Mr. Richard Smith, Natural Resource Specialist
U.S. Fish and Wildlife Service
2800 Cottage Way, Suite-1916
Sacramento, CA 95825

Subject: Comments on Upper Klamath National Wildlife Refuge Proposed Addition

Dear Mr. Smith:

On behalf of Klamath Water Users Association and its member irrigation districts, I offer the following comments:

The process the U.S. Fish and Wildlife Service (FWS) has initiated to transfer ownership of the Agency Ranch and to acquire the Barnes Ranch on the west side of Agency Lake, is based on a Need for Action Statement that has not yet gone through a planning or evaluation process to quantify the benefits resulting from restoration. It appears there aren't any specific restoration or management activities associated with any of the three alternatives. The Water Users do not support any alternative that may reduce the quantity of water available for irrigation of the Klamath Project lands or that is not part of a plan to alleviate Endangered Species Act restrictions on Project operations.

The alternatives, as presented, are nearly the same as they relate to the area involved. Reclamation has leased Barnes this year to maximize the storage potential; all the alternatives include managing both ranches. The question of whether management of the properties by FWS is more beneficial than current management is difficult to evaluate without any proposed management schemes attached to the alternatives.

There is an inference in the planning update that FWS would breach the dikes and Reclamation would not, but the real question is whether breaching the dikes will yield more water or provide more habitat than the current pumped storage management. This is not being evaluated within this process. The current management of Agency Ranch for storage, without breaching the dikes, should always result in a positive quantity of stored water to add to Upper Klamath Lake. While yield from the storage on the properties may increase in some years if the dikes are breached, there is also the potential for a negative effect due to evaporation when Klamath Lake doesn't fill. Average Klamath Lake levels may also decrease, in low inflow years if the dikes are breached. If reduced lake levels and storage are unacceptable in some years, and Alternative 1 does not remove the dikes, then the only option is Alternative 1. If improvements in habitat or water quality that may result with the breaching of the dikes outweigh any negative quantity effects, the other alternatives may be appropriate.

Breaching the dikes may increase the potential for habitat for suckers, but it may also increase the habitat for yellow perch, an introduced predator species known to be abundant in the Four Mile Channel. Large water quality improvements to Klamath are unlikely, but local improvements may be beneficial. The changes to fish habitat and water quality are not being evaluated and so the question whether FWS Refuge conservation goals and purposes will be met cannot be determined. In fact, funding and evaluation of restoration activities is a separate, future process. Again, without any management schemes attached to the alternatives, it is nearly impossible to evaluate the proposal.

Answers to following list of questions would help evaluate the FWS proposal:

1. Can all three alternatives address the need for action?

2. How much funding is required for each alternative?

3. How much future funding is required for restoration in each alternative? Can FWS conservation goals be met if restoration funding does not become available?

4. How would public access be different for alternative?

5. What are the potential benefits to the Klamath Project for each alternative?

6. Does any alternative assume or consider the acquisition of additional agricultural properties adjacent to the ranches?

These are but a few of the questions that need to be answered before the Klamath Water Users Association can take an informed position. We look forward to participating in this planning process. Thank you for your time and consideration.

Sincerely,

Greg Addington

Executive Director

Dave Solem