LDR Regulation Letter June 28, 2021

Oregon Fish and Wildlife Commission 4034 Fairview Industrial Driver SE Salem, OR 97302

June 28, 2021

Curt Melcher, Director Oregon Department of Fish and Wildlife 4034 Fairview Industrial Driver SE Salem, OR 97302 Submitted via email to: odfw.commission@odfw.oregon.gov and curt.melcher@odfw.oregon.gov Re:

Lower Deschutes River temperatures and fish kill prevention

Dear Mary Wahl, Chair, Oregon Fish and Wildlife Commission and Curt Melcher, Director, Oregon Department of Fish and Wildlife: On behalf of the Deschutes River Alliance (DRA), The Conservation Angler (TCA), and Native Fish Society (NFS), we write this letter in support of the Oregon Department of Fish and Wildlife’s (ODFW) June 25 emergency regulation announcement and to urge ODFW and the Oregon Fish and Wildlife Commission (OFWC) to immediately adopt additional angling restrictions on the lower Deschutes River. The lower Deschutes native fishes need these extra protections to limit the additional potential anglerinduced mortality attributed to water temperatures. We support instituting “hoot owl” regulations designed to reduced temperature-related moralities and urge ODFW and OFWC to consider, if necessary, a temporary angling closure of the lower Deschutes from Sherars Falls to the mouth of the river.

The DRA, TCA and NFS are science-based advocacy organizations seeking collaborative solutions to basin-wide threats to the health of the Deschutes River and its tributaries. We advocate for improved water quality, a healthy ecosystem, and for the

establishment and protection of robust populations of resident and anadromous fish throughout the river’s entire watershed.

Water temperatures in the lowest stretches of the lower Deschutes are already extremely high. Since mid-June, water temperature has been consistently increasing. In the last week, peak daily temperatures have consistently topped 70°F and have reached as high as 74°F.1 These extreme water temperatures add tremendous environmental pressure to the lower Deschutes’ fish species who depend on cold water for their survival. It only makes sense for ODFW to take actions that are available to them to try to buffer these important fishes from increased angler induced catch-and-release mortality that may be caused by these extreme water temperatures.

Columbia River wild summer steelhead are already migrating to the lower Deschutes River. All of these wild steelhead are listed as a threatened species under the federal Endangered Species Act. Their forecasts for 2021 are among the lowest on record.

Additionally, the early portion of the Columbia River steelhead regularly includes more wild fish than hatchery fish – the current fish count numbers at Bonneville Dam indicate that this is the situation currently.2 This means that anglers are more likely to encounter wild steelhead during authorized fisheries. It is our obligation to protect the wild fish, and if we do that, the fishing opportunity will follow.

As a reminder of what extreme water temperatures can do, we want to call attention, as well, to the fish kill events that happened in the lower Deschutes during summer, 2015.

High water and air temperatures resulted in large numbers of sockeye salmon dying from heat-related stress. The temperature conditions this year approximate those seen in 2015. As such, it is absolutely vital that ODFW and OFWC take proactive steps to reduce additional environmental stress by instituting “hoot owl” regulation and, if deemed necessary, a closure for the lowest segments of the lower Deschutes River from to Sherars Falls to the mouth of the Deschutes to prevent a repeat fish kill.

See United States Geological Survey Moody Gauge. USGS 14103000 DESCHUTES RIVER AT MOODY, NEAR BIGGS, OR. 1

2

http://www.cbr.washington.edu/dart/wrapper?type=php&fname=adultmg_1624914154_719.php

Thank you for your attention to this matter up to this point. We look forward to your careful consideration of regulations and, if needed, closures for the lower Deschutes River to protect its struggling native fish species. The DRA, TCA and NFS believes urgent action is necessary, and our staff and Boards are available to answer any questions.

Sincerely,

Sarah Cloud Executive Director Deschutes River Alliance

Dave Moskowitz Liz Perkin, PhD Executive Director Northern Oregon Regional The Conservation Angler Coordinator Native Fish Society