FROM PLANNING TO CONSTRUCTION- KLAMATH PROJECT DISTRICTS ADVANCE WATERSHED MODERNIZATION
Across the Klamath Project, irrigation districts are doing the detailed, often behind-the-scenes work required to turn long-standing infrastructure needs into fundable, construction-ready projects.
Through the federal Watershed Protection and Flood Prevention Program—commonly called PL -566—Klamath Irrigation District (KID), Klamath Drainage District (KDD), and Tulelake Irrigation District (TID) are each pursuing watershed plans to modernize aging water-delivery systems. Langell Valley Irrigation District (LVID) is building an initial foundation for its own modernization efforts.
The districts are at different stages, but they share a common purpose: better measurement and management of limited water supplies, more reliable service for agricultural producers, lower operating costs and tangible benefits for fish, wildlife, refuges and water quality.
This article begins a quarterly KWUA series reporting what has been completed, what comes next and how patrons and the broader community can participate.
What is PL-566?
The U.S. Department of Agriculture’s Natural Resources Conservation Service (NRCS) administers PL-566.
The Program provides technical and financial assistance to eligible public sponsors for purposes that include watershed protection, agricultural water management, flood prevention, fish and wildlife benefits, water-quality management, groundwater supply and municipal water.
A sponsoring district generally proceeds through feasibility, watershed planning and environmental review, design, funding authorization and construction. Planning is demanding by design. Engineers and environmental specialists evaluate existing infrastructure, define needs, develop and compare alternatives, estimate costs and benefits, consult with other agencies and seek public input.
Completing a Watershed Plan-Environmental Assessment does not itself build a project or guarantee immediate construction funding. It does, however, establish an approved framework and can make the project eligible to compete for substantial federal implementation funding.
Klamath Irrigation District: Planning Completed
KID reached a major milestone on May 15 when NRCS issued the district’s Final Watershed Plan-Environmental Assessment and a Finding of No Significant Impact (FONSI). The NRCS Chief authorized the plan in early June, allowing the district to move from planning into implementation. KID has since applied for federal funding to begin final engineering and design.
KID’s watershed plan evaluates a series of modernization measures, including piping or lining selected canals and laterals, installing automated flow-monitoring equipment and improving operational control throughout the irrigation system. The preferred alternative includes approximately 3.9 miles of gravity-fed pipe on the D-1 Canal, along with additional system improvements identified in the final plan.
These improvements are designed to strengthen water management by providing better information about where water is, how quickly it moves and how much is needed throughout the system. Enhanced monitoring and control will help operators respond more quickly to changing demand, reduce operational losses and spills, and improve delivery reliability.
Since receiving final federal approval, KID has secured nearly $9 million in state matching funds, contingent upon federal implementation funding, and has applied through USDA-NRCS for engineering and design assistance. The district is also coordinating with local Tribal partners to complete required cultural resource reviews, with the goal of beginning engineering during fiscal year 2027 and construction as early as fiscal year 2028.
“Completing the watershed plan is not the finish line,” said Gene Souza, KID executive director. “It gives us the roadmap needed to move into design, pursue construction funding and modernize the system responsibly.”
Meanwhile, KID continues advancing system improvements that can be completed independently of the watershed project.
Working with Farmers Conservation Alliance (FCA), the district is expanding its SCADA monitoring system by installing new automated monitoring equipment to improve flow measurement, reduce spills and strengthen day-to-day water management.
KID is also concurrently addressing immediate infrastructure needs to ensure reliable water deliveries before the 2027 irrigation season. The district and its partners are preparing emergency repairs to a failed 1960s-era steel siphon and other critical system components. Together, four high-repairs to a failed 1960s-era steel siphon and other critical system components. Together, four high-than government grants—represent more than $800,000 in investments to maintain system reliability.
“We’re moving forward on two tracks at once,” Souza said. “We’re advancing the long-term modernization needed for the future while making sure critical repairs are completed so water deliveries remain reliable next season.”
What comes next: Completing final engineering and design, finalizing project agreements, securing federal implementation funding and coordinating construction sequencing. Because the watershed plan includes multiple modernization projects, implementation is expected to occur in phases over several years rather than through a single construction contract.
