Study: U.S. Would Lose Over $2.3 Billion by Breaching Lower Snake River Dams (Pacific Northwest Waterways Association)

Loss of dams would also significantly increase carbon emissions and impacts to fragile economies

(PORTLAND, OR) – The removal of four lower Snake River dams would cost the U.S. over $2.3 billion over the next 30 years, lead to significant additional carbon emissions that contribute to climate change, and jeopardize health, safety and livelihoods in already economically fragile local and regional economies, according to an independent evaluation commissioned by the Pacific Northwest Waterways Association.

The study was performed by financial and economic consultants FCS Group to assess several impacts that would result if barging on the Snake River is lost. Significant additional effects due to the loss of hydropower, irrigation and other authorized uses would also occur, but are not captured in this targeted report.

Carbon emissions equivalent to the cumulative emissions generated by a Boardman coal-fired power plant every 5-6 years would result. Breaching the Snake River dams would cause diesel fuel consumption to increase by nearly 5 million gallons per year as barges are replaced by less efficient truck-to-rail shipments. At least 201 additional unit trains and 23.8 million miles in additional trucking activity would be required annually, resulting in increases in CO2 and other harmful emissions by over 1.2 million tons per year.

Transportation and storage expense will likely increase 50% to 100% for grain suppliers and shippers. At the current reported “break even” cost per bushel of $5.00, the transportation/storage cost is now approximately $0.40 per bushel of wheat. These costs could increase by up to $0.80 per bushel with barging removed as a transportation option.

If farm subsidies are not increased, over 1,100 farms may be at risk of bankruptcy. Average regional net farm cash income was only $42,825 in 2017. With wheat prices already down near the break-even point, the federal government would need to increase annual direct payments to farmers by up to $38.8 million to maintain current income levels.

Highway, rail and grain elevator networks would need over $1.6 billion in capital investment. If barging were removed from the Snake River, new infrastructure or costly upgrades would be needed to accommodate the displaced cargo. This includes hundreds of miles of shortline rail track that have been abandoned, new rail, major highway improvements, and retrofits for grain elevators that do not have rail loading capabilities.

Essential health, sanitation and safety would be jeopardized, along with other public services. As observed in the 1992 Snake River drawdown experiment, existing wastewater infrastructure is likely to be damaged or rendered useless if the river level drops, requiring new investments in water intakes, filtration and pumping/transmission systems for a number of cities, counties and major industrial businesses. Roadways, public docks and other infrastructure that are adjacent to the river would also be damaged or rendered useless. Safety is also a major concern, with additional rail and truck traffic leading to corresponding increases in accidents and fatalities.

The impacts would be socially unjust and target fragile economies. The 10 counties most impacted by a dam breaching scenario are primarily rural areas in which 1 in 5 people are already at or below the federal poverty level, and average wages are 25% below the national average. Dam breaching would have a negative regional economic impact on agriculture, manufacturing, transportation, warehousing and tourism businesses that are physically or functionally related to freight movement and river access.

“Dam breaching extremists talk about how easy and inexpensive it would be to compensate Washington, Oregon and Idaho businesses and residents if the lower Snake River dams were removed,” said PNWA Executive Director Kristin Meira. “We commissioned this study to show federal and state decision makers the real economic and environmental impacts on real people and communities that would result.”

The complete study is available on the PNWA website at https://www.pnwa.net/energy-salmon/.

WPUDA's George Caan Tapped to Serve on Energy Strategy Advisory Committee (Washington PUD Association)

(OLYMPIA, WA) -- Washington PUD Association Executive Director, George Caan, was selected to serve on the State Energy Strategy Advisory Committee. The Committee was established by the Clean Energy Transformation Act of 2019 (CETA) to work with the State Department of Commerce in updating the state's energy strategy.

CETA requires Commerce to review the state energy strategy by the end of 2020 and at least once every eight years thereafter. 

