Proposed Bighorn River Strategy Overview

Prepared by Doug Haacke, on behalf of Friends of the Bighorn River, Magic City Fly Fishers, Bighorn River Alliance, Montana Trout Unlimited and Montana Wildlife Federation.

Over the course of the last four years, the Montana Area Office of the Bureau of Reclamation (MTAO), on recommendations by the National Park Service’s (NPS) Bighorn Canyon National Recreation Area (BCNRA), has dramatically altered its management practices with regards to Bighorn Lake and Yellowtail Dam1.

By his own admission, MTAO Area Manager Dan Jewell2 has stated publicly that he is now managing the reservoir for a twenty foot window. That window specifies a minimum lake elevation of 3,620ft and a maximum of 3,640ft (the top of the conservation pool). Historically, rather than 20 feet, that window has been at least 32 feet and often larger.

We, the advocates of the river, its fishery and its economy, believe MTAO and BCNRA desire higher year round lake levels to support the Horseshoe Bend (HB) boat launch at the south end of the lake in Wyoming, and are unfairly disregarding the river fishery, its economy, and its greater number of visitors, most of whom enter the river from locations administered by BCNRA.

It is well known that HB is suffering from years of continued siltation which is causing 4,000 tons of sediment3 to drop in the south end of Bighorn Lake each and every day. In the last 20 years, the bottom of the boat launch has become buried under 25 feet of silt, and now requires a minimum lake level of 3,617ft to launch a boat safely, up from an original level of 3,590ft. Higher and higher lake levels will be required every year to accommodate launching at HB.
Barry’s Landing, another boat launch at the south end of lake, is 10 miles from HB, and supports launching at 3,590ft, and continues to serve as a popular launch location.
In its 1996 Water Resources Management Plan, BCNRA stated in regards to the siltation problem at Horseshoe Bend:

“The Bighorn Canyon National Recreation Area proposes to take no action to alleviate the situation and recognizes that it may no longer be economically feasible to operate a marina at Horseshoe Bend at some point in the future. It is the intent of the Park to work with other agencies and public-interest groups to seek reasonable alternatives to the problem.”

The last two years have shown us that the MTAO management style results in minimal to sub-minimal flows during late summer, fall, winter and early spring and record high lake elevations followed by extremely high, dangerous and economically stifling river releases in late spring and early summer.
To emphasize this point, river flow hydrographs for the last two years now more closely resemble those before the dam was built rather than after, which one would expect when operating a reservoir with an impractical and narrow lake elevation window. (See Fig 1.)

Fig. 1 Water Resources Management Plan, Bighorn Canyon National Recreation area, 1966

The results of these management practices have proven detrimental to the fishery and the economy of the Bighorn River, which flows through one of the poorest counties in the United States.

The Bureau of Reclamation has been authorized by Congress to manage Yellowtail Dam for hydroelectric power, irrigation, and flood control4. Yet, during water years 2008 and 2009, which were normal water years, we have seen approximately 10 months of minimal or sub-minimal flows in the river followed by approximately 2 months of extremely high flows and flooding.

Case and point: In the spring of 2008, in the middle of a successful brown trout spawn, river releases were drastically reduced well below minimum flows recommended by Montana Fish, Wildlife and Parks (FWP) biologists. MTAO admits this flow reduction was necessary to provide lake recreation at the southern end of the lake for Memorial Day, despite typically low lake usage at that time of year. The drop in river flows destroyed an entire age class of brown trout. Just a few weeks later river releases rose from 1,750cfs to 10,000cfs because of inadequate storage available in the lake.
In 2009, with lake levels higher than any period on record and despite above average snow pack, it was all but certain that when spring runoff began, flows would be extraordinary. In fact, additional (but not above normal) precipitation added to the snowmelt, and without adequate storage available in Bighorn Lake, dangerously high releases had to be made to evacuate the reservoir. Lake elevations not only reached the top of the conservation pool, but went 8 feet into the exclusive flood pool. Subsequent flooding in the Bighorn River caused thousands of dollars in damage to Montana Fish, Wildlife and Parks’ Grant Marsh Fishing Access Site. Record high lake levels reached beached driftwood, causing most of the northern half of the lake to close because of boating hazards or blocked boat launches. Campgrounds were either inundated or submerged, and were unable to open or be fully operational until mid and late summer. Anglers planning to fish the world-renowned fishery cancelled their reservations, fearing the high water. At one point, four boats in four days were dumped in the river. Had it not been for the heroic efforts of several guides and anglers, lives would have been lost. Outfitters, guides and fly shops sat nearly idle for six weeks waiting out the high flows they knew would arrive because of the high lake levels.

