Columbia River System Operations
Comment & Response

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

bluefish had 45 days to prepare the following comment                      
Coal, comment by, response by
Federal Response:
As described in the comment, the focus of the EIS is to evaluate the impacts of the alternatives on resources affected by Columbia River System operations, maintenance and configuration. The co-lead agencies developed a reasonable range of alternatives, including Multiple Objective (MO) Alternative 3, which identifies the impacts of breaching the four lower Snake River dams. The co-lead agencies also agree with the statement [h]owever, regional reliability depends on all utilities, and the loss of baseload generation in the region affects the value of the hydropower produced by the CRS. Thus, the CRSO EIS analyzed the value of the lost power generation associated with MO3 in the context of the regional power system.

The comment takes issue with the EISs discussion of future coal retirements and its impact on the scope of the EIS analysis. The Base Case analysis which was started in 2017 included high-quality information on the availability of resources. Coal generation that was online or expected to remain online was presumed to continue to operate in the Base Case. See Section, Base Case Methodology in the draft EIS. Since 2017, additional coal retirements were announced, along with other changes in the energy industry. The comment suggests that the co-lead agencies should have ignored these changes and limited the EIS to the information available in the Base Case.

The co-lead agencies, however, are not permitted under NEPA to ignore reasonably foreseeable future actions (e.g., coal retirements). More importantly, based on current information, the agencies could not legally ignore these coal retirements because this information squarely falls under significant information relevant to environmental concerns and bearing on the proposed action or its impacts. This language is the test for whether an agency would need to supplement an EIS. 40 C.F.R. 1502.9. Thus, consistent with NEPA, the agencies decided to acknowledge significant changes in the energy landscape in the EIS to avoid the need to supplement the EIS at a later date.

To account for these changes, the EIS included a Rates Sensitivity Analysis and Regional Cost Pressure Analysis. See Section, Rate Sensitivity Analysis in the draft EIS. The Rate Sensitivity Analysis and Regional Cost Pressure Analysis capture the effects of new or updated information on regional reliability. Specifically, the Regional Cost Pressure Analysis, described in the draft EIS in Section, addresses the impacts on regional reliability and regional resource costs if coal retirements were to accelerate. See Section, Availability of Coal Resources at pages 3-841-842 in the draft EIS. This analysis is presented as a sensitivity above the Base Case because the full extent of future coal remains uncertain. To reflect this uncertainty, the EIS developed two coal availability scenarios: limited coal and no coal. See Appendix H, Power and Transmission, Section 2.3 at pages H-2-8 15. The effect of the limited coal and no coal scenarios on regional reliability under each MO is described in the EIS. See Section, No Action Alternative at pages 3-845-84, Table 3-123 in the draft EIS.

Describing the MOs in light of known or likely additional coal retirements provides a more complete picture of the regional impacts of the MOs on regional reliability and costs.