Recovering Deschutes Basin Steelhead — Part 3
By Alex Hardison, Communications Manager, & Fiona Noonan, Wild Lands & Water Program Manager
A Vanishing Voyager
Of the many charismatic creatures found throughout the dense forests, expansive plateaus, glaciated peaks, and meandering waterways of the Pacific Northwest, steelhead may be the most captivating. Though elusive and enigmatic, they epitomize a certain tenacity and resilience needed to master the many challenges posed by this rugged part of the world.
But there is a limit to their capacity to perpetually surmount escalating threats in a world wrought by rapid and unnatural environmental change. Irrigation has “greened” arid lands for agriculture, but at the same time has profoundly transformed the West by wringing dry many of its rivers and streams. The extensive network of western dams has fundamentally altered natural flows and permanently blocked access to over 40% of historical Columbia Basin spawning and rearing habitat. A warming world driven by anthropogenic carbon emissions is elevating average air and water temperatures, straining water resources, reducing snowpack, and degrading ocean conditions, all of which negatively impact already imperiled steelhead populations.
Steelhead are uniquely impacted by climate change, because, unlike Pacific salmon that remain relatively close to the North American coast, steelhead quickly move offshore toward the middle of the ocean. This leaves them especially vulnerable to increasing marine heat waves and less productive oceanic conditions driven by climate change.
Credit: Su Kim, NOAA Fisheries
Like many watersheds east of the Cascades, these stressors converge in the Upper Deschutes Basin, where steelhead must contend with a watershed reshaped by irrigation infrastructure, water withdrawals, and, increasingly, climate change. What was once a freely accessible network of prime habitat that supported abundant steelhead and salmon populations has been dramatically degraded over the past century. Efforts to reestablish a naturally reproducing Upper Basin steelhead population remain limited by insufficient water quality and quantity due to withdrawals for irrigation.
The duality of steelhead resilience in the face of, and vulnerability to, anthropogenic transformations to the waterways that have sustained them for millennia is a somber juxtaposition. Amidst a global biodiversity crisis and in recognition of the existential threats facing species like steelhead, wildlife conservation regulations have emerged to address the threat of extinction. Within the Deschutes Basin, steelhead recovery efforts are inextricably linked to regional water management.
So far in this series, we’ve explored the fascinating life history of Deschutes Basin steelhead, the Upper Basin rivers and streams that once sustained abundant populations, and how irrigation infrastructure and water withdrawals have degraded the ecological conditions they depend on.
Now, we delve into the intersectional intricacies of the United States’ most famous wildlife conservation law and Central Oregon’s prevailing framework for (theoretically) balancing the needs of water users and threatened species to better understand a path toward meaningful steelhead habitat restoration and population recovery in the Upper Deschutes Basin.
Regulating for Recovery
Within the expansive northern Pacific domain of steelhead, the Columbia River Basin is the central artery to the interior of the western continental U.S. and a vast network of Pacific Northwest salmonid watersheds.
Modern distribution of anadromous fish throughout the Columbia River Basin.
Credit: NOAA Fisheries
Before 1850, up to 18 million steelhead and salmon returned to the Columbia Basin each year to spawn. Since then, steelhead and salmon populations have collapsed catastrophically due to the many dams that now block or limit fish passage and irrigation withdrawals from the waterways where native salmonids spawn and rear. In 2021, fewer than 70,000 summer steelhead returned upstream of Bonneville Dam for the entire Columbia Basin — the largest drainage in the Pacific Northwest — and the 2024 upriver summer steelhead return forecast was just over 126,000.
It’s clear that steelhead and salmon are in an existential struggle across the Pacific Northwest. Currently, there are 28 population groups of Pacific salmonids along the West Coast that are officially listed as “threatened” or ”endangered” under the Endangered Species Act.
The Endangered Species Act (ESA) has earned a reputation as one of the United States’ most powerful environmental laws. Congress passed the law in 1973 to protect plants and animals at risk of extinction due to the impacts of human activity. ESA protections have since helped bring many species back from the brink of extinction — including the California condor, the humpback chub, and even the bald eagle. The goal of the ESA is to prevent the extinction of imperiled species and support efforts to recover populations to stable levels that would allow for their removal from the endangered and threatened species list.
