Flathead Lakers Comments regarding Ashley Creek Use Attainability Analysis Public Comment Aimee Brunckhorst
From: Constanza von der Pahlen <constanza@flatheadlakers.org>
Sent: Monday, February 10, 2025 4:21 PM
To: Kalispell Meetings Public Comment; Coby Gierke
Subject: EXTERNAL Flathead Lakers Comments regarding Ashley Creek Use Attainability
Analysis
February 10, 2025
Dear Kalispell City Council members:
Thankyou for the opportunity to comment on the Use Attainability Analysis (UAA)for Ashley Creek. The
Flathead Lakers have several questions and concerns regarding the proposed modifications to water
quality standards.
The proposal argues that current water quality standards for lower Ashley Creek are unattainable due to
natural constraints, such as low gradient, fine sediment substrate, lack of riparian shade, and historical
limitations in salmonid populations. It further suggests that restoration efforts to reduce nutrients and
lower temperatures would have minimal impact. However, we believe some key aspects warrant further
exploration and discussion:
Historical data is limited and may not justify weakening standards
Long-term scientific data for Ashley Creek is limited and provides a narrow historical perspective on
Ashley Creek's conditions. Historical records suggest that native trout were once present, indicating that
habitat conditions may have been more favorable in the past.While we have no strong data to know how
robust the native trout population was, it also is unclear whether current population constraints are due
to natural constraints or long-term human impacts.Weakening water quality standards based on limited
historical data may prematurely dismiss the potential for restoration.
The role of restoration in improving water quality is understated
The UAA suggests that restoration efforts would have minimal impact,yet it does not sufficiently
examine case studies where riparian restoration and nutrient reduction strategies have successfully
improved conditions in similar low-gradient streams. By downplaying the potential for improvement, the
UAA may discourage necessary investments in restoration that could yield long-term benefits for Ashley
Creek and downstream waters.
Human impacts might play a significant role in water quality degradation
While the UAA acknowledges nutrient loads from agriculture and wastewater discharge, it largely
attributes poor water quality to natural conditions. However, decades of human activity, including
riparian vegetation loss, sediment runoff, and wastewater inputs, have undoubtedly contributed to
degradation. Effective riparian restoration, sediment reduction strategies, and stricter pollution controls
have the potential to improve conditions over time.A more detailed analysis on the contribution of land
use impacts on water quality and restoration scenarios are needed before concluding that
improvements would be negligible.
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The cost argument against restoration is overly dismissive
The report argues that meeting current water quality standards would require prohibitively expensive
interventions, such as riparian restoration and artificial cooling of effluent.While artificial cooling may
not be immediately viable, riparian restoration is a well-established, cost-effective approach with long-
term ecological benefits.Additionally, funding sources such as conservation grants and watershed
improvement programs could help offset costs. Dismissing restoration efforts as too costly overlooks
the potential for phased, strategic improvements that could yield significant environmental benefits.
Lowering standards could set a concerning precedent for other waterways
The UAA claims that Ashley Creek contributes minimally to nutrient loads in Flathead Lake,yet data from
the 2014 TMDL shows that it contributes the most per acre of any stream or river.Weakening water
quality standards for Ashley Creek could set a precedent for similar actions across the Flathead
watershed, potentially leading to broader cumulative impacts on water quality and aquatic habitat.
Protecting and improving water quality in Ashley Creek should remain a priority to prevent further
degradation of the region's waterways.
Given these concerns, we urge the Council to reconsider whether lowering water quality standards aligns
with long-term environmental and community interests.We appreciate your time and consideration of
these issues.
Sincerely,
Constanza von der Pahlen
Critical Lands Program Director
406-883-1346
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