# NONPOINT SOURCE MANAGEMENT PROGRAM PLAN

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Ahoh%3A64b676e5f63d8073

## Record

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

## Text

NONPOINT SOURCE MANAGEMENT PROGRAM PLAN
HOH RIVER WATERSHED
JEFFERSON COUNTY, WASHINGTON WRIA 20

Submitted to:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 10 TRIBAL ASSISTANCE PROGRAM
1200 Sixth Avenue, Suite 155
Seattle, Washington 98101

Submitted by:
July 2026
Hoh Indian Tribe Natural Resources Department
2269 Lower Hoh Rd, Forks, Washington 98331
In cooperation with: WESTECH CONSULTING, LLC
937 Boathaven Drive, Port Angeles, Washington 98363
Trevor Shea, CEO
Copyright 2025 by Trevor Shea, Westech Consulting, LLC – All Rights Reserved

CONTENTS
OVERVIEW ................................................................................................................................... 3
Summary of Waters .............................................................................................................. 34
Waters Facing Imminent Threats .............................................................................................. 4
High-Quality Waters Requiring Protection .............................................................................. 6
Olympic National Park Headwaters.......................................................................................... 6
Culturally Significant Waters .................................................................................................... 6
INTRODUCTION ....................................................................................................................... 7
Objective 1: Manage Temperature Impairments ................................................................ 87
Objective 2: Reduce Chronic Dissolved Oxygen Violations .......................................... 8
Objective 3: Develop Framework for Addressing Severe Acidification .................... 8
Objective 4: Address Streambank and Riparian Buffer Zone Vulnerabilities ....................... 8
Objective 5: Protect High-Quality Waters ............................................................................. 9
MANAGEMENT PROGRAM SUMMARY ................................................................................. 9
MANAGEMENT PROGRAM DESCRIPTION .......................................................................... 10
BMP Selection Considerations ............................................Error! Bookmark not defined.10
Nonpoint Source Pollution Categories................................................................................ 1114
Implementation .................................................................................................................. 2529
Governance Structure ....................................................................................................... 4649
CONCLUSION ..................................................................................................................... 4952
REFERENCES ...................................................................................................................... 5255

List of Tables and Figures
Table 1. Summary of NPS management plan for each pollutant category. ............................. 2224
Table 2. NPS categories and their potential pollutant impacts. ............................................... 2426
Table 3. NPS categories and impairments based on monitoring sites. .................................... 2527
Table 4. NPS objective and outcome measures by category.................................................... 3638
Table 5. Summary of Major Funding Sources for NPS Implementation. ................................ 4648
Figure 1. Hoh Tribe’s water quality monitoring program’s assessed waterways and wetlands in
the Hoh River Watershed. ............................................................................................................... 7

2

OVERVIEW
The Hoh Indian Tribe has developed this Nonpoint Source Management Program Plan (MP)
to establish the framework for addressing significant water quality impairments throughout the
299-square mile Hoh River Watershed. This plan, with the companion Nonpoint Source
Assessment Report (AR), fulfills requirements under Section 319 of the Clean Water Act,
qualifying the Tribe for federal nonpoint source implementation funding. The MP translates
assessment findings, documenting river miles of impaired waters into actionable strategies for
restoration while protecting remaining high-quality resources essential to treaty-protected
fishing rights and cultural practices.
The assessment report and the management plan comprehensively address four conditions
through synthesis of water quality monitoring data (FY2021-2025), field reconnaissance, and
geospatial analysis. The AR documented that 43.8 river miles (57.7%) of assessed waters fail
to meet applicable standards, with temperature impairments affecting 35.8 river miles
(47.15%) throughout the watershed in 2025 (Assessment Report 2025). The AR provides the
technical foundation upon which the MP builds its implementation framework.
The AR establishes eleven tributaries maintaining continuous 303(d) listings for temperature
since 1996: Alder, Anderson, Elk, Line, Maple, McQuarry-Fisher, Nolan, Owl, Split,
Willoughby, and Winfield Creeks. This demonstrates that nearly three decades of current
forest practices have proven insufficient for achieving recovery (Ecology 2025; Assessment
Report 2025).
Dissolved oxygen violations in Lower Chalaat Creek, with a 64.6% failure rate over 19 years
of monitoring, indicate ecosystem dysfunction requiring immediate intervention to protect the
Tribe's steelhead hatchery operations (Hoh Tribe FY25 CWA 106 Report). Severe acidification
in Hell Roaring and Lower Braden Creeks, with pH consistently below 5.5, has effectively
eliminated these waters from the functional habitat network (Assessment Report 2025).
SUMMARY OF ASSESSMENT FINDINGS
Key findings from the comprehensive AR provided the technical foundation for this MP.
Documented widespread water quality degradation throughout the Hoh River Watershed,
identified the primary pollution sources contributing to impairments and established the
scientific basis for selecting appropriate management interventions.
The following summary highlights the most critical impairments requiring immediate
attention, the dominant nonpoint sources driving degradation, and the high-quality waters
requiring protection from future impacts. This synthesis ensures that management strategies
directly address documented problems while building on existing watershed strengths.
Summary of Waters
3

The Hoh River Watershed exhibits widespread and persistent water quality degradation
throughout its 298.5-square mile drainage area, with the AR documenting that 43.8 river miles
(57.7%) of the 76 river miles assessed fail to meet water quality standards for at least one
parameter (Assessment Report 2025). This comprehensive impairment affects fish-bearing
waters from headwater tributaries to the mainstem river, threatening the ecological integrity
necessary to support treaty-reserved fishing rights and cultural practices. Certification of tribal
authority can be found in the appendix of this report. The severity and extent of these
impairments, documented through five years of intensive monitoring and field
reconnaissance, demonstrate that nonpoint source pollution control is essential for achieving
water quality standards throughout the watershed.
Waters Facing Imminent Threats
Temperature represents the most pervasive water quality impairment, affecting 35.8 river
miles (47.15%) of monitored stream length with violations documented at 26 monitoring sites
during FY2025 (Hoh Tribe FY25 CWA 106 Report).
The AR identified eleven tributaries maintaining continuous 303(d) listings for temperature
since 1996: Alder, Anderson, Elk, Line, Maple, McQuarry-Fisher, Nolan, Owl, Split,
Willoughby, and Winfield Creeks. This demonstrates that nearly three decades of current
forest practices have proven insufficient for achieving recovery (Ecology 2025; Assessment
Report 2025). The Hoh River mainstem joined this list of persistently impaired waters in 2012,
indicating that cumulative thermal loads from degraded tributaries now overwhelm the dilution
capacity of the main river. Maximum temperatures reached 19.7°C in Lower Nolan Creek in 2023,
approaching lethal limits for salmonids and exceeding the 16°C core summer salmonid habitat
criterion by 3.7°C (Assessment Report 2025).
Dissolved oxygen violations compound temperature stress in critical spawning and rearing
habitats, with monitoring documenting chronic failures at multiple sites throughout the watershed.
Lower Chalaat Creek exhibits the most severe impairment with a 64.6% failure rate over 19 years
of monitoring, where DO concentrations routinely drop below the 9.0 mg/L standard necessary to
support the Tribe's steelhead hatchery operations (Hoh Tribe FY25 CWA 106 Report). DO
violations frequently coincide with temperature impairments at sites including the Hoh River
mainstem and Lower Nolan Creek. This creates synergistic stress where elevated temperatures
reduce oxygen solubility while simultaneously increasing metabolic oxygen demand (Assessment
Report 2025). Field reconnaissance confirmed visual indicators of oxygen depletion through
extensive algal growth and stagnant conditions during summer low-flow periods.
Severe acidification has effectively eliminated Hell Roaring and Lower Braden Creeks from the
functional habitat network, with pH values consistently below 5.5 since monitoring began in 2005
(Assessment Report 2025). Lower Braden Creek exhibits both pH and dissolved oxygen
violations, creating particularly hostile conditions where acidification increases metabolic costs
while oxygen depletion limits available energy for aquatic organisms (Hoh Tribe FY23 CWA 106
4

Report).
The spatial distribution of impairments reveals clear patterns linking water quality degradation to
land management activities. Temperature impairments concentrate at actively managed state and
private forestlands, with streams showing marked deterioration (Assessment Report 2025). This
pattern indicates that current forest practices, particularly inadequate riparian buffers and extensive
clear-cutting documented during field reconnaissance, continue to drive thermal loading despite
regulatory requirements.
Conversely, dissolved oxygen and pH impairments concentrate in lower gradient reaches where
channel morphology and longer residence times create conditions for biochemical oxygen
depletion and acid accumulation.
Turbidity violations, while less pervasive than other parameters, create episodic impacts during
storm events that mobilize sediment from roads, harvest units, and unstable banks. Canyon Creek
experiences severe turbidity problems requiring further investigation, while monitoring at other
sites indicates general compliance except during high-flow events (Assessment Report 2025). The
limited turbidity monitoring conducted to date likely underestimates the extent of sediment-related
impairments, particularly given the 246 documented stream crossings and extensive unpaved road
network identified in the watershed assessment.
Multiple parameter violations create cumulative stress at six critically impaired locations where
temperature, dissolved oxygen, pH, or turbidity problems overlap. Lower Nolan Creek experiences
both severe temperature violations (maximum 19.7°C) and chronic dissolved oxygen depletion,
while Lower Chalaat Creek combines the watershed's worst dissolved oxygen conditions with
periodic pH depression (Assessment Report 2025). These multiply-impaired waters represent
priority restoration sites where addressing single parameters in isolation will prove insufficient for
achieving designated uses.
The persistence of these impairments despite decades of restoration efforts and regulatory
compliance demonstrates that current management approaches have failed to protect or restore
water quality. The eleven tributaries maintaining continuous 303(d) listings since 1996 show no
improving trends after 27 years, with several streams showing continued degradation (Ecology
2025).
Regionally documented impacts, including earlier snowmelt, extended summer drought, and
extreme heat events, will intensify existing impairments and make current degraded conditions
tomorrow's best-case scenarios without comprehensive intervention (Assessment Report 2025).
Several currently unimpaired or marginally impaired waters face immediate threats requiring
proactive protection measures before degradation occurs. Highway 101 corridor streams face
ongoing threats from transportation-related pollutants, with direct discharge of untreated road
runoff documented at multiple bridge crossings including sites where traffic and stormwater flow
directly into rivers without any treatment (Assessment Report 2025). Winter road maintenance
5

introduces sand, salt, and deicing compounds, while year-round vehicle traffic contributes
petroleum hydrocarbons, brake dust, and tire particles like 6PPDQ. These streams currently
maintaining marginal water quality could rapidly deteriorate without installation of stormwater
mitigation systems and regular maintenance of existing infrastructure.
Upper watershed areas currently protected by mature second-growth forests face potential
degradation as these stands reach commercial maturity and enter harvest rotations. Private
industrial forestlands typically operate on 35-45-year rotations, meaning forests regenerating from
1980s-1990s harvests will soon face cutting (Assessment Report 2025)
Proactive engagement with landowners to establish extended rotations, expanded buffers, or
conservation easements in key watersheds could prevent future temperature impairments before
they occur.
High-Quality Waters Requiring Protection
While the Tribe has documented extensive water quality degradation throughout the Hoh River
Watershed, it also identifies critical high-quality waters that maintain ecological integrity and
require protection from future impairment. These waters provide essential ecological functions
including cold-water refugia, source populations for downstream recovery, reference conditions
demonstrating achievable restoration endpoints, and sustained support for treaty-reserved fishing
rights (Assessment Report 2025). Protection of these remaining high-quality waters proves more
cost-effective than restoration and ensures preservation of the ecological foundation necessary for
watershed-wide recovery.
Olympic National Park Headwaters
The most extensive high-quality waters originate within Olympic National Park boundaries, where
109,888 acres (57.4% of the watershed) receive comprehensive protection under National Park
Service management that prohibits commercial resource extraction (Assessment Report 2025).
The glacially fed nature of the upper Hoh River and several headwater tributaries contributes yearround flow and naturally elevated turbidity from glacial flour, maintaining base flows even during
extended summer drought periods (Assessment Report 2025). Although most of the rivers and
creeks monitored by the Tribe in the ONP do not achieve water quality standards, waterways in
the park are cooler and better oxygenated compared to those outside of its boundaries on state and
private forestlands. These protected headwaters serve as the ecological backbone of the watershed,
providing water that moderates downstream impacts. The transition zones where streams exit park
protection warrant special management attention, representing the last opportunity to maintain
higher quality conditions before entering areas of active forest management.
Culturally Significant Waters
Waters holding special cultural importance to the Hoh Tribe require protection beyond their
ecological value, representing irreplaceable connections to traditional practices and spiritual
beliefs. These include traditional fishing sites at specific river bends and tributary confluences
6

where families have harvested salmon for generations, ceremonial bathing pools used for spiritual
cleansing and cultural practices, and medicinal plant gathering areas along riparian zones where
specific species grow. While specific locations remain confidential to protect cultural resources,
these waters often coincide with high ecological quality due to traditional management practices
and limited development.
The Tribe's steelhead hatchery on Chalaat Creek represents a modern expression of traditional
fisheries management, requiring high-quality water for successful operations that support both
subsistence and ceremonial needs. Continued degradation threatens long-term viability in Chalaat
Creek (Hoh Tribe FY23 CWA 106 Report). Protection of hatchery water supplies through
upstream buffer enhancement and sediment reduction becomes essential for maintaining tribal
fisheries programs.

