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Keno
Reservoir and Interim Dam License Conditions – A Klamath
Sleeper Issue
By Felice Pace
March 16, 2009
While it has been intentionally mystified
and ignored, what will be included in
Interim License
Conditions for Klamath River Dams is likely one
of the most important issues which will impact the fate
of Klamath Salmon, the health of the River and its
communities for the next 20 years or more.
Interim Conditions
refers to changes in operations and other actions
which the Federal Energy
Regulatory Commission (FERC) can require
PacifiCorp to
take between now and when the dams are either relicensed
for 50 years, removed or transferred to other ownership.
This could take a long time and during that time the
fate of Klamath River Coho and Spring Chinook could be
sealed…..one way or the other.
Several environmental and fishermen’s organizations and
at least two tribes supported
PacifiCorp’s
recent attempt to get California’s
State Water Resources
Control Board (SWRCB) to “suspend” consideration
of whether the dams can meet water quality standards
established to protect the
Public Trust and
the beneficial uses of water. These organizations argued
that PacifiCorp was making a good faith efforts toward a
dam settlement which would remove four of the five
mainstem dams and transfer a fifth dam – Keno – to the
Bureau of Reclamation.
Because of PacifiCorp’s good faith, these groups argued,
the company should not be required to participate in a
water quality study which would be moot if the dams are
removed.
However, these PacifiCorp apologists failed to mention
that the water quality studies which PacifiCorp wants
“suspended” will also recommend the
Interim Conditions
which PacifiCorp will be required by FERC to implement
until the dams are finally licensed, removed or
transferred. The apologists also failed to mention that
the state water quality studies and
Interim License
Conditions are the only way that California can
get PacifiCorp to do its part in cleaning-up Klamath
River pollution under a plan currently being developed
by the North Coast Water
Quality Control Board.
How do self-proclaimed
Klamath Defenders become apologists for the
interests of PacifiCorp and Warren Buffet? The answer
has a lot to do with ego, funding and future career
prospects: the removal of Klamath River Dams will
advance the careers of those who can claim credit
whether or not Klamath Salmon and the future health of
the River are compromised in the process.
With several of the Klamath’s most prominent
Defenders so
committed to dam removal that they will work for
PacifiCorp’s interest in order to facilitate a dam
removal deal, it falls to others to take up the slack.
The Hoopa Tribe
is doing its share – focusing on
Interim Conditions
for dam operations. But so far the Hoopa have only
pushed for interim flows within the Klamath
Hydroelectric Project Area. While this issue is
important (see KlamBlog’s January 27th post), the most
important issue which needs to be addressed in
Interim Conditions
is the poor water quality behind PacifiCorp’s Keno Dam,
i.e. in Keno Reservoir.
Also known as Lake Ewana,
Keno Reservoir
consistently contains water of the worst quality found
anywhere in the Klamath River Basin. Fish kills occur in
the Reservoir nearly every year. The water quality
related die-offs are downplayed by the
Oregon Department of
Environmental Quality and local media. For
example, a recent news article in the
Klamath Falls Herald and News gave the impression
that the fish kills are normal because they happen
nearly every year. But these fish kills include
endangered Kuptu
and Tsuam
(sucker species) and they are in no way natural.
Keno Reservoir
makes the polluted agricultural wastewater it receives
much worse because the extensive marshes which once
rimmed the area are now mostly gone – replaced by
irrigated agriculture, a plywood mill, a power plant and
livestock operations. If it is not cleaned up,
Keno Reservoir
could be a death trap for salmon and steelhead trying to
navigate to and from the Upper Basin once the other four
dams are removed.
It is essential to recovery of Klamath Salmon and to the
restoration of the Klamath River that the pollution at
Keno Reservoir
is addressed now – through
Interim Conditions
for PacifiCorp’s continued operation of the
Klamath Hydroelectric
Project. For one thing we may have to wait more
than a decade for dam removal to even begin. Most
importantly, if we don’t address Keno pollution now the
mandate for cleaning it up will pass with the transfer
of Keno Dam and Reservoir to the
Bureau of Reclamation
(BOR). With its powerful irrigation clients opposed to
clean-up, it would likely take years of litigation to
get the BOR to clean-up
Keno Reservoir.
Cleaning-up Keno is feasible but it will not be cheap.
Decades of tree bark which has accumulated on the
Reservoir’s bottom as a result of log storage must be
removed and the ongoing storage of logs in the Reservoir
must end. Either treatment plants or treatment wetlands
must be put in place on the Klamath Straits and on the
outflow from Upper Klamath Lake and the Lost River
Diversion Channel. All three discharge polluted
agricultural wastewater into
Keno Reservoir.
The most cost effective method for cleaning up Keno
would involve the restoration of
Lower Klamath Lake
whose extensive wetlands once stored and cleaned
high winter and spring flows for later release to the
River. Studies of existing permanent and seasonal
wetlands in the Lower Klamath area demonstrate that they
effectively remove phosphorus and other nutrients from
water which passes through them. Restoring
Lower Klamath Lake
would provide many other benefits including to
waterfowl, Bald eagles, duck hunters, bird watchers and
the local economy. But it is fiercely opposed by the
Irrigation Elite
who want to maximize the amount of public and private
lands which they can lease at low rates and then farm
with high profit margins.
What this all means is that the decision of the SWRCB to
continue the water quality studies and to recommend
Interim Conditions
for reservoir clean-up to FERC is a victory for the
River and Klamath Salmon. But that victory is partial at
best. Will the SWRCB focus on Keno and tell FERC to
require that PacifiCorp develop and implement a clean-up
plan BEFORE it is allowed to transfer the dam and
reservoir to the Bureau of Reclamation? With many
Klamath Defenders
preoccupied with dam negotiations or shilling for
PacifiCorp, it may be necessary for ordinary citizens
and new organizations to step up and demand the
clean-up. This may already be happening. An action alert
on Klamath water quality issues was recently circulated
by an entity calling itself
Klamath First Advocates
– a name which has not been seen before. The
entity has yet to define itself publicly.
Citizens who want to support the clean-up of
Keno Reservoir
before it is transferred to the BOR should let the SWRCB,
NCWQCB and FERC know that this is a priority. Tell them
that Interim Conditions
for operation of the Klamath River Dams must
include a requirement that PacifiCorp develop a clean-up
plan, time-lines and clean-up financing plan for Keno
Reservoir before it is transferred to the BOR. Contact
information is provided below.
Tam Doduc & Jennifer Watts
California State Water Resources Control Board
P.O. Box 2000
Sacramento, CA 95812-2000
Via e-mail: TDoduc@waterboards.ca.gov
JWatts@waterboards.ca.gov
Ms. Catherine Kuhlman, Executive Officer
North Coast Water Quality Control Board
5550 Skylane Blvd.
Santa Rosa, CA. 95403
Via e-mail: CKuhlman@waterboards.ca.gov
MStJohn@waterboards.ca.gov
Magalie Roman Salas, Secretary
Federal Energy Regulatory Commission
Project P-2082-027
888 First Street NE
Washington, DC 20426
http://www.ferc.gov/contact-us/contact-us.asp
John.Mudre@ferc.gov
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