# TRIBAL WATER QUALITY MONITORING STRATEGY (2019)

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URL: https://www.frixlaw.com/law-library/documents/tribal%3Aconfederated_clusi%3A196be0733521065f

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

TRIBAL WATER QUALITY MONITORING STRATEGY
(2019-2024)

PREPARED BY:
THE CULTURE AND NATURAL RESOURCES DEPARTMENT
CONFEDERATED TRIBES OF
COOS, LOWER UMPQUA, AND SIUSLAW INDIANS
DEPARTMENT OF CULTURE AND NATURAL RESOURCES
1245 FULTON AVE
COOS BAY, OR 97420

1

Time Period Strategy Covers:

2019-2024

Date Issued:

10/2019

Tribal Contact:

Ashley Russell, Water Protection Specialist
Alexis Barry, Interim Director
Department of Culture and Natural Resources
1245 Fulton Avenue
Coos Bay, OR 97420
Telephone: (541) 888-7511
(541) 888-7527
arussell@ctclusi.org
abarry@ctclusi.org

EPA Contact:

Kristine Carre, EPA Tribal Coordinator
Region 10: Pacific Northwest
805 SW Broadway, Suite 500
Portland, OR 97205
Telephone: (503) 326-7024
Fax: (503) 326-3399
carre.kris@epa.gov

2

Table of Contents

Table of Contents .......................................................................................................................................... 3
Elements of a Monitoring Strategy ............................................................................................................... 4
I. Monitoring Program Strategy ............................................................................................................... 4
Introduction and Scope......................................................................................................................... 4
Background ........................................................................................................................................... 7
II. Monitoring Objectives .......................................................................................................................... 8
III. Monitoring Design.............................................................................................................................. 10
IV. Core and Supplemental Water Quality Indicators ............................................................................. 14
V. Quality Assurance ............................................................................................................................... 16
VI. Data Management ............................................................................................................................. 19
VII. Data Analysis/Assessment ................................................................................................................ 21
VIII. Reporting ......................................................................................................................................... 22
IX. Programmatic Evaluation ................................................................................................................... 22
X. General Support and Infrastructure ................................................................................................... 23
Attachment A: ................................................................................................ Error! Bookmark not defined.

3

Elements of a Monitoring Strategy
I.

Monitoring Program Strategy

Introduction and Scope
The Environmental Protection Agency (EPA)’s Final Guidance on Awards of Grants to Indian Tribes
under Section 106 of the Clean Water Act (CWA) requires tribes, whose CWA 106 grants start in
calendar year 2007 with fiscal year 2007 funding, to develop a Tribal Assessment Report (TAR). These
TARs are comprised of three elements: (1) a description of the monitoring strategy, (2) a water quality
assessment, and (3) electronic copies of surface water quality data for nine basic parameters submitted in
a STORET-compatible format. This document addresses development of a water quality monitoring
strategy, satisfying element (1) of the TAR. The purpose of this strategy is to provide a long-term plan for
meeting identified water resource objectives. This strategy describes current and future monitoring
strategies and incorporates a timeline for implementation, with associated milestones, to address needed
enhancements.
Consistent with the CWA’s mission “to restore and maintain the chemical, physical, and biological
integrity of the Nation’s waters”, (33 U.S.C § 1251(a)), the Confederated Tribes of the Coos, Lower
Umpqua, and Siuslaw Indians (CTCLUSI or Tribe) also strives to restore, protect and enhance not only
the chemical, physical, and biological integrity of impaired waters within our Ancestral Territory, but also
to restore, protect, enhance, and sustain the native flora and fauna that depends on those waters.
In an effort to protect and manage Tribal waters for their multiple ecological, cultural, economic, and
intrinsic values for the next seven generations, the Tribe has developed this water monitoring strategy and
established an Integrated Water Quality Monitoring Program (IWQMP). The purpose of the IWQMP is to
generate scientific data that documents short-term variability and long-term changes in estuarine, stream,
and lake water quality of waters of/pertaining to Tribal lands. Data collected through the program will
inform the Tribe about the ecological health of aquatic resources within Tribal lands as well as the Tribe’s
Ancestral Territory. Moreover, data will aid in the development of strategic action plans addressing point
and non-point source pollution, management plans, best management practices, stewardships, total
maximum daily loads (TMDLs), and ordinances.
The ancestral homelands of the Tribe totals approximately 1.6 million acres located in southwestern
Oregon (Figure 1). CTCLUSI’s landholdings are composed of 94 parcels that total approximately 15,000
acres over seven watersheds. These lands are scattered among the Siuslaw River, Lower Umpqua River,
4

