Attach_14_-_20200126_NPDES_Exemption_Hatchery_Operations_Letterhead_for_MEMO_Signed_0001.pdf

United States Department of the Interior

FISH AND WILDLIFE SERVICE

Klamath Falls Fish and Wildlife Office 1936 California Avenue

Klamath Falls, Oregon 97601

(541) 885-8481 FAX (541) 885-7837

January 26, 2021 Memorandum

To: Jennie M. Land, Project Manager

From: Field Supervisor, Klamath Falls Fish and Wildlife Office Klamath Falls, Oregon

Subject: Klamath Falls National Fish Hatchery (Hatchery) Operations National Pollutant Discharge Elimination (NPDES) Permit Exemption

On July 29, 2020, U.S. Fish and Wildlife Service (Service) staff engaged in a Microsoft Teams Meeting with the staff from the Oregon Department of Environmental Quality (ODEQ). This meeting was called to discuss the need for an NPDES permit from ODEQ for the fish production operations of the Hatchery. During the meeting, it was presented that under 20,000 pounds (lbs) of fish would be produced and those fish would need no more than 5,000 lbs of feed per month.

In order for ODEQ to further evaluate the need for a permit or whether it falls under the stated exemptions they would need to review the site plans, location, etc.; volume and frequency of discharge; and pounds of fish per year and pounds of feed per month. Service staff also clearly stated that the Service’s operations are and will remain separate from the existing private property operations; this includes separate water supply and discharge facilities.

On August 4, 2020, the Service emailed the requested information and further explained that after the discussion on July 29 and further review of production and feed rates, the Service believes that conditions for an exemption are met and an NPDES permit would not be required at this time based on maximum projected production goals. The Service requested concurrence with this finding. The Service requested an update on the status of ODEQ’s review on August 18, and ODEQ responded on August 19 that they expected to complete their review in late August or early September 2020. The Service sent a follow-up email on September 10. On September 11, ODEQ responded that they were circulating internal comments and expected to provide a response to the Service by the following week. On September 30, the Service followed up again via email, but did not receive a response. Another follow-up email was sent on November 19 via email, also stating that National Environmental Policy Act compliance had been completed. No further response from ODEQ has been received to date.

The new Hatchery facility is believed to fall under the exemption since fish production and feed rates are well below the thresholds mentioned in the General National Pollutant Discharge

Elimination System (NPDES) Waste Discharge Permit documentation (attached – See Figure 2-3 in the 2020 Alternative Analysis Report).

Attached is a copy of the 2020 Alternative Analysis Report (AA Report) compiled by McMillan Jacobs and Associates, which outlines additional information related to the future buildout of the Klamath Falls National Fish Hatchery. This document also shows the current drainage schematic (See Figure 2-2 on page 16) and the proposed loading densities, which include the fluctuations throughout the year while providing for up to three year classes of production fish, domestic brood stock and salvage fish (See Table 1-1 on page 7).

Also included is the most recent design schematic of the proposed layout of the hatchery, which will include up to 9-10 surface acres of pond space with a capacity of approximately 40 acre-feet of water volume.

Annual Production and Feed Rates

As for annual production rates, it should be noted that year two and year three suckers are grown to a minimum target size of 200 millimeters (mm) total length, which is approximately 0.15 pounds (lbs) per fish. The Hatchery currently raises between 10,000-15,000 fish to this target size, and the annual production is about 2,250 lbs of fish. With a full buildout of the Hatchery, annual production goals will be growing 60,000 to 73,000 fish to a target size of 200 mm total length, which totals about 9,000 lbs to 10,950 lbs of fish annually (See AA Report, Table 1-1, page 7 for year two and year three fish). This is well below the General NPDES Permit threshold of 20,000 lbs for annual production.

Annual loading on the facility at any given time would be less than 13,000 lbs of aquatic animals, well below the 300,000 lbs limit (Yearly Production/Max Biomass row values added together in AA Report, Table 1-1 =12,875 lbs, rounded to 13,000 for these purposes).

Feed rates at full buildout are estimated to be less than 20,000 lbs annually (See AA Report, Table 1-1, page 7; Yearly Feed Load row added together = 19,311 lbs per year). Most of this feed will likely be fed within 8-10 months of the year, when water temperatures are highest.

This would amount to no more than 2,000-2,500 lbs of feed per month, which is well below the General NPDES Permit maximum threshold of 5,000 lbs of feed.

Landowner (Ron Barnes) Operations

ODEQ inquired about specifics regarding the operations of the landowner adjacent to the leased parcels used for Service Hatchery operations. In speaking with the landowner, Ron Barnes (owner and operator of “Gone Fishing, LLC”), his operations generate zero discharge since his system is a complete recirculation system for his tilapia production. His total inputs of exchange are less than 1 gallon per minute (GPM) overall and he reclaims any drain water during harvest or discharge to add back to his systems; he has separate catchment ponds and tanks for this purpose. Mr. Barnes produces 6,000-7,000 lbs of fish annually and uses less than 1,000 lbs of feed per month, even during the months of maximum feeding.

Mr. Barnes also asked that when the Service inquired about the NPDES permitting or exemption, that his operation be considered separate from the Service’s activities. Mr. Barnes does not want to impact Service operations in any way, and he does not want the Service to impact his, especially since his operations are small. Operations are also kept separate to prevent cross contamination between facilities.

Operations, Drainage, and System Schematics and Reports

The current Service production strategy involves keeping ponds static, with little to no overflow most of the year. The current plan has just enough flow to offset evaporation in the summer months, and some exchange of water in the winter months to help maintain water temperatures that are conducive for fish growth. With little evaporation during winter months (approximately October through April), there may be up to a max of 383 gallons per minute (GPM) of discharge.

