Tom Mallams: Written Comments Submitted to the California State Water Resources Control Board

Written Comments Submitted to the California State Water Resources Control Board
on Klamath River Basin TMDL

To: California State Water Resources Control Board
September 4, 2010

Re: Comments on Klamath River Basin TMDL

The whole process seems to be ignoring proven historical data on the absence of clean water in the Klamath Lake & Klamath River. There needs to be a proven starting point of correct water quality standard from historical facts. Many of the standards are set at a level to support cold water fish on a year round basis. This NEVER existed in the Klamath Lake or Klamath River. Historical facts say that the water quality in both the Klamath Lake and Klamath River are actually better today than they were when the first white explorers came through this area.

Since the development of the Klamath Reclamation project, and irrigation development in the upper basin there is a recorded increase of 30% of the inflows into Klamath Lake (study done by Mark Van Camp, a hydrologist). Without the project all the water from Lost River would never reach the Klamath River. Before the project, Lost River ended up in Tulelake and simply evaporated away there.

The dams on the Klamath River are being blamed for many of the water quality problems while not acknowledging the benefit of the dams. The dams keep water flowing in the late season where before the Klamath River often times “dried up.” True, water quality in the reservoirs is not the best in the late season, but even the problems with the algae has been exaggerated way out of proportion, to the extent that one of the Tribes posted warning signs on the bank, warning people of “dangerous” algae blooms that were present. This is simply scare tactics, since there are no documented cases of serious problems with the algae. The occurrence of any serious problems is highly unlikely. With that attitude you would have to ban all people from the Klamath River for fear of drowning since many have died or been injured from swimming in the river, where no one has died or been injured because of the algae. Before the dams were in place, algae problems existed throughout the entire river system.

Historically, it is said that there was originally 200,000 acres of wetlands, in the project area. After developing the project that number was reduced to 17,000 acres. Wet lands are supposed to filter the water. They apparently didn’t function well since before the project was developed, the water quality is documented as being so poor the early explorers wouldn’t even allow their livestock to water there.

A serious problem with expanding or putting wetlands back is what happens to all the organic matter produced in the wetland? That decomposing material and or the chemicals in the material often times still ends ups in the Klamath Lake or Klamath River, when there is a high water event. Wet lands also consume a greater amount of water than any irrigated crop in our area. This is thru evaporation in the large warm shallow water in the wetlands and transpiration or loss of water through the plants in a wet land. In the last 25 years, over 98,000 acres of irrigated land has been taken out of production in the upper basin. Much has been put into wetlands and there has been no improvement in water quality or additional quantity of water in our basin as a result.

Agriculture is routinely blamed for much of the water equality problems in the Klamath Basin. Our entire basin has a volcanic origin. Many of our springs and creeks literally come out of the ground loaded with phosphorus. Many times over allowable limits. This natural occurring phosphorus promotes algae growth in the shallow warm water in Klamath Lake and the algae then produced the nitrogen levels that continues the cycle of out of compliance water in both the Klamath Lake and the Klamath River. If we need to change what Mother Nature has given us, or we need to change what has been the historical conditions of the Klamath Lake and Klamath River, then be critical of Mother Nature, not agriculture!!

TMDL standards have been set according to what it takes to keep cold water fish alive. No scientific proof exists that proves cold water species ever existed above the dam locations on any consistent level in the years before the dams were built on the river. Any salmon that did make it past where the dams are were beat to pieces and not edible. The Klamath Tribe historically got their salmon in trading with the downstream tribes. Often time their form of barter was slaves for fish.

Another major conflict is that the Klamath Lake and the upper part of the Klamath River is habitat for the various warm water sucker species. That puts two opposing habitats being mandated in the same exact water bodies. If salmon were plentiful in the upper basin, why is the Klamath Tribe claiming the sucker fish has been their main diet. Who would want to eat sucker fish if salmon were present. There is so much written historical evidence from the earliest explorers to Tribal members themselves that seems to be ignored. Only one side is being recognized.

In conclusion, even if all agriculture was eliminated, the high probability is that with the natural occurring elements in our water, the entire water system would go back to the Poor state before agriculture was advanced here. The end result would be – NO Farms, No Jobs, No food production and still POOR WATER QUALITY.

Please use some simple common sense.

Thank you.

Tom Mallams
President Klamath Off-Project water Users
Chairman, Klamath Headwater Local Advisory Committee
541-533-2580
PO Box 249
Beatty, Oregon 97621