulting water quality violations have led to major changes in the ecology of the lower Deschutes River. These include changes in benthic algae, changes in aquatic insect hatches and populations, and changes in insectivore (insect eater) populations such as songbirds and bats. Warmer spring water temperatures due to surface water withdrawal are very likely responsible for a smallmouth bass invasion in the lower river. This year the Deschutes River at the mouth reached 60 degrees about 45 days before the Columbia River did, likely luring bass from the Columbia into the Deschutes.

The ecological impacts of tower operations are not limited to the downstream ecosystem. A recent report (Genetic Determination of Stock of Origin for Oncorhynchus mykiss Collected in the Upper Deschutes River Basin, Adams, DeHaan, et al, March, 2015) states that native redband trout have been all but extirpated from Whychus Creek. The cause cited is the genetic introgression of hatchery steelhead (planted for reintroduction purposes), which, once planted in Whychus Creek, failed to out-migrate and spawned with native redband trout. This has perhaps changed the redband trout genetics in Whychus Creek forever.

We strongly support the habitat rehabilitation work being done on Whychus Creek, McKay Creek, the upper watershed of the Warm Springs River, and the work being done in the upper reaches of Trout Creek. These are necessary efforts. These habitat improvement projects should take place irrespective of fish reintroduction for all the benefits this work provides. But the hatchery fish used for reintroduction purposes should not displace native resident fish.

Redband trout, lower Deschutes River. Photo by Brian O'Keefe.

Redband trout, lower Deschutes River. Photo by Brian O’Keefe.

Fish reintroduction efforts began in 2008 when juvenile fish were first planted in the tributaries to Lake Billy Chinook. To date, the results of the reintroduction effort have been less than successful. Numerical goals defining successful fish reintroduction contained in the Federal Energy Regulatory Commission license for the project have never been met, and we can see no likelihood that they will be.

PGE has claimed that they need more time. To do what? What is going to change in the next year or two that will result in enough juvenile fish migrating to the fish collection facility at Round Butte Dam (there to be trucked around the dams), or enough adults returning to the Reregulation Dam (to be trucked up to the reservoir), to meet the stated and defined goals of the reintroduction program?

Last year 32 sockeye salmon returned to the Pelton-Round Butte Hydroelectric Complex. Later analysis showed that only 3 of those fish originated from the dam complex. PGE claims that this year 400 sockeye have returned to the project. But how many of those fish are from out of basin or not otherwise part of the reintroduction program? Steelhead and Chinook salmon returns have been less than bountiful. Juvenile arrival numbers at the fish collection facility at Round Butte Dam would predict no improvement in adult fish returns for at least the next few years.

An objective audit of the fish reintroduction program needs to take place. We believe a major revamping of the reintroduction program is necessary if the program is to succeed and the serious unintended consequences of reintroduction are to be stopped.

The DRA has always supported fish reintroduction. But the fundamental requirements of the Clean Water Act must be upheld, and the Deschutes River’s ecology and resident species must not be sacrificed.

The reason that fish need to be reintroduced is because several major runs of anadromous fish were lost when the dams were constructed, blocking access to some of the most important spawning habitat in the Deschutes Basin. Let’s not compound that loss with a new generation of loss.

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Black Spot Disease Seen in Lower Deschutes River Fish

By Greg McMillan

We started receiving reports of “black spot” disease in lower Deschutes River bull trout a few weeks ago.  The first report was from Andrew Perrault from the Gorge Fly Shop in Hood River.  He sent along these photos and it is pretty easy to tell these black spots are not normal on bull trout.  Many of us know that bull trout are species Salvelinus and thus members of the char group.  These fish don’t have black spots as normal coloration.

Photo by Andrew Perrault.

Photo by Andrew Perrault.

Photo by Andrew Perrault.

Photo by Andrew Perrault.

Close up of lesions assumed to be due to black spot disease. Photo by Andrew Perrault.

Close up of lesions assumed to be due to black spot disease. Photo by Andrew Perrault.

Black spot disease on lower Deschutes River bull trout. Photo by Ryland Moore.

Black spot disease on lower Deschutes River bull trout. Photo by Ryland Moore.

Since that first report we’ve heard of other observations of black spot disease on both bull trout and red band trout.  The presence of black spot disease has been confirmed by sources at Oregon Department of Fish and Wildlife.