Lower Smith River, Lower Umpqua, Tenmile Lakes, Coos River, and Sixes River watersheds. The
parcels themselves consist of riparian areas, wetlands, forestlands, coastal beach front, lakefront, rural
residential and commercial development land uses. In total, this land base includes approximately .8 miles
of shoreline, 26 miles of rivers and streams, and 243 acres of wetlands.
Environmental issues occur within all of these watersheds and are negatively impacting the Tribe’s
cultural and natural resources in numerous noticeable conditions, including:
•

Impacts linked to natural resource extraction and recreation;

•

Water quality degradation due to point and non-point water pollution, including from agriculture,
timber harvesting, construction, wastewater management, and residential dumping;

•

Urban, industrial, and energy production discharges;

•

Downward trend of salmonid, lamprey, herring, eulachon, flounder, and green sturgeon returns;

•

Downward trend of other aquatic/marine traditional foods, such as abalone;

•

Maritime and chemical spills;

•

Toxins within water, sediments, cultural resources, and traditional foods;

•

Ocean acidification and hypoxia;

•

Environmental changes attributed to climate change, such as the reoccurrence of drought,
flooding, wildfires, harmful algal blooms, and invasive species, such as greenhouse thrips and
green crabs;

•

Shellfish closures due to harmful algal blooms;

•

Spreading of existing and new non-native invasive species.

5

Figure 1.

6

Background
In 2002, EPA approved the Tribe’s "treatment in a manner similar to a state" or TAS application under
Section 106 of the Clean Water Act. With this TAS approval, the Tribe became eligible to apply for EPA
grants under CWA 106 to develop and implement a Tribal water quality program. Initially, the
development of a water quality monitoring program was the primary focus. Late in 2003, the WQP
completed its first ever Quality Assurance Project Plan (QAPP) for surface water quality monitoring.
Soon after receiving EPA approval for QAPP 1.8, the WQP collected its first ever water sample on
February 5, 2004 on the North Fork of the Siuslaw River. Water quality monitoring was targeted on four
core water quality parameters in addition to salinity/specific conductivity:
•

dissolved oxygen

•

pH

•

water temperature, and

•

turbidity.

In December 2005, EPA approved QAPP 2.0, which incorporated YSI 6600 continuous data loggers at
three estuarine monitoring sites. In addition, QAPP 2.0 added measurement for the parameters of depth,
bacteria (Escherichia coli and enterococci), and chlorophyll monitoring to the WQP. QAPP 2.0 improved
the program’s ability to document and understand tidally influenced water quality fluctuations and
improved scheduled monitoring times. QAPP 2.0 also significantly increased the amount of data
collected, which resulted in the development of a Microsoft Access database capable of storing and
manipulating the dataset. The database was designed so that water quality data stored in the database
could be exported into a STORET compatible format.
Then in April 2007, a new revision for QAPP 3.0 received EPA and Tribal approval. The purpose of
QAPP 3.0 was to meet new requirements identified under EPA’s Final Guidance on Awards of Grants to
Indian Tribes under Section 106 of the Clean Water Act for Fiscal Years 2007 and Beyond. (EPA 832-R06-003). Four new water quality parameters were added to measure phosphorous and total nitrogen,
identify macroinvertebrates, and document basic habitat information.
In 2016, EPA approved QAPP 4.0, which added fresh water Harmful Algal Blooms (HABs) monitoring,
two new monitoring sites, required limits for the parameters measured for all previous QAPPs listed
above, and replaced YSI 6600 continuous data loggers with YSI EXO 2’s and 3’s. This latest revision of
the QAPP now listed a total of 14 water quality indicators measured.
More recently in 2018, the Western Oregon Tribal Fairness Act of Public Law 115-103, 131 Stat. 2253
was enacted and approximately 15,000 acres of Oregon and California Railroad Revested Lands (O&C
7

Lands) were conveyed to CTCLUSI, expanding the Tribe’s reservation and trust lands from less than 165
acres. Due to this significant increase in land management, IWMQP staff are currently revising for QAPP
5.0 to include additional water quality monitoring sites and additional water quality indicators, including
organic pollutants (e.g. diesel, oil, pesticides, pharmaceuticals), heavy metals (e.g. arsenic, mercury,
lead), as well as microbiota (e.g. phytoplankton, zooplankton, diatoms, dinoflagellates, and
cyanobacteria).

