Columbia River System Operations
Comment & Response
of bluefish.org

Cover Letter
----------------------------
Conservation
Coal
Carbon Sequestration
----------------------------
Irrigation
Barging Wheat
Barging Salmon and Steelhead
----------------------------
Survival of Salmon and Steelhead
Juvenile Survival through Hydrosystem
     Water Temperature
     Predation by Birds
Ocean Conditions
----------------------------
Greenhouse Gases
An Adequate Power Supply
An Economic Power Supply
A Reliable Power Supply
An Efficient Power Supply
----------------------------
Potatoes, Apples & Grapes
Petroleum to Pasco
----------------------------
Orca and Idaho's Chinook
Flex Spill to 125% TDG
Breach Lower Snake River Embankments
----------------------------
Social Effects
Cultural Resources
Environmental Justice
----------------------------
Conclusion

bluefish had 45 days to prepare the following comment                      

Potatoes, Apples and Grapes, comment by bluefish.org, response by CRSO.info

Federal Response:
Potatoes, Apples & Grapes- [Text contains figures that do not transfer to database.] Errors in moving data from Table 4-14 to 4-15: Alfalfa 175.20/ton to $201.20/ton, and Corn $4.56/bushel to $4.65/bushel = $0.09 /bushel, which seems small at first glance. Notably, CRSO Draft differs from 2002 Report by not removing 21% in calculations. Revising Table 4-15 w/o Apples & Grapes because they will continue to be irrigated. $315.6 - $230 (apples) - $16.2 (grapes) = $69 million Gross Value of Irrigated Crops.

Potatoes, Apples and Grapes, comment by bluefish.org, response by CRSO.info

Federal Response:
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. Please see Section 3.12 and Appendix N for additional information.

bluefish counter response:
Even though this "additional supply of 1.15 million acre-feet" is recognized -- and allows MO3 to meet the objective of Provide Water Supply -- by leaving it's socio-economic effect out of the analysis, the potential loss of irrigation near Ice Harbor dam turns the socio-economic effect of MO3 to a negative. Oddly, this "additional supply" is include on the one hand, but left out of the other.
Executive Summary excerpt: MO3 would meet the objectives to Maximize Adaptable Water Management and Provide Water Supply in most areas. ... However, some areas would be subject to major adverse effects. ... Under MO3, pumps that supply this water would no longer be operational once the dams are removed and nearby groundwater elevations drop up to 100 feet in some areas. ... Executive Summary (page 32)
MO3 would meet the objectives to Maximize Adaptable Water Management and Provide Water Supply in most areas. Along with additional supply of 1.15 million acre-feet from Lake Roosevelt at Grand Coulee, water supply in many areas is not affected by the dam breaching measures. However, some areas would be subject to major adverse effects. Entities pump water for irrigation at many locations in and near the reservoir pools of the four lower Snake River dams. This water is diverted under natural or live flow water rights issued by the states.

Under MO3, pumps that supply this water would no longer be operational once the dams are removed and nearby groundwater elevations drop up to 100 feet in some areas. Assuming 48,000 acres would no longer be irrigated as a result (primarily near Ice Harbor and Lower Monumental dams), the lost social welfare effect under MO3 is $17 million (annual equivalent). The regional economic effects stemming from a loss in crop production are $232 million in labor income and $460 million in output (sales) annually. This reduction in activity also results in a loss of 4,800 jobs (5.9% of the total economy in the Ice Harbor and Lower Monumental socioeconomic analysis area). Further information can be found in Section 3.12.

Even with the Governor of Washington asking for input on how to avoid this loss of corp production valued at $460 million in lost annual sales, the CRSO ignores the request. Purposefully, the CRSO avoids the topic and relies upon an outdated NEPA document. Why not tell us the truth of the matter, that this crop production need not be lost?
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."

Brought to light in the Irrigation page of this CRSO web series, water supply engineer Rod Sampson has us seriously consider pipe extension, costing less than $20 million in total. Most certainly, this is a reasonable and cost-effective means of mitigation.

Water supply engineer Rod Sampson estimates that continuing irrigation from Ice Harbor pool will cost approximately $20 million.
One also wonders why the CRSO so quickly dismisses the interests of the region's Indigenous People.
Executive Summary excerpt: Many tribes have commented that the economic impacts of implementing this (MO3) alternative must be viewed in the context of the ongoing and disproportionate social, cultural, and socioeconomic effects to Indian tribes and tribal communities from present and cumulative effects of the current System. They note that these negative effects, along with impairment of Indian treaty-reserved rights, would be reduced under MO3. Executive Summary (page 29)
Many tribes have commented that the economic impacts of implementing this (MO3) alternative must be viewed in the context of the ongoing and disproportionate social, cultural, and socioeconomic effects to Indian tribes and tribal communities from present and cumulative effects of the current System. They note that these negative effects, along with impairment of Indian treaty-reserved rights, would be reduced under MO3.
Once irrigation pipes are extended and sufficient horsepower is added to the pumps of fifteen farms, their crop land will not "simply vanish" with the implementation of Remove Snake River Embankments. This may very well be why, this great and simple idea was set aside. No longer then, will the CRSO be able to tell us that "MO3 has the highest adverse effect... especially social and economic effects".
Executive Summary excerpt: Fish modeling for MO3 predicts the highest benefits among all of the alternatives for ESA-listed salmon in the Snake River and could, in the long-term, provide additional riverine type recreational opportunities. However, breaching the four lower Snake River dams would not allow the Corps to operate and maintain the dams for their other congressionally authorized purposes of navigation, hydropower, recreation, and water supply. MO3 has the highest adverse effects to other resources, especially social and economic effects. Executive Summary (page 29)
Fish modeling for MO3 predicts the highest benefits among all of the alternatives for ESA-listed salmon in the Snake River and could, in the long-term, provide additional riverine type recreational opportunities. However, breaching the four lower Snake River dams would not allow the Corps to operate and maintain the dams for their other congressionally authorized purposes of navigation, hydropower, recreation, and water supply. MO3 has the highest adverse effects to other resources, especially social and economic effects.