July 11, 2022
RE: Lower Snake River Dam Benefit Replacement Draft Report
Dear Governor Inslee and Senator Murray,
Thank you for the opportunity to provide comments on the Lower Snake River Dam Benefit Replacement draft report. Washington Environmental Council (WEC) and Washington Conservation Voters (WCV) are grateful to you for taking on the challenging, yet unquestionably critical, issue of our time to save Snake River salmon from going extinct and honoring tribal treaty obligations. WEC and WCV support the removal of the dams. Washington and the Federal government must uphold Treaty Rights and restore the nearly extinct Snake River salmon.
WEC is a nonprofit, statewide conservation organization that has been driving positive change to solve Washington’s most critical environmental challenges since 1967. WEC’s mission is to develop, advocate, and defend policies that ensure environmental progress and justice by centering and amplifying the voices of the most impacted communities.
WCV advocates for environmental progress and justice through actions that mobilize the public, elect champions for the environment, and hold our leaders accountable. Over the last 40 years, WCV has elected environmental champions, held our elected leaders to the highest standard, and built statewide momentum for environmental campaigns through innovative voter outreach efforts and community organizing.
The Lower Snake River Dams Benefit Draft Report makes it quite clear that the dams’ services – energy, irrigation, and barge transportation – can be fully and feasibly, replaced with reliable, cost-effective alternatives. It acknowledges, based on the best available science, that dam removal is our best chance to prevent salmon extinction and that a comprehensive solution is needed that brings everyone
forward together (and provides a chance for Eastern Washingtonians to be part of a legacy-making opportunity).
The comprehensive solution necessitates Congressional authorization for the Army Corps to pursue breaching the dams and complete a funding strategy, collaboration and cooperation among all stakeholders, additional analysis where needed, and time. Preferably, replacements should be in place prior to breaching. However, time is running out– salmon are on a trajectory to extinction. We are optimistic that the final report and recommendation will find paths forward as we embrace and commit to the largest river restoration project in the world right here in Washington State.
The draft report clearly concludes that all the services the dams provide can be replaced and doing so would provide tangible jobs and economic opportunities to the region. It also provides a range of estimated costs of removing the dams and replacing their services of $10-27 billion over 50 years. We note that these costs are lower than Rep. Mike Simpson’s recent proposal estimating the cost to be $34 billion, partly reflecting improved clarity on cost-effective alternatives. But doing nothing and continuing the status quo would come at the exorbitant cost of salmon extinction, even as the dam infrastructure ages, maintenance costs grow exponentially, and the dams exceed their design life.
Our region is at a critical decision point. We cannot continue to spend resources, time, and energy on federal programs that have not brought salmon and steelhead back as promised, and on temporary fixes to 50-year-old dams that are older and past their lifespan. Expensive operation, maintenance, and capital costs now cost taxpayers about $151 million annually. Costs will escalate over time and require additional capital investments to keep them going, particularly in the face of a changing climate. For example, 21 of their 24 aging turbine generators need to be replaced at an estimated cost of more than $600 million.
The dams need to be retired. This is clear from an economic lens, and it is clear from a salmon recovery lens. Astonishingly, since 1980 Pacific Northwest electric customers have paid $26.1 billion (in 2022 dollars) for Bonneville Power Administration programs to recover fish and wildlife, mostly salmon. Unfortunately, they have failed in the real world of salmon survival as the Snake River salmon and steelhead remain on a path to extinction. Populations of Snake River salmon and steelhead today are still about where they were in the late 1990s, when all Snake River stocks were listed under the Endangered Species Act. If the Lower Snake River dams remain in place, these costs not only continue, but almost certainly increase as more extensive and expensive measures are needed– and without dam removal scientists tell us the salmon and steelhead will likely still go extinct. The cheaper option, by far, is to do what salmon scientists call for—restoring a free-flowing Lower Snake River—rather than double down on costly, failed strategies.
The breaching of the dams is an investment in our future: a future with clean and reliable energy for the 21st century, prosperous communities, abundant and harvestable salmon runs, new economic opportunities in fishing, agriculture, and recreation, and upholds tribal treaty obligations.
