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Columbia-Snake River Irrigators Association
Eastern Oregon Irrigators Association
Northwest Irrigation Utilities
DISTRIBUTION NOTICE
DATE: May 12,2000
TO: Mr. Larry Cassidy, Chairman, NPPC
Mr. Eric Bloch, Vice Chairman, NPPC
Mr. Mike Field, Chairman, Fish-4 NPPC
and Northwest Power Planning Council Members
Mr. Bob Lohn, Director, NPPC Fish and Wildlife Program
FROM: Tom Mackay, President, CSRIA (509-735-6461)
Fred Ziari, President, E OIA (541-567-0252)
John Saven, Executive Director, NIU (503-233-5823)
SUBJECT: Recommendation for an Amendment to the NPPC
Columbia River Basin Fish and Wildlife Program:
A New Water Management Alternative for the Columbia River
Basin
Distribution Copies Mailed with Technical Support
Materials Included;
Mr. Bob Lohn, Director, NPPC Fish and Wildlife Program
Distribution Copies FAXed without Technical Support
Materials Included (13 pages):
Mr. Bob Lohn, Director, NPPC Fish and Wildlife Program,
503-820-2370
Mr. Larry Cassidy, Chairman, NPPC
Mr. Eric Bloch, Vice Chairman, NPPC
Mr. Mike Field, Chairman, Fish-4 NPPC
and Northwest Power Planning Council Members
Interested Parties
CSRIA/EOIA
3030 W. Clearwater, Suite 205-A Kennewick, Washington,
00330
500-703-1020, FAX 000-730-3140
NPPCC Amendment/Page-1
Columbia-Snake River Irrigators Association
Eastern Oregon Irrigators Association
Northwest Irrigation Utilities
DATE. May 12, 2000
TO: Mr. Larry Cassidy, Chairman, NPPC
Mr. Eric Bloch, Vice Chairman, NPPC
Mr. Mike Field, Chairman, Fish-4 NPPC
and Northwest Power Planning Council Members
Mr. Bob Lohn, Director, NPPC Fish and Wildlife Program
FROM: Town Mackay, President, CSRIA (509-735-6461)
Fred Ziari, President, EOIA (541-567-0252)
John Saven, Executive Director, NIU (503-233-5823)
SUBJECT: Recommendation for Amendment to the NPPC
Columbia River Basin Fish and Wildlife Program:
A New Water Management Alternative for the Columbia River
Basin
Proposed Amendment:
The proposed amendment is a "New Water Management Alternative for the Columbia River Basin," to improve fish and natural resources, and to provide for the social and economic needs of local and tribal communities.
Amendment Sponsored By:
AMENDMENT VISION STATEMENT
The principal water management strategy (for fish) within the Columbia-Snake River Basin, the flow targets/augmentation program, needs to be restructured, in order to improve biological benefits and reduce societal costs. A restructured program also has significant policy implications, eliminating the NMFS "no net loss" water policy that threatens the authority of states to govern water rights--as well as opening the way for new economic development options for tribal and local communities.
The present flow targets/augmentation program has no hydrological basis, lacks necessary biological justification, and is an extremely costly measure. By restructuring the program, it will be possible to ensure a higher level of measurable biological benefits, while moving toward collaborative fish enhancement actions among federal-state agencies, the tribes, and the direct economic stakeholders.
A restructured program will rely on the development of new water resource projects in the tributaries, enhanced water transfer and marketing programs, and additional water delivery efficiency improvements; and financial resources to implement new water projects made available from the generation of additional hydroelectric power.
The restructured flow targets/augmentation program will lead to greater certainty and verification for measurable fish benefits within the tributaries. Fish benefits for the existing program are uncertain and to a large extent cannot be verified within system operations. Fish benefits will he derived from generally improved habitat conditions and lower water temperatures within the tributaries; fish will likely be in better physical condition when entering the mainstem environment.
By restructuring the existing flow targets/augmentation program, additional power revenues will be acquired from the federal hydroelectric power system. The river system will be managed under a new hydro regulation that offers additional power generation beyond the 1995-98 NMFS BIOP hydro regime. The additional revenues will be allocated to the construction/development of new water management projects.
