Federal Response:
Water temperatures under MO3, which includes breaching the four Snake River dams, indicates that nighttime summer water temperatures, as well as fall water temperatures, would be cooler than No Action conditions in the Snake River. However, even with the lower Snake River dams breached, maximum summer water temperatures would exceed state water quality standards (20C = 68F) at times, especially during hot weather events. The models showed minor changes in the Columbia River under this alternative.

Willful Ignorance -- bluefish counter response:

Wow! Quite the way to downplay the water temperature reality revealed by the CRSO Water Quality Workgroup,

Emphasizing that some late afternoon temperatures, during the hottest time of the year on a free-flowing river, will bring water temperatures above water quality standards "at times", really misses the point of the discussion.

With the Lower Snake River dams in place, the reservoirs are too warm a lot of the time. The problem does not go away by ignoring it.

Federal Response:
The co-lead agencies agree with the commenter's concern relating to water temperatures in the rivers and that is why the agencies have used current high quality information and resources available to model and evaluate impacts from operations described in each of the alternatives on water temperatures. Historically, water temperatures in the lower Snake River were warm (USGS 1960, 1961, 1964; Corps 2002a).

Hilarious -- bluefish counter response:

Suggesting that 60 year old data and the previous NEPA EIS from 20 years ago is "current information" is hilarious, if not preposterous.

Many studies and analyses have been completed regarding this important topic (e.g. EPA's Columbia River Cold Water Refuges Plan, excerpts and Figure 4 far below), but the CRSO EIS either ignores them entirely or deftly brushes them aside.

Appendix D, Annex A 1.3.9 Comparison to Other Model Predictions (page H-3-6)

With an eye on "Ice Harbor Tailwater Temperature" graph below, let's read that last sentence again, while noticing the emphasis on uncertainty:

Appendix D, Annex A 1.3.9 Comparison to Other Model Predictions (page H-3-6)

. . . due to the uncertainties in the simulation model, the authors of the Corps (2002 EIS) study concluded that the results showed only small differences between the current and without dam river temperature regimes.

In other words, rather than attempting to reduce uncertainties as much as possible, as the recent CRSO Water Quality Workgroup has admirably done (see "Ice Harbor Tailwater Temperature" graph below), the previous 2002 EIS concluded that due to large "uncertainties", Remove Lower Snake River Embankments would result in "only small differences between the current and without dam river temperature regimes."

For Snake River Steelhead and the SRKW important Fall-run Chinook, the autumnal difference between these two temperature regimes, spells life or death.

Has there been any interest in resolving these "uncertainties" over the intervening years, or is "uncertainty" something that the CRSO is aiming to sell to us as "current, high quality information"? Step right up, get your 1999 uncertain science here.

Appendix D - Annex A - Lower Snake River MO3 Model Development (page A-2-4)

The CRSO EIS narrative discounts the benefits of a free-flowing river. An honest EIS, on the other hand, would present informative graphics (e.g. "Ice Harbor Tailwater Temperatures" graph above) so that decision makers might best be prepared to make well-informed decisions.

A picture could replace a thousand confused sentences, but quite apparenty, that is not their intention.

Federal Response:
Observed historic water temperatures show that average monthly water temperatures during July and August, in the 1950s, averaged 7 to 8 degrees Fahrenheit higher than today's conditions, while maximum daily differences were 10 to 12 degrees Fahrenheit higher.

The differences observed in the lower Snake River today, as compared to historical conditions, are a result of the middle and upper Snake River reservoirs combined with the influence from Dworshak Dam operations. The study results indicate that the operations of the CRS do impact water temperature, but the CRS has limited ability to reduce temperatures in the lower Snake and Columbia rivers outside of Dworshak operations.

bluefish counter response:

Historic temperature readings were taken near the shoreline, "recorded in 1958... at the Yacht Club" and "approximately 24 miles downstream from the current location of Lower Granite Dam (USGS 1960, 1961, 1964)". Consequently, these readings may not be representative of the mid-stream river water temperatures.

