The following is my column
that will appear in the Pioneer Press next week
regarding the CIP.
Marcia Armstrong, Siskiyou County Supervisor
9/10/04
On Thursday, September 16, the Klamath Bureau
of Reclamation will hold a meeting from 6-9 p.m.
at Miner's Inn in Yreka on the basin-wide
Conservation Implementation Program (CIP.) A draft
CIP is available online at
http://www.usbr.gov/mp/kbao/docs/CIP-ProgramDoc.pdf
Personally, I dislike the plan because:
(1) It attempts to extend the reach of federal
agencies far beyond the scope of their spatial and
statutory jurisdiction, delegated authority and
requirement to mitigate incidental take for their
actions under the Endangered Species Act (ESA);
(2) Ignores and disrespects County
constitutional jurisdiction and authority in land
planning and in protecting public health and
safety in matters of resource use;
www.sisqtel.net/~armstrng/cntyjurisd.htm
(3) Smacks of regional government, distancing
decision-making hundreds of miles away from
affordable local access by those directly
affected;
(4) Sets up unelected, unaccountable
committees of interest groups to make decisions
over things like water use, watershed and resource
planning - in other words, your property; and
(5) Duplicates and over-lays existing planning
efforts such as the SSRT (Scott and Shasta
Recovery Team) and Watershed Plans and creates a
large new bureaucracy.
Under the federal Endangered Species Act
(ESA,) a "biological opinion" (BO) was completed
for operation of the Upper Basin Klamath Project
2002-2012. NOAA Fisheries (formerly NMFS) gave the
BoR a list of things to do related to the Scott
and Shasta Valleys to protect or "mitigate"
(counter-balance) the Project's impact on listed
coho. Among these "reasonable and prudent
alternatives" were:
(1) The restoration of wetlands in the Shasta
Valley.
(2) Studying development of Shasta and Scott
groundwater resources to replace surface water use
in those valleys.
(3) Use of non-government organizations (NGOs)
to acquire water rights totaling 25,000 acre-feet
in the Scott and Shasta Valleys. (The intention
was to find water flows outside of the Klamath
Project that would contribute 43% of the flow
required from Iron Gate Dam for the Klamath River
under the coho Biological Opinion.)
In addition, the BoR was directed to develop a
comprehensive basin-wide plan for ecosystem
restoration and scientific research through 2012.
The plan was to be developed by "networking
stakeholder groups" in the basin. It would then
provide direction for activities on the federal,
State and local level, as well as for interest
groups. It was envisioned that the program would
be built around of the Oregon Resource
Conservation Act of 1996 (ORCA P.L. 104-208, Title
2, Section 201) to promote ecological restoration,
as well as economic development and stability.
The purpose of the CIP is to: (1) largely
restore the Klamath River ecosystem to achieve
recovery of the Lost River and Shortnose suckers
and substantially contribute to the recovery of
Coho salmon; (2) contribute to the Tribal Trust
responsibilities of the Federal government to
provide harvestable fisheries; and (3) allow
continued, sustainable operation of existing water
management facilities and future water resource
improvements for human use in the Klamath River
System.
As proposed, the resulting CIP would establish
a new basin-wide bureaucracy complete with paid
federal staff. It is envisioned as an umbrella
program to coordinate all other programs in the
Klamath system. At the top would be the "Policy
Administration Group" (PAG) made up of the Tribal
Chair, BoR Regional Director and Area Manager, a
representative from the Governors' offices,
Agencies, CIP administrative officers and the head
of the CIP participant's organization. They would
ensure the plan is directed toward CIP goals,
approve or "ratify" committees or groups that
would implement the CIP, and oversee funding and
authorization.
Next in hierarchy is the "Coordination
Council" (CC.) This council is made up of one
representative of each of the CIP "Participants."
(Watershed Councils, Klamath Water Users, Hatfield
Working Group, Klamath Basin Coalition, etc.) They
will make recommendations to the PAG concerning
annual work plans and budgets; provide fish status
reports and progress reports to Congress and
tribal councils; and direct activities of the
various committees. These "Participants" will be
required to agree to pay for this new bureaucracy
and the implementation of its plans in order to
participate.
The next level is that of the various
committees These include the Public Involvement
Committee (PIC,) the Science/Peer Review Committee
(including various sub-committees;) the Water
Quality Committee; and the Tribal Trust Committee.
The PIC will include one appointed member from
each organization. It's function is basically to
distribute educational and informational material.
You, the public, will be allowed input into
the decisions affecting your property by these
unelected groups and agencies by attending
meetings often scheduled in Klamath Falls or on
the Coast and speaking at the limited "public
comment" period scheduled on the agenda.
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