Tribal participation will be encouraged in the development of new water projects. Also compensation strategies for the tribes could be explored to mitigate their potential fishing right impairments, or needs for economic development.
The restructured program will greatly reduce the costs of the current water management program, which is producing uncertain biological benefits. The end effect will be a much more cost-effective program. A restructured program also will reduce future costs to society, the opportunity costs associated with the NMFS no net loss water policy.
The amendment sponsors believe that water should be the answer to our water management questions and issues, not made the problem.
AMENDMENT OBJECTIVES
A. Specific Biological Objectives:
The biological objective is to increase the number of returning adult salmon and steelhead--both natural and hatchery supplementation stocks--within individual tributaries and watersheds. This increase would be the direct result of water management measures within tributaries or watersheds, including new water storage projects, water transfers or changes, and water efficiency measures.
The specific objective is returning adult fish to site--specific areas of the Basin that can be--have a reasonable probability of being--enhanced via water management actions. The measure of returning adult fish must take into account changing inland climate and ocean conditions, as well as any other direct habitat measures that could be taken to improve fish runs. This means that adequate monitoring and evaluation must be undertaken to ensure that measurable fish benefits are verified.
At this time, the objective is to increase fish numbers for specific areas, but no set target or unit levels are recommended. Target levels may be established in the future given more experience with water management operations and other habitat improvement actions.
B. General Environmental and Social Objectives:
The existing flow augmentation program does not optimize water use for either survival benefits (fish benefits per unit of flow) or economic costs (benefit per dollar cost) to the river system. The New Water Management Alternative will provide for higher levels of measurable fish benefits and do so in a more cost-effective manner than the current flow management regime. The key objective is to maximize fish benefits via water management and do so in a cost-effective manner.
Resource managers need to change water management operations away from mainstem flow augmentation actions to improving habitat-water management conditions within selected tributaries and watersheds. Greater fish benefits may be obtained within tributaries, using less volumes of water. This factor has been generally ignored within the present flow augmentation program, Understanding and optimizing water use in tributary habitats will likely offer a more biologically productive, and cost-effective approach, to water management than past efforts.
Water management actions should defer to the existing authority of state water rights and should allow for "Locally developed" solutions within specific watersheds. This could include implementing efficiency measures, enhancing water transfers and changes, and encouraging the development of new water storage projects to benefit both fish and economic interests. New water projects should provide water allocations that allow for environmental, economic, and tribal benefits--everyone should have access to benefits.
A broader social objective of the New Water Management Alternative is to reduce conflicts among interest and stakeholder groups within the region. The emphasis should be on identifying projects and actions that will both enhance environmental benefits and offer economic incentives.
IMPLEMENTATION STRATEGIES
The implementation of the New Water Management Alternative relies on two major components: A) a restructured flow augmentation program for the mainstem Snake and Columbia River system; and B) the development of a broad set of water management projects within the tributaries and watersheds.
A. Restructure the Existing Flow Targets/Augmentation Program.
The Council and federal water resource agencies shall develop a new hydro regulation for the Columbia Basin system, to review now project operations under a restructuring of the existing flow targets and augmentation program. This review shall be completed by the summer of 2001, or as soon as possible, for implementation during the fall of 2001 and thereafter.
The new hydro regulation review shall focus on a restructured flow augmentation program that better reflects an optimization of the existing water resources. The hydro regulation shall deal with power, flood control, recreation, and fish protection operations.
For fish protection operations, the hydro regulation shall focus on pre-determined volumes (or blocks) of water dedicated for flow augmentation, rather than specific flow targets. The existing flow target approach has not been implemented according to sound scientific and technical principles, and it has created an overly complex operational structure. Water dedicated to flow augmentation will be based on maximum volume allocations, with implementation initiated during the 2001-2002 water-year period or as soon as possible.
The water volumes available for flow augmentation will be based on the following specifications:
All Water-Year Conditions, Snake-Columbia River System:
During the summer period, the restructured program will limit flow augmentation to a level not to exceed operations that occurred in the summer of 1994 (drought conditions). This regime will take into account both biological and economic demands on the river system.
