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                      

Greenhouse Gases, comment by bluefish.org, response by CRSO.info

Federal Response:
The findings of the EIS emissions analysis for Multiple Objective Alternative 3 are consistent with this comment. The EIS does compare regional emissions to national levels in the Affected Environment discussion, finding relatively low levels of power sector emissions in the Northwest compared to national averages (see Draft EIS 3.8.2.2 pages 3-945 to 3-978). However, despite being small on a national scale, the increase in CO2 emissions that are anticipated under MO3 (even assuming reliance on renewable resources to replace power from the four lower Snake River Dams), makes regional emissions policies and goals more difficult to achieve.

bluefish counter response:
See Carbon Sequestration on left sidebar for details.


Greenhouse Gases, comment by bluefish.org, response by CRSO.info
Federal Response:
The findings of the emissions analysis for MO3 are consistent with this comment. The EIS acknowledges that the renewable power resource portfolio may better reflect future trends (see EIS Section 3.8.3.1 page 3-987 in the Draft EIS).

In addition, regarding the potential benefits of future clean energy technology, the EIS acknowledges that the energy sector is constantly undergoing transformation and that technological improvements will likely bring other options.

To avoid speculation, the EIS analysis focuses on primary technologies identified by the Northwest Power and Conservation Council in their Seventh Power Plan (page 13-5) that are deemed proven, commercially available, and deployable on a large enough scale in the Northwest. (The basis for developing the power portfolios may be found in Section 3.7.3.1, Methodology, and Section 3.7.3.5, Potential Replacement Resources and Associated Costs for MO3 specifically in the Draft EIS).

bluefish counter response:

Thanks for providing further detail of this CRSO excerpt.


Greenhouse Gases, comment by bluefish.org, response by CRSO.info
Federal Response:
The comment suggests the EIS should have ignored information relevant to environmental concerns and bearing on the proposed action or its impacts, which is inconsistent with the co-lead agencies obligations under NEPA. See 40 C.F.R. 1502.9. As described in a previous response, the analytical approach used in this EIS which included more recent information - provides a more complete picture of the Multiple Objective (MO) Alternatives impacts on regional reliability and costs and is consistent with what NEPA requires.

The comment incorrectly suggests that MO3 only considered a natural gas resource replacement portfolio. The EIS considered a range of resource portfolios to replace the power output of the four lower Snake River dams. That range is reflected in two portfolios used to outline the potential resource options: a least-cost conventional portfolio (natural gas) and a zero-carbon portfolio (primarily solar). See Section 3.7.3.5, at pages 3-904-910 in the draft EIS. These portfolios represent a range of potential portfolios that could be used to return the regional power system to the reliability level of the No Action Alternative.

The commenter is presumably referring to the Council's removal study in mentioning the Council's Least-Cost Conventional Portfolio. That analysis is not comparable to the analysis performed in the EIS. The Council's study removed a generic 1000 aMW carbon-free resource in the 7th Power Plan, rather than removing the four lower Snake River dams, with their particular generation, shape, and characteristics. Further, it is not clear if this study was modeled using the GENESYS model, which is the model relied upon in the EIS. See Section 3.7.3.1, Step 2: Analyze Effects on Power System Reliability at page 3-819 in the draft EIS. Further, the Council's study had an approximately 2,000 aMW lower load forecast than the forecast used in the EIS, which is more current.

The comment suggests that the lost capability from the four lower Snake River dams could be supplied through reduced exports of electricity from Bonneville. This is incorrect. The four lower Snake River dams are not used exclusively to support power sales out of the region. Rather, Bonneville sells power from the Federal projects on a coordinated, system basis. Loss of the capability from the four lower Snake River dams would increase the regions risk of a blackout. Under average water conditions and 80-year water data, the four lower Snake River dams produce between 460 aMW to upwards of 1400 aMW of power during the winter months of December through February, which are typically the most energy intensive months for Bonneville. See Section 3.7.3.5, Changes in Power Generation, Table 3-159 in the draft EIS. Without replacing the power from the four lower Snake River dams, the Loss of Load Probability (i.e., risk of blackouts) for the region would more than double to 14 percent, which is equivalent to one blackout every seven years. See draft EIS, Section 3.7, page 3-903 and Appendix H-Power and Transmission at Table 2-1.

bluefish counter response: Fed response to its own document here


Greenhouse Gases, comment by bluefish.org, response by CRSO.info
Federal Response:
There are notable differences between the Northwest Power and Conservation Council's (Council) analysis of Planned Loss of a Major non-GHG Emitting Resource and the Multiple Objective Alternative 3 analysis in the EIS that included breaching of the four lower Snake River dams.

bluefish counter response: Details of this difference is below at next "Click for Response".

