Keno Reservoir and Interim Dam License Conditions – A Klamath Sleeper Issue

While it has been intentionally mystified and ignored, what will be included in Interim License Conditions for Klamath River Dams is likely one of the most important issues which will impact the fate of Klamath Salmon, the health of the River and its communities for the next 20 years or more. Interim Conditions refers to changes in operations and other actions which the Federal Energy Regulatory Commission (FERC) can require PacifiCorp to take between now and when the dams are either relicensed for 50 years, removed or transferred to other ownership. This could take a long time and during that time the fate of Klamath River Coho and Spring Chinook could be sealed…..one way or the other.

Several environmental and fishermen’s organizations and at least two tribes supported PacifiCorp’s recent attempt to get California’s State Water Resources Control Board (SWRCB) to “suspend” consideration of whether the dams can meet water quality standards established to protect the Public Trust and the beneficial uses of water. These organizations argued that PacifiCorp was making a good faith efforts toward a dam settlement which would remove four of the five mainstem dams and transfer a fifth dam – Keno – to the Bureau of Reclamation. Because of PacifiCorp’s good faith, these groups argued, the company should not be required to participate in a water quality study which would be moot if the dams are removed.

However, these PacifiCorp apologists failed to mention that the water quality studies which PacifiCorp wants “suspended” will also recommend the Interim Conditions which PacifiCorp will be required by FERC to implement until the dams are finally licensed, removed or transferred. The apologists also failed to mention that the state water quality studies and Interim License Conditions are the only way that California can get PacifiCorp to do its part in cleaning-up Klamath River pollution under a plan currently being developed by the North Coast Water Quality Control Board.

How do self-proclaimed Klamath Defenders become apologists for the interests of PacifiCorp and Warren Buffet? The answer has a lot to do with ego, funding and future career prospects: the removal of Klamath River Dams will advance the careers of those who can claim credit whether or not Klamath Salmon and the future health of the River are compromised in the process.

With several of the Klamath’s most prominent Defenders so committed to dam removal that they will work for PacifiCorp’s interest in order to facilitate a dam removal deal, it falls to others to take up the slack. The Hoopa Tribe is doing its share – focusing on Interim Conditions for dam operations. But so far the Hoopa have only pushed for interim flows within the Klamath Hydroelectric Project Area. While this issue is important (see KlamBlog’s January 27th post), the most important issue which needs to be addressed in Interim Conditions is the poor water quality behind PacifiCorp’s Keno Dam, i.e. in Keno Reservoir.

Also known as Lake Ewana, Keno Reservoir consistently contains water of the worst quality found anywhere in the Klamath River Basin. Fish kills occur in the Reservoir nearly every year. The water quality related die-offs are downplayed by the Oregon Department of Environmental Quality and local media. For example, a recent news article in the Klamath Falls Herald and News gave the impression that the fish kills are normal because they happen nearly every year. But these fish kills include endangered Kuptu and Tsuam (sucker species) and they are in no way natural.

Keno Reservoir makes the polluted agricultural wastewater it receives much worse because the extensive marshes which once rimmed the area are now mostly gone – replaced by irrigated agriculture, a plywood mill, a power plant and livestock operations. If it is not cleaned up, Keno Reservoir could be a death trap for salmon and steelhead trying to navigate to and from the Upper Basin once the other four dams are removed.

It is essential to recovery of Klamath Salmon and to the restoration of the Klamath River that the pollution at Keno Reservoir is addressed now – through Interim Conditions for PacifiCorp’s continued operation of the Klamath Hydroelectric Project. For one thing we may have to wait more than a decade for dam removal to even begin. Most importantly, if we don’t address Keno pollution now the mandate for cleaning it up will pass with the transfer of Keno Dam and Reservoir to the Bureau of Reclamation (BOR). With its powerful irrigation clients opposed to clean-up, it would likely take years of litigation to get the BOR to clean-up Keno Reservoir.

Cleaning-up Keno is feasible but it will not be cheap. Decades of tree bark which has accumulated on the Reservoir’s bottom as a result of log storage must be removed and the ongoing storage of logs in the Reservoir must end. Either treatment plants or treatment wetlands must be put in place on the Klamath Straits and on the outflow from Upper Klamath Lake and the Lost River Diversion Channel. All three discharge polluted agricultural wastewater into Keno Reservoir.

The most cost effective method for cleaning up Keno would involve the restoration of Lower Klamath Lake whose extensive wetlands once stored and cleaned high winter and spring flows for later release to the River. Studies of existing permanent and seasonal wetlands in the Lower Klamath area demonstrate that they effectively remove phosphorus and other nutrients from water which passes through them. Restoring Lower Klamath Lake would provide many other benefits including to waterfowl, Bald eagles, duck hunters, bird watchers and the local economy. But it is fiercely opposed by the Irrigation Elite who want to maximize the amount of public and private lands which they can lease at low rates and then farm with high profit margins.

What this all means is that the decision of the SWRCB to continue the water quality studies and to recommend Interim Conditions for reservoir clean-up to FERC is a victory for the River and Klamath Salmon. But that victory is partial at best. Will the SWRCB focus on Keno and tell FERC to require that PacifiCorp develop and implement a clean-up plan BEFORE it is allowed to transfer the dam and reservoir to the Bureau of Reclamation? With many Klamath Defenders preoccupied with dam negotiations or shilling for PacifiCorp, it may be necessary for ordinary citizens and new organizations to step up and demand the clean-up. This may already be happening. An action alert on Klamath water quality issues was recently circulated by an entity calling itself Klamath First Advocates – a name which has not been seen before. The entity has yet to define itself publicly.

Citizens who want to support the clean-up of Keno Reservoir before it is transferred to the BOR should let the SWRCB, NCWQCB and FERC know that this is a priority. Tell them that Interim Conditions for operation of the Klamath River Dams must include a requirement that PacifiCorp develop a clean-up plan, time-lines and clean-up financing plan for Keno Reservoir before it is transferred to the BOR. Contact information is provided below.

Tam Doduc & Jennifer Watts
California State Water Resources Control Board
P.O. Box 2000
Sacramento, CA 95812-2000
Via e-mail: TDoduc@waterboards.ca.gov
JWatts@waterboards.ca.gov

Ms. Catherine Kuhlman, Executive Officer
North Coast Water Quality Control Board
5550 Skylane Blvd.
Santa Rosa, CA. 95403
Via e-mail: CKuhlman@waterboards.ca.gov
MStJohn@waterboards.ca.gov

Magalie Roman Salas, Secretary
Federal Energy Regulatory Commission
Project P-2082-027
888 First Street NE
Washington, DC 20426
http://www.ferc.gov/contact-us/contact-us.asp
John.Mudre@ferc.gov