Figure 1.Hoh Tribe’s water quality monitoring program’s assessed waterways and wetlands in the Hoh
River Watershed.

INTRODUCTION
This plan translates documented water quality impairments into actionable restoration
strategies The plan presents the programmatic structure through which the Tribe will
coordinate voluntary implementation of best management practices, leverage partnerships
across mixed ownership landscapes, and adaptively manage restoration efforts based on
monitoring feedback. Through this framework, the Tribe seeks to restore decades of
7

cumulative impacts that have impaired waters while protecting remaining high-quality waters
essential for treaty-reserved fishing rights and cultural practices.
The overarching goal of the Hoh Indian Tribe's NPS management plan is to restore and protect
water quality effected by NPS throughout the Hoh River Watershed to support treaty-reserved
fishing rights, cultural practices, and the ecological integrity necessary for sustaining salmon
and steelhead populations. This goal recognizes that water quality degradation directly
threatens the Tribe's ability to exercise treaty rights guaranteed under the Treaty of Olympia
(1855-1856) and affirmed through subsequent federal court decisions (United States v.
Washington 1974).
The management plan seeks to reverse decades of cumulative impacts from NPS pollution
while protecting remaining high-quality waters from future degradation. It establishes five
primary objectives that address known critical water quality impairments that are caused by
nonpoint source pollutants:
Objective 1: Manage Temperature Impairments in Persistently Degraded Tributaries
Prioritize restoration of the eleven tributaries maintaining continuous 303(d) listings for
temperature since 1996. These streams include Alder, Anderson, Elk, Line, Maple,
McQuarry-Fisher, Nolan, Owl, Split, Willoughby, and Winfield Creeks. These streams
collectively represent 25 river miles of impaired habitat, requiring comprehensive riparian
restoration, enhanced shade retention requirements, and modified forest practices to achieve
compliance with salmonid habitat criterion (WAC 173-201A-200; Assessment Report 2025).
Objective 2: Reduce Chronic Dissolved Oxygen Violations in Critical Spawning and
Rearing Habitat
Implement targeted interventions to address dissolved oxygen violations, particularly in
Lower Chalaat Creek where the 64.6% failure rate over 19 years threatens the Tribe's steelhead
hatchery operations (Hoh Tribe FY25 CWA 106 Report). Management actions will focus on
improving riparian function to moderate stream temperatures that influence oxygen solubility
and restoring natural channel complexity to enhance reaeration.
Objective 3: Develop Framework for Addressing Severe Acidification in
Headwater Streams
Establish specialized approaches for Hell Roaring and Lower Braden Creeks, where pH values
consistently below 5.5 have eliminated these waters from the functional habitat network
(Assessment Report 2025). Given the complex interaction between natural geology,
atmospheric deposition, and forest management practices contributing to acidification, the
program will implement restoration techniques. These include cedar spault removal, enhanced
wetland delineation, invasive removal, and modified harvest prescriptions in contributing
watersheds.
8

Objective 4: Address Streambank and Riparian Buffer Zone Vulnerabilities throughout
the Watershed
Streambank vulnerabilities like bank erosion, sediment delivery pathways, roadway runoff,
and riparian buffer degradation can benefit from sediment control practices or bank
stabilization. Sediment delivery from the extensive road network and associated stream
crossings creates chronic turbidity impairments throughout the Hoh River Watershed, with
Canyon Creek exemplifying the severity of erosion impacts through maximum turbidity
readings of 190.80 NTU upstream of Upper Hoh Road in FY2022, far exceeding the 5 NTU
over background standard for salmonid streams (Assessment Report 2025). The watershed's
forest road system, developed primarily during the timber harvest expansion of the 1960s1980s, continues generating sediment decades after construction through surface erosion,
crossing failures, and chronic maintenance deficits. The following sediment control practices
address both active erosion sources and legacy infrastructure contributing to water quality
degradation. Protection streambanks through buffer enhancement and conservation easements
could create stepping stones for watershed recovery.
Objective 5: Protect High-Quality Waters Within and Adjacent to Olympic National
Park
Implement protection strategies for parts of the watershed maintaining water quality standards,
particularly pristine headwater streams within Olympic National Park boundaries that serve as
critical refugia for cold-water species (Assessment Report 2025). Protection measures will
include enhanced riparian buffers on adjacent lands, strategic conservation easements in key
connectivity corridors, and proactive monitoring to detect emerging threats before
degradation occurs. The program recognizes that protecting functional habitat is more costeffective than restoration and essential for maintaining source populations for watershed
recovery.
MANAGEMENT PROGRAM SUMMARY
The Hoh Tribe's Natural Resources Department has demonstrated substantial governmental duties
and powers through decades of environmental management under the authority of the Hoh Tribal
Business Committee. This includes operation of EPA-approved water quality monitoring programs
under Section 106 using EPA General Assistance Program (GAP) since the early 2000s,
development of comprehensive forest management plans (Hoh Tribe 2015), and co-management
of fisheries resources throughout treaty areas. While the Tribe is currently pursuing Treatment as
State (TAS) status under Section 518(e) of the Clean Water Act for the Section 319 program, the
completion of these NPS Assessment Report and NPS Management Program Plan establishes the
foundation for TAS approval and subsequent eligibility for Section 319(h) base and competitive
grant funding.
The Hoh Tribe’s Water Quality Specialist manages a Partnership Performance Grant (PPG) which
bundles the General Assistance Program (GAP), Clean Water Act 106, and a Wetland Program.
9

The nonpoint source pollution management program will join the list of grants included in the
PPG. The Water Quality Specialist, along with other specialists in the Natural Resources
Department, will aid in establishing a framework for the program. Specialists include the Timber,
Forest, & Wildlife Biologist, Restoration Biologist, Wetland Specialist, Natural Resources
Director, Fisheries Manager and technicians. The Hoh Tribal Business Committee is presented
with details of the non-point source pollution program through bi-monthly council meetings with
the Natural Resources Director. Hoh Tribal Business Committee members have final oversight
into any nonpoint source program decisions. The program requires input from all staff to ensure
success of a comprehensive watershed-based approach of the Hoh River Watershed. The Tribe's
existing PPG and diverse portfolio of natural resource grants from NOAA, BIA, and other state
agencies, provides the institutional foundation necessary for successful implementation of
comprehensive NPS management throughout the Hoh River watershed.
The Tribe's authority to develop and implement this management program derives from its
inherent sovereignty as a federally recognized tribe, treaty-reserved rights under the Treaty of
Olympia (1855-1856), and status under the Clean Water Act. The Hoh Tribe is regarded on the
Department of Interior's list of Indian Entities Recognized and Eligible to Receive Services from
the United States Bureau of Indian Affairs, confirming federal recognition and government-togovernment relationship with the United States (Federal Register 2025). The
federal trust responsibility and treaty obligations provide additional authority for tribal water
quality protection that transcends specific Clean Water Act provisions. As affirmed through the
Boldt Decision (United States v. Washington, 384 F. Supp. 312, 1974) and subsequent federal
court rulings, the Tribe's treaty-reserved fishing rights implicitly include the right to protect habitat
and water quality necessary to sustain cultural resources. This plan aims to advance the Tribe's
sovereign responsibility to protect waters that have sustained the Hoh people since time
immemorial.
Identification of pollution sources and BMP’s decisions will coincide with Tribal goals outlined
in the EPA-Tribal Environmental Plan. The Tribe’s goals focus on restoration and protection of
the watershed based on historical data, cultural knowledge, and landowner participation.
Since the Hoh River Watershed (HRW) has various land ownerships and land usages it will be
important to establish strong relationships with local partners and stakeholders. With the guidance
of the Hoh Tribal Business Committee, expert consolation, and extensive research, the Tribe will
implement best management practices (BMP) while leveraging funding, waterway priorities,
infrastructure, landscape, cultural assessments, outcome success, and aquatic life health. Public
participation will be available to gain landowner input and cooperation. The Tribe will establish
communications with stakeholders to ensure cooperative management decisions.
MANAGEMENT PROGRAM DESCRIPTION
BMPs were addressed by categories to form an outline of how to respond to site specific NPS
pollution. Each monitoring site has a unique set of pollutants and conditions that may be
10

contributing to impairment(s). The Hoh Tribe’s water quality monitoring program first determined
impairments through historical monitoring. Next, pollutant sources were attributed to NPS
categories that could potentially be influencing waterways (Table 2). This determination aided in
addressing severity and source category impacts of our monitoring locations (Table 3). To assign
severity and category applications at each monitoring location was assessed for:
1.
2.
3.
4.
5.
6.
7.

