Comments On Corps’ Draft EIS for 13 Willamette Valley Dams Question Whether Plan Avoids Jeopardy For ESA-Listed Salmonids
A massive 2,000 page draft environmental impact statement on how Willamette River Valley dams impact threatened salmon, steelhead and bull trout is flawed and does not address one of its own primary goals, which is meeting obligations under the Endangered Species Act to avoid jeopardizing the existence of listed species, according to several groups and agencies that submitted comments to the U.S. Army Corps of Engineers in late February.
The Willamette River is 180 miles long and drains 11,487 square miles or nearly 12 percent of the state of Oregon. It meets the Columbia River at Portland. Today, over 70 percent of Oregonians live in the Willamette River basin.
Comments on the draft EIS ranged from a need for year-round deep drawdowns at some of the Corps’ 13 Willamette Project dams, to removal of two reregulating dams, to reconnecting downstream flood plains and side channels, to providing better up and downstream passage for bull trout and to de-authorizing hydropower.
The Public Power Council is concerned that among the Corps’ alternatives (there are eight) in its DEIS there is no “path for maintaining economic hydropower production in the Willamette Valley System.”
PPC said the Corps’ analysis shows “massive costs to regional ratepayers, but as described further in these comments, even these costs are likely to be drastically understated. This concern highlights the importance of the Corps’ fulfilling in a timely manner its Congressional mandate from the 2022 Washington Resources Development Act (WRDA) that directs the Corps to conduct disposition studies for power de-authorization of the Willamette Valley System.”
Both PPC and the Native Fish Society have since 2021 proposed federal legislation to study de-authorizing generation at the Corps’ Willamette dams. A joint OP-ED in the Eugene Register-Guard in June 2021, said that de-authorizing the dams’ requirement to produce power would help restore fisheries in the basin and it could reduce Bonneville Power Administration wholesale power rates.
In their recent comments, the groups, along with the state of Oregon, say the Corps should complete its studies for power de-authorization in time for it to be a part of the final EIS, which is due to be completed in 2024. The Corps has said it will complete the studies in 2026, two years after completing the EIS.
The Native Fish Society, Wild Earth Guardians and the Northwest Environmental Defense Center consider a congressional de-authorization of hydropower generation at the dams as a way to free up water for wild upper Willamette River spring Chinook, wild winter steelhead and bull trout, all listed as threatened under the federal Endangered Species Act.
In joint comments, the three conservation groups called on the Corps to provide a broader range of measures, such as year-round deep drawdowns at the dams to aid juvenile salmon migrating downstream, improving fish passage survival at the dams, earlier spill at Detroit Dam on the South Santiam River, and removal of Big Cliff (South Santiam) and Dexter (Middle Fork Willamette) re-regulating dams. All would require more water and result in less or no generation at many of the dams, but the suggested actions would also mean the Corps would have to complete its generation studies in time to include the results in the final EIS.
The draft EIS does not avoid jeopardizing the continued existence of ESA-listed species,” the groups said in their comments.
“The Corps rejected any measure that would eliminate or abandon hydropower based on their interpretation that this secondary purpose of the WVP was inviolable; even if the primary purpose of flood control was not jeopardized. Therefore, options that might remove some hydropower capacity while still allowing flood control and providing a high likelihood of recovering populations were not considered, developed, or evaluated,” the groups said.
As an example, they said the Middle Fork Willamette has the greatest potential for salmon recovery (and bull trout) because it contains a large area of high quality habitat that currently lacks upstream and downstream access.
“Removal of Dexter Dam, modification of Lookout Point Dam to allow evacuation of the reservoir and passive passage of juvenile and adult fish, and modification of Hills Creek Dam to provide upstream and downstream passage would have a high likelihood of meeting fish conservation and recovery objectives.” they said.
The impetus behind the DEIS is a March 2018 lawsuit in federal district court in Eugene, OR, by conservation organizations. Plaintiffs Northwest Environmental Defense Center, Wild Earth Guardians and Native Fish Society, represented by attorneys at Advocates for the West, asked the court to force the two federal agencies – the Corps and NOAA Fisheries – to reevaluate the impacts of the Corps’ Willamette Valley dams on the threatened fish, to reinitiate consultation and to make immediate operational adjustments to dams on four tributaries of the Willamette River (North Santiam, South Santiam, McKenzie and Middle Fork Willamette) that the groups say block between 40 and 90 percent of spawning habitat.
The last biological opinion by NOAA Fisheries of the Willamette River dams’ operations was in 2008. However, when the lawsuit was filed 10 years after the BiOp had been released, many of the actions required by the BiOp’s reasonable and prudent alternative had not been implemented by the Corps. The RPA is composed of a suite of alternatives that, if implemented, would be expected to not jeopardize the continued existence of the threatened fish.
Four agencies in Oregon pointed out that the Corps largely failed to implement “the most significant actions (downstream passage) from the 2008 BiOp that are necessary to halt the decline of these populations (the three threatened populations of salmon, steelhead and bull trout). Continued inaction or delayed action is not acceptable.”