In 1999, Middle Columbia River (MCR) steelhead were listed as threatened under the ESA. This listing extended ESA protections to steelhead throughout Middle Columbia River subbasins, including Central Oregon’s Deschutes Basin.
The Middle-Columbia River steelhead are designated as a Distinct Population Segment (DPS) under the ESA. Classifying a regionally specific population of a listed species as a DPS is intended to inform management strategies by recognizing the importance of the genetic diversity that comes from broad geographic distribution and isolation. For steelhead and Pacific salmon, this diversity is one of these species’ greatest assets and sources of resilience to environmental change throughout their range.
Credit: D. Crouse, NOAA
Two Federal agencies — the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS), collectively referred to as the “Services” — are responsible for the listing of threatened and endangered species under the ESA and managing them for recovery. Because steelhead spend part of their life in the Pacific ocean, their wellbeing is ultimately the responsibility of NMFS, the federal agency tasked with administering the ESA for listed marine species and anadromous fish.
The ESA prohibits any person, agency, or entity from killing or harming an ESA-listed species to the degree it impacts essential behavioral patterns — known in ESA parlance as “take.” The ESA listing of Mid-Columbia River steelhead meant that Deschutes Basin water users could be liable for the harms their activity inflicts on this protected species. Of all water users throughout the Basin, irrigation districts proportionally exert the greatest influence on the system due to their extensive activities and infrastructure. Irrigation dams and diversions in the Upper Deschutes Basin have fragmented and blocked hundreds of miles of historical steelhead habitat, interfered with the life history needs of native anadromous fish species, and severely degraded water quality. Collectively, these transformations to Upper Basin hydrology profoundly impact steelhead survival.
In order to shield themselves from possible liability over the take of steelhead and other listed species without suspending irrigation water withdrawals, eight irrigation districts and the City of Prineville began the process of developing the Deschutes Basin Habitat Conservation Plan (HCP) in 2008.
The stated purpose of the HCP was to create a collaborative management framework that would balance the ecological needs of ESA-listed species with the needs of Deschutes Basin water users.
The functional purpose of the HCP for the irrigation districts was to demonstrate to the Services that voluntary operational changes and conservation measures they agreed to adopt would minimize and mitigate to the maximum extent practicable the “incidental take” — i.e. unintentional, but not unexpected harassment, harming, killing, etc. — of steelhead and other ESA-protected species considered by this plan. By proving to the Services that the specific actions outlined in the HCP would reduce the degree of impacts from irrigation activities to the extent they would not interfere with steelhead survival and recovery, the districts would be issued an Incidental Take Permit (ITP) that would grant them the legal protection to continue irrigation activity despite the well-understood negative impacts to steelhead. When the Services decide to issue an ITP on the basis that an HCP will sufficiently minimize and mitigate harms to listed species, they are taking on ultimate responsibility and legal liability for the outcomes.
Development of the HCP began in 2008, and it wasn’t finalized until the last days of 2020. During this protracted period, several things happened that changed the calculus for steelhead protections in the Upper Deschutes Basin. Notably, fish passage was reestablished at the Pelton Round Butte dam complex in 2012, facilitated via two-way “trap-and-haul” operations that transport migrating salmonids by truck from Lake Billy Chinook to the Lower Deschutes River and vice versa. This meant that anadromous fish like steelhead and salmon could now move between the Upper and Lower Deschutes Basin for the first time since the Pelton Round Butte Project was completed in 1964 and a failed first attempt to establish fish passage was abandoned in 1968.
Round Butte Dam holding back Lake Billy Chinook.
With 2012 ushering in the return of anadromous fish above the Pelton and Round Butte dams, Upper Deschutes Basin water users needed to address how their activity would impact this steelhead homecoming. To recognize the implications presented by this new development, in 2013, NMFS took the unprecedented step of designating all steelhead above the Pelton Round Butte Project as a “non-essential experimental population” (NEP). The NEP designation relaxed some of the protections associated with standard ESA listings, temporarily allowing irrigation districts to conduct their otherwise lawful activity without violating the ESA.
