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NWF.101/Apr.25.2000
[1] DC Paper Says White House Pressured Corps Over Snake EIS
[2] NMFS' 'Sobering' Extinction Estimates Questioned At Senate Hearing
[3] Columbia Fish Count Stays Hot-Tops 90,000
[4] Hearing Gets Mixed Report On WA Salmon Progress
[5] BPA Tells Senate It Won't Foot The Whole Fish Recovery Bill
[6] Oregon Sets Sport Fishery For Coho Salmon
[7] Unmarked Hatchery Fish Releases Confound Fish Counts
[8] PUD Wants More Collaboration On Enloe Dam License
[9] Study Says Snake Dams Can Be Replaced With Clean Energy Resources

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[1] DC PAPER SAYS WHITE HOUSE PRESSURED CORPS' SNAKE EIS

The DC-based Washington Times reported last week that assistant secretary of the Army Joseph Westphal ordered the Corps of Engineers to delete a preferred alternative from its December 1999 draft Environmental Impact Statement on future operation of the four lower Snake River dams. As NW Fishletter reported last December, the Corps was ready to recommend that the dams remain in place, but that improvements be made to fish passage facilities.

According to the April 19 Times story, the newspaper obtained an Oct. 22, 1999 memo from Westphal--the Corps' highest ranking civilian official--to Corps Commander Lt. Gen. Joe Ballard, that said in part, "The Army does not at this time have a preferred alternative from among those alternatives considered in the draft lower Snake River feasibility study...Therefore, we need to ensure that the draft feasibility study and all related discussions and correspondence are consistent with this policy guidance and do not identify a preferred alternative at this time. In this regard, chapters six and seven of the draft feasibility study should be reserved for future use."

The Times' story said the idea to delete the preferred alternative first surfaced in an Oct. 8 e-mail message from Army Secretary Louis Caldera to the Corps. Caldera's message indicated that George Frampton, chair of the White House Council on Environmental Quality, did not think it was a requirement to include a preferred alternative in an EIS.

An Army spokesman told the Times last week that "officials ordered the Corps to change its report because they did not believe enough scientific evidence existed to make a recommendation."

But a Senate task force is looking into the possibility of inappropriate political interference by the executive branch on the professional judgment of Corps officials. One Senate staffer said last week that it seems the CEQ's role is becoming more apparent in many other Corps decisions as well, pointing to projects on the Missouri and upper Mississippi rivers and in the Everglades.

At a salmon recovery hearing near Seattle last week, Sen. Slade Gorton (R-WA) said he was troubled by the issue. "This action raises serious questions about the Administration's motives," Gorton said, "and unfortunately taints the trust of Washington citizens that future federal spending of their tax dollars on salmon recovery efforts will be based on sound science rather than a political agenda."

Last December, NW Fishletter reported that it was likely the Corps' preferred alternative had been excised by a decision at the Cabinet level. However, the official Corps position was that the White House exerted no influence, and that it was strictly an Army/Corps debate over the EIS.

Insiders have pointed out that technically, such a statement may be true, since the high-level conversations involved a "discussion piece" circulated by Westphal rather than the draft EIS itself. If the White House called for deletion of the preferred non-breaching option in the discussion piece, the Corps could say that no political pressure was exerted to change the EIS. -Bill Rudolph


[2] NMFS' 'SOBERING' FISH PREDICTIONS QUESTIONED AT SENATE HEARING

Debate went public last week over the method NMFS has used to predict extinction risks for ESA-listed salmon in the Columbia Basin. Testimony at an April 18 Senate field hearing at Bonneville Dam by fisheries professor Jim Anderson outlined the NMFS process, which he said does not include recent data that reflect improvements in fish survival from a friendlier ocean regime. The worst-case scenarios used by NMFS are of little use to decision-makers, Anderson maintained.

More than 8,000 spring chinook were counted passing Bonneville Dam the day before the hearing, with the total run about three times the 10-year average by April 18. High jack returns this year seem to portend the possibility of even more fish next year.

Sen. Gordon Smith (R-OR), who chaired the hearing--conducted under the auspices of the Senate
Photo of protestor in fish suit
Largest fish seen at
Bonneville Dam last week
Energy Subcomittee on Water and Power --called Anderson's testimony "very valuable." Before Anderson testified, Smith heard from NMFS Columbia Basin coordinator Rick Ilgenfritz, who told the Senator that the NMFS CRI (Cumulative Risk Analysis) produced "sobering" extinction risks for the Columbia River stocks. Ilgenfritz' comments echoed regional NMFS administrator Will Stelle's remarks at a DC hearing the previous week, at which he said upper Columbia stocks were more likely to go extinct than Snake River fish. Stelle said the CRI analysis shows that dam breaching is no silver bullet for the stocks' recovery, but that the hydro system has a huge impact on fish--forcing the region to make big improvements in all the Hs, especially in the habitat arena on both federal and private lands.

