HomeMy WebLinkAbout2009-10-21 Work Session MinutesC ENTRAL OREGON ESA RISK EVALUATION
SUMMARY: FINDINGS AND
RECOMMENDATIONS
P REPARED FOR:
Central Oregon Intergovernmental Council (COIC)
Redmond, OR
Contact: Katrina Van Dis
P REPARED BY:
ICF Jones & Stokes
317 Alder Street, Suite 800
Portland, OR 97204
Contact: John Runyon
503/248‐9507 x300
September 2009
ICF Jones & Stokes. Central Oregon ESA Risk Evaluation: Summary and Key Findings. September.
(ICF J&S Project 00885.08.) Portland, OR. Prepared for COIC, Redmond, OR.
Central Oregon ESA Risk Evaluation:
Summary of Findings and Recommendations ES‐1 September 2009
ICF J&S 00885.08
Executive Summary
Steelhead trout, which are listed as threatened under the Endangered Species Act (ESA), are being
reintroduced into the Upper Deschutes River Basin (Upper Deschutes Basin). The cities and
counties of central Oregon (the jurisdictions) are evaluating whether current local government
policies and practices are sufficiently protective of steelhead and their habitat and reduce the
potential of ESA‐related enforcement actions.
The Upper Deschutes Basin jurisdictions participating in this evaluation include Crook, Deschutes
and Jefferson counties, and the cities of Bend, Prineville, Redmond, and Sisters. The cities and
counties want to support successful reintroduction efforts and enhance the environment and
achieve regulatory predictability and protection from take liability.
The report describes the status of ESA‐listed steelhead in the Upper Deschutes Basin and outlines
ICF Jones & Stokes’ evaluation of the jurisdictions’ policies and practices to determine their potential
for take of listed steelhead. Land use planning, stormwater management, herbicide and pesticide
management, and routine road maintenance operations are evaluated for all the jurisdictions.
Municipal water diversion, groundwater withdrawal, and wastewater discharge is examined for the
participating cities.
The Middle Columbia River steelhead were ESA‐listed in 1999, and the listing was revised in 2006 to
delineating only anadromous steelhead (meaning those that spend part of their adult period in the
ocean) and not the resident form (i.e., rainbow trout). The Oregon Department of Fish and Wildlife
(ODFW) has developed a draft Conservation and Recovery Plan for Oregon steelhead populations in
the Middle Columbia River steelhead population segment, including the Upper Deschutes Basin
populations. The plan establishes a nonregulatory framework for implementing strategies and
actions to recover steelhead populations.
The dams that were constructed on the mainstem Deschutes River in the late 1950s and early 1960s
cut off the migration routes of steelhead and salmon to the Upper Deschutes Basin. With the recent
federal relicensing of the dams, the co‐owners of the dams—Portland General Electric and the
Confederated Tribes of Warm Springs—are developing facilities for fish bypass. In anticipation of
the bypass facilities, juvenile steelhead were released into Whychus Creek beginning in 2007 and
the Crooked River basin in 2008. The National Marine Fisheries Service (NMFS) is pursuing
rulemaking to designate the steelhead above Pelton Round Butte Hydroelectric Project as an
“experimental population” under section 10(j) of the ESA. During the period when experimental
population is in effect, the Upper Deschutes Basin population would be treated as proposed for ESA
listing, no critical habitat would be designated, and the rule will provide limits to ESA legal liability.
Findings and Recommendations
The risk exposure to ESA enforcement actions or third‐party lawsuits enforcement actions resulting
from the jurisdictions’ policies and practices is evaluated based on the application of best
management practices (BMPs) and the presence of steelhead trout in the affected waterways. The
evaluation was informed by guidance on BMPs that has already been developed to assist local
governments in the modification of their activities to comply with ESA requirements for salmon and
steelhead.
In areas of the cities or counties that contain waterways where steelhead trout are (or will be)
reintroduced, the jurisdiction has more ESA risk because its policies and practices can impact water
quality and riparian habitat that has direct pathways to portions of the system where fish are
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present. In the City of Bend and the counties upstream from steelhead trout‐bearing portions of the
Upper Deschutes Basin, it is difficult to directly link the activities to steelhead trout population
effects or modifications to aquatic habitat. Because there are more limited pathways in these
upstream areas that can affect steelhead trout populations or aquatic habitat, there is less
ESA‐related risk. For the City of Redmond, the ESA‐related risk is further reduced because there are
no steelhead present in the city or direct pathways to waterways were steelhead are or could be
present.
If a jurisdiction does not authorize or participate in high‐risk activities such as water diversions,
there is minimal risk that the jurisdiction’s activities could directly cause steelhead trout mortality.
For the most part, the jurisdictions are applying BMPs in a manner that protects ecological
processes and water quality that support steelhead trout populations. Correct application of the
BMPs limits potential that the jurisdictions’ policies and practices can affect steelhead trout or
aquatic habitat.
There are, however, policies and practices that can be improved through programmatic adjustments
to further minimize the exposure to ESA risk and enhance environmental benefits. Important areas
for improvement include riparian, floodplain development, stormwater management and sediment
control. Table ES‐1 outlines the recommendations for the six categories of activity identified for
evaluation.
Table ES1. Recommended Actions to Reduce ESARelated Risk from the Participating Cities and
Counties Policies and Practices
City or County Policy or Practice Recommendation
Land Use The jurisdictions should consider mapping and, where appropriate,
protecting channel migration zones. This effort should be
coordinated across the cities and counties.
The jurisdictions should consider comprehensively inventorying and
mapping all riparian areas to provide information for critical
resource areas. This effort should be combined with mapping
channel migration zones and coordinated across the jurisdictions
The jurisdictions should review recent NMFS floodplain development
guidance and determine how best to implement the
recommendations so as to avoid, minimize, and/or mitigate impacts
on floodplain habitat.
Stormwater Management The participating cities and counties are revising the Central Oregon
Stormwater Manual (COSM). The jurisdictions should consider
adopting the revised COSM, and should formally encourage the
implementation of low‐impact development techniques that
promote impervious surface reduction, on‐site retention of
stormwater, minimize clearing of native vegetation, and provide
erosion and sediment control BMPs.
The jurisdictions should consider developing and adopting
stormwater master plans and developing stormwater utilities that
could provide permanent, dedicated funding for stormwater
program implementation, monitoring, enforcement, and reporting.
Pest Control The jurisdictions should be aware of, and if necessary apply, the
current application BMPs and guidance from NMFS.
Routine Road Maintenance Because the Oregon Department of Transportation (ODOT) Routine
Road Maintenance Water Quality and Habitat Guide has been
adopted by NMFS under the 4(d) rule for salmon and steelhead
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City or County Policy or Practice Recommendation
trout, all of the jurisdictions should formally incorporate or adopt
procedures from the document to guide the implementation of road
maintenance procedures.
Surface/Groundwater
Withdrawals
The cities engaged in surface water withdrawals where steelhead are
present should follow NMFS BMPs and certification for fish screens.
Wastewater Discharge No recommendations are listed for this category.
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Contents
Page
Executive Summary ................................................................................................................... 1
Findings and Recommendations ......................................................................................... 1
Introduction ........................................................................................................................... 1
The Endangered Species Act ..................................................................................................... 1
ESA Status of Middle Columbia Steelhead Trout ...................................................................... 2
Deschutes River Steelhead ESA Status and Reintroduction Efforts ................................... 3
Steelhead Biology and Factors Contributing to Decline ..................................................... 7
ESA Risk Evaluation Approach and Results ............................................................................... 9
Watershed Context and Steelhead Presence Distribution ............................................... 11
Land Use ................................................................................................................... 13
Stormwater Management ................................................................................................ 14
Pest Control ................................................................................................................... 15
Routine Road Maintenance .............................................................................................. 15
Surface and Groundwater Withdrawals ........................................................................... 15
Wastewater Discharge ...................................................................................................... 16
Conclusions and Recommendations ....................................................................................... 17
References ......................................................................................................................... 19
Appendix A. COIC Endangered Species Act Liability Risk Assessment
Tables
On Page
Table ES-1. Recommended Actions to Reduce ESA-Related Risk from the
Participating Cities and Counties Policies and Practices ........................................ 2
Table 1. Essential Physical and Biological Features Necessary to Support
Steelhead Populations and the Associated Life Stages ........................................... 8
Table 2. How Evaluated Activity Categories Could Affect Key Factors
Impacting Steelhead Populations and Habitat ........................................................ 9
Table 3. Recommended Actions to Reduce ESA-Related Risk from the
Participating Cities and Counties Policies and Practices ...................................... 18
Figures
On Page
Figure 1. Reintroduced Steelhead Range of Distribution ....................................................... 6
Figure 2. Seasonal Occurrence of Deschutes River Summer Steelhead in
Freshwater by Life History Stage ........................................................................... 7
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Acronyms and Abbreviations
BPRD Bend Parks and Recreation District
BMPs best management practices
COSM Central Oregon Stormwater Manual
DEQ Department of Environmental Quality
DPS distinct population segments
EPA U.S. Environmental Protection Agency
ESA Endangered Species Act
FEMA Federal Emergency Management Agency
jurisdictions cities and counties of Central Oregon
MRCI Municipal, Residential, Commercial and Industrial
NMFS National Marine and Fisheries Service
NOAA National Oceanic and Atmospheric Administration
ODA Oregon Department of Agriculture
ODFW Oregon Department of Fish and Wildlife
Recovery Plan The Middle Columbia River Steelhead Conservation and
Recovery Plan
Upper Deschutes Basin Upper Deschutes River Basin
USGS U.S. Geological Survey
WSDOT Washington State Department of Transportation
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Introduction
Steelhead trout, which are listed as threatened under the Endangered Species Act (ESA), are being
reintroduced into the Upper Deschutes Basin. The cities and counties of Central Oregon (the
jurisdictions) are evaluating whether current local government policies and practices are
sufficiently protective of steelhead and their habitat. Specifically, the jurisdictions desire to avoid
the “take” of reintroduced steelhead, and reduce the potential of ESA‐related enforcement actions
and third‐party lawsuits.
