Bureau of Reclamation
2800 Cottage Way
Sacramento, CA 95825
California Department of Fish and Game
619 Second Street
Eureka, CA 95501
Sent via email to: firstname.lastname@example.org and KSDcomments@dfg.ca.gov.
December 30, 2011RE:
Ms. Vasquez and Mr. Leppig,
On September 15, 2011, the U.S. Department of the Interior (Interior) and the California Department of Fish Game (CDFG) (collectively, the Agencies), with input from the State of Oregon, jointly released the Klamath Facilities Removal Impact Statement / Environmental Impact Report (EIS/EIR), analyzing the potential impacts to the environment from removing four PacifiCorp Dams located on the Klamath River in California and Oregon. In response to this document, Trout Unlimited offers the following comments.
Trout Unlimited (TU) is the nation’s largest coldwater fisheries conservation organization,with more than 140,000 members nationwide dedicated to the protection and restoration of coldwater fisheries and their watersheds. TU has a long history of engagement in restoration efforts in the Klamath Basin and was a signatory to the Klamath Hydropower Settlement Agreement (KHSA) and Klamath Basin Restoration Agreement (KBRA).
Trout Unlimited supports removal of four dams consistent with the KHSA as a carefully balanced and environmentally preferred approach to resolving decades-old disputes in the Basin over water, ecology and economies and to reverse the continuing environmental degradation in the Klamath River. Specifically, we urge the Department to Adopt Alternative 2 (full removal of 4 dams) as the environmentally preferred alternative and encourage the Secretary to take Action as outlined in this alternative.
While we believe that Alternative 2 is the most comprehensive and environmentally beneficial alternative, we also recognize that Alternative 3 (partial removal of 4 dams toachieve a free-flowing river) may provide similar benefits with possible reductions to short-term environmental impacts and cost.
The evaluations and conclusions of the EIS/EIR make clear that full or partial removal of the four Klamath River under the KHSA would provide significant beneficial effects for the environment, economies and communities in the Klamath Basin. Dam removal allowing for a free-flowing river would restore more normal water temperatures in the river, eliminate toxic algae blooms from reservoirs, improve water quality and allow for increased recreational use of the river, ensure a predictable supply of water for farmers and for fishand wildlife, and increase salmon and steelhead productivity - providing a much needed boost to the recreational and commercial fishing economies.
Improved Conditions for Native Fish Populations:
Facilities removal as contemplated in the Proposed Action would result in significant benefits to fish populations in the Klamath River system. While dam removal and associated activities would have short-term impacts to fisheries – primarily related to sediment releases – these impacts are anticipated to be short-term and will not impact the long-term success of the affected populations. On the contrary, the EIS / ER predicts improved long-term conditions for all native fish populations. That conclusion is well founded.
Key benefits include:
• Water Quality: Dam removal would result in significant improvements to water quality within and below the Hydroelectric Reach including improved levels of pH and dissolved oxygen, reduction or elimination of algal toxins and improved river temperatures;
• Water Quantity: Dam Removal as described in the Proposed Action would improve base flows for salmonids and provide the opportunity for beneficial flushing flows along with the elimination of harmful peaking flows in the Hydroelectric Reach;
• Restored Connectivity / Habitat Quantity: Dam removal would significantly increase the amount of available habitat for anadromous fish by providing access to at least 49 tributaries upstream of Iron Gate Dam which could provide 420 miles of habitat. In general, the EIS/EIR concludes that the Proposed Action would provide the“greatest possible benefit related to fish passage, hence, the highest survival and reproductive success;”
• Habitat Quality: Dam removal would improve the quality of habitat available to fish in the Klamath River system by maximizing gravel recruitment within and below the Hydroelectric Reach (which would benefit spawning); Dam removal would also provide for a more natural flow pattern and more stable stream bed;
• Reduction of Fish Disease and Parasites: The Proposed Action is expected to reduce impacts on salmonids from diseases by reducing the primary factors contributing to parasitic fish disease.
In addition to these general benefits and improvements, the Proposed Action would also have the following additional species-specific benefits:
Full facilities removal will greatly benefit populations of Chinook salmon, with 80 percent increases in run size. Dam removal would restore connectivity to 420 miles of habitat in the Upper Klamath Basin for fall and spring-Run Chinook, and would also create additional spawning and rearing habitat within the Hydroelectric Reach. The Proposed Action will increase abundance, productivity, population spatial structure and genetic diversity of fall and spring-run Chinook salmon in the Klamath River watershed.
The Proposed Action would provide access to at least 68 miles - and possibly as much as 82 miles - of historic coho habitat for spawning and rearing. This expanded access will improve the availability of spawning sites, result in additional food resources and provide access to areas of better water quality. While elevated levels of Suspended Sediments would degrade critical habitat for Coho in the 3 to 4 months following draw down of the reservoirs, bedload movement following dam removal is expected to distribute sediments and, ultimately, result in habitat improvements.
The Proposed Action would restore connectivity to 496 miles of historic steelhead habitat in the Upper Klamath Basin and would create additional habitat within the existing Hydroelectric Reach. While the effects of suspended sediment under the Proposed Action are expected to result in significant negative impact to summer and winter steelhead in the short-term (particularly for mainstem spawners upstream of the Trinity River), the spatial distribution and life-history variability observed in steelhead indicates that the population will be able to avoid the most serious effects of the Proposed Action. Despite the short term impacts to steelhead under the Proposed Action, the EIS/EIR concludes that, overall,the Proposed Action would increase abundance, productivity, population spatial structure and genetic diversity for summer and winter steelhead within the Klamath Riverwatershed.
The Klamath River system is already one of the world’s best places for steelhead fishing. Dam removal would result in long-term improvements to the health of steelhead in the basin, which in turn will result in improvements to the recreational value of this fishery.