Conspicuously, the Federal Response does not display, or otherwise direct the reader to, Figure 6-29 (from Appendix D, below), revealing a cool Lower Snake River following Remove Lower Snake Embankments. Instead, CRSO respondents hide an informative graphic, and ask that we trust them, and their long-winded words.

Appendix D - Lower Granite Dam and Reservoir (page D-6-37)

Regionally high air and water temperatures result in water quality standard exceedances and are beyond the ability of the CRS to cool. The co-lead agencies agree life history patterns are driven significantly by the high air temperature in the summer. However, although the cooler water slips beneath the warm Snake River water, it does provide benefits.

Telemetry studies with depth sensitive transmitters show that migrating adult salmon indeed migrated deeper in the Lower Granite reservoirs than the same fish has in the downstream reservoirs, and juvenile condition and health improved since temperature management began.

bluefish counter response:

Openly, the CRSO respondents acknowledge that "cooler water slips beneath the warm" but quickly set it aside when in conflicts with the story that they are trying to tell.

Unexplainably absent from the CRSO models, but included in EPA's Columbia River Cold Water Refuges Plan (Figure 4 below displays actual temperature readings), McNary Reservoir is covered by warm water from the Lower Snake River. Why do you suppose this was left out of the CRSO discussion?

The cool Columbia River slips under the
reservoir-warmed Snake River at their confluence

Columbia River Cold Water Refuges Plan, Appendix 1 (page 4)

The warm and cold waters mix going through Lower Granite Dam, although the surface waters do warm due to air temperatures and solar input.

Misleading -- bluefish counter response:

If some cold water was taken from below the thermocline of the temperature stratified reservoir, then "warm and cold waters (would) mix going through Lower Granite Dam". But the plain fact is, the cold water releases from Dworshak are largely trapped behind Lower Granite Dam. Cold water is denser than the warm water and in slow-moving, "slackwater" Lower Snake reservoirs thermal stratification is present.

Appendix D, Alternatives Evaluation for Water and Sediment Quality Impacts (page D-3-27)

Notice the skillful, subtle use of the double negative. The Lower Snake River (LSR) Reservoirs "do not thermally stratify to the extent that (700-foot deep) Dworshak Reservoir and other deep reservoirs do." Then follows some technical mumbo jumbo suggesting that LSR reservoirs do not stratify, followed by the confession; "However, vertical temperature gradients can exist and are more pronounced... now."

In another Chapter of Appendix D, the narrative is in direct opposition to a nearby graphic (Figure 6-26 below). But who is going to notice? A quick trusting glance at the graphic might miss the fact temperature differences are modeled to increase, not diminish, "as water travels the ~140 river miles down to the Ice Harbor Dam location."

Appendix D - Lower Snake River Reservoirs (page D-6-39)

Appendix D - Lower Snake River Dams and Reservoirs (page D-6-34)

Federal Response:
The effects of the No Action Alternative (Page 3-389) discusses the recent survival rates of Snake River sockeye salmon that range from 0% - 70% to Redfish Lake, the Sawtooth hatchery weir, or other locations. The conditions affecting survival are also discussed, with water temperatures receiving the most attention. This range of survivals in differing conditions under the No Action Alternative is the baseline to which the multiple objective alternatives are compared. In years such as 2015, with low flows and high air temperatures, survival would continue to be compromised under all alternatives.

The models showed minor changes in the Columbia River even under MO3 (the alternative with the dam breaching measure), indicating that the operations of the CRS dams have a limited ability to reduce temperatures on the lower Snake and the lower Columbia rivers.

Regarding white sturgeon, this language came from our workshop with fish managers to describe the interaction between high temperatures limiting metabolism coinciding with the abundance of salmon carcasses.

bluefish counter response:

Yes, that is exactly the point. "The CRS dams have limited ability to reduce temperatures" and that is yet another reason why Remove Snake River Embankments is such a great idea; it does "reduce temperatures" whereas leaving them in place, does not.