However, Anderson, a UW fisheries scientist and guiding light of the CRiSP salmon passage model, said the NMFS analysis is flawed. "A 100-year prediction based on 15 years of data has little value and, in fact, substantially biases the perceived risks to the stocks," Anderson said in his testimony. "It ignores a major driving force of the stocks--variability in salmon productivity resulting from decadal scale ocean cycles."

According to Anderson, including newer data reflecting improved chinook ocean survival in the NMFS modeling effort would show the risks of extinction are much lower than CRI has predicted. Using an example of survival rates from the early 1980s, Anderson said the risk of extinction of any of the seven Snake River spring chinook index stocks would be zero, while CRI has predicted that two of the seven had a 5 percent to 10 percent chance of going extinct in that time frame.

He said that using the survival rates included in his example, only one of the seven stocks faces a chance of extinction over the next 100 years. Meanwhile, the CRI estimates that four of the seven stocks face a high probability of extinction over the next 100 years.

The CRI uses a stock performance database from 1980-1994, which Anderson said reflects "anomalously warm ocean conditions." The CRI modelers have gone astray, he added, because the last data point in the series carries more weight than others. If stocks are low, the modified version of the Dennis extinction model predicts that they will continue to decline. But if they are increasing, the model will produce more optimistic results. (Prof. Brian Dennis of the University of Idaho, who originally developed the extinction model, told NW Fishletter recently that he was not familiar with the modifications NMFS modelers had made).

The field hearing also gave Don Sampson, executive director of the Columbia River Inter-Tribal Fish Commission, a chance to explain his position. Sampson pointed out that NMFS itself has concluded that even with zero harvest, index populations of Snake spring chinook would decline.

He called for a 50 percent to 75 percent increase in BPA expenditures for fish and wildlife recovery. "Artificial propagation must be part of the solution," Sampson said, adding that he is "concerned" about NMFS limitations on the use of hatcheries for recovering wild stocks. The agency has not demonstrated problems with the supplementation strategy, Sampson said, although they say it's likely that supplemented stocks will produce less fish in the long run.

Assistant Public Power Council director Rob Walton said his concern is reflected in certain analyses from the PATH process, which pointed out that higher harvest rates are triggered when stocks rebound, which could have detrimental effects on the weakest runs.

But he agreed with Sampson on one main point: "I think hatcheries are getting a bum rap," he said. Walton suggested it is time for NMFS to make some "hard calls" about fish policy, such as requiring mass marking of all hatchery fish to monitor harvest and recovery actions.

Sen. Slade Gorton (R-WA) made a short appearance at the hearing and promised that no legislation that calls for breaching lower Snake dams would ever pass as long as he is in Congress. He noted the positive fish numbers and wondered whether the increasing returns have more to do with improvements at the dams or the "cooling" ocean. Finally, Gorton said he recognizes the high possibility of shortfalls in Northwest power generation in the next few years--another reason to keep the dams in place.

The hearing also gave several panelists a chance to knock the Corps of Engineers' recent economic study on dam breaching effects. Sportsfishing interests said the agency vastly underestimated breaching's benefits in providing greater fishing opportunities.

But Port of Portland spokesman Keith Leavitt said the Corps' study neglected to include important transportation and economic effects outside of eastern Washington and Idaho. He said breaching the lower Snake dams would end upriver container service, which could end his port's direct service to Australia, New Zealand, South America and southern Europe, with possible reductions around the Pacific Rim. -B. R.


[3] COLUMBIA RIVER SPRING CHINOOK RUN STAYS HOT, TOPS 90,000

By April 24, this year's spring chinook run up the Columbia River topped 90,000 fish--a number that hasn't been reached since 1978, when nearly 85,000 spring fish were counted passing the dam. One big difference with this year's run is that up to 90 percent are hatchery fish. Early PIT-tag detections at Bonneville Dam show that most are headed for the Snake River.

But biologists are reeling from unexpectedly high early jack counts
Fish going up the Fishladder
Spring chinook at the counter's window.
as well. Some 2,600 of them were counted by mid-week, which is more than 10 times the 10-year average (1990-1999). It was last year's high jack counts that signaled strong adult returns this year, but most were counted relatively later in the spring. By this time last year, only 154 had been counted at Bonneville Dam. What that means for next year's run is anybody's guess, but the region could see a phenomenal return of spring fish if the numbers keep climbing.

The migration is beginning to appear upriver as well. About 10,000 adults have passed McNary Dam, and more than 4,500 chinook have been counted in the Snake River at Ice Harbor--tracking about the same as adults at Bonneville, or about three times the 10-year average. -B. R.


