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for Siskiyou and Klamath Counties

May 2014 by the Bi-State Alliance


The Department Of Interior (DOI) Final (EIS/EIR) Environmental Impact Statement / Environmental Impact Report eliminates Alternative 11 (Fish Bypass: Alternative Tunnel Route) because it does not remove any the four dams under the Klamath Basin Restoration Agreement & Klamath Hydro-Electric Settlement Agreement (KBRA & KHSA) requiring DAM REMOVALS.

Alternative 11 (Fish Bypass: Alternative Tunnel Route) is identified by Siskiyou County as the environmentally preferable alternative that would result in a cost of 1/6 the cost of installing fish ladders, 5% the cost of dam removals, and has the fewest adverse effects to the biological and physical environment.

The below write up by the (DOI) and Calif. Department of Fish and Wildlife (CDFW)  3.11 Alternative 11 appears to have all the merits for the  Environmentally Preferable/Superior Alternative.

Per EIR/EIS section Environmentally Preferable/Superior Alternative:

NEPA requires the Lead Agency to identify the alternative or alternatives that are environmentally preferable in the Record of Decision (ROD) (40 CFR Part 1505.2(b)). to quote:

“The environmentally preferable alternative generally refers to the alternative that would result in the fewest adverse effects to the biological and physical environment. It is also the alternative that would best protect, preserve, and enhance historic, cultural, and natural resources.”


The DOI and CDFW are improperly invested in dam removals and will not and cannot consider feasible alternatives and mitigation measures because they have already signed and are committed to the KBRA and KHSA settlement agreements which will become invalid IF DAMS ARE NOT REMOVED.  Dam Removals or Partial Removals are the only alternatives being considered. The Lead Agencies’ Final EIR/EIS has failed to identify and properly weigh and consider the benefits of alternatives that do not support the Klamath Basin Restoration Agreement & Klamath Hydro-Electric Settlement Agreement (KBRA & KHSA) Requiring DAM REMOVALS.




To quote the write up in the EIS/EIR:

“3.11 Alternative 11 – Fish Bypass: Alternative Tunnel Route

This alternative would use a combination of natural drainages and a constructed tunnel to provide a migratory passage for anadromous species around Copco 1, Copco 2, and Iron Gate Dams while leaving the dams in place. This alternative also includes improvements to fish passage facilities at J.C. Boyle Dam to allow upstream and downstream passage. This alternative would allow continued power generation at the Four Facilities, but the Hydropower Licensee would need to obtain a new FERC license to continue operations. This alternative bypass would route upmigrating fish into Bogus Creek into an approximately five-mile tunnel that would connect Bogus Creek to Copco 1 Reservoir. The tunnel would connect to Bogus Creek at stream mile 2.9, well downstream of the existing fish ladder on the creek and the confluence with Cold Creek (Bacigalupi and Lake 2010) (Figure 3-8). The proposed tunnel would be 16 feet wide by 12 feet high and would contain a 4 foot wide by 2 foot deep fish channel on one side. Larger “rest areas” for the migrating fish would be placed every 250 feet, and vertical shafts would be installed at regular intervals to provide natural light to the channel (Bacigalupi and Lake 2010). The proposed gradient of the channel would be less than one percent, and flow would be above 10 cfs. A floating entrance structure at Copco 1 Reservoir would provide water and fish access to the tunnel. The structure would float with the level of the lake to provide a year round water supply regardless of the level of the reservoir, as well as serve as the access to the tunnel for anadromous species. The proposal addresses some of the issues associated with Alternative 10, the Bogus Creek Bypass route: the tunnel would allow migrating salmonids to swim in a consistently upstream direction, as the tunnel would be drilled to connect the reservoir with the downstream tributary. In addition, it would not require a new water supply or negotiations, as would the bypass in the fully appropriated Cold Creek (in Alternative 10), because water for Alternative 11 would be supplied from Copco 1 Reservoir. Finally, the tunnel might provide more capacity for the large numbers of migrating salmonids than the smaller drainages of Clear and Deer Creeks.”

The EIS/EIR clearly states that Alternative 11 does not meet consideration because it is not consistent with the requirements of the KBRA and KHSA as it would not remove any of the four dams.



The Final EIR/EIS Flood Hydrology section does not accurately represent current independent scientific or historical data.  The data and conclusions presented was data that supports the Lead Agencies’ desired outcomes Dam Removals and not supported by recognized engineering practices. It fails to weigh basic risks associated with Flood Hydrology.

The flood protection currently provided by the dams in place is notable.  Without the dams much of the private property below Iron Gate Reservoir adjacent to the Klamath River would be subject to flooding and sedimentation deposits.  Highway 96 may have to be relocated in several locations and many bridges may need to be replaced to provide the same level of service and protection that is currently enjoyed.

The 1964 flood destroyed many bridges on the Lower Klamath and washed out much of Highway 96. All of the dams that are proposed for removal were in place during the 1964 flooding. All roadways and bridges were re-located above the calculated Base Flood Elevation considering all existing dams in place.

