November 13, 1998
Mr. Steve West, Regional Administrator
Idaho Division of Environmental Quality
Boise Region Office
1401 N. Hilton
Boise, ID 83706
RE: Draft Lower Boise River TMDL and Subbasin Problem Assessment
Dear Steve:
I am pleased to provide comments on behalf of the Ted Trueblood Chapter of
Trout Unlimited on the Draft Lower Boise River TMDL and Subbasin Problem
Assessment (Draft Assessment). Trout Unlimited is the nation's largest cold
water fisheries conservation organization, with over 100,000 members organized
in some 450 local chapters. The Ted Trueblood Chapter of Trout Unlimited,
organized in 1991, represents about 400 Trout Unlimited members in the
Treasure Valley.
The Draft Assessment provides a good overview of water quality problems of
the lower Boise River. We found the documents well organized, with key
information in the 50-page report and the bulk of information in the
appendices. The overall balance of the Draft Assessment was primarily
focused on water quality conditions. There was less information on habitat
conditions as they relate to cold water fishes like trout and white fish. The
discussion on solutions to water quality and habitat problems was much too
brief to be very useful.
We would like to see more focus and discussion on the limiting factors
affecting fish habitat. A reference on page 26 does mention the habitat
assessment of Asbridge and Bjornn (1988), but does not summarize its key
findings or recommendations. Those aspects of the study should be brought
into this Assessment. Based on this study and Trout Unlimited members'
working knowledge of the Boise River, we believe a lack of suitable spawning
and rearing habitat is the limiting factor causing impairment to designated
beneficial uses of cold water biota and salmonid spawning. Control of
pollution from point and nonpoint sources will do little to reverse the
situation because sources of spawning gravels are blocked behind upstream
dams. The river has been channelized, and upstream water storage (flood
prevention) has also decreased habitat complexity.
The section on pollution control efforts needs expansion to discuss a full
range of watershed restoration actions. Restoration and/or creation of
spawning and rearing habitat in the upstream reaches of the lower Boise River
is possible with some side channels. Efforts with restoration along Loggers
Creek has had mixed success. A recent agreement between Idaho Fish and Game
and The Springs development will provide for a small side channel with
protection of the riparian area along the recommendations of IDFG. There are
other possibilities for side channel habitat restoration projects such as
through the Harris Ranch property and with the diversion channel into the
Boise City Canal. We have recently discussed restoration opportunities in a
partnership with Harris Ranch. If such an effort is launched in the near
future, we believe the Assessment could identify it as part of a larger
strategy for restoration to fully support the beneficial uses of the Boise
River.
We also have some comments on pollution control efforts. This section notes
that the agriculture community has demonstrated a willingness to protect water
quality in the lower Boise River (page 53). The Draft Assessment then states
that 9,279 acres have been incorporated into a project where best management
practices have been implemented. When this number is compared to the table
on page 20 (245,653 acres of irrigated cropland), it works out to 3.8 percent
of the lands making a contribution. The Draft Assessment should discuss the
strategy DEQ plans to employ to increase the percentage of lands implementing
pollution control efforts beyond 3.8 percent. Readers would also benefit
from knowing the participation rate needed to achieve necessary improvements
in water quality, i.e. is it 8 percent, 40 percent, or more?
The discussion on "reasonable assurance" on page 54 states that the TMDL will
rely substantially on nonpoint source reductions achieve desired water
quality, but if reductions are not achieved through "existing regulatory and
voluntary programs, then reductions must come from point sources." We would
recommend that said existing regulatory and voluntary programs could be also
be adjusted to be more effective, if necessary. Adjustments to existing
programs may be more cost effective and socially equitable than immediately
leaping to reductions from point sources as the sole solution to water quality
problems on the Boise River. Finally, the section could also describe how
organizations like Trout Unlimited can make a meaningful contribution to
improving water quality.
The Ted Trueblood Chapter would like to participate in the development of the
implementation plan when that work gets underway.
- Sincerely,
- Andy Brunelle
President,
Ted Trueblood Chapter
Trout Unlimited
cc. IDFG
ICL
IRU
EPA
Harris Ranch