NMFS bound the NEP designation to expire after a period of 12 years as a way to incentivize timely collaborative progress between local stakeholders working toward conservation measures — including the irrigation districts in the midst of developing the HCP — and gather information over time about the efficacy of the then-nascent reintroduction effort. On January 15, 2025, the 12-year NEP designation will expire and Upper Basin steelhead will be listed as threatened, affording them full protections under the ESA. Once this happens, the provisions of the HCP — rather than the NEP designation — will shield the Incidental Take Permittees from liability for their impacts on steelhead.
An Anemic Plan
With an existential alarm tolling for Upper Basin steelhead, the HCP was finalized in 2020. As a result, NMFS issued a 30-year ITP to the eight Deschutes Basin Board of Control irrigation districts and the City of Prineville to cover the impact of their collective activities on steelhead. USFWS also issued their own ITP for activities resulting in take of two ESA-listed species in their purview: bull trout and the Oregon spotted frog.
Map of HCP “covered waters.”
The final Deschutes Basin Habitat Conservation Plan is massive, complex, and dense, weighing in at 751 pages (plus appendices) that outline a legally enforceable plan meant to reduce the harmful effects of irrigation. Despite its heft, the HCP largely boils down to 21 conservation measures — some with as many as 12 sub-parts — that apply to the “covered waters” in the document: Crane Prairie Reservoir, Wickiup Reservoir, the Upper Deschutes River, Crescent Lake, Crescent Creek, the Little Deschutes River, the Middle Deschutes River, the Crooked River, McKay Creek, Ochoco Creek, and Whychus Creek.
These conservation measures vary, but the majority outline minimum streamflow levels or reservoir storage volumes — plus or minus 10 percent — both during and outside of the irrigation season. Others specify financial contributions to restoration funds and limits on the rate of flow increase or decrease as water withdrawals are managed.
Since the end of 2020, the HCP has been in effect, with the stated intent to mitigate the impact of continued irrigation activity on steelhead and other listed species through implementation of the conservation measures outlined in the plan. Though the HCP initially looked like it could be a way to substantially improve conditions for steelhead, it’s instead been broadly framed as a conservation “floor” upon which Permittees and the Deschutes Basin as a whole would continue to build through other processes. Ultimately, though, the adopted conservation measures are collectively insufficient for striking a balance that provides for the needs of both steelhead and agricultural producers.
This isn’t surprising. Before the HCP was finalized, Central Oregon LandWatch recognized the inadequacy of the draft plan, and submitted comments asking for increased mandatory year-round and seasonal flows in key reaches of the Deschutes, the Crooked, and Whychus Creek. LandWatch found that the proposed conservation measures would meet neither the needs of the river nor ESA-listed species, contained numerous loopholes that would result in a high level of uncertainty around whether the measures would be implemented, and would also fail to guarantee that irrigators with junior water rights could continue operating.
Four years into the HCP’s implementation, it’s clear that this was a prescient analysis. The HCP may be a starting point for minimizing take in the Upper Deschutes Basin, but it represents only a fraction of the available options for fully supporting steelhead recovery.
(Still) Managed Like Irrigation Canals
The Crooked River and Whychus Creek
Consider the HCP’s shortcomings within the two Upper Deschutes Basin waterways that together represent the greatest steelhead habitat restoration potential: the Crooked River and Whychus Creek.
A fundamental flaw in the HCP is that it does not establish mandatory flows and temperature standards that steelhead and other native fish species need to survive. At its core, it is a list of overly-flexible target flows — the 21 conservation measures — that have little basis in the ecological needs of the covered species in the Crooked River and Whychus Creek. Further, it does not provide the steps or mechanisms required to reach even these targets.