The committee will provide guidance to the department in conducting the review and includes representatives from utilities, energy users, the cities and counties, tribes, the clean energy industry, labor unions, civic organizations, environmental organizations, independent power producers, the Utilities and Transportation Commission, the Power Planning Council, and the two largest caucuses of the Senate. 

The committee will provide advice and recommendations for revisions to the energy strategy which the Department of Commerce will use in developing a written report to be submitted to the Governor and appropriate legislative committees. 

The committee will hold its first meeting on January 10th in SeaTac.  

Temporary Speed Limit Reduction Comes to SR 3 Near Belfair (Washington State Department of Transportation)

(BELFAIR, WA) – Travelers will soon notice new speed limit signs on State Route 3 near Belfair in Mason County. 

The Washington State Department of Transportation will temporarily reduce the speed limit from 50 mph to 35 mph and 25 mph between milepost 27.2 and 28.6 in advance of Mason Transit’s construction project.

The speed limit reduction is located in a roughly one-mile work zone where crews working for Mason Transit will build the SR 3/Log Yard roundabout and park and ride project.

The reduced speed limit will remain in place through project completion. The lowered speed limit is enforceable when signs are posted.

Pacific Northwest Waterways Association Weighs in on Snake River Stakeholder Process (Pacific Northwest Waterways Association)

(PORTLAND, OR) – The Pacific Northwest Waterways Association (PNWA) is weighing in on the Lower Snake River Dams Stakeholder Process draft report commissioned by the Washington State Governor’s Office, funded by the State Legislature, and made available today for public review and comment. This dam breaching report was one of the more controversial recommendations from the Southern Resident Killer Whale Task Force and did not have unanimous support from the group.

“This draft report on the Lower Snake River Dams Stakeholder Process was produced with Washington taxpayer funding, which could have gone toward activities that directly benefit salmon and orcas. While we appreciate the diligence of the consultants leading this process in reaching out to PNWA members and other stakeholders, the product that was commissioned by the State is essentially a status report of river operations followed by a survey of opinions – not science-based salmon recovery,” said Kristin Meira, executive director for PNWA.

“Federal agencies are already studying salmon and the river system and will have a draft report for the region to review in February. This Columbia River System Operations Environmental Impact Statement is based in science, complies with National Environmental Policy Act, and includes opportunities for citizen review as well as significant collaboration with cooperating agencies like Northwest tribes and states – including the State of Washington,” said Meira. “The CRSO EIS will include an evaluation of the Snake River dams, including an economic impact analysis with stakeholder input.”

As conversations continue in the region and the federal study process moves forward, PNWA's members will continue to support clean renewable hydropower, efficient barge transportation, and science-based salmon recovery.

Did you know?

Each Snake River dam has a navigation lock that allows cargo to move by water. The Snake River has had remarkably stable tonnage levels in the past 10 years. In 2017 alone, over 3.5 million tons of cargo were barged on the Snake River. It would have taken over 35,140 rail cars to carry this cargo, or over 135,000 semi-trucks. The Snake River is particularly important to our Northwest wheat farmers. The Snake River dams make it possible for nearly 10% of all U.S. wheat exports to move in the safest, lowest emission type of cargo transportation – barging.

Hydropower is a reliable, renewable domestic power source that produces no greenhouse gas emissions and provides nearly 60% of our region's electricity. The Snake River dams are key contributors to the Northwest energy profile and make it possible for intermittent renewables like wind and solar to integrate into our system. The lower Snake River dams are some of the most reliable and lowest-cost electricity sources of the 31 federal dams from which the Bonneville Power Administration markets power.

Salmon recovery in the Pacific Northwest is a collaborative effort by federal and state agencies, tribes, utilities, and countless other entities. Together we all work to address the many ways a salmon's life cycle can be affected by humans: Hydropower, hatcheries, habitat, and harvest. Ocean conditions also play a major role in salmon health, in addition to significant impact from predators like birds, sea lions, and other fish. Major improvements have been made in fish ladders, dam design, optimized river flow and habitat restoration, resulting in steady improvements to salmon runs. Juvenile fish survival rates past each of the eight federal dams are now between 95 and 98 percent.

