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Glen Spain, Zeke Grader
Dams are not forever, but they are given long-term 50-year licenses. This means any real opportunity to remove fish-killing dams represents literally a once-in-a-lifetime chance to restore an important river and save key salmon runs.
This month (November 2006) commercial fishermen have such a rare opportunity on the Klamath River. The four worst fish-killing dams on the Klamath are now up for license renewal by the Federal Energy Regulatory Commission (FERC). FERC must soon decide the fate of these dams, including whether to relicense them for another 50 years, or take them down entirely. Only FERC can make that decision, but FERC is taking public comments on its Draft Environmental Impact Statement (DEIS) on the various options under consideration – but only until December 1st, 2006. This will be the public’s only formal chance to comment on the record and influence FERC’s decision. This opportunity will not come again within most of our lifetimes. This is not a chance we can afford to miss.
One of the options under serious consideration by FERC, and the option recommended by the Pacific Fishery Management Council, National Marine Fisheries Service (NMFS), all the Klamath Basin Tribes, and PCFFA to best help restore Klamath salmon fisheries is complete removal. These dams have been an ongoing disaster for the Klamath salmon runs, and among the many dams that should come down to restore our fisheries, these are the worst.
As every California and Oregon salmon fisherman now painfully knows, salmon spawning runs have collapsed in the Klamath, this year triggering more than 700 miles of closed or nearly closed coastline, and a federal “fisheries failure” disaster declaration. PCFFA and other groups are still trying to get federal disaster assistance for the thousands of salmon fishermen out of work this season – if you can even call it a season. All these 700 miles of closures trace back to poor survival rates in the Klamath, which in turn traces back to the impact of the Klamath dams.
Klamath chinook salmon intermingle with other chinook stocks and typically migrate at sea as far south as Monterey and as far north as the Columbia River. When not enough salmon come back to the Klamath to meet the “minimum floor” of 35,000 spawners – like this year – the fisheries managers impose regulations nearing a “zero harvest,” closing or severely restricting the mixed-stock fishery, no matter how abundant non-Klamath fish are, wherever severely depressed salmon from the Klamath might incidentally be caught. Around Monterey, where Klamath salmon make up about 1.5 percent of the salmon population, saving one Klamath salmon means forgoing harvest on at least 66 otherwise harvestable fish. At the north end of their migration area, similar closures were also imposed.
The result is that the salmon fleet lost nearly all of its California and Oregon fishery this year, all because of problems caused in the Klamath. This will cost the industry well in excess of $150 million, no matter how much NMFS tries to low-ball the losses. Last year trollers lost more than 60 percent of a normal year’s harvest; this year it was more like 90 percent. Next year looks bad as well, with closures likely somewhere between 2005 and 2006 levels. Unless problems in the Klamath are corrected, there will be little fishing between Monterey and the Columbia for much of the foreseeable future.
While there is no doubt that a large portion of this most recent Klamath salmon collapse was caused by federal actions that dewatered the river in 2002 and triggered massive fish kills (see FN for August 2001, “Why the Klamath Basin Matters,” www.pcffa.org/fn-aug01.htm and FN for April 2005, “Can’t Fish Salmon? Federal Klamath Water Policies Are To Blame,” www.pcffa.org/fn-apr05.htm), there is also little doubt that the Klamath Dams have exacerbated all the river’s water quality problems and helped create the conditions for massive and toxic algal blooms. These dams made the disaster possible, have since prevented recovery of fish populations, and are likely to lead to more problems in the future. Getting those dams down won’t solve all the problems in the Klamath, but would go a very long way toward restoring these key salmon runs and opening up hundreds of river miles of blocked habitat.
PacifiCorp, an energy company recently acquired by investor Warren Buffet, owns four major Klamath Dams in the Upper Basin: from lowest to highest are Iron Gate Dam, Copco Dams Nos. 2 and 1, and J.C. Boyle Dam. Iron Gate and Copco No. 1 both have large reservoirs that trap heat, concentrate nutrients, and encourage algae growth and fish parasites. All were built without fish passage for salmon, and all now block access to at least 350 river miles of once-occupied salmon spawning and rearing habitat, much of it still in reasonably good condition and the rest restorable.
These dams have been a disaster for the Klamath fisheries. Serious water quality problems are created every year by the warm-water reservoirs behind each dam, where trapped nutrients breed algae and encourage the growth of fish parasites such as Ceratomyxa shasta, providing habitat for a host worm living in algae mats that wash downstream and allow the parasites then to spread to juvenile salmon. Hot water from Iron Gate Reservoir is also highly stressful to cold-water salmon in the lower river, every year pushing them past some of their natural temperature tolerance levels and making them more vulnerable to disease and parasites. All fish parasites are more biologically active in warmer water than in cold.