[4] HEARING GETS MIXED REPORT ON WA SALMON PROGRESS

Washington Sen. Slade Gorton (R) convened a "salmon summit" field hearing of the Senate Interior Subcommittee in Redmond, WA, last week to survey progress made on state salmon recovery since a similar event a year ago. It was clear the locals were having problems tracking with the feds and that the feds were having problems understanding the work load associated with last year's listing of Puget Sound chinook as a threatened species.

Gorton began the hearing with a recap of the story that the Clinton Administration had put the kibosh on the Corps' intention to declare a non-breaching preferred alternative in its December 1999 draft EIS on the Snake River dams). Democrats Sen. Patty Murray and Rep. Norm Dicks were having no trouble with Gorton's take on the salmon issues of the day, but Democrat Rep. Jay Inslee tried to get a second opinion on dam breaching from NMFS director Will Stelle late in the proceedings. Stelle chose to explain complexities, however, rather than express opinions.

William Ruckleshaus, chair of the state board that oversees salmon funding for the habitat-oriented state recovery program, said he is optimistic about the recovery effort. But county execs Ron Sims (King) and Doug Sutherland (Pierce) said they need more time than the June deadline NMFS has scheduled for beginning implementation of a 4(d) rule for Puget Sound. The rule, now in a draft framework form, will encompass the three biggest counties in Washington and spell out guidelines for future development, road building, runoff management and just about any other activity that could affect the listed salmon and bull trout populations.

"It's far more complex than we anticipated," Sutherland told Sen. Gorton. "It's like trying to drink out of a fire hose at full bore," he added. The Pierce County executive noted that because of limited resources, outlying jurisdictions are having an even harder time dealing with salmon recovery issues.

Sutherland also criticized federal agencies for a "lack of vision" because of their ESA mandate. He said that if the feds don't create a working relationship with the counties out of the current state of confusion, recovery efforts won't be successful.

Ruckleshaus pointed out that some areas of the state, notably northeast Washington and the Yakima River region, haven't yet developed lead entities to begin assessment of watershed needs--where recovery planning begins. And even with 23 other such entities in place, he said there is still no common assessment method for all of them.

Sims said not just counties, but federal agencies also need more manpower to deal with voluminous assessments of county projects and develop science to judge the value of recovery efforts. He said all county projects are being held up while being scrutinized by NMFS and USFW for fish friendliness--including critical programs such as the development of more low-income housing, much needed because of skyrocketing home prices in the region.

Gorton is pushing a bill in the Senate that would add 41 more NMFS staffers to ease the crunch. Representative Dicks said he hopes a way can also be found to help fund personnel in smaller counties that can't afford it themselves.

Ruckleshaus said the next round of funding, scheduled to be completed this fall, will include a category called "capacity building" to help all watershed resource inventory areas get involved with the process. He said the funding board screened 270 proposals last year--worth $45 million--and approved 84 of them, at a cost of $13 million.

But it is high-level coordination and a common strategy that are the most compelling needs, in Ruckleshaus' view. A volunteer group of heavy civic and business hitters, assembled initially by Ruckleshaus and former governor and US Senator Dan Evans, is continuing to work out a single strategy, he reported.

The state's hatchery reform effort, facilitated by veteran conciliator James Waldo, reported considerable progress in deciding whether and to what extent hatcheries can co-exist with wild stocks. Science committee member Peter Bergman of Northwest Biological Services said that after much pushing and shoving, the committee has concluded wild and hatchery stocks "could prosper under certain conditions." These conditions would require changes in hatchery management practices, particularly with respect to genetics.

A "Natural Factors" panel produced the liveliest give and take of the day. Daniel Diggs of regional USFW reported on, and downplayed the significance of, juvenile salmon predation by Caspian terns nesting on Rice Island. The loss estimate Diggs cited was 6 percent of migrating smolts, or 3 million to 6 million fish.

Rep. Dicks was clearly upset at Diggs' downgrading of the importance of such predation and fired a shot across the US Fish official's bow: "You just don't get it, with your fixation on the four Hs," he said sharply. Diggs admitted that such a fixation may exist, but with respect to the importance of tern predation, he insisted "we do not manage on the margin."

The tern margin was clearly good enough for Larry Cassidy, chair of the NW Power Planning Council, who thought the project of moving terns to another island out of the smolt mainstream is viable and the suit against the move filed by Audubon chapters "unfortunate." Cassidy learned during the meeting, and announced to the audience, that the state of Washington has decided, at his urging, to file an amicus intervention; Oregon plans to file an amicus this week.

Consultant Victor Kaczynski of St. Helens, OR, told the assembled fish folk there is no way that salmonid events in freshwater, where all the mitigation is concentrated, can account for the variations in run numbers that are at the core of recovery concerns. He cited research that correlates ocean fertility and salmonid abundance, stating that "we can only explain run variability by a combination of climate and ocean productivity."

