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Dr. Richard A. Gierak’s comments on federal agencies environmental assessments regarding removal of 4 hydro-electric dams on the Klamath River – 10-20-11

Dept. Fish & Game, Federal gov & land grabs, Klamath River & Dams


Dr. Richard A. Gierak

Bachelors Degrees in Biology & Chemistry, Doctorate in the Healing Arts, Director of Interactive Citizens United, Director of New Frontiers Institute, Inc. Prior Member of FERC and FPAT (Fish passage advisory team report) and HET (Hatchery evaluation team) Prior Vice President of Greenhorn Action Grange, Prior California State Grange Spokesman for the Water Committee, Prior National Whip of the Property Rights Congress of America, Representative of the Grange States of California, Oregon, Washington and Idaho regarding EFH regulations. Presently science consultant to Siskiyou County Water Users Association.

5814 Highway 96

Yreka, CA. 96097

530 475-3212

October 20, 2012

Response to Executive Study of the EIS/EIR Public Draft;

KHSA Dam Removal

The entire proposal for removing four hydroelectric dams on the Klamath River is to recover Coho Salmon populations. Reality, and historical documents clearly indicate that Coho were never native to the Klamath Basin and the present listing by California ESA and Federal NMFS are unlawful, arbitrary and capricious as there is no provision in the Federal ESA to list non-indigenous species. Secretary Ken Salazar is in violation of the Federal ESA as the Department of the Interior is responsible only for freshwater species of fish and it is the Department of Commerce that is responsible for saltwater species.

Water Quality Benefits

Water Quality will not improve under alternatives 2 & 3 as historic evidence clearly delineates that reservoirs in place allow detritus to settle out and water quality is improved with each reservoir in place. Least desirable water originates at the shallow Klamath lakes and Keno reservoir and California EPA Water Board confirms that water quality continues to improve as it flows downstream when reservoirs allow detritus to settle out. Historically in 1913, before dams, the total number of salmonids counted by California Fish & Game Commission was 38,000. Five years after the dam was in place that number rose to over 60,000. This was possibly as a result of the reservoir allowing detritus to settle out and water quality was improved enticing more salmonids to spawn in the Klamath. During the exploration phase of discovering the Klamath Basin the troops were faced with water that was not potable and even their pack animals refused to drink from the River. The native tribes named the river Klamath River which translated means Stinky River. No one wishes to return to this historical position. Late summer/fall water temperatures are improved by the deep reservoirs and reducing the impact of high summer temperatures.

Algae toxins were evaluated by the CDC in 2009 and were found to be non-toxic

with exception to those who may be seriously breathing impaired. There has never been an incident of an individual becoming ill from swimming, diving, dredging, skiing or playing in any of the reservoirs on the Klamath River.

Water Quality Summation;

I find that California F&G, EPA water Board, NMFS and USF&W service present unscientific evidence in their statements that dam removal will increase water quality based on their own historical reports.

Quote from 2009 Water Quality Klamath TMDL scoping comment responses

“The Regional Water Board can not establish life cycle-based water quality objectives for the mainstem Klamath River because the DO concentrations associated with salmonid life cycle requirements can not be met even under natural conditions-

Salmonid Benefits

Only reservoirs provide slightly cooler water benefiting migration of both adult and juvenile salmonids.

Dam removal will release thousands of tons of toxic sediment that will destroy salmonid spawning beds for years to come.

Access to salmonid in the Upper Basin has historically been refuted as accounts indicate that any salmonids that reached the area of the present Copco 1 dam they were non-viable for spawning and were diseased and useless for human consumption. As to reaches above Copco there were reefs that exceeded the height that salmonids could successfully navigate.

According to California Fish & Game in a 2003 report it is clearly stated that the only way to control the water flow for salmon runs are the dams that are in place.

Historically the Klamath River, in a dry year, would revert to marshes and swamps. This condition would destroy the Fall Run of Salmon without the reservoirs storage to supply the necessary water flow for the Salmonids to reach their spawning grounds.

Salmonid Benefits Summation;

To cite NMFS data in 1950 the total number of salmonids landed in the Pacific Northwest was 149,000 metric tons with 80% caught in Alaskan waters. Since the building of dams and hatcheries in 2007 the total number of salmonids landed in the Pacific Northwest was 403,000 metric tons with 97% caught in Alaskan waters due to the increased rise in temperature of the Pacific Ocean. There is little doubt that dams and hatcheries have been a positive effect on commercial salmonid production in the Pacific Northwest. In a 1993 Report by NMFS in their Oceanic report stated that the El Nino of 1983-1985 devastated the Coho Salmon population off the coast of California. Dr. John Palmisano was a Marine mammal biologist for NMFS in Juneau, Alaska, taught fisheries and biology at U of Washington. Also an environmental scientist for a consulting firm in Bellevue, WA. In 1997: he wrote. “Coastal waters from Mexico all the way to Alaska have gradually warmed since the climate shift of the 1970s and the subsequent, periodic affects of El Nino.” “It is estimated that 40 – 80 percent of estuarine habitat along the Pacific Northwest has been diminished or destroyed”. “It is clearly not the perceived mismanagement of inland streams and rivers that has caused the recent degradation of the Salmonid population”.