Impairments (historical water quality data)
Frequency of impairment
Land use
Road/highway proximity
Fish passage barriers presence
Invasive species mapping
Gravel mining activity

Since the water quality monitoring data can only provide input on impairment status (pollutants),
other knowledge regarding land use is a major factor in determining sources categories.
Based on our assessment of category impacts on specific monitoring sites, management activities
were selected to alleviate pollutant issues in each category. The following management activities
are considerations the Tribe could implement to resolve NPS pollutants.
Nonpoint Source Pollution Categories
There are six major categories of nonpoint source pollution contributing to water quality
degradation throughout the Hoh River Watershed, with forestry and logging roads representing
the dominant source. These pollution categories, characterized through synthesis of
monitoring data, field reconnaissance, and geospatial analysis, create multiple pathways for
pollutant delivery that vary in magnitude, timing, and spatial distribution. Understanding the
specific mechanisms by which each category degrades water quality provides the foundation
for selecting appropriate best management practices targeted to address identified sources.
1. Forestry and Logging Roads
Forest management activities and associated road networks constitute the most widespread
and impactful nonpoint source pollution category in the watershed, with commercial timber
harvest occurring throughout state and private lands that comprise approximately 45% of the
total watershed area (Assessment Report 2025). The combination of timber harvest, road
construction and maintenance, and log transport creates multiple pathways for sediment
delivery, thermal pollution, and hydrologic alteration that directly contribute to the
temperature impairments and increased turbidity affecting fish habitats.
Approximately 70% of the watershed area represents designated forest land available for timber
harvesting. These extensive timber harvest operations can be observed with clearcuts of varying
11

ages along the Hoh Mainline Road and Oil City Road that create a moving mosaic of thermal
source areas as harvest units progress through rotation cycles. The watershed's extensive forest
road network, with documented stream crossings requiring assessment for fish passage and
sediment delivery, generates an estimated 50-300 tons/mile/year of sediment from unpaved
surfaces (Assessment Report 2025).
Industrial private forestlands typically operate on 35-45 year rotations compared to 60-80 year
rotations on state lands, creating temporal and spatial variability in disturbance patterns. Current
Washington Forest Practices Rules require riparian buffers ranging from 90 to 200 feet, yet field
reconnaissance documenting numerous locations where harvest units approach or violate standard
buffer requirements, particularly from pre-1999 harvests when only 25-foot buffers were required.
These historical buffer violations continue affecting stream temperature decades after harvest, as
regenerating vegetation has not yet achieved the height and density necessary to provide adequate
shade (Assessment Report 2025). Even in areas that abide by more stringent buffer practices,
clearcuts and landscape alterations can disturb streams through cascading impairment effects,
influencing dissolved oxygen or pH in the process.
The comprehensive assessment of water quality conditions and pollution sources throughout
the Hoh River Watershed reveals a system under severe stress, with 52.4 river miles (65.4%)
failing to meet standards while forestry and logging roads affect approximately 70% of the
watershed area (Assessment Report 2025). The convergence of persistent temperature
impairments on eleven tributaries since 1996, chronic dissolved oxygen violations, and severe
acidification eliminating entire stream reaches from the habitat network demonstrates that
current management approaches have proven insufficient for achieving recovery.
The following chapter establishes the framework for selecting and prioritizing best management
practices that address identified pollution sources while building on existing high-quality waters,
recognizing that strategic investment in protection and restoration must be scaled to available
resources and focused where the Tribe maintains greatest management authority.
a. Riparian Forest Buffer Restoration (NRCS Practice Standard 391)

Riparian forest buffers represent the primary mechanism for reducing stream temperatures through
direct shade provision, with effectiveness dependent on buffer width, vegetation height, channel
orientation, and topographic shading. Riparian Forest Buffer Restoration provides technical
specifications for establishing woody vegetation adjacent to waterbodies, though site-specific
design must account for the unique characteristics of Olympic Peninsula streams. Recent peerreviewed research demonstrates that riparian buffers can achieve temperature reductions of 1-3°C
under current conditions, with effectiveness varying by stream size, aspect, and existing canopy
gaps (Fuller et al. 2022, Journal of Water and Change).
The Washington Forest Practices Board Manual establishes baseline requirements through WAC
222-30-021, mandating 90-foot no-harvest buffers on Type F (fish-bearing) waters for sites within
12

the timber harvest land base. However, research by Yonce et al. (2021) indicates that while 54meter (177-foot) buffers effectively mitigate timber harvest impacts through the 2050s, projections
suggest wider buffers will be necessary to maintain temperature standards into the 2080s. This
temporal dimension requires adaptive management approaches that anticipate future conditions
rather than simply addressing current impairments.
Field reconnaissance documented variable riparian conditions throughout the watershed, from
completely denuded reaches to areas with intact but inadequate buffers. At Winfield Creek, despite
existing riparian vegetation, extensive orange and green algae growth indicated severe temperature
stress correlating with the stream's 303(d) listing (Field Reconnaissance, August 2025). Anderson
Creek presented a more complex scenario, with thorough shading from large trees and shrubs
providing minimal direct sunlight penetration to the 3-5 foot wide flow, yet temperature
impairment persists due to a large clearcut immediately uphill to the west, suggesting subsurface
thermal loading and reduced humidity affecting stream temperature (Field Reconnaissance,
August 2025).
Buffer restoration effectiveness depends critically on vegetation composition and structure. Native
coniferous species including Thuja plicata (Western Red Cedar), Pseudotsuga menziesii (Douglas
Fir), and Tsuga heterophylla (Western Hemlock) provide superior shade density compared to
deciduous species, though Alnus rubra (Red Alder) offers rapid early growth and nitrogen fixation
benefits. Mixed species plantings that mimic natural succession patterns demonstrate greater
resilience to disturbance and disease while providing diverse ecological functions beyond
temperature regulation.
Temperature reduction through riparian shade restoration provides the primary mechanism for
DO improvement, as cooler water holds more dissolved oxygen while reducing metabolic oxygen
demand. Research by Ghimire & Johnston (2021) documented that urban riparian buffer zones
raised DO concentrations by 4-10% across three watersheds, with effectiveness
correlating directly with temperature reduction achieved. The temperature management
practices described earlier therefore serve dual purposes, addressing both thermal stress and
oxygen depletion simultaneously.
Watershed management addressing acid sources provides longer-term solutions though with
extended response times. Forest harvest prescriptions that retain canopy cover reduce acid
leaching from exposed soils, particularly in areas with naturally acidic parent material.
Selective harvest maintaining 50-70% canopy retention demonstrates reduced acidification
compared to clearcuts. Extended rotations allowing soil recovery between entries reduce
cumulative acidification. Protection of headwater areas with high acid-neutralizing capacity
preserves watershed buffering.
b. Tree and Shrub Establishment (NRCS Practice Standard 612)

Complementing riparian buffer restoration, Practice Standard 612 addresses temperature
impacts from upland harvest units and degraded areas beyond the immediate riparian zone.
13

This practice proves particularly relevant given field observations of extensive clearcuts at
various successional stages throughout the watershed, ranging from fresh cuts less than one
year old to maturing second growth exceeding fifteen years (Field Reconnaissance, August
2025). Strategic reforestation of critical areas can reduce landscape-level heating that
contributes to stream temperature through advective heat transfer and reduced humidity.
The effectiveness of tree and shrub establishment varies significantly with site conditions and
implementation methods. Survival rates in the challenging Olympic Peninsula environment
with extreme winter precipitation, summer drought stress, and intensive herbivory from
Roosevelt elk require careful species selection and establishment techniques. Protection
measures including browse barriers, competition control, and strategic placement within
protective microsites improve establishment success.
Native plant distribution programs expand the Jefferson County Conservation District's
successful annual sales to include comprehensive restoration support services. Species
selection emphasizes locally-sourced materials adapted to Olympic Peninsula conditions
including high rainfall, acidic soils, and browsing pressure from Roosevelt elk.
c. Wetland Development or Restoration (NRCS Practice Standard 657)

Wetland restoration offers natural treatment capacity for organic matter processing that
reduces biochemical oxygen demand. Properly functioning wetlands provide extended
residence time for organic matter decomposition, nutrient uptake by wetland vegetation, and
natural reaeration through plant oxygen transport. Logging and timber harvesting practices disrupt
soil, water, and vegetation development. Wetland development or preservation is key to the protection
of waterways from nutrient pollution and restoring natural mechanisms. Wetland restoration requires
careful design to avoid creating additional oxygen demand through excessive organic
accumulation. Site selection favoring degraded wetlands with restoration potential rather than
new construction minimizes disturbance while maximizing treatment benefits.
Wetlands mapping within the Hoh River watershed is underway but approaches to support
this vital proponent of waterway pollution filtration system are important to include in this
management plan. It is important to create an official wetland inventory to prevent
development on sensitive habitats and to avoid construction in areas that will likely flood
again. Long-term efforts will aim to use wetlands to address acidification and dissolved
oxygen impairments.
d. Large Woody Debris Removal

Cedar spaults, or waste cedar pieces left over from timber harvesting, may be leaching watersoluble tannins, which are natural acids, into the creeks. When cedar spaults are in the wetted
channel, the water can become acidified from the tannins. In some stretches of the creek, spaults
were so tightly packed that flow was reduced to a trickle. Hell Roaring and Braden were identified
as creeks most affected by cedar spaults in the early 2000’s. Despite the work to remove spaults
14

completed in 1999 and 2000, cedar spaults likely remain within the riparian zone and channel of
many creeks in the watershed. Large woody debris like cedar spault removal projects would
improve acidification of streams, overall appearance, and open fish habitat in streams.
e. Nutrient Management in Non-Agricultural Settings

While the Hoh watershed lacks intensive agriculture, the extensive algae growth observed at
multiple monitoring sites indicates nutrient enrichment requiring management intervention.
Residential fertilizers, septic systems, and natural sources including nitrogen-fixing Red Alder
and wetland drainage contribute nutrients that stimulate algae growth and subsequent oxygen
depletion.
NRCS Practice Standard 590, though traditionally agricultural, provides applicable principles
for residential and forest settings. Soil testing to determine existing nutrient levels prevents
over-application, timing restrictions avoid application before storm events, and buffer zones
prevent direct nutrient delivery to streams. Riparian buffer enhancement specifically targeting
nutrient interception requires wider buffers and specific vegetation selection compared to
temperature-focused restoration. EPA meta-analysis indicates buffers exceeding 50 meters
achieve 89.6% nitrogen removal efficiency, substantially higher than the 30-50% achieved by
narrow buffers (EPA 2022). Vegetation selection emphasizing high nutrient uptake species in
addition to shading effectiveness maximizes water quality benefits.
2. Hydromodification and Bank Erosion
Channel alterations, infrastructure encroachment, and flow regime changes from create chronic
sources of sediment while destroying critical habitat complexity necessary for salmonid
production. Natural baseline erosion rates are projected to increase through intensified storm
events and altered hydrology. However, accelerated erosion from riparian clearing and channel
modifications cause increases above these natural rates, delivering excessive sediment that fills
pools, embeds spawning gravels, increases stream temperatures, and reduces channel capacity.
Further effects of erosion from bank alteration include dissolved oxygen, pH, and nutrient
detriments from riparian buffer loss.
Specific hydromodification impacts identified include road embankments constraining channel
migration and concentrating erosive forces, timber harvests encroaching on riparian zones and
removing stabilizing vegetation, historical channel straightening that increase stream power and
bank stress, bridge abutments and riprap creating scour pools and deflecting flows into opposite
banks, and undersized culverts or dams channeling sediment and changing stream hydrology.
Projects that support engineered log jams (ELJ) or traditional log jams, large woody debris or rock
structures serve as fish habitat, improve streamflow complexity, and provide areas for sediment
transport or disposition (Martens and Devine 2025). The cumulative effect of these modification
simplifies channel morphology, reduces floodplain connectivity, and eliminates off-channel
refugia critical for juvenile salmonid rearing (Assessment Report 2025).
15

a. Stream Habitat Improvement and Management (NRCS Practice Standard 395)

Temperature reduction through channel modification represents an underutilized but highly
effective approach, particularly when combined with riparian restoration. Research by Poff et
al. (2022) demonstrated that channel narrowing combined with riparian restoration could
achieve temperature reductions up to 6.5°C in Oregon streams, potentially offsetting projected
impacts through the 2080s. This practice addresses the widened, shallow channels observed
at multiple monitoring locations where field crews documented dramatic width-to-flow ratios,
such as Winfield Creek with only 5-8 feet of flow in a 30-40 foot channel (Field
Reconnaissance, August 2025).
Channel modifications that reduce surface area exposure while increasing depth and velocity
provide immediate temperature benefits while restored riparian vegetation develops.
Techniques include large wood placement to create scour pools and channel complexity,
construction of channel-spanning structures to concentrate flow, removal of legacy sediment
deposits that create channel widening, and restoration of natural meander patterns in
straightened reaches. These modifications must account for fish passage requirements and
avoid creating velocity barriers while achieving temperature objectives.
Channel and flow restoration addressing the underlying morphological changes that reduce
reaeration capacity provides long-term DO improvement. Field observations documented
multiple sites where channel widening, pool formation, and flow stagnation create conditions
promoting oxygen depletion. Strategic channel modifications that increase turbulence and
atmospheric exchange while maintaining fish passage can improve oxygen dynamics.
However, these modifications must avoid creating velocity barriers or excessive energy
dissipation that could increase temperature.
b. Stream Crossing Improvements (NRCS Practice Standard 578)

The numerous stream crossings throughout the Hoh River Watershed create localized but
cumulatively significant temperature impacts. Undersized culverts create shallow, exposed
impoundments upstream while producing turbulent, aerated flow downstream that increases
surface heat exchange. Replacing culverts with bridges or bottomless arch structures eliminates
these thermal impacts while providing multiple co-benefits including restored fish passage and
reduced sediment delivery.
Research by Morris et al. (2015) documented that bridges produce 86% less sediment than culverts
while eliminating thermal barriers, making crossing improvements a high-priority practice
addressing multiple impairments simultaneously. Field observations at Oil City Road documented
an old corrugated metal culvert creating ponded water upstream, while observations at Anderson
and Maple Creeks noted single-lane bridges that, despite their age, maintained natural channel
dimensions and thermal regimes (Field Reconnaissance, 2025).

