 Oct
26, 2011
—————————————-
Dr. Richard A. Gierak
Bachelors Degrees in Biology & Chemistry,
Doctorate in the Healing Arts, Director of
Interactive Citizens United, Director of New
Frontiers Institute, Inc. Prior Member of FERC
and FPAT (Fish passage advisory team report) and
HET (Hatchery evaluation team) Prior Vice
President of Greenhorn Action Grange, Prior
California State Grange Spokesman for the Water
Committee, Prior National Whip of the Property
Rights Congress of America, Representative of
the Grange States of California, Oregon,
Washington and Idaho regarding EFH regulations.
Presently science consultant to Siskiyou County
Water Users Association.
5814 Highway 96
Yreka, CA. 96097
October 20, 2012
Response to Executive Study of the EIS/EIR
Public Draft;
KHSA
Dam Removal
The entire proposal for removing four
hydroelectric dams on the Klamath River is to
recover Coho Salmon populations. Reality, and
historical documents clearly indicate that Coho
were never native to the Klamath Basin and the
present listing by California ESA and Federal
NMFS are unlawful, arbitrary and capricious as
there is no provision in the Federal ESA to list
non-indigenous species. Secretary Ken Salazar is
in violation of the Federal ESA as the
Department of the Interior is responsible only
for freshwater species of fish and it is the
Department of Commerce that is responsible for
saltwater species.
Water
Quality Benefits
Water Quality will not improve under
alternatives 2 & 3 as historic evidence clearly
delineates that reservoirs in place allow
detritus to settle out and water quality is
improved with each reservoir in place. Least
desirable water originates at the shallow
Klamath lakes and Keno reservoir and California
EPA Water Board confirms that water quality
continues to improve as it flows downstream when
reservoirs allow detritus to settle out.
Historically in 1913, before dams, the total
number of salmonids counted by California Fish &
Game Commission was 38,000. Five years after the
dam was in place that number rose to over
60,000. This was possibly as a result of the
reservoir allowing detritus to settle out and
water quality was improved enticing more
salmonids to spawn in the Klamath. During the
exploration phase of discovering the Klamath
Basin the troops were faced with water that was
not potable and even their pack animals refused
to drink from the River. The native tribes named
the river Klamath River which translated means
Stinky River. No one wishes to return to this
historical position. Late summer/fall water
temperatures are improved by the deep reservoirs
and reducing the impact of high summer
temperatures.
Algae toxins were evaluated by the CDC
in 2009 and were found to be non-toxic
with exception to those who may be seriously
breathing impaired. There has never been an
incident of an individual becoming ill from
swimming, diving, dredging, skiing or playing in
any of the reservoirs on the Klamath River.
Water
Quality Summation;
I find that California F&G, EPA water Board,
NMFS and USF&W service present unscientific
evidence in their statements that dam removal
will increase water quality based on their own
historical reports.
Quote
from 2009 Water Quality Klamath TMDL scoping
comment responses
-
“The Regional Water Board can not establish life
cycle-based water quality objectives for the
mainstem Klamath River because the DO
concentrations associated with salmonid life
cycle requirements can
not be met even under natural conditions-
Salmonid Benefits
Only reservoirs provide slightly cooler water
benefiting migration of both adult and juvenile
salmonids.
Dam removal will release thousands of tons of
toxic sediment that will destroy salmonid
spawning beds for years to come.
Access to salmonid in the Upper Basin has
historically been refuted as accounts indicate
that any salmonids that reached the area of the
present Copco 1 dam they were non-viable for
spawning and were diseased and useless for human
consumption. As to reaches above Copco there
were reefs that exceeded the height that
salmonids could successfully navigate.
According to California Fish & Game in a
2003 report it is clearly stated that the only
way to control the water flow for salmon runs
are the dams that are in place.
Historically the Klamath River, in a dry year,
would revert to marshes and swamps. This
condition would destroy the Fall Run of Salmon
without the reservoirs storage to supply the
necessary water flow for the Salmonids to reach
their spawning grounds.
Salmonid Benefits Summation;
To cite NMFS data in 1950 the total number of
salmonids landed in the Pacific Northwest was
149,000 metric tons with 80% caught in Alaskan
waters. Since the building of dams and
hatcheries in 2007 the total number of salmonids
landed in the Pacific Northwest was 403,000
metric tons with 97% caught in Alaskan waters
due to the increased rise in temperature of the
Pacific Ocean. There
is little doubt that dams and hatcheries have
been a positive effect on commercial salmonid
production in the Pacific Northwest. In
a 1993 Report by NMFS in their Oceanic report
stated that the El Nino of 1983-1985 devastated
the Coho Salmon population off the coast of
California. Dr. John Palmisano was a Marine
mammal biologist for NMFS in Juneau, Alaska,
taught fisheries and biology at U of Washington.
Also an environmental scientist for a consulting
firm in Bellevue, WA. In 1997: he wrote.