Iron Gate Reservoir is also deep enough to create a lower layer of water with very low dissolved oxygen levels which, when it is released from the dam, depresses dissolved oxygen levels for many miles downstream. Without enough oxygen in the water, fish suffocate. Anoxic water also creates high ammonia levels, poisonous to fish. Because the total water volume of the Klamath River depends so heavily on releases from Iron Gate Dam, these impacts persist all the way from Iron Gate (at River Mile 191) to the influx of water from the Trinity River, the Klamath’s major tributary (at River Mile 40.5). This middle section of the Klamath River is where most of the juvenile mortality now occurs, from C. shasta and other causes. In short, these dams are killing a whole lot of fish throughout the lower river.
Moreover, in recent years there has increasing concern with the spread of highly toxic blue-green algae throughout the dams’ reservoirs. In particular a nasty little species known as Microcystis aeruginosa is produced -- a poisonous cyanobacterium that creates a potent liver toxin, microcystin. Even small exposures to microcystin can lead to serious liver damage in humans. The airborne form of microcystin is odorless, colorless and can affect boaters who never come in direct contact with the water. This potent liver toxin also accumulates in fish, creating serious health hazards for recreational and Tribal river fishermen, but also creating additional causes of concern for the health of the fish populations themselves.
During July 2006, water samples were taken in the Iron Gate and Copco reservoirs that found Microcystis aeruginosa everywhere at levels of serious concern. At one location in Copco Reservoir the levels exceeded the World Health Organization’s (WHO) “moderate exposure” standard by more than 3,900 times! According to the researchers conducting these studies, these levels are “among the highest recorded in the world.” This stuff thrives in the nutrient-rich warm waters of reservoirs behind the dams, but is not found anywhere else. The toxins from these algae blooms, however, wash downstream.
These dams have also changed the way the river works. Among other things, the dams have trapped sediment and impoverished the river of spawning gravel for at least for 50 miles downstream of Iron Gate. The dams have also significantly decreased the frequency of natural flushing flows that once washed out fish parasites, scoured out algae, and introduced and redistributed spawning gravel throughout the river.
Under current law, deliberately building or relicensing dams without fish passage is no longer legal. On March 24, 2006, the various federal agencies (NMFS, U.S. Fish & Wildlife Service and the Bureau of Land Management) set forth their proposed recommendations for FERC relicensing, including requirements for fish passage as a condition of any relicensing. Additionally, NMFS, in its own Federal Power Act 10(a) recommendation filing also stated:
“Recommendation: The Licensee shall develop and implement a plan to remove the lower four Project dams (Iron Gate, Copco 2, Copco 1, and J.C. Boyle dams), restore the riverine corridor, and bring upstream and downstream fish passage facilities at Keno dam into compliance with NMFS guidelines and criteria within ten years of license issuance, expiration or surrender.
Under its justification, NMFS went on to, among other things, add:
“While NMFS is prescribing preliminary fishways under its authority in Federal Power Act Section 18, NMFS believes that within this relicensing process the best alternative to contribute to restoration of all fish species of concern in the Klamath watershed is the decommissioning and subsequent removal of the four lower Project dams (Iron Gate, Copco 1 & 2, and J.C. Boyle), combined with improvements in fish passage at Keno Dam. The dam removal alternative is a superior alternative from a fish passage, water quality, and habitat restoration standpoint…. Implementing this dam decommissioning and dam removal alternative would go a long way toward resolving decades of degradation where Klamath River salmon stocks are concerned.”
Unfortunately, NMFS only has the legal power under the Federal Power Act (the statute under which dams are federally licensed) to require fish passage, and can only recommend removal. However, to its credit NMFS has said repeatedly said, including in this official filing, that the best option for recovering Klamath fisheries is four dam removal.
The Pacific Fisheries Management Council (PFMC) has weighed in as well in this fight. The PFMC is well aware that none of the problems we face today are caused by overfishing, but rather are caused by high salmon losses in the damaged Klamath river system. The PFMC on April 24, 2006 wrote to the Federal Energy Regulatory Commission (FERC), noting that the value of salmon fisheries that the dams disrupt far exceeds the value of any power produced, and concluded as follows:
“The Council believes the proposed relicensing of this project will have substantial adverse impacts on EFH [essential fish habitat] in the Klamath River. The project causes harm to salmon habitat; to the health of fish stocks; to commercial, recreational, and tribal fisheries; and to fishing communities along the Oregon and California coasts and in the Klamath River basin. Consequently, the Council recommends that FERC order the immediate decommissioning and removal of the four lower Klamath River dam structures and full restoration of habitat affected by the dams and reservoirs.”