16

c. Stream Crossing Rehabilitation (NRCS Practice Standard 578)

Stream crossings represent critical sediment delivery points where road runoff directly enters
aquatic habitats. The HRW contains numerous crossings while precise numbers remain
unquantified, the regional context from Jefferson County's 2000 inventory documenting 246
fish-bearing crossings county-wide indicates the potential scale of crossing-related impacts.
Field reconnaissance confirmed problematic conditions at multiple crossings, from failing
culverts with active erosion to aging bridges lacking adequate runoff treatment.
NRCS Standard 578 addresses crossing-related sediment through proper sizing, inlet
protection, and outlet stabilization. Recent research by Morris et al. (2015) quantified
sediment production by crossing type, finding bridges produce the lowest sediment (0.2 g/L
TSS), fords intermediate levels (1.4 g/L), and culverts highest (2.9 g/L). This order-ofmagnitude difference in sediment generation makes crossing upgrades particularly costeffective for water quality improvement.
Infrastructure sizing must accommodate increased peak flows to prevent catastrophic failure
during extreme events. Current design standards based on historical precipitation records
systematically underestimate future flows, as demonstrated by recent failures requiring
emergency repairs throughout the watershed. This reality requires oversizing infrastructure
above current standards and designing for easier modification as projections evolve.
The mechanisms driving crossing-related erosion extend beyond the structure itself to include
approach fills, drainage, and channel impacts. Undersized culverts cause upstream
aggradation and downstream scour, mobilizing stored sediment during high flows. Perched
outlets create plunge pools and headcutting that can extend hundreds of feet downstream.
Inadequate inlet protection allows road fill erosion during overtopping events. Approach roads
without adequate drainage concentrate flow at crossing locations. These cumulative impacts
create sediment plumes extending far downstream of the actual crossing.
Field observations documented these impacts directly, particularly at the Oil City Road
unnamed stream crossing where an old corrugated metal culvert with failing riprap had created
both sediment accumulation and partial fish barriers (Field Reconnaissance, 2025). The riprap,
intended for erosion protection, had fallen into the stream channel, creating additional
hydraulic disruption and sediment mobilization. This exemplifies how aging infrastructure not
only fails to provide intended functions but creates new erosion sources through altered
channel dynamics.
Crossing improvements must address both immediate sediment reduction and long-term
resilience. Design standards incorporating 15-25% increases in peak flows prevent future
failures while maintaining sediment control functions. Stream simulation designs that
maintain natural channel dimensions through the crossing reduce both sediment generation
and maintenance requirements. Removal of unnecessary crossings through road
decommissioning eliminates sediment sources permanently while reducing long-term
17

maintenance obligations.
d. Streambank and Shoreline Protection (NRCS Practice Standard 580)

Bank erosion contributes episodic but significant sediment pulses during high-flow events, with
field reconnaissance documenting active erosion at multiple locations including Canyon
Creek's clay deposits requiring riprap and netting installations (Field Reconnaissance,
August 2025). NRCS Standard 580 provides bioengineering techniques that combine
structural stability with ecological function, achieving reduction in bank erosion when
properly designed and maintained.
However, recent research using unmanned aerial system (UAS) monitoring reveals important
caveats about long-term effectiveness. A 2022 study published in Geomorphology found that
while bank stabilization projects reduce local erosion initially, continued erosion above toe
protection can cause benefits to diminish over time. This finding emphasizes the need for
comprehensive approaches addressing entire erosion zones rather than just active failure
points.
Bank erosion in the HRW results from both natural processes and human modifications that
require different management approaches. Natural meander migration in alluvial reaches
represents important channel evolution that creates habitat diversity. However, accelerated
erosion from land use impacts generates excessive sediment exceeding the stream's transport
capacity. Distinguishing between these erosion types ensures that stabilization efforts focus
on anthropogenic impacts while allowing natural channel dynamics where appropriate.
Bioengineering techniques appropriate for Olympic Peninsula conditions include vegetated
reinforced soil slopes using native species adapted to high precipitation, large wood or boulder
structures that deflect flow while creating habitat complexity, engineered log jams (ELJ) or
rip rap, that reduce near-bank velocity while maintaining channel capacity, and brush layering
that provides immediate protection while vegetation establishes. These living systems
demonstrate superior long-term performance compared to hard armoring while providing
ecosystem benefits beyond erosion control.
e. Road Decommissioning

Complete removal of unnecessary roads provides the most permanent and effective sediment
reduction, eliminating sources rather than treating symptoms. Research by Clingenpeel et al.
(2017) documented remarkable effectiveness, with median sediment production dropping to
zero kg/m² in the first two years post-decommissioning and road-stream connectivity
declining from 12% to 2%. This near-complete elimination of sediment delivery makes
decommissioning highly cost-effective despite higher initial costs compared to maintenance.
The Hoh watershed's evolved transportation needs create opportunities for strategic
decommissioning. Many roads constructed for timber harvest access no longer serve active
18

management given changed harvest patterns and improved equipment capabilities.
Redundant roads providing multiple routes to the same areas can be consolidated. Spur
roads accessing previously harvested units with no planned re-entry can be removed. Highrisk roads in unstable terrain where maintenance costs exceed access benefits become
decommissioning priorities.
Effective decommissioning requires more than simply abandoning roads. Full recontouring to
restore natural drainage patterns prevents gully formation, while decompaction of road surfaces
enables revegetation. Removal of stream crossing structures and associated fills eliminates
chronic sediment sources. Placement of physical barriers prevents unauthorized vehicle access
that could re-establish disturbance. These comprehensive treatments ensure permanent
restoration rather than temporary abandonment that continues generating sediment.
3. Invasive Species
Clearcutting and harvesting presents opportunities for invasive species to grow in place of native
species affecting soil composition, wildlife habitat availability, erosion, and hydrography (10,000
Years Institute, n.d.). Scotch broom (Cytisus scoparius), Spotted jewelweed (Impatiens capensis),
Reed canarygrass (Phalaris arundinacea), knotweeds, Canada thistle (Cirsium arvense), and
Everlasting peavine (Lathyrus latifolia) are invasives currently reported in the Hoh River
Watershed. Invasive growth and reproduction in areas where clearcutting occurs contributes to
monocultures where native species that provide food, habitat, timber, and other forest products are
outperformed. Scotch broom, found in gravel bars, forest harvest sites, along roads, reduce the
amount of shade availability for streams and soils, deplete water resources for native species, and
replace native riparian species that are crucial to regulating rain contributions that influence soil
development. Invasive species alter organic matter contributions in soils, which may have
detrimental effects on nutrient impacts in water quality.
Invasive removal programs clear room in riparian buffer zones for native plant species to thrive
while removing plants that are detrimental to the landscape. Services will not only target certain
invasives like Scotch broom or Knotweed but will focus on long-term effectiveness using chemical
applications to avoid future invasives from reappearing. Technical staff with extensive invasive
removal experience can provide landowners with expertise to develop an understanding of their
contributions to landowner property and watershed quality. Additionally, maintenance of this
project will be necessary given the nature of many invasive long term seed viability. Short term
goals include increasing invasive mapping tools and establishing prominent areas of interest and
removing invasive species from riparian buffer zones. Long-term goals include expansive mapping
tools, permeant removal techniques, maintenance of previously treated areas, and collaboration
with experts to ensure success.
4. Roads, Highways, and Bridges
Despite comprising only 3.90% of the watershed area, developed lands create concentrated
19

pollution loads that significantly impact receiving waters, particularly along the Upper Hoh
Road corridor (Assessment Report 2025). There is an abundant absence of stormwater
management infrastructure at major discharge points, like Nolan Creek Bridge or Hoh Hill
Bridge along Highway 101 where traffic and road stormwater flow directly into the river or
stream without any detention. These concentrated sources are particularly problematic during
first-flush storm events when accumulated pollutants, like sediment or toxic chemicals, wash
directly into streams without dilution or treatment.
a. Access Road Improvements (NRCS Practice Standard 560)

Forest roads represent the dominant chronic sediment source throughout approximately 70% of
the watershed affected by commercial timber management (Assessment Report 2025). NRCS
Standard 560 provides technical specifications for road surfacing, drainage, and location to
minimize erosion while maintaining access for management activities. Published
effectiveness studies from the Eastern United States demonstrate that comprehensive road
BMPs achieve 53-94% sediment reduction when properly implemented, with effectiveness
varying by rainfall intensity, soil type, and maintenance frequency (Hawks et al. 2022).
The persistent sediment generation from forest roads results from multiple interacting
mechanisms that compound across the extensive network. Surface erosion from native soil
and poorly maintained gravel surfaces generates fine sediment. Inadequate drainage
concentrates flow, creating gullies and cutslope failures during intense precipitation events.
Ditch lines efficiently route sediment-laden runoff directly to streams at crossing locations,
bypassing natural filtration. Inside ditches intercept subsurface flow, converting it to erosive
surface runoff that exceeds the transport capacity of drainage structures.
Road improvement effectiveness depends critically on addressing all erosion pathways rather
than single components. Surface treatments including chemical stabilization or pavement
installation provide immediate reductions in surface erosion but require proper drainage to
prevent failure. Cross-drain installation at intervals based on road grade and contributing area
prevents flow concentration while maintaining road stability. Ditch armoring with rock or
vegetation reduces erosion while maintaining conveyance capacity. Sediment traps at strategic
locations capture mobilized material before stream delivery. These integrated approaches
demonstrate superior performance compared to single-practice implementation.
Strategic targeting maximizes cost-effectiveness given limited restoration funding. Research
from the U.S. Forest Service using the Geomorphic Roads Analysis and Inventory Package
(GRAIP) methodology reveals that less than 10% of road networks typically deliver 90% of
fine sediment, enabling prioritized treatment of high-risk segments (USFS 2023). Factors
identifying priority segments include proximity to streams, particularly direct connections
through ditches or gullies; steep grades exceeding 10% that generate erosive velocities;
erodible soils, especially marine sediments and glacial deposits; and high traffic during wet
seasons that prevents surface armoring development.
20

b. Toxic Chemical Monitoring

Tire anti-degradant, 6PPD, is a compound capable of reacting with ozone to create a toxic chemical
called 6PPD-quinone. Roads and highways are hot spots during rain events for the chemical to
leach into rivers/streams through road crossings, bridges, or culverts. The contaminant has lethal
effects on aquatic species at low concentrations, particularly for culturally significant species like
salmonids (Tian et al. 2021). Intervention through restoration or green infrastructure modifications
are necessary to prevent road runoff from polluting streams.
Monitoring for 6-PPD in the watershed has been minimal. Programs with the Department of
Ecology and Northwest Indian Fisheries Commission have been established to help identify and
monitor areas that may be at risk. This management plan will aim to establish further monitoring
for this pollutant to determine if further BMPs are needed.
5. Natural Resource Extraction
Sand and gravel mining within the watershed delivers sediment to streams, destabilizes
streambanks, and expedites erosion. Active permits include the St. Regis Gravel Pit located near
Winfield Creek and an unnamed tributary, the Winfield Surface Mine near Winfield and Elk Creek,
and the Seton Construction Canyon Creek Quarry near Canyon Creek. Legacy effects from
previous aggregate mining activities may still be contributing to water quality issues.
Transportation of these resources spreads pollutants beyond the original site, dispersing sediment
along roadways and crossings. Small gravel pits have been observed throughout the watershed
near major and minor tributaries like Tower Creek and along Oil City Road.
Management practices to address erosion and sediment delivery loads due to natural resource
extraction include establishing stormwater mitigation systems to direct sediment away from
streams. Sediment catch basins or terraces and tree/shrub establishment are reliable preventative
and restoration efforts to prevent road run off and debris from entering streams. Additionally,
establishment of riprap, engineered log jams reduce the effects of this category on streambank
erosion. The management plan will also prioritize prevention and protection of sensitive areas
susceptible gravel mining.
6. Atmospheric Deposition
Atmospheric deposition from vehicle exhausts, coal burning, or hazardous material combustion
enter waterbodies through rainfall or runoff. These emissions are responsible for mercury or
nitrogen concentration elevations either through airborne or fallout particulate dispersal. Because
the watershed receives large volumes of vehicle traffic, particularly along Highway 101 to access
ONP and through extensive logging road networks, vehicle emissions can reach waterbodies
through proximity, not just aerial dispersal. High mercury concentrations have already been
detected in snow and fish in the Olympics (Eagles-Smith et al. 2014). Waterbodies are directly
affected through direct runoff; however, particulates also get distributed to soil through lichen
absorption or forest debris (Maynes 2008). This insinuates long-term adsorption from soil, even if
roads are no longer in use. Elevated mercury is a hazard to fish and human health.
21

