Draft EIS for Short-Term Modification to Total Dissolved Gas Levels in the Columbia and Snake Rivers

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Comment From: Chris Pinney

2/28/19 @ 3:40 PM

Prior to my retirement I served as a Federal agency Fishery Biologist for the Columbia and Snake river ESA-listed salmon life stage survivals through the hydrosystem, who had direct RM&E design and performance responsibilities for reservoir drawdown ...↓experiments, dam breach and return-to-natural river designs and evaluations and scientific/biological justifications, Dissolved Gas Abatement Studies and the spill program's hydraulic and TDG effects on passing salmon and steelhead, as well as water temperature effects on salmon and steelhead life stage survivals including designs to band-aid and emergency action localized and reach specific impact zones with passage temperatures through operational modifications of the spillways and adult ladders. The regional coordinators for fish operations in the mid- and late-1990s were lead to believe that the spill up to 120% TDG supersaturation waiver from the 110% TDG standard was to be a short-term or 'temporary' modification. Idaho DEQ and the Nez Perce Tribe did not flow with the Snake River arguments by maintaining the 110% standard in the Clearwater River, principally for ecological reasons of disrupting foodweb constituents required for salmon and resident species productivity. After 25 years, where is Ecology on this larger original baseline ruling? Similar to elevated water temperature effects systemwide, it is time to rectify and settle this forgotten rule. I hesitantly applaud Ecology on their cautious recommendation for maintaining 120% TDG standard in tailwaters, at least for 2019. SAR estimates are informative, but limited due to their complex derivation of most influential causation. FPC and others need to address the reach and systemwide juvenile survivals while incorporating all dam (project) specific survivals for those variations in flow years for which studies are available. My experience and 2018 spill operation (which did not achieve the desired low end PITPH because flows required high powerhouse operation) study indicates that spill up to, but not exceeding 125% TDG with minimal PITPH <2 is difficult to achieve or continually hold, juvenile salmon reach and project survival will not be any greater and maybe worse than a 120% TDG regime spilling 30-40 % at Snake River and 40-50% at Columbia river dams (a risk based on PIT tag evaluation) as long as you have reservoirs empowering existing spillway designs (higher avian predation opportunity, structural erosion, tailrace eddies, etc). My direct science and technical experience fully supports the reports and publications synopsized in the DEIS addressing the uncertain and risky abilities of the SMP to adequately monitor and guess at GBT symptom accumulation (Hans et al 1999, Elston et al 1997, Montgomery Watson 1995, Mesa et al 2000, Monk et al 1997, Weiland et al 1999, others such as White et al 1991, Fidler et al at Battelle 1998...). Just like bypass, powerhouse, smolt transportation, and less so for historic rivers there will be un-measurable and un-determinable latent, secondary, and tertiary mortality effects due elevated to maximum spill (ISAB deliberations). I support the DEIS Alternative 1, and better yet, Ecology taking a more active leadership role for the states of Washington and Oregon in regional salmon and steelhead survival and recovery management forums for wild stock production management by avoiding enhanced ecosystem impacts of any elevated %TDG >110% supersaturation (especially systemwide) by your serious consideration of an Alternative 4 for both water temperature and gas supersaturation regulation in a most haste return to natural river function with re-connection of the channel flow to its subsurface flowing water bodies (water table, hyporheic base flow, spring, acquifer, etc) on as wide of continuum footprints as permanent or seasonally possible. I am an independent (retired) fish ecologist (scientist, aka Subject Matter Expert termed by Federal entities) now, upon retirement, so feel free to contact me for any clarifications. Thank you for the opportunity to comment technically, and again for your recommended adherence in "short-term" hopefully for not exceeding 120% TDG standard.

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Comment From: Sierra Club, Washington State ... (Emi Okikawa)

2/28/19 @ 10:14 AM

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Comment From: Nez Perce Tribe (Shannon Wheeler)

2/28/19 @ 9:45 AM

Please see attached file. Thank you.

