[env-trinity] New Klamath Project Water Plan EA comment period ends March 19th

[Regina Chichizola]

Hello,

The Bureau of Reclamation is taking comments on current Klamath Project
Operations proposed under their new Biological Assessment. They have only
done a EA with a two week comment period and have not included spring flows
that are currently mandated to reduce fish diseases under the Klamath
Biological Opinion court order, or a emergency fish disease plan.

 Save California Salmon has put a petition up at change.org at
http://chng.it/yxx9TVxsbh or on our facebook page and twitter for people
that would like to comment. We are asking for an EIS and 90 day comment
period and many other actions to stop juvenile fish kills.

The notice is at
https://www.usbr.gov/mp/nepa/nepa_project_details.php?Project_ID=37522

Comments must be received by March 19, 2019. The comments may be sent via
email to tcampbellmiranda at usbr.gov, or by hard copy to Tara Jane Campbell
Miranda, Bureau of Reclamation, 6600 Washburn Way, Klamath Falls, Oregon
97603.

A background and key points for comments are below.

Thank you,

Regina Chichizola



 On March 6th, the Bureau of Reclamation (BOR) issued a public
Environmental Assessment on the Operations Plan for the  Klamath
Irrigation. Project Operations controls flows in the Klamath River below
Upper Klamath Lake. The outcome may determine whether  ESA listed coho
salmon and Lost River suckers will survive another generation and how many
chinook salmon people have for harvest. Despite the importance of the
decision, BOR is only allowing the public two weeks to comment.

The Biological Assessment will lead to a Biological Opinion or Bi-Op, which
will control flows  the Klamath River. The plan is a significant federal
action and BOR should complete an Environmental Impact Statement (EIS) that
analyzes the impacts of the proposed flows to the Klamath River fisheries,
water quality, economy and people, along with impacts to the coast
communities that depend on the Klamath’s fishery.

This EIS should include a 90 day public comment period and public hearings.

The Klamath Biological Opinion may sound familiar because the Bush
administration’s tampering with the 2001 Klamath Project Biological Opinion
lead to a massive fish kill of an estimated 64,000 adult salmon in the
Klamath River, and the 2013 Biological Opinion lead to a juvenile fish
disease rate of 84-92% during t during California’s recent drought. This
fish disease C. shasta  caused  massive juvenile fish kills, contributing
to the Klamath’s lowest recorded salmon run in 2017.

These fish kills and related low salmon runs have caused major impacts to
coastal and Tribal communities due to commercial and subsistence salmon
fishing closures. In  2017 Yurok Tribal members were allocated only 1 fish
for every 6 Tribal members. Karuk limited its dip net fishery for the first
time in history to 200 fish, and commercial, subsistence, and recreational
fishing was severely limited for others as well. Lack of salmon has also
led to major health, social and economic hardships for Tribal people and
coastal towns such as Eureka and Crescent City, and Brookings that rely on
salmon for food, income, ceremonies, and culture. It has also disrupted the
food web that relies on salmon.

The 2013 Biological Opinion was litigated by the Yurok and Hoopa Valley
Tribes along with Commercial fishermen and conservation groups. These
lawsuits resulted in court ordered improvements in flows.  The currently
proposed BOR flow schedule that are the subject of this Environmental
Assessment would result in lower flows and higher risk of fish disease.

In short:

* The BOR should do an Environmental Impact Statement on the water plan
analyzing all the impacts to all the Klamath River fisheries and water
quality impacts from their action,


* The BOR should include the court ordered flushing flows to combat fish
disease in their Environmental Water Accounting for all water year types,


* The BOR should not only not jeopardize endangered species, but also
provide enough water to protect tribal trust species and fishing rights,
the public trust, and the Clean Water Act. This means they need to provide
for a harvestable surplus of all species of salmon,


* The BOR should analyze the economic and social impacts to river and
coastal communities resulting from their actions,

* The BOR should analyze the cumulative impacts of their actions with other
state and federal impacts such as flow decisions in the Klamath
tributaries, the proposed LNG pipeline in the Upper Klamath Basin, along
with the new dam and diversion projects, and the Trump Water Plan, that
impact the Trinity River,


* The BOR should include an emergency flow plan to respond to massive fish
disease outbreaks of the C. shasta fish disease


 * The BOR should clearly account for, and detail, the water provided to
farmers and the   Environment Water Accounting, and not use confusing water
budgeting and accounting.








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