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Klamath River above Highway 101 with sediment deposited by 1997 storm. (83 Kb)

"The Total Maximum Daily Load (TMDL) process leads to a 'pollution budget' designed to restore the health of a polluted body of water. The TMDL process provides a quantitative assessment of water quality problems, contributing sources of pollution, and the pollutant load reductions or control actions needed to restore and protect the beneficial uses of an individual waterbody impaired from loading of a particular pollutant" (North Coast Regional Water Quality Control Board website).

The Clean Water Act driven TMDL plans currently being developed in the Klamath Basin represent a major opportunity for the improvement of water quality and cold water fish habitat. The recognized legal standing of TMDL plans (U.S. Court of Appeals Ninth Circuit, 2002. Pronsolino et al. vs. Nastri et al.) makes them important tools for the Tribes to use to reverse the decline of Pacific salmon and other important Klamath River fish species upon which they rely for subsistence.

Work Group member Tribes have been reviewing draft TMDLs to examine assumptions, methods and targets within Draft TMDLs are checked to see if they reflect "best-science" literature related to water quality and fisheries. Another criterion of evaluation is whether recognized Klamath Basin documents that characterize water quality and fisheries problems are being used. To speed implementation, the use of existing, scientifically sound restoration plans for improving watershed and aquatic conditions is recommended. In addition to participating in the development of the five Klamath Basin TMDLs, the Work Group and its member Tribes are building their technical capacity to use the models and other scientific tools applied by the agencies to characterize and plan remedies for water quality problems. This strengthened capacity will be used by the Work Group members to track the progress and implementation effectiveness of the TMDLs.

The documents cited below are only a partial list of comments submitted by the Work Group's member Tribes.

Klamath River TMDL for Nutrients, Temperature and Dissolved Oxygen

Status: Text partially written, water quality model scenarios selected, some preliminary model results completed and released to Tribes. No defined schedule for Public Draft release (likely 2007 or 2008).

Quartz Valley Indian Community. 2006. Comments Concerning the Klamath River TMDL Approach and Progress to Date. Memo to the U.S. EPA and North Coast Regional Water Quality Control Board of August 15, 2006. Quartz Valley Indian Reservation, Ft. Jones, CA. 35 p. (1.6 Mb).

Yurok Tribe. 2006. Comments Concerning the Klamath River TMDL, Approach and Progress to Date. Memo to the U.S. EPA and North Coast Regional Water Quality Control Board. Yurok Tribe. Klamath, CA.

• Use of PacifiCorp water quality model for Klamath TMDL should only continue if model results can be substantially improved to better predict trends observed in field data collected.
• The model used in the Klamath TMDL does not predict pH in California, yet Klamath River data show chronic exceedance of the Basin Plan standard of pH 8.5, a level known to be highly stressful to salmon and steelhead.
• Thus far, it appears that the Draft Klamath TMDL will not properly characterize the importance of Klamath River tributaries as temperature refugia for Pacific salmon, nor take concrete steps to provide protection to these critical habitats by establishing prudent risk thresholds for the disturbance of their watersheds.
• A TMDL that does not ensure protection and restoration of these refugia will not contribute to Klamath River salmon recovery and should not, therefore, be accepted.
• The final Klamath TMDL should recommend the removal of the Klamath Hydroelectric Project dams, given their role in thermal and nutrient pollution of the river.

See Relicensing pages for more on Klamath River health and water quality.

Klamath River downstream of Ash Creek. Note foam, brown coloration and algae covered bottom. Photo courtesy of Michael Hentz. (137 Kb)

Shasta River TMDL for Temperature and Dissolved Oxygen

Status: The North Coast Regional Water Quality Control Board (NCRWQCB) approved the Shasta TMDL on June 29, 2006 and it will be considered for adoption before the State Water Resources Control Board (SWRCB) on November 15, 2006.

Quartz Valley Indian Community. 2006. Review of public draft Shasta River Temperature and Dissolved Oxygen TMDLs. Quartz Valley Indian Reservation, Ft. Jones, CA.

• The TMDL reaches the scientifically supported conclusion that increasing flows is an important action needed to remediate water temperature problems.
• Model use in Shasta TMDL is valid and its assumptions were mostly well supported.
• Shasta TMDL model should have included pH because values over Basin Plan objectives are routinely exceeded and are high enough to be stressful to salmonids.
• Nitrogen (in all forms, not just ammonia nitrogen and organic nitrogen) should have been measured and modeled because of its role in stimulating aquatic plant growth.
• TMDL considers Shasta River as a 40 mile trunk without functional tributaries and there is no mention of restoring connectivity despite historic flow data showing that all tributaries had perennial surface flow.
• Pollution from reaches of streams like upper Parks Creek are not recognized in the TMDL because they are not part of the model, even though Parks Creek is connected to the Shasta River during major storms.
• Shasta TMDL recognizes water quality problems in Dwinnell Reservoir that contribute to Shasta River water pollution, but does not discuss removing the dam as a means of abating the problem
• Removal of Dwinnell Dam will likely be necessary for abatement of water quality recovery and salmon restoration.