Table 1. Summary of NPS management plan for each pollutant category.
NPS

Forestry and
Logging Roads

Impacts
• Generates pathways for sediment delivery
• Creates thermal source pollution
• Hydrologic alterations
• Influences soil development
• Disturbs riparian buffers
• Opens opportunities for invasive species

• Causes infrastructure encroachment
• Increases streamflow
• Alters channel migration
• Impacts habitat complexity
• Delivers excessive sediment
• Increases soil and stream temperature
• Increase bank stress
• Removes stabilizing vegetation
Hydromodification
and Bank Erosion • Provides opportunity for invasive species
• Alter soil nutrient profiles
• Creates scour pools
• Deflects flow

Management Activities
• Riparian buffer restoration
• Tree and shrub establishment
• Wetland protection, development, or restoration
• Cedar spault/Large woody debris removal
• Nutrient management
• Large woody debris placement
• Advocate for watershed-based protections
• Support research that aids in reducing impairments through pollution
sources
• Channel and flow modifications
• Large wood placement
• Sediment removal
• Restoration of natural hydrology
• Protection from sediment sources
• Restore habitats and riparian buffer zones
• Stream crossing improvements
• Culvert restoration/replacement
• Bridge modifications
• Stream crossing rehabilitation
• Streambank and shoreline protection
• Road decommissioning
• Stabilize eroding streambanks
• Preserve natural streambank and water quality conditions
• Monitor effects of restoration over time in relation to water quality
impairments
• Commit to research opportunities that support pollution reductions

22

Table 1. Summary of NPS management plan for each pollutant category.
NPS

Invasive Species

Impacts

Management Activities

• Replaces stabilizing vegetation in riparian buffer
zone
• Contribute to erosion and sediment delivery
• Reduces shade
• Increases soil, water, and air temperature
• Replaces organic matter contribution
• Decreases water availability
• Alters sediment transport
• Introduces allelopathic chemicals
• Changes nutrient profiles
• Eliminates biodiversity
• Delivers toxic chemicals to streams
• Introduces sediment pathways
• Uncontrolled stormwater flows
• Contributes to increased erosion
• Alters hydrology

•
•
•
•
•
•

Develop mapping of invasive species throughout the watershed
Restore native species
Remove invasive species near riparian buffer zones
Engage in research opportunities that focus on effects of invasives
Collaborate with experts to impose strategies for prevention and removal
Support maintenance of invasive removal

•
•
•
•
•
•
•

Improve access roads
Chemical stabilization
Pavement installations
Cross drain installation
Ditch armoring
Sedimentation traps
Gather information regarding emerging toxic chemicals like 6-PPDq or
PFAS
Tree and shrub establishment to reduce erosion and sediment delivery
Communicate with entities responsible for roads to promote management
measures
Streambank and shoreline protection
Establish stormwater mitigation systems
Establish stormwater mitigation systems
Tree and shrub establishment
Support sediment catch basins or terraces
Protect at-risk waterways
Preservation of hydrologic conditions and streambanks
Rip-rap, dolos, and log jam establishment to mitigate erosion cause by
mining
Stabilize stream channels

Roads, Highways,
and Bridges

•
•

• Creates sediment delivery pathways
• Erodes streambanks
• Destabilizes banks
Natural Resource
Extraction

•
•
•
•
•
•
•
•
•

23

Table 1. Summary of NPS management plan for each pollutant category.
NPS
Atmospheric
Deposition

• Impacts
• Contaminates stream with hazardous material
through rainfall or runoff
• Adsorption through soil or water

•
•
•
•
•

Management Activities
Construct catch basins
Establish vegetation on streambanks to buffer rainfall
Mitigation systems to prevent runoff onto stream
Conduct research to establish presence and identification of pollutants

Table 2. NPS categories and their potential pollutant impacts.

Forestry and Logging Roads
Roads, Highways, & Bridges
Hydromodification and Bank Erosion
Atmospheric Deposition
Natural Resource Extraction
Invasive Species

Temperature
x
x
x
x
x

Dissolved Oxygen
x
x
x
x
x

pH
x
x
x
x

Turbidity
x
x
x

Toxic Chemicals
x
x
x
x

x
x

24

Table 3. NPS categories and impairments based on monitoring sites.

25

Implementation
Implementation establishes the programmatic framework through which best management
practices will be deployed across the watershed's complex ownership landscape to achieve
water quality objectives. The implementation approach recognizes that with the Tribe
controlling less than 1% of the watershed, success depends on voluntary participation from
state and private landowners who manage the lands where most impairments originate.
The framework therefore emphasizes collaborative partnerships, technical assistance delivery,
and incentive programs that align landowner interests with water quality protection. Through
coordinated implementation leveraging multiple funding sources and partner organizations,
the Tribe will transform limited resources into comprehensive watershed restoration capacity.
Technical Assistance Delivery
Technical assistance represents the critical bridge between landowner willingness and
successful BMP implementation, transforming conservation interest into properly designed
and installed practices that achieve water quality objectives. The framework establishes
delivery mechanisms that provide expert guidance throughout the project lifecycle from initial
assessment through long-term maintenance. This comprehensive support ensures that BMPs
are appropriately matched to site conditions, correctly installed, and maintained for sustained
effectiveness.
Site Assessment Process
Initial landowner contact establishes the foundation for successful technical assistance
delivery through relationship building and trust development. Tribal staff or partner
organization representatives conduct preliminary conversations to understand landowner
objectives, concerns, and constraints. These early interactions determine whether properties
merit detailed assessment and identify potential barriers to implementation. Building rapport
during initial contact proves essential for long-term cooperation.
Property evaluation for BMP suitability requires systematic assessment of physical,
ecological, and management factors. Technical staff conduct field visits documenting soil
types, slope conditions, existing vegetation, and hydrologic features that influence practice
selection. Stream proximity, wetland presence, and critical habitat areas receive particular
attention given their regulatory implications. Management objectives include timber harvest
plans, livestock operations, or residential uses shape recommendations to ensure
compatibility.
The assessment process incorporates both contemporary scientific methods and traditional
ecological knowledge. GPS mapping and GIS analysis provide quantitative data on drainage
areas, buffer widths, and sediment delivery pathways. Conversations with tribal elders
26

familiar with historical conditions offer insights into seasonal flow patterns, fish usage, and
vegetation changes over decades. This dual approach strengthens assessment accuracy while
honoring indigenous knowledge systems.
Custom conservation planning develops site-specific recommendations tailored to each
property's unique conditions and landowner objectives. Plans prioritize practices addressing
the most severe resource concerns while considering implementation feasibility. Cost
estimates, funding sources, and implementation timelines help landowners make informed
decisions. Alternative approaches accommodate varying levels of landowner commitment and
financial capacity.
Design and Implementation Support
Access to qualified technical service providers ensures that BMPs meet engineering standards
and regulatory requirements. Engineers licensed in Washington State design stream crossings
and bank stabilization structures. Forestry consultants develop harvest plans incorporating
enhanced riparian buffers. Restoration ecologists specify native plant communities adapted to
site conditions.
Coordination with Conservation District expertise leverages decades of local experience and
established relationships. District staff provide soil testing, erosion assessments, and
agricultural conservation planning at no cost to landowners. Their familiarity with NRCS
practice standards ensures designs qualify for federal cost-share programs. Long-standing
presence in the community builds trust that facilitates project implementation.
Cultural considerations in BMP selection respect tribal values and traditional practices while
achieving water quality goals. Restoration designs incorporate culturally significant plants
like western red cedar and traditional food sources including camas and huckleberry. Access
provisions maintain tribal member gathering rights while protecting restored areas. Project
timing avoids disruption of ceremonial activities and seasonal resource collection.
Design review by tribal natural resources staff ensures projects align with watershed
restoration priorities and treaty resource protection. Technical experts evaluate hydraulic
calculations, planting specifications, and erosion control measures. This review process
maintains quality control while building tribal capacity through exposure to diverse project
designs.
Implementation oversight during construction prevents common installation errors that
compromise BMP effectiveness. Technical staff conduct pre-construction meetings reviewing
critical design elements with contractors. Field visits during installation verify proper
techniques and materials. Immediate correction of problems prevents costly repairs and
ensures practices function as designed. Post-construction inspections document successful
completion for cost-share reimbursement.
27

Monitoring and Adaptive Management
Effectiveness tracking framework establishes protocols for evaluating BMP performance
against water quality objectives. Baseline monitoring before implementation documents
existing conditions including temperature, turbidity, and channel morphology. Postimplementation monitoring at regular intervals tracks changes attributable to restoration
actions. Standardized protocols ensure data compatibility across projects and enable
watershed-scale assessment.
Photo documentation provides visual evidence of project evolution and effectiveness over
time. Established photo points capture seasonal variations and long-term vegetation
establishment. Before-and-after comparisons demonstrate tangible improvements that
motivate continued landowner participation. Time-lapse sequences reveal restoration
trajectories useful for refining future projects.
Technical assistance delivery must evolve with changing environmental conditions and
emerging restoration techniques. Increased storm intensity requires updated sizing criteria for
hydraulic structures. New research on riparian buffer effectiveness informs width
recommendations. Innovative bioengineering techniques offer cost-effective alternatives to
traditional approaches. The framework maintains flexibility to incorporate advances while
retaining proven methods.
Partnership development with regional technical providers expands available expertise
beyond tribal capacity. University extension services provide research-based guidance on
emerging issues. Engineering firms offer specialized design services for complex projects.
Non-profit restoration organizations contribute implementation experience from similar
watersheds. These partnerships ensure landowners access appropriate expertise regardless of
project complexity.
Maintaining healthy populations of fish and wildlife within our Usual & Accustomed Area is of
paramount importance to the Hoh Indian Tribe. The viability of fish and wildlife populations is
dependent on effective management of human activity within the Hoh River watershed to maintain
and improve water quality and habitat for fish and wildlife. Several agencies, organizations, and
timber companies participate in watershed management policy and planning in the Hoh River
watershed and other watersheds within the Hoh Tribe traditional areas, including Olympic
National Park, Olympic National Forest, Washington Department of Natural Resources,
Washington Department of Ecology, Washington Department of Fish & Wildlife, North Pacific
Coast Lead Entity, the Hoh Tribe, and timber companies such as Rayonier and Merrill & Ring.
The Hoh Tribe will participate in watershed management policy and planning to ensure that our
priorities of maintaining excellent water quality and fish and wildlife habitat are represented in
decision-making. We will participate in meetings with other stakeholders, submit written
comments, and participate in development of salmon habitat restoration strategy as a member of
the North Pacific Coast Lead Entity.
28