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Comment From: Columbia River Inter-Tribal Fi... (Faron Scissons)

2/28/19 @ 9:37 AM

Dear Ms. Bartlett, On behalf of the Columbia River Inter-Tribal Fish Commission, thank you for preparing the Draft Environmental Impact Statement (DEIS) regarding the short-term modification of total dissolved gas criteria in the Snake and Columb...↓

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Comment From: Save Our wild Salmon Coalition (Joseph Bogaard)

2/28/19 @ 9:21 AM

Attached is a letter addressed to Director Bellon and Program Manager Heather Bartlett at the Department of Ecology, signed by more than 1,000 individuals, asking that the Department increase total dissolved gas standards in the Columbia and Snake R...↓

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Comment From: Bonneville Power Administratio... (Kieran Connolly )

2/28/19 @ 8:48 AM

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Comment From: Washington Environmental Counc... (Rein Attemann)

2/28/19 @ 8:14 AM

Please accept comments from Washington Environmental Council on Draft EIS for Short-Term Modification to Total Dissolved Gas Levels in the Columbia and Snake Rivers. Cheers, Rein Attemann

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Comment From: Northwest River Partners (Kevin M. Nordt)

2/28/19 @ 7:41 AM

Please find attached the comments of Northwest River Partners with respect to the Draft Environmental Impact Statement for Short-term Modification of Total Dissolved Gas Criteria in the Snake and Columbia Rivers.

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Comment From: Defenders of Wildlife (Robb Krehbiel)

2/28/19 @ 7:26 AM

Defenders of Wildlife and our members support increasing TDG standards to 125% (alternative 3). Attached is our organizational comment letter and a petition from 527 of our Washington members and supporters in favor of alternative 3. If you have a...↓

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Comment From: Earthjustice (Todd True)

2/28/19 @ 7:19 AM

Please see attached letter regarding comments on draft EIS for Short Term Modification of total dissolved gas standards for federal dams on the lower Snake and lower Columbia rivers.

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Comment From: Oregon Department of Fish and ... (Curt Melcher)

2/28/19 @ 4:44 AM

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Comment From: Lynn Roebuck

2/28/19 @ 2:33 AM

I support the recommendation of the Orca Task Force to increase the state's TDG rate to 125% and urge you to implement this change for 2019.

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Comment From: Orca Salmon Alliance (Robb Krehbiel)

2/28/19 @ 1:54 AM

Please find the attached comment letter from the Orca Salmon Alliance supporting alternative 3: Increasing TDG standards to 125%. If you have any problems or questions regarding these comments, please contact Robb Krehbiel at 206-883-7401. Tha...↓

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Comment From: Ursula Valdez

2/28/19 @ 1:49 AM

PNW ecosystems have offered important ecosystem services for centuries, millennia and more. Early human inhabitants of this region, learned so well how to manage their resource use without altering ecosystems in significant ways, and were able to use...↓

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Comment From: MaryAnn Seward

2/27/19 @ 3:04 PM

I fully support your development of an EIS that, at least in the short-term, modifies WAC 173-201A.

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Comment From: Sharon Wenham

2/27/19 @ 6:58 AM

Please increase the spill by 125% if you are not going to breech the dams the Orcas eat 4yr old salmon give them a fighting chance and do it now not in 6 months time when it could be to late Extinction is for life and the lives of the Southern resid...↓

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Comment From: Samantha Moore

2/27/19 @ 3:16 AM

This is an easy decision to make with big short-term impact. Please make the right call here.

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Comment From: Ellen Moore

2/27/19 @ 2:10 AM

Please do what is needed (permitting salmon to move as freely as possible) to increase their numbers for our orca. Please do this with speed too. Unlike climate change, this is NOT a political issue and we shouldn't take sides. This is something that...↓

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Comment From: Friends of the San Juans (Tina Whitman)

2/27/19 @ 1:44 AM

Friends of the San Juans strongly supports Washington Department of Ecology's proposed short term modification of the WAC 173-201A water quality standard at the eight lower Snake and Columbia River dams in support of the new regional agreement for fl...↓

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Comment From: Teresa Brown

2/26/19 @ 7:24 PM

It is too late for the SRKW's to do an EIS at this point in time. What is needed, AND WANTED by the public is the breaching of the lower snake river dams. No more studies. Time is up! If everyone is absolutely unwilling to breach them, then this seem...↓

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Comment From: Aim L

2/26/19 @ 3:05 PM

I support increasing spill over the dams, at 125% total dissolved gas as recommended by Orca Task Force, or at least 120%, of the Columbia and Snake Rivers in order to help more salmon to survive. The dissolved gas would need to be adjusted if other ...↓

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Comment From: Molly Nicoletta

2/26/19 @ 1:48 PM

Yes! More spill! I am in favor of that and breaching Washington dams to save our salmon. Orcas are starving. We need more salmon available for them to survive. Thank you.