The ponds are kept in production for one to two years prior to harvesting the ponds. Upon harvesting, ponds are fully drained, thus creating a discharge into the wetland retention pond for one to four weeks at a time; this is generally in the spring and fall months. If the Service harvested half of the ponds annually while at full buildout, this would amount to the discharge of approximately 20 acre-feet (~6.5 million gallons) of water. When averaged over a year, this equates to 12.4 GPM. If the Service moved to harvesting all the ponds annually, this would amount to 40 acre-feet (~13 million gallons) or approximately 24.8 GPM.

Current pond space is 2.4 surface acres with 9.5 acre-feet of volume (46 ponds are 0.03 acres and four ponds are 0.25 acres). Discharge would be between 4.75-9.5 acre-feet (1.55-3.1 million gallons of water) given the same assumptions on harvesting used above. This amounts to a maximum of 5.9 GPM

There are also some limited periods when flow is 50-100 GPM through the Hatchery building to perform intensive early rearing of juvenile suckers, from May-July, or to care for salvaged suckers from the A-Canal near Upper Klamath Lake, from September-November. However, those operations would have minimal waste associated with them due to lower numbers of fish and duration they are onsite. They receive very little feed and treatment in comparison to overall hatchery operations prior to being released back to natural water bodies. For all practical purposes, however, only ~383 GPM can be pumped continuously from the well. Therefore, any discharges or flows over that amount throughout the year would obviously be unsustainable.

Most of the year, flow rates are less than 50-100 GPM.

Discharges

Currently, all discharge enters the man-made wetland on site, where it can either evaporate, percolate, or pass through a culvert under Lower Klamath Lake Road (only occurs if the wetland area is full) that discharges to the North Canal. The North Canal is a man-made irrigation ditch that serves Klamath Drainage District water users for agricultural irrigation purposes. Although connected to the Klamath River, it is not a free and open system. It has a gate that can completely shut off the water source and be dewatered. The canal is dewatered periodically for operations and maintenance purposes. Additionally, downstream is a recirculation pump that captures any runoff water and recirculates it onto agricultural lands.

With the full build out of the Hatchery, there will be approximately two or three settling ponds that will be used for primary and secondary clarification throughout the year prior to discharging to the wetland or potentially offsite (See KPFF Construction Plan (Schematic) for Ponds D10, D11, and D12). Pond 10 contains a single point of discharge from a flow control structure into the wetland. If desired, Mr. Barnes could reuse as much of the Service’s discharged water as he desires at any given time from the adjacent wetland. Mr. Barnes may also be able to pick up water from the Service system that otherwise would go to the wetland/retention pond from junction boxes along the way.

Mr. Barnes’s aquaculture, irrigation, and horticulture program is separate from the Service’s, and he has clearly stated that if he reuses any water discharged by the Service into the wetland/retention pond, 100% of that water will be used by his system, resulting in zero discharge.

Conclusion

After discussions with ODEQ, discussion within our office, and additional review of the design and production reports, the Service has determined that Hatchery operations will fall under the thresholds requiring a General NPDES permit, thus there is not a need to apply for an NPDES permit. The annual production and feed rates fall well under the exemption limits. Additionally, discharge rates would also be very low, if any. The Service will proceed with further planning and implementation of this project based on this determination.

Attachment

USFWS-Klamath Falls Alternatives Analysis McMillen Jacobs Associates

United States Fish and Wildlife Service (USFWS)

Klamath Basin Sucker Assisted Rearing Program

(KBSARP)

Gone Fishing Site

Alternatives Analysis

100% Draft Revision No. #1

June 30, 2020

USFWS-Klamath Falls Alternatives Analysis McMillen Jacobs Associates

This page intentionally left blank.

USFWS Klamath Falls Sucker AA. June 2020

McMillen Jacobs Associates i Rev. No. 1/June 2020

Table of Contents

1.0 Introduction

1.1 Purpose and Need

1.2 Location

1.3 Summary of Alternatives Analyzed

1.3.1 No Action Alternative

1.3.2 Action Alternative 1

1.3.3 Action Alternative 2

2.0 Alternatives

2.1 No Action Alternative

2.1.1 Existing Site Conditions

2.1.2 Production Capacities

2.1.3 No Action Alternative Production Capacity Summary

2.1.4 No Action Site Layout

2.1.5 Aquatic and Terrestrial Habitat

2.1.6 Water Resources

2.1.7 Hydraulic Profile

2.1.8 Schedule

2.1.9 Construction Costs

2.1.10 Permitting Summary

2.2 Action Alternative 1 – Development on Previously Disturbed Land Only

2.2.1 Site Improvements

2.2.2 Aquatic and Terrestrial Habitat

2.2.3 Water Rights and Availability

2.2.4 Hydraulic Profile

2.2.5 Actions Items

2.2.6 Production Capacity Summary

2.2.7 Site Layout

2.2.8 Schedule

2.2.9 Construction Costs

2.2.10 Permitting Summary

2.3 Action Alternative 2 – Full Site Build-out

2.3.1 Site Improvements

2.3.2 Aquatic and Terrestrial Habitat

Klamath Falls Sucker Hatchery Alternatives Analysis

McMillen Jacobs Associates ii Rev. No. 1/June 2020

2.3.3 Water Rights and Availability

2.3.4 Hydraulic Profile

2.3.5 Actions Items

2.3.6 Production Capacity Summary

2.3.7 Site Layout

2.3.8 Schedule

2.3.9 Construction Costs

2.3.10 Permitting Summary

3.0 Conclusions and Recommendations

4.0 References

5.0 Acknowledgments

Appendices

Appendix A Alternatives Considered but Eliminated from Detailed Discussion.

