To: Tara Jane Campbell Miranda
Bureau of Reclamation
6600 Washburn Way
Klamath Falls, Oregon 97603.

March 19, 2019
 

Comments to DRAFT Environmental Assessment

Implementation of Klamath Project Operating Procedures 2019-2024

Oregon and California 2019-EA-007

 

Attn: Tara Jane Campbell Miranda 

tcampbellmiranda@usbr.gov

 

First, your comment period notice was in our local Herald and News March 12th. That gave us, whose lives depend on our deeded stored water, only seven days to respond. Please give us another month, as these proposed actions would affect our entire lives, community, mostly-Hispanic labor, our groundwater, our bank loans and crop planning.  Since we grow a perennial crop, such a massive taking of our water and depletion of our groundwater could end our business.

 

Your draft EA proposal would be devastating to us farmers and ranchers by reducing the amount of water that we are allowed to use from our stored water, increasing lake levels, which as you detailed, would increase years of fallowing land, overusing groundwater, and increasing the cost of groundwater pumping, increasing unemployment and years of not having enough water to irrigate the Klamath Project.

 

Having read the Bureau’s Final Biological Assessment for the Klamath Project, it states that factors influencing bird predation are currently unknown. How can this be?

In 2009 millions of dollars were spent to build three islands in our refuges to relocate fish-eating caspian terns to the Tulelake Basin.  How many are there now? An estimated colony of 10,000 nesting pairs of Caspian terns on Rice Island in the Columbia River were consuming approximately 6 million to 25 million salmonid smolts per year, according to a 1999 USACE report. Is the Bureau saying that not only did they bring more fish-eating birds into Klamath Basin, but they have not studied the predators’ devastation on our many endangered fish in the region?

Another major fish predator you mentioned is the Cormorant. The U.S. Army Corp of Engineers estimates that cormorants kill and consume about twenty million salmon smolts each year in the Columbia River estuary.

 

Models used to mandate river levels go by chosen years to establish a historical average of levels. Historical guesses on quantities of fish are given to establish water level and flow mandates to try to attain numbers of Endangered fish, including salmon and suckers.

 

When it comes to historical land use, you use data of how many acres are now farmed compared to when this was a lake.

 

But when it comes to fish eating birds, there is no history from when the terns were introduced, and no studies, and no control of these predators. And regarding the land where Clear Lake Reservoir is, where many predatory birds thrive, that land historically was a meadow. There were no suckers, cormorants, terns. We Project irrigators built Clear Lake to store excess water for irrigation, you made it into a refuge on public land that we can not enter or view, and you mandated lake levels and fish counts although no fish lived in this historic meadow.
 

Your fish counts describe 10’s of thousands of suckers in the various areas. We asked in 2001 how many fish it takes to get them delisted since their endangered status is used to take our water. We have yet to get an answer from the various government agencies making demands on us farmers and ranchers.
 

In your EA proposal, partly because of fish predation by birds, you are taking my deeded water to leave more water in the lakes so these birds you’ve brought in won’t eat as many baby fish on the shoreline. You haven’t studied the results of this predator relocation. But I am supposed to get less irrigation water, pump more groundwater, somehow fallow our perennial crops more often and expect them to live, fire our labor that will relocate because we haven’t enough water for our crops. And then we are told that we are conspiracy theorists if we think our government is trying to get rid of us like in 2001, when the National Academy of Science said the water shutoff was not justified and lake level and river flow management is wrong. We lived through our neighbors’ suicides, heart attacks, auctions, and the mass exodus of farm labor, families that had lived here for decades.

 

Throughout the document, every problem throughout the Klamath River Watershed seems to be blamed on the Klamath Project Irrigators.  Only 3-5% of the water at the mouth of the Klamath River originates in the Klamath Project.

You additionally mention protected fish predators Lamprey.  Where are the results of their damage?
 

Also, according to your final BA, the affects of lake levels below 4142 has not been directly studied.

 

You state, “Current peer reviewed literature suggests that there is little or no relationship between water levels in UKL and water quality parameters (Morace, 2007; Wood, 1996; and NRC, 2004).” However you plan to raise lake levels and river flows at the expense of the irrigators.

 

Before devastating our entire farm community, lifestyle, economy, and aquifer, we suggest you actually study the predation of the relocated Caspian terns and other predators in our backyard and give us more time to respond.

 

We do appreciate that you were kind enough to specify how much damage to our water supply, groundwater, and our economy and workforce would be caused by your proposed EA.

 

I’d ask that we could be part of creating the EA rather than read a document composed by others when we are most affected  and devastated by the results.