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RE: Klamath River Dam Removal
Email from Glen Spain to Glen Brigs
June 30, 2009
Dear Glen Biggs....
Thanks for the detailed and thoughtful comments -- much more so than many I
receive -- so I owe you a similar response. Here are a few other facts for
your consideration. As a hard-headed engineer by training and trade, I am
sure you will find them interesting and be unable to ignore them in your
thinking like myself, even though they do disagree with some of your
premises. Facts are very annoying things to wish away, as any engineer knows
well, and are ignored at one's peril.
(1) All historical evidence is that spring and fall run chinook salmon and
steelhead were once abundant throughout the Upper Basin, including in the
Williamson and Sprague. See Hamilton, et al. (2005) attached for a peer
reviewed historical review of those facts. Coho did not occur, so far as we
know, above about the current position of J.C. Boyle because river gradients
are too steep (i.e., a natural barrier) but were common between the CopCo
dams and Iron Gate Dam until the 1960s when Iron Gate was constructed -- a
loss that was never mitigated by the way, contributing to their current ESA
listing. Chinook and steelhead, however, go much further up to the farthest
tributary they can get to and tolerate much steeper gradients.
(2) Best estimates we have from both historical record and habitat typing is
that the historical pre-European spawning runs of salmon in the Klamath
basin averaged about 880,000 annually, ranging from about 660,000 to 1.1
million. Most were chinook, with spring chinook predominating in the upper
basin co-existent with large runs of steelhead. Even today, nearly 600
stream-miles of once fully occupied salmonid spawning and rearing habitat
would be available, according to biologists expert in this field, if the
dams were removed and full volitional passage were possible. See Huntington
(2006) also attached. He estimates more than 100,000 additional salmon could
utilize that additional habitat, even under the currently degraded
conditions (which, by the way, numerous clean water TMDL programs are
working to clean up).
By the way, with that many fish carcasses from spawning runs, the mainstream
river water quality would have naturally been a little dicey while they were
decaying in some places. This would have been VERY good for many other
species if not man, enriching the river insect life enormously for the next
generation of emerging juveniles in a natural cycle we have largely
disrupted. But humans such as Gibbs think in human-centered terms, not in
terms of ecosystem benefits -- especially lawyers! Gibbs was obviously no
biologist.
The Gibbs story reminds me of the Lewis and Clark expedition, that had never
seen salmon before. One of them timidly tried it, and it was so rich a meat
(compared to their Army field rations at least) it made him sick (or so he
thought), so the rest of the expedition on his word and example considered
salmon to be poisonous and they all completely avoided eating salmon even
though this rich source of protein was all around them. Instead they traded
with the Columbia River tribes and bought pet dogs to eat. The Indians
thought they were stark raving nuts! History is often made of such
misunderstandings.
(3) The reservoirs themselves retain nutrients, they warm water to near
fatal levels for salmonids, encourage the growth of toxic algae (dangerous
to humans, including reservoir landowners as well as to fish), and create
MAJOR water quality problems far downriver. The FERC Final EIS is loaded
with pages and pages of analysis and documentation on these water quality
problems created by the dams themselves in their reservoirs. The FERC FEIS
also documents numerous other problems created by the dams for water quality
generally, which are killing off much of the lower river salmon runs
(heating and de-oxidizing the water, encouraging fish pathogens to multiply,
starving the lower river of spawning gravel recruitment, etc.). This should
be required reading in this debate. You can download it from the FERC
website www.ferc.gov, using the Docket Search function in the eLibrary under
Docket No. P-2082-027 -- the Klamath relicensing proceeding. The date is
Nov. 2007. Until you have read this, you will have few of the actual facts
to debate with and I will have you at an extreme disadvantage in these
discussions (grinning).
(3) There is no "status quo" here concerning the dams -- there are only two
choices facing PacifiCorp -- retrofit the dams to modern standards pursuant
to federal agency "mandatory prescriptions" (including fish passage) for a
new license, or abandon them entirely and invest elsewhere. Those are the
ONLY two choices legally available to the company, and both will cost a fair
bit of money. The only question is which is better economically and
environmentally.
(4) Several current engineering and cost analysis studies, including those
of the California Energy Commission (CEC) (which does power project cost
benefit analysis all the time) and one by FERC itself -- both of which know
a thing or three about dams -- say it will cost MUCH more money to retrofit
the dams and keep them (fish passage plus some 120 other mitigation measures
cost money) than to simply remove them and invest the money more wisely
elsewhere.