The EIS/EIR shows a 6.9% reduction in the flood attenuation of Iron Gate and COPCO Reservoirs combined. This is in substantial disagreement with an engineered independent evaluation.  (Using the 1964 flood data for Gage 11516530 (29,400cfs peek flow at Iron Gate) an inflow out flow hydrograph combining both reservoirs shows a 22% reduction in peek flow and a 9 hour delay in peek discharge.)

       The EIR/EIS section  Mitigation Measures, to quote: “Mitigation Measure H-1: Prior to dam removal, the DRE will inform the National Weather Service, River Forecast Center, of a planned major hydraulic change (removal of four dams) to the Klamath River that could potentially affect the timing and magnitude of flooding below Iron Gate. The River Forecast  Center is the federal agency that provides official public warning of floods.” (This is not mitigation, it is irresponsible)  


The Final EIR/EIS sediment removal proposal to allow flushing 20+/- million cubic yards of sediment retained behind the dams down river is a scientific impossibility.  The Lead Agencies failed to demonstrate adequate scientific knowledge to perform and make scientifically sound decisions to preclude decimating the Klamath R. forever. 

Sediment Removal to quote: “If analysis indicates that the release of sediment could result in significant effects, the EIS/EIR may include consideration of dredging sediments out of the reservoirs before removing the dams”

This option:(complete dam and sediment removals), is the only viable option to mitigate the sediment impacts on the River, and is not on the table because of predetermined conclusions that funding would not be approved or available to support the actual projected cost.  This is the reason that (Partial removal of 4 dams without sediment removal) was selected as the: Environmentally Preferable/Superior Alternative.


The (2007)cost of Dam Removals is expected to be in excess of $1 Billion for dam removals and on site mitigations and over $4 billion for dam removals including KBRA & KHSA agreements and proposed restoration projects. To quote:  

 “The KHSA sets a cost cap of $450 million for removal of the Four Facilities. Of this, an amount not to exceed $200 million would come from additional charges to PacifiCorp ratepayers residing in California and Oregon, and up to $250 million would come from the sale of bonds in California or other means deemed appropriate financing mechanisms to cover removal costs in excess of the rate-payer contributions. The United States government would not be responsible for the costs of facilities removal.”

    Where is the funding for the $1 Billion for dam removals and site mitigations and over $4 billion for dam removals including KBRA & KHSA agreements and proposed restoration projects?   

The Lead Agencies have failed to present a truthful and logical cost/benefit analysis projecting all cost related to dam removals and mitigations, together with KBRA & KHSA agreements and conditions, including replacement energy cost. How could any decision makers be expected to make a responsible public decision without knowing the true cost /benefits for all viable alternatives and identify the source of the funding?? 


CONCLUSION:    The KBRA&KHSA EIR/EIS document is riddled with bias conclusions and inappropriate mitigation measures that are not supported by fact, science, or properly engineered studies. This document was prepared supporting the KBRA&KHSA, a predetermined goal (Removing 4 dams on the Klamath River) and needs major revisions to comply with NEPA and CEQA regulations. The agreements were termed by the expert panel and Dr. Houser to be an experiment deemed for failure rather than a Restoration Plan at a cost to rate payers and tax payers of over 5 billion dollars. The plan might be better termed a Regression Plan rather than a Restoration Plan. If the DOI is going to experiment, experiment with Alternative 11 and save decimating the Klamath River and save tax and rate payers $5 billion dollars.


Appendix A – Klamath Settlement Final Alternatives Report

3.11 Alternative 11 – Fish Bypass: Alternative Tunnel Route



   Irresponsible expenditures during a national economic crisis

   Substantial increase in electricity cost

   Loss of the recent Pacific Corp clean energy rebates under AB32

   Dams currently will provide a 3 mo. Period of CDFW 700cfs min. flow given a complete shutoff of the upper K. River

   Unnecessary loss of green hydro-electric power for 70,000 homes

   Substantial Cost to replace hydro-with fossil fuel power falls on the rate payers

   Substantial loss of property values and esthetics (bath tub ring around dams)

   Substantial loss of Down River flood protection and emergency services

   Loss of infrastructure during flooding such as roads, bridges and structures

   Loss of sustained 1300 cfs minimum river flows will be replaced by waters from  the Upper Klamath, Scott and Shasta Valley irrigators

   Loss of Iron Gate fish hatchery

   Loss of lake fisheries, recreation and wildlife habitat

   Impacts on Shasta Nation Burial Grounds and Yreka water supply unknown

   Irresponsible release of dam sediments down river decimating river habitat.

   Promised?? power costs and water benefits to upper basin landowners without any direct factual benefits ( Black Mail to support the KBRA & Dam Removals)

   Anadromous fish habitat will not be enhanced by 420 miles (25miles at max)

   Lack of factual evidence that removing dams will restore any salmon runs



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