Columbia River System Operations
Comment & Response

Cover Letter
Carbon Sequestration
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

bluefish had 45 days to prepare the following comment                      

A reliable power supply, comment by, response by

Federal Response:
The four lower Snake River projects provide over 2,000 MW of sustained peaking capacity when there is sufficient flexibility in the forebay operating range. See Section, Lower Snake River Full Replacement, pages 3-905-907, Table 3-160 in the Draft EIS. Outside the fish passage season, the projects have 3-5 feet of operating range. The dams provide important ramping capability the ability to quickly generate energy to match spikes in energy usage with over 2,000 to 2,300 MW of capability in certain months of the year. See draft EIS, Section, Lower Snake River Full Replacement at pages 3-905-907 and Table 3-160.
Chapter 3 - Sustained Peaking Capacity is 6 peak hours per weekday for a month. (page 3-835)
Historical Sustained Ramping of Lower Snake River dams according to the Columbia River System Operations analysis.

Within the fish-passage season, the four lower Snake River projects are restricted in their operating range. (1-foot range in the No Action Alternative expanded to 1.5 feet under the Preferred Alternative.) The projects can increase generation for a brief period (1 to a few hours if flows are not so low that the project is restricted to minimum generation). The travel time for flows to reach the next project is about an hour. So if Lower Granite increases generation and outflow in one hour, then Little Goose would have higher inflows the next hour. Consequently, the projects are typically able to provide some reserves even with a restricted forebay range, but not the full amount they provide in the fall and winter.

bluefish counter response:
Because the Lower Snake River (LSR) dams are restricted by the river flows, as described in the Federal Resonse above, combined cycle combustion turbines (CCCT) are a better resource for Balancing and for managing Operating Reserves. As a Resource Replacement Portfolio, CCCT is again the best fit for an "adequate, economic and reliable power.

Notably, the CRSO accounting makes no mention of the improvement offered by CCCT in managing Balancing and Operating Reserves.

Chapter 3 - Integration Services (page 3-864)
Balancing and Operating Reserves costs of replacement resources of the various Multiple Objectives of the Columbia River System Operations analysis
The possible downside to CCCT, is that natural gas (extraction and combustion) contributes to global warming gasses in the Earth's atmosphere.

On the flip side, a restored Snake River Salmon and Steelhead population, would bring subtantial quantities of marine-derived nutrients to Idaho's forests, leading to greater forest health and forest growth that will more than compensate for the negative effect of CCCT replacing LSR dams. (See Carbon Sequestration for more on this interesting topic).

A reliable power supply, comment by, response by

Federal Response:
Bonneville staff have the expertise to run the GENESYS model and describe its outputs for the CRSO EIS. Bonneville has worked with the Northwest Power and Conservation Council (Council) on developing the model for many years. For areas of the CRSO EIS power analysis where Bonneville staff did not have expertise, Bonneville hired consultants; however for the GENESYS model, this expertise is housed within Bonneville. The Council received periodic updates on the CRSO EIS process similar to the general public. Since it is not a Federal, Tribal, state or local agency, the Council could not serve as a cooperating agency under NEPA. The Council received the Draft EIS when it was available for public review.

The Councils re-developed GENESYS is still in the testing phase, and was not available for use in the CRSO EIS.

bluefish counter response:
Without a doubt, the Northwest Power & Planning Council (Council) "re-developed" GENESYS model is the very best way to proceed and could have been used for this CRSO analysis. Unwavering, the CRSO respondent's insist that the "re-developed" version was "still in the testing phase" at the beginning of the CRSO process, and therefore it was not employed. That beginning was four years ago!

Meanwhile, the Council staff has informed bluefish that the verification testing, that had been occuring, during the start of the CRSO process, was already at a much finer time scale than the older GENESYS (hourly vs. monthly). Even while that re-developed GENESYS was in a "testing phase", verifying hourly and daily results with real-world results, it's modelling was already much better than the old GENESYS, which takes the 80-year monthly water record as input.

Moreover, that "testing phase" has long since come and gone. By using the outdated GENESYS, the NEPA process has failed to use the "most currently available information necessary for an informed response" [Enivironmental Law Reporter].

Remarkably, the Council has not weighed in on the CRSO process, nor will their upcoming Eighth Power Plan consider a LSR dam breach scenario, even though their Sixth and Seventh Power Plan did.

The Redeveloped GENESYS could have been run for CRSO long ago, and of course it could be used now. For the Final EIS, or for the upcoming Eighth Power Plan, is the most currently available information desirable?

The Council's draft version of their Seventh Power Plan (and curiously missing from the Final version of the Seventh Power Plan) found that a scenario, closely resembling the CRSO's Remove Snake River Embankments, would be replaced by a "Least Cost Resource Portfolio" simply by reducing exports out of the Northwest region. Existing natural gas (CCCT) would provide the backup power to the grid, when electricity demand and market prices dictate.

What are these government agencies (CRSO, BPA, USACE, NW Council) trying to hide? Are they troubled by the findings of the Draft Seventh Power Plan, that is missing from the Final version? The Council's silence, especially in the face of my repeated insistence, during their monthly public comments, is well worth noting.

The comment accurately cites to the EIS, which describes the need for additional resources to maintain regional reliability at the No Action Alternative level.

While the EIS use of this proxy is an accurate reflection of true missing costs under this scenario, the co-lead agencies, in response to public comments, updated the amount of the solar plus batteries replacement under the MO3 scenario framework in the analysis in the Final EIS.