Klamath Drainage District: Authorized and Moving Forward
After five years of planning and public scoping, KDD achieved a similar milestone in December 2025, when NRCS released its Final Watershed Plan-Environmental Assessment and FONSI. NRCS developed the project with KDD as sponsor and with the Bureau of Reclamation (Reclamation) and U.S. Fish and Wildlife Service as cooperating agencies. The district’s Watershed Plan, formally titled, “Klamath Drainage District Infrastructure Modernization Project,” was authorized by Chief Bettencourt in January 2026 becoming the first authorized Plan in the Klamath Basin.
KDD’s modernization plan is particularly significant because the district is connected not only to agricultural drainage and water delivery but also to the Lower Klamath National Wildlife Refuge (LKNWR) and the broader reuse of Project water.
With the District’s diversion and drainage being directly on the Klamath River, modernization would address the growing need for fish screens to keep fish out of places they do not belong. It would extend and re-engineer the North Canal to add another point of connection to the LKNWR that would improve management within KDD’s and the refuge’s conveyance system. The project also includes the installation of more energy and water efficient pumps at two pumping stations on the Straits Drain to support water-quality improvements and increase the district’s ability to provide water to Lower Klamath Refuge when supplies and operations permit. Finally, it would install an upgraded district-wide flow monitoring and automated gate(s) SCADA system for better real-time operations and water management.
“This work recognizes that efficient agriculture, healthier refuge habitat and better water management are connected,” said KDD General Manager Scott White. “Modernizing the district gives us more tools to serve all three.”
KDD has already demonstrated how agricultural infrastructure can support multiple purposes. In 2024, the district reported sending recycled Project water to Unit 2 of Lower Klamath Refuge, illustrating the connected nature of farms, drains, pumps and wetland habitat.
The total project cost of KDD’s Infrastructure Modernization Project is $16,878,000 with PL-566 federal funds covering 75%. KDD has already secured over 50% of the required matching funds through state and other federal (non-USDA) funding awards.
“This is an exciting opportunity for a district of our size,” White noted. “We are advancing critical infrastructure upgrades with virtually no impact to our landowners’ pocketbooks.”
To date, approximately 75% of the district’s SCADA system has been installed, the transfer of O&M on Straits Drain pumping plants has begun for upgrading the pumping facilities, and USDA/NRCS technical assistance funding has been requested to complete the final design of certain projects in the plan. The District expects completion of the prioritized projects by 2032.
What comes next: Continued funding coordination, final design, finalize negotiated O&M agreement, troubleshoot and bringing SCADA automation online, permitting and development of a phased construction schedule.
Tulelake Irrigation District: Building the Plan
TID’s watershed-planning effort is still underway. TID serves approximately 63,000 irrigated acres within a district encompassing roughly 96,000 acres. Its extensive system includes canals, pipelines, drains, wells and dozens of pumping plants.
TID faces an especially complex operating challenge. Much of the district’s supply consists of return flows from other parts of the Klamath Project. The amount arriving can vary considerably during the day, while the open-channel system provides limited real-time information about volumes and locations. Operators may have little water to manage at one point and excess water later, all while trying to make accurate and timely deliveries.
“Our challenge is not simply how much water is available—it is knowing where it is, when it will arrive and how to move it efficiently,” said TID manager Brad Kirby. “The watershed plan will help us identify the best long-term investments.”
Aging pumping plants and the cost of maintaining open canals and laterals also consume resources that might otherwise be invested in modernization. The planning process is examining how improved measurement, automated controls, pumping improvements and conveyance upgrades could strengthen reliability, reduce costs and improve drought resilience.
What comes next: Continued development and evaluation of alternatives, agency coordination, environmental analysis and preparing for public comment this fall before a draft and final plan are completed.
Langell Valley Irrigation District: Laying the Foundation
LVID occupies a unique position within the Klamath Project. Unlike many Project districts, it relies completely on water stored in Gerber and Clear Lake Reservoirs and is located in the eastern portion of the basin. Because supplies are relatively limited and drought impacts can be severe, improving delivery efficiency may provide substantial benefits.
While not yet participating in the federal PL-566 watershed planning process, LVID is steadily building the foundation for future modernization. With assistance from the Oregon Water Resources Department, Energy Trust of Oregon (Energy Trust) and Reclamation, the district completed a feasibility study evaluating opportunities to modernize its conveyance system, improve water measurement, increase energy resilience, and develop a long-term System Improvement Plan. That work has now evolved into a broader modernization strategy, with FCA assisting the district in identifying and advancing priority infrastructure improvements.
“We’re taking a long-term approach to modernization,” said LVID Manager Shane McDonald.
