July 11, 2022
Jim Kramer
Kramer Consulting, Inc.
6539 57th Ave. S.
Seattle, WA 98118
RE:
Mr. Kramer,
The Sierra Club is pleased to have the opportunity to comment on the draft report regarding benefits and ability to replace the services provided by the lower Snake River dams (LSRD’s). The Sierra Club has over 3.5 million members and supporters nationally and over 200,00 members and supporters in Washington, Oregon and Idaho. We recognize that a number of organizations that we work with are also providing comments on the draft report and do not want to repeat what you will be receiving from many of them. We note that Save Our Wild Salmon Coalition is providing comments on behalf of several groups and we endorse their comments. We intend to focus our comments on a set of issues that we believe are fundamental to the need and ability to move forward with breaching the dams. The Sierra Club has a long history of working for salmon and steelhead recovery across the Northwest and particularly in the Snake/Columbia Rivers. The Snake River is the single best opportunity to restore salmon abundance on the west coast. The high elevation, cold water, excellent habitat in SE Washington, NE Oregon and Central Idaho are a salmon sanctuary in a climate change world. Indeed, it may literally be the Noah’s Ark for salmon in the lower forty-eight states. We must take advantage of this opportunity for action before it is too late.
We want to commend you for the thorough compilation of the numerous studies and reports that have been done over the years on various aspects of this issue. You have done the region and the principals who requested this report, Senator Murray and Governor Inslee, a real service by developing this comprehensive set of information in an honest and understandable form. The region has spent far too much time debating fears, fantasies, and sometimes sheer hallucinations about the impacts of removing the dams and need to do so. The draft report provides a useful set of sideboards to frame the discussion and decisions that need to be made. This kind of comprehensive and honest representation of the various studies has long been needed.
The draft report makes clear some key findings:
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The salmon and steelhead of the Columbia/Snake River Basin that are listed under the Endangered Species Act (ESA) are at risk of extinction and forty plus years of federal agency plans and spending have not been successful in salmon recovery. As the report notes we have spent over $26 billion on Fish and Wildlife programs, with most of that on endangered salmon and steelhead, without recovering a single run of endangered fish. The Snake/Columbia River chinook salmon are an important source of food for the endangered Southern Resident Killer Whales (orca) and are impacted from the decline of these salmon runs.
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Salmon are critical to the tribes of the Columbia Basin and indeed the entire Northwest. Salmon are fundamental to their culture, economy, and way of life. We have not met our treaty rights and other responsibilities to the tribes and it past time for us to deliver on our commitments.
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The lower Snake River dams are a fundamental reason for the rapid decline in the population of wild salmon and steelhead in the Snake River basin and that salmon and steelhead that navigate fewer dams have much better smolt to adult (SAR’s) survival.
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The status quo is unsustainable and will not hold. The impacts to salmon, water temperatures and modification to how the dams must be operated will drive ongoing change - with or without removal of the dams. Climate change, declining snowpacks, and court mandated modification to operation of the hydro system will continue. There is no status quo to return too.
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We can responsibly and affordably replace and/or mitigate the services that the dams currently provide. In fact, smart investments can improve on existing services and create new opportunities.
In short, there are no showstoppers that prevent reaching the conclusion that we can breach the lower Snake River dams and responsibly replace their services. And, if we do not breach the dams the salmon and steelhead face near certainty of extinction and no chance of recovery. The draft report is also clear that if we breach the dams we must replace and mitigate these services before breaching to assure the reliability of power, irrigation and transportation of crops. However, the need to do so also argues for urgency in making the decision to breach the dams and move forward expeditiously with investments to replace the services. Time is not on the side of the fish – or us.
Below are a set of issues on which we would like to provide some specific comments.