That PFMC letter and the NMFS Recommendations are on the PCFFA web site available for downloading at: www.pcffa.org.
Even the scientific panel of the National Research Council, a division of the National Academy of Sciences, said in its 2004 report on the Klamath ESA-listed fish that water quality problems created by Iron Gate reservoir presents a serious problem for lower river coho because it traps and heats water that should be cooler, and that Iron Gate Dam should be seriously considered for removal.
The four upper Klamath dams are of little importance to the regional power grid. These are small dams, which are nearly obsolete. All the four major Klamath dams combined could generate only a maximum of 161 megawatts of electricity, but cannot run all the time and so on average they have produced about 82 megawatts/year. This is less than one-tenth the amount that can be produced by just one modern gas-fired turbine power plant, and amounts to only 2 percent or less of PacifiCorp’s total generation capacity.
These dams are not even needed. The California Energy Commission has already taken a look at the impact of removing all four dams on California’s energy supply, and found it to be “insignificant.” All four dams combined are substantially less than 1 percent of California’s total power production, and far less than could be saved by even the most modest of conservation efforts.
Furthermore, the cost of retrofitting these dams for effective fish passage is way more than the dams themselves are probably worth. The FERC staff, in fact, found that dam removal of at least two of these dams (Iron Gate Dam and Copco No. 1) would be far cheaper than installing fish passage, as would otherwise be required by the agencies. In other words, it is cheaper for PacifiCorp’s customers to have the dams removed than to keep them intact, after all the costs of bringing them into compliance with current fish passage requirements are taken into account.
All this is aside from the enormous social and economic costs of lost salmon fisheries and the economic devastation to our industry in both California and Oregon that these dams will continue to cause. Unless something is done about these dams, Klamath salmon runs will continue to suffer from heated water, toxic algae blooms, and numerous water quality problems, all of which weaken fish and greatly increase instream mortality. Fish pathologists have said that outbreaks of warm water-related C shasta in recent years have killed enough juveniles each year to be equivalent to the massive fish kill of 2002. Until these dams are removed, expect more of the same.
The amount of salmon already lost from the Klamath is tragic. The best estimate for this river’s historic salmon run size is and average of 880,000 adults returning each year, mostly spring chinook. Today we are hard pressed to maintain a spawner escapement floor of merely 35,000 chinook – only 4 percent of historic run size. And these are mostly fall chinook – the spring chinook, which preferred the upper river, were mostly killed off by the dams. This is how far the Klamath has deteriorated over the last 150 years.
While the upper Klamath Dams are by no means the only problem in the Klamath, they are the cause of the worst problems, have blocked hundreds of miles of reclaimable spawning and rearing habitat, and have utterly changed the character of a river that should be -- and could once again be -- far more productive than it is today.
Today our best hope for restoring the Klamath River to something like its former glory as the third largest salmon producing river system in America lies in taking out these four dams – Iron Gate, Copco Nos. 1 & 2, and J.C. Boyle. The remaining two dams (Keno and Link River) are much smaller, do not generate power, and could easily have fish passage installed. Leaving Keno and Link River in place also assures that there would be no change to the irrigation system for the Klamath Irrigation Project. None of the other dams provide any irrigation benefits.
Iron Gate Hatchery would have to be modified to run on river water rather than water piped from the dam, but that is no different than many other hatcheries. Iron Gate Hatchery can play an important role in maintaining commercial and in-river fisheries while fish are re-colonizing the 350 miles of unblocked habitat above the dams.
Instead of full four dam removal to assure complete fish passage and clean up the river, PacifiCorp is proposing a “trap and haul” alternative to keep the dams as they are. Trapping fish at one end of the dams, crowding them all together into tanks under intense stress and conditions which allow spread of disease, and then moving them around the dams on highways to dump them at the other end of the dams is not a solution, and is certainly not “fish passage” in any real sense of the word. PacifiCorp is proposing the same program tried in the Columbia River for over thirty years, where it has never succeeded. We know better than that and so should PacifiCorp.
Unfortunately, the law does not allow federal fish agencies to require FERC to take these dams down, only to require effective fish passage. However, FERC will listen to and consider public comments and does have the power to order dam removal -- if there is enough support for that option.
You should either attend one of the planned public hearings on the Klamath FERC relicensing plans or write a letter to FERC supporting dam removal -- or both.
The only public hearings on the DEIS will be held 14-30th of November, in Northern California and Southern Oregon (see SCHEDULE below). If you cannot attend one of these meetings in person (as most of you can’t), you should instead comment in writing on the DEIS in favor of full dam removal. See the SAMPLE LETTER below for talking points to adapt and use for your own wording.