Improved Recreation opportunities:
Recreational users will benefit from these improved river conditions. Removal of four dams will eliminate recreation associated with project reservoirs and whitewater boating releases from the hydro project. However, a free flowing river will result in additional new recreational use by boaters, anglers and others. The evaluation also indicates that a free flowing river will significantly reduce the existing toxic algae blooms, which currently restrict recreational access and use.
The EIS / EIR anticipates increased recreational fishing visits related to both Ocean and In-River Sport fishing as a result of improved numbers of salmon and steelhead following dam removal. Positive increases in recreational usage are greatest under Alternatives 2 and 3. According to the Oregon Dept. of Fish and Wildlife, hunting, fishing and wildlife viewing infuses $23 million annually into the economy of Klamath County alone. The improved opportunities for recreation will further support recreation economies.
Benefits to Jobs and Economy:
Removal of four dams not only provides the greatest environmental benefit, but this approach also bears the greatest economic benefit for the basin. In addition to positive environmental changes, removal of these four dams will result in a positive impact to the local economies in the basin. Although the EIS/EIR estimates that removing the dams would cost about 50 jobs tied to generating electricity at the dams, it is also projected to create more than 4,000 jobs, including about 1,400 for the dam removal itself and between70 and 695 farm jobs owing to a more reliable water supply. Additionally, the EIS/EIRconcludes that dam removal will cost roughly $290 million – significantly less than previous $450 million estimate and well within the range of the budget outlined in the KHSA.
Improved environmental conditions resulting from a free-flowing river will also result in long-term improvements to the commercial fishing industry and coastal communities who depend on healthy fisheries in the Klamath River system. The Klamath River historically supported one of the largest salmon runs on the entire west coast. Construction and operation of the Klamath River hydro system – along with other impacts – lead to continued declines of these populations. In 2006, low returns of salmon to the Klamath forced a near total shutdown of the West Coast salmon fishery, resulting in significant job losses and damage to coastal economies. Removal of four dams will dramatically improve conditions across hundreds of miles of habitat for anadromous and resident species of native fish – including populations of salmon and steelhead.
Dam removal would benefit salmon dependent Tribes by improving water quality and increasing abundance of salmon for harvest for subsistence, cultural practices and commercial uses. Alternatives 2 and 3 are found to have the greatest benefit for IndianTribes.
Farmers and Ranchers:
In addition to the benefits described above, the Proposed Alternative will benefit local agricultural industries. Agricultural production in Klamath County and Tule lake Irrigation District contributes over $600 million to the economy each year and 4,890 direct/indirectly induced jobs are supported each year between the states of California andOregon. Historically, millions of tax dollars have gone to farmers, ranchers, tribes and commercial fisherman because of drought and disaster assistance. The approach of The Klamath Agreements will save taxpayers money and improve water distribution for all. The agreements are good for people, fish and wildlife and are fiscally responsible. This approach is currently supported by fifteen irrigation districts, representing 95% of the acres irrigated from the Klamath River/Lake system.
Protection of Ratepayers – Removal of Four Dams is the Fiscally Preferred Alternative:
Removal of the four Dams under the KHSA protects ratepayers and provides a financially preferred alternative to continuing through the FERC process (as would be required underall other Alternatives). Through the FERC process – these facilities must either be relicensed or decommissioned. In order to obtain a new license, PacifiCorp will be required to implement significant facilities upgrades (including installation of fish passage facilities) and operational changes (including reduction of peaking operations) to bring the project into compliance with current law.
These upgrades and improvements would cost at least $460 million, an estimate which could increase significantly following water quality compliance review and assignment of any mitigation requirements as needed to meet state water quality standards. On top of these expenses, relicensing would result in operational changes that will significantly reduce profits. In fact, FERC estimated in its 2007 Final Environmental Impact Report(FEIS) on relicensing that even if fully relicensed, the required retrofitting would be so expensive that these dams would then operate at more than a $20 million/year net loss. Alternatively, PacifiCorp could pursue project decommissioning, the cost of which isestimated at $290 million.
Under either approach, the cost of a FERC relicensing or decommissioning will be passed on from PacifiCorp to its ratepayers. Under the Proposed Action – removal of four dams consistent with the KHSA – rate payer cost is capped at $200 million. This cost-cap provides protection to ratepayers under the KHSA; no similar protection related to costs incurred through a FERC relicensing or decommissioning proceeding.
Removal of four dams under the terms of the KHSA protects rate payers and provides a financially preferred alternative to project relicensing. Both the California Public Utility Commission and the Oregon PUC ruled that dam removal is in the best interest of PacifiCorp customers.
Healthy River for a Healthy Community
In addition to the benefits described above, the EIS/EIR makes clear that dam removal would immediately eliminate risks to health for river users (humans and fish and wildlife) from toxic algae blooms on the reservoirs. Dam removal would also restore more natural water temperatures, which would enhance water quality. The EIS/EIR makes clear that water quality will improve much more quickly with dam removal than with no action.
The EIS / EIR makes clear that removing four PacifiCorp Dams on the Klamath River will provide the greatest long-term benefit to the environment. Trout Unlimited supports the Proposed Action (Alternative 2) for full removal of four Dams on the Klamath River under the KHSA as the preferred alternative to advance restoration of the salmonid fisheries in the Klamath Basin in a manner that will protect local economies and ratepayers, and is consistent with statutory obligations and tribal rights. We appreciate the opportunity to review and comment and look forward to continued involvement and coordination with the Agencies as this process continues.
Please contact Brian Johnson at 510-528-4772, or Kate Miller at 503-827-5700 with any questions about these comments.
Western Energy and Water Council, Trout Unlimited
Brian J. Johnson
California Director, Trout Unlimited