Columbia River System Operations
Comment & Response
of bluefish.org

Cover Letter
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Conservation
Coal
Carbon Sequestration
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Irrigation
Barging Wheat
Barging Salmon and Steelhead
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Survival of Salmon and Steelhead
Juvenile Survival through Hydrosystem
     Water Temperature
     Predation by Birds
Ocean Conditions
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Greenhouse Gases
An Adequate Power Supply
An Economic Power Supply
A Reliable Power Supply
An Efficient Power Supply
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Potatoes, Apples & Grapes
Petroleum to Pasco
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Orca and Idaho's Chinook
Flex Spill to 125% TDG
Breach Lower Snake River Embankments
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Social Effects
Cultural Resources
Environmental Justice
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Conclusion

bluefish had 45 days to prepare the following comment                      
Carbon Sequestration, comment by bluefish.org, response by CRSO.info
Federal Response:
With respect to the influence of salmon on carbon sequestration, Section 3.5 identifies that fish migration through the lower Snake River corridor would improve under MO3.

Section 3.5.2.3 recognizes that anadromous fish deliver resources that affect food web productivity and influence flora and fauna across the Columbia River Basin. This indicates that, in some areas, MO3 would likely improve landscape carbon sequestration. However, in other areas, MO3 may reduce landscape carbon sequestration.

As described in Section 3.6.3.5, lower water levels in the spring and early summer in some areas under MO3 would reduce productivity in some existing emergent herbaceous and forested and scrub-shrub wetlands. The overall effect of MO3 on landscape level carbon sequestration across the Basin is uncertain.

OH REALLY? -- bluefish counter response:

While referring to the "small" wetlands, "scattered" along the 140 miles of LSR reservoirs, the CRSO respondents take no account of the increased planted acreage when LSR reservoirs are replaced with orchards and/or native grasses.

"There are approximately 160 acres of emergent wetland habitat in the LSRP study area."

Appendix F - Wetlands - Emergent Herbaceous (page F-2-59)
CRSO Excerpt: There are approximately 160 acres of emergent wetland habitat in the Lower Snake River Projects study area.

Revegetation following Remove Lower Snake River Embankments can easily provide that amount of wetlands and other plants that will assuredly surpass the limited "scrub-shrub" carbon sequestration. Plenty of money is set aside in the MO3 budget to reseed and replant the land currently inundated by impounded slack water (Appendix Q, Annex B).

Moreover, the exponential growth, of an annual supply of marine-derived nutrients, will easily overcome the static amount of "scrub-shrub" on the 1/4 square mile (160 acres) "scattered" in "small" places along the Lower Snake Reservoirs.

The magnitude maybe "uncertain" but the net positive direction is very certain. A legitimate NEPA document should be compliant, accurate and professional, and not feign ignorance.

USDA: Considering Forest and Grassland Carbon in Land Management (page 24)
Graphic: Carbon stocks within different ecosystems in the Eastern and Western United States, shown in metric tons per hectare.  Data from Liu et al. (2014).
 
USDA continued Emissions From Forest Management Operations (page 26)
Forest management activities can have a substantial influence on the amount of carbon stored in a forest, as well as what is available for use as wood products or bioenergy. The actual forest management operations also affect the size of the carbon benefit that can be gained. Operations such as tree harvesting, planting, fertilization, and trucking produce greenhouse gas emissions from the fossil fuel used to carry out these activities.


Survival of Salmon and Steelhead, comment by bluefish.org, response by CRSO.info If salmon recovery were to allow Idaho's forests to increase by at least 2% from its current size, then net carbon sequestration would result, even if electricity generation from four LSR dams were replaced ENTIRELY by natural gas combustion and NOT with renewable energy.
Federal Response:
Breaching the four lower Snake River dams would result in long-term benefits including improvements to fall water temperatures and the restoration of the river to more normative riverine processes. In addition, as described in Section 3.5, fish migration through the lower Snake River corridor would improve.

As highlighted in this comment, Section 3.5.2.3 does describe that anadromous fish deliver resources that affect food web productivity and influence flora and fauna across the Columbia River Basin. However, the extent to which the fish benefits described under MO3 affects productivity in Idaho forests is uncertain and, as described in Section 3.6.3.5, lower water levels in the spring and early summer in some areas under MO3 would reduce productivity in some existing emergent herbaceous and forested and scrub-shrub wetlands.

bluefish counter response:

See above "Click for Response" for more, with the excerpts below providing detail.

Appendix Q - Cost Analysis, Annex B - Mitigation Costs (page Q-B-10)
CRSO Excerpt: Restore arid native plant ommunities on approximately 13,000 acres of arid lands along the lower Snake River.
CRSO Excerpt: Develop and implement a planting plan for approximately 1500 acres of wetland and riparian species along the exposed shorelines.
By restoring Idaho's salmon and steelhead, while replacing LSR hydropower production with 680 MW of combined cycle combustion turbines (CCCT), the Pacific Northwest grid will become even greener (see Economic Power Supply).
Scientist Maps CO2 Emissions for Entire US SciTech Daily (10/9/20)
Map: Emissions map of entire U.S. landscape at high space- and time-resolution with details on economic sector, fuel and combustion process. Credit: Courtesy Northern Arizona University
Carbon sequestration in Idaho's forests, greatly increased by salmon restoration, will quickly and easily surpass the CO2 production of MO3's "Conventional Resource Replacement Portfolio" (see Economic Power Supply).

This important point was asked to be considered in bluefish's public comment to the CRSO. Instead of providing a calculation refuting this conjecture, a falsehood was created. The co-lead agencies completely ignored bluefish, asserting falsely that carbon calculations under MO3 would be "uncertain".

MO3's "Conventional Resource Replacement Portfolio" is also MO3's "Zero-Carbon Replacement Portfolio"!