Tri-Counties Letter to Department of the Interior Urging for Modification of the 2023 Operations Plan

June 1, 2023

Subject: 2023 Klamath Project Operations Plan

Dear Secretary Haaland and Commissioner Touton:

The counties of Klamath, Oregon and Modoc and Siskiyou, California (Tri-Counties) are writing this letter in regard to Klamath Project water allocations. In 2020, Reclamation adopted the Interim Operations Plan (IOP) for the Klamath Project, controlling the amounts of water made available in Upper Klamath Lake, the Klamath River, and for irrigation and wildlife refuges.

Since that time, drought conditions have required Reclamation to deviate from the specific terms of the IOP, which it has done with Temporary Operations Plans. However, during the winter of 2022- 2023 and spring of 2023, wet weather returned and snowpack conditions across the Basin were, as  of April 15, 185 percent of normal. Unquestionably there are no longer drought conditions warranting, let alone requiring, deviation from the IOP. 

If Reclamation were following the IOP, the 2023 Operations Plan would have provided 285,000 acre-feet from Upper Klamath Lake and the Klamath River for Klamath Project irrigators and refuges. That volume would still be far short of the Project’s overall water needs this year, but at least it would be justifiable in terms of being consistent with the IOP. There is no similar justification for the current allocation of 260,000 acre-feet, just like there is no reason to deviate from the IOP. On what grounds and what basis this decision was made remains unclear to stakeholders in the Basin.  

There is similarly no justification for Reclamation’s decision to attempt to maintain water levels in Upper Klamath Lake above 4,139.2 feet, which is also inconsistent with the IOP. It does not appear that Reclamation has properly evaluated the potential impacts of this decision in several important respects. First, this proposed new operating requirement was not evaluated in Reclamation’s current Environmental Assessment and supplemental documentation on Project operations in  accordance with the National Environmental Policy Act (NEPA). In fact, we now have abundant  evidence that the NEPA Finding of No Significant Impact for the IOP itself was inappropriate. Under the IOP, there have been major socio-economic impacts, farmland has dried up and literally blown away (causing negative effects on air quality), and the national wildlife refuges in our three counties were desiccated, for the first time ever.

In addition, the modified operation was not evaluated or considered as part of the Federal Energy  Regulatory Commission’s recent approval of the Klamath River Renewal Corporation’s plans to remove four hydroelectric dams on the Klamath River.

We strongly urge that Reclamation revise or amend the 2023 Operations Plan to be consistent with the IOP with respect to both the allocation for irrigation and refuges and the minimum elevation for Upper Klamath Lake. 

We appreciate your attention to these issues, and we look forward to hearing from you and your office. If you have any questions, please contact Elizabeth Nielsen at enie[email protected] by email or (530) 842-8012 by phone.

Sincerely,

Brandon A. Criss, District 1, Siskiyou County Board of Supervisors 

Michael N. Kobseff, District 3 Vice Chair, Siskiyou County Board of Supervisors

Ned Coe, District I, Modoc County Board of Supervisors

Geri Byrne, District V, Modoc County Board of Supervisors

Derrick DeGroot, Chair, Klamath County Commissioner

To download a PDF version of this letter, click Letter to Haaland and Touton On Project Supply & UKL Elevations