Our old friend Felice Pace, who I first interviewed about Klamath issues about a dozen years ago, offers this assessment of the federal government's recently unveiled final EIS:
The Final EIS/EIR does include analysis and assessment of impacts which are likely if the KHSA is implemented. With respect to the KBRA, however, we get the assessment without the corresponding analysis. That is because Interior chose to consider the KBRA programmatically. Programmatically is bureaucracy speak for deferring real analysis to what is know as the project phase, i.e. the time at which a component of the KBRA is ready to be implemented.Needless to say, Felice comes at it from a different angle than most opponents of the KBRA, in that he doesn't think it goes far enough to protect the environment. But the seemingly growing consensus of opinion as to the science behind the project is interesting, to say the least.
There are a couple of problems with Interior's programmatic approach. For one thing, many aspects of the KBRA are already being implemented by the Bureau of Reclamation and other federal agencies. Deferring analysis of actions that are already being implemented looks a lot like intentionally avoiding the analysis.
Assessing KBRA impacts in the Final EIS/EIR without the benefit of analysis means that the assessment and its conclusions are based on assumptions which may or may not correspond to reality. In numerous instances KBRA provisions are assessed as “positive” and “beneficial” without any real analysis to back up the assertions.