Tribal Treaty Obligations:
The draft report clearly states and acknowledges the past, present, and future impacts of the Lower Snake River dams (LSRD) to tribal peoples, tribal treaty obligations and cultural connections to water, land, salmon, and other animals. The report quotes the Affiliated Tribes of Northwest Indians, stating that the hydropower system “was built on the backs of tribal peoples.” While the report separately states that the replacement of services would need to be in place prior to any breaching of the dams, the same consideration was not available to replace the services and other intangible, intrinsic benefits previously available to tribal peoples when the system was built beginning in the 1930s. Reversing the decline of salmon and meeting tribal treaty tight obligations are driving the interest and need in breaching the four dams. The report outlines the economic and cultural benefits to Washington’s tribes when the dams are removed, and a free-flowing Snake River has been restored.
The LSRDs have inundated cultural sites important to the Tribes making them inaccessible, but not forgotten. Breaching the dams could create substantial benefits for affected Tribes. It would allow tribal people to resume their close religious and spiritual connection with the land and water of their ancestors, totaling at least 700 documented locations. Furthermore, the draft report has the foresight to ensure protection and safekeeping of tribal artifacts and sites once the waters recede after dam removal.
The draft report is supported by numerous tribal resolutions, scientific studies, documents, and other references as well as discussions and interviews with many tribal leaders, members, and staff.
Restoring salmon and steelhead runs in the Snake River is significant and important to tribal fisheries. It is estimated that the effects of the LSRDs have led to a loss of tribal harvest of salmon between 8.4 million and 14.3 million pounds annually.1
The draft report clearly identifies the impacts of the hydropower system on salmon runs and the potential benefits to salmon should breaching occur. Today’s salmon runs are roughly 10% of the salmon abundance that occurred in the Lower Snake River for thousands of years, before the dams were built. This report continues the honest evaluation of salmon impacts and benefits, mischaracterized in numerous previous Environmental Impact Statements, and appropriately focuses on hydropower rather than the other known pressures impacting salmon in addition to hydropower. We appreciate that the report sticks to the science of salmon recovery and avoids selecting statistics out of context to give the impression that salmon populations are stable. Salmon populations are not stable.
Breaching the dams would increase tribal harvests by 29% annually. That would add up to large increases in salmon abundance and meaningful harvests. We know of no other single action that would boost salmon harvests by comparable levels.
The removal of the dams fits within the larger regional context of meeting our climate goals and doing so in a way that addresses longstanding inequities of energy generation. Part of the work of removing these dams is to more fully evaluate what type and how much energy generation is needed, how to produce this electricity in a just and equitable manner, and what is the best use of that electricity. The report acknowledges various elements of this issue but falls short of fully evaluating how the dams and their removal fit within this larger context needed in the region.
And yet, even with this more limited scope, the report confirms that we can replace and even improve energy services provided by the Lower Snake River dams with the right planning and adequate funding. This is a critical finding of the report and one that should be emphasized as the work moves forward to conduct the needed evaluation and larger planning efforts tying the LSRD removal to the electricity generation and use needs of our region.
Already across the Columbia River and Snake River service territory, there are projects and approaches quickly emerging to increase energy efficiency, modernize grid networks, battery storage and other ways to meet our 21st century energy needs.
For example, Nimiipuu Energy’s recent investment and installation of three large solar operations with more than 770 panels and Tesla batteries–known as megapacks and powerpacks–at tribal headquarters with four additional projects in the works. We also call your attention to Nez Perce Tribe’s ambitious energy independence strategy. In May, the tribe revealed their intention of building a tribe-to-tribe solar and renewable network with the long-term goal to replace power produced by the four Lower Snake River dams. The tribe’s solar initiative — called the 5311 Project — gets its name from a Bonneville Power Administration fact sheet published in 2016 that said it would take 5,311 megawatts
of solar power to replace the output of the four Lower Snake River dams. With the goal of each tribe becoming energy independent, they envision connecting far-flung tribal solar and other renewable energy projects via a virtual power plant. The connected web of energy production and storage systems would be managed with software to send electricity where and when it is needed.
Furthermore, already in operation is the Wheatridge Renewable Energy Facility in Morrow County, Oregon. There, hundreds of solar panels and wind turbines are generating clean electric energy alongside an innovative battery technology that allows the facility to capture and store electricity even
These examples highlight how innovative approaches are already moving forward. And, with the appropriate resources, planning and focus, our region can meet its energy needs without the LSRDs, and do so in a cost-effective and more reliable way.
