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DateNameCompanyComment
 Jim McCarthyWaterWatch of OregonWilderness Trails Reservoir Comments – Application: R 89360 - June 18, 2023 The application states that migratory fish are “precluded” from reservoir reach but the ODFW Fish Habitat Distribution and Barriers web map shows documented presence of winter steelhead (spawning and rearing). This issue should be clarified. The reservoir impounds water within the Dead Indian Creek drainage, a tributary of Little Butte Creek utilized by federally-listed Coho salmon and state-sensitive summer steelhead. 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 the reservoir during the month of February, and only then if the instream water rights in Dead Indian Little Butte creeks are met. The state should also require full measurement to ensure compliance with storage season and rate and volume limits. The application describes an existing dam and reservoir without required fish passage or water use permit. The existing dam should be removed and 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 off-channel reservoir would make it easier to enforce limits on the storage season. The application should be conditioned to require no releases from the off-channel reservoir to prevent the release of warmed or otherwise poor quality water into the system downstream.