II.

Monitoring Objectives

The main goals of the Tribe’s IWQMP are to perform water quality investigations. Data generated from
these investigations will inform the Tribe about the ecological health of aquatic resources within Tribal
lands as well as the Tribe’s Ancestral Territory. Collected data will help to evaluate water quality trends,
determine water quality assessments, aid in the development and implementation of management plans
and best management practices, and advance Tribal Water Quality Standards (WQS), TMDLs, and
ordinances that protect both human and aquatic health.

Table 1.
Monitoring Objectives
Program Area

Objectives

Overall Water Quality Program

1. Establish baseline water quality conditions for all waters
of/pertaining to newly conveyed lands for all pertinent
uses.
2. Continue to document short term and long-term water quality
trends for all waters of/pertaining to Tribal lands.
3. Assess whether water quality standards are being met and
beneficial uses are being supported.
4. Identify waters needing restoration
5. Identify waters needing protection.
6. Develop restoration/protection plans.
7. Evaluate restoration/protection projects.
8. Develop Data Management Plan with partners/water quality
stakeholders.

8

Water Quality Standards

1. Continue to develop and refine Tribal water quality
standards.
2. Complete water quality standards and submit to EPA by
2021.
3. Adopt Tribal water quality standards.
4. Assess whether water quality standards are being met and
beneficial uses are being supported.
5. Obtain 303 Certification
6. Develop TMDLs in collaboration with Oregon Department
of Environmental Quality (ODEQ).
7. Develop 401 Certification Program
8. Develop a regulatory framework that ensures water quality
standards are being met and beneficial uses are being
supported.

Nonpoint Source (NPS) Program

1.
2.
3.
4.
5.
6.

Wetlands

1.
2.
3.
4.
5.
6.
7.

Biomonitoring

1. Biological assessment of macroinvertebrate communities.
2. Biological assessment of fish communities, where appropriate.
3. Biological assessment of algal communities.

Harmful Algal Blooms (HABs)

1. Continue to develop a Harmful Algal Bloom Monitoring Program.

Continue to identify impaired waters.
Identify causes/sources (point and nonpoint).
Identify waters needing restoration.
Identify waters needing protection.
Develop restoration/protection plans.
Employ post monitoring techniques to determine and quantify the
effectiveness of NPS projects in meeting water quality
standards and supporting beneficial uses.
7. Build partnerships/stewardships with water quality stakeholders
and private land owners to address NPS issues.
8. D e ve l o p w a t e r s h e d improvement projects with partners.
9. Evaluate cumulative watershed impacts from best management
practice (BMP) implementation.
Develop indicators and assess beneficial use attainment.
Continue to identify degraded/impaired wetlands.
Identify vulnerable wetlands needing protection.
Develop restoration plans to restore degraded/impaired wetlands.
Develop protection plans to protect vulnerable wetlands.
Evaluate restoration/protection projects.
Employ post monitoring techniques to determine and quantify the
effectiveness of restoration/protection projects in meeting water
quality standards and supporting beneficial uses.

9

Contaminants of Concern (COCs)
Monitoring

1. Establish baseline conditions for COC’s in water, sediment, culturally
significant vegetation, and fish tissue.
2. Document short term and long-term water quality trends.
3. Assess whether water quality standards are being met and beneficial
uses are being supported.
4. Identify waters needing restoration.
5. Identify waters needing protection.

Emergency Monitoring

1. Develop an emergency monitoring program for waters impaired by oil
spills or other chemical/pathological releases.

III.

Monitoring Design

The IWQMP has identified 14 new water monitoring sites (for a total of 21 sites) in which the Tribe
would like to expand water monitoring capabilities (see Attachment A). Most of these new water
monitoring sites are located on the newly conveyed lands and represent an initial assessment of
recognized water uses, including salmonid critical habitat or recreational activities. The other additional
sites have been identified as a result of emerging issues associated with increased pathological releases.
NPS effectiveness monitoring locations will be identified prior to any NPS project implementation and
parameters to be monitored will be determined on a project by project basis. Wetland monitoring sites
will be selected as soon as all wetlands on Tribal lands are assessed and degraded/impaired and
vulnerable wetlands have been identified. Sites for emergency monitoring will be selected based on
reported spill and sewage events, such as from the National Response Center and Oregon Office of
Emergency Management, that have been evaluated to have potential contamination to waters or other
vulnerable resources.
Table 2.