The Pacific Northwest Waterways Association is a non-profit trade association of ports, businesses, public agencies and individuals who support navigation, energy, trade and economic development throughout the Pacific Northwest.

U.S. Senator Gillibrand Urges Dam Safety Initiative (Politico Morning Energy)

U.S. Senator Kirsten Gillibrand, NY (D)

(WASHINGTON, DC) -- New York Sen. Kirsten Gillibrand wants Congress to address aging dams across the country following a report last month from the Associated Press that found more than 1,500 U.S. dams classified as high-hazard. Gillibrand, a member of the Environment and Public Works Committee, wrote to committee leaders John Barrasso and Tom Carper to urge them to "proactively address dam safety" in the Water Resources Development Act for 2020.

Columbia River Operators Increase Flows to Welcome Returning Chum Salmon (Bonneville Power Administration)

(PORTLAND, OR) -- Sometimes being underwater is a good thing, especially for Columbia River salmon nests, called redds. This fall, federal agencies have increased Columbia River flows below Bonneville Lock and Dam to ensure the redds of spawning chum salmon stay covered with water. The agencies have conducted these chum operations every fall since 2000.

Beginning in November, the U.S. Army Corps of Engineers holds the Columbia River below Bonneville Dam to between 11.5 and 13 feet above sea level to ensure chum can spawn at the mouth of Hamilton Creek in the Columbia River Gorge. For chum operations to occur, water is released from reservoirs as far away as Hungry Horse and Libby dams in Montana, more than 850 river-miles upriver from Bonneville Dam. The water is then captured and released as needed to keep the redds underwater.

“Chum are listed under the federal Endangered Species Act and they’re an important part of the ecosystem,” says Scott Armentrout, BPA vice president of Environment Fish and Wildlife.  “This operation is just one of the things we do with our federal partners to support this critical species.”

The annual run of Columbia River chum salmon historically numbered more than 1 million. However, habitat loss, harvest, and other factors caused their numbers to plummet during the last century to a low of just a few thousand fish returning to the river each year. An important ecological species and food for mammals such as whales, the federal government listed Columbia River chum as threatened under the Endangered Species Act in 1999.

Called “dog” salmon because of their canine-like teeth, chum are the last salmon of the year to return to the Columbia to spawn, and their young are the first to leave for the ocean in the spring. Chum salmon generally spawn in the lower part of the Columbia River below Bonneville Dam in areas where warm groundwater pushes up through gravel. The warm water then quickly incubates their eggs.

The Bonneville Power Administration has funded two hatchery programs and constructed new spawning habitat for chum in several areas of the lower Columbia River. These efforts appear to be showing signs of success: More than 45,000 chum returned to the Columbia in 2016 and scientists say 2019 shows signs of a good return as well.

Pacific Northwest Utilities Tap the Feds on Vegetation Management Within and Along Powerline Rights-of-Way (Northwest Public Power Association)

November 25, 2019

Daniel James Jiron

Acting Deputy Under Secretary, Natural Resources and Environment

USDA Forest Service

201 14^th Street SW, Mailstop 1124                                                                             

Washington, DC  20250-1125

Re: Docket Number FS-2019-0019; Procedures for Operating Plans and Agreements for Vegetation Management Within and Along Powerline Rights-of-Way

Dear Mr. Jiron:

Pursuant to the Federal Register notice published at 84 FR 50698, the western electric utility organizations[1] respectfully provide joint comments on the U.S. Forest Service’s proposed rule to update its vegetation management regulations in section 512 of the Federal Land Policy and Management Act of 1976 (the Act). 