ITPs allow limited harm to protected species, provided that the Permittees take steps to minimize and mitigate their impacts in order to not impede recovery. For species like summer steelhead, maintaining reliable water flows at the right times and locations is critical to fish population recovery efforts. In theory, therefore, the irrigation districts should be required to implement conservation measures to ensure that their water storage and withdrawal practices do not impede the necessary conditions for the survival and recovery of these species.
The Crooked River flowing through the Upper Canyon below Bowman Dam. Credit: BLM
On the Crooked River, irrigation activity has created a “reverse hydrology” below Bowman Dam by storing water in Prineville Reservoir throughout the winter and releasing the bulk of flows in the summer, creating an unnatural flow regime inconsistent with a high desert runoff-driven system like the Crooked. The HCP could have established minimum year-round flows in the Crooked River to support the recovery of imperiled native fish species, but the adopted measures fall well short of what experts believe is necessary to meet the ecological needs of steelhead.
Previous studies from the Oregon Department of Fish and Wildlife (ODFW), for example, have determined that flows of 140 cfs would optimize physical habitat conditions for juvenile steelhead, generally support all life stages of both steelhead and Chinook salmon (another fish species covered by the HCP), and would also benefit native redband trout. However, in recognition of the need to balance flows for fish with those for irrigators, further ODFW analysis found that flows ranging from 80 to 140 cfs in a median or wetter water year— lower in drier years — would sustain most of the fish below Bowman Dam, while also allowing for other water uses and adequate storage in Prineville Reservoir. Yet, the HCP still allows the Crooked River to go down to the legal minimum discharge from Bowman Dam of 10 cfs, which happened as recently as September 2022. Such conditions yield lethally low flows and high water temperatures, raising questions over the efficacy of the HCP in terms of minimizing harm, especially in the context of the compounding threats of climate change and drought.
The Crooked River below Bowman Dam at 10 cfs. Credit: ODFW
LandWatch’s Science Advisor, Amy Stuart — who spent 25 years working on the Oregon Department of Fish and Wildlife’s efforts throughout the Crooked River — explained that:
“Given the significant gap between current conditions and the flows that fish like steelhead require for their biological needs — whether for spawning, incubation, rearing, outmigration, or return migration–the HCP represented a monumental opportunity. With September of 2022 as a stark example, the HCP has fallen well short.”
Amy Stuart on the Crooked River below Bowman Dam.
If the HCP serves as a “floor” for steelhead conservation on the Crooked River, its lack of ability to prevent the truly alarming flow scenario that occurred in September 2022 also points to a substantial amount of remaining work needed to restore habitat conditions for steelhead and other native fish species.
Upper Whychus Creek.
To the west, on Whychus Creek, a similarly large gap exists between the flows necessary to support steelhead and the minimum flows required by the HCP. As with the Crooked and its tributaries, stream temperature is the key limiting factor for steelhead spawning and rearing in Whychus Creek, and low streamflow from irrigation withdrawals is primarily responsible for stream temperatures during critical parts of steelhead’s life history. In Whychus Creek, the temperature impacts of upstream water withdrawals are most evident at river mile six, after an extended stretch devoid of cooling spring-fed flows. Research by the Upper Deschutes Watershed Council has shown that 67 cfs — more than three times the HCP’s minimum flow of 20 cfs — would be required at the hottest time of the year when irrigation withdrawals are highest to meet the state-set threshold of 18°C for salmonid rearing and migration at river mile six.
As LandWatch’s Rivers Advocate, Tod Heisler, notes:
“We already know what 20 cfs minimum flow in [Whychus Creek] produces at river mile six. There’s no mystery. And we already knew that it was woefully inadequate [before the HCP]. So why would [NMFS] allow that minimum flow to be set in the conservation measures of the HCP when we know it doesn’t get anywhere near the right temperature?”
Tod Heisler on Whychus Creek.
In fact, the HCP will not improve stream temperatures on Whychus, because the conservation measures will not result in any additional instream flows in the next 30 years. Instead, the conservation measures on Whychus Creek primarily require the maintenance of flows established by restoration efforts that predate the HCP’s implementation.