The Draft Environmental Impact Statement (DEIS) is now out for public comment, and written comments are being taken until 1400 HRS (Pacific Time) on 1 December 2006. If you want a copy of the whole document, it is posted on the PCFFA web site, along with a summary by PCFFA, the full PFMC letter and other related documents.
The FERC Staff, in the Draft EIS, analyze only four options: (1) a ‘no-change’ option to establish a baseline (required in all such documents); (2) the “Staff Alternative” which is little more than a few additional mitigation measures and a very tentative “trap and haul” program; (3) an aggressive full fish passage option being advocated by the federal and state agencies; and (4) removal of Iron Gate and Copco No. 1, with fish passage elsewhere.
What is missing is consideration of a full four-dam removal option (Iron Gate, Copco Nos. 1 & 2 and J.C. Boyle) with full fish passage at the much smaller Keno and Link River non-power dams. FERC should also analyze this option as well. Even FERC Staff admit that the most serious water quality problems caused by the dams would be cured if some of these dams were removed (i.e., they went as far as studying removal of Iron Gate and Copco No. 1). There is no reason for them not to analyze, and ultimately to choose, the removal of all four. Tell them so.
And most important: remind FERC that the dams have jeopardized the health of the Klamath River, which in turn has jeopardized the whole California and Oregon ocean salmon fishing industry, triggered widespread coastal fishing industry closures and caused widespread economic problems over 700 miles of coastline this and last year that may continue far into the future -- unless these dams are removed.
We only get one chance every 50 years to get these dams down. This is the time, and until December 1st this is your opportunity to weigh-in, in favor of a restored Klamath and a restored west coast fishery.
Your next chance will be in 2056 – so don’t wait!
DATE
Margalie Roman Salas, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 29246
RE: For Filing -- Klamath FERC Relicensing Docket No. P-2082-027
Dear Secretary Salas:
I am writing as a [commercial fisherman][fish processor] [owner of a fishing-dependent business] to oppose the relicensing of the Klamath Hydroelectric Project dams and to support removing the primary dams (Iron Gate, Copco Dams Nos. 1 & 2, and J.C. Boyle) and requiring full volitional fish passage in the remaining dams (Link River and Keno). These dams have been a disaster for the Klamath River and its economically valuable salmon runs, once the third largest in the nation, that once occupied this once-productive river.
The abundance of the Klamath’s salmon runs determines the extent of nearly all of California’s and Oregon’s ocean salmon fisheries. This year, after years of declines, Klamath salmon runs have collapsed so badly that we could not meet even the 35,000 “minimum spawner floor.” As a result the fishing industry will suffer at least $100 million in economic losses from closures over nearly 700 miles of coastline because of the need to protect these weakest limiting Klamath stocks. These economic losses are far larger than any conceivable benefits from the generation of power from these small and nearly obsolete dams.
Until these dams are removed, our industry will continue to face these sorts of crises and closures. Even the FERC Draft EIS characterized the removal of at least two dams (Iron Gate and Copco No. 1) as environmentally the best option to correct serious water quality problems caused by the dams, as well as economically the cheapest.
In short, the four major Klamath dams (Iron Gate, Copco Nos. 1 & 2 and J.C. Boyle) should be decommissioned and removed because they:
The Final Environmental Impact Statement should analyze four-dam removal (i.e., Iron Gate, Copco No. 1 and 2, and J.C. Boyle dams) as an option, with effective volitional fish passage at both Keno and Link River dams, which produce no power. A transition plan for continuing use of Iron Gate Hatchery at least until new salmon populations are well established in the Upper River should also be part of FERC’s analysis.
The National Marine Fisheries Service (NMFS) and the Pacific Fishery Management Council (PFMC), many scientists and several state agencies have all recommended removal of these four dams. This should be the option selected by FERC as the most beneficial to the commercial fishing industry and to society as a whole.
Sincerely,
Your Name and Address
Date: Tuesday, 14 November 2006
Time: 0900 –1200 HRS
Place: Shilo Inn
Address: 2500 Almond Street
Klamath Falls, OR
Date: Wednesday, 15 November 2006
Time: Both 0900 –1200 HRS and 1900 – 2200 HRS
Place: Yreka Community Theatre
Address: 812 North Oregon Street
Yreka, CA
Date: Wednesday, 16 November 2006
Time: 1900 –2200 HRS
Place: Red Lion Hotel
Address: 1929 Fourth Street
Eureka, CA
Date: Wednesday, 29 November 2006
Time: 1900 –2200 HRS
Place: North Bend Community Center
Address: 2222 Broadway Street
North Bend, OR
Date: Thursday, 30 November 2006
Time: 1900 –2200 HRS
Place: Shilo Inn
Address: 536 SW Elizabeth
Newport, OR
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