I attach a letter from the California Energy Commission itself to the Oregon
PUC (I presume you live in Oregon -- if not, they said the same thing to the
PUCs of CA and WA) which makes the strong case that PacifiCorp's customers
should not have to pay for keeping the dams because removing them and
reinvesting in something much more cost efficient elsewhere is by far the
best economic option -- and by $114 million cheaper. Plus mere fish passage
is likely to be ineffective, and keeping the dams does not really solve the
Clean Water Act problems the dams create.
Oh... as a capper FERC in its FEIS found that dam removal costs would be
about $79 million (as compared to $360 plus for FERC relicensing according
to the CEC) and that, even if licensed, the dams would still LOSE MONEY EACH
YEAR -- about $20 million per year -- and therefore were simply no longer
cost effective as dams (see FERC FEIS Table 4-3 on Page 4-2). In other
words, they are functionally and economically obsolete.
(5) Although several sediment studies have already been done, and although
they are not yet comprehensive, NO toxic sediment problems of any sort have
to date been discovered. Dioxins, for instance, are at natural background
levels. There are no heavy metals -- the upper basin was not mining
territory, nor heavily industrialized but a farming community.
There is also not anywhere as much sediment build up as once thought, making
it much less of a problem to simply wash sediment through naturally in a
season, with a little bank stabilization (normal procedure = planting grass
seed and trees) to help limit the silt. So far -- sediment is simply not a
problem. Several of those sediment and other studies have been collected on
a Yurok Tribe web site at:
http://www.yuroktribe.org/departments/fisheries/DamRemovalStudies.htm
Don't take my word for it, go to the sources. In any event, these
preliminary studies will be confirmed by much more detailed studies starting
this summer, under the NEPA process the Secretary of Interior will be going
through to make a final removal vs. relicensing decisions in March 2012.
(6) Finally... the four dams combined generate only a miniscule amount of
power by modern power plant standards -- only about 88 MW average over the
50-year lifetime of the last license according to FERC records. This
represents only about 1.5% of PacifiCorp's overall generation. Since the
capacity of one modern gas-fired power plant is between 800 to 1400 MW, you
see that PacifiCorp investing elsewhere in more efficient power plants makes
a lot of sense as a business decision.
Also, it is relatively easy for PacifiCorp to replace this minimal amount of
"green power" with equivalent green power elsewhere. When the company was
purchased by MidAmerican Energy Company a couple of years ago, the PUCs made
them promise to install an additional 1,200 MW of green power "renewables"
anyway over the next ten years. The mere 88 MW necessary to fully replace
the power from the dams is only a very small amount (7%) of what they plan
to do anyway.
One modern wind farm, by the way, can contain 100-200 wind turbines. Each
turbine has a full capacity of about 6 MW now. Even running at half capacity
average, therefore, you can replace ALL the power generated by ALL the
Klamath dams by just 30 wind turbines. This is hardly going to be difficult.
(7) As to flood problems -- you recognize that these are not flood control
dams. The total storage capacity of all the dams combined for flood storage
is only a few hours, a couple of days at most. Also, Keno dam will remain as
a flow regulation dam. All in all, any fears of future floods are, in the
opinions of the experts who have looked at it, essentially no more than they
are today with the dams in. But that too will be analyzed more carefully in
the next couple of years to make sure.
Now... tell me again, in light of the above, why PacifiCorp should KEEP dams
that will lose them money, will not solve their environmental problems, will
continue to violate several federal laws, and will cost you -- the ratepayer
-- nearly twice as much as taking them down?
As an engineer you know that dams are human constructs designed and built to
serve specific purposes. When those structures become obsolete or
economically unfeasible, or they no longer serve those purposes, as a
society we typically go on to something that works better. This is why we
buy occasional new cars instead of patching up old clunkers that would cost
more to patch up than purchasing a new one. This is the situation PacifiCorp
finds itself in today -- trading in its current Klamath clunkers for
something that will serve its customers the same power benefits but much
cheaper than relicensing 90 year old obsolete technologies.
Our view is that dam removal will also benefit the fisheries, both lower in
the river by removing the environmental water quality problems that are
killing up to 90% of the juveniles each year, and by restoring access to
historic habitat to expand the population. I have seen nothing in your
argument that has not already been considered and rejected as a reason not
to proceed with the obvious solution -- dam removal and river restoration.
Cheers, and again thanks for your comments. I cannot promise to respond, but
I do read and keep comments like yours for future reference, and think about
them carefully.