Another important feature of this hydro regime program is annual review by the Council members for implementation. The program engenders flexibility within it to make changes that correspond to varying needs and conditions, as well as from improved information from monitoring and evaluation.
B. Water Resource Projects within the Tributaries and Watersheds.
Funding Mechanism:
By restructuring the existing flow targets/augmentation program, additional power revenues will be acquired from the federal hydroelectric power system. The river system will be managed under a new hydro regulation that offers additional power generation beyond the 1995-98 BIOP hydro regime.
The additional revenues--or a significant portion thereof--will be allocated to developing new water management projects within the tributaries and watersheds. Based on preliminary evaluations by the Council staff and others (Framework Process), the amount of funds available for this purpose is estimated to be about $40 million annually.
By the spring of 2001, the Council shall initiate a program review process to determine how to allocate funding derived from the new hydro regime. This review process shall involve representatives from the respective governors' offices, representatives from local economic stakeholder groups, and tribal representatives,
As a guiding principle, the funding shall be provided through state agencies, working with local stakeholder groups and the tribes, and funding specifically directed toward water management projects within tributaries and watersheds.
The restructured program will greatly reduce the costs of the current water management program, which is producing uncertain biological benefits. It also will reduce future costs to society, the opportunity costs associated with the NMFS no net loss water policy.
Prioritizing and Targeting Water Management Projects
The focus for water management will be on upper river and tributary fish enhancement projects. For example, such projects could be developed within key watersheds--the Yakima River Basin or the Upper Snake River Basin, and other areas. Potential projects should reflect a broad range of options for new water storage, water transfers and changes, and water efficiency measures.
Examples of water projects would include:
The new water resources projects shall be identified and developed jointly by state, economic stakeholder, and tribal interests. The new water projects would allocate water to fish, economic, and tribal needs.
The Council shall initiate water resources project funding by the end of calendar year 2001 based on its review of funding allocation protocol and the technical project review and priority study.
Tribal Role and Involvement:
In developing the new water resources projects, a portion of the power revenues from the restructured hydro regime shall be used to finance direct participation by the tribes. In effect, the tribes should become equity partners with the states and economic stakeholders in developing the new projects.
The current economic costs of flow augmentation can be transformed into venture capital for the tribes to become equity partners.
SCIENTIFIC FOUNDATION
Overview:
The river system benefits of flow augmentation are best estimated by relying on NMFS/UW data for flow-survival relationships (1993-1998 data), the CRiSP modeling analyses (which corroborate the NMFS/UW data), as well as other data and analyses being developed for fall chinook impacts. These data and analyses strongly suggest that the correlation between incremental flow changes and juvenile spring migrant survival is relatively inelastic, or that the survival benefits are very small. Also, flow augmentation benefits are best considered by examining the within year data relationships.
To date given the data available, estimated river system flow benefits--though limited--appear to favor fill chinook. But the uncertainty surrounding the effects of flow augmentation on overall fall chinook survival is great. Several factors are unclear or unresolved concerning direct inriver survival benefits within years, migration timing and flow conditions, temperature control and management, and the use of flow to improve transport collection efficiencies.
It is more clear that flow augmentation is a measure providing marginal survival benefits at best, while factors independent from the mainstem river system, such as ocean/inland climatic conditions, will govern total productivity levels.
Technical Review:
Beginning in 1993, NMFS and University of Washington researchers combined state-of-the-art PIT tag technology with sound statistical study design to quantify the relationship between juvenile migration survival and flow discharge in the Snake River. These data are now being collected under improved in-river test conditions of high spill and flow, as prescribed by NMFS in. the 1995 BIOP. The NMFS have published findings to date, covering multiple-year flow conditions data.
The results of the multi-year juvenile survival data in the Snake River probably give us the most definitive picture of how flow affects spring chinook and steelhead migrating through the Lower Snake and Lower Columbia hydropower corridor. Key points from the NMFS data come readily to light.
