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1 1 INTRODUCTION This document provides an analysis of the Draft Washington State Forest Practices Habitat Conservation Plan (FPHCP) (Washington State Department of Natural Resources [WDNR] 2004) with the intent of determining whether the actions proposed under this plan have the potential to result in jeopardy to one or more salmon species listed as threatened or endangered under the Endangered Species Act (ESA). In our analysis, we apply the standards and methods routinely used by NOAA Fisheries and the U.S. Fish and Wildlife Service to develop Biological Opinions (BiOps), following guidance set forth in Section 7(a)(2) of the ESA, 50 CFR Part 402 (the consultation regulations), and the Endangered Species Consultation Handbook (NOAA Fisheries and USFWS, 1998). We also reviewed other BiOps published recently for assorted Habitat Conservation Plans, hydropower facility licenses, and federally approved or funded projects in Washington State. If, in their Biological Opinion on the FPHCP, the federal services determine that the effects of the proposed action would appreciably reduce the likelihood of the survival and recovery of the affected species, the project proponent may respond in one of two ways. They may either abandon the proposed action or they may accept terms and conditions (e.g., reasonable and prudent alternatives; RPAs) imposed by the agencies that ensure that jeopardy or adverse modification of critical habitat will be avoided. An incidental take permit for the FPHCP can be granted only if the proposed action, modified as necessary, will not jeopardize a listed species. The jeopardy criterion applies to species, or in the case of anadromous salmonids, to the analogous Evolutionarily Significant Unit (ESU), that are listed as threatened under the ESA. Salmonid ESUs typically comprise multiple populations distributed across one or more drainages. Jeopardy to a listed ESU is avoided when a majority of their constituent populations are viable; that is, large and robust enough to conserve the genetic and phenotypic diversity of the ESU, adapt to environmental variability, and remain self-sustaining in the natural environment over the long-term. McElhany et al. (2000) describe viable salmonid populations as having a negligible risk of extinction due to threats from demographic variation (random or directional), local environmental variation, and genetic diversity changes (random or directional) over a 100-year time frame. The Technical Recovery Teams appointed by NOAA Fisheries to identify populations, conduct risk assessments, and oversee recovery planning and implementation for listed ESUs found in the western United States have determined that the most important indicators of population performance associated with viable salmonid populations are abundance, productivity (population growth rate), spatial distribution, and diversity, expressed at various life history stages in associated freshwater and marine habitats (McElhaney et al. 2000, 2003). Population performance is influenced by myriad physical and biological components and processes that affect salmonid behavior, distribution, and survival across different spatial and temporal scales. The majority of populations comprising listed ESUs have been determined not to be viable. ESUs will be removed from the ESA threatened species list (i.e., delisted) when factors for May 11, 2005 Page 1

2 decline have been ameliorated, a sufficient number of populations within the ESU have become viable, and there is reasonable certainty that the ESU will continue into the foreseeable future. The geographic range of salmonid ESUs found within Washington State, although large, nonetheless is significantly smaller than the action area identified for the FPHCP; i.e., all nonfederal and non-tribal timberlands encompassed within the state s borders. Because jeopardy and recovery standards apply at the ESU level, it is appropriate that the effects of the action be evaluated at a more limited scale; namely, the geographic area occupied by fish belonging to the same ESU. Given time and budget constraints, it was impractical for us to attempt to ascertain whether all salmonid ESUs within the action area would be affected by the proposed action. We therefore reasoned that if credible analysis demonstrated that the survival or recovery of a representative ESU would be compromised by the FPHCP, a jeopardy determination could be warranted. Moreover, if it can be shown that the FPHCP poses a significant threat to one ESU, it is reasonable to conclude that similar potential for jeopardy exists for other ESUs within the action area. In either case, serious consideration would need to be given to modifying the FPHCP. Our approach, therefore, was to focus on a single, representative ESU the Lower Columbia Steelhead ESU that was listed as threatened in 1998 (63 Fed. Reg , March 19, 1998). For our analysis of probable project impacts, we selected the Kalama River watershed in southwest Washington, which is home to a population of summer steelhead, as well as to populations of fish from each of two other threatened ESUs found in this region: chum and Chinook salmon (LCFRB 2005). The Kalama also supports a population of coho salmon that belongs to the larger Lower Columbia Coho Salmon ESU, which was recently proposed for threatened status (LCFRB 2005). The potential impacts of actions implemented under the FPHCP are evaluated specifically as they relate to the habitat conditions within the Kalama watershed that might limit the survival and recovery of the resident steelhead population. Our assessment considers the effects of the proposed action, taken together with any cumulative effects and added to the environmental baseline that can be expected, directly or indirectly, to appreciably reduce the likelihood of the survival and recovery of the affected species. See 50 C.F.R (g). Using this approach, we demonstrate that the proposed action is likely to result in jeopardy to the Kalama River steelhead population. To facilitate ESA recovery planning, the Willamette-Lower Columbia Technical Recovery Team (WLC-TRT) has designated the Kalama River summer steelhead as a core population in the Cascade Strata of the Lower Columbia Steelhead ESU. 1 Core populations were typically historically large, and thereby offer the most likely path to recovery. While it is not necessary that all core populations within a strata be viable for an ESU 1 The WLC-TRT was convened by NOAA Fisheries to develop delisting criteria and assist with recovery planning for ESA listed salmonid populations in the Willamette-Lower Columbia salmon recovery region (McElhaney et al. 2003). Page 2 5/11/2005