Monitoring Activities and Design
Program Area

Design

# Sites

Frequency Resources

Program
Description

Overall Water
Quality

Fixed
Station &
Targeted
Sites

7 sites
WQ

Continuous

7 sites
Bacteria

Once a month

Begun in 2005
Fixed YSI
EXO
dataloggers
located in the

Annual Avg.
of 3 FTE

10

Water Quality Status
& Trends

NPS Effectiveness
Monitoring

Same As
Above

Targeted
design
upstream/
downstream
of NPS
projects

14 sites
WQ+Bacteria

Seasonally
(Once a
month)

9 sites
Dissolved
Oxygen &
Temperature
9 sites
WQ+
Nutrients

Continuous
(Launched
Seasonally)

Same As
Above

Same As
Above

Same As
Above

Same As
Above

Same As
Above

Same As
Above

Same As
Above
Same As
Above
To Be
Developed

Same As
Above
Same As
Above
To Be
Developed

estuary that are
of/pertaining to
Tribal lands
and at North
Tenmile Lakes.
Long-term sites
for trends.
Seasonal Sites
will usually
extend from
May until
October.
Plan to
continue
monitoring
strategies as
long as
resources allow
to support
TMDLs.

Biannually

Same As
Above

Same As
Above

To Be
Determined

NPS sampling
targets sites
above and
below
restoration/
BMP
implementation
projects.
Sampling
timeframe for
each project

11

will be project
specific.
Wetlands

To Be
Developed

To Be
Determined

To Be
Developed

To Be
Determined

To Be
Developed

Biomonitoring

Targeted
Sites

9 sites
Macro
Communities
WQ

Biannually

2 FTE for 2
months

Sixes RiverStarted in 2007
Johnson Creek2 sites Spencer
Creek- 2 sites
Lake Creek 4 sites
Pucker Creek1 site

Sites To Be
Determined
Fish
Communities
WQ+Habitat
Assessment+
Flow

Seasonally

3 FTE for 4
months

Monitoring to
begin after
training has
been completed
(2020)
Lake Creek
Pucker Creek
Spencer Creek
Johnson Creek
Sixes River

3 (Additional
sites as
needed in
response to
newly
emergent
algal bloom
events)
Algal
Communities
WQ
+Nutrients

Seasonally

2 FTE for 3
months

Monitoring to
begin after
equipment has
been procured
and training
has been
completed.
Discrete grab
samples will be
collected at
North Tenmile
Lakes, Fossil
Point &
Gregory Point

12

HABs

Targeted
Sites

COCs

Targeted
Sites

Emergency
Monitoring

To Be
Developed

3 (Additional
sites as
needed in
response to
newly
emergent
algal bloom
events)
WQ+
Nutrients
5
(Additional
sites as
needed in
response to
newly
discovered/
suspected
contaminated
sites

Seasonally/As
Often As
Needed

2 FTE for 3
months

Discrete grab
samples and/or
fish tissue
samples will be
collected at
North Tenmile
Lakes, Fossil
Point &
Gregory Point

Seasonally/As
Often As
Needed

To Be
Determined

Discrete water,
soil, vegetation,
and/or fish
tissue samples
at Lake Creek
& Coos Bay

Contingent
upon extent
of release/
bloom

As needed, in
response to
incidents/
releases

Contingent
upon extent
of release/
bloom

Discrete water,
soil, vegetation,
and fish tissue
samples
contingent
upon type of
incident/release

The monitoring design will be reviewed at the end of Water Year 2020. At that time, Environmental
Protection Staff will assess and make changes to the monitoring design, if necessary, to ensure that water
monitoring objectives are being met.

13

IV.

Core and Supplemental Water Quality Indicators

In 2018, the Tribe was awarded the BIA Tribal Resilience Program Ocean and Coastal Management
Planning Grant, which significantly increased the Tribe’s capacity to monitor additional water quality
indicators, particularly Contaminants of Concern and Contaminants of Emerging Concern. Efforts are
currently being been made to obtain additional equipment and training to further expand the Tribe’s
capacity and monitor for heavy metals (e.g. arsenic, mercury, lead) and microbiota (e.g. phytoplankton,
zooplankton, diatoms, dinoflagellates, harmful algal blooms (HABs), and cyanobacteria).
The following table shows the core and supplemental water quality indicators that the Tribe will monitor
for the next five years as part of their water quality investigations.
Table 3.