Appendix B Draft Lease Agreement 6/18/2020, (Exhibits A and B)

Appendix C Site Plans

Appendix D Cost Estimates Details

Appendix E Permitting Summary

List of Tables

Table 1-1. KBSARP Production Goals and Culture Conditions

Table 1-2. Pond Sizes and Proportions

Table 2-1. Alternative Design Features Comparison

Table 2-2. No Action Alternative Production Capacity

Table 2-3. Existing Pond Sizes

Table 2-4. Action Alternative 1 Production Capacity

Table 2-5. Action Alternative 1 Pond Sizes

Table 2-6. Action Alternative 1 Cost Estimate

Table 2-7. Action Alternative 2 Production Capacity

Table 2-8. Action Alternative 2 Pond Sizes

Table 2-9. Alternative 2 Cost Estimate Summary

McMillen Jacobs Associates iii Rev. No. 1/June 2020

List of Figures

Figure 1-1. Anticipated Fish growth and Pond feeding requirements

Figure 1-2. Anticipated Fish Growth and Associated Feeding Rates

Figure 1-3. Location of Gone Fishing Hatchery

Figure 1-4. Gone Fishing Lease Parcels

Figure 2-1. Existing Well and Pump House

Figure 2-2. Retention Ponds and Site Drainage

Figure 2-3. NPDES Permit

Figure 2-4. Existing Hatchery Head Ponds

Figure 2-5. Existing Hatchery Structure and Contents

Figure 2-6. Parcel 1 Existing Ponds: (Left) 0.25 Acre Ponds, (Right) 0.04-Acre Ponds

Figure 2-7. Parcel #2 Existing Ponds: 0.04 Acres Ponds

Figure 2-8. Existing Water and Air Distribution lines

Figure 2-9. Action Alternative 1 Preliminary Schedule

Figure 2-10. Action Alternative 2 Hatchery Building Layout

Figure 2-11. Alternative 2 Preliminary Schedule

McMillen Jacobs Associates iv Rev. No. 1/June 2020

Distribution

To: Rob Moriarty

USFWS

Dan Blake

USFWS

From: Edward D. Aneshansley McMillen Jacobs Associates

Prepared By: Edward D. Aneshansley McMillen Jacobs Associates

Jessica Peters McMillen Jacobs Associates

Reviewed By: Jeff Heindel McMillen Jacobs Associates

Greg Allington McMillen Jacobs Associates

Revision Log

Revision No. Date Revision Description

1 June 30, 2020 100% Alternatives Analysis

McMillen Jacobs Associates 5 Rev. No. 1/June 2020

1.0 Introduction

In 1988, the Shortnose Sucker (Chasmistes brevirostris) and Lost River Sucker (Deltistes luxatus) were listed as “Endangered” under the Endangered Species Act. The U.S. Fish and Wildlife Service (USFWS) finalized a recovery plan for both species in 1993 (USFWS 1993) to arrest the decline and enhance Lost

River Sucker and Shortnose Sucker populations so that Endangered Species Act protection is no longer necessary. Since 2001, the adult populations of both species have continued to decline steadily. In 2013 the recovery plan was revised for the Lost River and Shortnose sucker (USFW 2013). The revised plan calls for the development of a controlled propagation program (Section 13.5.4) once the species hits a population decline threshold. A Species Status Assessment completed in 2019 (Childress et al. 2019) indicated the Shortnose Sucker has reached a critical population threshold and the Lost River Sucker are close behind. Therefore, the USFWS has initiated plans to expand their artificial propagation program as called for in the Revised Recovery Plan. This included a Site Feasibility Assessment in 2015 (USFWS, 2015; Vol A-B) to identify potential sites in the Klamath Basin for a hatchery facility.

Eight sites were identified, geographically extending from the Upper Klamath Basin to the Lower

Klamath Lake area,1 as potential hatchery development sites. These sites are summarized in (Appendix

A). Using this feasibility study, the USFWS evaluated all possible locations and eliminated seven of the eight sites. In 2016, a partnership was established between the USFWS and the landowner of the eighth site, the Gone Fishing Site, to establish the current Klamath Basin Sucker Assisted Rearing Program

(KBSARP) on the property using the existing water source, ponds, and some hatchery infrastructure. The

KBSARP’s success on this property has led to a potential long-term lease agreement to enable the expansion of KBSARP’s production capacity to meet the goals of the revised recovery plan. This

Alternatives Analysis evaluates three possible development strategies for this site, once the lease is fully executed. This Alternatives Analysis will compare two Action Alternatives, or development options, on this site and a No Action alternative in which the site is used to its currently permitted potential at the time of the lease signing, with no additional hatchery improvement activities.

A Species Status Assessment for the endangered Lost River Sucker and Shortnose Sucker clearly outlines the ecological requirements of the species, the current challenges, and the probable extinction of the species within 30 to 40 years without recovery efforts. The revised recovery plan established in 2013 clearly outlines eight program actions that includes establishing a Redundancy and Resiliency

Enhancement Program. A target number of 60,000 individual fish released each year, between 200 and

300 mm in length, has been determined to be sufficient to stabilize the local populations within a 5-year period. Based on the current larvae collection strategy, the 60,000 individuals released will include some ratio of Shortnose, Lost River, and Klamath Largescale (Catostomus snyderi) sucker species. This multi-species propagation and release is due to the wild larval capture practices that result in mixed species that are indistinguishable from each other in the larval form. Species can be successfully targeted based on the time and location that larvae are collected, but the process is not 100 percent accurate. For the

1 The Shortnose Sucker Conservation Aquaculture Facility and Site Feasibility Assessment Volumes I and II discuss in detail the revised recovery plan for shortnose and Lost River suckers, the biological criteria and operations schedules required for any hatchery established for these species, the eight sites selected for further evaluation, the criteria established for determining the feasibility of each site, and the costs associated with the proposed project. This information is incorporated by reference in this document; please refer to the Site Feasibility Assessment documents for more information.

