The Washington Department of Ecology made one thing clear at its first public meeting on implementing a TMDL for temperature in the Columbia and lower Snake River—the state will not lower its standards for providing cooler water that salmon and steelhead need.
While it's unclear how that might be accomplished, Ecology officials said at a Jan. 28 webinar that they'll soon begin meeting with tribes and stakeholders to start writing a plan to bring the Snake and Columbia rivers into compliance.
"We're all here today because we're concerned," said Kelly Ferron, Ecology's project lead for the TMDL implementation. "And we're concerned because salmon are in hot water in the Snake and Columbia rivers."
She said the rivers are seeing increasingly high temperatures from July through October, when the state's water quality standards are often not being met. Depending on the stretch of river, the standards range from 16 to 20 degrees Celsius (60.8 to 68 degrees Fahrenheit) as either a daily maximum or a seven-day average maximum.
The standards are set to maintain adequate conditions for salmon and steelhead to spawn, rear and migrate. "When water quality standards are not met, a plan must be put in place," she said.
And while water temperatures are already too warm in some months, the conditions will only worsen with climate change, she said, noting that by attempting to meet the standards now, the new plan could build in some resiliency for even worse conditions that are yet to come.
Ferron said the TMDL, or total maximum daily load, determines a pollution reduction target and identifies the different sources of the pollutant—in this case, high temperatures. Last May, the Environmental Protection Agency released the TMDL findings, which identified the major sources of temperature pollution as climate change and 15 hydroelectric dams. Those projects include five nonfederal dams operated by Chelan, Douglas and Grant county PUDs, and 10 federal dams operated by the U.S. Army Corps of Engineers and the U.S. Bureau of Reclamation.
Ferron said EPA's analysis noted it may be difficult to meet the state's standards at all times and in all places, and suggested making changes to the applicable designated uses to address that conflict. Known as a use attainability analysis, or UAA, the state could determine that maintaining low temperatures for salmon and steelhead is no longer a use that can be attained.
In an August letter to the agency, and again at the webinar, Ecology officials said they do not intend to weaken the state's water quality standards before attempting to improve conditions and meet the current standards. The agency asked EPA to clarify its language to say UAA is a tool that could be considered if standards are still not met after actions have been taken to address temperature pollution.
Cami Grandinetti, EPA's watershed branch manager for Region 10, said her agency is still going through more than 2,000 comments on the TMDL, and is making revisions to the document based on comments received.
Ferron said the TMDL identifies five general sources of temperature pollution for sections of the Columbia and Snake rivers covered by the analysis, which includes the Columbia River south of the Canadian border and the Snake River west of the Idaho border. The sources include climate change; point sources; nonpoint sources from dams and tributaries; natural sources; and geographic boundary conditions, or the influence of the water's temperature as it flows into Washington from Canada and Idaho.
According to the TMDL, water sometimes already exceeds Washington's standards when it enters the state.
Ferron said that for permitted point sources, tributaries and dam impacts from nonpoint sources, the TMDL established a total loading capacity (allowance for exceeding standards) of 0.3 C (0.54 F) for all three, or 0.1 C each (0.18 F).
Hydroelectric dams, through a wasteload permit called a National Pollutant Discharge Elimination System, will be given wasteload allocations for cooling water or other pollutants discharged through pipes. EPA has modified its NPDES proposal for eight projects in the lower Snake and Columbia rivers, and will accept public comments on the new draft until Feb. 15.
But the dams are also considered nonpoint sources due to the heat generated by impounding the river in reservoirs, and creating a larger surface area for the air temperature and sun to heat the water. "Dams are treated somewhat uniquely in the TMDL, both as a point source and a nonpoint source," Ferron said.
She said Ecology will work with federal agencies to meet standards through the NPDES permits, which require a state water quality certification. The Corps has appealed the state's water quality certification for the eight lower Snake and Columbia river projects, claiming conditions of the certification can only regulate discharges from the dams, and not impacts from the structures which were authorized by Congress decades ago. A hearing before the Pollution Control Hearings Board is scheduled in August.
"We have started meeting with these federal action agencies to better understand their operations," Ferron said.
She said so far, Ecology has been working internally to determine how to proceed with the nonfederal dams, and will be reaching out to the PUDs in the near future to discuss implementation of the TMDLs.
For PUDs, the main tool for implementing the TMDLs will be through the state's water quality certification which is provided during each dam's relicensing process through the Federal Energy Regulatory Commission, Breean Zimmerman, Ecology's hydropower projects manager, said. Most of those dams have been relicensed in the last 15 or 16 years, and with certification language that the PUDs must meet TMDL requirements, Zimmerman said.
In answering questions from the public, Ecology officials said plans to reduce temperature could involve implementing recommendations from EPA's Cold Water Refuge Plan. But the agency is still unsure how it will address continued warming from climate change, and water temperatures that exceed the state standards at the points it flows into the state from Canada and Idaho.
"We're still in the early stages of implementation," Ferron said, adding that Ecology hopes to work with EPA for guidance and support.