The Upper Deschutes Basin jurisdictions participating in this evaluation include Crook, Deschutes
and Jefferson Counties, and the cities of Bend, Prineville, Redmond, and Sisters. The jurisdictions
seek to proactively respond to the reintroduction of steelhead by participating in ESA certification of
practices or addressing issues through programmatic steps. The cities and counties want to support
successful reintroduction efforts and enhance the environment, as well as achieve regulatory
predictability and protection from take liability. A review of local government policies and practices
can inform city and county decision making and strategies for conserving steelhead in the Upper
Deschutes Basin.
This report describes the status of ESA‐listed steelhead in the Upper Deschutes River Basin (Upper
Deschutes Basin) and outlines ICF Jones & Stokes’ evaluation of the jurisdictions’ policies and
practices to determine their potential for take of listed steelhead. Land use planning, stormwater
management, herbicide and pesticide management, and routine road maintenance operations are
evaluated for all the jurisdictions. Municipal water diversion, groundwater withdrawal, and
wastewater discharge is examined for the participating cities. The evaluation was informed by
guidance that has already been developed to assist local governments in the modification of their
activities to comply with ESA requirements for salmon and steelhead. The report concludes with
recommendations to improve the jurisdictions’ policies and practices to better protect steelhead
populations and habitat.
The Endangered Species Act
In 2000, the National Marine and Fisheries Service (NMFS) adopted a rule prohibiting take of a
number of selected Pacific Northwest salmon and steelhead populations, including Deschutes River
Basin populations, listed as threatened under the ESA. NMFS’ 4(d) Rule for Threatened Salmon and
Steelhead on the West Coast establishes a prohibition on the take of any individual member of one of
the salmon and steelhead covered by the rule (NMFS 2000). The term "take" is defined by the ESA
to mean "to harass, harm, pursue, hunt, shoot, trap, capture or collect, or to attempt to engage in
such conduct." As related to take, the term "harm" is defined by administrative rule to include
"significant habitat modification or degradation where it actually kills or injures fish or wildlife by
significantly impairing essential behavioral patterns, including breeding, spawning, rearing,
migrating, feeding or sheltering."
The ESA provides a variety of tools for restoring steelhead populations threatened with extinction
(NMFS 2000). When the activities of state and local governments and private citizens harm listed
species, section 4(d) requires that harm be controlled so it does not lead to extinction. Section 4(d)
requires NMFS to issue regulations deemed “necessary and advisable to provide for the
conservation of the species.” The 4(d) rule can “limit” the take prohibitions by providing exceptions
to take so long as the take occurs as the result of a program that adequately protects the listed
species and its habitat.
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Activities carried out in accordance with 4(d) rule limits can help protect threatened species and
their habitats while relieving government agencies and other entities from liability for take resulting
from those activities. In NMFS' view, the limits are justified where the described program or activity
is "specifically tailored to minimize impacts on listed threatened salmonids to an extent that makes
additional Federal protections unnecessary for conservation of the listed species" (Filippi 2000).
The final NMFS 4(d) rule for Pacific Northwest salmon and steelhead sets 13 limits on take. The
limits cover a number of activities and programs including, emergency actions related to rescuing
or salvaging injured, stranded, or dead salmonids; fishery management activities, when the activities
are specifically tailored to meet certain criteria; and artificial production activities, including the use
of listed salmon or steelhead in hatchery operations.
Included in the 4(d) rule are three limits that are particularly important for evaluating the
jurisdictions’ activities:
1. Properly screened water diversions. According to NMFS, unscreened or improperly screened
water diversions can lead to the stranding of juvenile fish in diversion ditches, the impairment
of juvenile and adult migration behaviors, the entrainment of juveniles in pumping facilities, and
the impingement of fish on screens. The two basic requirements are written screen certification
by NMFS and access for inspection purposes.
2. Routine road maintenance activities in Oregon. The take prohibitions do not apply to road
maintenance activities (other than herbicide and pesticide spraying or dust abatement), so long
as the activity is covered by and conducted in accordance with the Oregon Department of
Transportation's (ODOT’s) Routine Road Maintenance Water Quality and Habitat Guide
(Routine Road Maintenance Guide) (1999; updated 2004). From NMFS’ perspective, the Routine
Road Maintenance Guide provides adequate safeguards for listed salmon and steelhead,
including ongoing and extensive training requirements for work crews; annual reporting of
program implementation; and ongoing coordination with NMFS staff. Significantly, the Routine
Road Maintenance Guide is also available to any state, county, city, or port, or any employee or
agent of those entities, once they have demonstrated in writing that their routine road
maintenance activities are equivalent to the ODOT document.
3. Certain Municipal, Residential, Commercial and Industrial (MRCI) Development and
Redevelopment Activities. In an effort to streamline ESA compliance, the take prohibition is
not applied where the MRCI development is governed by and conducted in accordance with
local ordinances that NMFS has reviewed and approved. This approach also shifts the burden of
developing conservation measures to local jurisdictions. The limit focuses on specific land
development issues and program implementation, including storm water discharge; riparian
buffers; stream crossings; streambanks; impacts on wetlands and surrounding vegetation;
erosion and sediment runoff during and after construction; monitoring; funding; and
enforcement.
ESA Status of Middle Columbia Steelhead Trout
Historically, Middle Columbia River steelhead trout (Oncorhynchus mykiss) spawned and reared in
nine major tributaries and smaller streams draining the east side of the Cascades Mountains in
central Oregon and south‐central Washington. By the late 1900s, Middle Columbia steelhead
populations had experienced significant declines in abundance as a result of loss or change to their
natural environment. In 1999, the National Oceanic and Atmospheric Administration’s (NOAA’s)
NMFS listed the Middle Columbia steelhead populations as threatened under the ESA. The ESA
listing included both anadromous and resident forms of the biological species. The anadromous
forms spend a portion of their life in the Pacific Ocean before returning to spawn in rivers and
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tributary streams. The resident form (i.e., rainbow trout [Oncorhynchus mykiss]) spends its entire
life within the river or tributary stream system and does not migrate to the ocean.
The Middle Columbia River steelhead ESA listing was developed in response to a biological review
which concluded summer steelhead in the Middle Columbia River basins were “likely to become
endangered in the foreseeable future” (NMFS 1999). The most primary factors leading to NMFS’
conclusion that Middle Columbia River steelhead were threatened included:
z declines in abundance of wild steelhead populations and levels of abundance well below historic
levels;
z large numbers of hatchery steelhead relative to wild steelhead, and little information regarding
the impacts of hatchery steelhead on wild steelhead populations throughout the region;
z limited information regarding the interactions between resident rainbow trout and anadromous
steelhead; and
z habitat alterations in the region’s rivers and streams resulting in a loss of spawning and rearing
habitat for steelhead, including habitat changes which have exterminated some steelhead runs.
In 2006, NMFS revised its species determination, delineating only anadromous steelhead distinct
population segments (DPS). The Middle Columbia steelhead DPS comprised populations within the
major river systems of the White Salmon, Deschutes, John Day, Klickitat, Umatillia, Walla Walla, and
Yakima rivers, and Fifteenmile, Rock, and Willow creeks.
The Middle Columbia River Steelhead Conservation and Recovery Plan (Recovery Plan) serves as the
roadmap for recovery of 10 steelhead populations that occupy Oregon tributaries to the Columbia
River (ODFW 2008). The Oregon steelhead populations that spawn and rear in the Deschutes, John
Day, Umatilla, and Walla Walla River basins and Fifteenmile Creek are part of the Middle Columbia
DPS. The Recovery Plan provides information required by NMFS to satisfy the requirements of the
ESA.