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Comment From: Carrie Gelegonya

2/26/19 @ 12:39 PM

I support increasing spill over the dams of the Columbia and Snake Rivers in order to help more salmon to survive. Our Southern Resident Orcas are in immediate danger of starving to death due to lack of salmon. While breaching the dams would be prefe...↓

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Comment From: Terri Mitchell

2/26/19 @ 12:03 PM

I fully support the proposal to allow more spill in the Columbia and Snake Rivers, at 125% total dissolved gas as recommended by Orca Task Force, or at least 120% if this lower rate would allow the proposal to move forward this year without delay. I...↓

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Comment From: Sarah Burr Arnold

2/26/19 @ 2:43 AM

I support the proposed Alternative 2 modification of WAC173-201A TDG Criteria for the dams on the Lower Snake and Columbia Rivers during the spring spill season to help the survival of salmon and orcas. It is of vital importance to the environment t...↓

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Comment From: Amy Lafferty

2/25/19 @ 12:53 PM

I support increasing the total dissolved gas levels for the Columbia and Snake Rivers.

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Comment From: Luan Pinson

2/25/19 @ 11:19 AM

Please up the spill level in both the Columbia & Lower Snake River as well as breaching the dams on the 4 LSDs to save Salmon and the Southern Orcas.

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Comment From: Bill Yake

2/25/19 @ 9:09 AM

While breaching of selected dams (especially those on the Snake River) is a much better long-term solution, strategically increasing spill and closely monitoring the results is better than nothing. So, I support this effort, but hope that eventually ...↓

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Comment From: Rene Smith

2/25/19 @ 9:05 AM

Increased spill at dams on the Columbia and Snake R. systems is an effective way to increase the number of Chinook salmon moving through these rivers.

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Comment From: Laurie Kerr

2/25/19 @ 8:08 AM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their...↓ survival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a time as happens with increasing frequency due to climate change, salmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Act leaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined impacts of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would most effectively reduce temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower; they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be brought about post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs be breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, while the federal government is failing to protect our irreplaceable environment and wildlife.

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Comment From: Palouse Great Old Broads (Borg Hendrickson)