Black spot disease is caused by a flatworm (trematode) parasite known in the scientific community as Uvulifer ambloplitis, and also known as “neascus”.  This parasite has a complicated life cycle that starts with eggs in water, which hatch and become juveniles known as miracidia, which in turn infect aquatic snails.  In snails this form of the parasite matures into the next life form, known as cercariae.  Cercariae are shed by the snails and become free swimmers, which attach to fish.  Once the cercariae have attached to the flesh of fish, the fish develops an immune response that causes the dark spot.

Kingfishers are the next host, which become infected when they ingest infected fish.  The cercariae develop into adult flatworms.  The parasite then produces eggs, which are shed in feces by kingfishers, and deposited in water where the life cycle is reinitiated.

Black spot flatworm. Illustration by Bruce Worden.

Black spot flatworm. Illustration by Bruce Worden.

These flatworms do not appear to be fatal to fish, or other hosts.  There are scattered reports of fish stressed from other sources dying while infected.  No human infections have been reported, but there is no real surveillance mechanism to detect human infections.  Although probably safe for human consumption after thorough cooking, there are no study data to confirm that.

None of us who have fished the lower Deschutes River for decades can say that we’ve seen many, if any, fish with this condition.  There are reports indicating there have been infected fish in the lower Deschutes River and tributaries in the past, but they aren’t common.  So what has changed?  Is this random?  Or linked to the ongoing ecological changes we are all seeing in the lower river?

This might be related to an increase in the snail population in the lower Deschutes River.  Portland General Electric’s Year 1 Data Summary Report from their Lower Deschutes River Macroinvertebrate and Periphyton Report Study published in 2014, indicates that there has been a significant increase in snail populations in the lower Deschutes River.  This increase in population in the intermediate host (snails) might be related to the increase in black spot disease noted in fish.  The snail population increase is likely linked to the increase in algae in the lower river.

Is this a catastrophic occurrence?  Probably not.  But it could be another indication of ecological change in the lower Deschutes River.

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Saving It for Fall: An Exercise in Redundancy

It’s fall time.  Everything says it.  The weather has finally turned.  Leaves are red and gold on deciduous bushes and trees.  Nights are cool, most days too.  The calendar tells us that we are now well past the Fall Equinox.

Ok, so the evidence is in.  It’s fall.  Can anyone disagree?  Why even ask that question?

Because in a recent “public information” piece, Portland General Electric (PGE) states that cold water needs to be held back in Lake Billy Chinook during hot summer months, and to not do so “could create worse conditions for fish later in the year.”  Based on presentations and publications by PGE that we’ve seen, “later in the year” means the fall.  It implies the cold water is needed for arriving Fall Chinook, who begin to spawn within a short period of time after arriving in the lower Deschutes River.  The Fall Chinook, true to their name, are now in the lower Deschutes River.

So where is that cold water that PGE needed to hold on to last summer when it could have been used to cool an overly warm lower Deschutes?  Apparently still in Lake Billy Chinook.

Here is what discharge temperatures from the Pelton-Round Butte Dam Complex look like from August 1 until now:

Water temperatures at Madras gage, August-September, 2015. Source: USGS online.

Water temperatures at Madras gage, August-September, 2015. Source: USGS online.

Note that the average temperature being discharged has only dropped about one degree F.  Yes, a whole degree.  Now look at the lower river temperature near the mouth at the Moody gauge 100 miles below the dam complex:

Water temperatures at Moody gage, August-September 2015. Source: USGS online.

Water temperatures at Moody gage, August-September 2015. Source: USGS online.

What you are seeing is nearly a ten-degree drop in temperature since August 1.  That would be fairly typical fall time cooling, despite it being a warmer than usual fall.  So adding any cold water from the reservoir now is (dare we say this?) redundant.

We are grateful that PGE gives Fall Chinook spawning such a high priority.  We wish they’d do the same with native redband trout spawning.  Over the course of the past two years, PGE has engaged in rolling back the legally defined timeframe for cold-water fish spawning and incubation in the lower Deschutes.  Until recently, that period was defined as being from October 15 until August 1 of each year.  That period encompasses spawning times for all cold-water fish species in the lower river.  The defined spawning and incubation period also carries legal requirements under Oregon Administrative Rules for minimums for dissolved oxygen and maximum limits for water temperature.