McMillen Jacobs Associates 6 Rev. No. 1/June 2020 remainder of this Alternatives Analysis, the population of sucker within the KBSARP, consisting of these sucker species listed above, will be generally classified as Klamath Basin Sucker.

This Alternative Analysis identifies the least impactful approach to achieve the production capacity of

60,000 Klamath Basin Sucker on the leased parcels of land located at the Gone Fishing Site.

1.1 Purpose and Need

1. Recruitment: The primary goal of the KBSARP is to culture and release a total of 60,000

Klamath Basin Sucker per year of 200 to 300 mm in length in several areas throughout the upper

Klamath Basin. This is the criteria established in the 2019 Species Status Assessment to meet the need to maintain several currently existing, independent, wild populations of Klamath Basin

Sucker at levels that are viable and self-propagating.

To achieve the primary recruitment goal, several short-term objectives must be achieved. These include:

a. Yearly harvest of at least 100,000 wild-spawned Klamath Basin Sucker larvae to stock the

KBSARP hatchery every year.

b. The successful rearing and larval development of feed trained Klamath Basin Sucker fry to stock into ponds for further grow-out.

c. Successful pond management and Klamath Basin Sucker husbandry to ensure adequate culture conditions for consistent growth and wellbeing until the target-release fingerling release size is achieved.

i. For this site, successful pond management includes the strategic management of geothermal well water to support elevated pond temperatures in the winter, which allows for extended growth seasons and shorter culture duration.

d. Successful restocking of most of the fish in the spring after 2 years of culture.

e. Additional capacity to hold a portion of the fish (up to 5 percent) to restock in the fall or following spring after 3 years of culture.

2. Captive Breeding: A secondary goal of the program is to maintain a captive brood stock population on site for all three Species of Klamath Basin Sucker, including the Shortnose Sucker and two subspecies of the Lost River Sucker, to reduce reliance on the natural spawning population and provide an option for producing larvae if there comes a time when larvae are not produced in the wild. The target of this goal would be to hold a captive population of males and females (1:1 male/female ratio) from each species in separate holding ponds of 500 individuals of each species. This program component would mitigate the reliance on wild-capture larvae for the successful operation of the KBSARP.

3. Salvage Fish: A third goal of the program is to maximize the ability to support the capture, quarantine, and rehabilitation and successful release of “salvage” fish that are rescued from canals, ditches, and impoundments within the Klamath Basin that are pumped or naturally dry-up

McMillen Jacobs Associates 7 Rev. No. 1/June 2020 seasonally. These fish otherwise face overwinter isolation from their natural habitat, inability to spawn, starvation, or likely predation. The ability to hold these fish for extended periods of time to supplement their strength and size would ultimately support the program goals with little effort or resources expended.

4. Operations: An additional goal of this program is to improve the daily operations of the facility by improving reliability of equipment, pond management practices, site safety, biosecurity, and sanitation workflows. Ideally, increased production would be accomplished with the current human resources and workforce available at the time of the lease agreement.

These goals are to be met under the following culture conditions:

Table 1-1. KBSARP Production Goals and Culture Conditions

Common Design Criteria

Units

KB

Sucker Rearing (Year 1)

KB

Sucker Rearing (Year 2)

KB

Sucker

Extended Rearing (Year 3)

Brood Stock

Extended Salvage

Indoor Hatchery Operations

Larvae Salvage

Program Goals fish/year 80,000 60,000 2,000 1,500 2,000 100,000 1,500

Final Fish Densities

*fish/SA 50,000 10,000 2,500 2,500 10,000 NA NA

Final Fish Densities sq ft/fish 0.9 4.4 7.0 17 4.0 NA NA

Make-up Water Required inches/SA-day

2.6 1.5 1.5 1.5 1.5 **8 ***20

Flow Required GPM 128 42 42 42 80 80 20

Target Fish Length

(mm) 100 200 275 400+ 225+ 10 200

Target Fish Weight

(g) 10 60 190 450 100 1 60

Required Feeding Rate

Biomass/day)

3% 2% 2% 2% 2% 10% 2%

Yearly Production/Max

Biomass Lbs./Yr. 1762 7930 837 1487 441 220 198

Feed Conversion

Ratio feed/biomass 1.5 1.5 1.5 1.5 1.5 1.5 1.5

Yearly Feed

Load

Lbs.

feed/year

2,643 11,894 1,256 2,230 661 330 297

* SA = surface acre

** gallons per minute (GPM) per 10,000 individuals.

*** gallons per minute (GPM) per 1,500 individuals.

Final Fish Density: Final fish Density was based on historical stocking density provided by the

USFWS.

McMillen Jacobs Associates 8 Rev. No. 1/June 2020

Makeup Water: Makeup water is elevated during the first year to increase overwinter rearing temperature and promote a faster growth rate. The daily makeup water rate is intended to keep up with daily evaporation. Pan evaporation data collected between 1949 and 2004 at the Klamath Falls Agricultural Station and reported by the Western Regional Climate Center reports monthly average pan evaporation rates peaking in July at 10.24 inches and totaling 56.54” for the yearly total.

Daily maximum evaporation rates are not anticipated to be higher than 0.5 inches per day.

Target Fish Length: Fish growth in length is normally linear under consistent water quality conditions. Growth rates are reduced in the winter due to lower temperatures.

See Figure (1.1)

Target Fish Weight: Fish growth in weight follows an exponential curve under consistent water quality conditions but is also reduced n the winter during lower temperatures.