Dr. Kaczynski noted that the decline of salmon runs at the focus of mitigation efforts were influenced by El Niño events in 1982, '83 and '84, by droughts in 1977, '78 and '81, and by "multiple factors" in other recent years. He cited figures on coastal coho that indicate 3 percent of spawned fish regularly make it to the ocean, but that returns "bounce all over the place"--from 0.05 percent to 14 percent. "We have grossly undervalued the impacts of climate and ocean productivity," he said.

At the end of the hearing, regional NMFS director Will Stelle said NMFS' CRI extinction project shows things "are much worse than we thought" in the Columbia basin, particularly on the mainstem. He did not address the ocean issues raised by Dr. Kaczynski, nor the upturns in fish counts that are not reflected in CRI projections. Stelle's main focus was on Puget Sound and a long-range mandate that requires "we must change much of what we do" in order to assure a Sound recovery program that is "comprehensive and durable."

Stelle was guardedly optimistic on progress, but talked of "huge efforts" that will take "several years" of "incubation and experimentation." Stelle acknowledged the difficulties the locals are having with NMFS' 4(d) timetables and consultations, but he pointed out that the NMFS regional staff numbers only 130 people--too few for the work load. He was assured by the congressionals of support for staff additions in the current Administration budget. -Cyrus Noë, Bill Rudolph


[5] BPA TELLS SENATE IT WON'T FOOT THE WHOLE FISH RECOVERY BILL

BPA told a US Senate Subcommittee hearing two weeks ago that while it "is committed to funding its share of the measures in the region's efforts to save fish and wildlife...there are a number of other federal funding components necessary to implement the regional plan for recovering species.

"Hydro is only one of the four Hs that might be addressed and our funding must be guided by a unified plan that is scientifically sound and which integrates the [Northwest Power Planning] Council's fish and wildlife program with ESA issues and actions," said BPA senior vice president Steve Wright.

Wright made his comments during a hearing called to examine federal fish recovery actions and their impact on Columbia River hydro operations. Water and Power Subcommittee Chairman Gordon Smith (R-OR) and Sen. Slade Gorton (R-WA) billed the hearing as an information-gathering session, but capitol sources say it served as a venue to debate the value of breaching dams. That theme was revealed in a press release from Gorton's office, in which he was depicted as "drilling" NMFS regional director Will Stelle on the viability of removing the four lower Snake River dams as a salmon recovery strategy.

In his testimony, Stelle shied away from a direct answer, but did list breaching as a strategy that is "likely to result in the needed improvements for fall chinook." However, he added that "the bottom line appears to be that breaching by itself may not be sufficient to recover all [Snake River] stocks." At the same time, Stelle cautioned against relying entirely on the remaining options, including improvements in hatchery operations and river habitat as well as harvest reductions.

In response to questions from Sen. Larry Craig (R-ID), it was reported that Stelle said breaching the dams could increase fall chinook habitat, but when Craig suggested that breaching would only increase fall chinook habitat by 7 percent of their original spawning range, Stelle didn't dispute the figure.

Stelle warned the subcommittee that there is no silver bullet, "no single decision or process that will lead us to recovery overnight." But he lauded studies that reportedly show "the importance of (improving) habitat.

"We recognize that this is not a popular observation, but the science is persuasive," he added.

Both Stelle and Wright emphasized the importance of the newly emerging "performance standards" that federal agencies are relying on to develop and fund the Northwest fish recovery strategy. Wright explained that Bonneville wants overall standards for the hydro system, as well as survival standards for each stage of the salmon life cycle. -Lynn Francisco


[6] OREGON SETS SPORT FISHERY FOR COHO SALMON

The Oregon Fish and Wildlife Commission and the Pacific Fishery Management Council have adopted a controversial coho salmon season. At issue is how many wild ESA-listed coho salmon should be harvested while sport and commercial fisheries are provided access to increasing numbers of hatchery fish from improved ocean survival. The Columbia River hatchery coho salmon reared and released by federal hatcheries continues to drive the ocean and inside fisheries. Given the strong political backlash on killing hatchery salmon at the hatcheries, the state of Oregon is interested in harvesting as many of these hatchery coho as possible.

The PFMC set the coho season from 3 miles offshore out to 200 miles, and the state of Oregon confirmed the federal limits and set its own harvest for state waters (inside 3 miles).

Before the PFMC adopted the coho rules, Oregon Gov. John Kitzhaber told his state's representatives to the council to hold the coho harvest at 15,000 hatchery fish. While Oregon proposed a 15,000-fish harvest level, California representatives amended it to 20,000 hatchery fish. The Oregon Fish and Wildlife Commission adopted the PFMC 20,000 coho harvest.

Past PFMC member Frank Warrens told the commission that the "governor's office's actions were inappropriate. For the second year in a row, they have tried to end-run the process."

"It's embarrassing when other states ask me whether the Oregon governor will support a low harvest of coho so they can harvest more fish," said another member of the PFMC serving on the salmon advisory panel and representing Oregon. "I lobbied California to amend the proposal advanced by Oregon to 20,000 rather than 15,000 coho."

