The Honorable Gordon Smith
404 Russell Building
Washington, D.C. 20510-3704

Dear Senator Smith:

This letter has been prepared in response to the letter sent to your office on January 28, 2004 by WaterWatch. According to the WaterWatch letter, they now oppose even studying the Long Lake storage proposal that our Commission endorsed last year. While I certainly respect WaterWatch’s right to take whatever position it chooses, their letter unfortunately contains several statements that I believe must be clarified as you consider the merits of the Long Lake proposal. I respectfully request that you consider the following perspective.

I applaud WaterWatch for their willingness to consider a range of storage options. However, I question their claim that natural storage through wetlands restoration provides more effective storage opportunities than the clear potential provided by new offstream storage. As you know, thousands of acres of farmland above Upper Klamath Lake (UKL) have already been converted to wetlands in the past ten years. While there may be some environmental benefits provided by these newly created marshes, it is not clear how these wetlands conversions have contributed to water supply improvements, particularly since UKL supplies to the Klamath Project were curtailed in 2001 and nearly curtailed last summer.

The U.S. Bureau of Reclamation’s (Reclamation) draft report on "Undepleted Natural Flow of the Upper Klamath River" shows that the average annual natural net inflow (inflow minus evaporation) to Upper Klamath Lake is approximately 251,000 acre-feet less than historical. This is likely due to the increased water consumption of the prevalent marshland in the upper basin under natural conditions and the increased evaporation from the larger, as compared to historical, UKL water surface area. The decrease in flow compared to historical is despite the fact that historical diversions in the upper basin have been added in the natural flow study, thus creating an increase in overall water supply under natural conditions.

WaterWatch has apparently backed off its original support for a Long Lake feasibility study, based primarily on a recent cost estimate of Long Lake prepared by Reclamation. The Klamath Water Users Association (KWUA) is currently developing its assessment of the Reclamation cost estimate and have preliminarily noted the following:

1. The diversion facilities assumed by Reclamation may be nearly three times the size required to actually fill Long Lake, as determined by modeling that covers the last forty years of hydrologic conditions. The estimated cost associated with a smaller, consolidated diversion facility will be much less than the Reclamation estimate.
2. Reclamation assumes that a new earthen embankment would be required in the Long Lake proposal. Actually, over 300,000 acre-feet of water can be stored in Long Lake – without constructing any sort of embankment.
3. Reclamation assumes that significant lining of the reservoir floor will be required to prevent leakage in Long Lake. This may or may not be the case – it is one of the reasons that must be further studied in a feasibility assessment.

These important findings will likely significantly reduce the construction costs assumed by Reclamation. I will forward this information on to you when KWUA completes its preliminary assessment. While WaterWatch is obviously entitled to dismiss Long Lake based on the Reclamation initial memo, I do not believe it is wise for policy makers to use the Reclamation document as justification to move in a similar direction.

WaterWatch continues to advocate for purchase of farmland as a means of addressing the Klamath water crisis. In response, I know that the practical effect of shifting farmland to habitat will lead to a net increase in water use, threaten a valuable source of food for waterfowl and bald eagles, and decrease the Klamath Project’s overall water efficiency. According to the University of California at Davis Intermountain Research Center, the average consumptive use of all crops produced in the Klamath Basin is approximately 2 acre-feet per acre. Wetlands, such as those in the refuges throughout the Klamath Basin, utilize more than 3 acre-feet per acre. A shift from farmland to wetlands will increase average water use per acre by more than 1 acre-foot.

The aforementioned Reclamation draft study of undepleted flows of the Upper Klamath River confirms that pre-Klamath Project marshlands evaporated and consumed more water than that used on reclaimed marsh now occupied by Klamath Project farmlands. The loss of this farmland would also further strain the food supply for the region’s waterfowl. As the California Waterfowl Association has noted in testimony to Congress, cereal grains grown on local farmland are an invaluable source of food for waterfowl and shorebirds that the refuges cannot provide.

WaterWatch states that the National Research Council’s (NRC) recent final report on Klamath River watershed threatened and endangered fishes recommends a "large scale program to restore upper basin wetlands and portions of Lower Klamath and Tule Lakes." Please note that the report actually proposes the actions in Lower Klamath and Tule Lakes contingent upon feasibility studies and increased control of sedimentation in Tule Lake. Our local community will play an important role in working with government agencies in these preliminary steps, which may or may not lead to subsequent restoration activities.

WaterWatch is correct to point out that the NRC report notes that Lower Klamath Lake historically had an important influence on the Klamath River "by storing and subsequently releasing water into the river". However, the NRC report was released prior to the aforementioned draft Reclamation flow study on the Upper Klamath River. This latter report assesses the significant magnitude of evaporation from historic Lower Klamath Lake. The report suggests that the magnitude of evaporation from Lower Klamath Lake under natural conditions is slightly larger than the magnitude of the net historical diversions (consumptive use) from the Klamath Project. If farmlands are converted to marshes in this area, it would appear that they would use more water, which would leave less water in the system for downstream uses. Thus, I would question how restoring wetlands in the Lower Klamath Lake area will improve water conditions for downstream salmon, as suggested by WaterWatch.

WaterWatch continues to advocate for removing farmers from the leaselands on the national wildlife refuges. As was made clearly apparent in 2002 and 2003 when Rep. Earl Blumenauer attempted to limit agricultural practices on the leaselands, the issue is much more complicated than the WaterWatch letter acknowledges. WaterWatch suggests that restricting agricultural production on the leaselands will provide more water for the refuges. This simple argument is simply incorrect because the Endangered Species Act, Tribal trust requirements and agricultural contracts take precedence over refuge wetlands.  Therefore, it is doubtful that this proposal would produce additional water for the refuges. Moreover, the lease lands consume less than 0.5 percent of the water generated in the entire Basin (assuming 50,000-60,000 acre-feet annual consumptive use and 12 million acre-feet runoff).   

WaterWatch has consistently claimed that agriculture is harmful to waterfowl and other wildlife and is wholly inconsistent with the purposes of wildlife refuges. Actually, farming and conservation can coexist, and Congress itself has recognized the dual benefits of the lease lands within the Klamath National Wildlife Refuge Complex in the 1964 Kuchel Act. Further, according to the California Waterfowl Association, "For nearly 100 years, farmers and ranchers of the Klamath Basin have coexisted with immense populations of wildlife. Many wildlife species, especially waterfowl, are familiar visitors to their highly productive farms and ranches. Klamath Basin agriculture provides a veritable nursery for wildlife."

I am encouraged by WaterWatch’s commitment to work with your office to develop solutions in the Klamath Basin, although I may have different ideas of what those solutions may be. There may well be legitimate future reasons for dismissing Long Lake, or Barnes, or other storage options in the Upper Basin. However, the justification for said dismissal must be solid, and realistic alternatives must be offered up and considered. It is far too early to dismiss Long Lake as a potential viable option that may provide real water to meet the needs of the watershed.

Sincerely,

John Elliott

Commissioner

Al Switzer

Commissioner

cc: Senator Ron Wyden

Rep. Greg Walden

State Senator Steve Harper

State Representative Bill Garrard

Klamath Basin Federal Working Group

WaterWatch of Oregon