The slow moving, half-mile wide, solar absorbing slackwater reservoirs are adding heat to the Columbia River System (CRS). The dams themselves, cannot solve the problem, but the removal of four uneconomic ones, will.

Curiously, the models of this EIS did not provide results for the reservoir into which the Lower Snake River drains (McNary pool), and where a "thermal block" was reported to have blocked the passage of both Snake River and upper Columbia River sockeye.

Other reports have documented this fact, but the CRSO EIS conveniently downplays the massive die-off of Sockeye during the summer of 2015. For example, while discussing sturgeon and the warm water tragedy of 2015, an abbreviated version of the Draft EIS appears in the Final EIS (see next response).

Federal Response:
Thank you for your comment; this entire comment is a direct quote from Chapter 3, page 430 (No Action Alternative) of the Draft EIS, although the commenter references page 493 (MO1). The co-lead agencies continue to support the material referenced in this comment.

Withdrawn -- bluefish counter response:

Oddly, the first paragraph -- "Mass mortality events... often coupled with sockeye mortality events" -- has mysteriously been removed after appearing in the Draft EIS.

Instead of informing the discussion, the authors have stricken important language following bluefish bringing it to their attention. Hiding this from public view in their Final EIS is the exact opposite of what bluefish.org had intended, as clearly stated at the beginning of the "Warm Temperature" comment:

The only "controversy" to speak of is that the federal agencies are steadfastly refusing
to listen to the science: The LSR dams impound a slow-moving thermal reservoir.

EPA's Columbia River Cold Water Refuges Plan 2019 (page 2)

Federal Response:
Reservoirs create a lag in the thermal response to environmental conditions, leading to colder conditions in the spring and warmer conditions in the fall as compared to unregulated systems. Breaching the dams would reverse these effects. Under a dam breach scenario, spring water temperatures will warm more quickly than No Action conditions. Similarly in the fall, under a dam breach scenario, fall water temperatures will cool more quickly than No Action conditions. These results make logical sense and are supported by results from CRSO EIS numerical water quality modeling.

bluefish counter response: Why not show one of these graphics alongside the narrative?

Water Temperature Prediction with No Lower Snake River Dams Appendix D, Annex A Figure 1-23

Appendix D - Annex A - Lower Snake River MO3 Model Development (page A-2-4)

Federal Response (continued):
What has surprised some stakeholders are the predicted summer water temperature effects under dam breaching. Many believe that removing the dams will result in colder water temperatures as compared to the No Action Alternative. While some cooler water temperatures may be observed in the summer under dam breaching, especially during cooler summer weather conditions and at night, water temperatures will remain warm and exceed the state water quality standard (20C = 68F) at times. This is because without the dams, the lower Snake River will be shallower and more susceptible to solar radiation and warming.

FALSE -- bluefish counter response:

A shallower, narrower river is LESS susceptible to solar radiation and warming. For those that are confused here, a primer on Heat Transfer now follows:

• Radiation is typically the most efficient means of heat transfer, notice how fast your coffee is heated in a microwave oven. In the case at hand, the solar radiation that warms our skin on a hot summer day, when we are unshaded, is the same heat transfer effect of the sun beating down on a half-mile wide reservoir of water. At night, especially when the sky is clear, some of this stored heat is radiated back into the atmosphere.

  During the winter months, when the sun's rays are less intense, due to their lower angle of incidence, and less long-lived, due to the fewer daylight hours, the balance of heat transfer favors the removal of heat from the reservoir and the water cools.

• Conduction is typically the least efficient means of heat transfer. but it is the most familiar to us. Consider the warm touch of a cup of hot coffee with no handle. Heat is transferred from the hot coffee to the cup and from the cup to our skin as we make contact with the cup. In the case at hand, the reservoir touches the earth, and over time they become the same temperature as a thermal equilibrium is reached.

  Heat transfers from higher temperatures to lower temperatures. On a hot, windless day, the higher temperature ambient air will warm the surface of the reservoir. At night, when the ambient air temperature is cooler than the surface water, heat is transferred from the water into the atmosphere. Without the flow of wind or current, this type of heat transfer is known as conduction.