See Figure (1.2)

Feed Conversion Ratio: The feed conversion ratio (FCR) indicates how effectively the fish convert feed to biomass. USFWS historical records indicate that for every 1.5 lbs. of feed fed, 1.0 lbs. of biomass is produced. The FCR along with the number and size of fish produced is used to estimate the total feed load over a one-year period.

For a max monthly feed load estimate the yearly feeding rate should be divided into 6 months per year, based on seasonal variation at this location.

Figure 1-1. Anticipated Fish growth and Pond feeding requirements

McMillen Jacobs Associates 9 Rev. No. 1/June 2020

Figure 1-2. Anticipated Fish Growth and Associated Feeding Rates

These design criteria are applied equally to each development strategy within the Alternative Analysis.

The criteria were developed based on current KBSARP program protocols that have been established since 2016 and have resulted in successful program outcomes year over year. The final fish densities are designed to provide adequate space for the individual fish and avoid overcrowding. The make-up water replacement rate is designed to replace water that is lost to evaporation and seepage, with some extra capacity. This criterion provides a means to evaluate the land and water resources required for implementation of each development strategy within the Alternatives Analysis.

1.2 Location

The Gone Fishing Hatchery site is a privately developed, actively operating aquaculture facility located near the town of Merrill, 10 miles south of Klamath Falls in Oregon (Figure 1-3) on Lower Klamath Lake

Road southeast of the Cross Road-Highway 97 intersection. Fishery facilities developed and operated on this 82-acre parcel since the late 1980s have successfully supported commercial production of cichlids and tilapia and, in cooperation with USFWS, the experimental production of Klamath Basin Sucker.

McMillen Jacobs Associates 10 Rev. No. 1/June 2020

Figure 1-3. Location of Gone Fishing Hatchery

The current landowner developed a production well from an on-site geothermal aquifer and implemented controls to reduce temperatures and manage water chemistry so that parameters are suitable for fish production. This 82-acre parcel is situated on the south-facing slopes of a ridge known as the Klamath

Hills. Two parcels within the overall site are currently used for KBSARP activities (Figure 1-4). The highest ground is along the north edge of the property at elevation 4180. The lowest elevation is along the paved Lower Klamath Lake Road, which forms the southern boundary of the parcel at elevation 4130.

Figure 1-4. Gone Fishing Lease Parcels

1.3 Summary of Alternatives Analyzed

This report analyses the following three alternatives outlined below.

McMillen Jacobs Associates 11 Rev. No. 1/June 2020

1.3.1 No Action Alternative

The No Action Alternative evaluates the site’s fish production potential for currently permitted activities at the time the lease is finalized. It is assumed that all necessary and required permits have been acquired and will remain active and in place to allow the USFWS to continue their

KBSARP operations without any disruption. No further development to increase the KBSARP production program beyond its current capacity would be engaged. No additional water resources or land disturbance would be required.

1.3.2 Action Alternative 1

Action Alternative 1 includes the development within Parcels #1 and #2, on and between areas that have been previously disturbed and developed for fish culture ponds and that may be in or out of current fish production operations.

o The development activities for this action alternative include the following:

Reconstruct the ponds and the associated pond access within the existing footprints to accommodate the following goals:

• Improve culture conditions and fish growth rates.

• Increase fish production capacity.

• Improve pond operation and management conditions.

• Address safety and security concerns.

• Address biosecurity concerns.

• Address water management challenges in head ponds.

• Address concerns around well pump reliability and water distribution.

• Address aeration infrastructure issues.

o This action alternative would address only outdoor production activities in ponds and would not include any improvements to larval rearing or salvage quarantine that currently takes place indoors.

o This action alternative would not require any additional water resources outside of what is currently permitted for the site.

o Ponds sizes would be changed to accommodate the following sizes and ratios as much as possible. The potential for future pond expansion would be considered. Table 1-2 was developed with USFWS staff input.

Table 1-2. Pond Sizes and Proportions

*Pond Size (SA) Ratio (# of Ponds) Whole # Ratio *SA Ratio

0.15 1 2 1.0

0.25 2 4 3.3

0.50 1.5 3 5

SA-Surface Area

McMillen Jacobs Associates 12 Rev. No. 1/June 2020

1.3.3 Action Alternative 2

Action Alternative 2 would be a complete site overhaul, which would include:

o All the changes outlined within Action Alternative 1.

o Develop additional ponds on previously undeveloped land within the leased parcels.

Outdoor ponds would be added to maximize the production capacity of the leased parcels or achieve the desired goals of the KBSARP. Ponds would be added according to the size and ratios listed in Table 1-2.

o Build a new hatchery building to add capacity to larval rearing and salvage quarantine.

o Build additional outpost building such as maintenance sheds and chemical Storage o Possible new well to the property to replace or backup the current well.

1.3.3.1 Action Alternative 2 Construction Phases

o The construction phases for this action alternative would be as follows:

Phase #1:

• Complete the outdoor pond modifications outlined in Action Alternative

1.

Phase #2:

• Permit and install a new well, location to be identified.

Phase #3:

• Add culture pond capacity.

Phase #4:

• Permit and install the new hatchery and outpost buildings.

• Demolish and remove the existing hatchery building.

• Upgrade water and aeration distribution capacities.

In this approach, it is assumed the Phase 1 construction could be accomplished in a manner that would continue to allow the KBSARP to operate their current activities while existing ponds are renovated. An alternative approach to this phased construction could be to increase the new pond capacity first and then renovate existing ponds. This would allow the program to move production activities to the new ponds while renovation takes place on existing ponds. One potential phasing approach is outlined in section 1.3.3.2.