2/25/19 @ 6:30 AM

February 19, 2019 Attn: Becca Conklin, Water Quality Standards Project Manager, and Maia Bellon, Director, Washington State Department of Ecology Re: Proposed WA DOE increased spill at 8 Lower Columbia River & Lower Sna...↓ke River dams Dear Manager Conklin and Director Bellon: The Palouse Great Old Broads, whose membership includes residents of eastern Washington and north central Idaho, is one of eight networked Oregon, Washington, and Idaho chapters of the national, 6000-member Great Old Broads for Wilderness. Great Old Broads (GOB) throughout the nation advocate for the protection and preservation of wilderness, wild lands and wildlife dependent upon healthy, pristine environments, streams and habitats. Currently, a regional and national GOB key focus issue is the plight of threatened and endangered Snake River salmon, steelhead and the related plight of the Salish Sea's endangered southern resident orcas. On a national level, we are engaged in education and advocacy efforts to draw attention to this issue. In light of the looming potential for "endangered" to become "extinct," with respect to Snake River Basin salmon and steelhead and to southern resident orcas, we urge all relative government agencies to take bold, urgent action as backed by sound scientific research to ensure a turn-around in the declining populations of these species. We urge WA Department of Ecology, specifically, to move forward with its proposal to increase Lower Columbia and Lower Snake dam spill to 120% total dissolved gas level beginning in 2019. We further recommend upgrading the water quality rules in 2019 to allow an increase in spill to a 125% total dissolved gas level. We understand that the WA DOE increased-spill proposal is supported by WA Gov. Jay Inslee's budget and correlates with the recently signed "flexible spill" agreement reached by the states of Oregon and Washington, the Bonneville Power Administration, U.S. Army Corps of Engineers and Bureau of Reclamation. We recognize that the WA DOE proposal has the support of the Department of Fish and Wildlife, the Columbia River Inter-Tribal Fish Commission, and a coalition comprised of the Northwest Sportfishing Industry Association, Columbia Riverkeeper, and fifty-five organizational partners of the conservation coalition Save Our Wild Salmon. With this present letter, we add our Palouse Great Old Broads seventy-one, cross-border members' support. In our region, all eyes are on salmon and steelhead run projections, fishing season options, and related economic impacts of the decline in wild salmon and steelhead, particularly in the Snake Basin and its main tributaries, the Clearwater River and Salmon River. Residents are also aware of and alarmed by the dire circumstances of the Salish Sea's southern resident orcas as a result of their no longer having plentiful food chinook salmon. According to the Oregon and Washington Departments of Fish and Wildlife February 20, 2019, Joint Staff Report, the Snake River total spring/summer chinook numbers in 2018, which had been projected to be 107,400 fish, numbered 67,596. The forecast total for 2019? Just 48,100 fish. As per the Report, the projected Snake River wild spring/summer chinook number of 18,500 actually came in at only 11,339. The forecast for 2019? A mere 8,200 fish. The Northwest Power and Conservation Council asserts a goal of overall smolt-to-adult return levels (SARs) in the 2%-6% range, with a 4% average and 2% minimum for federal ESA-listed Snake River and upper Columbia River salmon and steelhead. The Snake River overall geometric mean SAR during 19641969 was 4.3% compared to 1.0% during 19941999 and 1.1% since 2000. The four lower Snake dams were built between 1961 and 1975. According to data reported in 2017 by the Comparative Survival Study Oversight Committee and Fish Passage Center, the "smolt-to-adult (LGR to GRA, jacks included) of PIT-tagged Snake River wild spring/summer Chinook had a geometric mean of 0.84% and exceeded the NPCC's minimum SAR objective of 2% in only two migration years (1999 and 2008) during the period 1994-2015. ... SARs (LGR-GRA, jacks included) of the unlisted, reintroduced Clearwater River Chinook were somewhat lower (geometric mean 0.53%). ... the trends in the overall SARs (LGR-GRA) of Snake River wild and hatchery Chinook groups were similar and highly correlated (average r= 0.79) during 1997-2015." The Comparative Survival Study Oversight Committee and Fish Passage Center also stated that "... improvements to fish travel time, mortality rates and survival may be possible through management actions that reduce WTT [in-water travel time] and increase spill percentages. There are only two means for reducing WTT: reducing reservoir elevations and/or increasing flow rates. Currently, only the reservoirs in the lower Snake River are maintained near their minimum operating elevations during the fish migration season. The McNary, John Day, The Dalles and Bonneville projects [on the Columbia River] all operate several feet above their minimum operating elevations during the fish migration season. Even without a change in flow levels, the data indicate that there is opportunity to reduce fish travel time and increase survival through the MCN-BON reach if these four projects were to operate at their minimum operating pools. The data also indicate that there is an opportunity to reduce fish travel time and increase survival throughout the FCRPS through increases in spill levels up to the tailrace dissolved gas limits." Further, "Regional requests and recommendations to increase spill levels to improve survival for juvenile outmigrants have been countered by concerns over potential detrimental effects of high Total Dissolved Gas levels on juvenile mortality rates or survival probabilities. Using a comprehensive data set of instantaneous mortality rates and survival probabilities collected 1998-2016, we found no evidence that high TDG levels were associated with increased mortality rates or reduced survival probabilities." Finally, the above report concluded that "Pre-harvest SARs in the range of 4% to 6% are associated with historical levels of productivity for Snake River wild spring/summer Chinook." We find ourselves asking, what are humans willing, in good conscience, to not do to rescue wild salmon and SR orcas from the brink of extinction? the brink to which our dams have brought them. On that note, the Palouse Great Old Broads urge the WA Department of Ecology to, at the least, proceed with increasing spill to 120% total dissolved gas and to take the further step of increasing water quality rules in 2019 to allow 125% total dissolved gas. Cross-border Washington-Idaho Broad regards, Cynthia Magnuson and Patricia Jessup, Palouse Great Old Broads Co-chairs cmcindyidaho@gmail.com jessup.patricia@gmail.com USPO: Palouse Great Old Broads, %Borg Hendrickson, 1820 Orchard Ave. Moscow ID 83843

