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Official Comments at Yreka FERC Hearing
Marcia H. Armstrong Supervisor, District 5
Siskiyou County
Siskiyou
County is approximately 6,600 square miles large. Four of
PacifiCorp’s Klamath River Hydroelectric Project
developments, (Iron Gate, Fall Creek and Copco 1 and 2,) are
located in Siskiyou County, as is a portion of the eligible
Wild and Scenic River area between J.C. Boyle and Copco 1.
Siskiyou County has been, and continues to be, a
participant/intervener in the application, FERC and Settlement
Group processes.
I
believe the project should be re-licensed for the following
reasons:
·
The public benefit from the production of 151 megawatts (mw)
of clean electricity, especially the production from peaking
operations, is clearly needed especially during periods of
peak load demand. In addition, I feel the project does
supply some flood control benefits that can be critical to
residents downstream of Iron Gate Dam.
·
There are proposed license conditions to mitigate for the
effects of the hydro-project which will increase fish spawning
and rearing habitat, enhance wildlife habitat, support
recreational opportunities, and protect the quality of the
environment.
I
realize that FERC must incorporate final mandatory conditions
consistent with other applicable law and also use the facts as
determined by the Administrative Law Judge in the Hearing on
Issues of Material Fact. At this time, I support the Staff
Alternative as an improvement to PacificCorp’s Proposal as
presented in the DEIS for the following reasons:
·
The loss of electricity production from peaking operations
under agency preliminary mandatory conditions would be
irreversible and irretrievable.
· An
anadromous fish restoration plan and an adaptive approach are
the best strategies to achieve anadromous fish restoration.
Fish passage/byways that are fish-effective, as well as cost
effective, still need to be determined. Not all
necessary information is known at this time.
The
Staff Alternative allows for the public benefit that derives
from power generation, while complying with requirements of
the Wild and Scenic Rivers Act to protect and enhance the
Outstandingly Remarkable Values (ORVs) associated with the
designated river segment below the JC Boyle powerhouse in
Oregon; as well as the eligible segment continuing from the
California border down to Copco Reservoir. The Administrative
Law Judge has ruled in the Hearing on Issues of Material Fact
that the BLM preliminary mandatory conditions significantly
diminish Class IV+ whitewater boating and trout fly-fishing.
In addition, Oregon has designated the Oregon portion of the
river below J.C. Boyle as a Scenic Waterway, and dam removal
may violate Oregon law as well.
There
is no substantial or clear evidence that dams must come out to
mitigate for project effects. In fact, there are many negative
impacts of dam removal:
·
More than 20 million cu. yds. of fine sediment exist above the
dams that would be mobilized down river to cement-in spawning
beds, destroy populations of invertebrates and smother salmon
eggs. This would likely have significant, irreversible, and
irretrievable effects on fish, prey species, invertebrates,
and other elements of the river ecosystem immediately upon
breach and for decades following.
·
Approximately 1,500 privately owned parcels could suffer
depreciation in value due to: loss of shorefront property;
loss of water access; loss of lake views; loss of recreational
opportunity; impacts of the deconstruction process; and
impacts of muck and mire until the area is rehabed and
revegetated.
·
There would be a substantial resultant loss of tax revenue to
Siskiyou County and California for the facilities and any
diminishment of property values.
.
In addition, I would like to note that the DEIS analysis of the retirement of Copco I and Iron Gate Dams does not contain a robust assessment of significant adverse economic impacts on Siskiyou County, affected residents, and businesses doing business on the Klamath River, nor does it propose mitigations to offset these impacts. That analysis should be included in the Final EIS.
.
In addition, I would like to note that the DEIS analysis of the retirement of Copco I and Iron Gate Dams does not contain a robust assessment of significant adverse economic impacts on Siskiyou County, affected residents, and businesses doing business on the Klamath River, nor does it propose mitigations to offset these impacts. That analysis should be included in the Final EIS.
Thank
you for this opportunity to comment.
Permission to post.