=============================================
Glen H. Spain, Northwest Regional Director
Pacific Coast Federation of Fishermen's Associations (PCFFA)
PO Box 11170, Eugene, OR 97440-3370
(541)689-2000 Fax: (541)689-2500
Web: www.pcffa.org <http://www.pcffa.org/>
Email: fish1ifr@aol.com
Thanks for the detailed and thoughtful comments -- much more so than many I
receive -- so I owe you a similar response. Here are a few other facts for
your consideration. As a hard-headed engineer by training and trade, I am
sure you will find them interesting and be unable to ignore them in your
thinking like myself, even though they do disagree with some of your
premises. Facts are very annoying things to wish away, as any engineer knows
well, and are ignored at one's peril.
(1) All historical evidence is that spring and fall run chinook salmon and
steelhead were once abundant throughout the Upper Basin, including in the
Williamson and Sprague. See Hamilton, et al. (2005) attached for a peer
reviewed historical review of those facts. Coho did not occur, so far as we
know, above about the current position of J.C. Boyle because river gradients
are too steep (i.e., a natural barrier) but were common between the CopCo
dams and Iron Gate Dam until the 1960s when Iron Gate was constructed -- a
loss that was never mitigated by the way, contributing to their current ESA
listing. Chinook and steelhead, however, go much further up to the farthest
tributary they can get to and tolerate much steeper gradients.
(2) Best estimates we have from both historical record and habitat typing is
that the historical pre-European spawning runs of salmon in the Klamath
basin averaged about 880,000 annually, ranging from about 660,000 to 1.1
million. Most were chinook, with spring chinook predominating in the upper
basin co-existent with large runs of steelhead. Even today, nearly 600
stream-miles of once fully occupied salmonid spawning and rearing habitat
would be available, according to biologists expert in this field, if the
dams were removed and full volitional passage were possible. See Huntington
(2006) also attached. He estimates more than 100,000 additional salmon could
utilize that additional habitat, even under the currently degraded
conditions (which, by the way, numerous clean water TMDL programs are
working to clean up).
By the way, with that many fish carcasses from spawning runs, the mainstream
river water quality would have naturally been a little dicey while they were
decaying in some places. This would have been VERY good for many other
species if not man, enriching the river insect life enormously for the next
generation of emerging juveniles in a natural cycle we have largely
disrupted. But humans such as Gibbs think in human-centered terms, not in
terms of ecosystem benefits -- especially lawyers! Gibbs was obviously no
biologist.
The Gibbs story reminds me of the Lewis and Clark expedition, that had never
seen salmon before. One of them timidly tried it, and it was so rich a meat
(compared to their Army field rations at least) it made him sick (or so he
thought), so the rest of the expedition on his word and example considered
salmon to be poisonous and they all completely avoided eating salmon even
though this rich source of protein was all around them. Instead they traded
with the Columbia River tribes and bought pet dogs to eat. The Indians
thought they were stark raving nuts! History is often made of such
misunderstandings.
(3) The reservoirs themselves retain nutrients, they warm water to near
fatal levels for salmonids, encourage the growth of toxic algae (dangerous
to humans, including reservoir landowners as well as to fish), and create
MAJOR water quality problems far downriver. The FERC Final EIS is loaded
with pages and pages of analysis and documentation on these water quality
problems created by the dams themselves in their reservoirs. The FERC FEIS
also documents numerous other problems created by the dams for water quality
generally, which are killing off much of the lower river salmon runs
(heating and de-oxidizing the water, encouraging fish pathogens to multiply,
starving the lower river of spawning gravel recruitment, etc.). This should
be required reading in this debate. You can download it from the FERC
website www.ferc.gov, using the Docket Search function in the eLibrary under
Docket No. P-2082-027 -- the Klamath relicensing proceeding. The date is
Nov. 2007. Until you have read this, you will have few of the actual facts
to debate with and I will have you at an extreme disadvantage in these
discussions (grinning).
(3) There is no "status quo" here concerning the dams -- there are only two
choices facing PacifiCorp -- retrofit the dams to modern standards pursuant
to federal agency "mandatory prescriptions" (including fish passage) for a
new license, or abandon them entirely and invest elsewhere. Those are the
ONLY two choices legally available to the company, and both will cost a fair
bit of money. The only question is which is better economically and
environmentally.
(4) Several current engineering and cost analysis studies, including those
of the California Energy Commission (CEC) (which does power project cost
benefit analysis all the time) and one by FERC itself -- both of which know
a thing or three about dams -- say it will cost MUCH more money to retrofit
the dams and keep them (fish passage plus some 120 other mitigation measures
cost money) than to simply remove them and invest the money more wisely
elsewhere.