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Comment From: Joanne Richter

2/25/19 @ 5:45 AM

I strongly support increasing spill levels at the four Lower Snake River dams to the 125% total dissolved gas limit. The Salish Sea's endangered southern resident orcas once thrived thanks to plentiful thousands of Chinook salmon. Today with Columbia...↓

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Comment From: Rynda Clark

2/25/19 @ 5:02 AM

Please modify short term dissolvable gasses criteria to allow more spill from the Snake River dams. The salmon cannot survive current conditions without help. The entire ecosystem is near collapse. Please do what we can to save it.

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Comment From: Alida Bockino

2/25/19 @ 3:15 AM

I urge you to support the Washington Dept of Ecology"s proposal to increase spill levels on the dams. This proposal, also supported by the Washington Orca Task Force and Gov Jay Inslee, is the best way to improve salmon survival which in turn greatl...↓

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Comment From: Pat Rathmann

2/25/19 @ 2:19 AM

In order to protect the orca population it is necessary to provide adequate salmon. Breaching the lower Snake River dams will accomplish this.

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Comment From: Mary Bostick

2/25/19 @ 1:36 AM

I strongly support the WA DOE's proposal.The Salish Sea's endangered southern resident orcas once thrived thanks to plentiful thousands of Chinook salmon. Today with Columbia River/Snake River Chinook salmon populations in severe decline, the orcas n...↓

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Comment From: Kelly Iriye

2/20/19 @ 8:30 AM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their s...↓urvival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, Kelly Iriye Sequim, WA 98382

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Comment From: Shelly Johnson-Choong

2/19/19 @ 3:47 PM

I am in favor of the flexible spill agreement for the salmon season of 2019 through 2021 for the eight federal dams on the lower Snake and Columbia rivers. However, I see this as a temporary and short-term solution with the need for the Snake River d...↓

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Comment From: Darrel Jensen

2/19/19 @ 2:47 PM

Leave the dams alone!! Shoot the seals!!

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Comment From: Ranell Nystrom

2/19/19 @ 2:28 PM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their s...↓urvival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, Ranell Nystrom Tacoma, WA

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Comment From: Ashley Stefanoff

2/19/19 @ 12:13 PM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for thei...↓r survival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, Ashley Stefanoff

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Comment From: Melissa Borden

2/19/19 @ 9:51 AM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their ...↓survival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, Melissa Borden

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Comment From: Mary Coleman

2/19/19 @ 4:36 AM

Dear DOE, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their survival, as w...↓ell as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are NO LONGER NEEDED for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, M. Colemen