3 to be viable, the WLC-TRT has recommended that recovery planners prioritize core populations when developing recovery plans (McElhaney et al. 2003). By applying a widely accepted habitat-effects assessment methodology to extensive, good quality scientific data, we provide compelling evidence that the FPHCP, as currently conceived, will jeopardize the Kalama River steelhead and appreciably reduce the likelihood of their longterm survival. Due to the importance of the Kalama River summer steelhead population as a component of the larger Columbia River Steelhead ESU, and given the current status and trend of other populations within the ESU, we conclude that the likelihood of recovery of the Columbia River Steelhead ESU would be significantly reduced by forestry practices implemented under the FPHCP. This conclusion, which would be sufficient in itself to justify modification of the proposed action, may be extended to other ESUs residing within the action area. We would expect the FPHCP to adversely affect all ESUs with populations that reside in watersheds within Washington State where non-federal timberlands are extensive. The remainder of this document comprises the major components of this analysis, organized as follows: definition of the environmental baseline and criteria for determining jeopardy; analysis of the likely effects of the proposed action on the Kalama River watershed and focus species populations; the jeopardy determination; and extrapolation of findings in the Kalama River to other watersheds in the LCR and implications for the recovery of ESA listed salmonid populations. 1.1 Environmental Baseline and Jeopardy Criteria Regulations implementing Section 7 of the ESA (50 C.F.R ) define the environmental baseline as the past and present effects of all Federal, state and private actions and other human activities in the action area. The environmental baseline also includes the anticipated effects of all proposed Federal projects in the action area that have undergone Section 7 consultation, and the effects of state and private actions that are contemporaneous with the consultation in progress. In this BiOp, such actions include, but are not limited to, all prior timber harvest and road building on lands covered by the FPHCP, existing HCPs related to timber harvest, 2 the Northwest Forest Plan, Aquatic Conservation Strategy, PacFISH, critical habitat designations, Cowlitz River hydroelectric project relicensing, Daybreak Star mine permitting on the East Fork Lewis River, and the current Washington State Forest Practice Rules as they apply on state timberlands. The regional area covered by the FPHCP is quite large (estimated at nearly 9.1 million acres). The environmental conditions throughout this area have been severely altered and generally 2 It is presumed that other HCP holders will remain subject to the terms of existing agreements. However, if other land holders are free to follow the FPHCP should they find it less restrictive, this will increase the amount of affected area. Page 3 3/2/2010

4 degraded since Euro-American settlement by a number of activities including, but not limited to, forest practices. The FPHCP incorporates this baseline in the evaluation of direct and indirect effects of activities covered by the plan (Section 4e-1) and generally acknowledges the causes of the degraded baseline status of watersheds it covers. The FPHCP also acknowledges the requirement to evaluate impacts likely to result from the proposed taking of species for which the [incidental take] permit coverage is requested (National Marine Fisheries Service 1996), and that impact identification involves the quantification of anticipated take levels. Take levels can be estimated either in terms of the number of animals or the amount of habitat affected. Due to the size of the affected area and the complexity of the analysis involved, impact identification in the FPHCP relies on an evaluation of the effects of the action on habitat. While we generally concur with this approach, we find the evaluation of impacts in the FPHCP is deficient for the following reasons: The application of baseline in the FPHCP is not appropriate for the purposes of a Biological Opinion; The FPHCP impact identification relies on assumptions that are not based on the best available science and information, and; Suitable information is available to evaluate the potential for jeopardy using a case study of specific species in a selected watershed. These issues are discussed in more detail in the following sections Application of FPHCP Baseline The FPHCP approach to estimating take and evaluating direct and indirect effects applies a hypothetical minimal effects strategy as the baseline for comparison (Section 4e-2). More specifically, the authors assert that the FPHCP will avoid jeopardy for ESA listed salmonids and other species because the plan protects 80 percent of the aerial extent of an arbitrarily defined set of critical areas 3 supposedly protected in the minimal effects strategy. This baseline is an inappropriate basis for estimating take or evaluating direct, indirect and cumulative impacts because: 1. It is not legally valid This baseline does not meet the definition provided in 50 C.F.R It is not a logical basis for comparison The evaluation of impacts needs to consider what the actual impacts on the affected species will be based on the current environmental baseline, as opposed to comparing the proposed action to a hypothetical standard that is deemed to be unreasonably restrictive. While many of the management 3 Critical Areas in the FPHCP are identified as wetlands, riparian zones of specified width, and hazardous slopes. Page 4 5/11/2005

