from John M. Sully of Ashland, Oregon:
On September 7, 2010 the California State Water Resources Control Board adopted a set of standards for Total Maximum Daily Loads (TMDL) for the Klamath and Lost Rivers in the Klamath River drainage. The Action Plan for the Klamath River Total Maximum Daily Loads addresses Temperature, Dissolved Oxygen, Nutrients, and Microcystin Impairments in the Klamath River in California and Lost River. The action plan was forwarded to the EPA and approved 12/28/2010 under the Clean Water Act section 303 (d) (2).
The Klamath River was declared to be water quality limited in 1996. There has been pressure to get the California State Water Resources Control Board to set TMDL limits ever since. At least 4 species of fish are listed as rare/endangered in the Klamath Basin and River and tributaries. Recovery of these has been a mandate of the Water Resources Control Board. But declaring the river system to be water quality limited, and setting TMDL limits does not necessarily result in action being taken to clean up the river.
Recover of Four listed species of fish, the Endangered Species Act, the Clean Water Act section 303 (d) (2) could be a strong motive for taking action. Transferring Keno Dam to BOR from PacifiCorp may lead to an environmental review of the proposed Transfer Agreement and/or those of its provisions which are pertinent to Klamath River clean-up under the Basin Plan. It should happen as the impoundment behind Keno Dam has the accumulation of all pollution of human activity in the Klamath Basin and for which BOR will be responsible after the transfer!
Keno Reservoir receives all Upper Basin Ag and Municipal waste.
Keno has the worst water quality in the Basin and many opportunities to restore wetlands
Complying with the required TMDL limits does not have to be expensive or complicated!!! It can be as simple as utilizing existing or constructed wetlands as “cleaners”. Wetland functions include water storage, ability to remove pollutants by wetland vegetation (obligate wetland and facultative wetland, and facultative plants) growing in the wetlands. Wetlands will also reduce sedimentation downstream of the wetlands, reduce temperature of the incoming water through shading by the wetland vegetation, reduce erosion by slowing the flow of water, and increase habitat for wetland dependant species, i.e. waterfowl, various invertebrates, amphibians, fishes, etc.
Klamath Basin is an ideal place to establish constructed wetlands, or utilize existing wetlands to meet the TMDL standards. One example of a treatment wetland would be the Klamath Straits Drain area. The area is large, flat, and before the inception of the BOR project was a wetland. Flooding the area would have the effect of reestablishing a wetland. Modifications probably would have to be made to the “plumbing” to reestablish flow to the river. But it is a feasible project.
Other possibilities include creation of wetland swales around areas where cattle are grazing, cultivated fields, etc. Constructed wetlands could be located adjacent to sewage treatment plants for secondary sewage treatment, as has been done very successfully at the Arcata marshes and in Indio, California. Dr. Robert Gearhart of Humboldt State University may be available as a consultant in designing treatment wetlands for TMDL clean up.
The use of treatment swales has been successfully used along the I-5 freeway and the coastal route in Orange County in District 7 (Los Angeles) to protect marshes from highway nonpoint source pollution that threatened Marina Del Rey and Anaheim Bay (Bolsa Chica NWR). The use of constructed/treatment wetlands is a well recognized science by EPA and the National Research Council (see Wetlands Characteristics and Boundaries and Compensating for Wetland Losses Under the Clean Water Act, published by the National Research Council and publications of EPA).
If BOR is sincerely interested in “restoring” the Klamath Basin and doing so in an economical and ecological manner, the use of treatment wetlands/constructed wetlands for reducing pollution from point sources and non point sources would be a way to ease the conflict with the environmental community.