See also comments on the Shasta TMDL from conservation groups.

Scott River TMDL for Sediment and Temperature

Status: Adopted by the NCRWQCB in December 2005, by the SWRCB in June 2006, and by the U.S. EPA in September 2006.

Quartz Valley Indian Community. 2006. Comments on the Final Draft Scott River Total Maximum Daily Load (TMDL) Work Plan. Letter to the North Coast Regional Water Quality Control Board. Quartz Valley Indian Reservation, Ft. Jones, CA. 35 p. (1.6 Mb).

Quartz Valley Indian Community. 2006. Comments on Draft Scott River Watershed TMDL Implementation Work Plan and North Coast Basin Plan Amendment. Quartz Valley Indian Reservation, Ft. Jones, CA. 7 p. (1.5 Mb)

• The cumulative effects of timber harvest and related roads, which include increased flood flows, channel widening and depletion of large wood in stream are not addressed.
• Cumulative watershed effects are likely to confound efforts to abate sediment and temperature pollution.
• The upslope and instream monitoring measures proposed will neither support adaptive management nor will they provide an adequate basis from which to determine whether new Waste Discharge Requirement (WDR) permits or waivers are warranted, or whether existing permits and waivers should be continued.
• Groundwater and flow studies are assigned to the County of Siskiyou, rather than to a more impartial office like the SWRCB Water Rights Division. This assignment is inappropriate and it will likely slow the implementation of necessary water quality improvement measures.
• Neither the current collapse of the Scott River fall chinook salmon population nor the clear indications that the basin’s coho salmon population are at a high risk of extinction are acknowledged, nor are the recovery actions proposed sufficiently timely.
• The Implementation Work Plan fails to address the need to protect the coldwater refugia needed for salmon survival until the mainstem Scott River water temperature problems can be remedied.

See also comments on the Scott River TMDL from conservation groups.

Scott River below Jones Beach with sand covering what should be a salmon spawning riffle. From KRIS Version 3.0. (28 Kb)

Shackleford Creek runs dry before it meets the Scott River in foreground. Scott River water quality is impacted by flow depletion and lack of flow releases in fall block chinook migration. Photo by Pat Higgins. October 1997. (287 Kb)

Lower Lost River with agricultural drain water flowing in from culvert. Photo by Bill Hobson, NCRWQCB.

Lower Lost River TMDL for Nutrients and Temperature

Status: U.S. EPA has assumed responsibility for the TMDL on the California portion of the basin, which may delay action on implementation. Narrowly circulated pre-draft released August 2006. Public Draft due in early 2007. Oregon Department of Environmental Quality is working on a separate TMDL for Oregon's portion of this subbasin.

Yurok Tribe. 2006. Memo re: Yurok Tribe comments on Lower Lost River TMDL. From Kevin McKernan, Yurok Tribe Environmental Program Director, to Noemi Emeric of U.S. Environmental Protection Agency.

• Lost River Pre-Draft TMDL fails to consider the Lower Lost River sub-basin in an historical context that recognizes changes that have occurred in its land- and water use over time.
• Pre-Draft TMDL does not reflect review of recent, readily-available, substantial technical literature on the sub-basin.
• Over-reliance on the use of modeling for the TMDL and failure to adequately assess and use the available field data from the sub-basin.
• The model suffers from unmet assumptions, uncertainties, and does not incorporate processes such as nitrogen fixation.
• The Pre-Draft TMDL fails to recognize and articulate the relationship of the Lost River system’s water quality problems and with those of the Klamath River.

Upper Lost River TMDL for Nutrients and Temperature

Status: NCRWQCB found no proof of nutrient or temperature impairment and removed the Upper Lost River from the impaired water bodies list.

Resighini Rancheria. 2004. Memo re: Total Maximum Daily Load (TMDL) analysis for, and the proposed de-listing of the Upper Lost River from California's 303(d) list. From Chairman Frank Down to Catherine Kuhlman, NCRWQCB Executive Director. Resighini Rancheria, Klamath, CA. 9 p.

• Agree that Upper Lost River TMDL is sound and that conclusions based on available data are warranted.
• Call for additional collection of data in tributaries to Clear Lake.
• NCRWQCB staff need to work with Modoc National Forest to further reform grazing in order to improve conditions for the major populations of shortnose and Lost River suckers that spawn above Clear Lake.
• Grazing on the shores of Clear Lake in a National Wildlife Refuge should be discontinued.
• NCRWQCB should list the Upper Lost River for turbidity, given the findings of high values discovered through field data collection.