• Convection occurs when there is a breeze, a flow across a surface, and heat is being carried away. We experience convection when a cool breeze removes heat from our warm skin, or when hot air warms a cool reservoir's surface. Convection is an efficient mode of heat transfer, very much like conduction, but the relative movement increases the affect.

Occuring somewhat more slowly than convection, conductance moves heat from the warmed surface water down to the water below. Solar radiation also warms the upper layers of the reservoir, but at some limited distance, that radiative heat has been completely absorbed.

Suggesting that the free flowing "lower Snake River will be shallower and more susceptible to solar radiation and warming" is incorrect. The depth of the water only changes how much radiation is absorbed by the earth below, but conduction, convection and radiation of that interface tends to bring any temperature difference back to the water above, a thermal equlibrium is reached over time.

It is the width of the river/reservoir that makes all the difference. A greater surface area absorbs more of the warm air's heat, and more of the solar radiation. The depth makes little difference. Purporting that the free flowing, shallower, lower Snake River will be more susceptible to solar radiation and warming" is incorrect.

The above primer on heat transfer explains the truth of the matter. Oddly, the CRSO respondents, are apparently not interested in the truth. Why do you suppose that is? It is worth nothing that their fabrication is not a finding of the underlying appendices prepared by the NEPA analysts. The CRSO Water Quality Workgroup did a fine job, but the CRSO authors worked diligently to conceal their graphics and related findings.

The point that "surprises some stakeholders" here, is how often this $80 million EIS contradicts the CRSO Workgroup's findings, remaining uncollected from the detailed Appendices.

Federal Response:
Increases in water particle travel time are expected, but the lower Snake River has always been a warm system (USGS 1960, 1961, 1964; Corps 2002a) and breaching the dams will not change this fact.

Egregious -- bluefish counter response:

Not only are we being asked again, to rely upon historic shoreline temperature readings (discussion above), but we are being asked to forget that the cold water released from Dworshak is "typically between 43 and 46 degrees Fahrenheit". Importantly, a restored lower Snake River will be cooler than it was prior to the construction of Dworshak Dam.

Appendix D - Dworshak Dam and Reservoir (page D-3-26)

Using the lower outlets and capitalizing on Dworshak's thermal stratification, along with the reduction of solar radiation effects due to a narrower river system, Remove Snake River Embankments will bring a cooler Columbia/Snake River system.

Yes, the Columbia/Snake River will be cooler than these rivers were before the Snake River was impounded. There is no doubt about it, but the co-lead agencies would have us believe otherwise. Why not be honest with the public and with concerned stakeholders?

Following Remove Snake River Embankments, Snake River Fall Chinook will rebound to fill the available spawning habitat, which would be fiften times greater in area than it is today (see discussion elsewhere). With the consequent restoration of salmon abundance, the now starving SRKW will once again feast at the mouth of the Columbia River, a top-five Chinook Priority Stock List (see Orca and Idaho's Chinook).

This is abhorent. With willful and skillful tactics, the CRSO denies or obscures the very high likelihood of salmon recovery. Who is in charge here? I for one, would like to know.

Federal Response:
The co-lead agencies' analysis of MO3, which includes breaching the four Snake River dams, indicates that nighttime summer water temperatures, as well as fall water temperatures, would be cooler than conditions in the No Action Alternative in the lower Snake River. However, even with the dams breached, maximum summer water temperatures would exceed state water quality standards (20C = 68F) at times, especially during high air temperature events.

bluefish counter response:

River conditions would be better, especially in the autumn when Fall-run Chinook adults are in the Snake River, but things will not be perfect. Some heat wave events in the summertime might bring, at times, exceedances of State Water Quality standards. Good to know.

Are Cold Water Refuges available to salmon at these infrequent times? Yes, as much as they do currently provide, but the need will be less frequent.

Will the Columbia/Snake River experiences far fewer high water temperature events? Yes.

Do the co-lead agencies bring this to the readers attention? No.

