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Why the 2008 FCRPS Biological Opinion Does Not Include Removal of the Four Lower Snake River Dams by NOAA Fisheries FCRPS Biological Opinion, May 5, 2008

Note: bluefish has added bold formatting for emphasis and blue text for clarification.

Statement of Issue

Breaching of the Snake River Dams has been a regionally debated issue for several years. Dam breaching is a complex issue, and there are a range of regional views regarding biological benefits, economic consequences, and other environmental effects. It is certain, however, that breaching all four lower Snake River dams can

• at best help four of the 13 listed salmon and steelhead species in the Columbia River basin;
  
• would create adverse impacts to navigation, cultural resources and recreation;
  
• and would result in loss of power generation and potential increased environmental effects due to carbon emissions from replacement power.

Is removal of the Lower Snake River dams a viable option as either an RPA or a contingency in the 2008 FCRPS Biological Opinion?

Background

Regional debate over breaching the four Lower Snake river dams goes back to the early 1990's when it was discussed at the Regional Salmon Summit and later referenced in the 1995 Biological Opinion that called for evaluating such an action. In July 2000, the four Northwest governors recommended "an aggressive non-breach" strategy for salmon and steelhead recovery (Kempthorne et al. 2000). The U.S. Army Corps of Engineers formally rejected a dam breaching proposal again in June 2006 (Corps 2006b) because it is inconsistent with the authorized purposes established by Congress for the lower Snake River dams. Dam breaching would have far-reaching impacts on recreation, transportation, navigation, power production, air quality, and the region's economy - and so was not considered by the Corps to be a "reasonable and prudent alternative" under the ESA.¹⁴

In 2007, a Bonneville Power Administration (BPA 2007) analysis found that the power benefits of the dams could only be replaced with natural gas fired turbines, and that the cost of replacing the power lost with dam breaching had increased significantly since the U.S. Army Corps of Engineers' comprehensive study. That same year, a separate analysis by the Northwest Power and Conservation Council confirmed BPA's finding that the power would need to be replaced with natural gas and further quantified the additional carbon dioxide emissions that would result from that replacement.
(bluefish contends that this is not an accurate reading of the NW Council report which is quoted in note below).

During the course of the remand collaboration process, some PWG members and Remand Parties requested that the FCRPS Action Agencies evaluate a dam breaching alternative as part of the Remand Collaboration (American Rivers 2006). The Action Agencies did not agree and PWG members themselves were divided on whether to model the scenario. Some parties urged the federal agencies to pursue Congressional authorization and consider breaching the four lower Snake River dams as a contingency plan for species recovery (SOS 2008 and Nez Perce Tribe 2008). However most of the sovereign parties focused on better defining the key elements of aggressive non-breach - or All H - strategy to improve the survival and recovery prospects for ESA-listed salmon and steelhead.

Scientific Reviews of Four Lower Snake River Dam Removal

The 2000 FCRPS Biological Opinion (NMFS 2000b) evaluated the impacts of dam breaching on the biological requirements of eight listed species of salmon and steelhead over their life- cycle. It reviewed impacts of dam removal during the actual deconstruction (or transition) period and over the longer-term. One key input to the model was the assumption about delayed mortality. The model utilized three alternative hypotheses regarding delayed mortality in the breaching study. The model results varied significantly, depending on which delayed mortality assumption was applied (NMFS 2000b). But there was limited and conflicting information to assess which delayed mortality hypothesis was the most valid.¹⁵ Dam breaching by itself, the 2000 Biological Opinion concluded, would not recover listed salmon and steelhead. Instead, the 2000 FCRPS Biological Opinion established a comprehensive strategy to improve hydrosystem, habitat, and hatchery life-stages for listed salmon and steelhead as a more effective program for the fish. The same all-H approach continues today and is included in the 2008 FCRPS Biological Opinion (but Actions 147 & 148 are not included in the 2008 plan).

In a seven-year effort from 1995 to 2002, the Corps conducted a comprehensive study of four major alternatives to improve juvenile salmon passage through the hydropower system on the lower Snake River. In the Lower Snake River Juvenile Salmon Migration Feasibility Study (Corps 2002), one of the alternatives studied was breaching the four lower Snake River dams to return a 140-mile stretch of the river to a more natural free-flowing state. The Corps conducted an extensive evaluation of the effects of breaching the dams on all users and resources, along with other alternatives. Numerous analyses were done to assess the effects on fish, wildlife, water quality, navigation, irrigation, recreation, Tribal and other cultural resources, sediment, and the cost to implement.

The study determined that the economic and environmental impacts of dam breaching would be substantial and the action by itself would not likely recover the four listed stocks of salmon and steelhead in the Snake River. Additional mitigation actions would still be needed to address habitat, hatchery, and harvest problems for Snake River listed salmon and steelhead. Dam removal would not help the other nine listed species.
Idaho's Steelhead, Spring/Summer Chinook, Fall Chinook and Sockeye must negotiate Snake River dams and reservoirs (see Survival of Downstream Migration).

