(3) A DIFFERENT POINT OF VIEW

(response by Glen Briggs to letter written by Glen Spain to "Glen Biggs" dated June 30, 2009)

The above referenced letter seems to be in response to my (Glen Briggs) paper titled “PLEASE/ Do not Restore My Klamath River” and not to something written by someone named Glen Biggs.  My paper referred to facts and conditions along the Klamath River downstream from the confluence of the Scott River during Fall months when water within the Klamath main stem was low and warm.  There was really nothing in Mr. Spain’s letter that addressed expected conditions within the river down stream from the dams should they be removed.  In spite of that, I will give a different point of view concerning the FACTS included in the above letter.  I wish to thank Mr. Spain for giving me this opportunity.

I have found that FACTS come in many forms. Some are incomplete such as my name in the salutation in Mr. Spain’s letter, some are brightly colored and placed in fancy wrapping in order to make them say more than they really do, and then, somewhere down the line, there is the true or factual fact that holds its form regardless of the amount of scrutiny or varied interpretation applied.

Paragraphs (1) and (2):  There is actually no known historical physical evidence substantiating the fact that Salmon were caught upstream from Upper Klamath Lake.  Certain members of the Shasta Tribe state that tribes from the Upper Klamath Lake area came downstream to catch and dry Salmon within the fishing area ancestral to the Shasta tribes.  Both Hamilton and Huntington use models developed from empirical data that is then applied to tributaries upstream from the Upper Lake.  At one place in Hamilton’s presentation, he reasoned that fish could travel upstream past the Cascades in the Klamath River because they do it in the Columbia River.  The difference in the two rivers is so extreme that this assumption is ludicrous.  Their analysis completely ignores the one pre-dam reference included that says the predominance of the salmon run referred to could not get past the natural barrier and into the Upper Basin.  Also missing from those documents is any reference to any studies done during development of the Klamath Project, development of the hydropower system, or documentation of any kind from either the California or Oregon Departments of Fish and Game as to actual extent of early fish runs in that area.  My instinct tells me that there had to be considerable discussion before the decision was made to settle for a hatchery instead of fish passage facilities.  It seems the main emphasis of the two studies mentioned above was to determine how many anadromous fish the upper basin could accommodate without realistically evaluating just how many are likely to get that far.

Coho Salmon are stated to be a Fall run species and are known to have inhabited the lower Klamath up to the Salmon River and migrating into that river as well as Blue Creek and the Trinity River.  Coho Salmon were not known to resident fishermen fishing the mid to upper Klamath.  They were called Silvers in the lower tributaries referred to above.  Sometime in the late 1940’s Coho were introduced into the mid-Klamath after construction of the dams had improved fall water temperature conditions. This information was relayed to members of my family by a local Warden.  On going Water Quality Studies by the California North Coast Water Quality Control Board puts stringent requirements on water temperatures in their TMDL programs where Coho Salmon are considered part of the resident fish population.  I would think that a thorough search of the California State Dept. of Fish and Game records would reveal some interesting facts concerning Coho.  The above documents make no mention of expected river water temperatures with the Power Dams gone and with large, shallow Upper Klamath Lake discharging warm water, when it does discharge water, and with no source of cooling water to introduce downstream.  Predicted Fall flows and water temperatures are conspicuous by their absence from these documents.  Recent late  summer and fall studies sponsored by the U. S. Bureau of Reclamation has shown that with  releases of 500 CFS, river water temperatures are not cooled by incoming tributaries until you get to Seiad Valley and then between there and Orleans, water temperature cools by about 4 degrees.  I have yet to see the facts that will make me believe that river water temperatures after dam removal will be any different than they were 150 years ago.  Are you going to shut off all volcanic inflow in order to accomplish the TMDL’s?

True, salmon dying after spawning will contribute to stream pollution. However, in the case of the Klamath River, conditions described by Mr. Gibbs along with occurrences past on by earlier members of my family indicates more than just that.  Mr. Gibbs was trained as a lawyer in one of our country’s premier universities, and, like it or not, one of the benefits of being exposed to the educational process required of prospective lawyers is that it forces one to learn to think.  You can scoff at the conclusions described in his Journal; however, an open minded review giving due credit to conditions he was encountering along with the small amount of knowledge available for the area being studied should lead you to the conclusion that Mr. Gibbs was very capable both physically and mentally.

