Klamath Water Users Association
2455 Patterson Street, Suite 3
Klamath Falls, Oregon 97603
(541)-883-6100 FAX (541)-883-8893 kwua@cdsnet.net

Honorable Ted Kulongoski

State Capitol

Salem, Oregon 97301-4047

Honorable Gale Norton

U.S. Department of the Interior

1849 C Street, N.W., Suite 7229

Washington, D.C. 20240-0000

Honorable Mary D. Nichols

California Resources Agency

1416 9th Street, Room 1311

Sacramento, California 95814

Dear Governor Kulongoski, Secretary Norton and Secretary Nichols:

Thank you for your continued attention to the critical challenges facing Californians and Oregonians dependent upon the Klamath River for their livelihoods. On behalf of the Klamath Water Users Association, I am writing to urge your continued efforts to promote sound fishery management decisions on the Klamath River. Recent media reports suggest that we may be seeing record numbers of fish returning to West Coast rivers this summer. Although the fall of 2002 presented an occurrence that was unique, we must be prepared to avoid a repeat of last year’s crisis, where huge numbers of returning fish entered the lower Klamath River early, only to encounter water temperatures and overcrowding that allowed disease to quickly spread.

We urge that you objectively assess this situation and consider taking management steps that can help ensure that the 2002 experience is not repeated. We would like federal agencies, the states of California and Oregon, downstream tribes, farmers and fishermen to pool our collective resources towards an end that both improves the understanding and benefits the fish. We ask that you consider the following observations and recommendations, which are intended to begin constructive dialogue in this matter. These recommendations are further intended to complement and supplement the draft monitoring and evaluation plan proposed in An Action Plan to Minimize Risk of Die-Off of Trinity River Fall Run Chinook Salmon in 2003, prepared by the Trinity River Restoration Program earlier this month.

During late summer and early fall of 2002, Dave Vogel, a fisheries biologist with 28 years experience, conducted a field investigation to assess water temperatures in the main stem Klamath River. Vogel measured main stem water temperatures hourly just prior to and during the fall-run Chinook salmon migration season. He found that water temperatures in the upper Klamath River downstream of Iron Gate Dam during September 2002 were unsuitable for adult salmon, a finding that was similar to that of previous studies. Vogel also found that large numbers of salmon entered the lower Klamath River earlier than usual and were exposed to two uncharacteristic cooling and warming conditions likely causing disease outbreak from warm water and crowded conditions. According to Vogel, the combination of these factors was chronically and cumulatively stressful to fish and is probably the most plausible reason for the fish die-off.

These data indicate that September 2002 was unusual, but not necessarily for the reasons portrayed by opponents of the Klamath Project, who sought to immediately assign blame to the Project, located 200 miles from these events. To better ensure that sound science – and not divisive politics – drive management decisions this fall, we offer the following recommendations that we believe should be implemented immediately.

In September 2002, significant energy was dedicated towards counting and publicizing fish carcasses, but much less to collecting critically important data on potential causative factors that may have been responsible for the fish die-off. For example, water samples to determine the potential presence of toxic substances were not taken until eight days after the onset of the fish die-off. That time interval was well after toxic substances would have been flushed from the river system. This unfortunate circumstance means that toxic substances cannot be ruled out as a potential cause for the fish die-off.

Recommendation: Water samples should be collected in the lower river on a daily basis during the principal period when large numbers of salmon are entering the lower river. Samples should be preserved with the appropriate fixative and archived for potential future analyses. Analyses would not have to be performed unless another fish die-off occurs.

At the time of the 2002 fish die-off, Klamath Project water users requested that dissolved oxygen (DO) concentrations be measured throughout the water column (profiles) of the deeper pools where salmon were concentrated. This action was deemed necessary to determine if low DO could have been a contributing factor to the die-off. Apparently, this request was not granted, and those data were not collected. Although DO measurements were taken elsewhere, data were not collected directly in the pools where salmon were concentrated. Therefore, low DO caused by the combination of warm water and large numbers of salmon in confined areas cannot be ruled out as a potential causative factor in the 2002 fish die-off.

Recommendation: Install continuously recording DO and temperature-measuring devices at the bottom of the deepest pools where salmon are known to concentrate and stage in the lower river prior to their upstream migration.

We believe that unseasonably warm air and water temperatures were contributing factors to the 2002 fish die-off. Although the U.S. Fish and Wildlife Service (USFWS) had water temperature thermographs at various locations in the Klamath basin last year, there are important areas where data were not collected that would have demonstrated the inhospitable conditions for salmon in some upstream areas. In addition, the USFWS temperature data were not made available until many months after the fish die-off.

Recommendation: Additional air and water temperature thermographs should be placed in upstream mainstem areas and tributaries to more comprehensively document seasonal changes throughout the watershed prior to and during the principal fish migration period. Importantly, those data should be made available to interested parties on a timely basis to allow for a near-real time assessment of habitat conditions instead of post-season analyses. At a minimum, thermograph data should be downloaded weekly and posted on a government web site.

After the 2002 fish die-off, there were some anecdotal observations and speculations that one or more riffles in the lower river may have caused some form of fish migration barrier. Unfortunately and surprisingly, no agency or individual collected any data on this potential causative factor. Although we believe that this circumstance was not a contributing factor, data could have and should have been collected during 2002 to make that determination.

Recommendation: Water velocities and depths should be measured at any shallow riffles in the lower river where fish migration may be affected.

Surprisingly, despite well-know protocols in assessing fish die-off causative factors, fish health data were not collected until eight days after the onset of the 2002 fish die-off. Also, we understand that analyses to detect the potential presence of toxic substances in the fish carcasses were not performed. These major oversights resulted in no data collected at the time when the information was most important.