Overall the conclusion in the Draft EIS is that MO3 would be beneficial to anadromous fish for a number of reasons, but other objectives must also be considered in the selection of a Preferred Alternative.

The EIS set forth eight objectives which, in tandem with the Purpose and Need Statement, establish the framework for evaluating the ability of an alternative to satisfy the co-leads numerous legal obligations. The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3. However, the Preferred Alternative also meets all the other objectives of the study for resident fish, lamprey, hydropower generation, water management, and water supply, while minimizing adverse impacts to communities and the economy. The dam breaching alternative, by contrast, has significant regional economic impacts and community effects, and meet only a small subset of the EIS objectives. Thus, the co-lead agencies did not recommend MO3 because the Preferred Alternative is more likely to satisfy multiple complex and at times conflicting legal requirements for a complex system.

bluefish counter response:
The CRSO is setting aside MO3, which has a moderate to major effect on salmon population, and instead chooses a "spill experiment" that "has negligible effects on SRKWs". Where is the rationale?

The first paragraph above, suggests that the Preferred Alternative is being selected because it meets more of the EIS objectives than MO3. How many of the eight EIS Objectives are met or could be met if appropriate mitigations were to occur? That is a good question. It is all important.

• Multiple Objective 3 (MO3) and Preferred Alternative (PA) both Improve Juvenile Salmon (see image above);

• MO3 and PA both Improve Adult Salmon (see image above);

• MO3 and PA both Improve Resident Fish (see image above);

• MO3 and PA both Improve Lamprey (see image above);

• Provide a Reliable and Economic Power Supply;

  Executive Summary (page 30)
  Under MO3, hydropower generation would decrease by 1,100 aMW (about 1,000 aMW from breaching the four lower Snake River dams) under average water conditions, and 730 aMW under low water conditions compared to the No Action Alternative.
  . . .
  A "conventional" Resource Replacement Portfolio "includes 1,120 megawatts (MW) of combined cycle natural gas turbines at an overall cost of about $250 million a year. (See An Economic Power Supply for discussion of appropriate mitigation and (730 MW / 1,120 MW = 65% of) MO3 cost effects.)
  

• Minimize GHG Emissions;

  Executive Summary (page 31)
  MO3 would also not meet the objective to Minimize GHG Emissions. ... GHG emissions would increase the most if the hydropower were replaced with natural gas. This would lead to an additional 3.3 million metric tons (MMT) of CO2, a 9% increase in power-related emissions across the Northwest (See Carbon Sequestration)
  . . .
  In the future, technical advances in storage and other low-carbon options may become increasingly viable to help integrate variable renewable generation. With the expanded portfolio that is intended as a full replacement of the capabilities of the lost generation from the lower Snake River dams, the GHG emissions impact would probably be lower.
  

• MO3 would meet the objective to Maximize Adaptable Water Management (Executive Summary, page 32);

• MO3 and PA both Provide Water Supply; Measures implemented under MO3 could have major beneficial effects in Regions A and B and minor effects in Region D due to sediment accumulation near the pumps near McNary Dam.

  MO3 could affect delivery of current water supply in Region C, which would result in major effects to the Ice Harbor private, municipal, and industrial pumps located near Ice Harbor dam (see Irrigation).
  

  

Those are the eight stated Objectives of the EIS.
Strangely, the CRSO respondents suggest, incorrectly, that "minimizing adverse effects to communities and to the economy" and "hydropower" are stated Objectives of the EIS.

Of the eight EIS Objectives, how many are met, or could be met if appropriate mitigations were to occur? That is a good question. It is all important.

Federal Response (from opening paragraph above):
The Preferred Alternative is predicted to benefit juvenile and adult anadromous salmonids (two of the objectives), but not as much as MO3 which includes breaching the four lower Snake River dams.

The models showed minor changes in the Columbia River under this alternative, indicating that the operations of the CRS dams have a limited ability to reduce temperatures in the lower Columbia River.