1.3.3.2 Action Alternative 2 Alternate Construction Phases

o The alternative construction phased for Alternative 2 could include the following.

Phase #1:

McMillen Jacobs Associates 13 Rev. No. 1/June 2020

• Permit and install a new well, location to be identified.

• Upgrade water and aeration distribution capacities to accommodate

Phase #2 pond expansion.

Phase #2:

• Add culture pond capacity.

Phase #3:

• Complete the outdoor pond modifications outlined in Action Alternative

1.

Phase #4:

• Permit and install the new hatchery building.

• Demolish and remove the existing hatchery building.

McMillen Jacobs Associates 14 Rev. No. 1/June 2020

2.0 Alternatives

This section includes the alternatives analyzed in detailed study, which include the No Action Alternative, Action Alternative 1 and Action Alternative 2. A description of the measures for each of the alternatives is provided in Sections 2.1 through 2.3 below. The key design features for each of the alternatives are compared in Table 2-1 .

Table 2-1. Alternative Design Features Comparison

Item No Action Action

Alternative 1 Action

Alternative 2

Water Supply (GPM) Existing Existing New Well

Access Road Existing Existing New Access

Permitting Complexity None Small Medium

Air Blowers Existing New New

Air Piping Existing New New

Fencing Existing New New

Water Distribution Existing New New

Buildings Existing Existing New

Culture Ponds Existing Rehab Rehab + New

Effluent Retention Ponds Existing Rehab Rehab + New

Influent Retention Ponds/Storage Tanks

Existing Rehab Rehab + New

Earth Work None Medium Significant

2.1 No Action Alternative

The No Action Alternative would continue the currently permitted activities at the Gone Fishing Hatchery site. Activities would be restricted to the exiting conditions of the site which are outlined below.

2.1.1 Existing Site Conditions

Details on the two leased parcels can be found in Appendix B Lease Agreement. The parcels include the following equipment related to operations relevant to the KBSARP at the time the lease was executed:

o Permitted Geothermal Well: The existing well and water rights to the 399 gallons per minute

(gpm) of permitted well capacity would be included in the lease negotiation and made available for use in the KBSARP. A portion of this water is the currently being used in the program and is known to be suitable for hatchery activities based on USFWS’s historical aquaculture success with this water resource. The water source is 190° F coming directly from the well and requires temperature conditioning (i.e., cooling via surface exposure in holding ponds) prior to direct use in aquaculture activities. However, the temperature of the water serves as a benefit in the winter months by increasing the culture pond temps and improving growth rates. In addition, the water temperature reduces the risk of certain parasites and allows for non-chemical treatment for some disease. Figure 2-1 shows the existing well and pump house.

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Figure 2-1. Existing Well and Pump House o Aquaculture Water Discharge: The landowner will be receiving the discharge from the leased parcels into retention ponds within the property borders. The landowner will potentially reuse this water for fish culture activities on the property. The landowner requires that the water leaving the twenty-acre leased Parcel (Parcel #1) pass through a retention pond for passive solids settling. This is not a requirement for the five-acre parcel near the road (Parcel #2), as grade will likely not accommodate this. The landowner will accept discharge directly from culture ponds in this area.

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Figure 2-2. Retention Ponds and Site Drainage o There are no criteria set for effluent pond retention time or the water quality requirements that the landowner is willing accept. These details should be formalized in the lease agreement. Effluent flow from the landowner’s property flows under the road, through a private parcel of land and into an irrigation canal (figure 2.2) This irrigation canal is connected to the Klamath River. This hydraulic connection between the leased parcels and the Klamath River will likely require that the

USFWS apply for a National Pollutant Discharge Elimination Systems (NPDES) discharge

Permit for the activities taking place on the property. Oregon Department of Environmental

Quality has released the criteria that could preclude this site from requiring a NPDES permit

(figure 2.3)

Site Effluent Pipe

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Figure 2-3. NPDES Permit o Head ponds: There are three ponds currently being used to temper the water coming from the thermal well prior to being used for aquaculture activities. These are referred to as Head Ponds 1, 2, and 3 and are identified in Figure 2-4. These ponds are generally used during the warmer summer months to cool the well water when geothermal heating is not required in the hatchery program.

Figure 2-4. Existing Hatchery Head Ponds o Hatchery Building: There is a current hatchery greenhouse structure, approximately 100 feet long by 30 feet wide (i.e., 3,000 sq ft). The space is unheated, with no potable water or restrooms;

however, there is some capacity to heat the building during the winter using a heat exchanger. It provides a relatively protected area that serves as the Larval Incubation Lab for the KBSARP, as well as a quarantine area for tanks that hold salvage fish during rehabilitation. The hatchery is supplied with well water from the head ponds after tempering.

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Figure 2-5. Existing Hatchery Structure and Contents o Parcel #1 Rearing Ponds: Parcel #1 contains (24) 0.04-acre ponds that are assumed to be engaged in KBSARP production activities at the time of the lease agreement. Continuing the operation of these ponds is assumed to be permissible and their production capacity will be included in the No

Action Alternative. Figure 2-6 (right image) provides an example of the ponds located on Parcel

#1.

o Parcel #1 also contains four 0.25-acre ponds that are assumed to be engaged in KBSARP production activities at the time of the lease agreement. Continuing the operation of these ponds is assumed to be permissible and their production capacity will be included in the No Action

Alternative. Figure 2-6 (left image) provides an example of the 0.25-acre ponds located on Parcel

#1.

Figure 2-6. Parcel 1 Existing Ponds: (Left) 0.25 Acre Ponds, (Right) 0.04-Acre Ponds o Parcel #2 Rearing Ponds: Parcel #2 contains (22) 0.04-acre ponds that are assumed to be engaged in KBSARP production activities at the time of the lease agreement. Continuing the operation of these ponds is assumed to be permissible and their production capacity will be included in the No

Action Alternative. Figure 2-7 provides an example of the ponds located on Parcel #2.

