Comments by Dr. Kenneth A. Rykbost 

   For over 15 years I have studied all of the significant reports and documents related to the science behind the Klamath water issues and provided review comments on many of them. Some of the most cited documents that have served as benchmarks for policy decisions are gray literature that has never been subjected to critical peer review. Two of the most grievous examples are a report on water quality in Upper Klamath Lake from studies by Kann and Walker (Nutrient and Hydrologic Loading to Upper Klamath Lake, Oregon, 1991-1998) submitted to the Bureau of Reclamation in draft form in 1999 and never revised, and the Balance Hydrologics Inc.1996 report; Initial Assessment of Pre- and Post-Klamath Project Hydrology and Impacts of the Project on Instream Flows and Fisheries Habitat by Kamman and Hecht. Kann and Walker has been cited hundreds of times, including more than 10 times in the 2007 Biological Assessment prepared by the Bureau of Reclamation as the baseline for 2008 Biological Opinions by the NOAA Fisheries and US Fish and Wildlife Service. Kamman and Hecht set the precedent for using Klamath River flows at Keno Oregon from 1905 through 1912 as the basis for natural conditions of the river prior to Klamath Reclamation Project. That precedent has been used by Hardy Phase I and by the Bureau of Reclamation in their Natural Flow Study as the best indication of historical river conditions pre-project, even though the period is one of the two wettest periods on record during the past 120 years in the upper basin, and it ignores major changes in the hydrology of the upper basin that resulted in increased flows in the Klamath River compared to actual historical conditions before any changes in natural conditions. Your treatment of the Klamath issues; in spite of the statement in your second paragraph that “Science has been a special focus of our work”, completely ignores these and many other scientific facts that must be a part of any in depth analysis of the Klamath issues.

    The tone of your treatise is easily discernable by reviewing the list of contributors and their organizations and some of the citations, including those bastions of scientific excellence Glen Spain and Michael Milstein. Discussions of sucker and salmon problems are focused solely on perceived affects of the irrigation project operations while virtually ignoring all other factors that have contributed to declining populations. You frequently refer to production based on renewable resources as an “extraction” industry while failing to use that term in reference to the harvest of species for commercial, recreational, or tribal fisheries. In fact it is overharvest of suckers and salmon; including by predators, above all other factors, which has contributed to their population declines over several decades, a fact you conveniently ignore.

   One of the documents you cite frequently for various points is the OSU/UC Davis report “Water Allocation in the Klamath Reclamation Project: 2001”. This comprehensive compilation of information has many authors with a variety of disciplinary backgrounds and very divergent opinions on some of the important issues. Although there was some degree of review of each other’s sections, there are many major differences of opinion of statements concerning various issues. On page 7 you cite Woodward and Rohm as the source for a statement that massive algae blooms on Upper Klamath Lake are largely a result of agricultural runoff. These authors have no expertise in the field of water quality or affects of agricultural activities on water quality. I find similar examples of misrepresentation of sources for strong statements – mostly pointing a finger at agriculture as the evil source of all problems in the watershed. Shame on you!

   On the same page you state “oxygen levels in the upper Klamath River fell low enough to kill thousands of fish in 1986”. It is a well known fact that oxygen levels in the stretch of the Klamath River between Link River and Keno fall to very low levels every summer from mid-June through September. Wood debris decomposition; a left over result from decades of log decking for use in a mill, is a leading cause of the biological oxygen demand that produces conditions unsuitable for fish. The other most important oxygen demand is from the biological decomposition of the blue green algae that migrate from Upper Klamath Lake into this reach of the Klamath River. These are important facts that a treatise on science would not ignore, especially when making such a strong statement about a fish die-off.

