[1] Feds Say Proposed Dam Operations Would Kill More Fish, Cost $450 Million A Year
Federal attorneys said the proposal by BiOp plaintiffs to add more spill and flow to next year's dam operations on the Columbia and Snake rivers would kill more fish than operations outlined in the old 2004 BiOp. In addition, proposed changes to reservoir operations would hamstring winter power production and cost the region nearly half a billion dollars a year.
The feds say proposed changes that call for maintaining reservoir levels at their upper rule-curve elevations every other week from January through April are probably not even feasible, especially if plaintiffs think that Canadians are likely to run their reservoirs the same way.
The upshot of adding 4 million acre-feet to help migrating salmon in the spring and summer would be to shortchange other stocks that depend on steady winter flows to cover redds , such as Hanford Reach chinook and ESA-listed chum salmon below Bonneville Dam.
In their Nov. 22 response to the plaintiffs' call for more of everything filed in U.S. District Court in Oregon, the feds said biologists from both NOAA Fisheries and the Corps of Engineers agreed that adding more spill, especially later in the spring, would reduce the number of fish barged and cut survival to adulthood.
The feds have a new proposal of their own--to spill enough to keep transported and inriver migrants about equal, while boosting spill at dams where fish are not bypassed for barging.
After April 20, collector projects would cut spill to maximize barging, which is expected to increase smolt-to-adult returns for steelhead and later migrating chinook. They estimated a 16-percent boost in returns of wild chinook from the change in operations.
In order to spread the risk more evenly between barged and inriver migrating fall chinook, the feds propose spilling less during the summer than environmentalists would like, which would "substantially" increase SARS for wild spring/summer chinook and steelhead compared to the plaintiffs' proposal. They said the Court should afford substantial weight to the testimony of expert federal biologists with NOAA Fisheries and the Corps of Engineers in evaluating this strategy.
The federal scientists estimated that the plaintiffs' spill proposal, on the other hand, would reduce wild chinook and steelhead numbers by a couple of percent over BiOp operations, and cut returning adult numbers by more than 64,000 fish from what the feds expect by beginning full transport after April 20.
The federal response was also adamant that the plaintiffs have no proof that added flows improved fish survival. In fact, the response touts "best, available science," which "strongly calls into question whether there is any direct relationship between flow and survival."
Also, getting more water from Canada seems out of the question, especially on such a short time-frame, according to a declaration by BPA's Richard Pendergrass, who noted that operating reservoirs at upper rule curves would be contrary to the U.S./Canada Treaty, which was signed to optimize power and provide flood control.
He said the U.S. has no right to Canadian non-treaty storage that plaintiffs are calling for, either. But even if this were possible, declarations by Corps' personnel say the risk of flooding would increase if Canadian reservoirs were operated at upper rule curves, and would likely require lowering Grand Coulee to compensate, introducing a further set of problems.
Getting the storage from Grand Coulee would lower it seven feet more than the 10 to 12 feet already drafted for flow augmentation, which would have negative effects on cultural resources like burial sites and resident fish production.
Operating reservoirs as plaintiffs have suggested would reduce reliability of the hydro system itself, said the feds, citing the recent analysis by the Northwest Power and Conservation Council.
BPA analyst Roger Schiewe pegged the potential adverse economic impact to BPA from the plaintiffs' injunction at $347 million compared to the BiOp, if the water year turns out to be average. That's a reduction of about 640 aMW for his agency alone in the nine-month period of January through September. In his analysis of the 50 years modeled, one year's loss reached $541 million.
But the economic losses wouldn't be limited to BPA alone, Schiewe pointed out. The mid-Columbia PUDs would suffer as well, losing about $100 million a year on average in power production, which adds up to a January-September energy loss of about 770 aMW for the region.
Schiewe's analysis also suggested that ESA-listed chum below Bonneville Dam would be negatively affected by the plaintiffs' operation, with redds continuously covered in only 19 out of 50 years, while the BiOp would keep them covered in 31 out of 50 years.
Hanford fall chinook redds would also be adversely affected by keeping reservoirs at upper rule curves throughout the winter, he said. His modeling found that Hanford redds would only be continuously covered in 19 out of 50 years, while BiOp operations would provide continuous coverage in 49 out of 50 years.
Schiewe also analyzed the new federal proposal to adjust spill between early and late spring. He said it had no adverse affects on chum and Hanford chinook redds, nor did it change flow requirements for other species at risk like bull trout and white sturgeon. But it would cost, on average, another $43 million to implement the change compared to BiOp operations.
All in all, Schiewe concluded, the plaintiffs had incorrectly assessed impacts to other federal dam operations, power production and revenues.
The states of Montana, and Washington, along with the Spokane, Colville and Coeur d'Alene Tribes and the BPA Customer Group, filed a joint response as a "regional coalition" supporting the federal position. Idaho and the Kootenai Tribe filed separate responses, standing firmly with the feds on interim operations.
Only the state of Oregon seemed content to stay out of the fray, on a day, Nov. 22, when defendants and amici filed 40 responses and declarations. In September, along with other Northwest states, Oregon had supported a stance that called for collaborating with plaintiffs to develop interim dam operations using current BiOp mandates as a starting point. -Bill Rudolph
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