Dissolved Oxygen

pH

Water Temperature

Turbidity

Salinity

Conductivity

Pathogens

Chlorophyll

Nutrients (TP/TN)

Biological
Communities

Habitat Assessment

HABs

COCs

Flow

Program
Area

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Wetlands

X

X

X

X

X

X

X

X

X

X

X

X

Biomonitoring
HABs
COCs
Emergency
Monitoring

X
X

X
X

X
X

X
X

X
X

X
X

X
X

X
X

X

X
X

X

Overall Water
Quality
Water Quality
Status &
Trends
NPS
Effectiveness
Monitoring

X
X

Wetland
Hydrogeomorphic
Settings &
Function

Indicator Categories Sampled by Program Area

X
X

X
X

X

X

14

Data generated through monitoring the indicators listed in the table above will aid the Tribe in meeting
our monitoring objectives. Continuous samples of the surface water quality parameters (dissolved oxygen,
pH, water temperature, turbidity, salinity, and specific conductivity) and physical parameters (depth/tidal
stage) will be collected using automated data loggers at six estuarine sites and one freshwater site every
15 minutes. Seasonal continuous dissolved oxygen, where appropriate, and temperature data will be
collected using automated data loggers at 9 stream sites every 15 minutes.
Discrete samples of the surface water quality parameters (dissolved oxygen, pH, water temperature,
turbidity, salinity, and specific conductivity) and physical parameters (depth) are collected using a handheld meter at all other sites seasonally. In addition, monthly water samples will be collected for the
quantitative analysis of bacteria (E.coli and enterococcus where appropriate) at the continuous data
logging sites, seasonally for enterococcus at beach sites, and seasonally for E.coli at all other sites.
Discrete nutrient sampling will be conducted twice in a season at 9 of the 21 water monitoring sites.
Nutrient samples will also be collected at algal communities and HABs monitoring sites.
Macroinvertebrate samples will be collected seasonally at 9 stream sites. Aquatic inventories, particularly
fish communities assessments, habitat assessments, and flow sampling sites are yet to be determined but
initial determinations suggest that these will likely occur at the 9 stream sites. Algal communities and
toxic algal samples will be taken seasonally at 3 sites and additionally as needed in response to newly
emergent algal bloom events.
COCs samples will be collected at least seasonally at 5 sites to establish baseline data and additionally as
needed in response to newly discovered sites or suspected contamination events. Emergency monitoring
for pathogens, HABs, and COCs will be contingent upon type of incident/release and extent.

15

V.

Quality Assurance

Table 4. QAPPs in Place for Water Quality Investigations

Type
QAPP

QA System Documents
Title and Grant Number
Completion
Date

EPA Approval
Date

In Progress

In Progress

2/26/2016

3/17/2016

10/31/2008

02/25/2009

12/28/2006

4/30/2007

QA/QC

QAPP 5.0 for the Tribal Integrated Water
Quality Monitoring Program
QAPP 4.0 for the Tribal Integrated Water
Quality Monitoring Program
QAPP 3.1 for the Tribal Water Quality
Monitoring Program
QAPP 3.0 for the Tribal Water Quality
Monitoring Program
YSI 6600 Data Editing and Management

09/06/2006

NA

QA/QC

YSI 556 & YSI 650 Data Upload

3/10/2006

NA

QAPP

QAPP 2.0 for Water Quality Monitoring on
the Tribal Reservation
QAPP 1.8 for Baseline Water Quality
Monitoring Project on the Tribal Reservation

12/16/2005

01/03/2006

12/10/2003

12/29/2003

QAPP
QAPP
QAPP

QAPP

Standard Operating Procedures (SOPs) have been effective for a number of parameters, including for the
YSI EXO1 and EXO2 Sonde Multi-Parameter Dataloggers (5/31/2016), the YSI 6600 EDS Sonde
Retrieval (6/6/2006), and the Water Quality Monitoring Program (6/5/2006) as a whole. As seen in Table
4, several QA/QC procedures exist for data management. However, due to the program’s steady
maturation, the IWQP is currently formulating a more comprehensive QA/QC management plan.
Although not yet formalized, this mission recognizes needed elements in the quality system, such as:
•

management of quality records and other documents

•

management of chemicals and other materials

•

equipment tracking and maintenance tracking;

•

training procedures;

•

ubiquitous health and safety considerations in field and laboratory undertakings;

•

quality control of data outputs and reports;

•

understanding nonconformances and deviations; a
16

•

scheduling regular auditing of procedures.

