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NW Fishletter #388, Dec. 3, 2018
 Siskiyou County, Water Users Ask FERC To Deny Klamath Dam Removal
Siskiyou County, Calif., and the nonprofit Siskiyou County Water Users Association have asked the Federal Energy Regulatory Commission to deny a plan to remove four dams in the Klamath River.
The county says the plan underestimates the costs and risks, has an unrealistic time schedule, and "substantively fails to address many critical aspects of the project," while the water users say removal could wipe out the river's endangered sucker fish and would do little to boost coho runs, which--the group claims--may not have been present above the dams before they were built.
In a comment filed on Nov. 2, an attorney representing the county asks FERC to deny the application to transfer the license for the four projects from PacifiCorp to the Klamath River Renewal Corp. (KRRC); three of the hydroelectric projects are in Siskiyou County.
The comment states that KRRC's Definite Plan for removing the dams "is fatally flawed, and does not support a conclusion that KRRC will be able to undertake the project as proposed."
It says that KRRC's proposed schedule--to draw down the reservoirs on Jan. 1, 2021, to begin removal--doesn't take into account the lengthy environmental permitting requirements, from Endangered Species Act consultation and a National Environmental Policy Act review, to a Clean Water Act permit.
The short timeframe is one of the most significant flaws of the plan, the county claims, and "appears to be driven by KRRC's desire to make the cost of the Project ... fit within KRRC's budget."
The county also says that $450 million earmarked for dam removal and restoration is insufficient. Under KRRC's analysis, the project is likely to cost about $397.7 million; a "most probable low estimate," is $346.5 million, and a "most probable high estimate" is $507.1 million--$57 million more than the funding available from PacifiCorp customers and the California Legislature.
The county says that if the project is delayed by three to six years, the cost of the project can be expected to increase by $50 million to $100 million or more, but the plan includes no funding for delays.
Siskiyou County also argues that the plan does not attribute costs to several risks, and does not provide adequate funding to compensate landowners for lost property values or the county for lost revenue from decreases in property values and taxes.
The comment details many other components the county says are inadequately addressed, including aquatic and terrestrial resources and plans for road improvements, Yreka's water supply, downstream flood control, closing two fish hatcheries, water quality monitoring, groundwater well monitoring and fire and traffic management.
On Nov. 21, the water users association--an intervenor in the case--contends that the "entire stated reason for destruction of the dams rests on the belief that the coho salmon are indigenous to the Klamath, when in fact historical records show" they never were plentiful--if present at all--before the dams, its filed comments state. The filing asserts the fish have had to be replanted numerous times in recent history to keep the river stocked.
The association also claims that removing the dams is likely to impair water quality, and cause damages from flooding. And, it says, the Amended Klamath Hydroelectric Service Agreement that led to the current effort and to the FERC applications was illegal, as it circumvented prior unsuccessful efforts that required Congressional approval.
The eight-page letter suggests that KRRC is underfunded and offers no security to residents whose property may be damaged by flooding if the dams are removed. Additionally, it states, the dams now provide fire protection, flood control, sufficient flows for fish, recreation, improved property value, and a hatchery that raises more than 6 million smolts a year.
"We encourage the commission to reject this ill-founded attempt and underfunded effort by a shell corporation to remove these Klamath Dams, subjecting an entire population of endangered species as well as the human element to a major catastrophe," their letter states, adding that FERC "will be held fully accountable for a disaster occurring because of a failure to protect the public and the surrounding counties who will bear the brunt of any miscalculation." -K.C. Mehaffey
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