Water Board evaluates the Klamath Dam removal without a final plan by FERC

January 21, 2019

Letter to Siskiyou Daily News by Richard Marshall, President SCWUA

Re:      EIR Draft Water Board Klamath River

Recently Siskiyou Daily News carried a story regarding the submittal by the State of California Water Board supporting removal of the Klamath Hydroelectric facilities. We have reviewed Vol I, approximately 1800 pages, from the Water Board EIR.  Vol II which is nearly 6,000 pages has not yet been reviewed but consists primarily of public comments.

Our review of Vol I indicates that the Water Board which is making a report essentially to approve a project for which the definite plan from KRRC is yet to be approved by FERC and for which there remain serious questions, which have yet to be answered, and thus falls far short of being a legitimate product.  How can the Water Board evaluate the situation honestly, without a final plan having been issued by the FERC?

Besides the above the Water Board has not in the document submitted, dealt with the issues we raised in the draft response by Siskiyou County Water Users submitted to the Water Board during the commentary process. These issues included among others:

·       The Historic conditions affecting the Klamath River prior to the construction of the Dams:

o   Reliable historic data indicates that the Klamath River instream flows were always marginal, in the summer months.

o   Reliable historic data indicates that the Coho were planted in the 1890’s and were never a significant species.  They had to be replanted numerous times over the years.

o   The Klamath River, again prior to the dams, had marginal water quality and had a reputation for the development of blue green algae.

·       There is no analysis of how the court mandated instream flows would be maintained, without the dams in place.

·       No analysis of from where makeup water would come.  A BOR report indicated that the cost to find replacement water, in the areas in Oregon, would require nearly $8 Billion dollars of new investment, to create reservoirs on the feeder streams north of Klamath Lake.

·       No analysis of the damage to environmentally challenged species.

·       No analysis of the recently passed legislation by the California legislature to allow the extermination of long nose and short nose sucker fish.

·       No provision to proactively protect the potential environmental damage south of Iron Gate Dam resulting from release of sediments at high water down the river.

o   All protections offered are retroactive and therefore not effective in preventing any damage to the River.

·       No analysis of the impact on the shell life in the estuary at the mouth of the River.

·       No analysis of the impact of the project regarding the Klamath Compact provisions and the corollary provisions related to the Wild and Scenic Rivers Act.

·       No analysis of damage to the economy of Siskiyou County, Modoc County, or other adjacent and directly impacted counties.

·       No analysis of the damages caused by increase in carbon emissions as a result of the elimination of the hydroelectric generation facilities and the resultant use of carbon generating electric production facilities.

In addition to the above we would point out that the information used by the Water Board in its analysis was extremely dated going back to the 2012 EIR data used by the Department of Interior.  This data as we know from the testimony of Dr. Paul Houser, formerly the scientific quality control officer for the Department of Interior, was contaminated and manipulated to influence the decision in regards to the potential removal of the Dams, which is a politically motivated decision.

In short, we find that the report, although voluminous is disingenuous at best, as it seeks to justify a political decision to remove the dams regardless of the consequences.

Siskiyou County Water Users Association

Richard Marshall
President

A complete copy of the DEIR is available for viewing and comment at www.waterboards.ca.gov/waterrights/water_issues/programs/water_quality_cert/lower_klamath_ferc14803_deir.html

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