In the long-term, these formalized procedures will result in validated data, sufficiently and standardized
cross-trained staff, and foremost, ensure the quality of data. As a result of these findings, the IWMQP has
completed a number of SOPs to initiate the process that span several categories: document management
(DM); materials management (MM); field operating procedures (FOP); laboratory operating procedures
(LOP); equipment operation, maintenance, and calibration (EQ); data and information management (IM);
facility and safety (FS), quality assurance (QA), and chain of custody (CC). Table 5. provides a list of
(newly or planned revision) completed and anticipated SOPs. Moreover, SOPs for field and laboratory
procedures are currently being updated and are in the process of being reviewed and formally adopted
into an updated QAPP.
The IWQMP has identified an issue to capacity building that encompasses smaller issues in efficiency,
deliverables, and overall capacity building. Quality assurance and quality control (QA/QC) should be
supervisory to the quality management system and oversee the correct implementation of checks and
balances of all procedures. This need can be realized with 1.0 FTE. This staff person would handle quality
control of field and laboratory processes, put control measures and validate data outputs, and ensure
health and safety and other appropriate procedural trainings. With an increase in the programs ability to
measure water quality indicators, ensuring the quality management system is essential, and a quality
manager is thus paramount.

17

Table 5. New or Anticipated SOPs in the IWQMP Quality System

18

VI.

Data Management

The Department of Culture and Natural Resources is responsible for water quality investigations data
management for the Tribe. Water quality data generated from these investigations is managed by various
means, and is more explicitly outlined in Table 6.
Table 6. Data Management System Currently Employed by the IWQMP

Water Resource
Type and/or
CWA Program
Area and/or
Monitoring
Objectives

Overall Water Quality

Data
Mgmt
–on site

Data is
entered
into MS
Excel
Files are
backed-up
daily

Water Quality Status
& Trends
NPS Effectiveness
Monitoring
Wetlands
Biomonitoring
HABs
COCs
Emergency
Monitoring

Same As
Above
NA
NA
Same As
Above
Same As
Above
Same As
Above
Same As
Above

Data Management
Storet
Land Use Data

All data, except for
continuous data,
will be exported
into STORET using
the Central Data
Exchange (CDX)
annually.

Georeferencing

CTCLUSI is new to
managing land use data
and is currently
developing a GIS
database and team.
1:24,000 scale

Yes

New staff will need
trained on STORET
Same As Above

Same As Above

Yes

NA

Same As Above

Yes

NA
Same As Above

Same As Above
Same As Above

Yes
Yes

Same As Above

Same As Above

Yes

Same As Above

Same As Above

Yes

Same As Above

Same As Above

Yes

19

Continuous monitoring data (dissolved oxygen, pH, water temperature, turbidity, salinity, specific
conductivity, and depth) generated by data loggers is initially collected and stored on the data logger.
After the logger is retrieved from the field, the data is then transferred from the data logger to the
laboratory work station computer via the data logger’s associated installed software and stored as an xlsx
file on the Culture and Natural Resources Department’s dedicated server. After the raw data is
transferred, it will remain on the data loggers as back-up. At the end of the fiscal water year, the data is
combined, trimmed, and used in writing the water quality annual assessment report and shared with our
partners/water quality stakeholders. Raw data is kept intact and copies are used when combining and
manipulating data in case of overwrite errors. Technical assistance is needed in order to save continuous
data in a STORET compatible xlsx file.
Discrete water quality grab sample data is recorded on rain proof field data sheets that will include basic
information, such as station id, date, time, water/weather conditions, tide, and any other information
deemed useful for that particular water quality investigation. Once in the laboratory, the data will be
written into an xlsx file and saved on the departmental server. Since bacteria data is generated in house, it
is automatically saved in a STORET compatible xlsx file after it is analyzed and uploaded to WQX via
CDX biannually. Nutrients and Macroinvertebrates data are sent from the associated processing lab in an
xlsx file format. Technical assistance is still also needed for other discrete water quality grab samples and
assessments, such as other physical-chemical data (COCs), nutrients, macroinvertebrates, habitat,
biological, in order to save that data in a STORET compatible xlsx file and upload it to WQX via CDX.
The Tribe is currently working with the Siuslaw Watershed Council (SWC) to receive guidance on how to
save data in a STORET compatible xlsx file and may be uploaded to ODEQ’s Ambient Water Quality
Monitoring Portal for the interim.
Monitoring locations and data are georeferenced to the Projected Coordinate System NAD 1983 2011
StatePlane Oregon South FIPS 3602 Ft Intl. All scales are 1:24,000 or less, as scales are typically
customized to the audience, required formatting, and feature visibility. Garmin and Trimble data
collectors are used for field deployment and further manipulated with standardized software, such as
ESRI ArcGIS. Data is manipulated in reference to shared data, such as protected species critical habitat
layers from USFS and ODFW, hydrography layers from BLM, and spill response layers from NOAA and
USCG, to name a few. Formal published map products are generated by both internal and external
department staff under team-managed data permissions. CTCLUSI’s formalized GIS Team regularly
meets to discuss and collaborate on projects, data management, and resource procurement.

