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Letter from the Siskiyou BOS Attorney NOSSMAN to FERC requesting delay for KRRC / Klamath River Renewal Corporation's Application for Klamath Dam transfer and surrender


April 7, 2020
Mr. Anton C. Porter
Executive Director
Federal Energy Regulatory Commission
Department of Energy
888 First Street, NE
Washington, DC 20426

Re: Request to delay action on Klamath River Renewal Corporation's Application for the Lower Klamath Project Transfer and Surrender — P-2082-062, P-14803-000

Dear Mr. Porter:

We are writing on behalf of Siskiyou County (“County”) to request that the Federal Energy Regulatory Commission (“FERC”) temporarily delay action on the Klamath River Renewal Corporation’s (“KRRC”) application for the Lower Klamath Project License Surrender (“Project”), due to the prejudicial effect that the global COVID-19 pandemic will have on the public’s and the stakeholders’ participation in the proceeding and on the decision-making process.

As you are aware, KRRC and PacifiCorp have submitted an application to FERC for hydropower license transfer and surrender to decommission and remove four lower Klamath River dams—three of which are located within Siskiyou County. The County is an intervenor in the proceeding and, on multiple occasions, the County has expressed its concerns regarding:

the qualifications of the KRRC to hold the license, operate the dams and
appurtenant facilities, and effectuate dam removal;
the adequacy of funding for the Project;
the feasibility of the schedule to implement the Project set forth by KRRC;
the ongoing lack of transparency with respect to the environmental review process required prior to any action by FERC with respect to the Project; and
the potential impacts of dam removal on imperiled species, water quality, and theoverall health of the Klamath River ecosystem, as well as other environmental and societal impacts, including air quality, climate change, cultural resources, hazardous materials, and traffic impacts, in addition to socioeconomic impacts on the local community.

See, e.g., PacifiCorp, 162 FERC ¶ 61,236 at ¶ 28 (Mar. 15, 2018). The County has a strong
vested interest in ensuring that FERC is appropriately and lawfully informed of the Project’s

18101 Von Karman Avenue
Suite 1800
Irvine, CA 92612
T 949.833.7800
F 949.833.7878
Paul S. Weiland
D 949.477.7644

VIA FERC ONLINE Refer To File # 290380-0004

20200408-5018 FERC PDF (Unofficial) 4/7/2020 8:12:15 PM



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