The Recovery Plan seeks to remove or minimize threats to the long‐term persistence of Oregon’s
Middle Columbia steelhead populations, and improve the population viability to the level that it can
be removed from the endangered species list. The plan contains strategies and actions for each of
the steelhead populations, including the populations found in the Upper Deschutes Basin and
focuses on primarily addressing threats to the population posed by habitat degradation in rivers and
streams, hatchery strays, and dam system development and operations. According to the ESA
mandates, the Recovery Plan is not a regulatory document and does not require an agency to
implement the plan unless legally mandated to do so. Implementation of the Recovery Plan depends
on the current social and regulatory structure for management of habitat, hydropower facilities,
harvest, and hatchery management. The Recovery Plan identifies actions necessary to achieve
recovery goals, and depends on existing entities for the implementation: federal, state, and local
government agencies and non‐governmental organizations including watershed councils and land
trusts.
The Recovery Plan provides information for the following sections on Upper Deschutes Basin
steelhead ESA status, distribution, biology, and factors contributing to population decline.
Deschutes River Steelhead ESA Status and Reintroduction Efforts
The Middle Columbia steelhead DPS is divided into four major population groups: Cascades Eastern
Slope Tributaries, Yakima River, John Day River and Umatilla/Walla Walla River. The Deschutes
River steelhead population is part of the Cascades Eastern Slope Tributaries major population
group. Steelhead in this population group are exclusively summer‐run fish. Within the Upper
Deschutes Basin, there are two existing and one extinct population: the Deschutes River eastside
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tributaries (existing), the Deschutes River westside tributaries (existing), and Crooked River
(extinct).
Deschutes River Eastside Tributaries
This population encompasses the mainstem Deschutes River from its mouth to the confluence of
Trout Creek and the tributaries entering the Deschutes River from the east, including Buck Hollow,
Bakeoven, and Trout creeks.
Deschutes River Westside Tributaries
Steelhead in this population are separated from eastside tributary populations by habitat and life
history characteristics. This population covers the mainstem Deschutes River upstream from the
mouth of Trout Creek and tributaries entering the Deschutes River from the west, including Warm
Springs River, Shitike Creek and several smaller tributaries. Upstream movement of steelhead is
blocked at Pelton Dam at river mile 100. This dam is a barrier to steelhead to the Upper Deschutes
Basin, including the Metolious River and Whychus Creek. A management plan is place to reestablish
steelhead populations to the Metolious River and Whychus Creek.
Crooked River
Steelhead in this population once occupied the Crooked River watershed, an eastside tributary to
the Deschutes River. Because the Pelton Dam blocked passage, this historic population is now
extinct. A management plan is place to reestablish steelhead populations to the Cooked River basin.
The dams that were constructed on the mainstem Deschutes River in the late 1950s and early 1960s
cut off the migration routes of steelhead and salmon to the upper basin. Although fish passage was
incorporated into the Pelton Round Butte Hydroelectric Project, it didn't work properly because of
water currents in Lake Billy Chinook. Adult fish could pass upstream over the dams, but juveniles
could not move back downstream because of the current patterns in the lake. Steelhead populations
were effectively removed from their historic rang in the upper basin, including highly productive
spawning and rearing habitats in the Metolious and Crooked rivers and Whychus Creek (Figure 1).
For example, in the 1950s the number of steelhead counted in Whychus Creek ranged as high as 619
in 1953; counts dwindled to zero in the late 1960s (ODFW 2003).
Reintroduction Efforts
With the recent federal relicensing of the dams, the co‐owners of the dams—Portland General
Electric and the Confederated Tribes of Warm Springs—are developing facilities for fish bypass. In
anticipation of the bypass facilities, juvenile steelhead were released into Whychus Creek beginning
in 2007 and the Crooked River basin in 2008. Whychus Creek, and McKay and Ochoco creeks in the
Crooked River system, are considered to have a high potential for supporting self‐sustaining
populations of steelhead and were, therefore, targeted for releases of steelhead fry.
The release of juvenile steelhead in Whychus Creek and the Crooked River basin is intended to
produce enough naturally produced smolts to test fish passage effectiveness downstream through
Lake Billy Chinook and into the facility at the Pelton Round Butte Hydroelectric Project. The draft
reintroduction plan anticipates continuing annual releases of fry to supplement natural fish
production associated with the returns of adult fish.
In its 2005 Biological Opinion, NMFS concluded that reintroducing steelhead to historical habitat
above the Pelton Round Butte Hydroelectric Project would increase the viability of the Upper
Deschutes Basin population of Middle Columbia River steelhead by increasing their range. NMFS
did not find that the reintroduction effort was essential to the continued existence of Middle
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Columbia River steelhead.
As part of the Upper Deschutes River basin steelhead reintroduction effort, NMFS is pursuing
rulemaking to designate steelhead above the Pelton Round Butte Hydroelectric Project as an
“experimental population” under section 10(j) of the ESA. The designation allows for greater
flexibility in managing land uses and human activities without the usual level of protection afforded
ESA‐listed species. During the period when experimental population is in effect, the population
would be treated as proposed for ESA listing, no critical habitat would be designated, and the rule
would provide limits to ESA legal liability. Because the fish are considered a nonessential
experimental population, the 10(j) rule would provide exemptions from ESA’s take prohibitions.
NMFS is currently developing the rule and a draft version is expected by November, 2009
(Rosemary Furfey, NMFS, personal communication 2009).
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Figure 1. Reintroduced Steelhead Range of Distribution
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Steelhead Biology and Factors Contributing to Decline
The Upper Deschutes River steelhead are a summer‐run fish and its biology is similar to those of
other inland steelhead populations. Most fish rear for 2 years in the basin and then migrate down
the river to the ocean. The fish then spend 1 to 2 years in saltwater before reentering freshwater,
where they may remain up to 1 year before spawning. Summer‐run fish enter the Columbia River
from June to August. Adult steelhead ascend the Deschutes River and tributaries throughout the
winter, hold in deeper water areas, and then spawn in the late winter and early spring. Fry
emergence typically occurs between May and the end of June. Figure 2 outlines the timing for each
of the freshwater steelhead life stages.
Figure 2. Seasonal Occurrence of Deschutes River Summer Steelhead in Freshwater by Life
History Stage
Source: WPN 2009 and adapted from Cramer and Beamesderfer 2002.
Because steelhead spend up to 3 years in freshwater for migration and juvenile rearing, they are
particularly vulnerable to habitat modification. Each life stage—adult and juvenile migration, adult
holding, spawning, egg incubation, emergence, and juvenile rearing—can be disrupted by habitat
modifications. Steelhead eggs, for example, can be destroyed by flood events if there is not sufficient
depth gravels and floodplain connectivity to dissipate the high flows to protect the incubating eggs
from scour. Migrating adult fish can be prevented from reaching spawning areas by obstacles, such
as low water from flow diversions or other barriers to upstream movement.
Essential features of steelhead habitat include substrate, water quality, water quantity, water
temperature, food, riparian vegetation, floodplains and off‐channel habitats, and safe passage. These
features also describe the habitat factors associated with viable steelhead populations. The specific
habitat requirements vary by life stage. Table 1 depicts the physical and biological features
identified as essential to the conservation of steelhead and the life stage each feature supports.
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Table 1. Essential Physical and Biological Features Necessary to Support Steelhead Populations
and Associated Life Stages
Life Stage
Essential Physical and Biological
Features Steelhead Trout Life Stage
Freshwater spawning Water quality, water quantity, and
substrate (gravel quantity and quality)
Spawning, incubation, and larval
development
Freshwater rearing Water quantity Juvenile growth and mobility
Water quality and forage Juvenile development
Natural habitat elements Juvenile mobility and survival
Freshwater migration Free of artificial obstructions, water
quality and quantity, and natural habitat
elements
Juvenile and adult mobility and survival
a Natural habitat elements include shade, large wood, log jams, beaver dams, aquatic vegetation, large rocks
and boulders, floodplain connectivity, side channels, and undercut banks.
b Forage includes aquatic invertebrate and fish species that support growth and maturation.
Source: ODFW 2008.
Building on the essential biological and physical features cited above, the Recovery Plan has
identified the specific contributing factors to population declines and recovery limitation of Upper
Deschutes Basin steelhead. These factors are as follows:
1. Hydrologic regime. Low streamflows, primarily from water diversions.
2. Channel morphology. Channelization from channel straightening and bank hardening to
protect developed areas; increased channel scour and downcutting from increased storm‐event
flows.
3. Floodplain and riparian condition. Riparian vegetation density, composition and width;
floodplain connectivity to the stream and stream‐associated wetlands; floodplain development
and urbanization.
4. Fish passage. Fish passage barriers from low flows and diversions and other obstacles to
migration, including culverts and dams; potential entrainment of fish at point of diversion.
5. Water quality. Primarily water temperature, which is often associated with low flows from
water diversions.
The jurisdictions’ policies and practices can affect the factors limiting recovery of Upper Deschutes
Basin steelhead. Each of the activity categories—land use planning, stormwater management,
herbicide and pesticide management, transportation operations, and municipal ground and surface
water withdrawal and wastewater discharge—have the potential to affect the physical biological
features that support healthy steelhead populations.
