If you read this blog then you are most likely already aware that the Oregon Department of Environment Quality is currently proposing to update rules for temperature and dissolved oxygen standards in water bodies throughout the state. You can learn as much as you would like about this on their website. Earlier this week ODEQ held a Zoom meeting to go over the proposed changes, answer questions, and take public testimony. After reading most of the materials on the ODEQ website, watching the presentation, and listening to the public testimony, I was reminded of the keynote speech at the last Oregon Chapter of the American Fisheries Society meeting which encouraged professional fish biologists to not despair and continue to work on good science, even when so many detractors, even those claiming to represent fish, try to undermine their work.

While I have been a frequent critic of ODEQ, I do not question the basic science that has come from them. From my perspective, the issue has always been funding and the desire on the part of ODEQ leadership to address the really big, tough problems. For example, it’s one thing to say that the Crooked River is polluted by agricultural runoff, it’s another to have the political will and ability to do something about it.

I have been educating myself and writing about Deschutes Basin water quality, including the Crooked River, for many years. Here is a paper I wrote in 2017 in response to claims being made about pH in the Lower Deschutes. Here is a post I made in 2019 about water quality. Here is another, specifically about the Crooked.

I have no idea what type of written comments have been made on the proposed rules, but the public comments at the meeting mirror the messages I have seen from some NGOs. Some of these groups seem to want to stir up controversy, probably as a fund raising tool. Some negative comments were simply mind boggling, like, why haven’t you done this sooner? Well, as they explained, they now have the necessary data. Frankly, we should be happy they are doing it.

There were some comments about needing to extend the time periods when the dissolved oxygen standards are to be in place. I am not in a position to understand why ODEQ picked the dates they did, but they did work with ODFW on these new rules. Perhaps there is something I don’t understand going on here.

The primary criticisms, however, had to do with changing pH standards for the Crooked River and Trout Creek. This is a subject that I have be reading about for some time and have no concerns. To be clear, I am concerned about dangerously elevated pH, but pH at 9.0 is not a problem. You really should read the ODEQ paper on this, but let me summarize it. (BTW, if you read the paper, “diel” means a 24 hour period, think daily.)

pH is naturally occurring and also comes from human activities, like applying excess fertilizer which then pollutes a stream and generates high levels of algae which increases pH via photosynthesis. pH levels in basins similar to the Crooked and Trout Creek have natural pH levels above 8.5 and currently have pH standards up to 9.0. pH levels above Prineville Reservoir, and above most anthropogenic sources, have been measured exceeding the current 8.5 standard. There are no adverse impacts on aquatic life at pH levels of 9.0 and below. From 9.0 to 9.5, there must be extended exposure for adverse impacts to occur.

ODEQ states that they want to use the best available science to set pH standards. They acknowledge that human activities can contribute to elevated pH levels and state that this must be further studied and remedied if found to be a significant factor. They also acknowledge that elevated temperature can play a role and state that temperature standards must be set. None of this subtracts from the desire to set pH levels that reflect its natural occurrence using the current best available science.

At the public meeting the comment was made that pH standards in the Crooked River and Trout Creek should be kept low to protect the Lower Deschutes. I understand the abundance of caution argument, but science tells us that a pH up to 9.0 is not detrimental. Further, if the Crooked and Trout Creek have naturally higher pH levels, then they have been contributing that load to the Lower Deschutes for far longer than we have been here. Finally, I have had many conversations over many years with biologists and other scientists who believe that the Lower Deschutes should also have a pH range up to 9.0.

Sometimes the best available science is not followed for a variety of reasons: economic, social, political, organizational, etc. I believe that ODEQ is using the best available science in their proposed rule changes and support them. If you want to submit comments on the proposed rules I suggest you do not simply follow the recommendations made by others but go to the ODEQ website, at least skim the Notice of Proposed Rulemaking, and carefully read the ODEQ paper on the proposed pH changes. Comments can be made until June 23.