Replacing the dams’ power production adds value
The draft report highlights that there is sufficient information available now to make a regional decision in favor of retiring the LSRDs from service. Doing so is less expensive than the status quo and highly feasible along smart planning to replace the dams’ services. Each analysis cited by the draft report concluded that the energy services of the dams can be replaced with a portfolio of clean energy resources. The appropriate planning objective, precise mix of resources, upgraded and efficient grid networks, and exact cost of development are important pieces to be defined in the final report.
The dam’s cost of operation, maintenance, and capital (now roughly $151 million annually) will increase over time and require additional capital investments to keep them going (e.g., replacement of costly items like 21 of their 24 aging turbine generators at an estimated cost of more than $600 million). At the same time, the power output of the dams is likely to decrease as a result of changes in hydro operations to benefit fish and, potentially, the impacts of climate change on the amount of water in the river.
A 2022 study of power replacement options by Energy Strategies LLC found that “replacement portfolios will generate power at times when the region needs it the most, resulting in $69M – $131M million per year of energy value above and beyond what the LSR dams provide for the same time period. We can pay more for less or invest in clean new energy resources that would provide more value than the output of the Lower Snake River dams.” Once again, dam removal is likely the cheaper option.
Southern Resident Killer Whale & Chinook Salmon Linkage
Salmon experts have long supported the removal of the Lower Snake River dams as the best and most
effective way to recover Snake River salmon–we are encouraged that your draft report concurs with
that conclusion. However, we believe that the draft report is deficient and fails to acknowledge the
important linkage between the Southern Resident Killer Whale (SRKW) population and Chinook
salmon in the Columbia River Basin, both of which are on the brink of extinction.
One of the main threats to the continued survival of the SRKW population is the dramatic decrease in
Chinook salmon, which accounts for approximately 80% of their diet2. Chinook populations relied
upon by SRKW have declined significantly in the Columbia Basin. A strong correlation has been
documented between the survival rate and reproductive success rate of these whales and the Chinook
salmon on which they depend3. The best available science indicates that the orcas are especially reliant
on the Columbia Basin’s early spring, nutrient-rich Chinook salmon runs4.
The Columbia Basin once produced more salmon than any other river system in the world. Today, only
about 1% of the historic number of salmon returns to the watershed to spawn. According to National
Marine Fisheries Service “[p]erhaps the single greatest change in food availability for resident killer
whales since the late-1800s has precipitated the decline of salmon in the Columbia River.”5 Climate
change is only making the situation worse for the fish, and by extension, the SRKW population. In the
summer of 2015, warm water temperatures resulted in the death of a quarter-million Columbia and
Snake River salmon. In 2015, there was an extreme heat event that killed about 3/4 of the young
salmon in the Columbia River Basin and the salmon population did not recover for years6. Dams create
pools that heat water, which creates a deadly hazard in combination with warming caused by climate change.
The draft report downplays the SRKW heavy dependence on Chinook salmon by stating “Although Southern Resident orca consume a variety of fish and one species of squid, salmon are their primary prey” and “During winter, Chinook salmon appear to be the most important component of the diet for the K and L pods” (page 26). When in fact a 2016 fecal analysis shows over 98% of their diet in the summer is salmon, 80% Chinook for all three Pods- J,K, and L7. Further mortality information shows correlation between SRKW and coast-wide Chinook – they eat little amounts of other fish and not enough to sustain whale population when Chinook numbers are low and they will not switch to another fish type if Chinook salmon disappear. The science is clear that Chinook salmon ARE the most important prey source for the SRKW because of their high omega fat and nutritional and caloric intake value.
The best available science indicates that our region’s orcas are especially reliant on the Columbia River Basin (CRB)’s early spring, nutrient-rich Chinook salmon runs. CRB Chinook account for more than half of the Chinook consumed by the orcas when they are in coastal waters. Recent (2022) research also estimates a significant increase (34%) in the contribution of CRB salmon to the orcas’ diet. This aligns with long-term observational studies showing the whales are spending less time in their traditional spring and summer habitat areas in the Salish Sea and more time foraging off the west side of Vancouver Island, which means that they are more reliant on salmon from the Columbia Basin and other coastal river systems.
Early spring Chinook returning to the Snake and Columbia Rivers provide a unique nutritional value to the orcas in the late winter and early spring. These salmon are known to be large and have a high fat content, and can deliver extra nutritional benefits. Research assessing the changing nutritional status of the orcas additionally indicates that the conservation of early spring runs may be especially important to recovery efforts for the Southern Residents.
