1. The Corps’ $600 Million System Improvement Efforts on the Lower Snake River Have Failed.

 

Dams kill fish, millions of fish. In 2002 the Corps of Engineers’ Walla Walla District convinced the public that the most acceptable alternative for saving Snake River threatened and endangered salmon and steelhead and recapturing the many benefits of recovered fish runs was to modify fish passage over and through the dams with System Improvements. Since then, the Corps has spent approximately $600 million—on just the four lower Snake dams—attempting to improve fish passage, and the Corps intends to spend more. The results? According to the Fish Passage Center, estimated wild Chinook salmon smolt survival over the past 10 years has averaged only 52%, and wild steelhead survival has averaged only 46%. The wild Chinook survival rate in 1999 was 59%; in 2013, 56%. In 2013, NOAA Fisheries acknowledged “Chinook survival through the hydropower system has remained relatively stable since 1999 with the exception of lower estimates in 2001 and 2004.” That is, stable, not improved, even with the proven positive benefits of increased spill.

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While the system improvements have clearly been a failure with respect to smolt survival, the only true measure of recovery success for threatened and endangered fish species is the smolt-to-adult return, or SAR, ratio. Survival of the wild runs requires a minimum 1% SAR, and recovery of Snake River salmon and steelhead requires a 2%-6% SAR. Unfortunately, the SAR for wild Chinook salmon over the past 18 years has averaged .59% and has not surpassed .8% in any year.

 

2. Lower Snake River (LSR) Freight Transportation is in Long-term Decline.

 

According to the U.S. Army Corps of Engineers’ Waterborne Commerce of the United States website, over the past 20 years lower Snake freight volumes have declined 69% measured at the lowest dam on the river, Ice Harbor. This decline has occurred across all commodity categories, and some industry groups like lumber and paper have completely, or almost completely, abandoned the waterway.

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The Port of Lewiston (POL) handles the only containerized freight shipped on the lower Snake River. Since 2000, according to the POL’s shipping reports, container traffic measured in TEUs (20-foot equivalent units), has declined 82%. On April 8, 2015, the POL suspended all container shipments from Lewiston and hence on the lower Snake River.

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The latest (2009) State of Washington Marine Cargo Forecast projected overall annual growth for lower Snake River waterborne tonnage to average .0% from 2002-2039. However, actual tonnage during the first 12 years of the forecast period declined by 32%.

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Of the maintenance and operating costs of the LSR waterway—well over $10 million per year— 100% are borne by the American taxpayer.

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3. Lower Snake River Hydropower Has Already Been Replaced.

 

The nameplate capacity of the 4 lower Snake dams totals 3,033 Megawatts, but over the past 11 years they have only produced an average of 961 aMW (annual Megawatts), or 33% of nameplate capacity. The 4 dams produce their greatest amount of power during spring runoff, when power demand, and consequently price, are at their lowest levels. Further, this “greatest amount” output comprises only about 4% of the power produced in the Pacific Northwest.

 

Over the past few years, Pacific Northwest wind energy has increased dramatically to a current total nameplate capacity of 8,975 Megawatts. In 2012 northwest wind energy production was 2,007 aMW, while the 4 LSR dams that year had their second highest output in 7 years at 1,039 aMW, about half the output of wind energy. In 2014 the lower SR dams produced 979 aMW.

 

Additionally, the Idaho Public Utilities Commission recently approved 13 southern Idaho solar power projects with approximately 400 Megawatt capacity.

 

On a related note, all 24 LSR turbines will reach the upper end of their 35- 45-year life spans over the next 15 years. The first 3 turbine rehabs are now underway at a contract price of $97 million. This suggests a total rehab cost in today’s dollars of $776 million. If all turbines were to be rebuilt by the end of 2030, total cost would approach or exceed a billion dollars. In light of the acceleration of wind and solar energy developments and the depleted need for hydropower, a billion dollar investment in Snake River hydropower may not be economically justifiable.

