Fourteen Fatal Flaws

Of The Columbia River Systems Operations Draft Environmental Impact Statement


Reference documents linked were included in official comment

  1. Peaking, Ramping, Balancing, & Reserve hydropower benefits of the Lower Snake River Dams (LSRDs).
  1. 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).
  1. 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. 
  1. Salmon survival/mortality data insufficient.
  • Does not assess latent and reservoir mortality, SAR values, and recovery standards for each multiple objective.
  1. Snake Chinook deemed insignificant prey source for Southern Resident Killer Whales (SRKW).
  1. Irrigation mitigation of MO3 based on devaluing irrigated land, 47,840 acres at cost of $313.7 million.
  1. 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.
  1. 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.
  1. Flood conveyance dredging at Lewiston absent in multiple objective costs.
  • Could increase cost by approx. $12 million/year for NA, MO1, MO2, MO4 & PA.
  1. LSRD breach cost from 2002 EIS without mitigation uncorrected and escalated to $994 million.
  1. Congressional authorization assumption for MO3 unnecessary. Supported by CSRIA legal analysis. 

12. Breach alternative MO3 conflated with construction and                      mitigation costs on other dams.

  1. 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.
  1. Greenhouse gas emissions from LSRDs ignored in MO3.