Education and Outreach Strategy
Education and outreach programs create the foundation for long-term watershed stewardship
by building awareness of water quality issues and motivating voluntary conservation action.
The framework develops targeted messaging for diverse audiences, employing
communication methods appropriate to each group's information preferences and decisionmaking processes. This strategic approach ensures efficient use of limited outreach resources
while maximizing behavior change potential.
Target Audience Identification

Tribal members and reservation residents serve dual roles as both land managers and cultural
stakeholders in water quality protection. Treaty rights education reinforces connections
between watershed health and cultural survival. Youth engagement through school programs
and summer camps builds future conservation leaders. Elder involvement ensures traditional
knowledge informs contemporary restoration approaches while maintaining intergenerational
knowledge transfer.
Outreach Methods

Workshops and field demonstrations provide hands-on learning opportunities that prove
particularly effective for technical topics. Riparian planting workshops teach proper
techniques while participants help install restoration projects. Road maintenance field days
demonstrate drainage improvements and sediment control methods at actual problem sites.
These events build community among conservation-minded landowners while providing peer
learning opportunities. Social aspects including shared meals and informal discussions
strengthen relationships essential for sustained engagement.
Youth education through the Natural Resources Department builds environmental
stewardship ethics in future landowners. School presentations connect classroom science
curricula to local watershed issues. Summer culture camps integrate water quality lessons with
traditional fishing and gathering practices. Student monitoring programs provide hands-on
experience while generating useful data. Career exposure introduces natural resources
professions to tribal youth considering post-secondary education.
Key Messages Framework

Treaty rights protection provides the fundamental driver and ultimate measure of success for
this implementation framework. The Tribe's ability to exercise fishing rights guaranteed under
the Treaty of Olympia depends entirely on maintaining water quality sufficient to support
harvestable salmon populations. The persistence of temperature impairments since 1996,
chronic dissolved oxygen violations threatening the Tribe's steelhead hatchery operations, and
severe acidification eliminating entire stream reaches from the functional habitat network
demonstrates that current management approaches have failed to protect treaty resources
(Assessment Report 2025). This framework therefore represents not merely an environmental
29

program but a critical component of tribal sovereignty, cultural preservation, and economic
sustainability that cannot be deferred while impairments continue degrading treaty resources.
Treaty rights and cultural values create unique messaging opportunities that distinguish tribal
programs from other conservation efforts. The connection between water quality and salmon
survival directly links to treaty-protected fishing rights. Traditional ecological knowledge
demonstrates millennia of successful watershed stewardship. Cultural responsibility for
protecting resources for seven generations ahead resonates with both tribal and non-tribal
audiences.
Resilience through restoration addresses growing concerns about extreme weather impacts.
Enhanced riparian buffers moderate stream temperatures during heat waves while reducing
flood velocities. Improved road drainage prevents washouts during intense storms. Healthy
watersheds maintain base flows during droughts. Forward-thinking landowners appreciate
preparing for future conditions rather than reacting to crisis.
Building on Existing Communication Channels

Annual General Council meetings provide forums for discussing water quality concerns.
Cultural events including First Salmon ceremonies offer opportunities for conservation
messaging. These existing channels reduce costs while reaching engaged audiences.
Partnership communications multiply message reach through partner organizations'
networks. Conservation District newsletters reach rural landowners throughout Jefferson County.
NRCS field offices display educational materials reaching agricultural producers. North
Pacific Coast Lead Entity meetings connect with salmon recovery stakeholders.
Coordinated messaging ensures consistency while expanding audience reach.
Annual meetings with Washington department of Natural Resources and Department of
transportation inform the Tribe of projects within the watershed. It allows the Tribe to
provide feedback and inquire about projects that may affect the watershed of nearby areas.
Continuous improvement incorporates feedback and changing communication preferences.
Communication with participating restoration entities helps identify successful strategies
worth expanding and ineffective approaches requiring modification. Emerging technologies
offer new engagement opportunities requiring framework adaptation. Demographic shifts in
land ownership necessitate evolving outreach strategies. The framework maintains flexibility
while retaining proven methods that effectively motivate conservation action.
Implementation Schedule Overview
This chapter establishes the phased implementation schedule for nonpoint source management
activities over the initial five-year program period. The schedule provides a framework for
systematic deployment of best management. The timeline balances ambitious restoration
goals with realistic assessment of tribal capacity, landowner readiness, and funding
30

availability while maintaining flexibility for adaptive management based on monitoring
results and emerging opportunities.
The implementation schedule employs an approach that builds systematically from
foundation-setting activities through demonstration projects to watershed-scale restoration. It
recognizes that lasting water quality improvement requires more than technical solutions; it
demands trust-building with landowners, capacity development within partner organizations,
and documented success that encourages broader participation.
The Tribe's experience with the successful centralized wastewater treatment installation
demonstrates that complex environmental improvements require years of planning,
relationship development, and incremental progress before achieving transformational
outcomes. The schedule therefore emphasizes early investment in partnerships and
demonstration projects that create the foundation for accelerated implementation in later
years.
The schedule cannot mandate specific project locations or guarantee participation rates but
instead establishes general activity categories and capacity targets. This approach provides
EPA with reasonable assurance of progress while preserving the Tribe's flexibility to pursue
opportunities as they emerge rather than adhering to rigid timelines that ignore local realities.
Adaptive management principles embedded throughout the schedule ensure that
implementation strategies evolve based on effectiveness monitoring and practical experience.
Annual evaluation of BMP performance, particularly for temperature reduction of impaired
streams, will inform adjustments to technical approaches and priority areas. The schedule
incorporates specific review points where monitoring data and resource availability trigger
reassessment of implementation strategies. This iterative approach prevents continued
investment in ineffective practices while allowing successful approaches to expand more
rapidly than initially projected.
The implementation timeline directly connects to the Tribe's established monitoring programs
that will track both project outputs and environmental outcomes. Implementation milestones
include both activity metrics such as miles of riparian buffers installed and outcome indicators
including temperature reduction and dissolved oxygen improvement. This dual tracking
system enables the Tribe to demonstrate progress toward EPA grant requirements while
assessing actual environmental benefits that determine long-term program success.
Funding availability fundamentally shapes the pace and scale of implementation activities
throughout the five-year period. The confirmed FY2026 EPA funding provides initial
implementation resources. The framework recognizes that major implementation phases may
need adjustment based on competitive grant success, federal appropriation levels, and state
funding availability. However, the voluntary implementation approach's emphasis on
technical assistance and education ensures continued progress even during periods of
constrained implementation funding.
31

General Program Timeline
Short-term Goals: Foundation Building
The initial two years of implementation focus on establishing the organizational
infrastructure, partnership frameworks, and demonstration projects essential for long-term
program success. Year 1 priorities emphasize planning and relationship development that
create the foundation for on-ground implementation, while Year 2 transitions toward active
restoration with early adopter landowners. A watershed-based approach requires collaboration
among multiple landowners, the county road department, DNR for forest roads, and
potentially Federal Highways for Highway 101 crossings.
Year 1 activities center on establishing the technical advisory committee that will guide BMP
selection, project prioritization, and adaptive management decisions throughout the program
period. Initial meetings will develop operating protocols, review findings, and establish
criteria for project selection that balance ecological priorities with implementation feasibility.
The committee structure ensures that diverse perspectives inform implementation decisions
while building buy-in from organizations essential for program success. Initial projects will
focus on riparian buffer enhancement, culvert restoration (undersized/failing), large woody
debris projects, and invasive removal. The technical assistance framework will adapt based
on early participant feedback to reduce barriers and improve service delivery. Technical
assistance delivery in Year 2 will support project development cycles from initial site
assessment through BMP installation and maintenance planning.
Summary of Short-term Goals: Years 1-2 years
• Propose NPS 319 grant to Tribal Business Committee for approval
• Submit application for NPS Assessment Report, Management Plan, and TAS to EPA
• Assemble NPS technical advisory committee
• Implement NPS BMPs in accordance with priority areas to address the goals and objectives of

the Hoh River Watershed
• Discuss with Tribal members to ascertain priority pollutants and solutions
• Employ community dinners to establish connections and consultation
• Establish initial priorities for NPS projects based on assessments that account for reasonable

timelines, budgets, staff, and resources.
• Delineate lands where NPS pollution is projected

Intermediate Goals: Implementation
Years 3 through 4 represent the program's transition from demonstration-scale
implementation to systematic watershed restoration based on proven approaches and
32

established partnerships. This period emphasizes expanding successful BMPs to priority
watersheds, increasing landowner participation through documented successes, and refining
technical approaches based on effectiveness monitoring. The scaling process will remain
adaptive, accelerating in areas with strong landowner interest while adjusting strategies where
participation lags. Initiate systematic approaches to address road-related sediment sources
identified through GIS analysis and field reconnaissance. Rather than scattered individual
projects, the program will coordinate road improvements within priority sub-watersheds to
maximize sediment reduction benefits. By Year 5, the program will have established the
institutional frameworks and technical capacity for sustained long-term restoration beyond
the initial implementation period.
Activities focus on expanding temperature, sediment delivery, DO, and pH reduction efforts
from the eleven 303(d) listed tributaries and creeks on reservation. Successful restoration
approaches proven effective on tribal lands will be replicated at willing landowner properties,
with particular emphasis on Winfield Creek's severe impairments and Anderson Creek's
targeted restoration opportunities.
The expansion will utilize established cost-share mechanisms and technical assistance
partnerships to build on relationships developed during Years 1-2. Implementation will
proceed tributary by tributary rather than attempting simultaneous restoration across all
priority streams, ensuring adequate technical support and monitoring capacity for each project
area.
Enhanced outreach will target specific landowner segments, including small forest owners
unfamiliar with assistance programs and residential property owners with streamside parcels.
The Conservation District's established relationships and the Tribe's growing credibility as a
technical assistance provider will facilitate this expansion.
Summary of Intermediate Goals:
• Staff will track developments in watershed management planning and policy in the watershed

and other nearby watersheds and communicate with stakeholders to ensure participation in
decision making.
• Gather information regarding emerging contaminants in waterways, such as 6-PPD quinone

and PFAS/PFOS. If it is determined that an emerging contaminant is a threat to the water
quality in the rivers/creeks, tribal staff will investigate methods for managing the pollutant
• Adapt management strategies to decrease the impacts from land management activities on

water quality of streams and rivers
• Attend training opportunities to ensure proper expertise of staff to achieve program goals.