SHORTCOMINGS IN THE REPORT
As we previously noted the draft report did a commendable job overall in presenting the benefits and identifying options for replacing the services from the dams. However, the draft report did not provide the same accounting of costs for leaving the dams in place as was done for replacing their services. The report uses a 50 year time frame for estimated costs and benefits. The final report should provide a full comparison of all the costs and benefits for both removing the dams and replacing the services and leaving the dams in place. The draft report identified a number of costs associated with retaining the dams including annual operating and capital costs of $124-151 million, estimates for replacing the turbines, current annual LSRD fish and wildlife costs, etc. However, these costs and expenditures were not summed over the 50 year time period as was done for actions needed to replace the services. A full and direct comparison of the costs associated with retaining the dams and operating them over this time period should be compared to the range of estimates for replacing their services.
Similarly, the draft report fails to estimate the benefits from restored salmon and steelhead runs for sport and commercial fishing. Again, some useful data are included such as the tribal harvest could increase by 29% annually and that salmon and steelhead recovery could generate up to $1 billion annually in additional regional personal income and support up to 25,000 new family wage jobs.
We also want to underscore the importance of including the very substantial benefits identified in the ECO Northwest Lower Snake River Report. The existence value benefits that the public attaches to salmon are both real and capable of being estimated as ECO Northwest has done. Their estimate of the value the public places on retaining salmon dwarfs even the high-end costs of replacing the services from the dams. And we believe the high-end estimates are very unlikely. The comments provided by Glen Spain on behalf of PCFFA provide a strong framework for how to incorporate these benefits in addition to the direct benefits of the restored fisheries.
The draft report acknowledges that taxpayers heavily subsidize barge transportation on the lower Snake and Columbia Rivers. The CRSO EIS identified these costs at $27M of year in capital costs and $83 million on operation and maintenance. These too should be incorporated as a cost of dam retention.
The final report should put this information in a format comparable to the other costs and benefits provided so the public has a clearer view of the full range of costs of keeping the dams and of economic benefits of restored fisheries over the same 50 year time period the report uses.
ENERGY
Our colleagues at the NW Energy Coalition -- an organization of which the Sierra Club is a founding member – are submitting detailed comments on the energy aspects of the draft report, which the Sierra Club has co-signed and heartily endorses. Here we emphasize several essential points.
First, both keeping the dams and removing the dams have costs, but dam removal with replacement of their energy services is likely the less expensive option. There’s no free lunch, but with a free-flowing lower Snake River, lunch is affordable, and can at least include salmon.
The second point we would emphasize is that in the energy arena, we have an opportunity to not just replace the services the dams now provide, but improve on them. As the recent Energy Strategies study of LSRD power replacement concludes, “…replacement portfolios will generate power at times when the region needs it the most, resulting in $69M - $131M million per year of energy value above and beyond what the LSRD’s provide for the same time period”.
The limited value of the dams’ energy production is a result, of course, of the extreme seasonality of their output. Defenders of the dams like to emphasize that wind and solar are “intermittent” resources, but that’s a fair description of the LSRD as well. Wind turbines have capacity factors ranging, depending on siting, from 35%-50%. Solar in our region has a capacity factor around 25%. And the lower Snake dams’ capacity factor is about 30%. None of these resources qualifies as a “baseload” resource.
Finally, at least some of the costs of new transmission and grid modernization to support LSRD power replacement can be funded with money from the bi-partisan infrastructure bill, lessening the cost to Northwest electric consumers.
RECREATION
The Sierra Club encapsulates its mission this way: “Explore, Enjoy, Protect” the natural world. Thinking of the explore and enjoy portions of that mission, restoration of 140 miles of free-flowing Snake River replaces present recreational opportunities on the river, available on a number of other slackwater reservoirs in Washington, with something we don’t currently have: a destination river for multi-day rafting and kayaking trips.
Adding in the 108 miles of free-flowing river between Lewiston and Hells Canyon Dam, the river would provide almost 250 miles of river for rafters and kayakers from around the country and the world. For comparison, trips through the length of the Grand Canyon of the Colorado typically start at Lees Ferry and take out at Whitmore Wash, 188 miles downstream.
