Grower comments needed on river operations EIS

The Columbia River System Operations draft environment impact statement (EIS), which was released on Feb. 28, reviewed and rejected breaching the four lower Snake River dams as the best alternative to restoring endangered salmon runs. Despite the apparent victory for agriculture, growers are still strongly encouraged to submit comments on the EIS concerning the importance of the dams to their life and livelihood.

The EIS and a link to submit comments are available at nwd.usace.army.mil/CRSO/

Released jointly by the U.S. Army Corps of Engineers, the Bonneville Power Administration and the Bureau of Reclamation, the report argued that modest changes to the Columbia River System would increase salmon survival while providing the least impact to electrical generation, transportation, greenhouse gas emissions and farmers' production costs.

"Despite the major benefits to fish expected from (breaching the lower Snake River dams), this alternative was not identified as the Preferred Alternative due to the adverse impacts to other resources such as transportation, power reliability and affordability and greenhouse gas emissions," the report said.

The Preferred Alternative comprises operational and structural measures that allow federal agencies to operate the integrated system to meet congressionally authorized purposes and EIS objectives, including those that benefit Endangered Species Act–listed species. In the executive summary, the preferred alternative calls for "... a flexible spill operation that spills more for fish passage when power generation is less valuable and spills less when power generation is more valuable."

The comment period runs from Feb. 28 to April 13. Responses to substantive comments will be included in the final EIS, expected in summer 2020. Records of decision documenting final recommended actions will be issued in September 2020.

The Pacific Northwest Waterways Association (PNWA) has published a guide to help growers submit their comments. It recommends comments be:

• Substantive. Comments should clearly explain how this issue directly affects you and/or your organization; identify what in the draft EIS is incorrect and/or incomplete; and provide information that allows the agencies to correct/complete it.

• Original. Comments must be unique to be counted in the EIS process. Identical form letters or petitions are grouped and considered and treated as one single comment.

• Shared publicly. While providing information during agencies' decision-making process is important, it is equally important that growers influence the public conversation about the value of the Northwest river system and the role the dams play in creating that value. We need to show that river system supporters are a broad and inclusive set of the electorate. To that end, growers are encouraged to post comments on websites and social media; share them with customers and constituents; write letters to the editor; and share your perspective whenever and wherever the opportunity presents.

The PNWA guide also provides talking points that growers can incorporate into their comments, including:

• The system's hydroelectric dams and locks provide us with clean affordable energy for our homes and businesses, irrigation water for agriculture and navigable waterways that ship goods to and from the farthest inland port in the country. The environmental effects of these economic benefits are managed with world-class investments that help maintain salmon populations and other ecological benefits.

• One barge with tow can ship the equivalent goods of 1.4 100-unit freight trains or 538 semi-trucks. These trains and trucks would congest our communities, increase greenhouse gas emissions and decrease air quality if we lose the system of dams and locks that enable barge shipments.

• Our economies are not prepared to function with the loss of barging on the Columbia and Snake rivers. Our highway, rail and grain elevator networks would need more than $1.1 billion in capital investments to adapt. 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.

• Our system of affordable and renewable hydroelectric power is the backbone that will support our new clean energy economy-providing reliable energy for our communities when wind and solar cannot. Ninety percent of the Northwest's renewable energy comes from hydroelectric dams.

To access PNWA's guide, visit pnwa.net/rivervalues/.

–Reprinted with permission from the Washington Association of Wheat Growers