The four Oregon agencies are Fish and Wildlife, Environmental Quality, Agriculture and Water Resources.
Oregon said its agencies are “united in expressing concern for the fate of the listed salmon, steelhead, and bull trout in the Willamette Basin and the urgent need for the USACE to take actions to secure their future. The long-term persistence of these populations is vital to the social, cultural, and economic health of the State. That persistence continues to be threatened by the ongoing operation of the Willamette Valley System.”
NOAA Fisheries in its comments said that while the Corps “has provided targets (the quantitative metrics that define success) for many of the Preferred Alternative actions, the targets do not track or respond to effects on fish.”
For example, it said, changes in flows are evaluated by whether they are above or below the new target for minimum flows.
“Some effects on fish would be missed given warming trends in the Willamette, likely exacerbated by lower flows during spawner migration,” NOAA said in its comments to the Corps. “Other effects from shifting migration cues are also missed.”
In addition, changes in temperatures are measured by the percentage change in temperature, “which doesn’t capture the risk of temperatures over thresholds, leading to higher mortality.”
The Native Fish Society also asked for:
• Additional operations and project modifications to reduce Total Dissolved Gas;
• Additional measures that implement improvements to regulating outlets to improve their effectiveness as passage routes;
• Reassessment of downstream passage and water quality measures at Detroit Dam, Hills Creek Dam, and Lookout Point Dam in the context of removal, modification, and/or run-of-river operations at Big Cliff and Dexter dams.
• A commitment to continue funding and making the interim measures called out in the Injunctive Order in Northwest Environmental Defense Center, et al. v. United States Army Corps of Engineers, et al until there is a reasonable confidence that “their performance can be equaled or exceeded by new structural measures;
• Dam operations that will improve degraded habitat downstream of dams, including a program of revetment removal, relocation, and modification to increase floodplain connectivity and side-channel habitat in the tributaries and mainstem Willamette River.
Both Oregon and the Native Fish Society asked the Corps for:
• More robust Research, Monitoring, and Evaluation and adaptive management plans that include a broader range of evaluation and performance metrics to ensure that operation of the Willamette Valley dams does not continue to jeopardize listed species or adversely affect their critical habitats.
• More robust passage measures for Hills Creek dam, including measures that support movement of bull trout. The Corps’ plan, according to the two commenters, provide for downstream passage for adult bull trout, but no plan for their return upstream.
• Prioritization at all projects for volitional downstream passage.
The Willamette Valley System EIS website is here.
For fish, the alternative the Corps’ preferred alternative (not the chosen alternative yet; that comes with the final EIS in the spring of 2024) includes both structural and operational measures that, taken as a whole, prove to be best for the ESA-listed threatened wild upper Willamette River spring Chinook and winter steelhead, according to the draft EIS. The preferred alternative (alterative 5) rates high when compared with the other alternatives in terms of viable salmonid population (VSP) metrics, as well as performing well against other alternatives in passage efficiency for juveniles at the dams and their survival through the dams, the draft EIS says.
Alternative 5’s overall focus, according to the Corps’ Kathy Warner, Water Supply Specialist in the agency’s Reservoir Regulation and Water Quality Section and technical lead for the EIS, is:
• Improve fish passage with a combination of modified operations and structural improvements;
• Provide measures that balance water management flexibility while meeting ESA-listed fish obligations.
The preferred alternative includes:
• Floating Screen Structure and Temperature Control Tower at Detroit
• Adult fish facility at Green Peter Dam
• Spring and fall draw down to Diversion Tunnel at Cougar Dam
• Floating Surface Collector at Lookout Point
• Pacific lamprey passage and infrastructure
• Integrated Habitat and temperature flow regime
In more detail by river, alternative 5 measures include:
North Santiam (Detroit and Big Cliff dams)
•Detroit spring/summer spill for downstream fish passage and water temperature management
•Detroit fall lower regulating outlet (RO) for downstream water temperature management
•Detroit winter upper RO for downstream fish passage
•Big Cliff spread spill to reduce TDG
South Santiam River (Green Peter and Foster dams)
•Green Peter spring spill for downstream fish passage
•Green Peter fall deep drawdown for downstream fish passage through ROs
•Foster spring delayed refill and spill for downstream fish passage
•Foster fall spill for downstream fish passage
McKenzie River (Cougar Dam)
•Fall drawdown for downstream fish passage through ROs
•Spring delayed refill for downstream fish passage through ROs
Middle Fork Willamette River (Lookout Point, Dexter and Fall Creek dams)
•Hills Creek winter night-time RO prioritization for fish passage
•Lookout Point/Dexter spring/summer spill for downstream fish passage and water temperature management
•Lookout Point fall deep drawdown for downstream fish passage through ROs
•Fall Creek extended winter deep drawdown for downstream fish passage
•Fall Creek spring delayed refill for downstream fish
The Corps’ Willamette Valley System consists of 13 reservoirs, encompass 11 multiple purposes with 2 re-regulating dams and 8 hydropower dams. The dams were built between 1939 and 1969 and the last EIS was in 1980. Most of the dams are “high head” dams, over 250 feet tall and as a result, the Project blocks about 70 percent of Chinook and 33 percent of steelhead historic habitat in the upper Willamette basin while also modifying downstream habitat, the DEIS says.