5 actions included in the FPHCP will provide benefits to listed species, the FPHCP analysis does not directly analyze the potential impacts on listed species on the basis of current conditions and the best available science. 3. It may be factually invalid - The assumption that the FPHCP will improve habitat conditions (and thereby avoid jeopardy) based on this baseline comparison alone does not critically evaluate effects on habitat and the maintenance of, or progress towards, PFC Standards for Determining Jeopardy NOAA Fisheries has acknowledged that habitat-altering actions affect salmon population viability, frequently in a negative manner (NOAA Fisheries 2004a). However, it is often difficult to quantify the effects of a given habitat action in terms of its impact on biological requirements for individual salmon (whether in the action area or outside of it). Thus it follows that while it is often possible to draw an accurate picture of a species range-wide status and in fact doing so is a critical consideration in any jeopardy analysis it is difficult to determine how that status may be affected by a given habitat-altering action. In most BiOps, the state of the science usually will only allow a determination of the likely effects an action will have on a given habitat component. Since there is a direct relationship between habitat condition and population viability for species of concern, impacts on habitat condition are extrapolated to the impacts on the species as a whole. Examining the effects a given action has on the habitat portion of a species biological requirements provides a gauge of how that action will affect the population variables that constitute the rest of a species biological requirements and, ultimately, how the action will affect the species current and future health (NOAA Fisheries 2004a). Ideally, reliable scientific information on a species biological requirements would exist at both the population and the ESU levels, and effects on habitat should be readily quantifiable in terms of population impacts. In the absence of such information, BiOp analyses must rely on generally applicable scientific research that one may reasonably extrapolate to the action area and to the population(s) in question. Therefore, for actions that affect freshwater habitat, NOAA Fisheries usually defines the biological requirements in terms of a concept called properly functioning condition (PFC). PFC is the sustained presence of natural habitat forming processes in a watershed (e.g., riparian community succession, bedload transport, precipitation runoff pattern, channel migration) that are necessary for the long-term survival of the species through the full range of environmental variation. PFC, then, constitutes the habitat component of a species biological requirements. The indicators of PFC vary between different landscapes based on unique physiographic and geologic features. For example, aquatic habitats on timberlands in glacial mountain valleys are controlled by natural processes operating at different scales and rates than are habitats on low-elevation coastal rivers (NOAA Fisheries 2004a). In the PFC framework, baseline environmental conditions are described as properly functioning (PFC), at risk (AR), or not properly functioning (NPF). If a proposed action would be likely to impair properly functioning habitat, appreciably reduce the functioning of already impaired habitat, or retard the long-term progress of impaired habitat toward PFC, it will Page 5 3/2/2010

6 usually be found likely to jeopardize the continued existence of the species or adversely modify its critical habitat or both, depending upon the specific considerations of the analysis. Such considerations may include for example, the species status, the condition of the environmental baseline, the particular reasons for listing the species, any new threats that have arisen since listing, and the quality of the available information (NOAA Fisheries 2004a). Since lotic habitats are inherently dynamic, PFC is defined by the persistence of natural processes that maintain habitat productivity at a level sufficient to ensure long-term survival. Although the indicators used to assess functioning condition may entail instantaneous measurements, they are chosen, using the best available science, to detect the health of underlying processes, not static characteristics. Best available science advances through time; this advance allows PFC indicators to be refined, new threats to be assessed, and species status and trends to be better understood. The PFC concept includes a recognition that natural patterns of habitat disturbance will continue to occur. For example, floods, landslides, wind damage, and wildfires result in spatial and temporal variability in habitat characteristics, as will anthropogenic perturbations Evaluation Approach Our analysis focuses principally on the direct, indirect and cumulative effects of the proposed action and the related jeopardy determination. We do not provide information on the consultation history, the incidental take statement, conservation recommendations, or triggers to reinitiate consultation that are traditionally included in BiOps, as this information is not germane to the results presented here. Moreover, for brevity s sake, we have limited the amount of detail presented on the biological requirements of the species of interest summer steelhead much more so than is typical for BiOps. This type of background information normally provides important context for evaluation of biological requirements and impacts within the action area. However, it is readily available from the scientific literature and is well known to the authors of this report. The methodology we employ, although commonly referred to as a habitat-based impact assessment approach, goes well beyond the general analysis provided in the FPHCP. The FPHCP evaluation is flawed because it relies on an inappropriate baseline, is applied at too coarse a scale, and eschews recently developed species recovery criteria. Previous BiOps examining proposed actions that cover large geographic areas have evaluated effects at the site or drainage basin level, and, based on similarities with other areas, have extrapolated results to larger action areas. 4 This approach is both practical and scientifically sound since it is often infeasible to thoroughly evaluate impacts over exceedingly large action areas. There also 4 For example, the Plum Creek Native Fish Habitat Conservation Plan BiOp (US Fish and Wildlife Service and National Marine Fisheries Service 2000) examines the impacts of this action in 16 sub-basins across three Northwest states. Sub-basins are large river scale watersheds as defined by the Northwest Power and Conservation Council. Page 6 5/11/2005

