CEQA, Dam Removal, and Restoration of the Klamath River

Bob Brown, AICP, SHN’s Planning Principal, and Maia Singer and Lauren Dusek of Stillwater Sciences, will present “CEQA, Dam Removal, and Restoration of the Klamath River” at the Association of Environmental Professionals State Conference, in April 2022.  There are four PacifiCorp hydroelectric dams on the Klamath River, in Northern California and Southern Oregon.  Their removal will be the most significant dam removal and river restoration effort ever attempted in the United States.  The project will restore native anadromous fish access to potentially hundreds of miles of mainstem river and tributary habitat, and will restore riparian habitat along approximately 18 miles of river and tributary confluences that are currently inundated by reservoirs.  In the long term, dam removal will also improve water quality, reduce the incidence of disease among salmonids, and support commercial fisheries and tribal communities that depend on Klamath Basin fisheries as an important cultural resource.  

 Stillwater Sciences and SHN assisted the California State Water Board (the lead agency) with preparation of the project EIR.  One key EIR development issue was how the State Water Board determined potential project impacts for a major environmental restoration project, given the limited scope of the exception to federal preemption for Clean Water Act Section 401 water quality certification.  Other challenges were the consideration of five project alternatives in addition to the No Project alternative, and the uncertainty inherent to the transfer of project-related lands for future public use.

This large and complex CEQA project was a success due to methodical and thorough management of the document development process.  The Public Draft EIR was 1,800-pages with an additional 600+ pages of appendices; two sections of the Public Draft EIR (air quality and greenhouse gasses) were recirculated.  The Final EIR was over 3,300 pages, including responses to more than 2,500 individual comments delineated across 514 comment documents.

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