Misleading -- bluefish counter response:

For some unexplained reason, the models did not consider water temperatures of McNary reservoir to which the Lower Snake River flows. Current dam locations were all that was considered in these USACE models.

To state that "the models showed minor changes in the Columbia River under this alternative (Remove Snake River Embankments)" is misleading, because McNary reservoir, to which the largest tributary of the Columbia River flows, was left out of consideration.

Federal Response:
Summer water temperatures exiting the Snake River are typically 1 to 3 degrees Fahrenheit warmer than the receiving Columbia River temperatures. Even though the cold water released from Dworshak during the summer is less than 50 degrees Fahrenheit, the volume of water released is less than one tenth of the flow in the Columbia River. Since the distance between the confluence of the Snake and Columbia Rivers is about "180 miles downstream from Dworshak, the impact on water temperatures is negligible.

Regionally high air and water temperatures result in water quality standard exceedances that are beyond the ability of the CRS to cool.

Preposterous -- bluefish counter response:

Ice Harbor is less than 10 miles from the Columbia River confluence. Cool water releases from Dworshak "typically between 43F and 46F (6C and 8C)" plays a large role in the river cooling seen in the following graph, of the water temperatures following Remove Snake River Embankments.

Once again, the professional and informative results of a CRSO EIS Workgroup is being suppressed when it contradicts the narrative the co-lead agencies are committing to has us believe. Suggesting that Remove Snake River Embankments "impact on water temperatures is negligible" is not supported by Figure 1-22 (below), which is obscurely buried in an Annex A of an Appendix D, rather than being positioned in the forefront.

Water Temperature Prediction with No Lower Snake River Dams Appendix D, Annex A Figure 1-23

Federal Response:
The study results indicate that the operations of the CRS do impact water temperature but the CRS has limited ability to reduce temperatures in the lower Snake and Columbia rivers outside of Dworshak operations. Regionally, high air and water temperatures result in water quality standard exceedances and are beyond the ability of the CRS to cool.

bluefish counter response:

Actual temperature recordings, (see Figure 4 in the bluefish comment directly above, taken from Figure EPA's Columbia River Cold Water Refuges Plan), reveals the warm water effects of the Lower Snake River. When considering that the Columbia River is twice the volume as the Snake River at their confluence, the resulting temperatures at McNary forebay are surprising at first. But, as these temperature recordings reveal, the two rivers do not mix, and the "stratification of the water column" persists all the way down to the McNary Dam forebay.

Columbia River Cold Water Refuges Plan, Appendix 1 (page 4)

The CRSO EIS completely ignores this phenomenon which would largely disappear following Remove Lower Snake River Embankments because Snake River water would be significantly cooler during the summer and fall months.

Appendix D - Annex A - Lower Snake River MO3 Model Development (page A-2-4)

Drier and warmer years such as 2015, as summarized in NOAAs 2015 Adult Sockeye Salmon Passage Report (September 2016, National Marine Fisheries Service document) point out that tributary temperatures in the Okanogan and Salmon rivers were above 25C. Cooling water pumps have been installed at Lower Granite and Little Goose adult passage ladders to reduce temperature differentials between ladder and river and to reduce thermal stress during upstream passage. Additional considerations at other locations are included in the EIS.

In addition, the co-lead agencies are actively working on implementing the recommendations identified in NMFS's 2015 Adult Sockeye Salmon Passage Report (September 2016, National Marine Fisheries Service document) to improve management decision making and reduce, to the extent practicable, the negative impacts of high summer temperatures on migrating salmon, including adult sockeye salmon. Future analysis, particularly for real-time water temperature management, should focus on optimizing spill versus passing the water through the turbine units to maximize benefits to migrating salmonids.

bluefish counter response:

Columbia RiverKeepers' numerical modeling of the 2015 heat event, which destroyed 99% of Snake River Sockeye adults, is dispalyed below. What should now be abundantly obvious to the reader -- with the CRSO sly maneuvering of disguise, only highlighting the fact -- is that a damless system would have been much, much safer for migrating Sockeye adults.

Columbia Riverkeeper White Paper (page 4)