The Corps analysis indicated that Congress would have to provide the authority and appropriations to implement dam breaching. In addition, the analysis concluded that dam breaching could take 10 years to implement, once the authority and funding were in place. As a result, it was estimated that it would take more than 20 years for breaching to provide a benefit to fish (not a short-term alternative).

Because of these findings, the study recommended major system improvements for fish passage to improve fish survival at the four lower Snake River dams. Ultimately, based on regional discussions and ESA consultation, the Corps decided to pursue this option at the four Snake River dams as well as at the four lower Columbia River dams. This alternative consisted of actions such as: removable spillway weirs, turbine upgrades, and improvements in bypass systems - all of which have recently been implemented and are further being advanced in this 2008 FCRPS Biological Opinion.

Other Considerations about Dam Removal

To breach the lower Snake River dams, the earthen portion of each dam would be removed to return the river to a free-flowing state. The concrete-and-steel structures that currently provide power and navigation could remain in place but would be inoperative. Barge traffic through the lower Snake to Lewiston, Idaho would be curtailed and power production at these facilities would stop. These are Congressionally authorized purposes of the lower Snake River dams that cannot be changed without Congressional action. No such proposals are currently pending or under consideration.

In late 2006, the Save Our Wild Salmon coalition produced a report called Revenue Stream, An Economic Analysis of the Costs and Benefits of Removing the Four Dams on the Lower Snake River. The report examines the economic impact of dam removal and salmon recovery in the Pacific Northwest. The study estimated net increased revenues from recreation and tourism opportunities.

The Independent Economic Analysis Board (IEAB) of the Northwest Power Planning Council concluded the Revenue Stream report "cannot be viewed as a credible alternative to the Corps Lower Snake EIS analysis of the impacts of removing the four lower Snake dams" because the report had a number of analytical deficiencies, including lack of documentation, use of outside analysis that the IEAB had previously found deficient and lack of transparency about sources. The IEAB also noted that the report's authors erroneously chose not to address the likely distribution of costs and benefits over time or to discount future costs and benefits (IEAB 2007).

A 2007 Bonneville Power Administration (BPA) paper on Dam Breaching (BPA 2007) was developed to update information on the value of the power generated at the lower Snake River dams in terms of both economics and air quality. BPA used the assumptions in the Council's Fifth Power Plan to calculate the economic value of the power from the lower Snake River dams.

The analysis concluded that even if substantial new cost-effective conservation and wind resources were identified - beyond what the Council's Plan had called for - that it would cost electricity customers $400 million to $550 million annually to replace the power capabilities that would be lost if the dams were breached. BPA also noted that hydropower is the key resource the region relies on to back up the growing development of wind energy. Because the wind doesn't blow all the time, BPA noted, the power from the lower Snake River dams and other dams in the region is used to support or "firm up" wind energy.
Subsequent studies have revealed that the existing system can readily absorb at least 6,000 megawatts of wind energy.

The lower Snake River dams generate 1,022 average megawatts of emissions-free electricity per year, enough to power the city of Seattle. According to a 2007 study conducted by the Northwest Power and Conservation Council (NPCC 2007), removing the dams and replacing the power with the most likely fossil-fuel resource, would add 5.4 million tons of carbon dioxide (NPCC 2007 reported 4.4 million tons) every year to the region's air, contributing to the atmospheric carbon dioxide burden and possibly influencing climate change. The Council concluded that meeting the region's carbon reduction goals will be very challenging and that removing the lower Snake River dams would be "counterproductive."

NPCC 2007 states "Replacement of the power lost by breaching the lower Snake River dams by increased acquisition of conservation and renewable energy could, at least in the near term, delay some of the CO2 impacts of dam breaching. However, tying the increased development of conservation and renewables to dam breaching is misleading. If additional conservation and renewables are available and desirable, they should be pursued as part of a regional strategy to reduce CO2 emissions.".

Summary of Views and Comments

Save Our Wild Salmon urged the federal agencies to include a dam removal provision in the final Biological Opinion. While breaching would benefit four of 13 listed species, Save Our Wild Salmon suggests the water quality benefits of dam removal would aid the other nine species downstream. Given the work that needs to be accomplished prior to removal (e.g., removal studies, identifying how to most efficiently replace power and accommodate other uses of the dams), Save Our Wild Salmon suggests that NOAA Fisheries could include an "off-ramp" from dam removal if the Federal Action Agencies provide clear and convincing scientific evidence that such an action is not necessary to protect Snake River salmon and steelhead (SOS 2008).

Approach in the FCRPS Biological Opinion

1. Based on the best scientific information available, it is biologically not necessary to include dam breaching as an RPA action or contingency to achieve the survival and recovery of the listed salmon and steelhead species. Consistent with the previously discussed findings that breaching alone would not recover the stocks, the FCRPS Action Agencies are required to pursue a comprehensive program addressing the range of factors affecting fish survival. This aggressive non-breach strategy was also described in the 2000 FCRPS Biological Opinion (which, however, also included a contingency plan if performance standards were not met).

2. Since 2000, there have been significant improvements that should translate to increases in survival across the salmon life-cycle, including:
   • The Corps has installed removable spillway weirs (RSW) at Lower Granite, Ice Harbor, and recently at Lower Monumental dams on the Snake River. These RSWs have proved to be effective at passing juvenile fish, reducing fish delays upstream of the dams, and, most importantly, increasing survival for these fish without breaching.