Demand for this kind of outdoor recreation is growing exponentially in our region. As the draft report says, "Stakeholders interviewed for this effort noted that demand for recreation and rafting opportunities through free-flowing rivers is steadily increasing, with the odds of securing a permit to float the Snake River through Hells Canyon decreasing from one in six in 2010 to one in 17 in 2020, and for the Salmon River, the odds have decreased from one in 17 in 2010 to one in 43 in 2020."
CLIMATE IMPACTS
The Sierra Club is strongly committed to climate action and believes this issue is of paramount importance. We have worked locally, regionally, nationally, and internationally to accelerate the decarbonization of our electric sector and economy. Restoring resilience to ecosystems is also a fundamental part of any smart climate strategy. It is essential to do both in dealing with a climate changing world.
We are aware that some groups who are vested in keeping the dams, such as Northwest River Partners, assert that breaching the dams will increase the challenge of addressing climate change. This is a newfound concern for many NWRP members. Over the past decade when opportunities have risen to support climate action such as I-937, I-732, I-1641 and legislation (Clean Energy Transformation Act and Climate Commitment Act) more than a dozen NWRP member organizations went on record opposing the initiatives. Most opposed, and none are on record, supporting the legislation passed by the Washington legislature. The loudly voiced concerns by NWRP and its members ring hollow. It is also worth noting that a majority of public power members of the NWRP have a long history of getting the big issues wrong. The utilities that have financed the NWRP media ads were early and enthusiastic supporters, along with BPA, of the WPPSS nuclear program. This program resulted in the largest municipal bond default in America’s history up to that time, saddling BPA and its ratepayers with large rate increases to pay for plants that were never built (or needed). Indeed, BPA and its ratepayers are still paying for this failed effort. Similarly, these same utilities, businesses and BPA have supported the failed and failing salmon recovery plans that have kept the fish at the brink of extinction. And, as we know the courts have rejected these plans as inadequate and illegal multiple times. We also now know that the reservoirs themselves are a source of greenhouse gases and thus and not a carbon free resource as claimed by some (see, A new modelling framework to assess biogenic GHG emissions from reservoirs: The G-res tool, Sept. 2021). Now they are claiming we can’t replace the power without risks to climate action. Decision-makers should take a dim view of these assertions given their record of getting the big issues wrong.
The good news is that we can indeed replace the power from the dams and provide alternative transportation for moving crops to market with little or no impact on climate. The NWEC study shows a portfolio of renewable power, energy efficiency, demand response and batteries can replace the power and related services from the dams with little climate impact. Moreover, recent state and federal policies will also be rapidly decarbonizing the western grid. The recent Grain Transportation Study by Miguel Jaller prepared for American Rivers and the Water Foundation shows that moving grain by truck and rail rather than truck and barge results in either very modest increase in carbon, or equally likely a modest decrease in carbon emissions. As an indication of what may be possible as we shift away from barging on the lower Snake River the LSR Barge Replacement by Railroad report developed by Solutionary Rail provides a good compilation of information.
As mentioned previously climate action must occur on two fronts. We have to decarbonize both the electric system and the economy as a whole. We must also restore ecosystem resiliency where possible. Both are important. Removing the four lower Snake River dams is the single biggest step we can take to restore abundant salmon runs on the west coast and an essential action to restore ecosystem resilience to the Columbia Basin.
Again, we appreciate the systematic and comprehensive compilation and representation of benefits from the lower Snake River dams and the identifying of measures and actions that enable us to replace those services. It is clear that we can replace these services or mitigate the impacts of breaching the dams affordably and with currently available technologies, measures and strategies. It is critical that we now make the decision to breach the dams and make the investments that are needed. This is a once in a life-time opportunity to avoid extinction and achieve salmon recovery that will assure that generations to come will benefit from this rich heritage. It is imperative that we act and honor our treaties with the tribes. Thank you for the good work providing a solid foundation of information that shows the way forward.
Bill Arthur, Chair
Sierra Club Snake River Salmon Campaign
Marc Sullivan, Vice Chair
Washington Chapter Sierra Club