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NW Fishletter #382, June 4, 2018
 NOAA Fisheries Confirms Plan To Complete BiOp This Year
A spokesman for NOAA Fisheries said federal agencies have decided to undertake and complete a new BiOp for the Columbia River's federal hydro system by the end of 2018.
The decision comes in spite of U.S. District Judge Michael Simon's April 17 ruling in National Wildlife Federation v. National Marine Fisheries Service, delaying the deadline for a new BiOp until 2021, when federal agencies are also expected to complete an EIS with alternatives for operating the system that will include removal of four lower Snake River dams.
"Although the judge said we do not have to, the system would have no take coverage [incidental take] under ESA after the current BiOp runs out," NOAA Fisheries spokesman Michael Milstein said in an email to NW Fishletter.
Last month's decision by the court allowed, but did not require, NOAA Fisheries to complete the BiOp in conjunction with the EIS, but it also deferred the plaintiff's other request to allow the hydrosystem to operate under the 2014 BiOp.
Earthjustice lawyer Todd True said federal agencies have to make their own decisions about how to proceed with regard to the BiOp, but added, "I don't think there is any requirement or need. If they do one, we'll have to take a look at it and make our decision on how to proceed in light of that."
True said it's too soon to know whether the plaintiffs will file another injunction for spring spill, as the court's current order only covers 2018.
Federal hydro operations are now under the court's order to spill water at the four lower Columbia River and four lower Snake River dams to spill cap levels, which at all eight dams is 115 percent total dissolved gas (TDG) in forebays and 120 percent TDG in the tailwater.
Due to high flows, more water than required is flowing over each of the dams, putting operations under involuntary spill. That was not the case during most of April, and the U.S. Army Corps of Engineers filed its first report with the court on May 18 regarding its effort to keep spill at--but not above--the spill cap levels on multiple dams at once.
Tables in the report show when, during periods of voluntary spill, actual spill varied from target spill levels due to operational limitations, human error, maintenance or navigation, which occurred 20 times throughout the month, lasting from one to five hours apiece.
In all, the times when spill varied above target levels totaled three hours, while times when spill varied below targets totaled 42 hours, with some partial hours counted as full hours. The agency was operating on involuntary spill at some of the dams later in the month, when flows in both the Snake and Columbia were too high, and additional water had to be spilled to prevent flooding. Throughout the month, total dissolved gas hit 123 percent once, and rose above 120 percent less than a dozen times, mostly at Bonneville Dam's tailwater.
In an email, Corps spokesman Matt Rabe said his agency is committed to implementing the court-ordered spring spill and has been diligently managing spill each day.
"That said, implementing the gas cap spill operation has been challenging with the uncertainty associated with estimating TDG production in the river," he said. "Environmental factors such as wind, barometric pressure, and temperature dramatically impact TDG levels."
Rabe also confirmed there were no unanticipated or emergency situations in implementing the spill in April.
The report includes graphs for each of the eight dams showing total flow, generation flow, target spill, adjusted spill and actual spill. There's also a chart showing the 12-hour average TDG in the tailwater at each project, and the downstream forebay.
BPA spokesman David Wilson said in an email his agency has not calculated how much electricity would have been generated in April if the dams had not been under the court's spill order, or if it was operating under the 2014 BiOp.
Those determinations would involve complex calculations, and require a number of assumptions, he wrote.
Wilson added, "In implementing the spill surcharge, however, BPA's modeling forecast that the additional court-ordered spill for the entire spring fish passage season, will reduce hydropower generation at these eight federal dams by 253 annual average megawatts. This is based on a computational analysis of the impact of the increased spill across 80 water years in the historical record." -K.C. Mehaffey
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