Table 2 provides examples of how each of the jurisdictions’ activity categories could potentially
affect the key factors impacting steelhead populations and habitat.
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Table 2. How Evaluated Activity Categories Could Affect Key Factors Impacting Steelhead
Populations and Habitat
Activity
Category
Example of
Policy/Practice
Potential Impact on Key Factors Limiting Upper Deschutes
Basin Steelhead
Land use
planning
• Riparian and floodplain
development and
urbanization
• Bridge and culvert
placement
• Development of stream‐
associated wetlands
Channel morphology: channelization from channel
straightening and bank hardening; limiting channel meander
patterns from floodplain development and bridges
Floodplain and riparian condition: riparian vegetation density,
composition and width; floodplain connectivity to the stream
and stream‐associated wetlands
Fish passage: obstacles to migration from culverts and bridges
Stormwater
management
• Stormwater detention
and treatment
• Area in street and other
impervious areas
• Erosion control
Hydrologic regime: lower summer streamflows from
inadequate groundwater recharge; increased high flows from
stormwater runoff during storm events
Channel morphology: Increased channel scour and downcutting
from increased storm‐event flows; sediment in channels
Water quality: degraded water quality from street and other
stormwater discharges, including hydrocarbons and other
constituents
Herbicide and
pesticide
management
• Type of chemicals
applied
• Application proximity to
streams
Water quality: degraded water quality from introduction of
chemicals into waterways
Ground and
surface water
withdrawals
• Water withdrawal
quantity and rate
• Diversion screening
Hydrologic regime: low streamflows
Fish passage: barriers from low flows and diversions; potential
entrainment of fish at point of diversion
Wastewater
discharge
• Quantity and rate of
discharge
• Water quality
characteristics of treated
effluent
Water quality: degraded water quality from increased water
temperature or introduction of other constituents into
waterways
ESA Risk Evaluation Approach and Results
The intent of the ESA risk evaluation is to describe areas of potential ESA risk for the jurisdictions to
consider when planning a strategy to support the recovery of Upper Deschutes Basin steelhead
populations. The evaluation provides a framework for responding to the presence of reintroduced
steelhead trout through take limit certification under ESA Section 4(d), or other policy or
programmatic steps.
ICF Jones & Stokes used the following documents as guidance to evaluate the jurisdictions’ policies
and practices:
z NMFS Citizen’s Guide to the 4(d) Rule
z ODOT Routine Road Maintenance Guide (1996; updated 2004)
z Oregon Association of Clean Water Agencies Endangered Species Assessment Manual (2000)
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These documents are particularly relevant because they include specific risk assessment standards
and criteria for activities that have been identified by the jurisdictions for evaluation.
In addition to these documents, ICF Jones & Stokes evaluated the jurisdiction’s policies and practices
for conformance to other best management practices (BMPs) designed to protect water quality,
floodplain processes, and aquatic habitat. These BMPs are described in a variety of documents and
scientific studies. Because they are designed for the Upper Deschutes Basin’s unique climate,
hydrology, and landforms, the BMPs described in the Central Oregon Stormwater Manual (COSM)
provided additional guidance for evaluating stormwater practices.
Four categories of activities were evaluated for all of the jurisdictions:
z land use,
z stormwater management,
z pest control (herbicides and pesticides), and
z routine road maintenance.
For each category we identified specific criteria used to evaluate the policies and practices with the
potential to affect listed steelhead and their habitat. For each criterion we summarized the
jurisdictions’ practices and assessed the current level of protection afforded to steelhead as a result
of the policy or practice. The information on each jurisdiction’s practices was based on a review of
supplied documents and codes and interviews with staff from each of the participating cities and
counties.
The level of protection from ESA risk is determined within the following categories:
z Policies/practices adequately address ESA risk
z Policies/practices possess some ESA risk
z Policies/practices are inadequate and do not address ESA risk
Where the policy or practice does not conform to the accepted level of protection and presents some
ESA risk, the rationale for the variance is described. In addition and where appropriate, we
recommend potential modifications to the policy and practice to better address ESA risk.
In addition to the categories listed above, two additional categories of activities were described for
the participating cities:
z surface and groundwater withdrawals, and
z wastewater discharge.
It is beyond the extent of this evaluation to assess the likelihood of take caused by the jurisdictions’
surface and groundwater withdrawals and wastewater discharge activities. Instead, we present
BMPs for the operation of municipal surface and groundwater withdrawals and wastewater
discharge; it is assumed that these BMPs minimize the potential for take of listed steelhead. This
evaluation summarizes the ESA‐related case law without applying it to current surface and
groundwater withdrawals and wastewater discharge operations.
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Watershed Context and Steelhead Presence Distribution
The ESA risk resulting from the jurisdictions’ policies and practices is evaluated based on the
application of BMPs and the presence of steelhead trout in the affected waterways. In areas of the
cities or counties that contain waterways where steelhead trout are (or will be) reintroduced, there
is more potential for the jurisdiction’s activities to impact steelhead because there are direct
pathways to portions of the system where fish are present. The following is a description of the
steelhead presence and associated risk of impacts on fish or habitat for the participating counties
and cities.
Crook County
The Crooked River and its tributaries flow through Crook County. Steelhead, which were
historically present in Crooked River Watershed and have been reintroduced in the system, use the
river and tributary streams for migration, spawning, and juvenile rearing. Because these fish are
present in Crook County’s waterways there is risk that the County’s activities could have a direct
impact on steelhead populations or aquatic habitat. Crook County does not authorize or participate
in high‐risk activities (such as water diversions), so there is minimal risk that the County’s activities
could directly cause steelhead mortality. Crook County’s practices, however, can indirectly affect
steelhead. These indirect effects can include changes in riparian habitat, floodplain function, erosion
control, or other practices that could negatively impact fish populations or habitat where steelhead
are present.
Reintroduced steelhead are blocked from upstream movement into the historic range in the upper
watershed. Bowman Dam on the Crooked River and Ochoco Dam both prevent steelhead migration
above these barriers. As a consequence, there is minimal risk that Crook County’s activities in the
areas above these dams could have a direct impact on steelhead populations or aquatic habitat.
Nevertheless, the County’s practices above the dams can indirectly affect steelhead downstream
through changes in water quality, riparian and floodplain function, and other ecological processes
that support high quality aquatic habitat and water quality.
Deschutes County
Steelhead were historically present in waterways within Deschutes County, including portions of the
Deschutes River, Crooked River, and Whychus Creek. Steelhead have been reintroduced into these
waterways and use various parts of the system for migration, spawning, and juvenile rearing. There
is risk that Deschutes County’s activities could impact steelhead populations or aquatic habitat,
because these fish are present in the county’s rivers and streams. Deschutes County does not
authorize or participate in high‐risk activities (such as water diversions), so there is minimal risk
that the county’s activities could directly cause steelhead mortality. Deschutes County’s practices,
however, can indirectly affect steelhead. These indirect effects can include changes in riparian
habitat, floodplain function, erosion control, or other practices that could negatively impact fish
populations or habitat where steelhead are present.
Reintroduced steelhead are blocked from upstream movement to the Upper Deschutes River at Big
Falls, approximately 30 miles downstream from the City of Bend. As a consequence, there is
minimal risk that Deschutes County’s activities in areas along the Deschutes River or its tributaries
above Big Falls could have a direct impact on steelhead populations or aquatic habitat. The county’s
practices, however, can indirectly affect steelhead in the Upper Deschutes River downstream of Big
Falls through changes in water quality. Loss of riparian shade through the application of county
policies, for example, could increase water temperatures in downstream portions of the Upper
Deschutes River.
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Jefferson County
There are streams and rivers in Jefferson County below the Pelton Dam that currently contain ESA‐
listed Middle Columbia steelhead populations. These populations include eastside tributary
populations (Trout Creek) and westside tributaries (Shitike Creek and several smaller streams).
Steelhead were historically present and will be reintroduced in waterways within Jefferson County
above the dam, including portions of the Deschutes River, Metolious River, and Whychus Creek.
Because steelhead are present in Jefferson County’s waterways there is risk that the County’s
activities could have a direct impact on steelhead populations or aquatic habitat. Jefferson County
does not authorize or participate in high‐risk activities (such as water diversions), so there is
minimal risk that the county’s activities could directly cause steelhead mortality. Jefferson County’s
practices, however, can indirectly affect steelhead. These indirect effects can include changes in
riparian habitat, floodplain function, erosion control, or other practices that could negatively impact
fish populations or habitat where steelhead are present.
