From: <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Date: Jun 9, 2017 5:58 PM
Subject: RE: Idaho Department of Environmental Quality - Palouse River Subbasin: 2017 Temperature Total Maximum Daily Load (TMDL)
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Good Afternoon Benjamin,


The final Palouse River Subbasin Temperature TMDL document is on the Idaho DEQ website at water-quality/surface-water/ tmdls/table-of-sbas-tmdls/ palouse-river-subbasin/, links to the document are at the bottom of the page. Response to comments can be found in Appendix D. That you for submitting your comments and please feel free to contact me with any additional questions.






Sujata Connell


Water Quality Analyst


Idaho Department of Environmental Quality


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Excerpt from Palouse River Subbasin Temperature TMDL, Appendix D of the Comments Provided By: Electronic Review for the Environment, Inc.


Comment 1: Table of Contents – The list of tables relies heavily on shade data but doesn’t show data for temperature. Please consider adding water temperature data; it may help validate the other data, show useful information and potentially help identify inconsistencies or areas of special concern. Response: This comment will be considered in future temperature TMDL reviews in the subbasin.


Comment 2: Page 18 Sec 5.1.1 - Turbidity can be a factor that increases temperature from solar radiation due to suspended sediment absorbing heat from sunlight. This is a target factor of the Palouse Clearwater Environmental Institute projects that should be restated here for the purpose of explaining the importance of erosion control and riparian restoration pursuant to decreasing sediment load. Since it is unclear from this document how significant the turbidity affects temperature, the relative significance of this factor should be discussed. The discussion of the load capacity equation shown on page 17 section 5.0 should also consider the absorbance of heat attributable to this factor. If controlling turbidity is significant compared to shading, that information would be important for making decisions for priority-based allocation of resources (i.e. balancing efforts toward reducing turbidity and increasing shade). Response: This TMDL is written looking at system potential vegetation; we acknowledge that turbidity can be a factor that can add to the increase of stream temperature. However, by implementing riparian planting and other land management practices that increase shade, turbidity will also be reduced through stabilization of banks, filtering of runoff, etc.




Comment 3: Pages 25-26 - The design conditions for the Palouse River tributaries and South Fork Palouse River have no mention of measures to sustain the proposed potential natural vegetation (PNV) recommendations. Sustainable management strategies should reduce overgrazing in low shade areas and possibly utilize small net fencing to block grazing herbivores. A comprehensive ecological approach may improve sustainability for plant growth, foster beneficial animals, shade, and decreased water temperature. Palouse River Subbasin Temperature TMDL 105 Response: DEQ works with land management agencies in the subbasin to develop implementation plans that include sustainable management strategies for the assessment units in the TMDL. Assessment units in this TMDL are included in implementation plans that can be found at DEQ is working with the Palouse River Subbasin WAG and additional land management agencies to review and update the implementation plans in the Palouse River subbasin.



Comment 4: Page 37 section 5.5 – This section discussed implementation strategies for increasing shade along the Palouse River to bring the temperature down to be more conducive for salmon habitat. One strategy which should be considered includes coordination with wildlife management agencies adjust wildlife management plans in ways that may improve the overall ecosystem in ways that may reduce the river temperature. For example as shown on the website for Yellowstone Park, the reintroduction of wolves into the park had a positive effect on improving willow stands which in turn created more shade along creeks and rivers (which is a primary goal for this project): “Healthier Willow Stands in Yellowstone: This created a counterintuitive situation. Back in 1968, said Smith, when the elk population was about a third what it is today, the willow stands along streams were in bad shape. Today, with three times as many elk, willow stands are robust. Why? Because the predatory pressure from wolves keeps elk on the move, so they don’t have time to intensely browse the willow. Indeed, a research project headed by the U.S. Geological Survey in Ft. Collins found that the combination of intense elk browsing on willows and simulated beaver cuttings produced stunted willow stands. Conversely, simulated beaver cutting without elk browsing produced verdant, healthy stands of willow. In the three-year experiment, willow stem biomass was 10 times greater on unbrowsed plants than on browsed plants. Unbrowsed plants recovered 84 percent of their pre-cut biomass after only two growing seasons, whereas browsed plants recovered only 6 percent. With elk on the move during the winter, willow stands recovered from intense browsing, and beaver rediscovered an abundant food source that hadn’t been there earlier. As the beavers spread and built new dams and ponds, the cascade effect continued, said Smith. Beaver dams have multiple effects on stream hydrology. They even out the seasonal pulses of runoff; store water for recharging the water table; and provide cold, shaded water for fish, while the now robust willow stands provide habitat for songbirds. “What we’re finding is that ecosystems are incredibly complex,” he said. In addition to wolves changing the feeding habits of elk, the rebound of the beaver in Yellowstone may also have been affected by the 1988 Yellowstone fires, the ongoing drought, warmer and drier winters and other factors yet to be discovered, Smith said.” See full article On February 15, 2015 the Lewiston Tribune reported that wildlife agencies have been killing wolves in the Lolo region and that a motion is before a court requesting consideration of alternatives under the National Environmental Policy Act (NEPA). The case study of the reintroduction of wolves to Yellowstone Park cited above and the killing of wolves in the Lolo region suggest that perhaps wolves could be relocated to the Palouse River Subbasin. That might limit grazing of elk and deer along the creeks and river to improve the tree stands and shade as occurred at Yellowstone Park. Response: DEQ is not a land management agency, nor are we experts in specific implementation. DEQ does not suggest best management practices for implementation. DEQ works with land management agencies on implementation plans that include suggested best management practices to be implemented on private lands on a voluntary basis.From: Benjamin Wagner <This email address is being protected from spambots. You need JavaScript enabled to view it.>


  • 2/20/2017 at 12:49 PM
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