7 appears to be a legal precedent for this approach: in Pacific Coast Federation of Fisherman s Associations v. National Marine Fisheries Service, 265 F.3d 1028 (9 th Cir. 2001), the court adjured the federal agency to aggregate the effects of individual projects to ensure that their cumulative effects are perceived if they are to have any confidence in a wide regional no jeopardy opinion. Recent advancements in our scientific understanding and the emergence of new information enables us to reliably evaluate the potential impacts of the proposed action at the individual watershed level. The findings of this more robust impacts evaluation provide a basis for evaluating the potential for jeopardy at the scale of the FPHCP. The case study used in this analysis will focus on the summer steelhead population of the Kalama River in southwest Washington. The Kalama River provides an excellent example for a case study of the impacts of the FPHCP. Populations of salmonids representing three listed ESUs (Lower Columbia River Chinook, Lower Columbia River Steelhead, and Columbia River Chum), and one ESU that has been proposed for listing (Lower Columbia River Coho) are present in the watershed. Two races spring and fall of Kalama Chinook are present, as are two races summer and winter of steelhead. There is also one population each of chum and coho salmon in the Kalama. The current status and extinction risk of ESA-listed Kalama River populations was analyzed by the WLC-TRT. This information in turn has been used by the Lower Columbia Fish Recovery Board to develop a recovery plan for listed Evolutionarily Significant Units (ESUs) occurring in the Lower Columbia Region (LCR) of southwest Washington State (LCFRB 2005). Building off of the work of the WLC-TRT, the LCFRB has set numerical and viability goals for recovery and identified the key habitat limiting factors that constrain the abundance and productivity of salmonid populations in the Kalama and other river systems of the LCR. NOAA Fisheries has officially endorsed the LCFRB recovery plan as a platform for recovering ESA listed salmonids in the Lower Columbia Region (NOAA Fisheries 2005), indicating that the information in the plan constitutes and is based on the best available science. The detailed information on watershed conditions and habitat limiting factors compiled by the LCFRB is particularly useful for the purpose of this BiOp. NOAA Fisheries has traditionally relied on a habitat based proxy for determining jeopardy in BiOps, recognizing that it is difficult to quantify the actual level of take that may result from a proposed action. The readily available information on extinction risk, habitat limiting factors, and the recovery priorities developed for Kalama River populations strengthen the habitat based approach used in this BiOp analysis because it can be more clearly demonstrated how adverse impacts resulting from the FPHCP could constitute jeopardy. This case study BiOp impacts analysis will be developed following the legal definition of baseline provided in 50 C.F.R and the PFC framework for jeopardy determinations described in the previous section. The analysis will focus on the condition of watershed processes that contribute to habitat conditions that are predominant limiting factors for the species of concern, and the potential impacts of the proposed action on these limiting factors. Specifically, this analysis will examine whether the proposed action will be likely to impair Page 7 3/2/2010

8 properly functioning habitat, appreciably reduce the functioning of already impaired habitat, or retard the long-term progress of impaired habitat toward PFC. 1.2 Effects of the Proposed Action: Case Study Kalama River watershed The evaluation of the effects of the proposed action presented in this section is comprised of three primary elements: A description of current baseline conditions in the watershed; the relationship between the current status of focus species and baseline conditions; and the direct, indirect and cumulative effects of the proposed action Baseline Conditions The Kalama River watershed is located in the Lower Columbia Region of southwest Washington State. The watershed covers approximately 205 square miles extending from the southwest flanks of Mount St. Helens to the confluence with the Columbia River near the town of Kalama, Washington. The watershed is bordered by the Toutle and Coweeman sub-basins to the north and the North Fork Lewis River to the south. Ninety nine percent of the watershed lies within Cowlitz County (LCFRB 2005). Elevation ranges from near sea level at the confluence with the Columbia River to almost 8,000 feet. Past volcanic eruptions and associated lahars have shaped the landscape of the watershed over the past 20,000 years. Volcanic lahars left unconsolidated deposits in the upper watershed which are a source of instability on moderate to steep slopes (USFS 1996). Most of the Kalama River watershed is forested and nearly the entire basin (96 percent) is managed for timber production. A portion of the upper watershed lies within the Mount St. Helens National Volcanic Monument which is managed primarily for natural resource protection and tourism. Areas along the lower river have also experienced agricultural, industrial and residential development, but in comparison to timber harvest these land uses are minor. Over 85 percent of the watershed is subject to the provisions of the proposed FPHCP. The Kalama River watershed is characterized by a limited range of aquatic habitats for salmonids. The lower basin is low gradient with tidal influence up to RM 2.8. Above Lower Kalama Falls at RM 10 the river enters a narrow V-shaped valley from the falls to its headwaters. These falls historically blocked access to all anadromous fish except summer steelhead until it was laddered in 1936, improving passage for summer run steelhead and spring Chinook. Another set of falls at RM 35 blocks passage to all anadromous species. Upper watershed tributaries have steep gradients and anadromous fish only have access to the downstream reaches. In general, anadromous habitat is limited to the Kalama River mainstem, the larger tributaries, and the lower reaches of smaller tributaries. Major Kalama tributaries include Gobar Creek, Elk Creek and the North Fork Kalama River (LCFRB 2005). The Kalama is one of eleven major sub-basins in the Lower Columbia Region. This watershed historically supported thousands of, winter steelhead, summer steelhead, and spring Chinook, fall Page 8 5/11/2005