 

4. The U.S. Army Corps of Engineers Can No Longer Financially Support Aging and Nonproductive Infrastructure.

 

Nationally, the Corps of Engineers maintains and operates an extensive network of aging dams, locks, levees, and other infrastructure. In 2010 the Corps asked the National Academy of Sciences to prepare a report on possible USACE financial options. The report concluded the Corps was in an “unsustainable situation” and was “facing increased frequency of infrastructure failure and negative social, economic and public safety consequences.” One major alternative the NAS outlined was the divestiture or decommissioning of parts of Corps-operated projects.

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The U.S. Army Corps of Engineers evaluates the performance of a waterway based on ton-miles; that is, 1 ton of freight being transported a distance of 1 mile. A “high use” waterway moves 3-5 billion ton-miles of freight annually, a “medium use” waterway 1-3 billion ton-miles annually, and a “low use” waterway less than 1 billion ton-miles annually. A waterway trafficking less than .5 billion ton-miles is considered a waterway of “negligible use.” The lower Snake transports just .3 billion ton-miles of freight annually. Even were the LSR’s current freight volume to double, the LSR would still be categorized “of negligible use.”

 

In other words, continuing expenditures for the LSR as a transportation waterway can not be economically justified—particularly in light of the tremendous investment needs of more productive waterways elsewhere, including the Columbia River.

 

5. In its 2002 “Lower Snake River Juvenile Salmon Migration Feasibility Report,” (LSRFR) the Walla Walla District of the Corps of Engineers Understated the Cost of Keeping the LSR Dams in place by an Average Annual $161 Million.

 

In January 2015, retired 35-year career Army Corps engineer Jim Waddell completed a comprehensive reevaluation of the LSRFR using the same methodology the Corps had used to prepare the 2002 Report. As the former Deputy District Engineer for Programs in the Walla Walla District when the LSRFR was finalized, Waddell brings a unique and informed perspective to the reevaluation. By correcting earlier cost projections with now-available actual costs and addressing omissions, errors, miscalculations and faulty assumptions, Waddell’s reevaluation demonstrates that in its 2002 Report, the Walla Walla District understated the true cost of keeping the dams in operation by a staggering $160.7 million on an average annual basis. Waddell’s corrected figure for keeping the dams for a 100-year project-life beginning in 2000 is an average annual cost of $217 million per year. To arrive at that figure, Waddell used the Corps’ own 2000 discount rate of 6.75%. (Had the Corps used the then current BPA rate of 4.75%, the corrected average annual cost would be $232.7 million.) Using a 100-year project-life and a base year of 2015, along with the BPA discount rate, increases the average annual cost of keeping the dams to $435.6 million. Such figures sweep into the forefront the question of whether Americans can afford not to breach the LSR dams.

 

6. “Lost Benefits” Add Millions to the Cost of Keeping the LSR Dams.

 

The “costs” noted immediately above entail actual taxpayer and ratepayer expenses, the kind that typically require someone somewhere to write a check. Yet leaving the dams in operation presents other costs as well, costs economists call “opportunity costs,” often referred to as “lost benefits.” For example, the 2002 Report identified benefits that would result were the lower Snake River restored to free-flowing status. Under “recreation,” for example, the 2002 Report estimated the benefits of breaching the 4 LSR dams would range from $36.5 – $324.1 million, and to arrive at a single figure, settled on a total annualized benefit of $73 million. Several studies on the economic value of an expanded recreational fishery in Idaho alone suggest that an annualized $73 million figure is significantly low. Other examples of “lost benefits” include the west coast, Columbia River, and Snake River commercial fisheries opportunities and economic and cultural opportunities for Native American tribes.

 

7. “Passive Use Values” trump All Possible Benefits of Keeping the LSR Dams.