   The reference to long declines in salmon populations due to upstream dams and diversions fails to credit any of the other important factors leading to population declines. First and foremost was the great expansion of commercial fishing brought on with government subsidized financing of the commercial fleet. Loss of spawning beds to very extensive mining, overharvest by tribes of dwindling supplies, predation by a burgeoning population of seals and sea lions, sedimentation associated with logging and road building in major tributaries, affects of the 1964 flood, and disease are all widely recognized contributors to salmon declines. Yet nowhere do you credit any of these factors as important to the salmon problem. Why not?

   Here and in other sections you downplay the value and sustainability of the agricultural industry in the Klamath Basin. Yes, the industry does have limitations imposed by distance to markets, lack of local processing facilities, and weather limitations including susceptibility to summer frosts and limited rainfall. However, the climatic conditions in the region have some very significant affects on crop quality for the crops we do grow. While sugarbeets were produced in the region, our crop had the highest sugar content of any production region in the US. Our mint oil has much superior quality which is taken advantage of by blending our oil with poorer quality oils from other regions. Our alfalfa hay is recognized as the highest of quality for the dairy industry. Grain quality as based on test weights is superior to grain produced in almost all other regions. All of the quality benefits are attributable to our moderate daily high temperatures and the cool nights and plentiful sunshine of the semi-arid region. As a result, local crops often command premium prices which offset somewhat lower yields than those obtained by crops in areas with longer growing seasons. Another benefit is a lack of important disease and pest problems that plague other production areas. For example, potatoes are not damaged by the Colorado potato beetle which costs growers up to $200/acre to control in other production areas. With the exception of two years, late blight control at costs up to $300/acre in many production areas is a non-issue in the Klamath Basin.  Disease and pest problems are also less important in onion, cereal, and alfalfa crops.

   Although our sugar beet production never exceeded 12,000 acres, for several years the farm gate value of this crop exceeded the off-boat value of the salmon harvest for Oregon’s entire fishery. Farm gate value of the crop production in the Klamath Project has exceeded the off-boat value of Oregon’s commercial fishery for all species in most recent years. It is inappropriate to compare pasture or hay crops with so-called high value crops as you have done. Input costs must be included in the analysis and when thrown into the mix pastures may be more profitable than onions or potatoes. Over 50 percent of the farm gate in the basin as well as in the project has historically been from sale of livestock. Pastures are the base of that industry.

   By far the highest value crop currently produced in the basin is strawberry plantlets. This crop, grown on about 3,500 acres, is the plantlet source for over one-half of the California berry crop. Gross value of the crop is about $30,000/acre. Thus this crop alone generates nearly a $100 M in farm gate value. In the past two years production of leafy vegetables has doubled to nearly 1,000 acres with a gross value similar to that of strawberry plantlets. Both of these crops have found a niche here because of freedom from important pests and diseases.

   I was hoping to finally read about science in this section. Sadly there was very little about science here and the only fact that was presented was the repeat of a myth that has been promulgated by many folks many times over. You state unequivocally that up to 90 percent of the Trinity River is diverted to the Sacramento. This statement has been made publicly by the head hydrologist in the Klamath Reclamation Project office more than once, was made twice in print in the IMST report on the Klamath Crisis of 2001, and is cited in many other venues. The fact is that in the past up to 90 percent of the North Fork of the Trinity River above the dam at Lewiston has been diverted to the Sacramento. In recent years the percentage has been significantly reduced. An analysis of the river flow data for all the years of record, including over 30 years before and after the dam was built, reveals that the average annual diversion during the high years was about 1 million acre-feet out of a total flow of about 6 million acre feet, or about 15 percent of the Trinity flow. There is no diversion of flows in the South Fork of the Trinity River. When the hydrographs of the river are com pared for the years before and after the dam was constructed they suggest that the timing affect on river flows was a significant reduction during April through June and little affect on flows during the remainder of the year. Since this is the period of out-migration of salmon smolt this is indeed an important factor for salmon success, but it may be offset by hatchery production and management.