33

• Provide presentations and solicit input from council members and other members of the

community regarding the NPS; present to the Hoh Summer Camp participants, when
requested.
• Tribal staff will meet with personnel from federal, state, and regional governments and

organizations regarding watershed management issues to advocate for protection and
restoration of water quality and habitat.
• Submit annual reports that highlight progress of proposed work.
• Conduct inventory and GIS analysis of streams affected by specific pollutant sources

Long-term Goals: Expansion and Refinement
Year 5 will receive an emphasis on adaptation strategies as monitoring data reveals
temperature trends and the effectiveness of current restoration approaches under changing
conditions. The program will identify and protect cold-water refugia including deep pools,
groundwater springs, and north-facing tributaries that provide critical habitat during
temperature extremes.
Riparian restoration specifications will be modified to account for projected inclement
weather patterns, potentially increasing buffer widths or adjusting species composition for
future conditions. These adaptations will be developed through consultation with regional
scientists and incorporation of traditional ecological knowledge about historical refugia
locations.
Year 5 activities establish frameworks for long-term program sustainability while evaluating
progress toward water quality goals. The Tribe will pursue formal partnerships with
organizations including The Nature Conservancy, Trout Unlimited, and 10,000 Years
Institute, Wild Salmon Center to coordinate landscape-scale restoration beyond the initial
five-year period.
Funding diversification strategies will reduce dependence on EPA base funding by developing
competitive grant applications for state and federal programs. The permanent monitoring
network framework will be designed to track long-term trends while reducing monitoring
costs through strategic station selection and parameter prioritization.
Integration of traditional ecological knowledge will be formalized in Year 5 through structured
consultation processes building on the Tribe's established methods using community dinners
and elder interviews. This knowledge will inform restoration priorities, identify historical
reference conditions, and guide adaptive management decisions.
The synthesis of western science and indigenous observations accumulated over generations
will strengthen both technical approaches and community support for continued restoration
efforts. Documentation of traditional knowledge will ensure its preservation and application
34

in future restoration planning while respecting cultural protocols for information sharing.
Summary of Long-term Goals:
• Update assessment and management plan as needed with the NPS technical advisory
• Staff will track restoration efforts in the watershed and communicate with stakeholders to

ensure participation in decision making. When possible, staff will monitor the short- and longterm effects of restoration on channel geomorphology, hydrology, and water quality.
• Collaborate and support research that will aid in a greater understanding of watershed

pollutants.
• Expand NPS program priorities if needed with other entities to expand program operations and

funding
• Education and outreach to tribal members once success, research, and

implementation have been established
• Monitor conditions of the watershed pre- and post- BMP implementation
• Increase monitoring for NPS pollution sources
• Assess the success of monitoring, implementation, progress, and conclusions of NPS BMPs on

a project-by-project basis. As well as refine procedures to adapt NPS projects if needed.
Category dependent objectives and measurable outcomes:
Each category of NPS pollutant sources requires unique objective and outcomes based on need
and priority according to Tribal standards. The table below documents short- & long-term
objectives, and success standard by each category.

35

Table 4. NPS objective and outcome measures by category.
NPS Category
Short-term objectives
Long-term objectives
Success measurements
• Identify high-priority riparian restoration sites
• Restore water quality in streams on
• Demonstrable temperature, DO,
with property managers on logged properties
logged properties
pH reductions at established monitoring
• Discuss with property managers where
• Assess effectiveness of various
sites.
restoration activities like large woody
treatments to inform adaptive
• Quantify high-priority sites identified
Forestry and
debris establish, wetland protections, and riparian management and potential watershed• Establish GIS inventory of
Logging Roads
buffer protections would be most beneficial.
wide application
cedar spaults causing NPS pollution
• Inventory and GPS cedar spault presence
• Alter management strategies to tailor
throughout the watershed
• Assist partners with BMPs intended to
goals and objectives
• Number of connections with property
reduce forestry-related pollution sources
managers
• Identify high-priority riparian restoration sites
• Track restoration results and influence
• Establish relationship with property
with property managers on logged properties
on NPS pollution reduction
managers
• Focus restoration to address large woody debris, • Monitor or assist in research to assess
• Measurable reductions to pollutants
riparian replanting, and culvert restoration in
effectiveness
from restoration efforts
Hydromodification
areas that would be most beneficial.
• Expand programs to increase
• Quantify restoration efforts (# of
and Bank Erosion
• Assist expert personnel with implementation of
monitoring
culverts replaced, miles of riparian
related BMPs
• Observe water quality changes over
buffers restored, etc.)
• Coordinate with land managers to build closer
time
ties
• Inventory and map invasives in the watershed
• Track riparian changes over time
• Calculate riparian buffer zone/river
• Collaborate with expert
• Continue to advocate for invasive
miles restored
personal to establish priority areas
removal and safe practices to ensure
• Determine measurable reductions to
• Work jointly with interested parties to address
prevention
pollutants
shared invasive removal projects
• Review miles of removed invasives
Invasive Species • Enforce invasive removal projects and provide
along riparian areas
participation needed to establish success
• Monitoring will assess effectiveness of
various treatments to inform adaptive
management
• and potential watershed-wide
applications.
• Work with agencies to establish 6ppd
• Conduct long term monitoring on toxic • Identify at-risk streams
monitoring plans
chemicals
• Expand program goals if needed based
• Map at risk areas and establish sampling plans
• Monitor project areas and
on urgency of pollution source
Roads, Highways,
• Gather information regarding emerging
assess strategies to mitigate pollution
• Number of at-risk streams assessed for
and Bridges
contaminants in waterways, such as 6-PPD
source
6PPD
• Conduct research and testing on a 6PPDQ,
• Increase monitoring if 6PPD is a
including effects on wildlife and habitats
known persistent pollutant
36

Table 3 (cont.): NPS objective and outcome measures by category
NPS Category

Short-term objectives
Long-term objectives
Success measurements
• Determine and prioritize sites with high-risk
• Create baselines for data at high• At-risk high-priority sites identified
pathways to streams
risk streams
• Confirm or deny pollutant presence
Natural Resource • Gather research to confirm or deny if pollutants • Coordinate with agencies to assist in
Extraction
are affecting water quality
streambank restoration sue to aggregate
• Collaborate with agencies to address pollutant
resource pollution
pathways and issues
• Determine if contaminants are present
• Develop further plans that address
• Needs are established based on research
Atmospheric
• Establish areas where pollution sources affect
contaminants of interest
and data gathered
Deposition
waterways and establish priority areas
• Adapt management strategies based on
data gathered

37

Milestones and Evaluation
The implementation schedule includes specific milestones and evaluation criteria that enable
tracking progress toward water quality goals while maintaining flexibility for adaptive
management. These milestones provide accountability to EPA and the tribal council while
avoiding unrealistic numerical commitments that could constrain the voluntary program's
ability to respond to opportunities.
The evaluation framework emphasizes both implementation metrics and environmental
outcomes, recognizing that water quality improvements may lag behind BMP installation by
several years. Regular assessment ensures that the program remains on track while identifying
necessary adjustments to strategies or priorities.
Annual reporting to EPA and the tribal council will document progress across multiple
performance categories without binding the Tribe to specific quantitative targets. Reports will
track acres of riparian buffers established, number of BMPs installed by type, landowners
engagement, and partnerships developed or strengthened.
Environmental outcomes including temperature trends at priority sites, dissolved oxygen
improvements in Lower Chalaat Creek, and pH changes in acidified tributaries will be
assessed against baseline conditions, sedimentation baselines created. These reports will
provide transparency while acknowledging the inherent variability in voluntary participation
and environmental response times.
Persistent water quality standard violations despite BMP implementation would initiate
comprehensive review of technical approaches and potentially identify need for regulatory
backstops. These triggers ensure that ineffective approaches are modified rather than
perpetuated through program inertia.
Success metrics will be organized into categories that reflect the program's multiple objectives
without establishing rigid numerical targets. Implementation success will be evaluated
through BMP installation rates compared to regional programs and leveraging ratios showing
non-EPA funding attracted.
Environmental success will be assessed through trend analysis showing movement toward
water quality standards, increased stream miles supporting beneficial uses, and maintenance
of high-quality reference waters. Partnership success will be measured through active
participation in the technical advisory committee and coordination with restoration partners.
The evaluation framework explicitly acknowledges factors beyond tribal control that
influence program outcomes. Variability including extreme heat events or atmospheric rivers
may overwhelm BMP effectiveness temporarily. Changes in timber markets affecting harvest
timing and intensity could alter landowner participation patterns.
Federal funding fluctuations might accelerate or constrain implementation pace despite
38

consistent tribal commitment. The evaluation process will distinguish between controllable
program elements requiring adjustment and external factors requiring patience and
persistence.
Flexibility to adjust implementation based on monitoring results and emerging opportunities
remains paramount throughout the evaluation process. The schedule represents a framework
for action rather than rigid commitments, allowing the Tribe to accelerate successful
approaches while modifying or abandoning ineffective strategies.
This adaptive approach ensures that resources generate maximum water quality benefit while
building the experience base for long-term watershed restoration. The evaluation framework
provides sufficient structure for accountability while preserving the nimbleness essential for
successful voluntary conservation programs.
Funding Source Overview
The Hoh Tribe identified potential funding sources available to support implementation of the best
management practices and programs described throughout this Management Program Plan. The
diversity of funding opportunities presented here demonstrates the Tribe's understanding of the
complex funding landscape for nonpoint source management while providing multiple pathways
for securing implementation resources. These sources range from federal programs specifically
designed for tribal water quality protection to innovative market-based mechanisms that align
economic incentives with environmental outcomes.
The funding sources identified directly support the voluntary implementation framework
established and the phased schedule outlined earlier. Each source has been evaluated for alignment
with the specific BMPs identified, ensuring that funding pursuits match both water quality
improvement needs and program eligibility requirements. The Tribe's existing funding portfolio,
including annual EPA GAP support plus diverse federal and state resources, provides the
foundation for leveraging these additional opportunities.
The Hoh Tribe's approach to securing implementation resources builds systematically from
an established foundation of federal and state funding that demonstrates institutional capacity
and program sustainability. Current annual support from EPA GAP funding plus Section 106
monitoring grants, combined with diverse funding from NOAA, BIA, and Washington State
programs, provides the administrative infrastructure essential for pursuing competitive
implementation grants. This existing portfolio, spanning fisheries management and habitat
restoration, positions the Tribe as a capable recipient for expanded nonpoint source
management investments. The funding strategy emphasizes strategic alignment between
identified water quality impairments and programs designed to address specific pollution
sources.
Diversification across federal, state, regional, and private sources reduces dependence on any
single funding stream while creating opportunities for leveraging match requirements. Federal
39

programs often accept state funds as match, while private foundations may provide the
unrestricted resources needed for federal match requirements. The Tribe's established
partnerships with organizations including The Nature Conservancy, Trout Unlimited, and the
10,000 Years Institute facilitate joint applications that access larger competitive grants
requiring collaborative approaches.
Implementation timing will necessarily respond to funding cycles and award notifications
rather than following rigid schedules. The implementation framework described earlier
provides flexibility to accelerate activities when resources become available or adjust
approaches based on funder priorities. This adaptive approach ensures that water quality
improvements proceed regardless of specific funding outcomes while maintaining readiness
to scale up when major resources materialize.
The phased implementation schedule deliberately aligns with typical funding trajectories for
watershed restoration programs. Years 1-2 focus on planning and demonstration projects
typically supported by base funding and smaller grants. Years 3-5 expand successful
approaches using competitive implementation grants that require proven effectiveness and
established partnerships. Long-term sustainability beyond Year 5 depends on demonstrating
measurable water quality improvements that justify continued investment.
Cost-effectiveness remains central to funding competitiveness given limited resources for
watershed restoration nationwide. The emphasis on voluntary implementation through
existing technical assistance programs reduces administrative costs while leveraging
landowner contributions that extend public investments.
Federal Funding Sources
EPA Programs