“Coastal waters from Mexico all the way to
Alaska have gradually warmed since the climate
shift of the 1970s and the subsequent, periodic
affects of El Nino.” “It is estimated that 40 –
80 percent of estuarine habitat along the
Pacific Northwest has been diminished or
destroyed”. “It
is clearly not the perceived mismanagement of
inland streams and rivers that has caused the
recent degradation of the Salmonid population”.
There is no doubt that removal of dams on the
Klamath River will force the river to revert to
its original historical condition which will
decimate any future runs of salmonids based on
data from California Fish & Game, NMFS, NOAA,
NASA and the Expert Panel analysis of 2010.
Renewable Energy Power Supply;
According to USGS “Hydropower
is the most important and widely-used renewable
source of energy.” Not
only does the above apply, but, to attempt to
use coal or natural gasses will increase the
production CO2 in our atmosphere. To attempt to
utilize wind or solar the costs would increase
from 300 to 400 percent. At this time these dams
supply over 70,000 individuals in Southern
Oregon and Northern California and removal will
burden these individuals with increased costs
for electricity.
Regional Economic impacts;
Loss of power generation will negatively affect
disproportionally resource based economies in an
already struggling economy.
Sediment impacts;
Significant and deleterious effects on the
aquatic environment and the spawning beds of
salmonids would occur with dam removal.
Historic Distribution in the upper Klamath Basin
Access to salmonid in the Upper Basin has
historically been refuted as accounts indicate
that any salmonids that reached the area of the
present Copco 1 dam they were non-viable for
spawning and were diseased and useless for human
consumption. As to reaches above Copco there
were reefs that exceeded the height that
salmonids could successfully navigate.
KBRA
Effects;
The KBRA will not produce adequate social and
economic benefits from implementation of dam
removal.
Loss of
Reservoir environment;
Dam removal will not only affect
property values but will increase wildfire as
the reservoirs will not be available to fire
helicopters for filling their water buckets in
addition to removing the aesthetic and
recreational value to the County which is
significant.
Flood
Risk;
In 1960 the California The State Water Rights
Board has granted a water rights permit on the
Klamath River to the California Oregon Power
Company for its proposed Iron Gate Dam. “The
move was hailed by local citizens as a boon to
the county. The dam will serve for both power
and flood control, thus lessening flood danger
in the Klamath area“.
SUMMATION;
Based on scientific data and historical evidence
the proposed removal of four hydroelectric dams
on the Klamath River will result in the
following effects:
1. Loss of property values
2. Increased forest fire danger
3. Devastation to Agriculture and jobs
4. Increased inundating floods to
residents downriver.
5. Loss of revenue to the County by loss
of recreational attributes of dams.
6. Loss of Fall Run of Salmon in the
Klamath Basin.
7. Loss of salmonid spawning grounds due
to released toxic sediments.
8. Pandering to eco-terrorists without
any scientific data to support their position.
9. Loss of the planets most renewable
energy source to 70,000 residents.
10. Increased pollution of our
atmosphere by oil based power production.
11. Violation of the Federal Endangered
Species Act by California ESA, NMFS and the
Department of the Interior.
12. Government open disrespect to the
WILL OF THE VOTERS of Siskiyou County wherein at
the November 2010 election the voters clearly
voted 79% to retain the dams for all of the
above reasons cited.
Respectfully submitted;
Dr. Richard A. Gierak
——————————————————————————————————
In response to the Executive study I find that
the language throughout this document are based
on junk science and words such as may, could
should, possibly and a plethora of
inconsistencies that dam removal will do
anything of value for Salmon returns. It is a
travesty of lies and junk science with only one
outcome…… Dam removal.
Dennis Lynch has stated that “this is an
experiment and we have to try to see if it
works“. I must say that when you consider the
mandates of the Department of the Interior your
involvement in the removal of Dams for the
hopeful return of Coho Salmon is unlawful and
should be terminated.
To John Hamilton I must also state that the
involvement of U.S. Fish & Wildlife Service,
under the Department of the Interior, is also in
violation of your Congressional mandates as Coho
Salmon are a saltwater species under the
jurisdiction of the Department of Commerce.
As to Mark Stopher I find that the California
ESA is in violation of the Federal ESA by
listing Coho Salmon as endangered in the Klamath
as there is not one single document alluding to
Coho Salmon being native to the Klamath River.
The recent expert panel report indicated that
the Coho Salmon are from Cascadia, Oregon. In
addition several de-listing petitions were filed
with California Fish & Game and no response was
ever received from them.
The first mention of Coho in the Klamath was
when they were planted in 1895 from various
sources. In 1913 W. H. Shebley, Superintendent
of Hatcheries, writes “There was no
run of either kind of Salmon in the River.”
Based on historical evidence the listing of Coho
Salmon is arbitrary, capricious and unlawful and
should be removed as a listed species. This
would cancel the removal of Klamath River Dams
as the prime purpose for dam removal is the
unlawful listing of Coho Salmon.
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