Greenhouse Gases, comment by bluefish.org, response by CRSO.info
 

Greenhouse Gases, comment by bluefish.org, response by CRSO.info

Federal Response:
The Council modeled the loss of generic non-GHG emitting resources. If the Council had analyzed the timed removal of the four lower Snake River dams, resource strategies would have had to also account for the 1,700 to 2,000 megawatts of sustained peaking loss and not just the loss of 1,000 average megawatts of energy generating capability. This would have likely increased the magnitude of the requirement for replacement resources. (Council 7th Power Plan, page 3-13). Specifically, In the Planned Loss of a Major Resource scenario, it was assumed that a total of 1,000 megawatts nameplate capacity producing 855 average megawatts of energy resources that do not emit carbon dioxide were retired by 2030. (Council 7th Power Plan, page 15-37). This is a resource that is not only slightly smaller in energy, but significantly smaller in capacity than the combination of the four lower Snake River dams. In the EIS LOLP analysis, surplus/export loads are not included. Even without this load, the LOLP for MO3 at 14 percent was more than double that of the No Action Alternative at 6.6 percent and nearly three times the Council's target of 5 percent. The Council used their Resource Portfolio Model for the 7th Power Plan analysis of this study. The EIS used the Council's GENESYS model, Council data (including that of the 2022 Resource Adequacy Assessment), and the Council's resource adequacy metric and standard and only proposed replacement resource portfolios if that standard was not met.

bluefish counter response: The hydrological conditions have not changed, so the appropriate Resource Replacement Portfolio has not changed: 680 MW of natural gas combined cycle combustion turbine is an appropriate replacement in both models. Equally well, an increase on Market Reliance -- utilizing the day ahead markets, hour ahead, half-hour and 15 minute markets -- for 500 MW is also an appropriate replacment for Remove Snake River Embankments.

Chapter 3 - Power System Flexibility and Reliability (page H-3-6)
CRSO excerpt


Greenhouse Gases, comment by bluefish.org, response by CRSO.info
Federal Response:
The findings of the emissions analysis for Multiple Objective Alternative 3 (MO3) are consistent with this comment. The EIS analyzed two resource portfolios to replace the hydropower generation of the four lower Snake River dams, one that included natural gas and one that included all renewable resources, both of which maintain regional power system reliability. The EIS does find an increase in fossil fuel generation even assuming all renewable replacement resources are built to meet demand. This increase results when renewables are not generating power because some level of fossil fuel generation would be required to maintain reliability in the electric system. Given that policy and legislative decisions in Oregon and Washington are targeting large reductions in greenhouse gas emissions, even a 2.7 percent increase in CO2 emissions, even with the renewable replacement resources, makes these goals more difficult to achieve. The basis for developing both of these power portfolios may be found in Section 3.7.3.1, Methodology, and Section 3.7.3.5, Potential Replacement Resources and Associated Costs for MO3 specifically of the Draft EIS.

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.

bluefish counter response: Fed response to its own document here


Greenhouse Gases, comment by bluefish.org, response by CRSO.info
Federal Response:
The comments in this statement regarding changes in power generation due to climate change are consistent with discussions in Section 4.2.5, Power Generation and Transmissions, and Appendix J, Hydropower in the Draft EIS. Specifically, the EIS examined four future climate scenarios to assess potential changes in hydrology, and thus, how climate change may impact generation. Section 4.2.5.2 in the Draft EIS discusses the change in loads and impacts to reliability in relation to climate change.

bluefish counter response: Fed response to its own document here