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Comment From: JoAnn Margo

2/19/19 @ 3:06 AM

Dear Department of Energy, Orca scientists have made it clear that our Southern Resident Orca (SROs) are in a starvation crisis. Because SROs' diet consists of at least 80% chinook salmon, having an ample chinook salmon population is key for their s...↓urvival, as well as that of many other species, and indeed, the entire PNW ecosystem. The Columbia/Snake chinook population is crashing this year, with fewer than 50,000 expected to return, about 1/10 of the 10-year average. Accordingly, I urge you to exercise Washington's authority under Clean Water Act section 401 to help ensure the Columbia Basin's federal dam operators take action to reduce rising water temperatures, protect salmon, and help save the Southern Resident orcas from extinction. When river temperatures exceed 70F for several days at a timeas happens with increasing frequency due to climate changesalmon have difficulty migrating upstream and begin succumbing to stress and disease. According to the Fish Passage Center, an independent government agency, "under a climate change scenario, the long-recognized and largely unaddressed problem of high-water temperatures in the [Columbia and Snake rivers] becomes an ever-increasing threat to the survival of salmon." On the Columbia and Snake Rivers, hydroelectric dams make the heat pollution even worse. Federal dams on the Columbia and Snake rivers have never obtained water quality certifications under Section 401 of the Clean Water Actleaving Washington without authority to protect its own water quality and fisheries. Until now. According to EPA's own draft analysis, summer temperatures in portions of the Columbia and Snake rivers are up by 1.5 degrees Celsius since 1960 because of the combined effects of climate change and dams. Temperatures are so high, sometimes exceeding 70 degrees, that they kill migrating salmon, such as in the sustained hot summer of 2015. The EPA's own analysis also shows that removing the 4 Lower Snake River dams (LSRDs) would have the most impact on reducing temperatures to the salmon survival range. Removing the 4 LSRDs would also assist with lowering the temperatures behind the 4 mainstem Columbia dams. The 4 LSRDs are no longer needed for hydropower, as they generate only about 3% of the system's power, which is at about 16% surplus. Nor do they provide any flood control. The irrigation provided at Ice Harbor Reservoir to about 37,000 acres can still be provided post dam breaching via lengthened pipes and additional pumps. It is imperative for the sake of having our SROs and salmon survive that the 4 LSRDs are breached in 2019. I therefore request that DOE enact water temperature standards that will provide incentives for the federal operator, USACE, to breach the 4 LSRDs to come into compliance with the Clean Water Act and Endangered Species Act. Lower water temperatures in the Columbia and Snake Rivers will help save salmon, orcas, and the entire PNW ecosystem. We in WA state must be leaders, where the federal government is failing to protect our irreplaceable environment and wildlife. Thank you, JoAnn Margo Minnesota

