






|
Become a friend of
the Klamath Bucket
Brigade
Send
Donations Here
All donations are tax
deductible
|
|
This Website is Dedicated to
Alvin Alexander Cheyne
January
10, 1921 - June 17, 2005
|

GovTrack.us is an independent tool to help the public
research and track the activities in the U.S. Congress, promoting
government transparency and civic education through novel uses of
technology.
|
|

Politics, Science and the Klamath Water Deal
By Felice Pace
March 26, 2009
Promoters of the proposed Klamath Water
Deal (officially the "Klamath Basin Restoration
Agreement" or "KBRA") are continuing to promote it
– and the federal legislation which is needed to finance it
– in spite of substantial opposition from inside the Klamath
River Basin and beyond.
Recently that opposition has grown. The Industrial
Customers of Northwest Utilities (ICNU) represents
big industrial power users like the Aluminium and Internet
Industries. ICNU recently alerted FERC that it has an
interest in the relicensing. On its face that interest is to
keep the dams up and producing power. But what is really
behind their involvement is the Water Deal which
proposes giving Klamath Project Irrigators
cheap power from Bonneville. ICNU currently uses a big
chunch of that cheap power; if the Irrigation Elite
succeeds in getting a piece of Bonneville power for
themselves the ICNU members will likely get less.
But the most significant opposition to the Deal
could come in the future. The Obama Administration,
which has not yet made known its position on the Deal,
has pledged publicly to use the best science
when making natural resource decisions. And the scientific
underpinnings for the KBRA are weak at best. Knowing this to
be the case, the Deal’s promoters are doing what
they can to ignore and downplay scientific studies and
opinions which do not support the Deal. While some
scientists in the employ of Water Deal promoters
tell us it is based on good science and will allow salmon
and other species to recover, no independent scientists have
endorsed the KRBA . KlamBlog predicts that no independent
scientist will endorse it in the future either. Here’s why:
The National Research Council (NRC) is one
of the nation’s most prestigious scientific organizations.
Here’s how it describes itself:
The National Research Council (NRC) functions under the
auspices of the National Academy of Sciences (NAS), the
National Academy of Engineering (NAE), and the Institute of
Medicine (IOM). The NAS, NAE, IOM, and NRC are part of a
private, nonprofit institution that provides science,
technology and health policy advice under a congressional
charter signed by President Abraham Lincoln that was
originally granted to the NAS in 1863. Under this charter,
the NRC was established in 1916, the NAE in 1964, and the
IOM in 1970. The four organizations are collectively
referred to as the National Academies.
The mission of the NRC is to improve government decision
making and public policy, increase public education and
understanding, and promote the acquisition and dissemination
of knowledge in matters involving science, engineering,
technology, and health. The institution takes this charge
seriously and works to inform policies and actions that have
the power to improve the lives of people in the U.S. and
around the world.
Back in 2003 the federal Department of Interior
requested that the NRC review the scientific underpinnings
of the Biological Opinions for Coho Salmon, Kuptu and
Tsuam (aka Shortnose and Lost River suckers).
Subsequently the NRC was also asked to review two Klamath
River flow studies that have been completed under the
auspices of the Department of Interior.
The first NRC report concluded that the science underlying
the biological opinions was weak; the second concluded that
the two flow studies are fundamentally flawed and therefore
"Not likely to contribute effectively to sound decision
making…" The second report in particular – which examined
both the Natural Flow Study completed by the
Bureau of Reclamation and the Instream
Flow Study completed by the Department of
Interior (aka The Hardy Study) – has been
all but ignored by the press and stakeholders. When a report
is ignored there is likely a reason and that reason is
usually that folks do not want to know – or for others to
know – what it concludes.
KlamBlog believes that when facing important natural
resource decisions we ought to consider and evaluate all
information and all scientific opinions – not pick and
choose based on whether we like the conclusions. So we
publicize information which is being suppressed or
intentionally ignored. Here then are excerpts from the NRC
report which promoters of the Water Deal would
rather see forgotten. The report is titled Hydrology,
Ecology and Fishes of the Klamath River Basin. The full
report can be read
on line or downloaded for a
price.
