Of The Columbia River Systems Operations Draft Environmental Impact Statement
Reference documents linked were included in official comment
- Peaking, Ramping, Balancing, & Reserve hydropower benefits of the Lower Snake River Dams (LSRDs).
- Claimed over 2,000 MW with a value of $996 million for total zero-carbon replacement cost.
- Inconsistent with claims in 2002 EIS, Waddell et al. 2020 ” Claims of Sustained Peaking, Ramping, Reserve, Flexibility and Balancing Power from the lower Snake River Dams, What Is Feasible?”
- Recreation Visitation Estimated at 2.4 million non-local visitors/year for LSRDs.
- 2.4 million visitors is more than those going to Mt Rainier, 6,575 visitors every day.
- Data from 2002 EIS since corrected to 53,000 visitors/year by Earth Economics 2016 “National Economic Analysis of Four LSRDs.”
- Used to extrapolate Multiple Objective 3 (MO3) losses of 1,420 jobs, $59 million in labor income, and $189 million in annual sales. No benefits quantified, though 3-4,000 jobs would be created (Earth Economics 2016).
- MO3 anadromous fish mitigation with additional hatchery salmon, cost of 78.1 million.
- Absent in the 2002 EIS breach alternative because appropriate timing is in winter, when almost no fish are in the river. Breaching is the mitigation, preventing the death of ~8 million chinook smolts per year.
- Salmon survival/mortality data insufficient.
- Does not assess latent and reservoir mortality, SAR values, and recovery standards for each multiple objective.
- Snake Chinook deemed insignificant prey source for Southern Resident Killer Whales (SRKW).
- Irrigation mitigation of MO3 based on devaluing irrigated land, 47,840 acres at cost of $313.7 million.
- Mitigation method justifies loss of 4,800 jobs, $232 million in labor income and 460.5 million in sales.
- Pipe extension and pump installation mitigation overlooked, estimated at $20 million from Sampson, Rob 2018 “A brief review of the impacts to irrigated farmland from breaching the four dams on Lower Snake River”.
- MO3 navigation rate increase based solely on opinion of “some stakeholders.”
- 25 to 50% increase in rail shipment costs cannot be justified without cost estimate modeling and supporting data.
- Use of recently upgraded rail line along the snake that can move all grain to market is not mentioned.
- Navigation dredging of Lake Wallula/Lower Snake in MO3 with cost of $76 million.
- 2002 EIS did not include this cost because no dredging is required in this location, breaching sediment drops out above Ice Harbor.
- Flood conveyance dredging at Lewiston absent in multiple objective costs.
- Could increase cost by approx. $12 million/year for NA, MO1, MO2, MO4 & PA.
- LSRD breach cost from 2002 EIS without mitigation uncorrected and escalated to $994 million.
- Error of approx. $600 million, from Waddell et al. 2016 “Reevaluation of The Lower Snake River Juvenile Salmon Migration Feasibility Report And Supplemental Environmental Impact Statement Appendix D Natural River Drawdown Engineering.”
- Stated as $994 million in chapter 3, inconsistent with appendix Q that says it is $955 million.
- Congressional authorization assumption for MO3 unnecessary. Supported by CSRIA legal analysis.
12. Breach alternative MO3 conflated with construction and mitigation costs on other dams.
- Power Replacement Costs & Loss of Load Probability overstated for 1,000 MW.
- Least-cost power resource acquisition strategy not modeled, most up-to-date costs of wind and solar not used for cost replacement, if needed.
- Greenhouse gas emissions from LSRDs ignored in MO3.
- From US Department of Energy 2013 “Evaluating greenhouse gas emissions from hydropower complexes on large rivers in Eastern Washington.”