Before completion of the first Power Dam across the Klamath, my family, living in the Mid-Klamath area, experienced episodes where the stench from dead fish was so great that the children were told to take sharp sticks to throw the fish back into the water.  A past brother-in-law of mine who happened to be a fisheries biologist some years back with California Dept. of Fish and Game confirmed from Fish and Game records that at least some of these episodes were the result of diseased fish.  This along with the notation by Gibbs that the salmon looked diseased only a short distance inland has to tell a story.

ARMY RATIONS for the Lewis and Clark expedition!  You have got to be kidding!

Paragraph (3):  I must admit that I will choose to stay at the disadvantage in these discussions because I do not wish to scan the FERC files which in my opinion have been padded with colored and incomplete facts in addition to much reliable information.  I will stay with the knowledge I have acquired over the years and, though it may be as incomplete as the above referenced studies, I am comfortable with it.  First, water coming to the reservoir already contains nutrients and, also, that portion of it that has passed through Upper Klamath Lake already would contain the toxins if such toxins are carried downstream instead of dissipating.  The top few feet of the reservoirs are normally heated by the sun’s rays; however, colder water settles to the lower depths, something about the density of cold water, and the sun’s rays have little effect on this cold water.  Toxins that do not dissipate would generally be found within that top few feet of warm water or within the organic sediment.  Upper Klamath Lake, being a shallow lake would not have the benefit of colder water at depth plus it has whatever warming local hot springs might generate so I have a problem with your contention that water from the reservoirs kill off the salmonids and yet you say hundreds of thousands will pass through Upper Klamath Lake successfully.  Water for use in the hatchery is drawn from the reservoir just a few feet below the surface and yet the hatchery has been able to operate successfully.  Suction dredge mining has been a popular activity in the Klamath River for a number of years.  These miners stay under water in the Klamath day after day with no apparent ill effects.

It is true that salmon living within the waters of the Klamath are subject to different diseases and some of these diseases kill off large numbers of the young and others large numbers of the adults.  Be this as it may, I know of no study that relate these diseases to the Dams.

Paragraph (4):  Cost studies and conclusions referred to in this paragraph are incomplete in their overall cost analysis; therefore, I will hold off comments pending completion of presently planned studies.  The CEC letter strikes me as being more oriented around assumptions and suppositions than true and complete all around analysis.

Paragraph (5):  Comprehensive studies presently being planned should determine toxicity of sediments and a pretty fair guess of total quantity.  Existing sediments will probably contain a fair amount of organic material from the algae so if it is not toxic, just where does the toxicity exist and for what period of time?  Whatever sediments sent downstream by whatever means will end up coating the banks along the river for decades.  Sand, silt and other fine sediments thrown up along the river by various high waters back to and including the 1964/5 flood still coat the banks in many places.  If sediment from the reservoirs contain toxins or other toxic material, it will be a threat to wildlife along the river for generations.

Paragraph (6):  To reason that the dams should come out just because they only represent  a very small percentage of the companies overall generating capacity is not good reasoning.  This power is renewable with the energy removed from the falling water having no side affect on the physical world around this source of power except possibly erosion of the streambed for a short distance downstream.  With the Klamath, loss of renewable gravel source through the dammed area would not be great, especially with Upper Klamath Lake in close proximity upstream and with many mountain tributary streams downstream acting as replacement sources.  Whereas, continual expansion of wind farms should be expected to have a changing affect on weather patterns in those areas.  Winds are created by differences in atmospheric pressure which could be subject to change with interruption of the air movement.  I have seen nothing speaking to this possible problem and, if it has not been investigated, it should be.  If I remember my lessons correctly, there is no action without a reaction.

"Dear Glen Biggs....

Thanks for the detailed and thoughtful comments -- much more so than many I receive -- so I owe you a similar response. Here are a few other facts for your consideration. As a hard-headed engineer by training and trade, I am sure you will find them interesting and be unable to ignore them in your thinking like myself, even though they do disagree with some of your premises. Facts are very annoying things to wish away, as any engineer knows well, and are ignored at one's peril.

