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DateNameCompanyComment
 James McCarthyWaterWatch of OregonBig Dog Reservoir Comments – Application: R 88373 - MAY 20, 2017 The applicant states this reservoir is off-channel (p. 3) but the ODFW review sheet indicates at Question #1 that it is not off-channel. This issue should be clarified. The ODFW review further states that native migratory fish are not present (Question #2) but later states that the reservoir impounds water within the Bitterlick Creek drainage, a tributary of Little Butte Creek utilized by federally-listed coho salmon and state-sensitive summer steelhead. This issue should be clarified. ODFW states that confining the diversion to the recommended storage period (December through March) will lessen impacts to fisheries resources. However, according to ODFW data presented on p. 60 of the Rogue River Project Biological Assessment (U.S. Bureau of Reclamation, March 2012), federally listed coho spawners have been observed in Little Butte Creek from November 25th until February 1st. In addition, the same biological assessment presents data on pp. 62 and 63 indicating that a significant portion of the total coho smolt migration in Little Butte Creek occurs throughout the month of March. This assessment further states on pp. 58 and 59 that “The Little Butte Creek watershed provides some of the best coho salmon production in the Rogue River basin... and, from 1996 to 2000, this stream averaged 15 coho salmon spawners per mile (ODFW 2001a). This represents the highest average density of coho salmon spawners of all Rogue River basin areas sampled.” Given the threatened status of coho salmon and the primary importance of the Little Butte Creek subbasin to Rogue River coho abundance and recovery, to appropriately lessen impacts to fisheries resources, this application should be conditioned to only allow appropriation for storage at Big Dog Reservior during the month of February, and only then if the instream water water right on Little Butte Creek is met. The state should also require full measurement to ensure compliance with storage season and rate and volume limits. If on-channel, the reservoir should be required to move off-channel to prevent fish passage impacts as well as water quality impacts downstream from flows passing through the pond. In addition, an on-channel reservoir would make it difficult to enforce limits on the storage season. Even if fish are only present downstream of the reservoir (as appears to be the case), the water quality and regulatory problems remain for on-channel reservoirs. If off-channel, the application should be conditioned to require no releases from the reservoir to prevent the release of warmed or otherwise poor quality water into the system downstream.