We are trade associations and joint action agencies representing over 155 electric utilities in the Western United States and Canada.  In the United States, our members include electric utilities in Alaska, California, Idaho, Montana, Nevada, Utah, Wyoming, Oregon, and Washington.

In order to provide retail electric service to their communities, our utility members operate electric facilities on or near U.S. Forest Service lands.  In all cases, these utilities are responsible for ensuring that rights-of-way (ROW) are clear of vegetation that could potentially encounter electric transmission and distribution lines for the safe and reliable operation of electric systems.  Challenges arise when approval of special use authorizations to implement integrated vegetation management on or near ROW are delayed, when application of standards for approving such work are inconsistently applied, or when requests to cut hazard trees that are in danger of falling onto ROW are held up or denied.  In addition to the serious impacts for human safety when wildfires occur, utilities are routinely held liable for fire suppression costs and damages resulting from vegetation encountering electric lines. 

We appreciate the U.S. Forest Service’s efforts to propose vegetation management regulations per the deadline set by Congress in the Act.  As you are aware, wildfires in western states pose a significant risk to the reliability of our members’ electric systems and to the safety of their employees and the communities they serve.  In fact, liability for catastrophic wildfires represents the largest financial risk for many of our electric utility members. As a result, we were outspoken advocates of congressional efforts to improve the federal process for approving special use authorizations for management of hazardous trees and vegetation on or near ROW, and the limitation on liability for fire suppression costs contained in the Act.  Our members have highly anticipated these proposed regulations and believe, if implemented as intended by Congress, these rules will play a significant role in protecting electric systems and our nation’s forests and grasslands from wildfires.  

With that in mind, it is imperative that the U.S. Forest Service implement its new authority in the following manner.

1.  Regulations and Guidelines must closely align with the primary intent of the underlying law.  House Report 115-165 filed by the House Natural Resources Committee contains clear objectives for this vegetation management law.  The report states that the legislation “seeks to reduce such wildfires, in part, by promoting federal consistency, accountability, and timely decision-making as it relates to protecting electricity transmission and distribution lines on some federal lands from hazard trees.”  Therefore, in implementing this law, it is imperative that the U.S. Forest Service establish procedures with robust timelines and milestones that promote efficiency, accountability, and consistency in approving special use authorizations to manage vegetation on ROW, facilitate coordination between federal land managers and ROW owner/operators, and promote responsible management of USFS lands that are immediately adjacent to ROWs to enable operators to address hazard trees and fuel loads on federal lands that are a threat to infrastructure within and adjacent to the ROW. 

2. Prioritize establishment of joint guidelines with the Bureau of Land Management as mandated under the Act.  In section 512(b) of the Act, Congress mandated “the Secretary[s] . . . shall issue and periodically update guidance to ensure that provisions are appropriately developed and implemented for utility vegetation management, facility inspections, and operation and maintenance of rights-of-way . . .”  These guidelines must eliminate or minimize the need for case-by-case approvals for routine operations and for utility vegetation management activities that are necessary to control hazard trees.  Delays in development of these guidelines will delay development and approvals of vegetation management plans, threatening the safe operation of electric systems and the prevention of wildfires. 

3. Establish a culture at the U.S. Forest Service that prioritizes review of utility vegetation management plans and collaboration with ROW operators.  Often, our members find various inconsistencies working with federal agency personnel, as outcomes vary based on individual federal employees’ decisions and timelines.  For example, a single utility that provides service in an area overseen by two separate district offices may receive differing guidance and cooperation in approving special use authorizations for utility management of vegetation on or near the utility’s ROW.  In other instances, decision making is delayed while in other locations, decisions are made in a more reasonable and timely manner. Establishing a culture within the U.S. Forest Service that prioritizes review of vegetation management plans and collaboration with ROW operators will aid in the timely review and approval of those plans and the safe operation of electric systems.