20

VII.

Data Analysis/Assessment

The Tribe uses Microsoft Excel and RStudio to analyze data for Water Quality Annual Assessment
Reports. Furthermore, formal training using EPA recommended statistical analyses specific to trend
analyses of water quality data and project design would help build departmental capacity.
The Tribe currently does not have a documented method for assessing attainment of water quality
standards. However, the Tribe currently includes an assessment of Tribally adopted water quality
standards in our annual water quality report. For the purposes of TAS for CWA 303 and 401 certification,
we will need to develop an assessment methodology, which will consist of a panel of Environmental
Protection Staff members who report to Tribal Council. This panel will analyze monitoring data from
CTCLUSI, as well as from Oregon Department of Environmental Quality (ODEQ), Oregon Health
Authority (OHA), South Slough National Estuarine Research Reserve (SSNERR), United States
Department of Agriculture (USDA), and other water quality partners/stakeholders (e.g. watershed
councils) data, where appropriate. The panel will then forward its findings and recommendations to the
Tribal Council on an annual basis at minimum, and on an emergency basis when the need arises.
Determinations derived from discussions with Tribal Council will be included in the Tribe’s annual Tribal
Assessment Report (TAR) (i.e water quality assessment report).

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VIII.

Reporting

An annual Tribal Water Quality Assessment Report (TAR) is completed and submitted to our EPA Tribal
Coordinator at the end of each water calendar year. The report includes a graphical display of the data
collected during the water year (October thru September) and provides a brief narrative for each
monitoring site. The final report is available on the Tribe’s website (www.ctclusi.org) within the Water
Quality Program page. In addition, Quarterly Performance Reports are completed thirty days after each
fiscal quarter. These reports describe the quarterly activities completed by the IWQP and are provided to
our EPA Tribal Coordinator.
Table 7.

Tribal Reports
Report

Timeframe

Entities receiving Comments
copies of the
report

Annual Water Quality
Assessment Report

Annually by December
1st

Summary of WQ data
with comparisons to
WQ criteria

Quarterly Performance
Report

Quarterly

EPA
Posted on CTCLUSI
Website for public
EPA

Nonpoint Source
Pollution Assessment
Report
Wetland Inventory and
Assessment Report

2022

EPA
Posted on CTCLUSI
Website for public
EPA
Posted on CTCLUSI
Website for public

Updated report that
includes newly
conveyed lands
Updated report that
includes newly
conveyed lands

IX.

2022

Programmatic Evaluation

The Director of the Department of Cultural and Natural Resources and Environmental Protection Staff
will meet at the beginning of every new water calendar year (beginning October 1st) to evaluate the
performance of the IWQMP. During the evaluation, emerging issues, data needs, and resource gaps
identified during the previous year’s water monitoring investigations and assessments will be addressed.
Objectives will be reprioritized based on data needs and resource availability. Emerging issues and
resource gaps may also be addressed anytime during the water calendar year to ensure that water
22

monitoring investigations are meeting program objectives. Programmatic coordination for effectiveness
monitoring and assessments with partners/water quality stake holders will also be evaluated at the
beginning of every new water calendar year.
The Tribe looks forward to any technical assistance the EPA can provide to aid the Tribe in furthering
their endeavors to restore, protect, enhance, and sustain the chemical, physical, and biological integrity of
impaired waters within our Ancestral Territory and the native flora and fauna that depends on those
waters. Specific areas of focus will be selected during the annual evaluation of the strategy.

