bluefish had 45 days to prepare the following comment
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 18.104.22.168 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:
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 and Carbon Sequestration).
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"!
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 22.214.171.124 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 126.96.36.199, Methodology, and Section 188.8.131.52, Potential Replacement Resources and Associated Costs for MO3 specifically in the Draft EIS).
bluefish counter response:
Thanks to the Federal respondents for providing further detail of this CRSO excerpt.
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 184.108.40.206, 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 220.127.116.11, 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.
Hilarious -- bluefish counter response:
The Federal response that "it is not clear if this study was modeled using the GENESYS model" is astounding. How could an $80-million NEPA study be so ignorant, and too lazy to place a quick phone call to the NW Council for clarification and confirmation?
The Seventh Power Plan's Chapter 11 tells it like it is, quite plainly: GENESYS is the model that was used. Of course it was.
Seventh Power Plan Chapter 11 - System Needs Assessment: KEY FINDINGS (page 11-3)
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.
bluefish counter response:
Replacing hydropower from the Lower Snake River dams, by reducing exports, is not my suggestion. It is a fact and can be found in the Seventh Power Plan.
This information was clearly presented in the bluefish.org comments to to the Draft CRSO. The Federal respondents have suggested this is an idea put forth, solely by bluefish.org, which is obviously inaccurate and another example of misleading information in this illegitimate NEPA document.
From the Draft version of the Seventh Power Plan - Figure 3-14 Average Annual Net Regional Exports for Least Cost Resource Strategies (page 3-29)
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 18.104.22.168, 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:
Meanwhile, Multiple Objective 4 which lies at the core of the CRSO's Preferred Alternative (PA), has a Loss of Load Probability (LOLP) of 30%. Thirty percent!
Appendix H Chapter 2 - Power Supply and Replacement Resources (page H-2-3)
With MO4 -- the multi-objective that lies at the core of the CRSO Preferred Alternative (PA) -- Flex Spill was added to mitigate for the great expense of reducing MO4's LOLP to 6.4%. Since the CRSO process did not provide an analysis for us to consider, one is left to wonder what a Flex Spill to 120% TDG might look like alongside MO3.
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:
The primary difference of the two, is that the Council's analysis looked at the equivalanent of removing one Lower Snake River dam every three years over ten years (see bluefish response above, Figure 3-14). The Council's analysis also looked at an "Unplanned Loss of a Major non-Greenhouse Gas Emitting Resource" with an eye to what might happen if the region's sole nuclear power plant (1000 aMW) was suddenly brought off line. This "Unplanned Loss" scenario is quite similar to the CRSO MO3's analysis removing all four Lower Snake River dams (980 aMW) over two consecutive years,
A seconday difference, noted by the CRSO narrative, is that the Council's analysis did not consider the fast ramping capabilities of the LSR dams. The CRSO's "Conventional Resource Replacement Portfolio" for MO3 employs combined cycle combustion turbines, so this difference is relatively mute.
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. Alternately, 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)
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 22.214.171.124, Methodology, and Section 126.96.36.199, 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 188.8.131.52 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 184.108.40.206, 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)
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: "13,000 acres of arid lands along the lower Snake River", "1500 acres of wetland and riparian species along the exposed shoreline", and "155 acres of wetlands downstream of Ice Harbor").
Moreover, the exponential growth, of an annual supply of marine-derived nutrients to Idaho's forests, will easily overcome the static amount of "scrub-shrub", "scattered" in "small" places throughout the 1/4 square mile (160 acres) of 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 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.
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 220.127.116.11 in the Draft EIS discusses the change in loads and impacts to reliability in relation to climate change.
Sad -- bluefish counter response:
Sad that the co-lead agencies primary concern of Climate Change is the effect it has on their power system's reliability, especially when all these LOLP increases are easily addressed by implementing Flex Spill, as indicated in the CRSO's Preferred Alternative.
Super sad that the co-lead agencies show little regard, for the effects of Climate Change, on Idaho's critically endangered salmon, and the 137 other species that rely on salmon as their primary (or principle) food source species.
Moreover, the Federal Respondents have chosen to ignore, and set aside analysis of, the bluefish public comment suggestion (see Carbon Sequestration public comment and bluefish mathematics for Orcas Task Force's Question 17) that recovery of Idaho's Salmon will increase the carbon sequestration potential of Idaho's forests.
Incredulously, the Federal Respondents would have us believe that 160 acres is larger than 14,500 acres.