Magalie R. Salas
Secretary, Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426

November 22, 2006

Dear Ms. Salas,

The following are my comments on the Draft Environmental Impact Statement (DEIS) for the relicensing of PacifiCorp’s Klamath Hydroelectric Project, No. 2082-027. I am submitting these comments as a concerned citizen who cherishes and enjoys the natural resources of the Klamath River Basin.

PacifiCorp’s hydroelectric operations on the Klamath River have a well-documented negative impact on salmon and steelhead runs and on water quality.  The Klamath River was once the third largest producer of salmon on the West Coast, yet today the river’s economically and culturally valuable salmon runs have suffered severe declines.  A lethal combination of low water flows, poor water quality, and loss of habitat are the primary culprits in the decline of these fish.

The collapse of Klamath salmon runs have in turn led to severe economic and cultural hardship for the region’s Native American Tribes, as well as for recreational and commercial fishing communities.  Commercial salmon harvest off the coast of Oregon and Northern California was subject to a near-total closure this year.  The closure was put in place to protect what is left of the Klamath River’s wild fall Chinook run.

Unfortunately, the Federal Energy Regulatory Commission (FERC) DEIS appears to give little consideration to these facts.  The draft statement failed to address a number of crucial issues that should be evaluated and incorporated into a new DEIS to ensure a complete analysis of the effects of Pacificorp’s hydroelectric operations upon the Klamath River.  These include:

1. Fully evaluate dam removal.  FERC only examined the removal of two dams in the DEIS.  A four dam removal scenario (JC Boyle, Copco 1, Copco 2, and Iron Gate dams) is likely to produce far more benefit for salmon, particularly for severely depressed runs of spring Chinook.  Removal of the lower four dams will provide salmon and steelhead vastly more habitat than the more modest scenario examined by FERC’s DEIS.  Removal of all four of these dams is also likely to result in a much greater improvement in water quality in the Klamath River below the dams.

2. Trap and haul schemes are ineffective.  In preparing the DEIS, FERC staff developed their own alternative to dam removal that requires trapping fish at the base of Iron Gate Dam, loading them into trucks, and hauling them nearly 75 miles upstream before releasing the fish back into the Klamath River above JC Boyle Dam.  FERC’s alternative ignores the widespread failure of similar trap and haul efforts throughout the Pacific Northwest.  It also ignores NOAA Fisheries’ requirement for full volitional fish passage at the dams.

3. Sediment is not an issue of concern.  The California Coastal Conservancy recently conducted an analysis of the sediment trapped behind the lower four Klamath River dams.  This study concluded that dam removal could be done safely and at reasonable cost without exposing the river to toxic materials or increasing flood risks.  FERC should consider and incorporate this study into the final environmental impact statement.

4. Consider the findings of the Energy Policy Act hearings.  The administrative law judge that oversaw the recent Energy Policy Act hearings concluded that Pacificorp’s Klamath River hydroelectric project operations “…have and continue to adversely affect…” river health, including the resident trout fishery and riparian habitat.  The Judge went on to conclude that fish passage and environmental restoration measures required by federal agencies would benefit threatened coho salmon and other anadromous fish, resident trout, Pacific lamprey and riparian habitat.

Thank you for your consideration of my comments on the relicensing of PacifiCorp’s Klamath Hydroelectric Project, No. 2082-027.  I hope that FERC address the shortcomings of the current DEIS, and makes improvements in a new DEIS so that it better addresses the essential need to protect the spectacular resources of the Klamath River.

Sincerely,