bluefish had 45 days to prepare the following comment
The comment is correct that, in Region C under the MO3 alternative, the analysis concludes that pumps are unable to deliver water to an estimated 48,000 acres. This EIS discusses engineering solutions (pipeline extensions for example) in Section 3.12.3 Environmental Consequences.
(bluefish notes: Section 3.12.3 DOES NOT discuss pipeline extensions, nor any other "engineering solution".)
The report which this (circa 1999) EIS draws upon as discussed, concluded that modifying the existing pump system was cost prohibitive. This report remains the most current information on these impacts. There is a physical limitation to delivering water to these lands in the absence of the dams. Breach of the dams has the potential to drop surface and groundwater levels up to 100 feet and it is not possible from an engineering or cost standpoint to replace the delivery mechanisms. Please see Section 3.12 and Appendix N for additional information.
Out-Dated -- bluefish counter response:
Why is this NEPA process insisting that a twenty-year old NEPA document is the "most current information"?
Not enough time
"To determine the economically justified alternative by conducting an economic cost benefit analysis... related to water supply would be time consuming and cannot be completed within the EIS imposed schedule.".
-- Federal Response to Todd True, EarthJustice (Appendix T page T-631)
Need addtional information
"The potential for agricultural activities in the currently inundated area and associated effects would depend on multiple subjects for which information is not reasonably ascertainable, including the soil types, drainage conditions, topography, and water availability. Without this information, it is not feasible to determine if land can even be used for crops and, if so, for what type(s) of crops. Such an analysis would also need to consider additional information that is not available, such as the cost of land development (leveling, irrigation equipment, drainage infrastructure, pumps). To say that the inundated lands are suitable for crop production and that the agricultural benefit would outweigh the development costs is therefore speculative and not based on high quality information."
-- Federal Response to Todd True, EarthJustice, (Appendix T page T-680)
Why? Because sticking to old conclusions of negative socioeconomic effects relies upon old results for support.
The National Environmental Policy Act (NEPA) requires that all relevant, reasonable mitigation measures that could diminish the adverse impacts of the project be identified in the document, even if they are outside the jurisdiction of the lead agency or the cooperating agencies.
The inclusion of mitigation measures in Chapter 5 is not intended to indicate that the co-lead agencies, or the Federal government as a whole, has the authority to perform all of the measures listed. If the measures are outside the jurisdiction of the co-lead agencies, those measures will not be included in the Preferred Alternative or Record of Decision (ROD). Their inclusion in Chapter 5 serves to alert other agencies, officials, and the public who can implement the measures to the potential benefits of the measure. The mitigation requested, while identified in the Draft EIS, is not within the co-lead agencies' current authorities. The co-lead agencies do not have the authority to provide mitigation for the effects to private infrastructure such as irrigation pumps, wells, or private docks.
Even the State of Washington is Ignored
Jay Inslee, State of Washington, Office of the Governor
(Appendix T, page 1070)
"Regarding lower Snake River irrigation affected by lower Snake River dam breaching, Washington suggests including more information in the final EIS on the cost of replacing irrigation from the reservoir behind Ice Harbor Dam and/or compensating landowners for diminished value of dryland acreage or acreage that would require deeper wells. That is more realistic and desirable than simply assuming, as does the draft EIS, that irrigated agriculture in that area will simply vanish."
"The evaluation on the loss of irrigated acres in MO3 is incomplete. The dEIS states that all irrigated acres receiving water from the current pumps would no longer be irrigated (with condition) and would convert to dryland pasture (without condition). This may be true if the action agencies proceeded with only breaching the four Snake River dams with no mitigation plan in place, but it is far from a realistic action that would be taken.
"The dEIS does not provide any opportunities to evaluate actions that can be taken that are outside administrative authority, so the public is left with an unrealistcally dark picture of what MO3 may bring to farmers and irrigators who currently rely on a dammed Snake River system.
"This analysis also perpetuates the notion that it is either fish or farms in the Northwest, which could not be further from the truth.
"MO3 should have included an evaluation, even if out of the administrative scope, that showed the possibility of legislation to provide federal funds to modify irrigation systems, upgrade rail infrastructure, and mitigate for the loss of barging along the Snake River to allow the continuation of an extremely important economic and social sector of the Northwest."