City of Bend
The Deschutes River and Tumalo Creek flow through the City of Bend. Steelhead were not
historically present nor will they be reintroduced in the waterways within the City of Bend’s urban
growth boundary or other areas subject to city management (e.g., water withdrawal and conveyance
from Bridge Creek). Reintroduced steelhead are blocked from upstream movement into the Upper
Deschutes River at Big Falls, approximately 30 miles downstream from the city (see Figure 1). As a
consequence, there is minimal risk that the City of Bend’s activities could have a direct impact on
steelhead populations or aquatic habitat. There is no risk, for example, that the city’s practices could
directly cause fish mortality through improper activities such as uptake of fish through water
conveyance systems. A change in water quality or flow in the Upper Deschutes River downstream of
Big Falls could have an indirect affect on fish populations or habitat. Any downstream effects on
steelhead populations or habitat, however, are difficult to quantify.
This evaluation does not cover the activities of either the Bend Parks and Recreation District
(BPRD), which manages a significant portion of the lands along the Upper Deschutes River and
Mirror Pond within the city, or the privately owned Old Mill Shopping District, which is located
adjacent to and along approximately 0.50 mile of the Upper Deschutes River in the city. These
entities manage practices that have the potential to impact waterways and land, which encompasses
a significant portion of the riparian areas along the Deschutes River.
Additionally, this evaluation does not cover the activities of two private drinking water purveyors in
the city, both of which rely on groundwater withdrawal for drinking water supplies.
City of Prineville
Crooked River and Ochoco Creek flow through the City of Prineville. Steelhead, which were
historically present in Crooked River and Ochoco Creek, have been reintroduced in the system and
use the river and creek for migration, spawning, and juvenile rearing. Because these fish are present
in the City of Prineville’s waterways, there is risk that the city’s activities could have a direct impact
on steelhead populations or aquatic habitat. There is risk, for example, that the City of Prineville’s
practices could directly cause fish mortality through improper activities such as the uptake of fish
through water conveyance systems. In addition, the City of Prineville’s practices can indirectly affect
steelhead. These indirect effects can include changes in water quality, streamflow, or floodplain
function that could negatively impact fish populations or habitat in the City of Prineville or the
downstream portions of Crooked River and Ochoco Creek.
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City of Redmond
There are no waterways containing steelhead within the City of Redmond’s urban growth boundary.
The City of Redmond is more than 5 miles from the nearest stream that could contain reintroduced
steelhead. Because the City of Redmond does not contain waterways and there are no city activities
(e.g., stormwater discharges) that have direct pathways into streams, there is minimal risk that the
city’s practices could have an impact on steelhead populations or aquatic habitat. There is no risk,
for example, that the City of Redmond’s practices could directly cause fish mortality through
improper activities such as the uptake of fish through water conveyance systems. In addition, there
is limited risk that indirect effects, such as groundwater withdrawals, could negatively impact fish
populations or habitat in the Deschutes River or Crooked River.
City of Sisters
Whychus Creek flows through the City of Sisters. Steelhead, which were historically present in
Whychus Creek, have been reintroduced in the system and use the creek for migration, spawning,
and juvenile rearing. Because these fish are present in the City of Sisters’ waterways, there is risk
that the city’s activities could have a direct impact on steelhead populations or aquatic habitat.
There is risk, for example, that the City of Sisters’ practices could directly cause fish mortality
through improper activities such as the uptake of fish through water conveyance systems. In
addition, the City of Sisters’ practices could indirectly affect steelhead. These indirect effects could
include changes in water quality, streamflow, or floodplain function that could negatively impact
fish populations or habitat in the City of Sisters or the downstream portions of Whychus Creek.
Land Use
ICF Jones & Stokes evaluated the jurisdictions’ land use plans, policies, and activities for their
potential to cause take of listed steelhead. The land use portion of this evaluation was based on
objectives identified by NMFS under Limit 12 of the 4(d) Rule for Threatened Salmon and Steelhead
on the West Coast—the MRCI Development, and Redevelopment limit (4(d) rule. By evaluating the
jurisdictions’ plans and policies compared to the 4(d) rule objectives, ICF Jones & Stokes determined
the extent to which land use and development policies and practices adequately protect listed
steelhead. While most of the MRCI limit objectives were used as part of the land use and
development evaluation, some were addressed under other activity categories (e.g., stormwater).
The following key questions guided the land use evaluation:
z Are the locations of important natural resources and habitat areas mapped?
z Do the jurisdiction’s development policies and practices adequately protect riparian areas?
z Does the jurisdiction’s development code adequately protect historic stream meander patterns
and channel migration zones?
z How does the jurisdiction’s development code address development in the floodplain? Is the
jurisdiction’s floodplain area mapping up to date?
z Do the jurisdiction’s development code and practices adequately protect wetland areas?
Land use evaluation findings:
z Most of the jurisdictions have delineated riparian areas (e.g., 100 feet along fish‐bearing
streams) and have codes in place for protecting riparian vegetation. There is, however,
variability in the width of the protected riparian vegetation buffer. The quality of the inventory
and mapping of riparian habitats is variable. Some jurisdictions do not have a riparian
inventory in place; there is not a standard for inventory or mapping across all of the
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jurisdictions.
z Some of the jurisdictions have comprehensively inventoried and mapped wetland areas. While
all of the jurisdictions have codes in place to protect wetlands, the protection is variable because
several do not have comprehensive information on wetland locations.
z Most of the jurisdictions have not comprehensively mapped channel migration zones, nor are
there development restrictions in place for channel migration zones.
z All of the jurisdictions have policies in place that require Federal Emergency Management
Agency (FEMA) development standards to minimize flooding impacts on houses and property.
Very few of the jurisdictions, however, have associated floodplain policies that address the
ecological function of floodplains and historic stream channels. NMFS has recently developed
floodplain development guidance on how best to revise floodplain development requirements
so that the jurisdictions avoid, minimize, and/or mitigate impacts on floodplain habitat.
Stormwater Management
In order to protect ESA‐listed fish species, NMFS requires that development ordinances adequately
prevent stormwater discharges from impacting water quality and quantity and streamflow patterns
in the watershed. These impacts include peak and base flows in perennial streams. NMFS states
that stormwater management programs must require development activities to preserve or
enhance streamflow patterns so they are as close as possible to the historic peak flows, base flows,
durations, volumes, and velocities. These flows can be accomplished by reducing impervious
surfaces and maintaining vegetation cover and natural soils. These conditions will, in turn, maintain
essential habitat processes such as natural water infiltration rates, transpiration rates, stormwater
runoff rates, and sediment filtering, and they will provide hydrographic conditions that will
maintain and sustain aquatic life.
The following key questions guided the stormwater evaluation:
z Do the jurisdiction’s policies and practices ensure that stormwater from new development or
redevelopment will not impact the water quality of fish‐bearing streams?
z Do development policies and practices protect historic streamflow patterns such as peak and
base flows in perennial streams?
z Do development policies and practices require BMPs that establish erosion and sediment
controls during and after construction?
z Are there mechanisms in place and adequate levels of funding and resources for program
implementation, monitoring, enforcement, and reporting?
Stormwater management evaluation findings:
z The COSM, which describes stormwater BMPs that are appropriate for the Upper Deschutes
Basin’s climate, geology and land use conditions, is used by all of the jurisdictions as guidance.
None of the jurisdictions have formally adopted the COSM, and the application of its BMPs varies
considerably across the jurisdictions. The participating cities and counties are currently
revising the COSM.
z There is considerable variation in the implementation of low‐impact development techniques
that promote impervious surface reduction, on‐site retention of stormwater, practices that
minimize clearing of native vegetation, and the application of BMPs that provide erosion and
sediment control.
z Most of the jurisdictions do not have a stormwater master plan in place, nor do they have a
stormwater utility that could provide permanent, dedicated funding for stormwater program
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implementation, monitoring, enforcement, and reporting.
Pest Control
The evaluation of pest control focused on the jurisdiction’s use of herbicides and pesticides. ICF
Jones & Stokes reviewed herbicide and pesticide management plans and policies to determine the
potential for take of listed steelhead. The evaluation was based on Oregon Department of
Agriculture (ODA) guidelines and recent guidance from NMFS.
The following key questions guided the pesticide and herbicide evaluation:
z Are there mechanisms in place and adequate levels of funding and resources for program
implementation, monitoring, enforcement, and reporting?
z What pesticides and herbicides are currently used by the jurisdiction?
z How does the jurisdiction determine what pesticides and herbicides can be used?
z Does the jurisdiction maintain guidance on appropriate locations and methods for the
application of pesticides and herbicides?
Pest control evaluation findings:
z The application of herbicides and pesticides across the jurisdictions was variable; many of the
jurisdictions apply herbicides on a very limited basis and rarely apply pesticides. To the extent
that the jurisdictions apply pesticides and herbicides, they follow ODA practices and U.S.
Environmental Protection Agency (EPA) label requirements. To minimize the risk associated
with the application of pesticides and herbicides, NMFS has developed guidance for application
of specific chemicals along waterways with ESA‐listed salmon or steelhead trout.
Routine Road Maintenance
The jurisdictions’ routine road maintenance practices were evaluated to determine if they are
substantially similar to—and at least as protective as—the Routine Road Maintenance Guide
practices approved under the current 4(d) rule. Should the jurisdictions’ practices differ from the
Routine Road Maintenance Guide, either in organization or in substance, the evaluation determined
whether the practice was less protective, as protective, or more protective than the ODOT guidance.
