Agencies Flooded with Commentsby Mike O'Bryant
After being overwhelmed by over 200 comments about its preliminary summer spill proposal, the Bonneville Power Administration and the U.S. Army Corps of Engineers put off until April 21 the release of their amended proposal and for one week a regional federal executives meeting previously scheduled for today.
The agencies expect to make a final decision by April 30.
Two weeks ago, BPA and the Corps laid out their preliminary proposal for a three-year program that could save BPA as much as $45 million each year by reducing spill at dams in July and completely eliminating spill in August. A complete elimination of summer spill would save the agency as much as $70 million.
The goal of the operation is to achieve similar or better biological benefits for salmon using offset mitigation actions at an estimated cost of $2 to $5 million, which is less than the cost of the current spill program, according to BPA.
In its proposal, BPA proposed an accelerated Pikeminnow program and one-half of the benefit of Grant County Public Utility District's additional anti-stranding actions as potential offset measures.
State and fishery interests focused on recommending additional offset measures to gain certainty in obtaining benefits or, as is the case with the Columbia River Inter-tribal Fish Commission, completely opposing the plan.
However, utility comments supported reductions in spill in order to lower BPA costs and focused on adding to the offset list proposed by BPA and the Corps such actions as a reduction in non-treaty commercial salmon harvests, increased hatchery production and avian predation controls.
"As you know, the summer spill program is the costliest salmon recovery effort currently implemented and is the only one of 199 actions in the 2000 Biological Opinion (BiOp) and was intended to protect juvenile ESA-listed fall chinook salmon migrating from the Snake River," said Kevin Banister of Pacific Northwest Generating Companies in a letter to both BPA and the Corps.
All letters were delivered to BPA Administrator Steve Wright and Commander of the Corps' Northwest Division Brigadier General William T. Grisoli.
"While this proposal represents a positive first step in achieving greater cost accountability in the region's salmon recovery efforts, a full elimination of summer spill would mark real progress in that regard," Banister continued. "PNGC Power believes that implementing programs that provide the greatest benefit to salmon at the lowest possible cost represents the best way to achieve sustainable results that will benefit the diverse yet similar interests of citizens in the Northwest."
A letter from Oregon Gov. Ted Kulongoski to BPA and the Corps said the state "considers the increase in salmon and steelhead mortality caused by the proposed reduction in spill to be significant. We also consider the two specific offset in your preliminary proposal are insufficient to mitigate for increased mortality on their own."
The letter went on to say that, other than the two offset measures included in the preliminary proposal, the offsets lacked the details needed to evaluate them. In addition, the letter said that the biological impacts of the proposed change in spill operation would impact salmon more than indicated by BPA and the Corps.
"Offsets should provide reasonable assurances to avoid additional impacts to listed and non-listed salmon and steelhead," Kulongoski said. "Oregon believes priorities should focus on in-place, in-kind and in-time alternatives to offset increased fish mortalities associated with non-spillway dam passage. In the near-term, we believe an offset to increase flows to improve survival associated with fish passage would have significant biological value."
The Pacific Northwest Utilities Conference Committee (PNUCC) believes the two offsets included in the preliminary proposal are sufficient to make up for expected losses due to a change in spill. However, recognizing others disagree, it offered several additional options, including a reduction in the non-treaty commercial fishing harvest and increased hatchery production.
"Reducing commercial harvest, whether through a voluntary compensation program or through a federal mandate, would have very measurable effects on salmon populations," said Dick Adams, Executive Director of PNUCC. He added that a 1 percent reduction in lower river non-tribal commercial harvest would yield "at least 80 ESA listed Snake River fall chinook salmon escaping upriver. This would be more than 4 times the mitigation needed from the most severe adverse affects to listed Snake River fall chinook salmon."
Since the majority of fish impacted by the reduction in summer spill would be hatchery fish, increasing hatchery and supplementation programs should also be considered, Adams said. PNUCC also supports an avian reduction program beginning in 2005 that would reduce the number of Caspian terns in the lower Columbia River by 2,500 to 4,500 breeding pairs. That would reduce predation losses by 350,000 to 500,000 juveniles, Adams said.
A Washington Department of Fish and Wildlife proposal would significantly increase the number of offsets as well as the cost to BPA of eliminating spill, but the state's additional proposed offsets would only apply to Washington fish stocks.
Jeff Koenings, Director of WDFW, in a letter to Bob Nichols, representing Washington Governor Gary Locke, said that Washington's proposed offset actions "should provide some reasonable level of certainty that spill reductions would not result in additional reductions in the returns of Columbia River salmon and steelhead." He added that spill reductions should be subject to a no net impact (NNI) standard and that offset actions should be combined since "no single action can meet the NNI for all affected populations."
"No mainstem flow improvements have been identified for upper Columbia summer chinook, so an offset package will have to rely heavily on tributary habitat work, fish augmentation and predation reduction," he continued.
Washington's list of offsets differs greatly with the list provided by BPA and the Corps. It includes:
The Columbia River Inter-Tribal Fish Commission opposes reducing summer spill and considers the impacts on hatchery fish as important as impacts on endangered Snake River fall chinook.
"No one has more vital interests aligned to the salmon resource than the tribes," said CRITFC Executive Director Olney Patt, Jr. "While some disparage the value of hatchery-reared salmon, there is no 'bright line' between the value of these salmon and naturally produced salmon."
"The right of tribes to fish must not be subordinated to other economic interests such as competing fisheries, irrigation storage, or power demands," he added.
He goes on to say that "every juvenile salmon and lamprey that survives the hydrosystem passage through spill has the potential to bring back some of the river's wealth to the tribal economy and culture," which he said has been taken from tribal people through past actions.
"The federal agencies are proposing to eliminate spill without full regional support and contrary to specific requirements of the 2000 FCRPS Biological Opinion," Patt said. Since the region has not completed an evaluation of 2001 when summer spill was curtailed, there is no biological basis to abandon spill now, he said. And, he added, the proposal for the next three years lacks a specific evaluation program that would monitor the biological impacts of that operation.
He concluded by urging BPA and the Corps not to curtail summer spill.
bluefish does the math for your convenience: BPA estimates that eliminating summer spill would provide 1.15 - 1.49 million Megawatt*hours (MWh) of "surplus" electricity to sell (typically to California) at an estimated average price of $32/MWh (yielding $37 - $46 million). Prices of course will vary with time of day and electricity market conditions. BPA estimates that elimination of summer spill could potentially provide a 2% electricity rate reduction.
learn more on topics covered in the film
see the video
read the script
learn the songs