When comparing juvenile survival between years, there is higher survival in years with higher flows. This parallels the findings of the original Sims and Ossiander study (1981), a study whose data have been criticized as statistically inadequate. Among other considerations, the inter-annual relationship seems to depend on the fact that there are very large differences in seasonal discharge from year-to-year; flow regimes much larger than we observe in weekly or monthly variations within each year. Examination of the data tends to suggest that it may not be the provision of higher flows that elicits the survival benefit.
In reviewing these data, it appears that for years when the average spring discharge is below 80-90 kcfs in the Snake River, survival is much lower than when it is above this value. But in particular, the within year survival data strongly suggest that there is no apparent relationship between survival and flow. The biological or physical cause of why there is a strong between-year survival relationship, but no within-year relationship, is speculative; it is likely based in ecological factors that are well beyond the effects of the single flow rate variable.
For example, an examination of week-to-week survival of migrating juveniles indicates that the specific weekly discharge does not seem to greatly influence survival. That is, in examining the flow-survival relationship within a specific year, the same kind of strong relationship does not manifest, as noted between years. Is it possible that this situation exists because there is not a significant change in flows from week-to-week to elicit a survival response?
In answering this question, it can be observed that flows within a season can vary by as much as 50 to over 100 kcfs. Thus, it can be said that fish are exposed to highly variable flows within a year. It is not unusual to see Snake River flows at the beginning of the season at 40-60 kcfs and reach 120-140 kcfs as run-off proceeds. Snake River discharge history from 1994-1997 illustrates this point well. In 1994, flows began near 30 kcfs but never exceeded 100 kcfs--a very low flow year. In 1996, by contrast, flows began around 90 kcfs and peaked near 200 kcfs. In both years, flows fluctuated greatly within the season (sometimes within a week), yet no survival relationship emerged. Both years presented natural experimental opportunities for survival to show weekly fluctuations, because flow conditions were often highly variable week-to-week. But the survival data do not correspond to the flow variations.
This observation suggests that survival is not a function of week-to-week discharge; it is not the instantaneous flow condition that is providing a measurable survival benefit. Instead, it appears that it is the overall annual condition of low flow (drought) versus high-flow (flood) years. Seasonal, not daily or weekly, volume water discharge is a predictor (or a correlate) of annual in-river survival percentages--likely due to multiple variables stemming from wet seasons versus dry years.
Consider, as well, even if total seasonal discharge was the only variable driving survival--an unlikely assumption--is it possible to "turn a low-flow year into a high-flow year" by using reservoir storage and thereby increasing survival? If we compare the volume of water that passed Lower Granite Dam in the spring of 1994 and 1996, we find that total river flow in 1996 (14.6 MAF) was nearly twice that of 1994 (7.6 MAF). In order to make river conditions in 1994 resemble 1996, it would require an additional 7 MAF of flow augmentation. Currently, the total Snake River storage is about 12 MAF (System Operations Review estimate). Therefore, we would need to evacuate two-thirds of the entire storage in Idaho and release it in a two-month period. Even if this were hydrologically possible, it would leave negligible storage or available instream flows for other purposes; and the region would need to forego most uses for water later in the year, including fish and wildlife in the Middle and Upper Snake River.
It appears likely that the use of storage as a mitigation tool is relatively limited in how much increased in-river survival it can provide, within the hydropower corridor. A major objection to previous juvenile survival data has been inadequate in-river conditions to maximize in-river survival. NMFS has provided improved conditions to test this hypothesis since 1993, in the form of both higher spill and flow target levels.
Based on their own data, the NMFS recovery strategy should anticipate that survival of juveniles will vary year-to-year, and survival appears to be contingent especially on whether we anticipate a drought year and therefore low survival in-river. For now, it appears that flow as a tool to enhance in-river survival of spring migrants, within seasons, has severe limitations in the Snake River; and that the survival benefits of simply drafting storage will be small, first by storage limitations themselves, and second by the survival benefits--no matter what we may be willing to pay biologically or economically in the way of upstream costs.
The benefits to fill chinook are less understood (undefined at the present time) during the summer migration season. It also is recommended that appropriate monitoring and evaluation continue here, based on the limitations accepted by the Council.