The evaluation also examined the extent to which the jurisdictions could identify all road locations
where maintenance activities may affect streams and the locations of critical steelhead habitat
adjacent to roads.
The following key question guided the routine road maintenance evaluation:
z To what extent does the jurisdiction rely upon and implement the Routine Road Maintenance
Guide?
Routine Road Maintenance evaluation findings:
z All of the jurisdictions apply the ODOT Routine Road Maintenance Guide. The jurisdictions,
however, have not formally adopted the guide, nor have they documented its implementation.
Surface and Groundwater Withdrawals
The Upper Deschutes Basin has been the subject of extensive hydrologic and policy evaluation. In
2001, the U.S. Geological Survey (USGS) published the Water‐Resources Investigations Report 00‐
4162, a basin‐wide study that concluded there is a direct relationship between surface and
groundwater. Based on this study, subsequent investigations, and many years of stakeholder
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involvement, the state legislature enacted a special mitigation program for future groundwater
withdrawals. The Oregon Water Resources Department adopted and implemented rules for the
program. In light of the Upper Deschutes Basin’s complicated history and the variability between
water systems among the jurisdictions, it is beyond the extent of this evaluation to assess the
likelihood of take caused by the quantities of water withdrawn by the jurisdictions in the Upper
Deschutes Basin. Instead, we outline current BMPs for operating municipal surface and
groundwater withdrawals and use that minimize the potential for take. In addition, this evaluation
summarizes the related case law without applying it to current operations (see Appendix A, COIC
Endangered Species Act Liability Risk Assessment Memorandum, ICF Jones & Stokes, April 6, 2009).
The cities of Prineville, Redmond, and Sisters obtain most of their municipal water from
groundwater wells. The City of Bend obtains approximately equal amounts municipal water from
ground and surface water sources. All of the cities’ groundwater withdrawal activities are currently
permitted by the Oregon Water Resources Department and all cities are engaged in the state’s
groundwater mitigation program, which constitutes the appropriate BMPs. Several cities have
surface water withdrawals. Where steelhead are present, the jurisdiction should follow NMFS
screen certification design and operation BMPs.
The ESA prohibits take of endangered species and assigns liability to any actor who causes it, either
directly or through habitat modification. The Endangered Species Act Liability Risk Assessment
Memorandum (Appendix A) concludes, however, that citizen suits against small government actors
for permitted water withdrawal activities have not proven to be an effective mechanism for
enforcing the ESA’s prohibitions. Lawsuits resulting from ESA liability are rare for permitted water
withdrawal activities and can be minimized through the appropriate implementation of policies and
practices that protect water quality, stream habitat, and direct uptake of fish.
Through careful compliance with accepted BMPs the cities’ risk of ESA liability from water
withdrawal activities is minimal.
Wastewater Discharge
The discharge of wastewater into fish‐bearing streams has the potential to allow the entry of
pollutants into aquatic habitats that could lead to take of listed steelhead. Since local governments
are responsible for the treatment and discharge of wastewater, they could be held responsible for
such take under the ESA.
ICF Jones & Stokes reviewed the cities’ current wastewater discharge policies and practices to
determine if standard practices are preventing the discharge of pollutants to fish‐bearing streams to
the maximum extent practicable. All of the cities’ management of wastewater is permitted by the
State of Oregon Department of Environmental Quality (DEQ), and the wastewater activities are
designed to minimize impacts on water quality and fish habitat. Treated effluent is stored in
evaporative ponds or land applied on local agricultural or forest lands. At all times, there is no
discharge to the Deschutes River. At periodic intervals, soils in the irrigated areas are sampled for
leaching nitrates to assure that groundwater levels are not increasing.
ICF Jones & Stokes’ evaluation of wastewater discharge includes a summary of the related case law
to provide the jurisdictions with an understanding of the potential risk of legal actions as a result of
permitted wastewater discharge (see Appendix A). The memorandum provided as Appendix A
concludes that through careful compliance with all permit conditions, the risk of liability from
wastewater discharge activities is minimal.
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Conclusions and Recommendations
The risk exposure to ESA enforcement actions or third‐party lawsuits resulting from the
jurisdictions’ policies and practices is evaluated based on the application of BMPs and the presence
of steelhead trout in the affected waterways. In areas of the cities or counties that contain
waterways where steelhead trout are (or will be) reintroduced, the jurisdiction has more ESA risk
because its policies and practices can impact water quality and riparian habitat that has direct
pathways to portions of the system where fish are present.
In the City of Bend and the counties upstream from steelhead trout‐bearing portions of the Upper
Deschutes Basin, it is difficult to directly link the activities to steelhead trout population effects or
modifications to aquatic habitat. Because there are more limited pathways in these upstream areas
that can affect steelhead trout populations or aquatic habitat, there is less ESA‐related risk. For the
City of Redmond, the ESA‐related risk is further reduced because there are no steelhead present in
the city or direct pathways to waterways were steelhead are or could be present.
If a jurisdiction does not authorize or participate in high‐risk activities such as water diversions,
there is minimal risk that the jurisdiction’s activities could directly cause steelhead trout mortality.
For the most part, the jurisdictions are applying BMPs in a manner that protects ecological
processes and water quality that support steelhead trout populations. Correct application of the
BMPs limits potential that the jurisdiction’s policies and practices can affect steelhead trout or
aquatic habitat.
There are, however, policies and practices that can be improved through programmatic adjustments
to further minimize the exposure to ESA risk and enhance environmental benefits. Important areas
for improvement include riparian, floodplain development, stormwater management, and sediment
control BMPs. Because steelhead occupy streams and rivers that flow through all of participating
cities and counties in the Upper Deschutes Basin, the jurisdictions should continue to coordinate
planning and other activities. Steelhead recovery necessitates information and coordinated actions
at the basin‐scale.
Table 3 outlines the recommendations for the six categories of activity identified for evaluation.
Regardless of whether steelhead trout are present, these recommendations should be applied
throughout the jurisdiction’s management area. Improving policies and practices will help maintain
aquatic habitat and watershed processes that will yield improvements to the environment that
support steelhead trout and other aquatic and riparian‐dependant species.
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Table 3. Recommended Actions to Reduce ESARelated Risk from the Participating Cities and
Counties Policies and Practices
City or County Policy or Practice Recommendation
Land Use The jurisdictions should consider mapping and, where appropriate,
protecting channel migration zones. This effort should be coordinated
across the cities and counties.
The jurisdictions should consider comprehensively inventorying and
mapping all riparian areas to provide information for critical resource areas.
This effort should be combined with mapping channel migration zones and
coordinated across the jurisdictions.
The jurisdictions should review recent NMFS floodplain development
guidance and determine how best to implement the recommendations so as
to avoid, minimize, and/or mitigate impacts on floodplain habitat.
Stormwater Management The participating cities and counties are revising the COSM. The
jurisdictions should consider adopting appropriate parts of the revised
COSM, and should formally encourage the implementation of low‐impact
development techniques that promote impervious surface reduction, on‐site
retention of stormwater, minimize the clearing of native vegetation, and
provide erosion and sediment control BMPs.
The jurisdictions should consider developing and adopting stormwater
master plans and developing stormwater utilities that could provide
permanent, dedicated funding for stormwater program implementation,
monitoring, enforcement, and reporting.
Pest Control The jurisdictions should be aware of, and if necessary apply, the current
application BMPs and guidance from NMFS.
Routine Road Maintenance Because the Routine Road Maintenance Guide has been adopted by NMFS
under the 4(d) rule for salmon and steelhead trout, the jurisdictions should
formally incorporate or adopt procedures from the document to guide the
implementation of road maintenance procedures.
Surface/Groundwater
Withdrawals
The cities engaged in surface water withdrawals where steelheads are
present should follow NMFS BMPs and certification for fish screens.
Wastewater Discharge No recommendations are listed for this category.
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References
Cramer, S.P. and R.C.P. Beamesderfer. 2002. Population dynamics, habitat capacity, and a life
history simulation model for steelhead in the Deschutes River, Oregon. Prepared for PGE,
Portland, Oregon. S.P. Cramer and Associates, Sandy, OR.
Filippi, D.E. 2000. NMFS' Final 4(d) Rule for Salmon and Steelhead. Published in Oregon Insider
and by Stoel Rives LLP, Portland, OR. Available:
http://www.stoel.com/showarticle.aspx?Show=909. Accessed: August 5, 2009
National Marine Fisheries Service(NMFS). 2000. A Citizen’s Guide to the 4(d) Rule for Threatened
Salmon and Steelhead on the West Coast. NMFS, Northwest and Southwest Regions.
Oregon Association of Clean Water Agencies. 2000. Endangered Species Act Assessment Manual.
Version 1. Prepared by CH2M‐Hill. Portland, OR.