There is no doubt that removal of dams on the Klamath River will force the river to revert to its original historical condition which will decimate any future runs of salmonids based on data from California Fish & Game, NMFS, NOAA, NASA and the Expert Panel analysis of 2010.

FINAL Report_Coho Salmon-Steelhead_Klamath Expert Panels_04 25 11


Renewable Energy Power Supply;

According to USGS “Hydropower is the most important and widely-used renewable source of energy.” Not only does the above apply, but, to attempt to use coal or natural gasses will increase the production CO2 in our atmosphere. To attempt to utilize wind or solar the costs would increase from 300 to 400 percent. At this time these dams supply over 70,000 individuals in Southern Oregon and Northern California and removal will burden these individuals with increased costs for electricity.

Regional Economic impacts;

Loss of power generation will negatively affect disproportionally resource based economies in an already struggling economy.

Sediment impacts;

Significant and deleterious effects on the aquatic environment and the spawning beds of salmonids would occur with dam removal.

Historic Distribution in the upper Klamath Basin

Access to salmonid in the Upper Basin has historically been refuted as accounts indicate that any salmonids that reached the area of the present Copco 1 dam they were non-viable for spawning and were diseased and useless for human consumption. As to reaches above Copco there were reefs that exceeded the height that salmonids could successfully navigate.

KBRA Effects;

The KBRA will not produce adequate social and economic benefits from implementation of dam removal.

Loss of Reservoir environment;

Dam removal will not only affect property values but will increase wildfire as the reservoirs will not be available to fire helicopters for filling their water buckets in addition to removing the aesthetic and recreational value to the County which is significant.

Flood Risk;

In 1960 the California The State Water Rights Board has granted a water rights permit on the Klamath River to the California Oregon Power Company for its proposed Iron Gate Dam. “The move was hailed by local citizens as a boon to the county. The dam will serve for both power and flood control, thus lessening flood danger in the Klamath area“.


Based on scientific data and historical evidence the proposed removal of four hydroelectric dams on the Klamath River will result in the following effects:

1. Loss of property values

2. Increased forest fire danger

3. Devastation to Agriculture and jobs

4. Increased inundating floods to residents downriver.

5. Loss of revenue to the County by loss of recreational attributes of dams.

6. Loss of Fall Run of Salmon in the Klamath Basin.

7. Loss of salmonid spawning grounds due to released toxic sediments.

8. Pandering to eco-terrorists without any scientific data to support their position.

9. Loss of the planets most renewable energy source to 70,000 residents.

10. Increased pollution of our atmosphere by oil based power production.

11. Violation of the Federal Endangered Species Act by California ESA, NMFS and the Department of the Interior.

12. Government open disrespect to the WILL OF THE VOTERS of Siskiyou County wherein at the November 2010 election the voters clearly voted 79% to retain the dams for all of the above reasons cited.

Respectfully submitted;

Dr. Richard A. Gierak


In response to the Executive study I find that the language throughout this document are based on junk science and words such as may, could should, possibly and a plethora of inconsistencies that dam removal will do anything of value for Salmon returns. It is a travesty of lies and junk science with only one outcome…… Dam removal.

Dennis Lynch has stated that “this is an experiment and we have to try to see if it works“. I must say that when you consider the mandates of the Department of the Interior your involvement in the removal of Dams for the hopeful return of Coho Salmon is unlawful and should be terminated.

To John Hamilton I must also state that the involvement of U.S. Fish & Wildlife Service, under the Department of the Interior, is also in violation of your Congressional mandates as Coho Salmon are a saltwater species under the jurisdiction of the Department of Commerce.

As to Mark Stopher I find that the California ESA is in violation of the Federal ESA by listing Coho Salmon as endangered in the Klamath as there is not one single document alluding to Coho Salmon being native to the Klamath River. The recent expert panel report indicated that the Coho Salmon are from Cascadia, Oregon. In addition several de-listing petitions were filed with California Fish & Game and no response was ever received from them.

The first mention of Coho in the Klamath was when they were planted in 1895 from various sources. In 1913 W. H. Shebley, Superintendent of Hatcheries, writes “There was no run of either kind of Salmon in the River.”

Based on historical evidence the listing of Coho Salmon is arbitrary, capricious and unlawful and should be removed as a listed species. This would cancel the removal of Klamath River Dams as the prime purpose for dam removal is the unlawful listing of Coho Salmon.


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