The WVS also includes five fish hatcheries, a Willamette bank protection program and 100 miles of revetments (bank support and changes). The WVS provides approximately $1 billion in annual flood risk benefits, 26 million in hydropower revenue, and 5.4 million in recreation benefits, the EIS says.
For background, see:
— CBB, March 9, 2023, SCIENCE PANEL GIVES THUMBS-UP ON FISH RESPONSE MODELS CORPS USED TO DEVELOP DRAFT WILLAMETTE RIVER BASIN EIS, HTTPS://CBBULLETIN.COM/SCIENCE-PANEL-GIVES-THUMBS-UP-ON-FISH-RESPONSE-MODELS-CORPS-USED-TO-DEVELOP-DRAFT-WILLAMETTE-RIVER-BASIN-EIS/
— CBB, December 2, 2022, CORPS RELEASES DRAFT EIS FOR 13 WILLAMETTE BASIN DAMS INTENDED TO AID ESA-LISTED SALMON, STEELHEAD; DRAWDOWNS, STRUCTURAL CHANGES, LESS POWER, HTTPS://CBBULLETIN.COM/CORPS-RELEASES-DRAFT-EIS-FOR-13-WILLAMETTE-BASIN-DAMS-INTENDED-TO-AID-ESA-LISTED-SALMON-STEELHEAD-DRAWDOWNS-STRUCTURAL-CHANGES-LESS-POWER/
— CBB, February 24, 2022, CORPS DETAILS TO COUNCIL NUMEROUS MEASURES TAKEN AT WILLAMETTE PROJECTS TO AVOID JEOPARDIZING LISTED SALMON, STEELHEAD, HTTPS://CBBULLETIN.COM/CORPS-DETAILS-TO-COUNCIL-NUMEROUS-MEASURES-TAKEN-AT-WILLAMETTE-PROJECTS-TO-AVOID-JEOPARDIZING-LISTED-SALMON-STEELHEAD/
— CBB, September 2, 2021, JUDGE ISSUES FINAL ORDER FOR OPERATIONS AT CORPS’ WILLAMETTE VALLEY DAMS TO AID ESA SALMON, STEELHEAD; DEEP DRAWDOWNS, SPILL, HTTPS://CBBULLETIN.COM/JUDGE-ISSUE-FINAL-ORDER-FOR-OPERATIONS-AT-CORPS-WILLAMETTE-VALLEY-DAMS-TO-AID-ESA-SALMON-STEELHEAD-DEEP-DRAWDOWNS-SPILL/
— See CBB, July 15, 2021, “Federal Judge Orders Corps To Take Immediate Action To Protect ESA-Listed Willamette Valley Wild Spring Chinook, Steelhead; ‘No Patience For Further Delay,’” https://columbiabasinbulletin.org/federal-judge-orders-corps-to-take-immediate-action-to-protect-esa-listed-willamette-valley-wild-spring-chinook-steelhead-no-patience-for-further-delay/
— CBB, August 26, 2021, “Willamette River Reservoirs Far Below Average As Parties Move Forward On Court-Ordered Interim Measures To Address Listed Steelhead, Chinook,” https://columbiabasinbulletin.org/willamette-river-reservoirs-far-below-average-as-parties-move-forward-on-court-ordered-interim-measures-to-address-listed-steelhead-chinook/
— CBB, November 12, 2020, “Corps Modifies Operations At Willamette Valley Dam To Improve Juvenile Salmon Passage As Court Case Continues On ‘Remedies’ For Wild Salmon/Steelhead,” https://columbiabasinbulletin.org/corps-modifies-operations-at-willamette-valley-dam-to-improve-juvenile-salmon-passage-as-court-case-continues-on-remedies-for-wild-salmon-steelhead/
— CBB, August 19, 2020, “Federal Judge Rules Corps Not Moving Fast Enough To Halt Continued Decline of ESA-Listed Upper Willamette River Wild Spring Chinook/Steelhead; ‘Significant Measures Never Carried Out,’” https://columbiabasinbulletin.org/federal-judge-rules-corps-not-moving-fast-enough-to-halt-continued-decline-of-esa-listed-upper-willamette-river-wild-spring-chinook-steelhead-significant-measures-never-carried-out/
— CBB, November 21, 2019, “NOAA Says Corps’ Draft Proposal On Managing Willamette Dams/Reservoirs Likely To Jeopardize Salmon, Steelhead,” https://columbiabasinbulletin.org/noaa-says-corps-draft-proposal-on-managing-willamette-dams-reservoirs-likely-to-jeopardize-salmon-steelhead/
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