According to Hans Radtke, an Oregon rep to the PFMC, staffs of Oregon Department of Fish and Wildlife and Kitzhaber reached an agreement to avoid a public debate, while holding the harvest of hatchery coho to the same 15,000-fish harvest goal adopted in 1999. The Governor's staff based its position on the advice of the Independent Multidisciplinary Science Team, which actually called for no fishing. Kitzhaber's recommendation allowed for some harvest, but would have minimized the mortality of ESA-listed wild coho.

Radtke said the harvest of 15,000 hatchery coho would result in the mortality of 6,000 unmarked coho salmon. But not all unmarked coho are wild; Columbia River tribes and the state of California are releasing unmarked hatchery coho. Still, the bulk of the unmarked fish are believed to be ESA-listed coho. A 20,000-fish harvest rate means that between 8,000 and 9,000 unmarked coho salmon would be killed.

From 1997 through 1999, the ESA-listed wild runs did not replace themselves, and some biologists are concerned that the wild coho are still not rebuilding. This year's smolt out-migration is very small because of floods and low spawner abundance.

"Oregon Trout believes that a good case could be made for the commission to be more conservative than the NMFS and the PFMC have been with the management of a threatened species," said Jim Myron, conservation director for Oregon Trout, in a letter to ODFW. "Just exactly what does 'prevent the serious depletion of any indigenous species' mean and how should that statutory requirement affect this decision?" -Bill Bakke


[7] UNMARKED HATCHERY FISH RELEASES CONFOUND FISH COUNTS

Since 1998, the National Marine Fisheries Service and the states have reached agreements with Columbia River tribes to trade sport fishing access for tribal release of millions of unmarked hatchery fish. But the future of the program is unclear.

Releasing unclipped hatchery fish makes it hard to evaluate the effectiveness of hatchery programs, according to the Independent Scientific Advisory Board's hatchery review in 1999. The review concluded hatcheries have failed to meet their objectives and managers have failed to evaluate hatchery programs. "The only way a hatchery program can be evaluated is to be able to identify the hatchery fish when they return," says ISAB chair Jim Lichatowich.

Tribes call fin clipping "mass mutilation" and feel that if a hatchery fish makes it back to spawn in the wild, it should be counted as a wild fish to supplement natural runs. As CRITFC director Don Sampson pointed out at a Senate field hearing last week, the tribes don't agree with NMFS' concept of "evolutionarily significant units" which means, according to Sampson, that there is "no value in using surplus hatchery fish."

Harvest managers have their own problems with unmarked hatchery fish, including difficulties in estimating the size of the wild runs and the setting fish allocation levels for incidental take in legal commercial and sport fisheries. Each year, the National Marine Fisheries Service determines whether a fishery, among other things, is likely to jeopardize the ESA-listed salmonids in the Columbia River.

According to NMFS biologist Mike Delarm, his agency is concerned about the "masking effect" that unmarked hatchery fish have on wild fish abundance, which is being discussed with tribes and states as part of ongoing negotiations over fishing seasons and hatchery production.

The unmarked hatchery fish "inflate the wild run size and increase the incidental take, and this is a real risk," said Delarm, who also noted there are some hatchery fish that should not be marked because they are important to rebuilding or reintroducing a run, and therefore should be protected. If they look like wild fish, they will more likely escape the sport fishery and spawn. The reintroduction of spring chinook into the Walla Walla River is an example of where unmarked hatchery spring chinook would be used to re-establish a run that was driven into extinction decades ago.

Delarm also said NMFS will make a jeopardy call this year if hatchery fish impact a natural population. Since marked fish can be sorted out before they spawn, unmarked returning fish will make it more difficult to determine whether the hatchery fish are having an impact on wild stocks.

Since the spring and summer chinook are expected to return in great numbers this year, thousands of extra hatchery fish are likely to flood facilities. Columbia River tribes would like these fish to spawn naturally to boost the number of spawners, but NMFS wants to limit the number of hatchery fish spawning with wild fish to better protect the native salmon.

"We need to maintain an accurate accounting of wild steelhead and fall chinook status, and in our judgement it would require a mark," said NMFS manager Steve Smith. He said his agency would accept an external mark other than the adipose fin clip, so the fish could be passed through the fishery (Only fish with an adipose clip can be retained in the sports fishery).

Smith also stated that "not enough Snake River fall chinook are being marked to provide an evaluation of the program." These fish are coming from federal hatcheries, with marking supported by federal dollars from the Bonneville Power Administration or U.S. Fish and Wildlife Service.

"In the upper Columbia River, the biological opinions include more hatchery marking, such as the Carson Hatchery spring chinook released into the upper Columbia tributaries," said Smith. "Also, Carson Hatchery spring chinook will be removed from the Winthrop Hatchery this year," he said.

