Comments on 2006 Fish Passage Plan
Letter to  Rex Baxter, USACE - Walla Walla District
Tuesday, January 17, 2006
By Terry Flores, Director, Northwest RiverPartners

Thank you for the opportunity to comment on the U.S. Army Corps of Engineers (Corps) 2006 Fish Passage Plan (FPP). Northwest RiverPartners is a partnership of farmers, electric utilities and large and small businesses in the Pacific Northwest, joined together to ensure that the Columbia and Snake Rivers remain living, working rivers.

We propose the Federal Columbia River Power System (FCRPS) be operated in a manner that provides residents with clean and affordable electricity, irrigation for our farm lands, healthy fish and wildlife, maritime trade, and a multitude of recreational opportunities. We urge the Corps to assess the efficacy of all fish protection operations at FCRPS facilities to assure actions taken demonstrate a measurable biological benefit. In addition, where alternatives exist, the Corps should implement the most cost effective measures available.

Bonneville Dam

On average from 1996 to 2005, fewer than 50 adult steelhead have passed the Bonneville Dam per day from December 1 through February 28. According to Section 2.2.3 of the FPP, water is spilled adjacent to fish ladders to provide adult attraction. At current market prices, this spill costs Bonneville Power Administration (BPA) ratepayers approximately $12,000 to $14,000 per day in lost generation, or over $1.0 million over the 3 month period. Also, it does not appear that this spill operation occurs at any of the other Lower Columbia River or Lower Snake River dams. We urge the Corps to reassess the need for attraction flows at Bonneville Dam from December 1 through February 28.

The Dalles Dam

In 2005, Corps biologists estimated that spill through the ice and trash sluiceway (ITS) in November demonstrated a benefit of 2 to 3 additional adult chinook salmon returning to the Columbia River at a cost to BPA ratepayers of $900,000 to $1,036,000. As a result, the Corps chose to end spill through the ITS on October 31. However, in the 2006, the FPP proposed to continue spilling through the ITS through November 2006. Please refer to Section 2.4.1.2.e of the FPP. We strongly urge the Corps to stand by its decision last year and end spill through the ITS on October 31, 2006.

Ice Harbor Dam

The new Removable Spillway Weir (RSW) at Ice Harbor Dam is proposed to be tested this year. We urge the Corps to operate Ice Harbor Dam RSW in a manner similar to the operation of the RSW at Lower Granite Dam which proved to be very successful in providing safe fish passage. Specifically, when the initial testing of the RSW at Ice Harbor shows it is doing well and fish are passing safely, the RSW at Ice Harbor Dam should be operated 24 hours per day, rather than at full project spill through the season.

We appreciate the difficulty of balancing the many competing interests while operating the FCRPS dams for their authorized purposes. However, with the vastly increasing cost of generation resulting from the ongoing litigation of the Biological Opinion, the BPA customers and other user groups urge the Corps to aggressively pursue dam operations that are both biologically effective and cost efficient. Please contact me if you have questions regarding these comments.