The Oregon Stream Protection Coalition supports the staff recommendation to move forward with the “Modified Siskiyou Alternative,” but we further urge the Board to recognize that there is reason to be concerned about whether the Board is meeting its obligations to protect and monitor aquatic resources in Eastern Oregon.
Available information supports an equally pressing need for adaptive management attention to Eastern Oregon as to the Siskiyou. There is not sufficient evidence that reliance on voluntary measures alone is an adequate approach.
Many Eastern Oregon streams are impaired for parameters associated with forest practices: at least 68% of streams that pass through private forestlands in the Eastern Cascades region are listed for temperature/sedimentation/turbidity, and at least 64% for the Blue Mountains region. (EPA 2017).
We also know from research that stream temperatures in the Grande Ronde Basin of northeast Oregon are limiting overall summer density and abundance of juvenile steelhead and chinook salmon, that increased stream shade can produce significant reach-scale stream cooling that directly benefits salmonids, and that thermal refugia associated with cold tributaries and groundwater upwelling sites help sustain juvenile salmonids during the warmest hours of the day in midsummer. (Ebersole et.al. 2003). Overall, existing information indicates that: 1) under prevailing conditions, any loss of shade is likely to translate into lost fish population abundance and productivity, 2) warming of tributary streams resulting from forest thinning in near-stream areas likely harms salmonids in receiving waters, and 3) improvements in riparian shade cover can be expected to benefit salmonid populations.
The high resource risk associated with current stream protection rules in Eastern Oregon, particularly in a changing climate, justifies inclusion of these ODF regions in monitoring efforts as soon as resources allow. Regardless of when a monitoring program effort is initiated for eastern Oregon, we hope dialogue about these issues will continue at the Board level.
(1) Memo from Mary Scurlock to the Oregon Board of Forestry Re: Information relevant to the need for adaptive change to riparian protection on private forestlands in Eastern Oregon. 13 pp.
(2) EPA Region 10. 2017. Memorandum from Peter Leinenbach, R10 EPA to Alan Henning, R10 EPA Re: River distance associated with 303d segments with temperature/sedimentation/ turbidity listings within the Rogue/Siskiyou, and Blue Mountain assessment areas in Oregon. 3 pp.