Klamath Basin Hydroelectric Project FERC letter from Marcia Armstrong 111806

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"This was my comment today at the FERC hearing in Yreka," Marcia Armstrong, Siskiyou County Supervisor District 5, November 15, 2006

FERC Project P2082-027 Magalie Roman Salas Secretary
888 First Street NE Washington, DC 20426COMMENT POINTS: FERC WORKSHOP, 11.15.06

RE: Draft Environmental Impact Statement (DEIS) for the relicensing of the Klamath Hydroelectric project

Siskiyou County is approximately 6,600 square miles large. Four of PacifiCorp's Klamath River Hydroelectric Project developments, (Iron Gate, Fall Creek and Copco 1 and 2,) are located in Siskiyou County, as is a portion of the Wild and Scenic River area between J.C. Boyle and Copco
1. Siskiyou County has been, and continues to be, a participant/intervener in the application, FERC and Settlement Group processes.

I believe the project should be re-licensed for the following reasons:

· The public benefit from the production of 151 megawatts (mw) of clean electricity, especially the production from peaking operations, is clearly needed especially during periods of peak load demand. In addition, I feel the project does supply some flood control benefits that can be critical to residents downstream of Iron Gate Dam.

· There are proposed license conditions to mitigate for the effects of the hydro-project which will increase fish spawning and rearing habitat, enhance wildlife habitat, support recreational opportunities, and protect the quality of the environment.

I realize that FERC must incorporate final mandatory conditions consistent with other applicable law and also use the facts as determined by the Administrative Law Judge in the Hearing on Issues of Material Fact. At this time, I support the Staff Alternative as an improvement to PacificCorp's Proposal as presented in the DEIS for the following reasons:

· The loss of electricity production from peaking operations under agency preliminary mandatory conditions would be irreversible and irretrievable.

· An anadromous fish restoration plan and an adaptive approach are the best strategies to achieve anadromous fish restoration. Fish passage/byways that are fish-effective, as well as cost effective, still need to be determined. Not all necessary information is known at this time.

The Staff Alternative allows for the public benefit that derives from power generation, while complying with requirements of the Wild and Scenic Rivers Act to protect and enhance the Outstandingly Remarkable Values (ORVs) associated with the designated river segment below the JC Boyle powerhouse in Oregon; as well as the eligible segment continuing from the California border down to Copco Reservoir. The Administrative Law Judge has ruled in the Hearing on Issues of Material Fact that the BLM preliminary mandatory conditions significantly diminish Class IV+ whitewater boating and trout fly-fishing. In addition, Oregon has designated the Oregon portion of the river below J.C. Boyle as a Scenic Waterway, and dam removal may violate Oregon law as well.

There is no substantial or clear evidence that dams must come out to mitigate for project effects. In fact, there are many negative impacts of dam removal:

· More than 20 million cu. yds. of fine sediment exist above the dams that would be mobilized down river to cement-in spawning beds, destroy populations of invertebrates and smother salmon eggs. This would likely have significant, irreversible, and irretrievable effects on fish, prey species, invertebrates, and other elements of the river ecosystem immediately upon breach and for decades following.

· Approximately 1,500 privately owned parcels could suffer depreciation in value due to: loss of shorefront property; loss of water access; loss of lake views; loss of recreational opportunity; impacts of the deconstruction process; and impacts of muck and mire until the area is rehabed and revegetated.

· There would be a substantial resultant loss of tax revenue to Siskiyou County and California for the facilities and any diminishment of property values.
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In addition, I would like to note that the DEIS analysis of the retirement of Copco I and Iron Gate Dams does not contain a robust assessment of significant adverse economic impacts on Siskiyou County, affected residents, and businesses doing business on the Klamath River, nor does it propose mitigations to offset these impacts. That analysis should be included in the Final EIS.

Thank you for this opportunity to comment.

Sincerely,

Marcia H. Armstrong Supervisor, District 5 Siskiyou County P.O. Box 7750 Yreka, CA 96097