On Thursday, September 16, the Klamath Bureau of
Reclamation will hold a meeting from 6-9
p.m. at Miner’s Inn in
Yreka on the “basin-wide” Conservation
Implementation Program (CIP.) A draft CIP is available online at http://www.usbr.gov/mp/kbao/docs/CIP-ProgramDoc.pdf
Personally, I dislike the plan
because:
(1) It attempts to extend the
reach of federal agencies far beyond the scope of their spatial and statutory
jurisdiction, delegated authority and requirement to mitigate incidental take for their
actions under the Endangered Species Act (ESA);
(2) Ignores and disrespects
County constitutional jurisdiction and authority in land planning and in protecting public
health and safety in matters of resource use;
http://www.sisqtel.net/~armstrng/cntyjurisd.htm
(3) Smacks of regional
government, distancing decision-making hundreds of miles away from affordable local access
by those directly affected;
(4) Sets up unelected,
unaccountable committees of interest groups to make decisions over things like water use,
watershed and resource planning – in other words, your property; and
(5) Duplicates and over-lays
existing planning efforts such as the SSRT (Scott and Shasta Recovery Team) and Watershed
Plans and creates a large new bureaucracy.
Under the federal Endangered
Species Act (ESA,) a “biological opinion” (BO) was completed for operation of
the Upper Basin Klamath Project 2002-2012. NOAA Fisheries (formerly NMFS) gave the BoR a
list of things to do related to the Scott and Shasta Valleys to protect or “mitigate”
(counter-balance) the Project’s impact on listed coho. Among these “reasonable
and prudent alternatives” were:
(1) The restoration of
wetlands in the Shasta Valley.
(2) Studying development of
Shasta and Scott groundwater resources to replace surface water use in those valleys.
(3) Use of non-government
organizations (NGOs) to acquire water rights totaling 25,000 acre-feet in the Scott and Shasta Valleys. (The intention was to find water flows outside of
the Klamath Project that would contribute 43% of the flow required from Iron Gate
Dam for the Klamath River under the coho Biological Opinion.)
In addition, the BoR was
directed to develop a comprehensive basin-wide plan for
ecosystem restoration and scientific research through 2012. The plan was to
be developed by “networking stakeholder groups” in the basin. It would then
provide direction for activities on the federal, State and local level, as well as for
interest groups. It was envisioned that the program would be built around of the Oregon
Resource Conservation Act of 1996 (ORCA P.L. 104-208, Title 2, Section 201) to promote
ecological restoration, as well as economic development and stability.
The purpose of the CIP is to: (1) largely restore the
Klamath River ecosystem to achieve recovery of the Lost River and Shortnose suckers and
substantially contribute to the recovery of Coho salmon; (2) contribute to the Tribal
Trust responsibilities of the Federal government to provide harvestable fisheries; and (3)
allow continued, sustainable operation of existing water management facilities and future
water resource improvements for human use in the Klamath River System.
As proposed, the resulting CIP
would establish a new basin-wide bureaucracy complete with paid federal staff. It is
envisioned as an umbrella program to coordinate all other programs in the Klamath system.
At the top would be the “Policy Administration Group” (PAG) made up of the
Tribal Chair, BoR Regional Director and Area Manager, a representative from the Governors’
offices, Agencies, CIP administrative officers and the head of the CIP participant’s
organization. They would ensure the plan is directed toward CIP goals, approve or “ratify”
committees or groups that would implement the CIP, and oversee funding and authorization.
Next in hierarchy is the
“Coordination Council” (CC.) This council is made up of one representative of
each of the CIP “Participants.” (Watershed Councils, Klamath Water Users,
Hatfield Working Group, Klamath Basin Coalition, etc.) They will
make recommendations to the PAG concerning annual work plans and budgets; provide fish
status reports and progress reports to Congress and tribal councils; and direct activities
of the various committees. These “Participants” will be required to agree to pay
for this new bureaucracy and the implementation of its plans in order to participate.
The next level is that of the
various committees These include the Public Involvement Committee (PIC,) the Science/Peer
Review Committee (including various sub-committees;) the Water Quality Committee; and the
Tribal Trust Committee. The PIC will include one appointed member from each organization.
It’s function is basically to distribute educational and informational material.
You, the public, will be
allowed input into the decisions affecting your property by these unelected groups and
agencies by attending meetings often scheduled in Klamath Falls or on the Coast and speaking
at the limited “public comment” period scheduled on the agenda. |