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Comment From: Jim Waddell

2/18/19 @ 5:00 PM

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Comment From: Ninette Jones

2/17/19 @ 7:35 AM

History reveals that before the construction of the Bonneville Dam that there have always been bottlenecks on the Columbia River where fish would pool and rest and humans and marine mammals could eat them. Historians note log jams, beaver dams, and...↓ the great Celilo Falls is once where the strongest and fastest salmon escaped dip nets and hungry animals from winter until the spring as Chinook salmon ascended the tumultuous river & thunderous & sacred falls. One Hundred and thirty other non human animal species rely on salmon for their very sustenance --not sport. In the Columbia River estuary sea lions and seals could easily feed on fish through the winter until the spring as Mother Nature intended, and there were always enough salmon for the tribal fisheries, abundant populations of bears (grizzly and black), wolves, coyotes, bobcats, lynx, osprey, terns, loons, herons, eagles, mergansers, American dippers, cormorants and on and on that all subsisted in part on differing life histories of salmon and steelhead within the Columbia Basin( B. Mc Millan 2008). Celilo Falls although, created an impassable bottleneck for pinnipeds on the Columbia River. Moreover, healthy salmon swim faster than sea lions by Mother Nature's design and as history has shown us the Columbia River was once a series of tumultuous swirling, frothy, cold, rolling rapids; rushing to propel, young salmon, down river on their outward migration, towards their adult habitat, the sea. The Columbia River habitat now consists of warming narrow channels and slack water lakes created by the US ACOE hydroelectric dam's reservoirs and now Chinook salmon returning to Idaho's Snake River must pass eight dams twice in their lifetime. National Marine Fisheries now reports a 20% conversion rate for these salmon at each passage facility so the US ACOE providing intentional adequate river flow over the dam in the spring will help push young salmon towards the sea in a timely manner. Altogether, cold water spilling over the dam helps young fish avoid the dam's turbines, avoid lenthic warming aquatic habitat conditions that now favors non- native piscivorious fish such as small-mouth bass, walleye, channel catfish, northern pike, pike minnow and American shad (NMFS, Sanderson 08) over native cold water fish. Most of the non- native fish- eating fish were and are still intentionally stocked or not, and or released into the Columbia River for sport fishing. And these non native and hatchery fish populations are all well known for competing with the salmon for food and habitat resources and non-native and hatchery fish known for predating heavily on millions and millions of baby salmon as they float down river on their outward migration towards their adult habitat the sea. Non- native fish populations now make up the most abundant populations of fish in the Columbia River estuary. On the other hand what we know about marine mammals is that sea otters, Steller sea lions and southern resident orca populations are all important native key- stone species in the Pacific Northwest bioregion. Sea lions for example are opportunistic eaters and they are breast stroke swimmers and sea lions tend to consume the prey that is most abundant in the estuaries which are now populations of non native and hatchery fish (Sanderson08). The US ACOE observers at the dam have reported that not all sea lions that visit the Bonneville Dam are proficient at catching salmon. In addition, according to sea lion scat samples taken in the lower estuary-- NMFS reports that 90% of the time sea lions diets do not consist of salmon. Sea lions and many other species of marine mammals and Chinook salmon have always called the Columbia River estuary home and both of these species thrived and survived together in huge populations just fine for over ten thousand years in the Columbia River estuary. In addition, sea lions and other species of marine mammals all have very important jobs to perform in our Pacific Northwest ecology. Attached is a peer reviewed study that compares the difference between human and the sea lion's gut flora and highlights these important differences to show how the sea lion's gut flora are corner stone in the food web for all life in the oceans. Altogether, sea lions have 60 plus micro- biomes that are significantly different than the human micro-biomes and that sea lions and whales are essential nutrient productivity pumps that enhance the health of our rivers, oceans and estuaries. It is now, known, how important top native, non- human animal predators are such as, whales, orcas, wolves, sea otters and steller sea lions that all have the power to potentially influence change across terra and aquatic landscapes down to the plant life, influence the climate, influence the health & distribution of prey, and that removing key stone species can directly influence a river's flow. Native key stone species are very valuable for the Columbia River estuary and losing them will be a great loss for many populations of fish species In the end the state of Oregon and Washington waging war on sea lions below the Bonneville Dam and on a Superfund site called the Willamette River undermines the productivity of the food- web in the Columbia River estuary and her tributaries; it does not enhance it (trophic cascades). Top key stone species like steller sea lions, sea otters and southern resident orcas keep the health of the Pacific Northwest ecology in check by predating on the weak, the sick, the old, the injured, NIS and hatchery fish. Steller sea lions and southern resident orca are both important species in providing food for scavengers and for promoting estuary health -- the sea lion's gut flora creates fish food and these animals bring life enhancing nutrients into the estuary and up river. The presence and protection of many populations of marine mammal species in the Columbia River estuary is corner stone in protecting and enhancing the productivity of the food web, and important for strengthening the hearts, minds and strengthening the very genetics of the native wild cold water fish. As well, the US ACOE intentionally, providing adequate spill of cold flowing river water over their eight dams in the spring is a positive step towards ensuring the survival for many, many human and non-human animal species in the Columbia River estuary for many future generations to come. For the children, marine mammals, salmon, and the Columbia River estuary. Ninette Jones Portland, Oregon _____________________________________________________ 1. http://bioscience.oxfordjournals.org/content/59/3/245.full 2. http://bioscience.oxfordjournals.org/content/59/3/245.full 3. "The volume of plant plankton has declined across much of the world over the past century, probably as a result of rising global temperatures. But the decline appears to have been been steepest where whales and seals have been most heavily hunted. The fishermen who have insisted that predators such as seals should be killed might have been reducing, not enhancing, their catch". https://www.newscientist.com/article/mg21128201-700-vital-giants-why-living-seas-need-whales/ 4. Lichatowich, Jim. "Salmon, People and Place " A Biologist's Search for Salmon Recovery. Corvallis OR: Oregon State University Press, 2013. 5. https://lewisandclarkjournals.unl.edu/search?utf8=✓&qfie ld=text&qtext=phoca rock 6. https://lewisandclarkjournals.unl.edu/item/lc.jrn.1806-02-23 7. B. Mc Millan 2008 Researching Columbia Sea lion Population

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Comment From: Jacqueline Koch

2/16/19 @ 3:40 AM

We need action now -- More spill to ensure greater salmon returns. I am a longtime resident and the chinook salmon and orca are our living national treasure. We cannot allow these endangered species face extinction on our watch. Near term, the only o...↓