   • To benefit a broader group of listed fish (Upper Columbia and Mid-Columbia) a similar approach for improved survival is being taken at lower Columbia River dams.

   • New turbine technologies are being tested at Ice Harbor dam that will increase turbine survival for juvenile fish.

   • As a result of these structural improvements and hydro operations for fish passage, in 2006 and 2007, the NOAA Science Center found that juvenile spring chinook survival through the eight federal dams on the Columbia and Snake Rivers was the highest yet measured. Juvenile fish survival today is higher than was estimated in the 1960s when there were only four dams in place.

   • Extensive habitat improvements have been funded and implemented by the FCRPS Action Agencies, with additional survival benefits for listed fish.

3. Also, under the ESA, the action is necessarily limited to operating the FCRPS consistently with authorized project purposes. Currently, none of the responsible Federal agencies has Congressional authority to significantly alter the Snake River dams. Therefore, absent new Congressional action, it is not possible that such an action would be reasonably certain to occur or otherwise meet ESA standards for inclusion in the FCRPS Biological Opinion.
   (Contingency plan of Actions 147 & 148 were not deemed illegal when the 2000 BiOp was remanded).

4. Adverse environmental effects from dam breaching are also an important consideration. Water quality for all downstream species would be negatively impacted by movement of sediment following dam breaching. An estimated 100-150 million cubic yards of impounded sediments have accumulated upstream of the Snake River dams. The Corps' Lower Snake River Feasibility Study estimated approximately one-half of this material would migrate downstream and end up in the McNary reservoir. The biological implications of the sediment movement are uncertain but would likely result in high turbidity loads for 5-7 years following breaching (Corps 2002).
   (2000 BiOp found that increased turbidity may provide benefit for Idaho salmonid as juvenile salmonids may better avoid predators)

5. In addition to water quality and other effects (Corps 2002), these include the air quality implications of replacement power resources (NPCC 2007), moving backwards rather than forwards in regional goals to decrease carbon emissions (NPCC 2007), and loss of ability of integrate other renewable resources into the regional power grid (BPA 2007). Considering the potential for climate change, these environmental considerations also argue against pursuing Snake River dam breaching.

The 2008 FCRPS Biological Opinion supports a comprehensive, All-H strategy including continued fish passage improvements at the Snake River dams such as surface collection and bypass improvements, as well as offsite actions including habitat and hatchery improvements, to meet the needs for listed fish. This approach benefits not only Snake River fish, but also Upper Columbia and Mid-Columbia salmon and steelhead.

Footnotes:
¹⁴ Reasonable and prudent alternatives are "recommended alternative actions identified during formal consultation that can be implemented in a manner consistent with the intended purposes of the action, that can be implemented consistent with the scope of the Federal agency's legal authority and jurisdiction, that are economically and technologically feasible, and that the director believes would avoid the likelihood of jeopardizing the continued existence of listed species or the destruction or adverse modification of designated critical habitat" [50 CFR §402.02].

¹⁵ During the FCRPS remand collaboration, several agencies proposed post-Bonneville relationships, including those addressing "latent" mortality (mortality related to passage through the hydrosystem but expressed outside of the hydrosystem). The ISAB (2007b) reviewed various latent mortality hypotheses and concluded "that the hydrosystem causes some fish to experience latent mortality, but strongly advises against continuing to try to measure absolute latent mortality. Latent mortality relative to a dam-less reference is not measurable. Instead, the focus should be on the total mortality of in-river migrants and transported fish, which is the critical issue for recovery of listed salmonids. Efforts would be better expended on estimation of processes, such as in-river versus transport mortality that can be measured directly."

Action 147 of 2000 FCRPS BiOp
As a contingency plan, the Corps (in cooperation with other Federal agencies) shall develop a project management plan to reevaluate more intensive hydropower-related actions (including breaching) for the four Lower Snake River dams. This project management plan will identify the scope, schedule, costs, tasks, products, and responsibilities for the reevaluation study. The study should assess all significant changed conditions to the Lower Snake River Feasibility Report and Environmental Impact Statement (Corps 1999c). The project management plan should be consistent with direction from Congress, Corps authorities, and other legal requirements. The completed management plan should be coordinated with the appropriate regional interests. The project management plan should be consistent with direction from Congress, Corps authorities, and other legal requirements. The completed management plan should be coordinated with the appropriate regional interests. The project management plan should include, but not be limited to, plans to mitigate disproportionate impacts of communities, industries, and Tribes, detailed water and air quality effects, implementation plans, and a complete public involvement program. The decision to start the reevaluation study should result from the NMFS check-in process in Section 9.5. The Corps will request funding or reprogramming to complete the project management plan within 1 year after NMFS' issuance of a check-in report indicating the need to seek additional authority. the study should result in a general reevaluation report and supplemental environmental impact statement, which would be used to seek authorization and/or appropriations to implement, recommend action(s), if need. The general reevaluation report/ supplemental environmental impact statement will require approximately 2 years to complete.