4. Implement tools provided by Congress including use of categorial exclusions to NEPA and a training program for agency staff.  We also urge full implementation of the tools Congress provided to the U.S. Forest Service in the Act including use of categorical exclusions for routine and regular work on or near ROW, and development of a training program for agency staff involved in vegetation management decisions.

The U.S. Congress provided the U.S. Forest Service with discretion to identify categories of actions for exclusion from the National Environmental Policy Act (NEPA) in section 512(c)(5) of the Act.  We support implementation of the agency’s discretion to categorically exclude actions in development of vegetation management plans and in implementation of those plans from NEPA.  Actions such as routine vegetation management, hazard tree removal, and operations and maintenance of electrical equipment on ROW should fall within the agency’s discretion to categorically exclude from NEPA. 

Training agency staff is another tool encouraged by the U.S. Congress in section 512(i) of the Act.  Delays in approval of special use authorizations for vegetation management on or near ROW often occur due to frequent agency staff turnover.  Frequent turnover results in loss of experience and expertise on the issue. Use of this important training tool in consultation with electric utilities and sharing of utility employees with federal agencies to help educate agency staff on reliability standards and requirements in maintaining and operating distribution and transmission lines in ROW can help meet the goals of the Act for a more efficient, consistent and timely approval of integrated utility vegetation management plans.

Finally, the Act, if implemented as intended, will authorize two important provisions: efficient removal of trees identified as hazards (Section 512(c)); and, limitations on liability for ROW owners/operators (Section 512(g)).   A key provision of the Act was a process by which ROW owners/operators can identify hazard trees – trees that are dead or likely to fail and cause substantial damage or disruption of electrical systems and take action to remove that tree while notifying the U.S. Forest Service.  This provision is vital to quick and decisive action to protect electric systems, prevent wildfires and ensure public safety.  The Act also provides reasonable liability limits for damages that may result from activities conducted in accordance with the operation and maintenance plans established and submitted pursuant to this Act.  Utilities, and ultimately their customers, bear the cost of maintaining ROWs as well as the cost of liability for damages.  Limiting strict liability for utilities is a key to success as it empowers ROW owners/operators to remove hazardous trees and quickly address other urgent threats to power lines in order to avert potential crises.

Our members are environmental stewards who support responsible forest management because they are led by people who live in the communities served.  Many are in areas that have seen devastating wildfires in recent years and are actively engaged in ROW management to reduce this threat.  We support the various elements of this rulemaking that will provide more uniform guidelines for operating and maintaining utility ROWs on federal land, that will establish a process to enable our members to address emergency hazards quickly and effectively, and that will fully implement the limitations on strict liability established in the Act. 

We look forward to working with the U.S. Forest Service towards a more efficient and consistent vegetation management program that ensures the safe and reliable operation of the electric utility system and prevents wildfires on our nation’s lands. 

Sincerely,

Scott Corwin

Executive Director

Northwest Public Power Association

on behalf of NWPPA and

Utah Associated Municipal Power Systems

Northern California Power Agency

Washington Rural Electric Cooperative Association

Oregon Rural Electric Cooperative Association

Oregon Municipal Electric Utilities Association

Wyoming Rural Electric Association

Montana Electric Cooperatives’ Association

Golden State Power Cooperative

Nevada Rural Electric Association

Alaska Power Association

Idaho Consumer-Owned Utilities Association

Oregon People’s Utility District Association

California Municipal Utilities Association

Washington Public Utility Districts Association

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[1] Northwest Public Power Association, Utah Associated Municipal Power Systems, Northern California Power Agency, Washington Rural Electric Cooperative Association, Oregon Rural Electric Cooperative Association, Oregon Municipal Electric Utilities Association, Wyoming Rural Electric Association, Montana Electric Cooperative Association, Golden State Power Cooperative, Nevada Rural Electric Association, Alaska Power Association, Idaho Consumer-Owned Utilities Association, California Municipal Utility Association, Oregon People’s Utility District Association, Washington Public Utility District Association.