   In Chapter 3 on page 50 two very large factual errors are stated. You identify the water diversion to the Reclamation Project at 1,345,000 acre-feet. That number is in fact the approximate annual discharge from the upper basin at Iron Gate Dam. The diversion to the Klamath Project is approximately 400,000 acre-feet, ranging from about 300,000 in high rainfall years to around 425,000 acre-feet in very dry years with little precipitation during the growing season. Although you later correct this error, you will have lost many readers before they get to the corrected figure. One of the problems with factual errors such as this is that they become accepted fact when repeated often enough. The myth about the Trinity River diversion is a prime example of this problem to the point that the lead hydrologist in the Reclamation Office has misstated that fact on a number of occasions.

   A more serious error is made in the next paragraph. As previously pointed out, potato is not the highest value crop grown in the basin. Strawberry plantlets hold that distinction and have for several years. But your water consumption numbers are way out of line. Potato has a consumptive use of less than 2.0 acre-feet per acre. Applications above 2.0 acre feet are likely to lead to serious disease problems and rot breakdown in storages. The Bureau of Reclamation maintains a service for the western states identified as Agricultural Meteorology or AgriMet for short. This service is based on over 150 weather stations strategically located throughout the west to monitor weather parameters and predict irrigation requirements for a range of crops based on local conditions. There have been four of these stations situated in the Klamath Basin since 2001, including one established at the OSU Klamath Experiment Station in 2000. Our crop research at the station has confirmed the accuracy of this service in predicting irrigation requirements for the crops we grow in the region. Alfalfa has the highest consumptive use of the crops grown locally. It requires about 2.8 to 3.0 acre-feet per acre. In contrast, evaporation from an open body of water is slightly higher than 3.0 acre-feet per acre and evapotranspiration from emergent vegetation in a wetland consisting of Cattails and Tules can be considerably higher than from open water. Figures published by one of the members of the 2007 NRC Committee indicated this vegetation can exceed open water evaporation by up to 180 percent.

   Even more puzzling is the statement that water use in the Klamath Project is inefficient by western standards. Several studies of project efficiency have been conducted over the years. A recent University of California – Davis study found just the opposite; the project is among the most efficient projects in water use. An efficiency of over 92 percent was reported. The high efficiency was attributed to the reuse of tail water at many points in the system. Over 600 miles of drain canals within the project pick up subsurface flows contained by impermeable confining soil layers and these return flows are reused over and over again. Solid data from years of records indicate the average consumptive use for the project is very close to 2.0 acre-feet per acre. Consumption above that amount is confined to the lakes and wetlands in the upper basin. This would include substantial evapotranspiration and evaporation from Klamath Lake, the Upper Klamath Marsh, the Sycan Marsh, Clear Lake and Gerber Reservoir.

   This points to a second myth that is promoted extensively by the environmental community. That is that converting agricultural properties back to wetlands will enhance water supply. In fact the opposite is the case. Evaporation and evapotranspiration from open water and wetlands will always exceed crop consumptive use. Declining inflow to Upper Klamath Lake during the past 20 years is at least partly the result of large increases in the acreage in Klamath Marsh and Sycan Marsh wetlands. Recent conversions from agricultural use to wetland of properties adjacent to Upper Klamath Lake will further reduce water availability for irrigation and flows down river.

   I could go on and point out many more areas where this treatise misrepresents important facts about the Klamath Basin and it’s issues. A big problem exists with the basis for requirements for high lake elevations to protect suckers both in terms of water quality and survival of adult suckers and recruitment of new suckers to the population. I submitted an analysis of these facts to the 2002 NRC Committee and I believe their assessment of the inadequacies of the data to support lake level requirements imposed by the BO bears out my opinion of this data. The basis for high flows at Iron Gate Dam is also highly suspect. I believe the flows called for based on Hardy, the Natural Flow study by the Bureau of Reclamation, and the most recent BO draft by NOAA Fisheries are far above historical flows realized before any changes to the hydrology of the upper basin. These topics are a possible future book which would tell a very different story than the one you are trying to sell in this treatise.