PGE has been engaging with the Oregon Department of Environmental Quality in a systematic fashion, out of public view, to roll back the end point of the defined spawning time from August 1 to June 15 (and yes, we have solid evidence of that).  So now, between June 15 and August 1 of each year, water discharged from the dam complex can be warmer and have lower oxygen levels than prior to the change.

This photo was taken on July 30, 2015.  It is obviously a fresh redd, and is undoubtedly a redband trout red.  This unaltered photo was taken in the lower Deschutes River below the dam complex.  No spawning after June 15?   Say what?  Apparently the fish did not get the memo explaining that spawning and incubation now ends on June 15.

Photo by Greg McMillan.

Photo by Greg McMillan.

Why would PGE want to roll back the spawning period definition?  To make dam operations have less impact on the lower Deschutes?  Apparently not.  The problem at the dams is that the warmer the water is, the harder it is to maintain adequate levels of dissolved oxygen.  But why change operations when you can change the rules?

Now let’s address another statement in PGE’s “public information” piece.  It is stated that exposure to “direct sunlight” causes warming of the water released from the dam complex, and that “to reduce water temperatures slightly (our emphasis) at our project… (water) would just be warmed again by the time it arrived, 100 miles downstream.”

Fair enough.  The problem is that the sun doesn’t shine 24 hours a day.  The ambient canyon conditions are not the same throughout a 24-hour period.  We were recently, while analyzing thermal imaging data, able to track flows discharged from the dam complex during low light and darkness for up to 90 miles downstream.  The length of river cooled during those low light or nighttime flows can make up nearly the entire length of the lower river.

When fish are dying in the lower river, whether those fish are from the lower Deschutes or not, it’s time to not just facilitate “slight” water temperature reductions, but drop the temperatures as much as possible.  During the summer, the water at the bottom of Lake Billy Chinook is twenty degrees cooler than the surface water being used at the Tower; so much cooler water is available to discharge into the lower river.  Do we really want more heat related fish die-offs?  Or is it really better to save the cold water for fall time?

An article just appeared in The Drake magazine by Steve Hawley, author of the book, Saving a Lost River.  In the article he describes the bottom draw operation at Round Butte Dam that existed prior to construction of the Selective Water Withdrawal Tower as an “unnatural act, but one that anglers around the world came to appreciate.”  Yes we did.

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Lower Deschutes Redband Trout Harvest Rule Change Proposal Rescinded by ODFW

This past Monday, August 31, the Oregon Department of Fish and Wildlife issued a press release announcing that the proposed rule change that would have allowed harvest of two redband trout of 8 inches or longer per day on the lower Deschutes River, has been withdrawn.

Redband trout, lower Deschutes River. Photo by Brian O'Keefe

Redband trout, lower Deschutes River. Photo by Brian O’Keefe

This news has delivered a sense of relief to many longtime anglers on the lower river, many of whom responded with letters and emails to the OFDW Commission expressing their opposition to the proposed regulation change.  A number fly shops, guides and outfitters committed to not only sending in comments to the Commission, but had made plans to testify in Seaside on Friday, September 4 opposing the rule change.

Jon Belozer deserves special credit for sounding the alarm on the rule change.  Mark Bachman put a lot of time into making phone calls, writing emails, and was packing his bags to attend the Commission hearing.  John and Amy Hazel sent out emails to nearly 4,000 customers asking them to respond to the Commission’s proposal, and the Hazels were prepared to travel to Seaside to testify before the Commission.  John Smeraglio notified his customers and had them send in emails.  Brad Staples produced many emails to many contacts.   And I know that these business owners and guides were not alone.  Others contributed to the effort too.

The DRA wants to express our deep sense of gratitude to everyone who responded to the proposed rule change.  Our supporters stepped up and delivered when it was necessary.  Thank you for sending emails and writing letters.

We also want to express thanks to the staff at ODFW for recognizing the value the angling public places on conservation management on the lower Deschutes.  To those at ODFW involved in that process, thank you.  And on behalf of all of our supporters, we extend thanks to ODFW.

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Oregon Department of Fish and Wildlife Commissioners Considering Opening Lower Deschutes Trout Fishery to Kill for Fish Over 8 Inches

The Urgent Issue

On Friday, September 4, the ODFW Commissioners will be voting on a large package of angling rule changes created to “simplify” the Oregon fishing regulations.

