Subject: Request for Water Transfer to Tule Lake Sump 1B

Hydrologic modeling provided to the Service by Reclamation indicates that if no action is taken to bolster water storage in Sump 1B, water depth in the sump will drop as low as 0.5 feet by early October. This extremely low water depth would highly impact waterfowl by removing nearly all of their habitat, exacerbating anticipated avian botulism outbreaks as the summer progresses and undermining the Service’s obligations to protect waterfowl habitat on NWRs under the National Wildlife Refuge Improvement Act. The low water depth would also place significant stress on sucker populations in Sump 1B, which could result in the mortality of the entire population at this location. The Service views this action as helping Reclamation fulfill its obligations related to the 2020 biological opinion on Klamath Project operations. By providing 10,000 acre-feet, Reclamation’s modeling indicates that sump depth in early October would be approximately 3 feet, which would greatly improve the quality and diversity of habitat for waterfowl and would provide the same protections for suckers from predation provided at the mouth of Pelican Bay in Upper Klamath Lake.

The Service would also like to clarify a few points related to our understanding of this water transfer. We understand this will be a time-limited borrow of the water volume from PacifiCorp reservoirs, to be repaid in full on a schedule to be determined by PacifiCorp. The Service expects Reclamation will work with TID to effect repayment, and there will be no net loss of storage in Upper Klamath Lake as a result of this transfer. We understand, based on conversations with TID, that Reclamation and TID will ensure that irrigation from the sump during and after the water transfer will be managed such that there is a net zero impact to water storage from irrigation activities. Reclamation and the Service will coordinate to monitor relevant water storage data to ensure that both the borrow and the repayment are conducted as expected. Finally, the Service wants to be clear that the volume borrowed to place in Sump 1B for NWR purposes and ESA requirements will not affect future water availability for Tule Lake NWR or Lower Klamath NWR in the form of winter deliveries, Project water deliveries, or any volumes associated with transferred water rights.

The Service greatly appreciates Reclamation’s willingness to work with us to address the challenges that we share in managing water on Tule Lake NWR. We are hopeful that by providing the requested water in a timely manner, there will be significant mitigation of potential impacts to waterfowl and suckers who rely upon Sump 1B. We will continue to coordinate closely with Reclamation, as well as our partners at NMFS, the Tribes, and irrigators, to realize the best possible outcomes for all resources in this extremely difficult year.