Fact Sheet: The Hardy Flow Reports are Fatally Flawed
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In June 2002, Miller Ecological Consultants, Inc. of Ft .Collins, Colorado completed its assessment of the Phase I Hardy Report, which was used as the interim basis for the National Marine Fisheries Service biological opinion for 2001 Klamath Project Operations. That opinion called for higher than normal flow releases at Iron Gate Dam, ultimately contributing to the federal government’ s decision in 2001 to curtail water – with disastrous community impacts – to Klamath Project family farms and ranches. Miller found the Phase I Hardy Report to be "fatally flawed" for the following reasons:
  • A biological basis for the interim flows is currently absent.
     
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  • There are no literature citations for conclusions or for statements of fact regarding fish life history. Attribution is lacking…especially where Hardy lists information regarding species life history, temperature thermal limits, habitat requisites or use of various sections of the river by fish.
     
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  • The report relies heavily upon personal communication and unpublished reports.
     
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  • It is not possible to determine if the five hydrology-based methods used to drive interim flows were applied correctly.
     
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  • No mention of any field effort is listed…so one would assume the methodology was not correctly followed for deriving a minimum instream flow.
     
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  • The hydrologic methods used are not used today for a variety of reasons. Most of the methods used to determine interim flow are no longer applied except in the simplest situations.
     
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  • The hydrologic methods used are generally arbitrary in nature and lack a biological basis for the flow specifications. It appears that no field visits or field documentation of any of the methodologies were conducted.
     
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  • Each of the methodologies applied in the system are hydrology-based and have little or no biological basis for the derived flow.
     
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  • The application of the Phase I instream flows is based solely on hydrology and ignores water quality, which may be a larger issue in limiting in the system.

 

Klamath Water Users Association
2455 Patterson Street, Suite 3
Klamath Falls, Oregon 97603
Phone (541) 883-6100
FAX   (541) 883-8893  
kwua@cvcwireless.net 


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