BOR: Increase Klamath River flows, and do an EIS for Water Plan

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On March 6th, the Bureau of Reclamation (BOR) issued a public Environmental Assessment on the Operations Plan for the  Klamath Irrigation. Project Operations controls flows in the Klamath River below Upper Klamath Lake. The outcome may determine whether  ESA listed coho salmon and Lost River suckers will survive another generation and how many chinook salmon people have for harvest. Despite the importance of the decision, BOR is only allowing the public two weeks to comment.

The Biological Assessment will lead to a Biological Opinion or Bi-Op, which will control flows  the Klamath River. The plan is a significant federal action and BOR should complete an Environmental Impact Statement (EIS) that analyzes the impacts of the proposed flows to the Klamath River fisheries, water quality, economy and people, along with impacts to the coast communities that depend on the Klamath’s fishery.

This EIS should include a 90 day public comment period and public hearings.

The Klamath Biological Opinion may sound familiar because the Bush administration’s tampering with the 2001 Klamath Project Biological Opinion lead to a massive fish kill of an estimated 64,000 adult salmon in the Klamath River, and the 2013 Biological Opinion lead to a juvenile fish disease rate of 84-92% during t during California’s recent drought. This fish disease C. shasta  caused  massive juvenile fish kills, contributing to the Klamath’s lowest recorded salmon run in 2017.

These fish kills and related low salmon runs have caused major impacts to coastal and Tribal communities due to commercial and subsistence salmon fishing closures. In  2017 Yurok Tribal members were allocated only 1 fish for every 6 Tribal members. Karuk limited its dip net fishery for the first time in history to 200 fish, and commercial, subsistence, and recreational fishing was severely limited for others as well. Lack of salmon has also led to major health, social and economic hardships for Tribal people and coastal towns such as Eureka and Crescent City, and Brookings that rely on salmon for food, income, ceremonies, and culture. It has also disrupted the food web that relies on salmon.

The 2013 Biological Opinion was litigated by the Yurok and Hoopa Valley Tribes along with Commercial fishermen and conservation groups. These lawsuits resulted in court ordered improvements in flows.  The currently proposed BOR flow schedule that are the subject of this Environmental Assessment would result in lower flows and higher risk of fish disease.

In short:

* The BOR should do an Environmental Impact Statement on the water plan analyzing all the impacts to all the Klamath River fisheries and water quality impacts from their action,
* The BOR should include the court ordered flushing flows to combat fish disease in their Environmental Water Accounting for all water year types,
* The BOR should not only not jeopardize endangered species, but also provide enough water to protect tribal trust species and fishing rights, the public trust, and the Clean Water Act. This means they need to provide for a harvestable surplus of all species of salmon,
* The BOR should analyze the economic and social impacts to river and coastal communities resulting from their actions,

* The BOR should analyze the cumulative impacts of their actions with other state and federal impacts such as flow decisions in the Klamath tributaries, the proposed LNG pipeline in the Upper Klamath Basin, along with the new dam and diversion projects, and the Trump Water Plan, that impact the Trinity River,
* The BOR should include an emergency flow plan to respond to massive fish disease outbreaks of the C. shasta fish disease
 * The BOR should clearly account for, and detail, the water provided to farmers and the   Environment Water Accounting, and not use confusing water budgeting and accounting.

It is time for the BOR and Trump administration to Restore the Klamath Salmon and Suckers and support all the communities that rely on Klamath watershed.

Comments must be received by March 19, 2019. The comments may be sent via email to tcampbellmiranda@usbr.gov, or by hard copy to Tara Jane Campbell Miranda, Bureau of Reclamation, 6600 Washburn Way, Klamath Falls, Oregon 97603.