While the decades-long work to update irrigation infrastructure, restore flows, and improve habitat conditions in Whychus Creek has been collaborative, innovative, and a huge step in the right ecological direction, it simply isn’t enough to ensure the survival of steelhead populations.
Part of the overarching problem with the HCP as it pertains to Whychus Creek and the Crooked River is that it uses ecological baseline conditions detached from the biological needs of the species to establish conservation measures. The plan insufficiently describes how steelhead have been impacted by dams, irrigation withdrawals, and altered flow regimes over the past 150 years, and treats the period immediately prior to the start of planning in 2008 as the “historical conditions” that form the reference point for any conservation measures. By neglecting the long history of human harms to steelhead, the HCP frames the impacts of irrigation activities as relatively minor, and in turn posits solutions that are equally minor.
We need a plan for the Crooked River and Whychus Creek that meaningfully redresses the impacts of irrigation and details the steps required to aid steelhead recovery in the Upper Deschutes Basin.
LandWatch sees the “balanced flows” described by ODFW as an important baseline to achieve on the Crooked River.
As a first step on Whychus Creek, even ensuring minimum flows equivalent to the instream water right below Indian Ford Creek — which varies between 33 and 50 cfs throughout the year — would meaningfully raise the “floor” for steelhead habitat conditions. And at critical junctures for migration, spawning, and rearing, Three Sisters Irrigation District (TSID) could adaptively manage streamflows to meet steelhead’s life history needs. TSID’s ability to flexibly adjust flow levels is unique in the Deschutes Basin, and the result of massive public investment in their irrigation infrastructure modernization over the past several decades. Although the HCP did not require such adaptive management, TSID’s technical capacity offers an unparalleled opportunity to support both anadromous fish and irrigation-dependent farmers.
Such changes are straightforward in concept, but they require significant compromise and creativity given the regulatory complexities that enshroud regional water management. Despite these challenges, one thing remains glaringly evident: it will require bold, imaginative, and urgent action on the part of water users that goes well-beyond what the HCP will accomplish on its own to restore the foundational ecological conditions steelhead need to survive and recover in the Upper Deschutes Basin.
An adult steelhead swimming upstream. Credit: USFWS
Rewatering for Recovery
Assailed by countless threats as freshwater juveniles, steelhead embark on a perilous migration to the Pacific Ocean, where they spend years navigating danger and adversity while growing into indomitable underwater nomads. Eventually, instinct beckons them back to their natal spawning grounds on a taxing journey to fulfill their life’s purpose, becoming living testaments to unwavering perseverance and vital engines of ecology in the process. By transporting abundant nutrition from the ocean to inland freshwater and terrestrial ecosystems during their return migration — both as a direct food source for wildlife and through post-spawning decomposition — they are essential for the ecological health of environments throughout their range. With each obstacle they overcome, their aquatic quintessence is revealed — a poetic reflection of the environment from which they emigrate, return to, through final rites nourish, and ultimately become.
The only way steelhead populations have a chance of meaningfully recovering in the Upper Deschutes Basin is if we improve habitat conditions by increasing the amount of water left in the rivers and streams they depend on. The fundamental opportunity of flow restoration is to ensure that the fish who successfully complete an arduous journey to return to the Upper Basin can capitalize on their efforts with adequate access to quality spawning grounds and begin reestablishing a natural cycle of reproduction.
To ensure steelhead remain a vital part of the Upper Basin’s future, we need a more robust and comprehensive water management framework that prioritizes the ecological needs of steelhead. The HCP did not get us there, but options for more efficient and equitable distribution remain. This includes establishing sufficient and enforceable minimum flows, improving irrigation infrastructure efficiency and addressing widespread waste, and implementing market-based incentives that promote water conservation and sharing in our water-scarce region.
These actions are both necessary and achievable, and collectively, they form a critical solution that can restore a thriving steelhead population to the Upper Basin. By embracing these innovative and pragmatic strategies, we can welcome steelhead home and ensure the long-term health of the watershed.
The iconic Deschutes steelhead. Illustration: Joseph Tomelleri