Oregon Department of Fish and Wildlife (ODFW). 2003. Anadromous fish and bull trout
management in the Upper Deschutes, Crooked, and Metolius River Subbasins. Oregon
Department of Fish and Wildlife, Portland, OR.
———. 2008. Conservation and Recovery Plan for Oregon Steelhead Populations in the Middle
Columbia River Steelhead Distinct Population Segment. ODFW, Salem, OR.
Oregon Department of Transportation (ODOT) Routine Road Maintenance Water Quality and
Habitat Guide (Routine Road Maintenance Guide). 1999 (updated 2004). ODOT, Salem, OR.
Watershed Professionals Network (WPN). 2009. Whychus Creek Restoration and Management
Plan. Prepared for the Upper Deschutes Watershed Council, Bend, OR and the City of Sisters, OR.
WPN, Bend, OR.
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Appendix A:
COIC Endangered Species Act Liability Risk Assessment
Memorandum
Date: April 6, 2009
To: Crook, Deschutes, and Jefferson Counties; Cities of Bend, Prineville, Redmond,
and Sisters; Central Oregon Intergovernmental Council (COIC)
From: Megan Smith, JD
Subject: COIC Endangered Species Act Liability Risk Assessment
INTRODUCTION AND SUMMARY
This memorandum and its accompanying summary have been prepared for general informational
purposes only. It does not constitute legal advice and must not be used as a substitute for the
advice of qualified legal counsel. Preparation and use of this information does not create an
attorney-client relationship between any ICF Jones & Stokes employee and any recipient of this
information.
The Endangered Species Act prohibits the take of any endangered species by anyone subject to
the jurisdiction of the United States. Daily activities such as withdrawal of surface and
groundwater, as well as permitted wastewater discharge, are suddenly high profile issues when
they become the subject of an ESA citizen suit. While performance of these activities is
commonplace nationwide, existing case law has focused on the actions of larger entities,
primarily federal, and provides little specific guidance to county and municipal actors. This
analysis discusses the procedural requirements of citizen suits under Section 11 of the ESA, as
well as under what circumstances water withdrawal and discharge of wastewater and other
constituents into streams may be the subject of a citizen suit. Due to the lack of citizen suit case
law discussing specific causes of action against counties, municipal or smaller government
entities, no specific actions or Best Management Practices are identified.
Issue One: What scope of activities is regulated by ESA?
Statutory Structure of the Endangered Species Act
Despite several subsequent Congressional amendments, the basic framework and policy of the
Endangered Species Act have remained unchanged since 1973, requiring that all federal
departments and agencies seek to conserve endangered and threatened species. The ESA divides
responsibility for its administration between the Secretary of the Interior, through its Fish and
Wildlife Service (FWS), and the Secretary of Commerce, through NOAA’s National Marine
Fisheries Service (NMFS). These two agencies, jointly referred to as “the Services”, have
promulgated regulations (see 50 CFR parts 401 - 453) to meet their obligations under ESA’s
April 6, 2009
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various provisions. Currently, there are 34 listed marine and anadromous fish species under
NMFS’ purview, the majority of which are West Coast species.1
The ESA contains six major provisions. Section 4 governs FWS’ and NMFS’ ability and
obligation to list a species and designate the species’ habitat as "critical habitat;" as well as
impose certain protections for species listed as threatened.2 Section 7 imposes requirements
upon all federal agencies to consult with the Services on any federal action that may affect a
listed species or adversely modify or destroy designated critical habitat and provides for issuance
of biological opinions by the Services that may include take authorization.3 Section 9 prohibits,
among other things, the “taking” of any endangered species, while Section 4(d) authorizes FWS
and NMFS to adopt administrative rules to impose the same, or varying levels, prohibitions for
threatened species.45 Section 10 authorizes the Services to grant exceptions to the "take"
prohibitions of Sections 9 and 4(d) for actions not authorized or carried out by a federal agency.6
Lastly, Section 11 details possible civil and criminal penalties for violations of the ESA, any
implementing regulations, and any permits issued under the ESA or the regulations.7
Section 9’s Take Prohibitions and Habitat Modification
While Sections 4, 7 and 10 describe the obligations of the Services under the Act, Section 9, the
legal prohibition against “take” of an ESA-listed species, represents the real teeth of the Act for
private individuals.8 Along with prohibiting the importation, exportation, and interstate sale of
endangered species,9 the Act also prohibits the "taking" of any endangered species within the
United States or upon the high seas by anyone under United States jurisdiction. 10
What constitutes a prohibited take is defined broadly, and includes actions “to harass, harm,
pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such
conduct.”11 While affirmative actions to trap, capture, or kill a listed species should be easily
identified and avoided, it is the term “harm” that has proven most difficult to define. The ESA
defines “harm” as constituting “an act which actually kills or injures wildlife.”12 Harming a
species may be indirect, in that the harm may be caused by habitat modification, but habitat
1 http://www.nmfs.noaa.gov/pr/species/esa/fish.htm (last visited March 16, 2009).
2 16 U.S.C. § 1533 (2009).
3 16 U.S.C. § 1536 (2009).
4 16 U.S.C. § 1538 (2009).
5 16 U.S.C. § 1533(d) (2009).
6 16 U.S.C. § 1539 (2009).
7 16 U.S.C. § 1540 (2009).
8 16 U.S.C. § 1538 (2009).
9 16 U.S.C. § 1538(a)(1)(A), (E)‐(F) (2009).
10 16 U.S.C. § 1538(a)(1)(B)‐(C) (2009).
11 16 U.S.C. § 1532(19) (2009).
12 Id.
April 6, 2009
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modification does not constitute harm unless it “actually kills or injures wildlife.”13 Such act
may include significantly impairing essential behavioral patterns, including breeding,
spawning, feeding or sheltering.14 15
Clearly, activities that reduce surface flows and cause discharge of contaminants may result in
take of a listed fish species. In response to the American Fisheries Society and numerous citizen
petitions for protection, many of the most depressed salmonid populations are now federally
listed under the ESA; at present there are 28 separate and evolutionarily distinct stocks of
salmonids in California, Oregon, and Washington listed as threatened or endangered.16 In the
vast majority of these declines, and in most every salmonid ESA listing, sheer lack of water,
resulting in part from surface diversions, has been identified as a major contributing factor.17 In
one survey of salmon problems commissioned by the legislatures of California and Oregon,
researchers found that, “[d]iversion of water is potentially one of the most serious factors
adversely affecting salmon in western Oregon and northern California.”18 Likewise, the health of
a river’s habitat is clearly influenced by land use, and by the resulting quantities and quality of
wastewater discharge and stormwater runoff. 19
ESA Case Law Concerning Surface and Groundwater Withdrawals, Wastewater Discharge
Under the ESA as defined above, both government entities and individuals are subject to the
jurisdiction of ESA when authorizing activities such as water withdrawals and wastewater
discharge. Despite the clear potential for take of listed species through these activities, there is a
nearly complete lack of published ESA case law that discusses the issue. However, the lack of
case law should not be interpreted as a lack of liability for water withdrawals and wastewater
discharges that cause take. Several factors will typically limit published cases, from a plaintiff’s
13 Babbitt v. Sweet Home Chapter of Communities for a Great Oregon (Sweet Home), 515 U.S. 687 (1995). In
upholding the definition of "harm" as encompassing habitat modification, the Supreme Court emphasized that
“every term in the regulation's definition of ‘harm’ is subservient to the phrase ‘an act which actually kills or
injures wildlife.’” Id. at 700, n. 13.
14 50 C.F.R. § 17.3 (2002).
15 The first salmonid water‐related action that was barred by the courts as an illegal take under the ESA was a
federal enforcement action again Glenn‐Colusa Irrigation District for entrainment of Sacramento River winter‐run
Chinook by irrigation water diversion pumps. United States v. Glenn‐Colusa Irrigation Dist., 788 F. Supp. 1126, 1135
(E.D. Cal. 1992).
16 http://www.nwr.noaa.gov/ESA‐Salmon‐Listings/upload/snapshot‐9‐08.pdf (last visited March 6, 2009).
17 See, e.g., Threatened Status for Central California Coho Salmon Evolutionary Significant Unit, 61 CFR 56, 138, 56,
141 (Oct. 31, 1996), identifying “dewatering” of river habitat as a factor in the decline of coho salmon.
18 See Botkin, D. et al. Status and Future of salmon of Western Oregon and Northern California: Findings and
Options. Report #8. The Center for the Study of the Environment, Santa Barbara, California. (1995).
19 “Plainly, lack of water is not the only cause of river harm. Watercourse health is a function of the quantity and
quality of water, both of which are related and impacted by a variety of factors. The quantity of water in any
particular watercourse depends not only upon the extent of any diversions from the watercourse and any
hydrologically connected aquifers but also on land use which partially dictates the timing and quantities of runoff.”
Rasband, J. Priority, Probability, and Proximate Cause: Lessons from Tort Law About Imposing ESA Responsibility
for Wildlife Harm on Water Users and Other Joint Habitat Modifiers. 33 Envtl. L. 595, 618‐23, 628‐30 (2003).