The movements of Southern Residents in coastal waters are also likely driven by the seasonal timing of Chinook salmon returns to major river systems, including the Columbia River. All three Southern Resident pods use the coastal waters of their critical habitat year-round, with highest use during the winter and early spring months. Data compiled from passive acoustic monitoring, satellite tagging, opportunistic sightings and boat-based surveys show areas of “high occurrence” to include the mouth of the Columbia River. In its recent revision of the orcas’ critical habitat, NMFS described the mouth of the Columbia River as a “high use foraging area.” Approximately 50% of the time the orcas spend in coastal waters is between Grays Harbor and the Columbia River, with K and L pods using the entire Washington Coast between January and May.
Salmon returning to the Columbia and Snake Rivers are an extremely important food source for these orcas, and the potential for salmon restoration in the Columbia Basin is unparalleled. Sadly, Columbia Basin salmon runs continue to struggle despite billions of dollars wasted to reverse the trend. Clearly, the status quo is not working for salmon, SRKW, or many tribal and non-tribal communities that rely on our region’s abundant salmon runs. The final report needs to bolster the linkage of these two species with one another and the significance of breaching of the Lower Snake River dams to their survival.
WEC and WCV support the removal of the dams. Washington and the Federal government must uphold Treaty Rights and restore the nearly extinct Snake River salmon. People in the Pacific Northwest are looking to you to be bold, courageous, and work with other policymakers and regional sovereigns to develop a comprehensive solution for the Columbia Basin, particularly the Lower Snake River.
In a recent poll, a majority of Washington voters supported a plan to remove the Lower Snake River dams to prevent salmon extinction that also includes investments in clean energy, transportation for farm products, and irrigation.
With your leadership, we can restore abundant salmon populations in the Columbia Basin, support the recovery of Southern Resident orcas, uphold our nation’s obligations to tribes and tribal fisheries, ensure a clean energy future, and invest in affected communities. But the situation for salmon and orcas, tribes and fishing businesses, and our energy system is dire.
We look forward to the final report and recommendation that is an actionable plan that will rise to this monumental challenge.
Puget Sound Campaigns Manager
Washington Environmental Council
1 Meyer Resources, Inc. (1999). Tribal Circumstances and Impacts of the Lower Snake River Project on the Nez Perce, Yakama, Umatilla, Warm Springs and Shoshone Bannock Tribes. Columbia River Inter-Tribal Fish Commission. Retrieved from: https://www.critfc.org/wp-content/uploads/2014/11/circum.pdf?x78172
2 Ford MJ, Hempelmann J, Hanson MB, Ayres KL, Baird RW, Emmons CK, et al. (2016). Estimation of a Killer Whale (Orcinus orca) Population’s Diet Using Sequencing Analysis of DNA from Feces. PLoS ONE 11(1): e0144956. doi:10.1371/journal.pone.0144956
3 Ford JKB, Ellis GM, Olesiuk PF, Balcomb KC (2010). Linking killer whale survival and prey abundance: food limitation in the oceans’ apex predator? Biol. Lett. 6, doi: 10.1098/rsbl.2009.0468
4 Ayres KL, et al. (2012), id., at pp. 7-9
5 NMFS (2008) Recovery Plan for Southern Resident Killer Whales (Orcinus orca), p. II-82. National Marine Fisheries Service, Northwest Region, Seattle, WA, available at http://www.nwr.noaa.gov/Marine-Mammals/Whales-Dolphins-Porpoise/Killer-Whales/ESA-Status/Orca-Recovery-Plan.cfm
6 Snover, A.K. et al. 2019. “No Time to Waste. The Intergovernment Panel on Climate Change’s Special Report on Global Warming of 1.5C and Implications for Washington State.” University of Washington Climate Impacts Group, Seattle, WA, p. 5 Figure 6. Available: https://cig.uw.edu/wp-content/uploads/sites/2/2019/02/NoTimeToWaste_CIG_Feb2019.pdf
7 Ford MJ, Hempelmann J, Hanson MB, Ayres KL, Baird RW, Emmons CK, et al. (2016). Estimation of a Killer Whale (Orcinus orca) Population’s Diet Using Sequencing Analysis of DNA from Feces. PLoS ONE 11(1): e0144956. doi:10.1371/journal.pone.0144956
Zachary DeWolf, Washington Environmental Council, 206-639-3760, firstname.lastname@example.org