Recommendation: Fish health data must be collected in a much more timely manner. Those data should be collected immediately after any observations of moribund or dead fish. Tests to determine the potential presence of toxic substances in fish carcasses should also be conducted.

Apparently, it was well known that there was a larger than average salmon run size and earlier than average run timing in advance of the 2002 fish die-off. We believe that the circumstances of run size and timing contributed to the 2002 fish die-off because of two unseasonable cooling and warming trends that stressed the fish. Data on the salmon run size and run timing were collected in 2002 but not made available until after the fish die-off occurred.

Recommendation: More timely reporting of those data will provide valuable warning signals of potential future fish die-offs if environmental conditions in the river are unsuitable. Additionally, those data would allow for potential rapid management changes for in-season harvest. For example, a more liberal in-season harvest prior to the fish die-off in 2002 would have helped reduce the high concentrations of salmon in the lower river that undoubtedly contributed to the die-off event.

Apparently, accurate information on the lower Klamath River flows was not available during the fish die-off. According to a recent report by the U.S. Geological Survey, this circumstance is attributable to a variable (unstable) stage-discharge rating curve at the river gauge site (known as the Terwer gauge).

Recommendation: The Terwer gauge should be calibrated more frequently during late summer and early fall to allow better data collection on flows in the lower Klamath River. In addition, because of the effect of the sand spit at the mouth of the Klamath River on fish passage and estuarine conditions, data on the sand spit configuration should be collected during the principal fish migration period. Even something as simple as daily photos and field note observations of the sand spit would be valuable.

We recognize the coordination that is underway between California, the United States, and Klamath River downstream interests to manage the pulse flow of Trinity River water later this summer. It is our understanding that approximately 33,000 acre-feet of additional water will be released between the end of August and mid-September to provide cold water for fish downstream. We further understand that Trinity flows will increase from 450 cubic feet per second (cfs) to 1,650 cfs during the time period, and then ramp down to 450 cfs by mid-September. In the meantime, steady flows of 1,168 cfs will be released out of Iron Gate Dam. Based on last fall’s data, the water temperature at the location of the fish die-off exceeded 69 degrees F for the first four days of the die-off. Water temperatures below Iron Gate Dam were at least this warm, or warmer for the same duration. Meanwhile, water temperatures below Lewiston Dam on the Trinity River were approximately 20 degrees cooler.

Our concern is this: if migrating salmon are attracted to the cooler Trinity flows, and begin moving upstream, what happens when the Trinity pulse flow ends, and the volume of warmer, Klamath River mainstem water is 2 ½ times greater than the Trinity flows at the Trinity-Klamath confluence? What is to prevent fish bound for the Klamath River mainstem – attracted by the cooler Trinity River releases - from encountering potentially hostile water quality conditions on the Klamath River mainstem below Iron Gate Dam?

There are serious questions about the wisdom of releasing additional Klamath Project stored water downstream in August and September, particularly when last year’s study completed by the National Academy of Sciences (NAS) found that higher flows "may work to the disadvantage of the coho population" in summer months. In 1994, despite warnings from Klamath Project biologists, federal agencies increased summer flows, which prematurely attracted fall-run chinook salmon to an upper area of the river where natural conditions were hostile to their health. The net result of the increased flows during late August of that year could have ultimately been detrimental to 1994 fall-run Chinook in the Klamath River.

It appears that the current Klamath Project operation plan proposes to send more potentially hot water down the river than what would likely have been present in summer months in the absence of Klamath Project stored water. Further, the recent Environmental Assessment prepared by the U.S. Bureau of Reclamation and the action plan prepared by the Trinity River Restoration Program to minimize risk of die-off of Trinity River fall run Chinook salmon this year do not assess the role of ambient air temperatures as a consideration regarding "triggering" of the Trinity pulse flow.

Recommendation: The coordinated operations of Klamath River mainstem and Trinity River flows must be carefully evaluated. We believe that the very important relationship that exists between ambient air temperature and Klamath River mainstem flows must be considered in flow management decisions this fall.

We believe the proposed short-term actions described above should be immediately implemented. These actions would also form the basis for a long-term solution that might include:

• Creation of a Central Monitoring System to assess water quality and flow parameters to alert of potential conditions that might lead to fish die-offs in the Klamath-Trinity system.
• Improved coordination between Klamath Project and Central Valley Project Trinity River export operations to meet potential emergency needs.
• Pulse flow management that is driven by sound science and collaboration.
• Improved hatchery management.

The sooner that success can be reached in the short-term, the sooner we can more confidently begin working together to develop meaningful long-term solutions to the challenges we face.

We must learn from last year’s unfortunate situation and attempt to better understand all of the complexities that may have led to the fish die-off. Quickly jumping to conclusions and assigning blame – especially in the absence of critical data and analyses – does nothing but polarize stakeholders and further delay the necessary constructive and collaborative work that must be done to improve our watershed. We look forward to your leadership and cooperation as we continue to take a constructive approach toward improving our destiny and contributing to effective species recovery.

If you have any questions about this matter, please do not hesitate to contact Dan Keppen at 541-883-6100.

Sincerely,

Dan Keppen

Executive Director

cc: U.S. Senator Ron Wyden

U.S. Senator Gordon Smith

Modoc County Board of Supervisors

Siskiyou County Board of Supervisors

California Department of Fish and Game Director Robert Hight

California State Water Resources Control Board – Art Baggett

U.S. Bureau of Reclamation Klamath Basin Area Office – Dave Sabo

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