In contrast to some of the biological impacts, the economic trade-offs of flow augmentation are more predictable. Flow augmentation does increase costs to the hydropower system--one of the single largest costs of the salmon recovery program--and it can create significant costs to water users, through either direct water curtailments or abrogating state water permits.
It should be further underscored that flow augmentation program effectiveness is directly affected by the collection efficiency of the smolt transportation program. Under a full or "maximized" transport collection program, the flow augmentation benefits within the mainstem corridor become very limited. For example, in the case of Snake River spring chinook collection at Lower Granite and Little Goose dams, 80% collection efficiencies win leave less than 5% of the migrating fish within the river system (below Little Goose Dam). If transport collection efficiencies improve at the McNary Project, then the flow benefits for Mid-Columbia fall chinook will decrease as well. And as technical modifications are made at the collection facilities to improve fish guidance, the upriver effects of flow augmentation to improve fish guidance are diminished.
Key Supporting Technical Reports/Materials Used to Prepare Amendment:
The following technical documents are included with this amendment as supporting materials:
Water Management and Hydra System Operations:
The future resource issue for the Northwest will not be dam removal, but how to manage water. Dam breaching costs will exceed the region's willingness-to-pay for uncertain fish benefits; but some groups may assert that these costs should serve as the region's "avoided cost" to set the level of future fish program expenditures. Dam breaching and reservoir drawdown alternatives will be eliminated from further review or consideration.
The end-effect of the existing flow targets/augmentation program is the misallocation of water; water is being used "speculatively," at best, with no demonstration of beneficial use--either biological or economic. Water management should be optimized based on measures of biological-environmental benefit and cost-effectiveness.
New water management projects will be evaluated for both environmental benefits--particularly--fish protection and enhancement--and how they enhance the social and economic needs of local and tribal communities.
Regarding mainstem hydro system passage, the Council shall rely on some mix of "share the risk" practices during the years ahead--a mix of juvenile fish transportation, spill programs, and improved turbine/bypass survival passage measures. These measures will change and evolve through time based on careful monitoring and evaluations.
Regional Water Policy and Economic Needs:
There can be a restructured flow augmentation program--because several MAF provided in low water--ears has no, or no measurable, biological value. The NMFS now program cannot demonstrate beneficial use.
The restructured flow augmentation program would allow for additional growth of water use for municipal, industrial, and irrigation sectors--use the "saved" water from the flow augmentation program for beneficial uses (several MAF would be available, at least 3-6 MAF).
Also, water transfers (marketing) can be pivotal in reducing the demand for new water permits in the future and providing economic incentives for efficiency improvements Pragmatic economic incentives will rival regulatory "hammers" or theory any day. The criteria for whether water right holders or the state should receive "saved" water should be the funding source--private or public funds.
The great water right its a property right versus public trust debate is fine for academic discourse, but property rights sire what make the water system function. Water rights provide for economic incentive, flexibility, and productivity; and financial certainty. Lenders, bankers, and public bond purveyors want property rights, not public trust dogma. A water right must be functionally treated as a property right, or the water supply system will rapidly break down.
Tribal Interests and Participation in Water Projects:
In considering tribal interests within the political economy of salmon recovery, there should be a recognition that tribal commercial fisheries-even with catch improvements--represent a very limited solution to tribal economic development--direct net benefits of a few million dollars annually, at best. Other activities and ventures will be needed, and water management projects can open the door to new economic development options.
But in considering tribal interests, there should be a recognition that tribal ceremonial and subsistence (local retail) fisheries in Zone 6 can be maintained and perhaps enhanced. This is important because these fisheries are an empirical expression of protecting tribal property rights (somewhat undefined), which could hold significant economic value--but the property right will focus on water.
In considering tribal interests, economic stakeholders should view tribal fisheries as an impaired property right. This could, or should, lead to discussions to consider opportunities to allow the tribes to become vested interests in long-term economic development projects, such as new water management projects.
CONCLUDING COMMENTS
The amendment sponsors applaud the Northwest Power Planning Council members and our Northwest state governors for an opportunity to submit recommendations to the new Columbia Basin Fish and Wildlife Program.
The sponsors believe that the centerpiece for the new
fish program can and should be a New Water Management Alternative for the
Columbia River Basin.