(1) All historical evidence is that spring and fall run chinook salmon and steelhead were once abundant throughout the Upper Basin, including in the Williamson and Sprague. See Hamilton, et al. (2005) attached for a peer reviewed historical review of those facts. Coho did not occur, so far as we know, above about the current position of J.C. Boyle because river gradients are too steep (i.e., a natural barrier) but were common between the CopCo dams and Iron Gate Dam until the 1960s when Iron Gate was constructed -- a loss that was never mitigated by the way, contributing to their current ESA listing. Chinook and steelhead, however, go much further up to the farthest tributary they can get to and tolerate much steeper gradients.

(2) Best estimates we have from both historical record and habitat typing is that the historical pre-European spawning runs of salmon in the Klamath basin averaged about 880,000 annually, ranging from about 660,000 to 1.1 million. Most were chinook, with spring chinook predominating in the upper basin co-existent with large runs of steelhead. Even today, nearly 600 stream-miles of once fully occupied salmonid spawning and rearing habitat would be available, according to biologists expert in this field, if the dams were removed and full volitional passage were possible. See Huntington (2006) also attached. He estimates more than 100,000 additional salmon could utilize that additional habitat, even under the currently degraded conditions (which, by the way, numerous clean water TMDL programs are working to clean up).

By the way, with that many fish carcasses from spawning runs, the mainstream river water quality would have naturally been a little dicey while they were decaying in some places. This would have been VERY good for many other species if not man, enriching the river insect life enormously for the next generation of emerging juveniles in a natural cycle we have largely disrupted. But humans such as Gibbs think in human-centered terms, not in terms of ecosystem benefits -- especially lawyers! Gibbs was obviously no biologist.

The Gibbs story reminds me of the Lewis and Clark expedition, that had never seen salmon before. One of them timidly tried it, and it was so rich a meat (compared to their Army field rations at least) it made him sick (or so he thought), so the rest of the expedition on his word and example considered salmon to be poisonous and they all completely avoided eating salmon even though this rich source of protein was all around them. Instead they traded with the Columbia River tribes and bought pet dogs to eat. The Indians thought they were stark raving nuts! History is often made of such misunderstandings.

(3) The reservoirs themselves retain nutrients, they warm water to near fatal levels for salmonids, encourage the growth of toxic algae (dangerous to humans, including reservoir landowners as well as to fish), and create MAJOR water quality problems far downriver. The FERC Final EIS is loaded with pages and pages of analysis and documentation on these water quality problems created by the dams themselves in their reservoirs. The FERC FEIS also documents numerous other problems created by the dams for water quality generally, which are killing off much of the lower river salmon runs (heating and de-oxidizing the water, encouraging fish pathogens to multiply, starving the lower river of spawning gravel recruitment, etc.). This should be required reading in this debate. You can download it from the FERC website www.ferc.gov, using the Docket Search function in the eLibrary under Docket No. P-2082-027 -- the Klamath relicensing proceeding. The date is Nov. 2007. Until you have read this, you will have few of the actual facts to debate with and I will have you at an extreme disadvantage in these discussions (grinning).

(3) There is no "status quo" here concerning the dams -- there are only two choices facing PacifiCorp -- retrofit the dams to modern standards pursuant to federal agency "mandatory prescriptions" (including fish passage) for a new license, or abandon them entirely and invest elsewhere. Those are the ONLY two choices legally available to the company, and both will cost a fair bit of money. The only question is which is better economically and environmentally.

(4) Several current engineering and cost analysis studies, including those of the California Energy Commission (CEC) (which does power project cost benefit analysis all the time) and one by FERC itself -- both of which know a thing or three about dams -- say it will cost MUCH more money to retrofit the dams and keep them (fish passage plus some 120 other mitigation measures cost money) than to simply remove them and invest the money more wisely elsewhere.

I attach a letter from the California Energy Commission itself to the Oregon PUC (I presume you live in Oregon -- if not, they said the same thing to the PUCs of CA and WA) which makes the strong case that PacifiCorp's customers should not have to pay for keeping the dams because removing them and reinvesting in something much more cost efficient elsewhere is by far the best economic option -- and by $114 million cheaper. Plus mere fish passage is likely to be ineffective, and keeping the dams does not really solve the Clean Water Act problems the dams create.