The district is in the process of completing its System Improvement Plan while at the same time pursuing engineering funding through multiple agencies to move priority projects toward design. LVID is also working with the Energy Trust on the Moxley Solar and Battery Storage Feasibility Study, which is evaluating opportunities to reduce long-term energy costs, improve operational resilience, and support more efficient water delivery.
“Every step we complete today—from planning and engineering to evaluating energy options—helps position the district to take advantage of future funding opportunities,” said Mr. McDonald. “We’ll be able to deliver water more efficiently when those projects move forward.”
What comes next: LVID will continue refining priority projects identified in its System Improvement Plan while seeking engineering funding to advance project design. Results of the Moxley feasibility study will help guide future energy investments, and the district will continue working with FCA and funding partners to position priority modernization projects for implementation as new funding opportunities become available.
FCA Helps Move Projects From Concept to Construction
FCA is supporting the districts and NRCS through the complex planning and development process. FCA brings engineering, project management, environmental-review and funding expertise to irrigation communities that may not have the staff capacity to independently manage a large federal watershed project. Its role includes helping districts assess infrastructure needs, develop and compare alternatives, coordinate technical studies and public involvement, and prepare projects to advance from watershed planning into design and construction.
FCA describes its broader mission as partnering with Western communities to move irrigation modernization “from concept to construction.”
“Being able to modernize these systems is a great way to be able to address a number of agricultural security, food security, economic development, and environment
al issues,” said Julie O’Shea, FCA Executive Director.
A continuation—Not a New Direction
“These plans should not be viewed as the Klamath agricultural community’s first entry into watershed stewardship,” said KWUA Executive Director Elizabeth Nielsen. “They are the latest chapter in a record extending back decades.”
Starting in the late 1990s’, KWUA and Project water users advanced early sucker-recovery and ecosystem-restoration proposals, participated in wetland rehabilitation and land-conversion projects, supported “walking wetlands,” implemented voluntary conservation and water-bank programs and invested in fish screens and passage improvements.
“Local producers are not merely regulated parties,” said Scott Seus, KWUA President and Tulelake producer. “They are also active participants in environmental problem-solving.”
Early KWUA proposals addressed wetland restoration, water quality, hydrologic management and fish habitat. Later efforts included the A Canal fish screen, screening and passage work elsewhere in the Project, voluntary NRCS conservation programs and development of the Klamath On-Project Plan. The record shows a consistent principle: durable solutions are most likely when environmental objectives and viable working agriculture are pursued together.
The current PL566 plans apply that principle to infrastructure built for another era. Modern measurement, automation, conveyance and pumping improvements cannot create water during drought. They can, however, help districts manage the water that is available with greater precision, flexibility and accountability.
“That is proactive watershed work – and it is now moving from concepts and assessments toward design and, ultimately, construction,” said Ms. O’Shea.
KLAMATH BASIN LEADERS URGE ACTION
Over the past several months, the Klamath Water Users Association (KWUA) and Klamath Project irrigation districts have worked closely with partner organizations, conservation groups, agencies, and Tribes to advance the 2026 Tule Lake Flow-Through Pilot. This broad coalition has come together around an immediate opportunity to help prevent a devastating botulism outbreak that could impact hundreds of thousands of migrating waterfowl at the Tule Lake and Lower Klamath National Wildlife Refuges.
The pilot would deliver critically needed water to the refuges, improve water circulation through refuge wetlands, reduce conditions that fuel botulism outbreaks, enhance water quality, and collect valuable scientific information to evaluate the long-term ecological benefits of Flow-Through throughout the Klamath Basin.
To learn more about the pilot and why so many organizations support moving forward this year, we encourage you to explore the following:
• Barbara March’s feature in Ag Mag highlights the long-term vision of Flow-Through while emphasizing the urgent need to implement a pilot in 2026.
• Karuk Tribe Vice Chair Kenneth Brink’s Herald and News op-ed discusses the interconnected nature of the Klamath Basin—its ecology, communities, and shared future. He reminds us that when “an environmental emergency threatens the place we all care about,” we have a responsibility to work together, and that Flow-Through provides an opportunity to do just that.
• Ducks Unlimited’s podcast, Why Waterfowl in the Klamath Basin Need Help Right Now, features Dr. Dan Smith explaining botulism, how it spreads, and why it poses such a serious threat to migratory waterfowl. Jeff McCreary, Ducks Unlimited’s Director of Operations for the Western Region, also discusses the critical importance of the Klamath refuges, not only to the Basin, but to the entire Pacific Flyway.
