DRA urges Oregon Department of Environmental Quality (ODEQ) to prioritize projects to benefit the Deschutes Basin

On May 24, the Deschutes River Alliance submitted comments on the Oregon Department of Environmental Quality’s proposed “priority projects” for water quality standards implementation in its 2021-2023 Triennial Review. 

Under the Federal Clean Water Act, ODEQ is required to periodically review and update water quality standards, with input from the public. In its review, ODEQ identifies and prioritizes needed ‘projects’ to improve its water quality protection directives for the next three years.

In our comments, DRA supported three of ODEQ’s “high priority” projects - updates to the fish use maps used to set water quality standards for (1) temperature and (2) dissolved oxygen, as well as (3) plans to finally create procedures to address excessive and nuisance aquatic plant, algae, and phytoplankton growth.

The map updates are desperately needed. They were last updated in 2003. As mentioned briefly in our previous post, the available data on current fish use directly conflicts with ODEQ’s outdated maps. And despite ODEQ’s previous identification of the need in its 2017’s Triennial Review for 2018-20, no changes were made to the maps. Based on this, DRA pressed ODEQ to take specific and urgent action to complete these updates, to the direct benefit of redband trout and bull trout in the lower Deschutes River.

DRA also supported ODEQ’s high prioritization of creating a “phased, integrated approach” to deal with excessive, nuisance algae growth that often produce toxin dangerous to both humans and pets. Lake Billy Chinook’s frequent,annual algal blooms are a prime example of these conditions. The blooms that shut down Salem’s drinking water supply in 2019 are another example. We’re glad ODEQ is finally prioritizing it taking an active role on this important project.

To improve ODEQ’s approach on excessive growth, DRA suggested also addressing three other projects simultaneously with it – setting numeric nutrient pollution limits, revising and enforcing the numeric pH limits for priority waterbodies, and creating procedures to implement narrative algal growth controls. All of these projects directly influence, or are influenced by, the other projects. Nutrient pollution is a major contributor to excessive growth. An alternate indicator of excessive nutrient pollution and growth is pH levels. And by implementing the narrative standards for algal growth will improve ODEQ’s ability to respond to the issue on a whole. Addressing these together will create a more comprehensive approach to excessive growth that is more likely to be successful than any one of these projects on its own.

Finally, DRA urged ODEQ to prioritize ‘valuable’ and ‘urgently-needed’ projects. Currently, ODEQ also considers a project’s ‘level of effort’ and ‘risks to success.’ In our comment, DRA argued that valuable and urgently-needed projects that may be resource intensive or risky are exactly the project that need to be prioritized. Difficult projects need the extra attention and prioritization to be able to overcome inexperience or potential ‘risks.’ Delay will only make the project more difficult, and there is much more risk to Oregon’s aquatic life and ecosystems from ODEQ’s inaction. With that in mind, we urged ODEQ to emphasize whether a project is valuable and/or urgently needed rather than the difficulty or risk of undertaking the project. 

We will continue to fight to ensure that ODEQ provides sufficient protections for the Deschutes Basin and, in doing so, improves water quality statewide. We will continue to pay attention to ODEQ priorities and efforts and urge the agency to do all it can to improve the state’s waters.

Keep an eye on our blog for more updates.