I attach a letter from the California Energy Commission itself to the Oregon
PUC (I presume you live in Oregon -- if not, they said the same thing to the
PUCs of CA and WA) which makes the strong case that PacifiCorp's customers
should not have to pay for keeping the dams because removing them and
reinvesting in something much more cost efficient elsewhere is by far the
best economic option -- and by $114 million cheaper. Plus mere fish passage
is likely to be ineffective, and keeping the dams does not really solve the
Clean Water Act problems the dams create.
Oh... as a capper FERC in its FEIS found that dam removal costs would be
about $79 million (as compared to $360 plus for FERC relicensing according
to the CEC) and that, even if licensed, the dams would still LOSE MONEY EACH
YEAR -- about $20 million per year -- and therefore were simply no longer
cost effective as dams (see FERC FEIS Table 4-3 on Page 4-2). In other
words, they are functionally and economically obsolete.
(5) Although several sediment studies have already been done, and although
they are not yet comprehensive, NO toxic sediment problems of any sort have
to date been discovered. Dioxins, for instance, are at natural background
levels. There are no heavy metals -- the upper basin was not mining
territory, nor heavily industrialized but a farming community.
There is also not anywhere as much sediment build up as once thought, making
it much less of a problem to simply wash sediment through naturally in a
season, with a little bank stabilization (normal procedure = planting grass
seed and trees) to help limit the silt. So far -- sediment is simply not a
problem. Several of those sediment and other studies have been collected on
a Yurok Tribe web site at:
http://www.yuroktribe.org/departments/fisheries/DamRemovalStudies.htm
Don't take my word for it, go to the sources. In any event, these
preliminary studies will be confirmed by much more detailed studies starting
this summer, under the NEPA process the Secretary of Interior will be going
through to make a final removal vs. relicensing decisions in March 2012.
(6) Finally... the four dams combined generate only a miniscule amount of
power by modern power plant standards -- only about 88 MW average over the
50-year lifetime of the last license according to FERC records. This
represents only about 1.5% of PacifiCorp's overall generation. Since the
capacity of one modern gas-fired power plant is between 800 to 1400 MW, you
see that PacifiCorp investing elsewhere in more efficient power plants makes
a lot of sense as a business decision.
Also, it is relatively easy for PacifiCorp to replace this minimal amount of
"green power" with equivalent green power elsewhere. When the company was
purchased by MidAmerican Energy Company a couple of years ago, the PUCs made
them promise to install an additional 1,200 MW of green power "renewables"
anyway over the next ten years. The mere 88 MW necessary to fully replace
the power from the dams is only a very small amount (7%) of what they plan
to do anyway.
One modern wind farm, by the way, can contain 100-200 wind turbines. Each
turbine has a full capacity of about 6 MW now. Even running at half capacity
average, therefore, you can replace ALL the power generated by ALL the
Klamath dams by just 30 wind turbines. This is hardly going to be difficult.
(7) As to flood problems -- you recognize that these are not flood control
dams. The total storage capacity of all the dams combined for flood storage
is only a few hours, a couple of days at most. Also, Keno dam will remain as
a flow regulation dam. All in all, any fears of future floods are, in the
opinions of the experts who have looked at it, essentially no more than they
are today with the dams in. But that too will be analyzed more carefully in
the next couple of years to make sure.
Now... tell me again, in light of the above, why PacifiCorp should KEEP dams
that will lose them money, will not solve their environmental problems, will
continue to violate several federal laws, and will cost you -- the ratepayer
-- nearly twice as much as taking them down?
As an engineer you know that dams are human constructs designed and built to
serve specific purposes. When those structures become obsolete or
economically unfeasible, or they no longer serve those purposes, as a
society we typically go on to something that works better. This is why we
buy occasional new cars instead of patching up old clunkers that would cost
more to patch up than purchasing a new one. This is the situation PacifiCorp
finds itself in today -- trading in its current Klamath clunkers for
something that will serve its customers the same power benefits but much
cheaper than relicensing 90 year old obsolete technologies.
Our view is that dam removal will also benefit the fisheries, both lower in
the river by removing the environmental water quality problems that are
killing up to 90% of the juveniles each year, and by restoring access to
historic habitat to expand the population. I have seen nothing in your
argument that has not already been considered and rejected as a reason not
to proceed with the obvious solution -- dam removal and river restoration.
Cheers, and again thanks for your comments. I cannot promise to respond, but
I do read and keep comments like yours for future reference, and think about
them carefully.
=============================================
Glen H. Spain, Northwest Regional Director
Pacific Coast Federation of Fishermen's Associations (PCFFA)
PO Box 11170, Eugene, OR 97440-3370
(541)689-2000 Fax: (541)689-2500
Web: www.pcffa.org <http://www.pcffa.org/>
Email: fish1ifr@aol.com
(Permission to post from the receiver.)