"Irrigation impacts under MO3 vastly overstated old and flawed assumptions brought forward into the DEIS. No loss in farm income with breaching. Corrected cost to modify irrigation systems is $20 million, instead of a farm value loss of $314 million. This is a fatal flaw of the DEIS and renders immediate breaching highly beneficial to the region.
. . .
"A farmland valuation analysis was used in 2002 and carried forth as a planning assumption in the 2020 DEIS. However, at the time this $291 concept and cost estimate was challenged as being incorrect, but was not changed given the time constraints and the belief by Walla Walla planners that even if it was of no cost, it would not change the overall economic analysis and benefit cost ratio in favor of keeping the dams.
. . .
"Rob Sampson's report, 'A brief review of the impacts to irrigated farmland from breaching the four dams on Lower Snake River' is attached. Also a link to prospective piece on agriculture in lower Snake Valley after breaching."
Ignored, were public comments to the CRSO pointing to "currently available information" from water supply engineer Rod Sampson that considers pipe extension as a "reasonable mitigation measure". Apparently, "extension agents in Washington and Oregon", for some unexplained reason, did not desire to consider pipe extensions (pun intended), costing less than $20 million in total.
With exception of MO3, the alternatives including the Preferred Alternative are not expected to have an effect on water delivery in the Columbia River Basin. MO3 could affect delivery of current water supply in Region C, and is expected to result in major effects to the Ice Harbor private, municipal, and industrial pumps located near Ice Harbor dam. As mentioned in Section 18.104.22.168, Water Supply, private and public entities could extend intake pumps, ground water wells, or other infrastructure to offset any potential effect as a result of MO3. The co-lead agencies would not prescribe how those entities would implement their actions.
Self-Contradictory -- bluefish counter response:
Which is it? Are irrigation pumps "technically feasible" or "not possible from an engineering standpoint"? They cannot be both.
"The co-lead agencies reviewed the 2002 study and came to similar conclusions as the study. First, the conclusions reached about the infeasibility to deepen wells or extend individual pumps were based on engineering and hydrogeologic facts that had not changed since 2002. Second, though building a new pump structure and modifying existing irrigation infrastructure was considered to be technically feasible, it was not economically feasible; this conclusion was based on high-quality information."
-- Federal Response to Todd True, EarthJustice (Appendix T page T-837)
Not possible from an engineering standpoint
"There is a physical limitation to delivering water to these lands in the absence of the dams. Breach of the dams has the potential to drop surface and groundwater levels up to 100 feet and it is not possible from an engineering or cost standpoint to replace the delivery mechanisms, nor do the co-lead agencies have the authority to do so currently."
-- Federal Response to AKU Enterprises, LLC, (Appendix T, page T-627)
Which is it? Are irrigation pumps "cost prohibitive" or up to "private and public entities"?
"Engineering solutions, such as pipeline extensions and/or modifying existing pump system would be cost prohibitive."
-- Federal Response to Northwest Requirements Utilities, (Appendix T page T-933)
Others Could Do It
"The mitigation requested, while identified in the Draft EIS, is not within the co-lead agencies' current authorities. The co-lead agencies do not have the authority to provide mitigation for the effects to private infrastructure such as irrigation pumps, wells, or private docks. However, private and public entities could extend intake pumps, groundwater wells, or other infrastructure."
-- Federal Response to Oregon Department of Justice, (Appendix T page T-941)
Also worth noting, is that the whole of MO3, increases irrigation water supply to the region. Mistakenly, the CRSO accounting of MO3, assumes an overall decreases, somehow forgetting to include the increases elsewhere.
* Unable to Deliver
"You are correct that as part of MO3 there are operations to provide additional water supply at Hungry Horse, Grand Coulee, and for the Chief Joseph Dam project. Socioeconomic effects resulting from the use of this water after withdrawal were not evaluated, because the details of how and where this water would be used is subject to as-yet undefined future Federal and other actions. As a result, additional NEPA analysis would be needed prior to implementing any such action.
The MO3 analysis on existing water supply concludes that in Region C that pumps are unable to deliver water to estimated at 48,000 acres."
-- Federal Response to bluefish (Appendix T page T-837)