9 Chinook, chum and coho salmon. Today, numbers of naturally spawning salmon and steelhead have plummeted to levels far below historical abundance. Chinook and chum salmon and steelhead have been listed as Threatened under the ESA and coho salmon are currently proposed for listing. The decline has occurred over many decades and can be attributed to a number of causes. Freshwater and estuary habitat has been reduced by agricultural and forestry practices. Key habitats have been altered or eliminated by modification of stream channels, floodplains, and wetlands. In the upper portions of the watershed, historic timber harvest practices have dramatically impacted riparian conditions and large woody debris (LWD) recruitment potential, and greatly increased the delivery of sediment to the stream channel. This in turn has resulted in simplified and degraded habitat conditions throughout the majority of the watershed. Hydropower operations on the Columbia River have also altered stream flows, estuary conditions, and migration timing and behavior. Listed fish populations are also impacted by commercial harvest, with the exception of steelhead (LCFRB 2005). Much of the Kalama River watershed is currently in relatively recent clearcut (46 percent) or early-seral stage vegetation (15 percent). Approximately 32 percent of the watershed is in midseral stage vegetation which will likely enter the harvest rotation within the lifetime of the FPHCP. Only 1 percent of the watershed is in late-seral stage vegetation, primarily on Federal lands (LCFRB 2005). Plum Creek Timber owns approximately 5,800 acres of timberlands in the central northern portion of the watershed (US Fish and Wildlife Service and National Marine Fisheries Service 2000). These lands are covered by the Plum Creek Timber Native Fish HCP (NFHCP), however it is not clear which provisions these lands would fall under should both HCPs go into effect. 5 Historic timber harvest activities on private timber lands are the primary cause of degraded habitat conditions within the watershed (LCFRB 2005, Wade 2000). This included the removal of a significant proportion of the watershed s riparian vegetation, high forest road density, and extensive logging on steep erosion prone slopes. High erosion rates and a significant increase in landslide frequency resulted in a significant increase in sediment delivery to the stream system. Splash dams, sediment inputs exceeding transport capacity, and loss of LWD recruitment potential have resulted in simplified channel conditions and loss of habitat diversity (LCFRB 2005, Wade 2000). While habitat conditions as a whole can be considered degraded, the current baseline condition shows an improving trend in many habitat variables because of changes in forest practices and the regeneration of riparian zones in areas that are in between harvest rotations. However, full recovery of riparian vegetation and the sediment transport regime in the Kalama River may take many decades (Wade 2000). Baseline conditions in the Kalama River watershed are described in more detail below using the diagnostic indicators provided in NOAA Fisheries matrix of pathways and indicators guidance 5 The potential influence of more restrictive HCP standards on Plum Creek lands are considered inconsequential for the purpose of this analysis. These holdings constitute a small portion of the total watershed acreage (approximately 4 percent) and are not likely to appreciably influence the overall findings. Page 9 3/2/2010

10 for conducting biological opinions (NMFS 1996). Following NOAA Fisheries guidance, watershed diagnostic indicators are rated using the following metrics: Properly functioning conditions (PFC) At risk (AR) Not properly functioning (NPF) Diagnostic - Water Quality A review of available Water quality in the Kalama River by the LCFRB (2005) found that water temperatures are a concern in some portions of the watershed. The lower 10 miles of the river and Hatchery Creek are on the state s 303(d) list (33 U.S.C. 1313) due to exceedances of water temperature standards. Of particular concern are elevated water temperatures at the mouth of the river where sediment accumulation has resulted in a wide shallow channel, creating a probable thermal migration barrier for some species. Stream temperature data for the middle and upper reaches of the river and its tributaries are generally within limits suitable for salmonids, even during summer low flow periods. However, temperatures as high as 23ºC have been recorded in Fossil Creek, a tributary stream above the anadromous zone (LCFRB 2005). This indicates the potential for poor shading and low stream flows to contribute to elevated water temperatures in some tributaries. Habitat modeling conducted by the LCFRB indicates that water temperatures are a limiting factor for several species (see Section ). Based on this information, water temperature conditions are rated AR for portions of the watershed. Long term monitoring water quality monitoring data for the Kalama River has shown routine nitrogen and phosphorous loading in excess of State standards, and occasional turbidity exceedances (Washington Department of Ecology 2005). Based on this information, the remaining water quality indicators are rated as AR. Turbidity conditions are a particular concern in many areas of the watershed given the current state of sediment processes Diagnostic - Habitat Access Habitat access in the Kalama River watershed is currently rated as AR, although there is a general trend towards improvement as man-made barriers are addressed. Sediment accumulation attributable to loading in excess of transport capacity has created a passage and possible thermal barrier at the mouth of the river, especially during low tide conditions. Sediment accumulation in downstream reaches, as well as culverts and logging debris jams are also thought to have created passage barriers in several tributary streams in the watershed Diagnostic - Habitat Elements Habitat conditions in the Kalama River and its tributaries are generally degraded, with several habitat elements rated as NPF. The primary reason for this rating is the lack of LWD and Page 10 5/11/2005