According to Smith, hatchery production planning is best done comprehensively through subbasin plans and not through annual harvest agreements. But subbasin plans require a public process, and any hatchery plans would also require a hatchery genetic and management plan, which also includes a public process. Up to now, agreements have not been conducted in public, but negotiated in the private deal-making process between the parties to U.S. v. Oregon negotiations. These negotiation sessions have involved the tribes and fish managers for the states and federal agencies, but little common ground has been reached of late. "The parties are so far apart, on harvest and hatchery agreements, the court will have to establish a common ground and set some rules," said Steve Sanders, assistant Attorney General for the Oregon Department of Fish and Wildlife.

On April 21, ODFW harvest manager Guy Norman told his Fish and Wildlife Commission that the harvest pie is getting harder to cut. "If the tribal fisheries were to harvest their 50-percent share of the upriver bright fall chinook run, there would be no fish left over for non-Indian fisheries." This means the tribes could take so many ESA-listed fish trying to get their quota of Hanford Reach fall chinook that there would be no room for additional take of listed fish to allow a sport fishery. Consequently, " the tribes are willing to trade some upriver bright fall chinook harvest for some hatchery production consideration," said Norman.

But before the commission OK's such an agreement again this year about unmarked hatchery releases, member John Esler said he wants ODFW department staff to come back with a recommendation on a future course of action. -Bill Bakke


[8] PUD WANTS MORE COLLABORATION ON ENLOE DAM LICENSE

In a case involving minimal megawatts but significant precedents, Okanogan County PUD has asked the Federal Energy Regulatory Commission to reconsider its decision to rescind the license of Enloe Dam based on NMFS' controversial demand for installation of fish passage facilities. The PUD wants the commission to return the license to "pending" status and refer the case for alternative dispute resolution.

Meanwhile, the commission's February order also managed to provoke the ire of NMFS. In a letter to FERC, regional administrator Will Stelle reiterated his support of the decision, but accused the commission of using it "to inflame controversy by making unwarranted and inaccurate assertions regarding NMFS' 'intentions' as a consulting agency" in the licensing process.

The 4.1-MW Enloe Dam has a long and varied history plagued with fish passage issues, and FERC's February order marks the third time its license has been rescinded. The latest proceeding began with the utility's 1991 license application, which FERC granted in September 1996. NMFS and a handful of others promptly appealed. By July 1999, the PUD had reportedly reached agreement with a number of parties. But NMFS' insistence on the inclusion of a fish ladder proved divisive, and the agency accused the commission of usurping its authority to mandate fishways under Section 18 of the Federal Power Act by asking other parties to comment on measures the agency said it would require.

In its February order rescinding the license, FERC said it "had expected that future upstream fish passage decisions would be reached through a collaborative effort involving all interested entities." But the commission said circumstances--including a perceived "new urgency" for NMFS to use Enloe licensing as a way to enhance endangered stocks in the upper Similkameen River, the potential for conflict with BC interests opposed to fish passage and the fact the PUD would have to bear all the costs of the fish ladder--had changed enough "to alter our original conclusion that issuance of a license is in the public interest."

In a concurring opinion, FERC commissioner Curt Hébert criticized NMFS for deciding "not to work to advance a collaborative, regional solution" and instead impose the "fish passage remedy it favors..." Hébert added that he views the licensing process, "where some participants, bearing veto power, have more negotiating authority than others, if indeed inclined to negotiate at all, as absurd."

Okanogan PUD echoed this theme in its March 27 request for reconsideration. The PUD argues that NMFS has chosen to use its mandatory conditioning authority in the Enloe case "in an adversarial and arbitrary fashion to prompt its preferred option, license denial."

But the utility also faults FERC. The PUD said the commission itself identified a number of NMFS "transgressions" in its order, but "the commission's response--bluntly stated--was to surrender." In doing so, the PUD argues, FERC erred in its February ruling by abandoning both its responsibilities under FPA Section 10 to "foster comprehensive development" of the nation's rivers "for all beneficial public purposes," and its own policy favoring collaborative processes.

"That the commission would wish to make the Enloe Dam licensing proceeding a poster child for the crying need for reform in its licensing process is not surprising," the utility added, citing hydro licensing reform legislation now pending in both houses of Congress. "Notwithstanding its impact on the public debate about licensing reform, the district has little enthusiasm for volunteering to be the next corpse slumped at the exit from this obscene regulatory maze...The district cannot simply walk away from this controversy and respectfully submits that the commission should not do so either."

The PUD also argues that FERC's decision to revoke Enloe's license "effectively rewards NMFS and deprives the District, as license applicant, of any opportunity to challenge or otherwise resolve the license conditions to which the commission itself objects. "The PUD points out that there is no existing avenue for an administrative appeal at FERC or NMFS. And further, without "pending" license status, the utility lacks standing to challenge NMFS' mandatory conditions in court.