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Comment From: Brad Staples

2/16/19 @ 1:42 AM

Please look at increased spill through the Columbia River Hydro System to flush migrating Salmon & Steelhead juveniles over the Dam's Spillways, instead of through the turbines. I know that there is a risk of Gas Bubble Trauma that can cause increase...↓

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Comment From: Fish Passage Center (Michele DeHart)

2/14/19 @ 7:22 AM

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Comment From: Kelly Iriye

2/14/19 @ 4:53 AM

Spill, by itself, is not going to result in successful increase in Chinook salmon. This past year, spill caused Adult mortality because the dissolved gas started causing bubbles under their skin. Then the force of the spilled water and current litera...↓

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Comment From: Daniel O'Brien

2/13/19 @ 9:48 AM

Please take down the lower snake river dams because we really have to save the chinook salmon and the southern resident orcas who eat them for food. This is an emergency.

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Comment From: Northwest Sport Fishing Indust... (Liz Hamilton)

2/12/19 @ 5:00 PM

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Comment From: Defenders of Wildlife (Sristi Kamal)

2/12/19 @ 5:00 PM

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Comment From: Sea Lion Defense Brigade (Ninette Jones)

2/12/19 @ 5:00 PM

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Comment From: Whale & Dolphin Conservation (Colleen Weiler)

2/12/19 @ 5:00 PM

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Comment From: Columbia River Inter-Tribal Fi... (Rob Lothrop)

2/12/19 @ 5:00 PM

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Comment From: Howard Garrett

2/08/19 @ 2:47 AM

I support increasing the dissolved gas levels to 125% and the duration of spills to help smolts get downstream, despite the potential cumulative deleterious impacts to all fish downstream that may weaken them, impairing their abilities to function, a...↓

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Comment From: Tim Colton

2/05/19 @ 11:35 AM

I'm glad to see WA State increase spill levels through Columbia River System Dams during salmon out-migration. This is an important short term step to increasing salmon populations in the Columbia watershed. I do believe that more drastic measures,...↓

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Comment From: Mark Booker

2/05/19 @ 8:01 AM

Using spill and River Dam spillways to move migrating fish downstream is short sighted for at least the following reasons: 1. The tremendous turbulence of the ninety foot spill down the spillway will damage any migrating fish very likely beyond surv...↓

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Comment From: Rodney Fosback

2/04/19 @ 11:12 AM

Start with Boundary Dam; doesn't matter who owns it. Next: Where is all the electricity going to come from for all the electric cars planned, with tax payer money, for the future? And please, don't say more wind mill generators. Those inefficie...↓

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Comment From: Gene Spangrude

2/03/19 @ 6:06 AM

My comments, including three (3) PDF attachments, are focused towards the 'historical conditions' of the Lower Columbia River Basin, including the Lower Snake River. Salmon related issues have been long documented and presented in various Reports,...↓

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Comment From: Elizabeth Siler

2/03/19 @ 4:22 AM

Spill the water. Save the salmon. Save the orcas. Can WA state really afford the awful worldwide publicity of pictures of a starving orca mother carrying a starved dead orca baby for two weeks? These are iconic animals. Do what us needed ...↓

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Comment From: Mark Booker

2/01/19 @ 7:59 AM

Increasing flows on the river system has been proven to be counterproductive to migrating fish. Increasing gas levels only makes migrating fish bare more stress, resulting in limiting natural migrating fish ability to avoid/react to predators in r...↓

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Comment From: Janet Alderton

1/31/19 @ 4:47 AM

I support the implementation of this plan to help more juvenile salmon survive their passage from above the dams on the Snake and Columbia Rivers to the down-river waters that connect to the Pacific Ocean. The Endangered Southern Resident Orca Whales...↓

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Comment From: Angela Harrison

1/31/19 @ 4:28 AM

We need to do whatever is necessary to restore our environment. Increasing the spill may be a good start but please consider doing more. This solution seems to be a half hearted and politically motivated. The environment is the economy and we ar...↓

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Comment From: Cathy Home Cathy

1/31/19 @ 1:26 AM

Yew, increase spill on all the dams. Yes, dam removal on the lower 4 snake river dams is good place to start. What is good for the salmon is good for all of this fragile eco system. I live in the San Juan islands and I believe that we need to do...↓

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