Removal of the Klamath dams could impact the Fall Creek water facilities – Yreka’s only water source. To address concerns, the city of Yreka submitted comments Friday to the Bureau of Reclamation in response to the Draft Environmental Impact Statement and Report (EIS/EIR) for Klamath Facilities Removal.
The Yreka City Council voted Thursday to approve 69 pages of comments that were prepared by staff following review of the 10-inch thick Draft EIS/EIR.
The comments were submitted independent from the county. The deadline for public comment on the draft was originally Nov. 21, but the Department of the Interior announced this week that the deadline has been pushed back to Dec. 30.
“The city of Yreka is commenting on these proceedings to protect the city’s interest in its water rights, public water supply, and associated facilities near the PacifiCorp powerhouse at Fall Creek,” the comments state.
The Draft EIS/EIR indicates that Yreka’s 24-inch diameter water pipeline from Fall Creek (which crosses the Klamath River near the upstream end of the reservoir impounded behind Iron Gate Dam) would likely sustain damage by high-velocity river flows following dam removal.
The Draft EIS/EIR proposes the construction of a pipe crossing on a constructed bridge above the reservoir surface. The new pipeline would be connected to the existing buried pipeline at each end of the bridge by horizontal bends. Valves would be installed at each end to divert water from the old to the new pipe crossings.
According to Yreka City Manager Steve Baker, the pipe crossing project and associated costs are estimated at $5.6 million.
Additional long-term water system costs from increased maintenance and operational expenses resulting from the proposed pipe crossing were addressed in the city’s comments.
While bond funds are available to communities to mitigate the financial impacts of dam removal, Baker said that whether the city will be burdened with any of these expenses “is very speculative at this time.”
“It is not appropriate to impose this cost on the city. This is not a city project,” Yreka City Attorney Mary Frances McHugh said. “This should not be charged to our ratepayers.”
Calling a pipe crossing “an attractive nuisance” in the comments, staff noted the city’s liability if trespassers attempt to climb on the structure and are injured, the increased risk of vandalism to the water pipe and the likelihood of the pipe crossing sustaining flood damage.
Furthermore, the pipe crossing as it is currently designed in the  Draft EIS/EIR would be installed three feet above the elevation of the 100-year floodplain. The comments state that elevating the water pipe would change the hydraulics of the system and put a greater demand on pumps that push water into the city system for delivery.
Favoring the idea of burying the water line, the city’s comments state that it was not consulted regarding the proposed pipe crossing and that it should be afforded the opportunity to participate in the design and approval of plans, construction inspection and final acceptance of any improvements affecting its water system.
The Draft EIS/EIR references the possibility of burying the pipe beneath its existing location in lieu of the construction of the pipe crossing. However, it does not include an extensive study of this option because of the higher cost of pipe burial.
“Burial should not be dismissed because it is more costly than an aerial bridge. … There is no evidence (in the draft) that the burial of the water pipeline was evaluated and discarded as infeasible,” staff wrote in the comments.
Included in the comments is a letter from Pace Engineering that indicates pipe burial is feasible and is a common practice.
The city contends in its comments that the EIS/EIR draft fails to comply with the National Environmental Policy Act (NEPA) and California Environmental Quality Act (CEQA) requirements because it does not include an analysis of pipe crossing alternatives, and therefore deprives the public and the city of a meaningful review.
In addition, the Draft EIS/EIR does not include an analysis of the reconstruction of the cathodic field that protects the water pipe from erosion.
The city of Yreka currently has seven water storage tanks. Staff commented that if the water supply was turned off, water storage capacity is limited to one to three days. The comments go on that the EIR and EIS do not adequately address these concerns in the project description.
Furthermore, the city commented that additional water sources and storage would be necessary in the event that the pipe crossing sustains damage (due to flooding, vandalism or geologic impacts) and must be disengaged.
The city is calling for a complete revision and redistribution of the EIS/EIR draft that includes an assessment of all the pipeline relocation alternatives.
“If modification of the city’s water supply is part of the project, it must be part of the project description, and it must be a complete description,” city staff wrote.

Water rights

The city’s comments address the threat to Yreka’s water rights as a result of the Iron Gate Dam removal.
Fall Creek and Jenny Creek are critical components of Yreka’s water supply. The emphasis of the reintroduction of anadromous fish and the fishery habitat values of these streams if the Iron Gate Dam is removed “will impose additional constraints on the availability of water right,” the comments state.
The Department of Fish and Game mandates 15 cubic feet per second must be available in streams for fish, explained a letter from Pace Municipal Consultants (PMC) that was included in the comments.
Currently, the city meets that requirement. However, when Iron Gate is removed there could be further constraints on the water supply, the city commented, adding that it could jeopardize the water permit.
Staff requests in the comments for the dam removal entity to identify alternative water resources to compensate for the loss of allowed water diversion from Fall Creek that could potentially result from the project and for this plan to be included in the draft.

Current projects
The city of Yreka qualified for a $10 million loan and grant from the United States Department of Agriculture to fund water and sewer system improvement projects.
Baker said that based on the information at hand, it does not appear that the plans outlined in the EIS/EIR draft threaten the recently completed projects. However, staff comments include concerns that jeopardy of the city’s water supply and water right may impact its debt obligations.