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Figure 2-7. Parcel #2 Existing Ponds: 0.04 Acres Ponds o Aeration and Water Distribution Piping: At the time of the lease agreement, it is assumed that there is existing water distribution piping that delivers well water and low-pressure air directly to all the culture ponds to support KBSARP operations. Figure 2-8 provides an example of the existing water and air distribution lines available throughout the site.

Figure 2-8. Existing Water and Air Distribution lines

2.1.2 Production Capacities

The current production capacity of the Gone Fishing Site using the current equipment in its current condition at the time of the lease agreement is described in the following sections.

2.1.2.1 Indoor Egg Incubation Capacity:

There is currently no space or equipment dedicated to egg incubation in the existing hatchery building.

However, for planning and allocating space and water use in the new hatchery the following criteria was established.

• Incubation Jars:

McMillen Jacobs Associates 20 Rev. No. 1/June 2020 o Eggs per jar: 20,000 o Total Water Required: 4 gpm per jar (non-consumptive, serial reuse) o Total Area Required: 40 sq ft indoor general hatchery space

2.1.2.2 Larval Rearing Capacity

• Tanks: (5) 35-gal tanks and (30) 150-gal Tanks o Total Water Required: 32 gpm o Total Area Required: 1,800 sq ft indoor general hatchery space o Rearing Capacity: 40,000 larvae/yr

2.1.2.3 Salvage Fish Capacity

• Tanks: (6) 60-gal, (6) 150-gal, (4) 300-gal o Total Water Required: 20 gpm o Total Area Required: 1,000 sq ft indoor quarantine hatchery space o Rearing Capacity: 1,500 individual fish at one time

2.1.2.4 Juvenile Rearing (Year 1) Capacity

• Ponds: (12) 0.04-acre ponds o Total Water Required: 19.6 gpm o Total Area Required: 0.4 acres o Rearing Capacity: 24,000 individuals/year

2.1.2.5 Juvenile Rearing (Year 2) Capacity

• Ponds: (34) 0.04-acre ponds and (3) 0.25-acre ponds o Total Water Required: 57 gpm o Total Area Required: 2.0 acres o l Rearing Capacity: 21,100 individuals/year

2.1.2.6 Extended Rearing (Year 3) Capacity

• Ponds: (1) 0.25-acre pond o Total Water Required: 7.1 gpm o Total Area Required: 0.25 acres o Rearing Capacity: 625 individuals/year

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2.1.3 No Action Alternative Production Capacity Summary

The production capacity of the No Action Alternative is limited to the sum of the 2- and 3-year-old fish that are stocked from the KBSARP yearly (Table 2-2). This total is estimated to be 20,925 individuals per year. Production capacity is based on the final fish densities of fish in the ponds identified in Table

1-2. These loading rates is applied equally to all alternatives to provide a consistent comparison.

Four of the 0.04-Acre Ponds are converted to support brood stock and extended salvage fish production to align with the program goals in table 2-2. There is capacity to hold 300 individual brood stock and 400

Extended Salvage individual in the No Action Alternative production summary. Table 2-2 shows a comparison of the production capacities under the No Action Alternative.

Table 2-2. No Action Alternative Production Capacity

Common Design Criteria

Units Juvenile Rearing (Year 1)

Juvenile Rearing (Year 2)

Extended Rearing (Year 3)

Brood Stock

Extended Salvage

Indoor Hatchery

Operations Totals

Pond 1 Size SA 0.04 0.04 0.04 0.04 0.04

Pond 1 Quantity # 10 32 0 3 1 46

Pond 2 Size SA 0.25 0.25 0.25 0.25 0.25

Pond 2 Quantity # 0 3 1 0 0 4

Total Pond Area SA 0.4 2.03 0.25 0.12 0.04 2.4

Total Fish Capacity fish/yr

20,000

20,300

40,000

Make-up Water Required gpm 20 58 7 3 1 52 141

Goal Achieved % 25% 34% 31% 20% 20% 40%

SA = surface acre, gpm = gallons per minute

Table 2-2 indicates that the overall production falls well short of the KBSARP production goals as identified in Section 1.1 Purpose and Need, at 20,925 of the 60,000 Year-Two and Year-Three fish target, or 34% and 31% respectively, of the primary program objectives needed. All the secondary objective also fall short of the program goals. The total water use requirement is 36% of the site permitted capacity and the land utilization is also about 30% capacity.

2.1.4 No Action Site Layout

The current site layout is distributed between lease Parcels #1 and #2. Table 2-3 lists the exiting pond sizes. The current existing layout are located in Appendix C, Site Plans.

Table 2-3. Existing Pond Sizes

Pond # Width Length Ft2 ACRES QTY

1 20 85 1700 0.04 46

2 100 108 10800 0.25 4

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2.1.4.1 Operational Limitations and Risk

The current layout of the facility is inefficient and requires more labor than necessary. There are nearly

50 ponds to manage. The ponds are small, shallow, and lack the appropriate draining capabilities. The indoor hatchery is dilapidated, and lacks heat, potable water and proper restrooms for the staff. There are limited biosecurity protocols in place and ineffective predator deterrents. The infrastructure associated with the well pump house is dilapidated, along with the distribution piping for air and water. These factors will continue to have a negative impact on the production capabilities and create risk of catastrophic disease outbreaks or mechanical failure.

2.1.4.2 Potable Water

There is currently no potable water service to the hatchery building. Personnel must bring in drinking water. There is no municipal water service from the road. The well water does not likely meet drinking water standards and should be evaluated closely as a possible water source for sanitary purposes and fish production.