• The Tri-Counties’ commentary in Capital Press highlights the urgency of getting water to the refuges now. It recognizes the support of the Karuk and Yurok Tribes and emphasizes the important leadership opportunity for the Klamath Tribes to exercise their sovereign authorities to help make the pilot a reality.
The broad coalition supporting the 2026 Tule Lake Flow-Through Pilot reflects a shared recognition that the Klamath Basin’s fish, wildlife, agriculture, and communities function best as one connected system rather than separate interests. The partnerships are building, the need is clear, and the opportunity is here.
Now let’s take action.
New ESA Rule Marks Significant Shift in Federal “Harm” Policy
After years of advocacy by the Klamath Water Users Association (KWUA), the Family Farm Alliance (Alliance), and dozens of allied agricultural and water organizations, the U.S. Departments of the Interior and Commerce have finalized a rule rescinding the federal regulatory definition of “harm” under the Endangered Species Act (ESA).
While the change may sound technical, it represents one of the most consequential ESA policy reforms in decades.
“This rule is about restoring a clear connection between ESA regulation and actual impacts to listed species,” said Elizabeth Nielsen, KWUA Executive Director. “It provides an opportunity for future decisions to be based on the law Congress wrote and on sound science.”
For more than 40 years, federal regulations interpreted “harm” to include certain habitat modifications that could indirectly kill or injure protected species. Supporters of the new rule argued that interpretation expanded ESA implementation beyond Congress’s intent, creating uncertainty for landowners, water managers, and federal water projects throughout the West.
Following the U.S. Supreme Court’s 2024 decision in Loper Bright v. Raimondo, the agencies concluded the regulation could no longer be justified. They determined that the ESA’s statutory definition of “take” provides the appropriate legal standard and declined to adopt a replacement definition.
“Importantly, the rule does not change the ESA itself, nor does it reopen existing biological opinions, incidental take statements, or permits issued under the previous regulation,” Ms. Nielsen said. “Instead, it changes how the agencies will interpret and apply the law moving forward.”
Legal Challenges Already Underway
The rule has already drawn legal challenges from several national environmental organizations. In one lawsuit filed in the U.S. District Court for the Northern District of California, the Western Environmental Law Center, representing the Environmental Protection Information Center, Cascadia Wildlands, and other Conservation groups argue the agencies reversed decades of policy “abruptly and without reasoned analysis,” placing threatened and endangered species at immediate risk.
A second lawsuit, filed in the U.S. District Court for the Western District of Washington by Earthjustice on behalf of the Center for Biological Diversity, Sierra Club, WildEarth Guardians, Oregon Wild, and several other organizations, contends that the Endangered Species Act has long recognized that habitat destruction can constitute unlawful harm because it kills wildlife “just as surely as shooting them.”
“Preventing harm to wildlife by protecting where they live, eat, and sleep is the foundation of the Endangered Species Act,” said Earthjustice attorney Kristen Boyles.
Defenders of Wildlife also filed suit.
“The law has been clear for decades: destroying the habitat—the home—of endangered wildlife harms that species,” said Jane Davenport, senior attorney for Defenders of Wildlife. “We will use the full force of the law to fight back.”
Why It Matters in the Klamath Basin
For the Klamath Project, the rule could eventually lead to a closer connection between ESA decisions and demonstrable impacts to listed species, rather than speculative or highly attenuated habitat effects.
That issue has been particularly relevant in the Klamath Basin. In comments submitted by the Alliance-led coalition in 2025, supporters pointed to ESA restrictions affecting Klamath Project irrigators that were tied to Southern Resident killer whales hundreds of miles away through a chain of assumptions involving Klamath River Chinook salmon and ocean food availability.
The coalition argued this stretched the concept of “harm” well beyond what Congress intended when it enacted the ESA.
KWUA Helped Shape the Rule
KWUA leadership and its legal team played a leading role throughout the rulemaking process. Executive Director Nielsen joined more than 40 agricultural, water, local government, and business organizations in urging the Services to require objectively discernible physical impacts to listed species rather than relying on speculative ecological effects.
“ESA claims based on harm-by-habitat modification legal theories have led to expensive litigation for water users—litigation that has not provided actual benefits for protected species in their habitats,” said Brittany Johnson of Somach Simmons & Dunn, KWUA’s general counsel. “This change lets the word ‘harm’ speak for itself and discourages that type of wasteful litigation.”