X.

General Support and Infrastructure

As of 2018, the Indian Environmental General Assistance Program Act in addition to CWA 106 and 319
grant funding provides the IWQP with 2.07 FTE to complete all water quality monitoring and reporting
tasks. The current funding level sufficed monitoring needs for the small acreage of approximately 540
acres that the Tribe owned previous to January 8, 2018. On that date, the Western Oregon Tribal Fairness
Act was enacted and the Tribe was conveyed 7 tracts of O&C lands spread over 3 counties and totaling
14,742 acres.
Many of the waters within these tracts have been designated critical habitat for Oregon coastal coho
salmon (Oncorhynchus kisutch) and will require that additional water quality indicators be monitored for
to ensure that water quality standards are being met, beneficial uses are being supported, and human
health and aquatic health are being protected. Reference Table 8. for resources the Tribe currently utilizes
for monitoring and those that the Tribe will need in order to meet the new objectives set forth in this
strategy.
In order to be able to monitor for the additional water quality indicators set forth in this strategy, the Tribe
has been building laboratory capacity to monitor for COCs and COECs. Efforts are still ongoing to build
in house capacity to monitor HABs. Additional training will also be required to perform aquatic
inventories and wetland inventories and assessments.

23

Table 8.

Objectives
Existing:
Provide Water
Quality
Investigations and
Assessments and
continuity with
past water quality
investigation
efforts
Work with
Partners/Water
Quality
Stakeholders to
address NPS
issues

Staffing
2.07 FTE

Biologist
Water
Protection
Specialist
Air & Water
Protection
Specialist

Training

Current staff are
highly competent
in ambient water
quality
monitoring;
bacteria
monitoring;
nutrient
sampling; and
macroinvertebrate
communities
sampling
Scuba
Certification

Equipment
1 GSA Leased
Vehicle

1 Flat Bottom Boat
and Trailer
1- 40 hp Honda
Outboard Motor
1- 8 hp Yamaha
Outboard Motor
1 YSI EXO 1
Handheld MultiParameter Sonde
Probe with cable
and complete set of
probes
6 YSI EXO 2 data
loggers with a
complete set of
probes

Lab Resources
Marine Chemistry
Laboratory at the
University of
Washington’s
School of
Oceanography for
nutrient analyses

Aquatic Biological
Associates, Inc. for
macroinvertebrate
analyses
Oregon Department
of Fisheries and
Wildlife’s Marine
Resources Program
for phytoplankton
analyses

1 YSI EXO 3 logger
with a complete set
of probes
17 HOBO water
temperature data
loggers and software
1-IDEXX
Bacteria Lab QuantTray sealer and
trays, supplies, and
2 incubators.
1 GCMS with
workstation

24

computer and
software
1 Centrifuge
1 Analytical Balance
2 Microscopes
1 Nutrient
AutoAnalyzer
1 Fume Hood
1 Mini Refrigerator
1 Freezer
4 Workstation
computers &
software
Future:
Reassess
monitoring
priorities and
design
NPS Effectiveness
Monitoring
Wetlands
Monitoring
Wetlands
Monitoring
EPA Approved
Water Quality
Standards
Establish
Regulatory
Framework for

3.50 FTE
Biologist
Water
Protection
Specialist
Air & Water
Protection
Specialist
Lab
Technician

GCMS Training
Handheld XRF
Analyzer
Training
FlowCam
Training
Current
Meters/Flow
Gauges
Installation;
Operations; &
Data Analyses
Training
Wetland
Functions
Assessment
Training

1 Field
Laptop/Tablet
~10 Dissolved
Oxygen Data
Loggers
1 Handheld XRF
Analyzer

Southwestern
Community College
Laboratory
HABs analyses
Heavy Metals
analyses

1 FlowCam
~ 10 Current
Meters/Flow Gauges
WQ statistical
software
ARC-HYDRO

25

Developing 303
and 401
Certification
Programs
Regulatory
Framework

Aquatic
Inventories
Training
Habitat
Assessment
Training
Algal
Communities
Inventories &
HABs monitoring
Training
COCs Training
Flow
Measurements
Training
Emergency
Monitoring
Training
STORET
Training
RStudio Training
WQ Statistical
Software
Training
ARC-HYDRO
GIS Training

26

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Aconfederated_clusi%3A196be0733521065f. Public record. Not legal advice.