1.     08/21/15

      "The plan does not address the single largest source of fish kill on the Klamath River – The abnormal water surge (pulse) generated for the two week Hoopa Boat festival.   Normal water profiles should align to the fall precipitation.  The triggering of a “SUMMER” salmon run is a sure method of generating fish kills.

2.       Methodolgy – No outline of contributing factors with assignments of relative magnitude are presented in the outline.

3.       Process fails to adhere to the tenants of the 90/10 rule – that is you obtain 90% of the desired effect with 10% of the effort.  In this case since the Hoopa boat festival is an artificial event – delaying it until normal fall runoff would be the appropriate means of reaching the desired goal.

4.       Removal of the Klamath river reservoirs will only aggravate the problem in drought years.  In accordance with the early explorers and survey log records of the Klamath River.  The Klamath at the confluence of the Shasta River was deemed as fit for neither man nor beast to drink from. Horses refused to drink.  Augmentation from this source is not reasonable or feasible.

5.       Until the fall rains and cooling weather cool the river sufficiently to reduce parasites – all actions which would trigger runs my flow managers should be eliminated – the number one is the pulse of the Trinity with cold water triggering a late summer run when the general Klamath is at its warmest temperature with highest number of parasites.  In drought years without the Lewiston reservoir with no snow pack there would not be a source of water for the Hoopa Festival or this proposed flow augmentation program.

6.       Flow augmentation from the upper Klamath only exacerbates the problems

7.       Review of history and issues -

a.       Drought years – inescapable – there will be lower flow rates, with or without Agriculture. There will be increased die offs if BOR continues its August Trinity Releases for the Hoopa Boat Festival.  The upper Klamath system is an arid alkaline volcanic basin.  The underlying basis does not change.

b.      Sea Temperatures on where the salmon are returning to the coast.  They do adjust their migratory patterns

c.       Marine mammal populations. The impact of the 6000% increase in Sea Lion Populations on the Northern California Coast since enactment of the Marine Mammals Protection Act.

d.      Increased take by off shore commercial fisheries – Salmon are a transpacific fish.

e.      Increased take by the Klamath River tribes for commercial harvesting and sales

8.       Flow augmentation without a sound review of the overall picture is seeking to implement a solution to the BOR generated summer run (not natural) resulting from the Hoop Boat Festival Pulse.  If the runs are returned to their natural order – there is no need for flow augmentation from the Lewiston Reservoir."