Western Leaders Voice Support
Supporters of the rule – including some Western lawmakers – say the agencies have appropriately returned ESA implementation to the statutory language enacted by Congress and reinforced by the Supreme Court’s decision in Loper Bright. Rep. Celeste Maloy (R-Utah) called the rule “a long-overdue win for the people who steward our nation’s lands.”
“Farmers, ranchers, and landowners know how to maintain ecological balance while putting our land to its proper use,” she said. “Conservation cannot succeed by ignoring the people closest to the land.”
Looking Ahead
Although the practical effects of the rule will depend on how future ESA consultations, pending litigation, and ultimately the courts unfold, KWUA believes the action is an important step toward a more predictable regulatory framework—one made possible through years of coordinated advocacy by western water users, agricultural organizations, and local communities.
“For years, Klamath Project water users have operated under regulatory assumptions that reached far beyond direct impacts to listed species,” said KWUA President Scott Seus. “This reform is an important step toward a more balanced and predictable process.”
THE FERGUSON GROUP FEDERAL REPORT
By: Mark Limbaugh & Chris Kearney
Another busy month in Washington, particularly on the executive branch front.
First, after more than three years of unsuccessful negotiations among the seven Colorado River Basin states, the Department of the Interior (DOI) and the Bureau of Reclamation released the Final Environmental Impact Statement (FEIS) establishing a preferred framework for Colorado River operations from 2027 through 2036. DOI’s preferred alternative creates an adaptive management framework under which operating guidelines can be adjusted over time, based on hydrologic conditions, while preserving the opportunity for future state-negotiated agreements. The framework contemplates significant operational flexibility, including Lower Basin shortage reductions of up to 3 million acre-feet, Lake Powell releases ranging from 5 to 12 million acre-feet annually, and continued use of conservation and water storage tools. The document is a major milestone but not final: a formal Record of Decision (ROD) will follow to establish the new operating rules.
In addition, on an issue long of importance to KWUA, the Advisory Council on Historic Preservation (ACHP) recently voted to revise regulations under the National Historic Preservation Act (NHPA), narrowing which properties count as historic, making public comment optional, and limiting tribal consultation. The Trump Administration’s view is the current process creates unnecessary permitting delays for a range of projects (e.g., water, energy, housing, etc.), but critics, including former ACHP chair Sara Bronin, say it would instead invite an “administrative mess” and risk destroying historic and cultural sites without adequate outreach. Lawsuits are likely. The move also complicates bipartisan permitting talks on Capitol Hill, where NHPA changes have been a sticking point. Democrats, including Sen. Martin Heinrich (D-NM) and Rep. Jared Huffman (D-CA), criticized the council’s action as undermining tribal consultation and jeopardizing a deal. The revised regulation now goes to the White House for regulatory review.
Regarding the administration’s efforts to modify how the Endangered Species Act (ESA) is implemented, recent actions have been taken on two fronts. First, a significant milestone has been reached as the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) have finalized a rule rescinding the regulatory definition of “harm” under the ESA, eliminating language from the Code of Federal Regulations that has underpinned habitat-modification protections for endangered species since 1975. The basis of the decision stems from the Services’ determination that the ESA’s own definition of “take” is sufficient and declined to issue any replacement definition for “harm.” The rule follows a proposed rulemaking published in April 2025 that drew roughly 358,000 public comments. Several environmental groups have sued to stop the rule from taking effect. Pending court action, the rule is expected to take effect September 14.
In addition, the White House has begun its official review of two proposed regulatory language changes by the Services: 1) removal of a provision barring consideration of “possible economic or other impacts” when determining species protections. Species decisions would still rely ultimately on scientific and commercial data, but the change could increase the possibility of cost analyses as a factor in listing-related actions; and 2) allow regulators to exclude designating critical habitat when a species faces threats that “cannot be addressed by management actions.”
There have also been developments on matters related to the “Waters of the United States” (WOTUS). EPA has sent a supplemental WOTUS proposal to the White House for review, just seven months after unveiling an initial rule officials had called the “final word” on the contentious Clean Water Act (CWA) standard. The original proposal, meant to align WOTUS with the Supreme Court’s Sackett decision, required wetlands and streams to physically touch a larger waterway and hold standing water through a region’s “wet season” to qualify for federal protection. But the undefined “wet season” standard drew broad pushback. Damien Schiff of the Pacific Legal Foundation warned it could reintroduce the uncertainty Sackett sought to eliminate, since the ruling recognized only drought and low tides, not months-long seasonal gaps, as exceptions to continuous surface-water connection. EPA water chief Jessica Kramer said the agencies remain focused on a “durable definition” consistent with Sackett, describing the new proposal as a chance to gather more input rather than a reversal. A new public comment period will commence once the proposed revised rule is published in the Federal Register.