11 degraded substrate conditions due to high sediment inputs. elements are provided below Ratings for individual habitat Large Woody Debris/Riparian LWD is lacking in most mainstem and tributaries, and there is low recruitment potential throughout the watershed due to the past timber harvest practices and the removal of instream wood during the 1970s and 1980s. The LCFRB rated riparian conditions as moderately impaired in all but one of eighteen subwatersheds in the system (the former, rated as functional, occurs on Federal lands) (LCFRB 2005). Based on these findings, riparian conditions and LWD are rated as NPF. Substrate Substrate conditions in the Kalama River are also rated as NPF, primarily because of ongoing concerns regarding high levels of substrate fines throughout the watershed. Sediment production in the watershed is influenced by high road densities on steep slopes and erodable soils. In addition, many areas of natural instability exist in the basin in conjunction with past clearcuts. These conditions have increased the frequency of mass wasting events in the basin and many areas of instability are known or presumed to exist. Existing studies conducted by WDFW in the basin through 1994 indicate that fine substrates in sediments are a significant concern. A screening level watershed analysis conducted by the LCFRB indicated sediment processes were degraded in 12 of the 18 Kalama River subwatersheds, with moderately impaired to impaired conditions predominating in watersheds in the middle and upper part of the basin. The LCFRB also conducted habitat modeling which indicates that sediment impacts on incubation success are a primary limiting factor for all 5 ESA listed salmonids occurring in the watershed. As previously mentioned, there are also concerns regarding the accumulation of coarse sediments at tributary mouths that may create passage barriers (WDFW 1998, LCFRB 2005). Off-Channel Habitat Off-channel habitat availability in the watershed is limited due to channelization of the lower river and the confined nature of the V-shaped valley enclosing the middle and upper river. Nearly all of the lower Kalama floodplain has been disconnected by diking for agriculture, transportation infrastructure, and Port of Kalama property development. Past forestry practices, particularly road building, are likely to have resulted in some loss of off-channel habitat in the Kalama River watershed. The LCFRB (2005) has estimated that there are 0.6 miles of streamside road for every mile of stream in the watershed. It is likely that many older roads obliterated some of the limited historic off-channel habitat in steep V-shaped valleys. Page 11 3/2/2010

12 The lack of off-channel areas potentially limits overwintering habitat for coho and spring Chinook salmon, and steelhead (LCFRB 2005). Based on current conditions relative to potential, off-channel habitat conditions are rated as NPF. Pool Quantity/Quality Despite the widespread lack of LWD and low habitat complexity, pool quantity and quality in the Kalama River is generally considered adequate (LCFRB 2005). Exceptions occur in some tributary streams that have low pool frequencies. This habitat element is currently rated as PFC. Refugia The availability of refugia in the Kalama River system is rated as NPF. This watershed has very little area accessible to anadromous fish with multiple habitat elements rated in PFC. However, the fact that much of the watershed is in timberlands and has limited residential or urban development is an overall benefit. This indicates the potential for high quality habitats to develop over time as passive recovery of riparian vegetation and channel conditions proceeds, providing that the permitted actions do not result in additional degradation of habitat conditions or the extirpation of ESA listed species. 6 However, the eventual recovery of quality refugia will take several decades because the baseline condition of riparian vegetation is degraded and existing levels of functional LWD are low throughout the watershed (Wade 2000). Due to the time required for passive recovery, the benefits of long-term passive recovery do not outweigh short-term impacts that contribute to extinction risk. Several ESA listed populations in the watershed are currently at a high risk of extinction (see Section 1.2.2), and any short term additional degradation of habitat conditions is likely to substantially elevate this risk Diagnostic - Channel Dynamics The condition of channel dynamics in the watershed is complex due to many contributing factors. Channel stability in the river has been greatly impacted by a combination of natural and human factors, including accelerated erosion from unstable volcanic deposits on steep slopes, accelerated erosion caused by logging activities, transport of logs using splash dams, and numerous landslides associated with clearcut logging and road construction. Sediment supply has stabilized in recent years because the level of active logging in the basin is currently relatively low. However, current channel dynamics reflect the legacies of past management 6 Passive management actions rely on the natural and/or successional recovery of terrestrial, riparian and aquatic systems from the impacts of past management actions. However, successional recovery will require several decades to produce habitat conditions that can be considered properly functioning, whereas the adverse impacts of timber harvest will be immediate, persistent, and potentially severe enough to negate any gains produced by passive management. In watersheds like the Kalama where ESA listed populations are currently at a high level of risk, short-term adverse impacts could result in extinction before the benefits of passive recovery are realized. Page 12 5/11/2005

