The article “An Ecological Function Approach to Managing Harmful Cyanobacteria in Three Oregon Lakes: Beyond Water Quality Advisories and Total Maximum Daily Loads (TMDLs), Water
11:1125” by Hall et al. critiques the current approach used by the state of Oregon with regard to managing cyanobacterial blooms and offers the proper functioning condition (PVC) as a superior method of managing cyanobacterial blooms in lakes derived from nonpoint sources of pollution. They evaluated three lakes in Oregon as examples of how this approach could be applied to support water quality improvement. Two of the three lakes, Lemolo and Diamond, experienced cyanobacterial blooms, not as a function of nonpoint source loadings from the watershed, but rather because of internal nutrient cycling associated with high fish biomass. The third lake, Tenmile Lakes, in additional to having a greatly altered fish community, also experiences cyanobacterial blooms (CyanoHABs) issues because of timber harvest on steep slopes, loss of wetlands, altered watershed hydrology and nutrient input from septic systems. The authors’ attempts to use satellite images and PVC methodology on the stream networks is incomplete with respect to Tenmile Lakes and is totally misdirected regarding Lemolo and Diamond Lakes. Although I don’t support the current system employed by the state of Oregon to manage lakes experiencing CyanoHABs issues, the proposed approach offered by staff with the U.S. Environmental Protection Agency will yield little water quality benefit for the lakes in question.
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