Oh... as a capper FERC in its FEIS found that dam removal costs would be about $79 million (as compared to $360 plus for FERC relicensing according to the CEC) and that, even if licensed, the dams would still LOSE MONEY EACH YEAR -- about $20 million per year -- and therefore were simply no longer cost effective as dams (see FERC FEIS Table 4-3 on Page 4-2). In other words, they are functionally and economically obsolete.

(5) Although several sediment studies have already been done, and although they are not yet comprehensive, NO toxic sediment problems of any sort have to date been discovered. Dioxins, for instance, are at natural background levels. There are no heavy metals -- the upper basin was not mining territory, nor heavily industrialized but a farming community.

There is also not anywhere as much sediment build up as once thought, making it much less of a problem to simply wash sediment through naturally in a season, with a little bank stabilization (normal procedure = planting grass seed and trees) to help limit the silt. So far -- sediment is simply not a problem. Several of those sediment and other studies have been collected on a Yurok Tribe web site at:

http://www.yuroktribe.org/departments/fisheries/Dam
RemovalStudies.htm

Don't take my word for it, go to the sources. In any event, these preliminary studies will be confirmed by much more detailed studies starting this summer, under the NEPA process the Secretary of Interior will be going through to make a final removal vs. relicensing decisions in March 2012.

(6) Finally... the four dams combined generate only a miniscule amount of power by modern power plant standards -- only about 88 MW average over the 50-year lifetime of the last license according to FERC records. This represents only about 1.5% of PacifiCorp's overall generation. Since the capacity of one modern gas-fired power plant is between 800 to 1400 MW, you see that PacifiCorp investing elsewhere in more efficient power plants makes a lot of sense as a business decision.

Also, it is relatively easy for PacifiCorp to replace this minimal amount of "green power" with equivalent green power elsewhere. When the company was purchased by MidAmerican Energy Company a couple of years ago, the PUCs made them promise to install an additional 1,200 MW of green power "renewables" anyway over the next ten years. The mere 88 MW necessary to fully replace the power from the dams is only a very small amount (7%) of what they plan to do anyway.

One modern wind farm, by the way, can contain 100-200 wind turbines. Each turbine has a full capacity of about 6 MW now. Even running at half capacity average, therefore, you can replace ALL the power generated by ALL the Klamath dams by just 30 wind turbines. This is hardly going to be difficult.

(7) As to flood problems -- you recognize that these are not flood control dams. The total storage capacity of all the dams combined for flood storage is only a few hours, a couple of days at most. Also, Keno dam will remain as a flow regulation dam. All in all, any fears of future floods are, in the opinions of the experts who have looked at it, essentially no more than they are today with the dams in. But that too will be analyzed more carefully in the next couple of years to make sure.

Now... tell me again, in light of the above, why PacifiCorp should KEEP dams that will lose them money, will not solve their environmental problems, will continue to violate several federal laws, and will cost you -- the ratepayer -- nearly twice as much as taking them down?

As an engineer you know that dams are human constructs designed and built to serve specific purposes. When those structures become obsolete or economically unfeasible, or they no longer serve those purposes, as a society we typically go on to something that works better. This is why we buy occasional new cars instead of patching up old clunkers that would cost more to patch up than purchasing a new one. This is the situation PacifiCorp finds itself in today -- trading in its current Klamath clunkers for something that will serve its customers the same power benefits but much cheaper than relicensing 90 year old obsolete technologies.

Our view is that dam removal will also benefit the fisheries, both lower in the river by removing the environmental water quality problems that are killing up to 90% of the juveniles each year, and by restoring access to historic habitat to expand the population. I have seen nothing in your argument that has not already been considered and rejected as a reason not to proceed with the obvious solution -- dam removal and river restoration.

Cheers, and again thanks for your comments. I cannot promise to respond, but I do read and keep comments like yours for future reference, and think about them carefully.

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Glen H. Spain, Northwest Regional Director Pacific Coast Federation of Fishermen's Associations (PCFFA) PO Box 11170, Eugene, OR 97440-3370
(541)689-2000 Fax: (541)689-2500 Web: www.pcffa.org Email: fish1ifr@aol.com