In making its case for having the docket reactivated and referred for alternative dispute resolution, Okanogan says FERC's February order "does not adequately address the real interests of any of the participants in this proceeding, including NMFS." Dispute resolution, the PUD argues, would allow other regional entities to participate "that have the resources or influence to help settle key issues...Enloe Dam and the underlying fish passage problem will not go away."

But in a March 23 letter to FERC, NMFS regional administrator Will Stelle asserted that license denial does not foreclose the possibility of reaching agreement on Enloe's fish passage issues. "Rather, we believe that the opportunities for timely and collaborative resource planning (including measures needed to recover endangered steelhead and chinook salmon) are increased by the commission's decision to refrain from authorizing a new, uneconomical power source at the existing Enloe Dam site," he wrote.

Stelle also reiterated that "NMFS strongly objects to the commission's improper usurpation of our authority to prescribe fishways," and blasted FERC--particularly Commissioner Hébert--for assertions he labeled "particularly counterproductive, in addition to being inaccurate." Stelle took issue with FERC's statement that NMFS intended to require the installation of fish passage facilities immediately and without collaboration.

"This distorted representation of NMFS' 'intent' appears to assume that the only possible means of collaborating on matters related to fish passage and fish recovery is through some post-licensing procedure under the direct, discretionary control of the commission's Office of Hydropower Licensing staff," Stelle wrote. -Angela Becker-Dippman


[9] STUDY SAYS SNAKE DAMS CAN BE REPLACED WITH CLEAN ENERGY RESOURCES

The "key finding" of a controversial new study says that "conservation and renewables would be no more expensive--and in some cases, cheaper--than market strategies" in replacing power from the four lower Snake River dams, said Karen Garrison, director of the National Resource Defense Council's Northwest Salmon Project. Relying on Northwest Power Planning Council data and modeling techniques, the analysis released two weeks ago examines the residential rate and BPA stranded cost impacts, as well as changes in carbon emissions, associated with removing the dams and replacing their output.

The study, a combined effort from NRDC and the Northwest Energy Coalition, concludes that, compared to a baseline where the dams remain in place, the groups' preferred "zero carbon strategy" for replacing Snake River hydro power would raise residential rates by an average of $1 to $3 per 1000 kWh from 2002 to 2021--contingent upon variables such as market prices and how much power the individual customer's incumbent utility purchases from BPA. This compares to an average residential rate increase of $1 to $2 per 1000 kWh if the dams are removed and power replacement is simply market-driven.

Titled "Going with the Flow: Replacing Energy from Four Snake River Dams," the analysis has been in the works for at least two years. NWEC cited its preliminary results in November 1998, when the group formally endorsed breaching the four lower Snake dams as long as conservation and renewables filled the resulting power gap. Since then, said Garrison, the analysis has been refined. "What took the longest was getting comfortable with its assumptions," she told NW Fishletter.

The study compares the region's energy costs under nine different conditions. In the baseline scenario where the dams remain in place, BPA's 2002-2021 Net Present Value (NPV)--the agency's projected revenues if it sold power at market rates, minus its estimated total costs--is calculated when market prices are high (levelized at $35.54/MWh in 1998 dollars), medium ($24.19/MWh) and low ($16.85/MWh). The NPV figures are then compared with the costs of removing the dams and replacing their power under both a market-driven replacement strategy and a strategy consisting solely of conservation and renewables acquisition. These costs are also figured across the three different market price conditions. To make these calculations, the study relied upon NWPPC's Stranded Cost Simulation model and the AURORA market-price forecasting model.

The baseline condition at the heart of the study was extracted from the Power Council's 1998 analysis of BPA's future potential costs and revenues. It incorporates more transportation, flow and spill relative to levels stipulated in the 1995 BiOp--resulting in a decrease of 196 aMW in federal hydro generation. "We wanted a base case that improved conditions for in-river fish, but not the more extreme alternatives," said Garrison. "We were simply trying to say the status quo wasn't acceptable, and it turns out that our estimate is pretty close."

"The number they chose might actually be more conservative than the reality today," confirmed NWPPC power system analyst John Fazio. He said that increased and extended flows, as well as increased spill to aid steelhead under the 1998 Supplemental BiOp, cut generation to levels pretty close to those included in the study.

The analysis' estimate of BPA's baseline, 20-year NPV ranges from stranded costs of $565 million in low market price conditions to benefits of $17.5 billion if prices are high. The cost of each power replacement scenario is then subtracted from the agency's NPV to arrive at the 20-year cost of breaching and securing replacement power.

Both strategies begin with the premise that if the dams were breached the region would have to replace about 940 average megawatts of federal power per year, relative to the baseline. Based on Army Corps' analyses, the study puts the cost of breaching in both replacement scenarios at $700 million. Other common costs include $130 million in transmission upgrades that BPA says dam removal would necessitate.