Section 319(h) Nonpoint Source Implementation Grants represent the primary federal
mechanism for implementing the BMPs identified in Chapter 3, with competitive awards
typically ranging from $100,000 to $750,000 for projects demonstrating measurable pollutant
load reductions. These grants require approved assessment and management plans, which this
document fulfills, and support riparian restoration, forestry BMPs, and road improvements
that directly address the temperature, sediment, and nutrient impairments documented
throughout the watershed. The 40% non-federal match requirement can be met through other
federal programs with specific authority, tribal in-kind contributions, or state and private
resources.
Section 106 Water Pollution Control Grants currently support the Tribe's monitoring program
and can expand to include implementation effectiveness monitoring as restoration projects
proceed. Wetland Program Development Grants provide $75,000 to $300,000 for developing
wetland restoration programs that address the dissolved oxygen impairments in Lower Chalaat
Creek through enhanced natural treatment systems. Environmental Justice Grants recognize
40

that tribal communities face disproportionate impacts from water quality degradation and
provide resources for community-based solutions.
USDA Conservation Programs
The Natural Resources Conservation Service Environmental Quality Incentives Program
(EQIP) provides exceptional support for tribal producers through 90% cost-share rates
compared to 75% for other landowners, making conservation practices economically feasible
on agricultural lands. Eligible practices directly addressing watershed impairments include
riparian forest buffers (Practice 391), livestock exclusion fencing (Practice 382), nutrient
management planning (Practice 590), and sediment basins (Practice 350). Annual payment
limits of $450,000 per entity over five years enable substantial landscape-scale restoration
when combined with other funding sources.
The Conservation Stewardship Program (CSP) supports landowners already implementing
conservation practices who commit to additional enhancements, providing annual payments
of $1,500 to $40,000 based on acreage and practices implemented. The Regional Conservation
Partnership Program (RCPP) leverages partner contributions for landscape-scale projects,
with awards typically ranging from $250,000 to $10 million for multi-year collaborative
efforts.
The Conservation Reserve Enhancement Program (CREP) provides 10-15 year rental
payments for removing environmentally sensitive land from agricultural production while
establishing permanent vegetation, particularly valuable for riparian buffer creation. Forest
Service Tribal Forest Programs support management activities on the 41.9% of the watershed
in forest ownership, including road decommissioning, riparian thinning, and erosion control.
The Emergency Watershed Protection Program responds to natural disasters with 75% federal
funding for restoration, relevant given the increasing frequency of extreme weather events
affecting the watershed.
Bureau of Indian Affairs Programs
The Water Management, Planning, and Pre-Development Program offers $50,000 to
$400,000 for comprehensive water resource management including watershed assessments,
restoration planning, and project development. These programs recognize tribal sovereignty
in natural resource management while providing flexible funding for activities that may not
qualify under other federal programs.
Rights Protection programs currently supporting fisheries management through Pacific
Salmon Treaty and Western Washington Boldt allocations can expand to include water quality
protection as essential for maintaining treaty resources. The BIA Forestry Programs
complement USDA efforts with specific focus on tribal trust lands and culturally significant
forest resources. Water Resources Programs support infrastructure improvements including
irrigation efficiency and water conservation that reduce stream withdrawals during critical
low-flow periods.
41

Other Federal Programs
NOAA's Community-based Restoration Program provides $75,000 to $3 million for habitat
restoration projects benefiting threatened salmon populations, directly supporting temperature
reduction efforts through riparian restoration. The program's emphasis on collaborative
partnerships aligns with the Tribe's established relationships with The Nature Conservancy
and Wild Salmon Center. NOAA's Transformational Habitat Restoration and Coastal
Resilience Grants under the Infrastructure Investment and Jobs Act provide $1 million to $15
million for large-scale ecosystem restoration.
U.S. Fish and Wildlife Service Tribal Wildlife Grants range from $25,000 to $200,000 annually
for species conservation projects, with potential application to cold-water refugia protection
and riparian habitat enhancement. The National Fish Passage Program supports removal of
barriers to fish migration, addressing the culvert and crossing improvements identified through
field reconnaissance. Partners for Fish and Wildlife provides technical and financial assistance
for habitat restoration on private lands, facilitating engagement with non-tribal landowners.
Federal infrastructure programs authorized through the Infrastructure Investment and Jobs Act
and Inflation Reduction Act provide unprecedented funding for water quality improvements.
The Federal Highway Administration's Promoting Resilient Operations for Transformative,
Efficient, and Cost-saving Transportation (PROTECT) program funds infrastructure
improvements addressing landscape vulnerabilities. Rural Surface Transportation Grant
Program supports road improvements in rural areas, applicable to the extensive forest road
network contributing sediment. These programs typically provide 80% federal funding with
reduced match requirements for tribal governments.
State and Regional Sources
Washington Department of Ecology Programs

The Water Quality Combined Funding Program represents Washington's primary mechanism
for implementing water quality improvements, integrating multiple funding sources into
streamlined application processes with awards typically ranging from $100,000 to $5 million.
This program supports nonpoint source pollution control, on-site sewage system
improvements, and stormwater management projects that directly address the impairments
documented throughout the watershed. The Centennial Clean Water Program component
provides grants and low-interest loans for water quality infrastructure, particularly relevant
for addressing septic system failures contributing to dissolved oxygen impairments.
The Coastal Protection Fund provides resources for projects protecting coastal waters from
nonpoint source pollution, with the Hoh River's direct discharge to the Pacific Ocean
establishing eligibility for downstream water quality protection. Terry Husseman Grants
support watershed planning and implementation with typical awards of $50,000 to $300,000
for collaborative projects involving multiple partners. The Stormwater Financial Assistance
42

Program addresses runoff from developed areas and roads, applicable to sediment delivery
from the extensive road network identified.
Washington Recreation and Conservation Office
The Salmon Recovery Funding Board, through which the Tribe already receives support, can
expand to include water quality components of habitat restoration with typical project grants
ranging from $75,000 to $500,000. The Washington Wildlife and Recreation Program's
Riparian Protection Category specifically funds conservation of riparian corridors critical for
temperature reduction, with awards often exceeding $1 million for landscape-scale protection.
The Aquatic Lands Enhancement Account supports restoration of aquatic habitat on stateowned aquatic lands, relevant where state ownership extends into the watershed.
The Brian Abbott Fish Barrier Removal Board coordinates statewide fish passage restoration
with dedicated funding for high-priority barriers, directly applicable to the high-risk crossings
identified through GIS analysis. These programs leverage state capital budget appropriations
that have increased substantially in recent biennia due to court-mandated culvert replacement
requirements. The Land and Water Conservation Fund state allocation provides additional
resources for habitat protection and public access improvements.
Washington Department of Natural Resources Programs

The Family Forest Fish Passage Program provides 75-100% cost-share for small forest
landowners to replace fish passage barriers, critical given that DNR and private forest lands
comprise 41.9% of the watershed where temperature impairments concentrate. The Forestry
Riparian Easement Program compensates small forest landowners for timber value foregone
when implementing riparian buffers beyond regulatory requirements. Rivers and Habitat
Open Space Program supports acquisition and restoration of ecologically valuable lands along
rivers and streams.
Community Forestry Assistance provides technical support and funding for urban and
community forest management, applicable to developed areas within the watershed. The
Forest Health and Resilience programs address landscape adaptation needs through strategic
thinning and species selection that maintains forest cover while reducing fire risk. These
programs recognize the interconnection between forest management and water quality,
providing pathways for addressing temperature impairments on forested lands.
Other State Agency Programs
The Washington Department of Commerce Infrastructure Assistance programs provide
funding for rural infrastructure improvements including road upgrades and stormwater
management systems. The Public Works Board's Construction Loan Program offers lowinterest financing for infrastructure projects that protect water quality. The Transportation
Improvement Board's Small City and Rural Area programs fund road improvements that can
43

incorporate water quality protection measures during reconstruction.
The Department of Fish and Wildlife's Aquatic Invasive Species Prevention program supports
early detection and rapid response efforts that protect native ecosystems from additional
stressors. The State Conservation Commission provides funding through conservation
districts for voluntary conservation practices on agricultural lands. These diverse state
programs enable comprehensive approaches addressing multiple impairment sources
simultaneously.
Regional Partnership Programs
The North Pacific Coast Lead Entity, in which the Tribe maintains voting representation,
coordinates salmon recovery funding across multiple watersheds and jurisdictions with annual
allocations typically exceeding $2 million regionally. This established partnership provides
technical assistance for project development, regional prioritization that strengthens
individual applications, and coordination among restoration practitioners. The Lead Entity
process ensures that projects align with regional recovery plans while maintaining local
priorities.
The Pacific Coast Salmon Coalition facilitates collaboration among tribes, agencies, and
conservation organizations implementing restoration across the Olympic Peninsula. Hood
Canal Coordinating Council, while focused primarily on Hood Canal, provides models and
partnerships applicable to Olympic Peninsula watersheds. The Washington Coast Sustainable
Salmon Partnership develops regional strategies that individual projects support,
strengthening funding applications through demonstrated contribution to landscape-scale
recovery.
Olympic Natural Resources Center facilitates research partnerships between tribes, agencies,
and academic institutions that can provide technical support and monitoring for restoration
projects. The Northwest Indian Fisheries Commission coordinates tribal natural resource
management programs, providing technical assistance and advocacy for funding programs
supporting treaty rights protection. These regional entities provide both direct funding and
critical support services that enhance the Tribe's capacity for successful implementation.
Private and Foundation Sources Environmental Foundations
The Bullitt Foundation prioritizes ecosystem protection and restoration throughout the Pacific
Northwest, with particular emphasis on projects demonstrating resilience and community
engagement in environmental stewardship. Grant awards typically range from $25,000 to
$100,000 annually for multi-year commitments supporting both implementation and capacity
building. The foundation's focus on environmental justice and tribal sovereignty aligns with
the Tribe's leadership in watershed restoration while addressing disproportionate impacts on
tribal communities from water quality degradation.
44

The Wilburforce Foundation supports landscape-scale conservation in western North America
with grants ranging from $20,000 to $250,000 for projects protecting intact ecosystems and
restoring degraded habitats. Their emphasis on collaborative approaches matches the
partnership framework, particularly for engaging private forest landowners in voluntary
conservation. The M.J. Murdock Charitable Trust provides capacity building support for
Pacific Northwest nonprofits and tribes, with awards up to $500,000 for strengthening
organizational infrastructure essential for long-term program sustainability.
The Paul G. Allen Family Foundation has invested substantially in Puget Sound and coastal
restoration, with potential application to the Hoh watershed given its direct connection to
Pacific coastal waters. The Russell Family Foundation supports environmental sustainability
in Puget Sound and Washington State, emphasizing innovative approaches to environmental
challenges. The Kongsgaard-Goldman Foundation provides smaller grants of $5,000 to
$25,000 for grassroots environmental efforts, suitable for demonstration projects and
community engagement activities.
Corporate Partnership Opportunities
Timber companies operating within the watershed, including Rayonier which manages
substantial acreage in the basin, increasingly support collaborative restoration that maintains
working forests while protecting water quality. These partnerships can provide match funding,
equipment, technical expertise, and access to lands for restoration implementation.
Technology companies with Pacific Northwest presence, including Microsoft and Amazon,
have established environmental grant programs supporting ecosystem restoration in their
operating regions.
Outdoor recreation companies including Patagonia, REI, and Columbia Sportswear maintain
grant programs supporting watershed protection given the connection between healthy rivers
and recreational opportunities. Fishing industry partnerships through commercial and
recreational fishing organizations recognize the direct connection between water quality and
salmon productivity. Beverage companies dependent on clean water resources increasingly
fund source water protection initiatives that align with temperature and sediment reduction
goals.
Conservation Organization Partnerships
The Nature Conservancy, already partnering with the Tribe, leverages private philanthropy for
landscape-scale conservation with capacity to bring matching funds and technical expertise to
joint grant applications. Trout Unlimited's Western Washington program combines member
donations with foundation grants to support cold-water habitat restoration directly addressing
temperature impairments. Wild Salmon Center's partnerships bring international attention and
funding to Pacific salmon watersheds, with particular emphasis on refugia protection.
Bonneville Environmental Foundation's Model Watershed Program provides multi-year
45

funding for comprehensive restoration initiatives demonstrating innovative approaches to
watershed management. National Fish and Wildlife Foundation administers multiple
corporate-funded programs supporting habitat restoration, with typical awards ranging from
$50,000 to $500,000. American Rivers, Trust for Public Land, and Conservation Northwest
offer both direct funding and technical assistance for projects protecting riverine ecosystems.
Table 5. Summary of Major Funding Sources for NPS Implementation.
Program

Agency

Typical Award
Range

Match
Required

Se

[Text truncated at 120,000 characters. The full text is on the page linked above.]

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Ahoh%3A64b676e5f63d8073. Public record. Not legal advice.