The NRC
on the BOR’s Natural Flow Study ~
- The committee concluded, however, that the
Natural Flow Study was seriously compromised by
several fundamental issues, including its choice of a
basic approach for understanding natural flows, choices
of the models for calculations, and serious omissions of
factors likely to influence river flows at the Iron Gate
Dam gauge site.
- The calculations of the fate of water in the upper
basin related to evapotranspiration were not done
according to the best current methods, such as the
Food and Agriculture Organization’s (FAO’s)
version of the modified Blaney-Criddle method. A more
serious concern was the model behavior when a
sensitivity analysis of its output concerning
agricultural land was conducted. The results were not
explained, and the apparent anomaly appears to be
related to the component of the model that deals with
reduction of evapotranspiration in the Upper Klamath
Lake marsh when it is converted to agriculture.
- The Natural Flow Study did not fully
address the issue of changes in land use and land cover.
- The study failed to adequately model the connection
between the Klamath River and Lower Klamath Lake.
- The study did not adhere closely enough to standard
scientific and engineering practice in the areas of
calibration, testing, quality assurance, and quality
control.
- The committee concluded that the Natural Flow
Study includes calculated flows that are at best
first approximations to useful estimates of such flows.
The present version of the Natural Flow Study
is less than adequate for input to the Instream Flow
Study Phase II and does not provide enough
information for detailed management of flows for the
benefit of listed and other anadromous fish species in
the Klamath River downstream from Iron Gate Dam.
The
NRC on the Hardy Report ~
- As a general perspective, the Instream Flow
Study Phase II followed steps outlined in the
Instream Flow Incremental Methodology (IFIM), which
has seen wide application in studies of this type. The
authors of the Instream Flow Study Phase II
applied the IFIM properly. They also used bioenergetics
and a fish-population model to test their results, and
they tested model output by comparing observations of
fish with predicted fish locations.
- Despite these strengths, the committee found
important shortcomings in the Instream Flow Study
Phase II and its use of various models and data.
Two major shortcomings—use of monthly data and lack of
tributary analyses—are so severe that that they should
be addressed before decision makers can use the outputs
of the study to establish precise flow regimes with
confidence……the shortcomings resulted from constraints
imposed by the US Bureau of Reclamation,
which indicated that lack of time and resources
prevented them from providing additional calculations
that would produce daily flows for the ecological
modeling.
- The elimination of consideration of tributary
processes apparently resulted from an agreement reached
by basin managers not to include tributary processes in
the habitat studies to simplify the engagement of
stakeholders in the process. Since only the main stem of
the Klamath River was subject to analysis, stakeholders
with interests in tributary locations would not have to
deal directly with the study.
- The Klamath River is not a confined gutter for
rainwater, and therefore analyzing the river without
considering its tributaries is akin to analyzing a tree
by assessing only its trunk but not its branches. In
addition, the study did not include important
water-quality attributes, such as dissolved oxygen
levels, nutrient loadings, contaminants, and sediment
concentrations, although each has important implications
for the vitality of the fish populations of the Klamath
River. Second, high flows are especially important to
the physical and biological processes of the Klamath
River, and further analysis of their frequency,
duration, and timing is essential in understanding the
dynamics of the river’s hydrologic, geomorphologic, and
ecological processes. Reliance on monthly flow data, as
outlined above, made analysis of high flows impossible
within the scope of the study.
- There are three major shortcomings in the
experimental design of the Instream Flow Study Phase
II: a fundamental beginning assumption about limits
on salmon habitat, a lack of thorough assessment of the
representativeness of the reaches used for detailed
study, and the statistical approach to analyze the
calculated set of instream flows did not use normalized
data and did not have provisions for identifying serial
autocorrelations.
- Despite these limitations, and in the absence of any
better information currently available, the committee
concludes that the recommended flows resulting from the
Instream Flow Study Phase II probably represent
an improvement for the anadromous fishes in the Klamath
River over the current flow regime.
- To the degree that the studies conclusions are
followed, it should be on an interim basis, pending the
improvements the committee outlines below and a more
comprehensive and integrated assessment of the science
needs of the basin as a whole.
The
NRC on Implications for anadromous fishes in the Klamath ~
- The internal workings of the model in the
Natural Flow Study include several computational
shortcomings that limit its use. These issues imply that
the natural flow model produces results that probably
cannot be used as a precise replication of natural flows
and that the individual numbers generated by the study
are not firm, irrefutable values. The study’s
shortcomings imply that managers of the biological
resources of the basin may use the results of the model
in a general way as a form of guidance for the broad
characteristics of the natural flow regime, but they
cannot use the exact values produced by the study as a
template for developing a flow regime with much
confidence.