One of the rule changes calls for opening up kill on redband trout in the lower Deschutes River.  Presently, there is a “slot limit” that only allows the take of 2 redband trout between 10 and 13 inches of length per day.  The new rule would allow the taking of any 2 redband trout over 8 inches per day.

Our position at the DRA is that if the Commission wishes to simplify the angling rules, the easiest thing would be to do away with any kill of redband trout on the lower Deschutes by making it a catch and release fishery with the required use of barbless hooks.  Now that would be simple!  Easy to understand, no measuring of fish would be necessary, and it would be easily enforceable.  Anything short of this deserves a deferral on decision-making to allow the public to provide input on rule changes.

You can support us in this by emailing the ODFW Commissioners at:

We are hoping that the Commission will receive at least 1,000 emails from those of us who love the lower Deschutes River.  Everyone who reads this needs to send an email.  Help us meet a goal of 1000 emails by sending one today!  Do it now!

You can find a summary of the proposed rule changes via this link:

ODFW 2015 Statewide Proposed Regulation Changes

For more information on the Commission and the upcoming meeting:

ODFW Commission Meeting Agenda – September 3 and 4, 2015 

Redband trout, lower Deschutes River. Photo by Brian O'Keefe.

Redband trout, lower Deschutes River. Photo by Brian O’Keefe.

Why Does ODFW Want to Open Up Kill of Redband Trout?

Part of the justification for proposing opening up kill on fish over 8 inches on the lower river is that the river “already has a catch and release culture.”   So the question would be why does ODFW want to use that as a justification for opening up kill?  This makes no sense.

As a matter of fact, this change could very well change the catch and release “culture” of the lower river by inviting in a harvest mentality, which would have the opposite effect suggested as a consequence of the rule change.

This could also have a long-term impact on the economy that has grown around the catch and release “culture” of the lower river.  We’ve done some first order approximations of the value of the lower river fishery (and will be commissioning a formal economics study in the near future).  We’ve determined that the lower Deschutes fishery is worth roughly $135 million per year (using American Sportfishing Association guidelines).  Trout angling is only a part of that total dollar amount.  But why does ODFW want to punish the businesses dependent upon the current angling practices on the lower river?

No one has proposed a biological benefit of the new rule opening up kill for redband trout over 8 inches that is based on data.  As a matter of fact, ODFW recently completed a study in which they claim the lower river redband trout population is healthy.  So why do they want to change trout harvest management?

It would appear that the proposed change is a heavy-handed measure without biological benefit.  So why?

“Simplifying” Angling Rules and a Possible Larger Agenda

It’s not just the Deschutes that is potentially impacted by the current rule change proposals.  The new “simplified” rules would have statewide impacts on many rivers and lakes.  Some of the rule changes would be positive, some have negative consequences for established fisheries, and some are frankly meaningless.  Opening high lakes prior to the opening of the roads to access them each year would have little or no benefit to many anglers, or to the fish.

Certainly the angling rules need some simplification.  The language used in many of the rules is confusing and hard to understand.  Some improvements are needed.  Clearer writing would fix many of the problems.

The rule changes have apparently been in the works for months.  There has been little or no effective notification of the public of the nature of this rule making process.  The public meeting wherein the rules will be adopted is being held the Friday of Labor Day weekend in Seaside.  There is probably no more difficult location to travel to on that date than Seaside.  In case you are interested in going, there are presently no hotel/motel rooms and no campsites available in the Seaside area due to the holiday.

Anyone wishing to testify on the proposed rules will be allowed three minutes to testify.  No one can testify on all of the proposed rule changes in three minutes!

If you try to find the proposed rule changes on ODFW’s website without the link provided above, good luck.  You won’t find the proposed rule changes using Google or the ODFW website search engine.  You have to dig to find them.  Why are the proposed rule changes being posted in a way that makes them obscure and difficult to access?  Why are they not being publicized via public media?  Why hasn’t there been email notification of effected constituencies?

We ask the Commission, please, defer voting on the present proposals until adequate opportunities have been created to obtain public input.  The public deserves to be heard on these matters.

Fishing the lower Deschutes River. Photo by Brian O'Keefe.

Fishing the lower Deschutes River. Photo by Brian O’Keefe.

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

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