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Klamath Dam Removal

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October 27, 2006

Margalie Roman Salas, Secretary                                                                   
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC  20246
 
RE: Klamath FERC Relicensing Docket No. P-2082-027

Dear Secretary Salas:

I am writing 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 fish passage in the remaining dams (Link River and Keno).  These dams have been a disaster for the Klamath River and its valuable salmon runs, once the third largest in the nation.

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 they did 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, we 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 the cheapest and most effective way to correct serious water quality problems caused by the dams.

The four major Klamath dams (Iron Gate, Copco Nos. 1 & 2 and J.C. Boyle) should be decommissioned and removed because they:

- Have no fish passage and block some 350 stream miles of once occupied salmon spawning and rearing habitat that could be once again productive;

- Collect huge pools of nutrient-laden warm water in their reservoirs which are breeding grounds for toxic algae and fish diseases like Ceratomyxa shasta;

- Add warm water from their reservoirs that decreases dissolved oxygen levels and adds to stresses on cold-water fish, often pushing summer water temperatures in the lower river past salmon tolerance levels;

- Block recruitment of gravel to the lower river for salmon spawning and rearing habitat for at least 50 miles downstream from Iron Gate Dam;

- Have disrupted the natural hydrology of the Klamath River, including limiting flushing flows that in the past have scoured out fine sediment and algae, limited the spread of fish diseases, and nourished riparian vegetation;

- Represent less than 2 percent of PacifiCorp’s total power generation, and only a fraction of 1 percent of California’s and Oregon’s power grid;

- Provide only a minimal amount of power that can be easily replaced by renewable energy sources or through very minimal conservation efforts;

- Create more social harm (including economically devastating the west coast salmon fishing industry) than any conceivable power benefits they might provide, and;

- Violate the Clean Water Act, the Endangered Species Act, the Magnuson-Stevens Sustainable Fisheries Act and federal legal obligations to the Tribes and to commercial fishermen to protect our salmon fisheries.
 
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 fish passage at both Keno and Link River dams, which produce no power.  

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.
 
Sincerely,

Your Name and Address