13 activities and sediment supply rates that exceeded transport capacity over many years. Channel stability is considered a primary or secondary limiting factor for the majority of ESA listed salmonids in the watershed. Floodplain connectivity is fragmented in the limited areas of the lower watershed with an active floodplain, primarily due to land conversion for agricultural and industrial development and transportation infrastructure (LCFRB 2005) Road densities in the watershed are still quite high (averaging 5.75 miles/square mile), and in combination with the large areas of recently clearcut land this results in an increased frequency of landslides in the watershed relative to PFC conditions. For example, the February 1996 floods triggered at least 39 landslides (LCFRB 2005). Fine sediment loading associated with forest roads and clearcut areas also affects channel dynamics. Based on the current channel conditions and the potential for ongoing degradation due to the increased frequency of landslide events, channel stability in the Kalama River is rated as AR. Floodplain connectivity is rated as NPF, due to the conditions noted in the lower river Diagnostic - Flow/Hydrology Hydrologic conditions in the Kalama River are degraded due to impacts from past timber harvest practices and high forest road densities in combination with the inherent sensitivity of the watershed to hydrologic impacts. Approximately 35 percent of the watershed lies within the rain on snow zone. Combined with extensive hydrologically immature vegetation and high road densities, this creates the potential for elevated peak flow conditions. As mentioned previously, approximately 61 percent of the watershed vegetation is in relatively recent clearcut or early seral-stage condition, meaning that nearly two-thirds of the ground cover is hydrologically immature. Combined road densities are relatively high, at 5.75 miles/square mile. Based on vegetation and road conditions, USFS estimated a potential 10 percent increase in peak flow volumes relative to undisturbed conditions in the majority of subwatersheds they evaluated (USFS 1996). Using a similar analysis approach, LCFRB estimated that 17 of 18 of Kalama River watersheds are hydrologically impaired (LCFRB 2005). Based on these ratings and basin conditions, peak flows in the Kalama River watershed are rated as NPF. NPF peak flow conditions suggest the likelihood of impaired low flow conditions as well. Available data support these findings. An IFIM study conducted by the Washington Department of Ecology on the Kalama River mainstem found that streamflows were below optimal for coho and Chinook spawning in October, and below optimal for juvenile salmon and steelhead rearing from mid-june to mid-october (Caldwell 1999, LCFRB 2005). Low flow conditions contribute to elevated stream temperatures, and compound passage problems where excess sediment accumulation blocks tributary mouths. Based on these findings, the low flow conditions in the Kalama River watershed are rated as AR. Page 13 3/2/2010

14 Diagnostic - Watershed Condition For the purpose of this BiOp, watershed condition is based on the following characteristics: Increase in the drainage network; road density and location; disturbance history, and; the extent of existing riparian reserves. Based on the high existing road density and the high proportion of these roads that likely predate modern forest practice regulations, the drainage network condition in the watershed is rated as NPF. Available data on road density and location is also indicative of degraded conditions. As mentioned previously, road density in the watershed is quite high (5.75 miles/square mile), and on average, there are nearly 0.6 miles of streamside road and 4.6 road crossings per mile of stream. Based on this information, road density and location are rated as NPF. The disturbance history of the watershed includes significant natural events (e.g., repeated deposition of volcanic ash on steep slopes, stand clearing fires), and damaging timber harvest practices including riparian logging and splash damming. Lower gradient and floodplain areas of the watershed have been developed for agricultural, residential and industrial uses. In contrast however, the majority of the watershed is forested and the extent of developed area is limited. Based on these conditions, this watershed factor is rated as AR. Riparian condition in the watershed is widely degraded due to harmful logging practices primarily from the 1960s through the 1980s. An analysis of available aerial photographs used in the 2000 limiting factors analysis for this watershed found that the riparian zones along 85 of the 97 stream miles accessible to anadromous fish in the watershed were either primarily deciduous or lacked riparian vegetation altogether (Wade 2000, LCFRB 2005). These conditions prevail throughout the watershed. Based on an analysis of remote sensing data, the LCFRB found that riparian conditions were moderately impaired in 17 of 18 Kalama River subwatersheds (LCFRB 2005). Riparian conditions and the extent of riparian reserves in the watershed are rated as NPF. While riparian conditions are slowly improving as successional recovery proceeds in the watershed, it will take several decades for riparian conditions to reach PFC. In contrast, ESA listed fish populations are currently at a high risk of extinction, and short term impacts on watershed conditions will likely increase this risk before riparian vegetation can reach PFC. Table 1 Summary of Baseline Watershed Diagnostic and Indicator Ratings Diagnostic Category/Indicator Water Quality Temperature Other water quality parameters Habitat Access Culverts Sediment accumulation/ debris jams Habitat Elements Riparian/LWD Baseline Rating AR AR AR AR NPF Page 14 5/11/2005