Advocates of the river have tried without success to have MTAO re-consider their management practices. Regular intra-agency meetings, conference calls and quarterly public issue group conferences have succeeded only in benefiting the south end of the lake and HB. During the drought years, all stakeholders shared the pain of limited water resources. However, it is our firm belief that the river should not suffer in good to above average waters as was the case in 2008 and 2009.

Further, we believe this sudden and clear change in management of the reservoir did not include a National Environmental Policy Act (NEPA) analysis, which would be triggered whenever significant impacts to the river and/or fishery occur or might occur.

The river economy, and the world-class trout fishery, cannot endure another year of these management practices.

I am humbly asking you for legislation that would require an immediate independent review of the MTAO Yellowtail Dam reservoir management practices, and to verify NEPA compliance. I believe the review could accomplish the following:

1. To review the current Yellowtail Dam and reservoir operations from the standpoint of providing sustainable recreation opportunities on the river (downstream of the dam) and the reservoir, and to evaluate other reservoir operation models that could be applied to better manage available water supplies for recreation as well as the authorized project purposes. The review would make specific recommendations and include how the project would be operated if the river fishery were balanced with other project purposes.
2. To review the methods and effectiveness of coordination between the MTAO operations with upstream projects at Buffalo Bill and Boysen reservoirs in optimizing the benefits and minimizing impacts to the recreation uses of Bighorn Lake and the Bighorn River below Yellowtail Dam, and recommend specific improvements.
3. Involve the stakeholders in the Yellowtail Dam Project in the a) selection of the review consultant(s), b) formulation of the study plan, c) conduct of the study and d) the preparation of study findings and recommendations.

Suggested draft language for Reclamation's fiscal year 20__ appropriation might be something like the following:

"From funds appropriated to Bureau of Reclamation in FY ____ for operations and maintenance not to exceed $300,000, Bureau of Reclamation is directed to obtain the services of a private consultant to conduct an independent review of the operating procedures being used in the operation of reservoir storage and dam releases at the Yellowtail Dam Project in Montana and of the coordination of operations between the Yellowtail, Buffalo Bill and Boysen projects. This review is to evaluate operational impacts to the recreational uses of the Bighorn River below Yellowtail Dam and of Bighorn Lake. The products of this independent review are to include an assessment of impacts to recreation uses and recommendations for improvements to Reclamation operational and coordination procedures. Reclamation is to involve stakeholder groups in the Yellowtail project throughout the project review process; from selection of the review consultant, formulation of the study plan, tracking progress of the study and the preparation of findings and recommendations. The Commissioner of the Bureau of Reclamation shall report findings and recommendations of this review to Congress no later than ______."

Lastly, it is important to mention that BCNRA has a current resource management plan (RMP) for the lake, but they do not have an RMP for the river.
Given that the upper three miles of river below Yellowtail Dam is under the Park's jurisdiction and accounts for the majority of visitors and revenues for BCNRA, it should stand to reason the should also have a RMP for the river.
I would very much like to discuss with you any ideas you might have that could result in the development of an RMP for the river.

Thank you for your consideration.

Sincerely,



Doug Haacke
848 Main St, Suite A4
Billings, MT 59105

Daytime: 406 252-7210
Cell: 406 855-6357
Email: dhaacke@gmail.com



1 Yellowtail Dam Operating Plans (http://www.usbr.gov/gp/mtao/index.cfm).
2 Conference call with Reclamation, July 28, 2009.
3 Water Resources Management Plan, Bighorn Canyon National Recreation Area, 1996
4 Senate Document 191 and House Document 475, as revised and coordinated by Senate Document 247, 78th Congress, 2d session.