2824 South Highway 3
Etna, CA 96027
North Coast Regional Water Quality Control Board
5550 Skylane Blvd, Suite A
Santa Rosa, CA 95403
RE: Comments Klamath River Total Maximum Daily Loads and Action Plan
Having worked on fish and water issues, plans and permits since 1992 I can honestly say this is the poorest compilation of relevant science, lacks clear objectives with purpose and has timelines that are unreasonable. There are too many individual areas of concern to address them all, so I shall limit this response to five general points.
First, the Klamath TMDL has gone from river specific to watershed. The Scott & Shasta already have working and approved TMDLs in place. Attributing additional limiting factors to these watersheds and incorporating them into the Klamath TMDL is simply wrong. We do not need another layer of permits, regulations and restrictions.
Second, the entire Klamath TMDL is unreasonable in nature. Per the North Coast Water Quality Control Boards own policy, you are to evaluate ALL beneficial uses and develop a plan than assesses and meets the needs of all uses, with out negatively impacting others. The Klamath TMDL clearly places its emphasis on cold water fisheries and ignores the impacts to agriculture and other beneficial uses.
Third, a full assessment on the economic impact of the Klamath TMDL was missing. In this case, it should be a cumulative economic impact, including the effect of all TMDLs and the Department of Fish and Games ITP. This will be the third and in some cases, the fourth or fifth permit or plan than private landowners will have to endure. Especially in the current economic situation, it must be noted that agriculture and timber can not sustain any more additional cost, whether it be in capital or in time.
Fourth, as written, the Klamath TMDL assumes that the dams will remain in place. However, the tone of the TMDL lends credence to removal. Therefore, the Klamath TMDL must also include the potential scenario of the dams being removed.
Fifth, the Boards additions to what qualifies as an acceptable Ranch Management Plan are unacceptable. Farmers and ranchers do not have the resources, or the time to meet the new criteria. The surveys, studies and monitoring described are unreasonable.
Overall, the Klamath TMDL presents the tone that the farmers, ranchers and timber managers are guilty before proven innocent. We are good stewards of the land and are benefiting the environment for both aquatic and terrestrial species. We have implemented conservation practices and are efficiently utilizing our resources in order to provide healthy and productive farms and ranches for future generations. Local agriculture and business cannot endure any more regulations, restrictions or limitations.
In conclusion, I have three suggestions.
1. The NCWQCB needs to remove all portions of the plan that involve any tributary that already has an approved TMDL in place.
2. The NCWQCB needs to sit down at the table with the Siskiyou County Board of Supervisors and discuss in earnest, the entire Klamath TMDL, until the county is satisfied.
3. The NCWQCB must meet with the CDFG and come up with the desired ratio of spawners to out migrants that will indicate a healthy fishery.
The bottom line is that we all want a healthy fishery. Farmers and ranchers are experts at growing things. Tell us the ratio you want for the system we manage. We can directly affect what happens inland and we have over the past 15+ years, in a positive way. We cannot be held responsible for low numbers returning when we have spawned them and sent them out alive. Adding regulation upon permit upon restriction on the private land owner will not bring back more fish. Instead it will lead to more economic hardship, higher unemployment and more conversion of valuable habitat.
Thank you for the opportunity to present comments on this document.
Jeffrey N. Fowle
Rancher, Farmer, Agriculturist, Environmentalist