Members of the Senate Committee on the Environment and Natural Resources:

As a multiple degreed geologist, I would like to comment on the last available Federal Energy Regulatory Commission environmental impact statement on the removal of the Klamath dams *.

This report states that complete studies have not been undertaken to understand the total amount of sediment accumulated behind the four Klamath mainstem dams to be removed, nor the riverine and fluvial effects generated by the release of this sediment. Until those studies are completed and we understand the nature of the sediment and its totality, it is very unwise to pass legislation regarding ratepayer monetary assumptions resulting from dam removal.

The FERC report states that removal of the sediment, should that be the course chosen, could range up to $4.5 BILLION. That assumption is that there are no heavy metals or toxics in the sediment that would require a Superfund type cleanup of the sediment. If that is the case, an order of magnitude greater cost will be incurred. The few sediment cores taken to date are only a few centimeters deep, while the actual accumulated sediment ranges from about 1 and a half to four million metric tons of fine sediment.

So no real knowledge of the toxicity or heavy metal analyses are available for all four dams. 540,000 ratepayers, most of whom are in Oregon, divided by the FERC high estimate of sediment removal would be a cost of about $8000 per ratepayer.

Citizens who live on the river year round are very concerned about the flooding of the mainstem Klamath during the months of December through April. Many who have lived there prior to the building of Irongate state that extensive flooding and erosion of the river regularly occurred. The FERC report also states that no definitive studies have yet been undertaken to determine probablility of flooding, whether they be 50, 100, 500 or thousand year flood events. When major runoff events happen in the Klamath Basin, above the mainstem of the river, the dams now provide a “ponding” effect which decreases the water velocity and decreases overall turbidity throughout the system. If the dams are removed, the massive erosional effect of these runoff events will destroy most of the gravel beds which provide the salmon breeding grounds of the river. Sediment will be redistributed irregularly throughout the lower areas of the fluvial system and many of the salmonids known breeding locations will be eradicated.

The FERC report states that $35 million additional per year will be required from 540,000 Pacificorp ratepayers as the cost of replacement electricity. That will increase the average ratepayer’s monthly electric bill by 10% for the next ten years, at today’s rates. If “green” electricity is required as a replacement that will increase the monthly electricity charges by an order of three or four times their present rates. The replacement cost is presently determined based on coal fired replacement. Pacificorp presently uses power generated from its Wyoming coal fired plants. To exchange clean hydropower for coal fired electricity is draconian at best.

I urge SB 76 not be released from committee until a better understanding of the actual cost ** to ratepayers and the geology and geomorphology of the system without the dams is accurately understood.

Respectfully submitted by:

Gail Hildreth Whitsett

BS in Geology, Honors College Oregon State University
MS Geology, Oregon State University
Princeton University, Yellowstone-Bighorn Research Facility

23131 N. Poe Valley Road
Klamath Falls, Oregon 97603
(541)882-1315

*FERC Report –FINAL ENVIRONMENTAL IMPACT STATEMENT FOR HYDROPOWER LICENSE –FERC/EIS -0201F Vol 1 and Klamath Hydroelectric Project FERC Project No. 2082-027 Appendices Vol. 2

Pages 853-891 add estimated costs of option implementations. Intentionally spreading any reference to possible sediment removal costs apart from other costs, references on estimated sediment volumes totaling approximately 9100 acre feet is on Table 3-3 (page 3-21) and the estimates of sediment removal costs range up to $487,000 per acre foot (page 4-6) , with individual possible sediment removal estimates for: John C. Boyle on page 4-8 ($7 million); Copco 1 on page 4-8 ($2.9 billion) and Iron Gate p. 4-10 ($1.5 Billion)

**A facet of SB 76 that is not addressed is that no one is responsible in the event dam removal results in cost overruns. The Agreement in Principle (page 9 ) states:

“The final Agreement shall resolve how to provide for further funding of costs in excess of the State Cost Cap, if during the process of Facilities removal it becomes reasonably apparent that actual Facilities removal costs are likely to exceed $450,000,000 or in fact do exceed that amount. The United States, California, Oregon, Pacificorp and Pacificorp’s customers do not accept liability for any costs in excess of $450,000,000 for Facilities removal, absent specific subsequent agreement.”

It seems imprudent to apply $200 million toward a project when there is not currently a plan in place for funding the project in its entirely. It is foreseeable that in the future there will be cost overruns and the state will be required to authorize additional funding or be left with a partially removed dam or set or dams. Undoubtedly, the state will feel compelled to provide additional funding under these circumstances, or perhaps legislation will be required to put the additional charges on the shoulders of the ratepayers. The state should wait until there is a plan in place for funding the entire cost of dam removal before investing money in this project. Otherwise, the initial contribution puts the state in a position where it will be required to either force taxpayers or ratepayers to cover a portion or all of the unforeseen costs associated with these dams removal.

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