Questionable Savings

According to the study, these expenses would be somewhat offset by about $420 million in savings--relative to the baseline--on avoided expenditures that would have been necessary to bring the river into Clean Water Act compliance, as well as by elimination of BPA operating, maintenance and capital costs no longer incurred if the dams were retired .The CWA compliance strategy includes cost estimates of hundreds of millions of dollars in engineering modifications, such as submerged ports below spillways that could reduce gas levels in lower Snake, but may also be detrimental to fish survival.

The cost of the two replacement strategies do, however, differ in other ways. According to the NWEC/ NRDC analysis--with resource prices based on NWPPC data--the region's energy costs could vary dramatically under the market-based replacement scenario. Electric expenses--that is, the difference between BPA's baseline NPV and the cost of replacing generation via the market--would rise from $900 million when prices are low to $2.5 billion when market prices are high.

Using the AURORA model, the study also estimates that under the market-driven strategy, all newly-built resources would be gas-fired, and that all told, about 87 percent of the replacement generation would come from natural gas and about 13 percent from coal. The net result would be a 0.7 percent increase in carbon emissions across Western Systems Coordinating Council territory.

This is in contrast with the zero carbon replacement scenario, which would result in no net increase in emissions over the 20-year period. According to the study, a total of 1091 aMW in annual conservation and renewable would have to be added to cover the additional emissions from market purchases made while the clean resources were being phased in. Under the enviros' plan, this strategy would consist of 75 percent low-cost conservation (at $17/MWh) and 18 percent non-hydro renewables, comprised mostly of wind. Relative 20-year energy costs with this strategy would be highest if market prices are low--$1.5 billion above the non-breaching baseline. The zero emissions option would cost about $1.4 billion more relative to baseline in medium priced market conditions, and $1.5 billion more when prices are high.

The study's authors point out that this puts the zero carbon strategy on equal footing with the market driven response when prices are in the medium range, and indicates it would be even cheaper when market prices are high.

"Even after incorporating the main cost of dam removal and clean energy replacement, BPA electricity rates are likely to be competitive with market rates," the study concludes. "Only if future energy costs are low is BPA likely to face stranded costs over a 20-year period, and in that case its rates would be noncompetitive with or without removing dams and replacing their energy."

Study Recommends Expansion of BPA's Resource Plan

Based on the results, the study recommends that BPA should expand the resource plan being developed to address its existing projected power shortfall to include enough conservation and renewables acquisitions to replace the lower Snake River dams' output. The authors recommend BPA extend the plan beyond the current five-year rate period to 2011. And to avoid potential cash flow problems, the study also suggests the agency explore creating a reserve fund, borrowing in the market or instituting a long-term slice of the system mechanism.

"Incentive programs are great, and BPA is positioned to play an important leadership role," said NWEC policy director Nancy Hirsh. "BPA will be losing the power, and they will have the expense of replacing it. Clearly they have an obligation to pursue conservation and renewables."

Hirsh said one of the virtues of the zero emissions strategy is its flexibility. "Conservation is a constantly evolving resource over time. The reservoir's big enough not only to support the supply shortage now, but to continue to provide benefits when we do dam removal."

Hirsh added that not only BPA, but states, individual utilities and entities such as the Northwest Energy Efficiency Alliance would all have to play a role in implementing the conservation and renewables strategy. "It's a package," she said. "And BPA may be the logical hub. They've played that role in the past and the region isn't psyched about going back," she conceded. "But it makes sense."

While the study released last week deals extensively with the economics of replacing power from the lower Snake dams, Garrison and Hirsh acknowledged that various externalities--for example, emissions resulting from increased trucking if the dams were removed--were beyond its scope. Also, because the Council's data did not include information on fuel cells, the study failed to take up the replacement potential of distributed generation. Another topic not addressed is the region's looming capacity and reliability problems.

Jeff King, senior power analyst for the Power Planning Council, said he has seen a number of versions of the report, "and I have relatively few problems with it at first cut." King said the Council "provided the data we had in hand" and that the study relied on the NWPPC's own assumptions regarding the costs and performance of conservation and renewables.

"It was a good idea to do this study, and to have this idea out on the street," King added, "but it definitely needs some additional analysis before people run out there and start implementing the programs that they recommend."

Price Forecasting Improved

King said that since the groups' study was begun, the AURORA price forecasting model has been improved. "It's better now than it was at that time. It's a twitchy sort of model, and you'd definitely want to do those runs over very carefully," he said of the study's market projections. He also po-nted to the fact of the capacity problem, "which these programs might exacerbate, and which certainly bears more analysis."

King said that at the moment the Power Council has no plans to take up the subject of the study itself. "I'd say it would be unlikely that we do anything unless the issue of dam breaching became more concrete," he predicted. "Speaking for myself, I think that to some, looking at a replacement power policy would be an implicit acknowledgment that we're moving ahead on breaching." -A. B. D.

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