April 6, 2009
Page 4
choice of defendant to the ultimate goal of the suit. Here, citizen suit plaintiffs have primarily
chosen to attack the actions of the permitting authorities, typically federal agencies, when
permitted actions are perceived to cause take.
While complying with the conditions of a federally issued permit may not relieve an actor of
ESA liability, it may act to deter citizen suits. Additionally, as described below, the legal
concepts of standing and causation have made the success of a lawsuit against a permitting actor,
rather an individual permittee, more likely.
Issue Two: What actions may increase or decrease vulnerability to citizen suits?
Section 11’s Citizen Suit Enforcement Mechanism
According to the Supreme Court, the ESA’s citizen suit provision, contained in Section 11, is “an
authorization of remarkable breadth,” and one that has been used extensively to challenge the
way in which the Services carry out their duties under ESA.20 To encourage citizen suits, the
ESA eliminates many of the traditional federal jurisdiction requirements for jurisdiction over
citizen suit claims. Under the citizen suit provisions, any person with standing may seek to
compel the Secretary to list or delist species deemed threatened or endangered, or to designate
critical habitat for listed species.
The ESA also expressly grants to any person with standing the right to commence legal action
against any other person or entity, including the United States or any other government entity,
acting in violation of the ESA.21 But despite the breadth of the statute’s authorization, the ESA
also encourages low-level case resolution. Case law review shows that the § 1540(g)(1)(A) suits
against non-federal actors rarely result in court opinions. Two possible explanations may lie in
the jurisdictional and remedy portions of the statute.
Under Section 11, a citizen may not bring suit prior to sixty days after written notice of an
alleged violation has been given to the Secretary and alleged violator, a jurisdictional
requirement that must be met before a case can proceed.22 “A failure to comply with the notice
requirement acts as an absolute bar to bringing suit under the ESA.”23 The purpose of the 60-day
notice provision is to put the agencies on notice of a perceived violation of the statute and an
intent to sue. When given notice, the agencies have an opportunity to review their actions and
take corrective measures if warranted, to eliminate the perceived taking or to apply to the
Services for the appropriate authorization. The provision therefore provides an opportunity for
settlement or other resolution of a dispute without litigation.
20 Bennet v. Spear, 520 U.S. 154, 164 (1997).
21 A citizen suit not related to the Secretaries’ obligations under ESA is known as a §1540(g)(1)(A) suit.
22 Southwest Ctr. for Biological Diversity v. Bureau of Reclamation, 143 F.3d 515, 520 (9th Cir.1998).
23 Id.
April 6, 2009
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Also encouraging settlement is Section 11’s limited remedy scheme. The only remedy afforded
a Section 11 plaintiff in a citizen suit for violation of ESA is injunction; Section 11’s civil and
criminal penalties are reserved for enforcement actions and are not remedies available to private
party plaintiffs.24 Thus, if early notice gives the parties an opportunity to resolve the perceived
harm, the injury has been redressed and the plaintiff no longer has standing before the court. The
ESA expressly authorizes the Court to award attorney fees “whenever the court determines such
award is appropriate” to further encourage settlement in good faith.25
Common Citizen Suit Subject Matter
The perception exists that most ESA citizen suits are brought by organizations seeking to
broaden the scope of the ESA; however, citizen suits that have developed the water withdrawal
take area of the ESA case law are often challenges to limitations in water deliveries imposed on
Bureau of Reclamation (Bureau) by the Services. The clearest instance in which a court upheld
water diversions alone as constituting a prohibited take is a Klamath Basin case challenging the
legitimacy of ESA-required irrigation reductions for users of the Bureau’s Klamath Irrigation
Project (Project).26 Pursuant to Section 7 consultation, the Services required the Bureau to
sharply reduce Project water deliveries to keep more water in-river for threatened coho salmon
and in Upper Klamath Lake for resident sucker fish. The Project-dependent irrigators sued to
overturn those 2001 BiOps in Kandra v. United States; the court held that the water-scarcity
mitigation measures that protected ESA-listed fish could be required of the Bureau and were
consistent with the ESA.27
The Interplay of Causation and Standing
Harmful habitat modification is most often the result of multiple actors, that reality can make it
24 16 U.S.C. § 1540 details civil penalties that can range from $500 to $25,000 per violation. Knowing violations of
the ESA, rules adopted pursuant to the ESA, or permits or certificates issued under the ESA can result in civil
penalties ranging from $12,000 to $25,000. Any other violation can be assessed a civil penalty of up to $500 per
violation. A person who knowingly violates most provisions of Section 9 of the ESA is subject to criminal penalties
of a fine of not more than $50,000 or imprisonment of up to one year, or both. A person who knowingly violates
any other provision of the ESA can be fined up to $25,000, imprisoned up to 6 months, or both. A knowing
violation occurs when the violator knowingly commits the action, regardless of whether or not he is aware the
action violates the ESA.
25 16 U.S.C. § 1540(g)(4) (1999)
26 During 2000, the Bureau of Reclamation had failed to consult under Section 7 on the impacts of its Klamath
Project’s 2000 Annual Operations Plan, resulting in a lawsuit. On April 3, 2001, the Bureau was ordered to consult
with the Services on its 2001 Annual Operations Plan, and was also enjoined from any further water deliveries to
its contract irrigators until it did so. Pac. Coast Fed’n of Fishermen’s Ass’ns. v. U.S. Bureau of Reclamation, 138 F.
Supp. 2d 1228, 1250 (N.D. Cal. 2001). Two 2001 BiOps were issued that, for the first time, were based on flow
needs for lower river coho salmon developed in the Hardy Flow Study and on minimum lake level needs for
endangered suckers. Pac. Coast Fed’n of Fishermen’s Ass’ns. v. U.S. Bureau of Reclamation, No. C02‐02006‐SBA,
2003 U.S. Dist. LEXIS 13745, at *13‐*14 (N.D. Cal. July 14, 2003), rev’d on other grounds, 426 F.3d 1082 (9th Cir.
2005).
27 Kandra v. United States, 145 F. Supp. 2d 1192, 1207 (D. Or. 2001).
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Page 6
difficult for a defendant to establish “standing”. Standing is defined as the right to commence
legal action, established by showing a concrete, imminent injury traceable to the defendant’s
action that can be redressed by a favorable decision.28
While a plaintiff may be able to establish that an agency’s actions resulted in foreseeable harm,
stopping that action may not redress the harm if the other habitat modifiers continue. A variety
of actions combine to cause take; diversion, stormwater runoff, and groundwater pumping can
combine to result in harm to of a listed fish species. Where enjoining the actions of a few
defendants is insufficient to redress the harm, the plaintiff has no standing to bring suit.
The traditional causation analysis applied in ESA cases requires a defendant’s actions be the
proximate cause of the death or injury of the wildlife harmed, requiring that the harm be a
foreseeable consequence of a knowing action.29 However, in at least one 9th Circuit case, this
approach was not employed.
In Pyramid Lake Paiute Tribe v. U.S. Dep’t of Navy, the plaintiff alleged the Navy violated ESA
Section 9 because its diversions from the Truckee River in Nevada lowered the water level in
Pyramid Lake, and consequently, the clearance at the delta between the Lake and the Truckee
River, up which the fish must travel to spawn.30 Denying the plaintiff’s claim, the court held that
no harm was shown, as “[t]he evidence does not establish that any one year's diversions of
Project water has actually caused the cui-ui's spawning problems”; and the Tribe failed “to
distinguish the Navy from other users of Truckee River water,” one of whom was the Tribe
itself.31
Conclusion
ESA prohibits take of endangered species, and assigns liability to any actor who causes it, either
directly or through habitat modification. However, citizen suits against small government actors
have not proven to be a popular mechanism for enforcing the Act’s prohibitions. Nevertheless,
these entities face possible liability when their actions through water withdrawals and wastewater
28 Standing is defined as “the question of… whether the litigant is entitled to have the court decide the merits of
the dispute or of particular issues.” Warth v. Seldin, 422 U.S. 490, 498 (1975). Article Three of the United States
Constitution requires a plaintiff establish standing by showing:
(1) it has suffered an injury in fact that is
(a) concrete and particularized and
(b) actual and imminent, not conjectural or hypothetical;
(2) the injury is fairly traceable to the challenged action of the defendant; and
(3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.
29 Sweet Home, 515 U.S. at 700, n.13, calling for the application of “ordinary requirements of proximate causation
and foreseeability.”
30 898 F.2d 1410 (9th Cir. 1990). The 9th Circuit’s decision reflects the unresolved difficulty in applying traditional
tort law concepts such as proximate cause to water withdrawal issues, in which users are not equally positioned,
due to the first‐in‐time, first‐in‐right nature of water use seniority. See Rasband, J., above at fn. 19.
31 Id.at 1420.
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discharge result in take of a species through habitat modification. Through careful compliance
with all permit conditions, the risk of liability can be further reduced.