235 



DRAFT 



Irrieation (pages 78-81) 



The totals for the columns in the Table titled Oregon River Basin runoff characteristics 

 (cfs) are 105,000 (mean annual runofO, 22,500 (mean summer runofO, and 5730 (low 

 summer runofO respectively, not 107,000, 21,000, and 6,000 as indicated. 



Nonpoint Source Pollution (pages 80-81 and 159-160): 



The authors provide an adequate assessment of the distribution and impacts of nonpoint 

 source pollution (NFS), but they imply that agriculture is the only land management 

 activity responsible for these problems. Nonpoint source pollution is common to many 

 land use activities, but agriculture appears to be solely implicated because: (1) this 

 discussion is presented only in the agriculture section, and (2) by the statement that 

 'agricultural land use predominates the monitored problem areas. " It should be 

 clarified that the referenced ODEQ report was prepared to guide the development of an 

 NPS database and NPS control plans, and was not designed as a "...fault-finding or 

 finger-pointing exercise" (ODEQ 1988). Further, the statement that agriculture 

 'predominates the monitored problem areas" is not a conclusion of, nor appears to be 

 substantiated by the ODEQ report. Assigning the relative importance of land 

 management activities basal upon the location of "monitoring areas" is an invalid 

 approach that does not recognize that upstream activities can affect water quality in 

 downstream reaches. 



The ODEQ report (ODEQ 1988) included a description of land use activities potentially 

 contributing to NPS problems by citing the "land uses most commonly cited in 

 connection with" the NPS problems for each basin. This qualitative information is 

 summarized in Table 1. For consistency with the OFIC report subject, six basins were 

 excluded because they do not contain anadromous salmonids. Forestry was referenced 

 by the respondents as often as agriculture and grazing in identifying land use activities 

 potentially contributing to the NPS problems. Forest management was also identified 

 as a potential contributor in all basins where anadromous salmonid populations exist 

 except the Umatilla. 



The ODEQ also presented a version of this information in a subsequent document that 

 reported the number of miles of stream affected by NPS pollution in each basin of the 

 state, and the suspected sources of this pollution (ODEQ 1990). This information is 

 reproduced in Table 2 (basins without anadromous salmonids were again excluded from 

 the comparison for consistency with the OFIC report subject). This information 

 suggests that forest management activities represent a considerable source of NPS 

 pollution, and that the number of stream miles potentially affected by forestry exceed 

 the estimates for all other individual activities. The authors incomplete presentation of 

 the ODEQ reports resulted in potentially erroneous conclusions. 



In describing the relative distribution of NPS problems the authors cited ODEQ (1988) 

 in reporting that: 



'Hood River Basin appeared most affected (84 perceru of assessed miles 

 had moderate or severe water quality impacts), and the Rogue River 

 Basin appeared least affected (44 perceru of assessed miles had water 

 quality problems). " 



A-29 