15 Substrate/sediment Off-channel habitat Pool quantity/quality Refugia Channel Dynamics Stability Floodplain connectivity Flow/Hydrology Peak flows Low flows Watershed Condition Drainage network increase Road density/location Disturbance history Riparian reserves NPF Not properly functioning AR At risk PFC Properly functioning condition NPF NPF PFC NPF AR NPF NPF AR NPF NPF AR NPF Relationship of Focus Species Status to Baseline Condition As noted in Section 2, there are six Kalama River salmonid populations listed under the ESA or proposed for listing. Kalama spring Chinook, fall Chinook and chum salmon, and winter and summer steelhead are listed as threatened. Kalama coho salmon are currently proposed for listing. The abundance of each of these populations is substantially depressed in comparison to historic numbers (see Table 2). The current viability of these populations, as estimated by the WLC-TRT, ranges from very low with a 60 to 70 percent likelihood of extinction within 100 years (spring Chinook, chum and coho), to better than medium with only a 10 percent likelihood of extinction (winter steelhead) (Table 2). Baseline habitat conditions contribute to a number of factors that are limiting the productivity and abundance of Kalama River salmonid populations. The LCFRB has conducted a modeling exercise based on an extensive evaluation of available data and information to identify the most critical limiting factors and life stages affected (LCFRB 2005). This information is summarized in Table 3. As shown, survival through egg incubation is the most critical stage limiting abundance for 5 of the 6 populations of concern (coho salmon being the exception). Sediment and channel stability rank as primary or secondary limiting factors impacting incubation success. Juvenile survival through summer and winter rearing are also a concern. Habitat diversity, channel stability and streamflows are primary limiting factors affecting survival through these life history stages. These findings comport with the baseline condition rankings described in the previous section. Baseline sediment conditions in the Kalama River watershed, currently rated as NPF, are a primary limiting factor for all populations. Channel stability in the watershed is rated as AR, and Page 15 3/2/2010

16 four of the five habitat elements that compose habitat diversity are rated as NPF. Other habitat related limiting factors limiting factors identified by the LCFRB, including temperature and stream flows are rated as AR or NPF (see Table 1). Based on these findings, it is apparent that baseline habitat conditions in the Kalama River watershed are contributing to extinction risk for species of concern. Following federal BiOp guidance, any federally permitted action that would further degrade Kalama River habitat conditions from baseline, or retard the progress of these habitats towards PFC would be considered likely to jeopardize the continued existence of these species. Further, the current level of risk facing ESA listed populations and the period over which it operates must be considered when evaluating the likely effectiveness of passive recovery of channel and riparian conditions. Listed populations face a high and escalating risk of extinction in the short term, while the benefits of passive recovery of habitat conditions will in many cases not be realized for several decades. In this context, the short to moderate term (e.g., within 10 to 15 years) effects of the FPHCP must be critically considered for the potential to adversely impact at risk populations. 7 Of particular interest, the WLC-TRT has identified the Kalama River summer steelhead as a core population in the Cascade Strata of the Lower Columbia Steelhead ESU for the purpose of ESA recovery planning. A core population is considered necessary to maintain the evolutionary legacy of the ESU. Core populations were typically historically large, and as such are likely to offer the most likely path to recovery. Because of these characteristics, the WLC- TRT has recommended that recovery planners prioritize core populations when developing recovery plans (WLC-TRT 2003). The current viability of the Kalama summer steelhead population is rated as Low+, which equates to a 30 percent risk of extinction in 100 years (Table 2) (McElhaney et al. 2003, LCFRB 2005). Recent population abundance has ranged between 200 and 2,300 spawning adults. Historical abundance is estimated to have ranged between 1,300 and 7,000 individuals (Table 2) (LCFRB 2005). The LCFRB recovery plan has identified the primary factors limiting the survival, abundance and productivity of Kalama River summer steelhead. As shown in Table 3, poor incubation survival is the critical concern for this population, and fine sediment loading and channel stability are the primary and secondary limiting factors. These two sources of habitat 7 For example, if permitted actions under the FPHCP resulted in short term impacts on hydrologic and sediment condition in the Kalama River, and degraded freshwater conditions coincide with a decline in ocean survival conditions, this could greatly accelerate extinction risk. Smolt condition migration timing strongly influence marine survival (Holtby 1988, Holtby et al. 1990). Low size and smolt condition, or a temperature driven mismatch between out-migration and favorable ocean conditions can greatly reduce marine survival rates. Because high quality freshwater habitat provides a survival buffer against poor ocean conditions, retarding habitat recovery or reducing habitat quality from baseline conditions in the short term will further reduce the resilience of already at risk populations. Page 16 5/11/2005

17 degradation are identified as the primary limiting factors for all other ESA listed salmonids occurring in the Kalama River watershed (LCFRB 2005). Table 2 Status and Population Viability of Kalama River Salmon and Steelhead Populations (Source: McElhaney et al. 2003, LCFRB 2005). Focal Species ESA Status Historical Numbers 1 Recent Numbers 2 Current Viability 3 Extinction Risk 4 Fall Chinook Threatened 3,800-20,000 3,800-20,000 Low+ ~30% Spring Chinook Threatened 6,000-15, Very Low ~60% Chum Threatened 15,000-40,000 <50 Very Low ~70% Coho Proposed 2,000-26,000 Unknown Low ~70% Summer Steelhead Threatened 1,300-7, ,300 Low+ ~30% Winter Steelhead Threatened 1,000-8, ,300 Med+ ~10% Historical population size inferred from presumed habitat conditions using Ecosystem Diagnosis and Treatment Model and NOAA back-of-envelope calculations. Approximate annual range in number of naturally-produced fish currently returning to the watershed. Prospects for long term persistence based on criteria developed by the NOAA Technical Recovery Team. Probability of extinction within 100 years corresponding to estimated viability. Page 17 3/2/2010