- The model does not treat the tributaries of the
Klamath River, although they are and have been an
essential part of the environments of the anadromous
fishes. Without understanding the ecological and
hydrological condition and dynamics in the tributaries,
it is not possible to understand the ecological and
hydrological condition and dynamics of the river.
- The most important outcome of the Instream Flow
Study was that it indicated that increases in
existing flows downstream from Iron Gate Dam probably
would benefit fish populations through improved physical
habitat associated with more water and through reduced
water temperatures. If these conclusions were borne out
by studies incorporating experimental flows and
monitored responses, managers would be able to have
greater confidence that decisions to increase flows
would have a beneficial effect on anadromous fishes in
the lower river.
- Despite various concerns about the study, it is
extremely unlikely, in the committee’s judgment, that
following the prescribed flows of the Instream Flow
Study Phase II would have adverse effects on any of
the anadromous fish species. Based on general principles
and the information developed in that study, following
its prescribed flows probably would have some beneficial
effects on the suite of anadromous fishes in the Klamath
River considered as a whole, although not necessarily
for every species.
The
NRC on what needs to happen now ~
- The committee found that science in the basin was
being done by bits and pieces, sometimes addressing
important questions, but not linked to other important
questions……The committee found that the most important
characteristics of research for complex river-basin
management were missing for the Klamath River: the need
for a "big picture" perspective based on a conceptual
model encompassing the entire basin and its many
components. As a result, the integration of individual
studies into a coherent whole has not taken place, and
it is unlikely to take place under the present
scientific and political arrangements.
- To address science and management in the basin, the
committee first recommends that the agencies,
researchers, decision makers, and stakeholders together
define basin-wide science needs and priorities. One
method of achieving success in this effort would be
through the establishment of an independent entity to
develop an integrated vision of science needs. The body
that defines this vision must be viewed by all parties
as truly independent for it to be effective.
- The Trinity River basin experience, despite some
difficulties, provides a good example to follow in many
aspects of the overall basin-wide effort.
- Connecting effective science with successful
decision making for delivering water to users,
sustaining downstream fisheries, and protecting the
populations of protected species has been problematic in
the Klamath River basin. The Natural Flow Study
and the Instream Flow Study Phase II are not
likely to contribute effectively to sound decision
making until political and scientific arrangements in
the Klamath River basin that permit more cooperative and
functional decision making can be developed.
- The employment of sound science will require: A
formal science plan for the Klamath River basin that
defines research activities and the interconnections
among them, along with how they relate to management and
policy; An independent mechanism for science review and
management that is isolated from direct political and
economic influence and that includes a lead scientist or
senior scientist position occupied by an authoritative
voice for research; A whole-basin viewpoint that
includes both the upper and lower Klamath River basins
with their tributary streams; A data and analysis
process that is transparent and that provides all
parties with complete and equal access to information,
perhaps through an independent science advisory group;
An adaptive-management approach whereby decisions are
played out in water management with monitoring and
constant assessment and with periodic informed
adjustments in management strategies.
- The committee recommends that the researchers,
decision makers, and stakeholders in the Klamath River
basin emulate their colleagues in the Trinity River
basin in connecting science and decision making and that
the two units coordinate their research and management
for the greater good of the entire river basin.
Those who crafted the proposed Klamath Basin
Restoration Agreement (aka The Water Deal)
used flawed studies to develop recommendations for Klamath
River flows, ignored calls by independent scientists for a
whole basin approach and did not propose using the sort of
independent science process that the National
Research Council recommended. Essentially the
proposed Deal seeks to substitute its political
calculations for good science. Klamath history teaches that
when good science is ignored bad things happen. That may be
the future to which the Klamath River Basin is headed if
promoters of the Klamath Basin Restoration Agreement
get their way.
+++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
NOTE: In accordance with Title 17 U.S.C. section 107,
any copyrighted
material herein is distributed without profit or
payment to those who have
expressed a prior interest in receiving this
information for non-profit
research and educational purposes only. For more
information go to:
http://www.law.cornell.edu/uscode/17/107.shtml
|