bluefish had 45 days to prepare the following comment
In 2018, 72 percent of overall freight volume on the Lower Snake system traveled downriver, the majority of which (87 percent) was wheat and barley. As discussed in Section 18.104.22.168 of the Draft EIS, 28 percent of overall freight traveled upriver. In 2018, 25 percent of overall freight on the Lower Snake River was petroleum products that terminated below Ice Harbor Dam. These shipments do not utilize the Snake River locks and would not be directly affected by dam removal under MO3. This was unclear in some instances in the Draft EIS, and has been corrected and clarified in Section 3.10 and Appendix L.
Other commodities that utilized the Snake River system included pulp and paper products (4 percent) as well as chemicals and iron/steel commodities (8.5 percent), some of which also terminate below Ice Harbor Dam. To the extent that these shipments utilize the Snake River locks and dams, they would be affected under MO3 by increased transportation costs. These potential effects are discussed qualitatively in Section 22.214.171.124.
bluefish counter response:
Without a doubt, the loss of subsidized shipping is the biggest negative impact following Remove Snake River Embankments.
Aside from this one, all of the other CRSO-defined "negative impacts" can be mitigated, leaving Navigation as the lone "adverse effect" of Multiple Objective 3 (MO3). Electric rates go down, farmers continue to irrigate via extended pipes, and salmon populations will become de-listed from Endangered Species Act protection. (Did I leave out the cruise industry? Perhaps, but they will ply the impounded Columbia River waters unaffected).
The only negative of Remove Snake River Embankments, is that some Northwest wheat shippers will have to pay their fair share of the cost -- as all other wheat growers do throughout the West -- when the federal sponsored channel dredging, 24/7/330 availability of lockages, operations & maintenance, is lost. Competition will be restored, where it has been missing for decades. Is not competition, a basic principle of a free market economy?
Executive Summary: Transportation (page 32)
Major adverse effects would be anticipated under MO3. The lower Snake River shallow draft navigation channel would no longer be available, eliminating commercial navigation to multiple port facilities on the lower Snake River, including the four primary commercial navigation ports--the Port of Lewiston, the Port of Clarkston, the Port of Whitman County (Wilma, Almota, Central Ferry), and the Port of Garfield. As a result, the cost to transport goods to market would increase. For example, the cost to transport wheat, which accounted for 87% of the downbound tonnage on the lower Snake River in 2018, is estimated to increase by $0.07 - $0.24/bushel.
Section 3.10 of the Draft EIS provides an evaluation of the Columbia Snake River Navigation System, assessing its relative efficiency, low costs for shippers, safety considerations, low air emissions relative to other transportation modes, potential regional economic, and other social effects that could occur under MO3. Section 3.10 of the EIS recognizes that access to barge transportation is the most cost effective means of accessing export markets for many grain producers in the Pacific Northwest currently and removing that option would increase transportation costs for grain producers. The EIS evaluates potential effects on farmers associated with increased transportation costs under MO3 in Section 126.96.36.199.
The EIS finds that under MO3, average transportation costs for wheat farmers would increase 10 to 33 percent, but that individual farmers could experience increases that are doubled. The cost increases to specific shippers would depend upon location and would vary throughout the region, depending on transportation options at each location. Generally, those grain shippers that are the farthest from alternate shipping locations (shuttle rail facilities or river ports on the Columbia River) would be the most adversely impacted. The EIS recognizes that there is no guarantee wheat grown in the Northwest would be competitive now or in the future because there are many factors that influence international commodity markets (e.g., trade agreements, the U.S. dollar, global supply, etc.). However, the analysis finds that the cost to transport wheat to market would continue to be lower than costs paid by other wheat growers in the United States (e.g., the Dakotas and Midwest).
bluefish counter response:
Let's hear that again:
"The cost to transport wheat to market would continue to be lower than costs paid by other wheat growers in the United States (e.g. the Dakotas and Midwest).
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. See 40 C.F.R. 1502.16(h) and 1505.2(c); 46 Fed. Reg. 18026. The inclusion of mitigation measures in this 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. 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 is not within the co-lead agencies' current authorities. The co-lead agencies do not have the authority to provide payments or provide infrastructure for rail lines.
Self-Contradictory -- bluefish counter response:
Although it is promised that mitigation measures are included in Chapter 5, none were described. For the CRSO respondents, impacts to Navigation and Transportation under Remove Snake River Embankments "could not be feasibly mitigated".
Navigation and Transportation (Chapter 5 secion 188.8.131.52)
While "NEPA requires that all relevant, reasonable mitigation measures that could diminish the adverse impacts of the project be identified in the document", none are identified in this NEPA document. The suggestion is made, however, that other entities could mitigate these impacts.
The Great Northwest Railroad, owned by WATCO, is a short-line railroad that runs along the Snake River from Lewiston, ID to Ayer Junction, WA. Research completed for the EIS suggests that elevator to river port movements via short line rail are not currently occurring because in order for them to ship grain to river terminals on the Columbia, they must operate on part of Union Pacific's rail line and WATCO's operating agreement with Union Pacific does not allow for these shipments.
The commenter is correct that the effect of including this assumption and allowing movements on these short lines during a dam breach scenario would be to somewhat reduce the anticipated increases in shipping costs to shippers. A statement has been added to Section 184.108.40.206 to this effect, along with a reference to Appendix L that provides additional discussion of the impacts of modifying this assumption on quantified costs to shippers.
bluefish counter response:
In response to comments, the Final EIS has appended Annex B to Appendix L. Therein it is admitted that while excluded from the final CRSO analysis, the short rail line for grain shipment was included in an earlier run of the Transportation Optimization Model (TOM).
With Annex A as a correction, remove the big red line from the map above:
That grain would move on the short-line that parallels the river.
To reiterate, 1.3 millon tons (80.6 million bushels at 60 bushels per ton) of Wheat & Barley would move along the current rail line that parallels the Lower Snake River under the TOM model Scenario 3, where rail rates increase by 50 percent. This sizable result was not included outside of Annex A, and it did not percolate up to the Executive Summary or the Final CRSO Chapters (see Figure 3-11 unchanged above).