Questions? Skyler Palmer | 541-256-0850
KLAMATH PROJECT OPERATIONS UPDATE
By: Gene Souza, KID Executive Director
2026 remains a severe shortage year.
Reclamation determined approximately 221,000 acre-feet of Project water available from Upper Klamath Lake and the Klamath River, well below full irrigation demand.
As of August 3, we have delivered roughly 141,500 acre-feet, leaving about 79,500 acre-feet — 36% of the deemed-available supply. Daily diversions are held no higher than conditions require, and the water-order wait list remains short.
Stretching a limited supply across the Project has taken every available tool:
• Recirculation — Districts are running recirculation and return-flow pumps at full capacity, Klamath Irrigation District has re-lifted more than 14,000 acre-feet of return flow back into the system for reuse and reducing the fresh diversion needed to meet demand, including Warren Act obligations.
• Groundwater augmentation — permitted supplemental wells added groundwater to the system, offsetting surface-water demand on the lake.
• DRA programs — patrons enrolled acres in the Klamath Project Drought Response Agency’s reduced-irrigation programs, further reducing surface-water demand.
• Advanced management techniques — daily diversion tracking, forecast-based scheduling, and disciplined operations keep deliveries matched to the available supply.
• Other Water-savings measures — through the K.I.D. Surface Water Abatement Program (SWAP), patrons took acres off Project surface water for per-acre payment; enrollment closed at 1,022 acres.
Working in combination, these measures are making a measurable difference. With water-savings measures, recirculation, groundwater augmentation, DRA participation, and advanced management techniques all in play, we currently anticipate delivering Project water beyond September 30 — a meaningful outcome in a year of this severity.
Yet, our refuges are seeing mortality of waterfowl. On the Tule Lake side botulism has claimed an estimated 10,000 birds this year from low water levels in Sump 1A. On the Lower Klamath National Wildlife Refuge, Unit 3 is nearly dry, habitat for the young ducks is now lost, and many young birds are reported as mortalities. USFWS continue to remove the dead birds daily to prevent disease from spreading.
We continue to work with our partners to find solutions that enable us to maintain a healthy ecosystem.
POWER UPDATE: KWUA REMAINS ACTIVE IN OREGON AND CALIFORNIA RATE PROCEEDINGS
KWUA continues to actively advocate for Klamath Project irrigators in both Oregon and California utility proceedings that could have significant impacts on future power costs.
Oregon General Rate Case
KWUA has formally intervened in PacifiCorp’s 2027 Oregon General Rate Case (OPUC Docket No. UE-370) to advocate for Klamath Project irrigators and help minimize future electricity costs.
PacifiCorp has proposed an average 8.6% rate increase for Oregon customers. Of particular concern to the Klamath Project is the proposed 11.7% increase for Schedule 41 (pumping and drainage), which serves many irrigation pumping loads. This disproportionate increase would place a greater burden on Project farmers and ranchers than the average customer.
Following a recommendation from the KWUA Power Committee, KWUA filed its petition to intervene and will participate in the proceeding on behalf of its members. KWUA’s efforts will focus primarily on challenging the proposed Schedule 41 rate spread, with the goal of reducing costs for irrigators. We will also address opportunities to improve irrigation rate structures and explore options, such as time-of-use rates, that could provide additional savings where operationally feasible. KWUA has successfully participated in previous Oregon utility rate cases and will once again work closely with its technical and legal team throughout this proceeding.
California Wildfire Cost Recovery Proceeding.
KWUA also continues to participate in PacifiCorp’s California wildfire cost recovery proceeding before the California Public Utilities Commission (CPUC). California Farm Bureau also intervened in the proceeding and submitted an initial set of data requests to PacifiCorp. PacifiCorp has since provided its responses, which California Farm Bureau shared with KWUA. Our consultant, Lloyd Reed, is currently reviewing the materials, and a coordination meeting with the intervening parties—including KWUA, California Farm Bureau, and Cal Advocates—is scheduled in the coming weeks to evaluate the information and determine whether additional data requests should be submitted.
KWUA’s opening brief in the proceeding is due in November. Between now and then, the Power Committee and technical team will continue evaluating the evidence and developing recommendations to ensure the interests of Klamath Project irrigators are effectively represented throughout the case.