bluefish had 45 days to prepare the following comment
Regarding MO4 and summer temperatures: Under MO4 and as with the No Action Alternative, the four lower Columbia River reservoirs (McNary, John Day, The Dalles, and Bonneville) would continue to show weak to no stratification during the summer months, largely due to the short residence time, wind and flow-induced turbulent diffusion, and convective mixing that occurs in the reservoirs. Maximum tailwater water temperatures and the frequency of water temperature standard exceedances would be similar for MO4 and the No Action Alternative over a range of river and weather conditions. Minor effects to water temperature are anticipated downstream of McNary Dam, while negligible effects are expected downstream of John Day, The Dalles, and Bonneville Dams.
bluefish counter response:
Regarding the Preferred Alternative vs. MO3: The co-lead agencies are legally obligated to operate and maintain the CRS to meet multiple statutory purposes. They are also required to ensure operation of the CRS complies with other laws.
Under the ESA, in particular, the operation of the CRS may not appreciably reduce the likelihood of listed species survival and recovery, or adversely modify or destroy designated critical habitat. The ESA does not, however, require the co-lead agencies to take affirmative actions to recover ESA-listed species as that is a broader goal with shared responsibility. Under the ESA, in particular, the operation of the CRS may not appreciably reduce the likelihood of listed species survival and recovery, or adversely modify or destroy designated critical habitat. The ESA does not, however, require the co-lead agencies to take affirmative actions to recover ESA-listed species as that is a broader goal with shared responsibility.
Based on the fish analysis in Section 7.7.4, the co-lead agencies anticipate that the Preferred Alternative would provide substantial benefits to ESA-listed species and is not expected to diminish the likelihood of recovery. Recovery is a broader regional goal and is above and beyond the co-lead agencies obligations under Section 7(a)(2) of the ESA for the effects of operation and maintenance of the Columbia River System.
That call, however, is ultimately the role of NMFS and the USFWS. Recovery efforts will need to continue to involve parties across the region that have an influence and impact on ESA-listed species.
bluefish counter response:
The EIS set forth eight objectives which, in tandem with the Purpose and Need Statement, establish the framework for evaluating the ability of an alternative to satisfy the co-leads numerous legal obligations.
The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3 which includes breaching the four lower Snake River dams. However, the Preferred Alternative also meets most other EIS objectives including those for resident fish, lamprey, hydropower generation, water management, and water supply, while minimizing adverse effects to communities and the economy. MO3, by contrast, has significant regional economic and community effects, and meets fewer of the EIS objectives. Thus, in the Draft EIS, the co-lead agencies did not recommend MO3 which includes breaching the four lower Snake River dams, because the Preferred Alternative is more likely to satisfy multiple complex and at times conflicting legal requirements for a complex system.
The CRSO is setting aside MO3, which has a moderate to major effect on salmon population, and instead chooses a "spill experiment" that "has negligible effects on SRKWs". Where is the rationale?
The opening paragraph above, suggests that the Preferred Alternative is being selected because it meets more of the EIS objectives than MO3. How many of the eight EIS Objectives are met or can be met, if appropriate mitigations were to occur? That is a good question. It is all important.
Multiple Objective 3 (MO3) and Preferred Alternative (PA) both Improve Juvenile Salmon (see Executive Summary excerpt above);
MO3 and PA both Improve Adult Salmon (see Executive Summary excerpt above);
MO3 and PA both Improve Resident Fish (see Executive Summary excerpt above);
MO3 and PA both Improve Lamprey (see Executive Summary excerpt above);
Provide a Reliable and Economic Power Supply;
Executive Summary (page 30)
Under MO3, hydropower generation would decrease by 1,100 aMW (about 1,000 aMW from breaching the four lower Snake River dams) under average water conditions, and 680 aMW under low water conditions compared to the No Action Alternative.
. . .
A "conventional" Resource Replacement Portfolio "includes 1,120 megawatts (MW) of combined cycle natural gas turbines at an overall cost of about $250 million a year. (See An Economic Power Supply for discussion of appropriate mitigation and (680 MW / 1,120 MW = 65% of) MO3 cost effects.)
Minimize GHG Emissions;
Executive Summary (page 31)
MO3 would also not meet the objective to Minimize GHG Emissions. ... GHG emissions would increase the most if the hydropower were replaced with natural gas. This would lead to an additional 3.3 million metric tons (MMT) of CO2, a 9% increase in power-related emissions across the Northwest (See Carbon Sequestration)
. . .
In the future, technical advances in storage and other low-carbon options may become increasingly viable to help integrate variable renewable generation. With the expanded portfolio that is intended as a full replacement of the capabilities of the lost generation from the lower Snake River dams, the GHG emissions impact would probably be lower.
MO3 would meet the objective to Maximize Adaptable Water Management (Executive Summary, page 32);
MO3 and PA both Provide Water Supply;
Measures implemented under MO3 can have major beneficial effects in Regions A and B and minor effects in Region D, due to sediment accumulation near the pumps near McNary Dam.
MO3 could affect delivery of current water supply in Region C, which would result in major effects to the Ice Harbor private, municipal, and industrial pumps located near Ice Harbor dam (see Irrigation).
Those are the eight stated Objectives of the EIS.
Unabashedly, the CRSO respondents suggest that "minimizing adverse effects to communities and to the economy" is also a stated Objective. Although desirable, it is not a stated Objective of the EIS.
"Hydropower generation" is also not a stated Objective of the EIS, despite the CRSO respondents best efforts to lead the public to this conclusion. The acronym MO in the CRSO EIS is intended to represent "Multiple Objectives". Unfortunately, the authors of the Executive Summary lost sight of this simple, but important fact. It is clear their MO (Modus Operandi) is to intentionally misrepresent the results of this complex issue, with bias against MO3 and the breaching of the four lower Snake River dams.
How many of the eight EIS Objectives are met or can be met if appropriate mitigations were to occur? That is a good question. It is all important.
Federal Response (from opening paragraph above):
The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3 which includes breaching the four lower Snake River dams.
Regarding the FSWG comment: the co-lead agencies are currently in discussions with federal agencies, states, and Tribes on the structure of this forum. While the intent is to keep the spirit of the FSWG, there will be some modifications to the Draft EIS in this area based on our current discussions.