John C. Boyle Dam Gates Open
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By Jerry Bacigalupi
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THE KLAMATH RIVER HYDROELECTRIC FACILITIES (FERC Project No. 2082) have been requested for decommissioning by PacifiCorp with support from some state and federal agencies (Surrender of License #20160923-5370) for Iron Gate Dam, Copco No. 1 Dam, Copco No. 2 Dam, J.C. Boyle Dam, and appurtenant hydroelectric works and to be transferred to a dam removal (“shell”) corporation (KRRC).
SEDIMENT AND EROSION CONTROL PLANS are the most important environmental documents in dam removals. As a Registered Civil Engineer, it is inconceivable that State and Federal project approval agencies are requesting the contractor to be responsible for developing and implementing a Stormwater Pollution Prevention Plan (SWPPP) and a Water Quality Management Plan (WQMP). These plans must be developed and approved by qualified engineering personnel before any project goes out to bid.
This Project (FERC Project No. 2082) is one of the most upside-down administered undertakings that has been introduced and supported by State and Federal agencies; ignoring existing State and Federal regulations in order to support the allowance of 20 million +- cubic yards of poor-quality sediment down river with unknown consequences. This reckless action is a violation of existing laws and regulations and not acceptable to local private or public agencies, nor the public without ensuing major lawsuits.
The only environmentally acceptable answer to Klamath River Dams Removal Project (FERC Project No. 2082), if approved, is the requirement for State and Federal agencies to prepare acceptable SWPPP and WQMP plans before the project goes to bid in order to prevent the release of dam-collected sediments down river (after an acceptable plan review period by State, Federal, Local agencies, and the Public).
RECOMMENDED SEQUENCE FOR PREPERATION OF A SWPPP
A Stormwater Pollution Prevention Plan (SWPPP) requires the detention of peek flows not to exceed historic peek flows and the retention of project-generated sediments.
Starting at the most upstream reservoir, J.C. Boyle, and proceeding downstream to Copco 1, Copco 2, and Iron Gate Reservoirs the following environmental measures (to control river flows and prevent the release of 20 million +/- cubic yards of poor-quality sediment down river to the estuary) must be performed:
1. Slowly drain the reservoir using the existing outlet drain facilities. 2. Dredge the sediments out of the dams as the water level is lowered. 3. Place the wet sediment at an environmentally safe location to allow drying prior to final placement (also in an environmentally safe location). 4. Place environmental erosion control fencing on exposed bare slopes subject to erosion as the water level lowers. 5. Open the bypass tunnels after sediment removal. 6. Remove the dam embankment and hydroelectric facilities prior to moving downstream to the next reservoir. 7. Move downstream to the next reservoir and perform the above sequences.
It is important to maintain downstream dams and hydroelectric facilities as operational during upstream project removals. This will allow the generation of hydroelectric power, retain any upstream released sediments, and control peek river flows.
Note: The dams proposed for removal satisfy both SWPPP and WQMP requirements for all Klamath Basin Projects developed in the past 100+ years. To remove these dams and allow the release of 20+/- million cubic yards of project-generated sediments and uncontrolled flood waters down river is irresponsible, reckless, and violates existing laws and regulations. The State and Federal agencies and responsible directors who allow this to happen should face lawsuits and possible reorganization with appropriate removals from office.
Please review, study, and consider the following information pertaining to the Klamath River Basin and the many benefits provided by the Klamath River Dams:
1. The Klamath Basin is the only upside-down basin on the west coast (warm poor water quality above J.C. Boyle Dam), with water temperature and quality improving as it travels to the ocean.
2. Moonshine Falls, directly below J.C. Boyle Reservoir, is cited by CDFW to be the upper most habitat for anadromous fish.
3. The downstream dams have absolutely nothing to do with the Upper Basin water wars. They improve the DOI Klamath Project’s regulated flows to farmers and ranchers by providing required minimum instream flows.
4. The California dams have been inspected recently by the Division of Dam Safety and are in good condition.
5. These dams provide a 25+% down river flood and surge protection (based on the 1964 flood hydrograph measured at the gage below Iron Gate Dam) and provide an average yearly water quality improvement.
6. Given the condition of a complete Klamath River cutoff by the DOI, or a severe drought, the dams can also provide CDFG/CDFW’s 700 cfs minimum instream river flows for a three-month period with adequate storage retained for lake habitat.
Furthermore, it is within the SWRCB & FERC’s responsibility to consider the public interest to retain and pursue the relicensing of the hydroelectric facilities to a “responsible” entity.
Siskiyou and Klamath Counties, and the cities within, have the statutory responsibility to provide and protect the public’s interest and safety to all citizens and protect the environment for present and future generations. In 2010 the voting populous of Siskiyou County (79.04%) and in 2016 Klamath County (72%) voted to keep the dams. Through proper and legal voting procedures the people overwhelmingly voted to retain the Klamath River Dams and Hydroelectric Facilities.
Coho Truck and Haul Studies above J.C. Boyle Dam were demanded but refused by the DOI, likely because they realized anadromous habitat did not exist. It is said that the only way Coho juveniles can get back from the tributaries of Upper Lake to the ocean is to become flying fish. Truck and haul studies must be completed to support removing the dams. Without this study the environmental documents fail and are subject to MAJOR LAWSUITS.
The environmental documents are incomplete. They fail to analyze alternatives with the dams in place. They fail to provide Cost/Benefit Analyses. They fail to include substantial crop and property value losses to farmers and ranchers due to unjustified water cutoffs. They fail to examine the financial losses and potential hardships to the County, for example.
The release of 20 +/- million cubic yards of toxic sediments retained behind the dams and released down river for years to come is irresponsible, violates the 401 Clean Water Act, and requires the preparation of a Storm Water Pollution Pretention Plan. It will decimate river habitat for decades. It is careless that sediment removal by dredging has been abandoned because of costs.
Under existing law, the California Division of Dam Safety requires Dam Removal Plans be submitted and approved and then verify Dam Removal Plans and Conditions are followed. They annually inspect the Klamath River Dams and consider them in good condition.
Siskiyou and Klamath Counties have and are mandated (within their existing regulations and public safety authorities) to require and approve Klamath River Dam Removal Permits and are not preempted by State and Federal agencies.
The DOI and State agencies have circumvented State and Federal laws by certifying false, questionable, bogus scientific studies to justify dam removals.
The flood control provided by the Klamath River dams proposed for removal is substantial. See my comments on the Klamath Facilities Removal Final EIS/EIR to the BOR which shows that my 100 year flood calculation of 37,000 cfs below Iron Gate Dam (based on the 1964 flood hydrograph peek flow of 29,400cfs) reduces peak flow by 26%. My 100 year peak flow should be much lower than the BOR 30,000 cfs, which is being used for the Klamath River flows for the Lower Klamath Project, noting the BOR Table 3.6-9 shows the dams only provide a 6.9% reduction in flood attenuation.
The Draft EIR fails to consider feasible and public-supported alternatives with the dams remaining in place.
MY FINAL RECOMMENDATION IS TO KEEP THE DAMS AND PROPOSE BENEFICIAL, CONSTRUCTIVE ALTERNATIVES WITH THE DAMS IN PLACE. It has not been established that anadromous fish habitat exists above J.C. Boyle Reservoir or that any other Federal or State listed benefits justify dam removals. Therefore, STOP the largest Proposed Dam Removal Project in the world and preserve the Klamath River Basin economy and ecosystem.