2.1.4.3 Domestic Wastewater

There is no municipal wastewater service from the road and no septic associated with the hatchery operations on the site. Personnel must use portable toilets for restrooms.

2.1.4.4 Power

Three-phase overhead power is available along the Lower Klamath Lake Road.

2.1.4.5 Communications, Monitoring, and Alarms

A landline is available on site.

2.1.4.6 Fire Protection

The site is served by the Merrill Rural Fire Protection District. There are no active sprinkler systems in the hatchery building.

2.1.4.7 Site Security

The facility is partially fenced and includes an on-site residence that is owned and is inhabited by the landowner, outside of the leased parcels. No other vandalism deterrents are in place.

2.1.5 Aquatic and Terrestrial Habitat

This site is on the higher-elevation perimeter of the eastern Klamath Basin in uplands suitable for grazing and irrigated agriculture. The Gone Fishing parcel is dry, open terrain characterized by domestic and native grasses, sagebrush, and rabbitbrush. There are no streams in the area, so aquatic habitat is entirely artificial. Current water management practices discharge effluent through a holding pond and, after settling, into a system of pipes that passes under the highway to a canal and pipeline that irrigates neighboring grazing lands.

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2.1.6 Water Resources

Water resources available include ground water resources only. There is no access to surface water on this site.

2.1.6.1 Groundwater

Oregon Water Resource Department (OWRD) records show that water right Permit G-13285 is appurtenant to the Gone Fishing property (Tax Lot 100) in Section 34, T.40 S., R.9 E. Permit G-13285 authorizes use of 0.89 cfs of groundwater for Industrial Use (Aquaculture and Geothermal Heating), with an April 2, 1997, priority date. The period of use is year-round. There is no information in OWRD’s records as to whether development of Permit G-13285 has been completed; however, use is known to be occurring.

The existing geothermal well is permitted to withdraw 399 gpm. The groundwater temperature is lethal to all fish species in an uncooled state; however, the owner indicated that he was able to cool the water in outdoor ponds to the 16° to 19° C (approximately 61° F to 66° F) range by atmospheric exposure with no mechanical chilling needed. The actual culture temperature of the ponds is regulated by the flow rate and temperature of the well water feeding the pond. In the winter, pond temperatures can be maintained at 18 deg C with high flushing rates direct from the geothermal well. These flushing rates can be equivalent to

15” of makeup water per day to maintain this codndition. As the site capacity grows, and additional ponds are brought online, the ability to regulated water temperature in the winter will be diminished and growth rates will likely be reduced. It is advisable to run all the makeup water flow through Juvenile

Rearing Year-one ponds and reuse the effluent into Juvenile Rearing Year-two and three ponds. The volume of Juvenile Rearing Year-one ponds is small, and the additional flow would give them a bump in growth through the first winter.

2.1.6.2 Surface Water

Although there are several other water rights in the area, including irrigation and industrial/manufacturing uses, the irrigation rights are surface rights using water from the Klamath Project North Canal that would not be suitable for hatchery use. The neighboring industrial/manufacturing rights are groundwater rights;

a portion of one of these rights may be transferable to an aquaculture facility if the holder is willing.

The existing aquaculture facilities are fully supplied by well water. It may be possible to obtain limited amounts of surface water via a water right transfer; however, the potential to obtain high-quality surface water is unlikely.

2.1.7 Hydraulic Profile

The water supply for this site is currently pumped. The aquifer supplying the existing well is approximately 100 feet deep. Well water is presently pumped to an elevated head pond to the west of the hatchery building. A gravity-flow piping system distributes water from the head pond to points of use.

Facilities are sited appropriately to provide good slopes for gravity-flow drains. The existing piped drain under the road to the south would be adequate to convey the proposed facility drain rates.

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2.1.7.1 Disease and Biosecurity Concerns

The USFWS teamed with the current landowner to experimentally raise sucker at this facility from 2006 to 2008. Experimentation in 2006 and 2007 included raising wild-caught sucker larvae to juvenile size, and in 2007 to 2008 included continued rearing of previously cultured fish. Larval capture and transport to the site were successful, with low mortality. The site used geothermal water that the owner was able to cool below critical limits for sucker production and used greenhouses with opaque covers that reduced solar tank heating.

Bacterial infections were not noted as problematic during culture, but ectoparasitic infection did occur, specifically Ichthyopthirius and Ichthyobodo infection. Amelioration was rapid and successful with formalin treatment and the addition of rock salt to the culture water. Lernaea spp. infection also occurred with the salvage fish, but prolonged culture in water with elevated salt content was effective in clearing the infection. Salvage fish are also quarantined from the main population. Disease concerns at this site are minimal based on previous experimentation and the use of geothermal wells as a water source.

This site is near Lower Klamath and Tule Lake National Wildlife Refuges, so predation by piscivorous birds is possible; however, all ponds are covered with netting to reduce this risk. During site visits, no piscivorous birds were observed.

2.1.8 Schedule

There is no schedule associated with the No Action Alternative. The production activities would continue unchanged at the time of the lease agreement.

2.1.9 Construction Costs

There are no construction costs associated with the No Action Alternative.

2.1.10 Permitting Summary

There are no additional permits required for the implementation of the No Action Alternative.

2.2 Action Alternative 1 – Development on Previously Disturbed Land Only

Action Alternative 1 would limit new actions at the Gone Fishing Hatchery site to areas within the parcel that have already experienced disturbance due to current development at the site.

2.2.1 Site Improvements

The following site improvements were selected as key requirements by USFWS staff and cooperators:

• Improve culture conditions and fish growth rates –…