 

The Corps of Engineers defines “passive use values” as “the values individuals place on natural resources independent of direct use of a resource by the individual.” For example, people value knowing a resource is available for use by family and friends, protecting the natural resource for its own sake, and knowing the resource will be available to future generations. Although the 2002 Report did identify passive use values, it did not include them in its economic analysis. The report, for example, states that the passive use value for angling, if the dams were breached, ranges from $22.8 – $48.8 million on an annualized basis, and for a free-flowing river aside from angling, $420 million.

 

Today, the 2013 “Federal Principles and Guidelines for Water and Land Related Resources Implementation Studies,” which now applies to any report such as the 2002 Report, would require inclusion of passive use values in the Corps’ economic analysis. Were they included, as now mandated, passive use values identified for the lower Snake alone would eliminate any and all claims that the economic benefits of not breaching the lower Snake dams exceeded the dams’ economic cost. In other words, passive use values alone would today trump the benefits of keeping the status quo of the 4 dams.

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8. Climate Change Poses Multiple New Challenges to Continuing Operation of the Lower Snake River Dams.

 

The 2013 “Principles and Guidelines” mentioned immediately above also require inclusion of the effects of climate change in any analysis of water-related resources. A river’s volume and water temperature, for instance, are critical variables in determining the success of salmon and steelhead migration to and from their natal streams. Low flow levels extend juvenile transport time and increase exposure to predators. For adult fish, warm water temperatures increase disease and can create thermal blocks to upstream migration. Slackwater created by dams slow fish migration and thus increase travel time and also raise water temperatures. These factors are now being exacerbated by global warming, which results in lower mid-elevation snowpack, shorter periods of spring run-off, and warmer water temperatures.

 

Additionally, based upon number of acres burned over the past 40 years, our warming climate has also resulted in a four-fold increase in forest fire activity in the lower Snake River basin. As one result, scientists are predicting sediment in the basin could increase by up to 10 times present levels. Even a doubling of sediment volumes would pose a major future cost consideration for sediment management for navigation and flow conveyance (aka flood risk). Hotter summers, drier forests, and longer fire seasons say as much about water as about land—lower flows, higher temperatures, shorter periods of run-off, additional costs, and greater peril for threatened and endangered fish stocks.

 

9. The Lower Snake River Dams are Driving Species to Extinction.

 

In Puget Sound, Southern Resident Killer Whales are starving, to the extent that their population has declined to fewer than 80 whales. Their principal food source is Chinook salmon, and one of the greatest historical sources for such salmon is the Snake River basin and its 5500 miles of pristine and near pristine salmon habitat. Sockeye salmon from Idaho’s Redfish Lake have declined to a few hundred fish propped up by an extensive hatchery program. Many scientists argue that Snake River fall Chinook will only escape extinction with the return of the lower Snake River to near natural conditions. Other threatened and endangered fish species remain in official jeopardy status. In addition, Pacific lamprey numbers have declined by an estimated 95% and are likely candidates for a threatened or endangered listing.

 

10. The Lower Snake River Dams Violate U.S. Treaty Obligations.

 

Salmon are key to the cultural heritage of many people in the Pacific Northwest, but for Native Americans these fish are deeply woven into each tribes’ existence as a people—their sustenance, economic well being and spirituality. During the second half of the 19th century the U.S. government signed treaties with numerous tribes guaranteeing the right to fish in their usual and accustomed places. Those treaties require the continued existence of both water and fish. To argue otherwise is to dishonor the sacred trust of the American people and the U.S. Constitution.

The enormous tab for the near destruction of wild fish runs on the lower Snake River and enormous losses to the Northwest’s Native peoples are coming due. Twenty years of “Biological Opinion” litigation and a billion dollars of fish-passage “improvements” across the hydro system have purchased time but not an honorable and sustainable solution. The size of this pending financial obligation is unknown, but it may make the cost of breaching the four dams on the Lower Snake River one of the few, and most fruitful, taxpayer bargains of the 21st century.

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