This spring the Klamath Basin Restoration Agreement (KBRA) Drought Plan Lead Entity, a subset of the KBRA signature parties, released the agreement’s draft drought plan—a plan that had not been created when the controversial agreement was signed back in February 2010.  While the long-awaited plan, open to public comment, was supposed to provide a structure and strategy for the basin’s response to drought or extreme drought under the KBRA, it fell significantly short of this anticipated agenda. 

It’s no secret, given Oregon Wild’s concerns over the KBRA and its partnered Klamath Hydroelectric Settlement Agreement (KHSA), we had high expectations for one of the deal’s most critical elements—the Drought Plan.  As we all know, the Klamath doesn’t make headlines in average or wet years.  Instead, anxieties and blood pressures rise when the river and lakes fall low and the summer temperatures hit highs.  The Drought Plan was to be the key to resolving the uncertainties posed by drought in the Klamath under the KBRA.  Instead, reviewers found a framework for a plan, a plan for a plan, a shadow, hint, ghost of a plan. 

You can access the draft plan here and review Oregon Wild’s comments on the Draft Drought Plan here.  A few excerpts from our comments include: 

-The Draft Drought Plan is notable for its general lack of specifics regarding the nature and extent of any future response to drought or extreme drought under the KBRA. The plan does not identify the likely success of its programs or offer details on how they would function. Given its general nature, it is hard to envision how the plan would be used to address the significant flow deficits that could result from implementation of the diversion limitation in certain years.

-The draft plan implies the use of “best available science” when evaluating drought risk (Section 5.2.1.B), however there is no evidence of the basin’s best available science being used in the development of the draft plan itself.

 

-In addition, it is clear the draft plan is insufficient based on the fact that Section 3.3 lists a number of tasks and critical research that have yet to be completed in order to adequately inform the team and a potential drought response (e.g., Section 3.3.1 Research and Analysis).

-Section 8.1 effectively identifies the National Research Council’s elements of and effective Adaptive Management Plan.  Unfortunately, and ironically, the Draft Drought Plan does not adhere to the elements identified:

    A. Clear restoration goals and targets;
    B. Sound baseline/reference conditions;
    C. An effective process for learning fro restoration    and management actions;
    D. An explicit process for refining and improving future restoration actions (discussed further below under Adaptive Management); and
    E. An effective peer review process.

-The Draft Drought Plan does not acknowledge the role of the Endangered Species Act (ESA), except to acknowledge that the draft plan is not intended to “limit the applicability of effect of the ESA…” (Section 1.1.).  Otherwise, the draft plan appears to assume that the ESA will either disappear or simply adopt the terms of the KBRA, as its legal requirements of flows in the Klamath Basin are not further discussed. To the extent that neither of these occurs, the draft plan fails to clearly articulate how it will constructively interface with the ESA. We see this as a missed opportunity to reach a good result for the basin.

In considering what might constitute a valuable and appropriate Drought Plan, Oregon Wild contends that a Final Drought Plan must address actual water quantities.  That is, a plan must define the scope of the issue to be addressed; consider and identify what the desirable water targets are for each stakeholder or resource demand; address how, during a drought, each demand is affected; and clearly identify the target or baseline that the plan is attempting to achieve. 

Oregon Wild, along with the fish, look forward to a final plan that incorporates appropriate demand reduction targets, considers peer review, and administers the region’s best available science.