The Ramifications and Reality of Breaching the Dams of the Pacific Northwest

April 14, 2024
By Sarah Clendenon

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What are the ramifications and true reality of breaching the dams of the pacific northwest (PNW)?

Please begin with our first article. Here in Part 2, we bring you additional information on the potential effects of dam breaching on the movement of wheat and other grains from Idaho, Oregon, and Washington farms to the Portland harbor for distribution worldwide. According to the Port of Portland, “The Portland harbor exports the largest volume of wheat in the United States” and “The Columbia River is the third largest grain exporting center in the world.”

In particular, this installment addresses omissions from the Columbia River System Operations Environmental Impact Study (CRSO EIS) and potential conflicts of interest identified by the Columbia-Snake River Irrigators Association (CSRIA).

CSRIA’s Who We Are page explains,

“The Columbia-Snake River Irrigators Association (CSRIA) represents many of Eastern Washington’s most prominent farming operations, with its members irrigating about 300,000 acres of prime row crop, vineyard, and orchard lands. The CSRIA works directly with its sister organization, the Eastern Oregon Irrigators Association, collectively bringing about 400,000 acres of irrigated lands into bountiful production.”

CSRIA 2024 Mission Statement:

The CSRIA will “keep the water at the pumps,” and it will work to enhance access to new water supplies for its irrigation, industrial, and municipal members.

The CSRIA supports water resources projects that are economically sound and promote the direct interests of water right holders and the communities that serve our economic base.

The CSRIA supports stewardship and environmental benefits based on sound economic policies for water resources management.

In a memo sent in September 2020 and addressed to CRSO Agencies EIS Managers and Interested Parties, CSRIA discusses the omission of options other than the complete breaching of the four dams, information on the need for an in-depth discussion of the impact this option would have on rail lines, and a potential conflict of interest in regard to the individual tasked with submitting the navigation and transportation impact portion of the EIS.

“The National Environmental Policy Act (NEPA) and its “Regulations Implementing the Procedural Provisions of the NEPA” dictate that a federal agency EIS [Environmental Impact Study] must include a review of relevant alternatives to the proposed action (preferred alternative) that manifest “reasonable courses of action… with information sufficient to permit a reasoned choice for the agency to evaluate…” While newly updated NEPA Regulations streamline review efficiency, alternatives to the proposed action must be identifiable with the “spectrum” of alternatives being analyzed.

The Final EIS contains no analytical review of Lower Snake River dam breaching/pool drawdown measures other than the complete, four-dam breaching alternative. Other potential hydro project alternatives affecting dam beaching or pool drawdowns are invisible and impossible to consider under the EIS review. The Final EIS presents a “worst case scenario,” avoiding a cogent picture of less disruptive hydro project measures that also could meet multiple project and ESA objectives.”

Specific to the irrigation aspect of the study, CSRIA concluded,

“The Final EIS irrigation sector impact analyses are impressively insufficient, lacking an experienced and fully engaged level of review.

From CSRIA’s perspective, the USBR [United States Bureau of Reclamation] placed little energy into assessing irrigation sector impacts on the Lower Snake River system, because they had no operational experience within the area, and they simply wanted to “get it done”…

The end result of the Final EIS is to underestimate the empirical and economic impacts to private sector irrigation projects along the Lower Snake-Upper McNary Pool river system.”

In the navigation-transportation arena, CSRIA is also very critical, saying,

“As with the irrigation sector, technical analyses for the navigation-transportation sector did not sufficiently commence until late in the EIS preparation process. Nor did this analysis receive much, if any, structured input from parties that had raised key technical concerns. The analysis problem focuses on an alternative rail route for grain shipments, where grain is no longer being shipped by river barge under a four-dam breaching operation.

The Draft EIS did not incorporate into its alternative rail route analyses operation of the main WATCO-Union Pacific rail line that borders the Lower-Snake (and Columbia) River system. This is a high-capacity line capable of moving increased grain volume.

The CSRIA has prepared two technical memorandums that outline the analyses problem, and that the omission of the alternative rail route in the TOM [Target Operating Model] analyses leaves a deceptive quality to the EIS analyses. …more effort was placed on avoiding the WATCO-Union Pacific route analysis than actually integrating it into the TOM analyses.”

The person listed as the primary author of the navigation-transportation section of the Draft EIS is Professor Eric Jessup, the Director of the Freight Policy Transportation Institute at Washington State University.

Although that is Jessup’s title at WSU, it was purported that he and another WSU professor were hired as “private sub-consultants” to write the navigation analysis for the EIS.

According to the CSRIA memo, Jessup wrote the following email to the Army Corps:

“Folks,
Based on interviews with the grain shippers and WATCO, the TOM model does not include the option to move grain from upland grain elevators to any river terminal via rail (similar to what has happened in the past using the Washington State Grain Train cars). The model does allow for these shipments to occur via truck, but according to WATCO the operating agreement with Union Pacific now makes this [rail transport] not possible.”

CSRIA says that just weeks later, representatives from WATCO and Union Pacific told them they had not ever been contacted by Jessup, and they had not spoken to anyone at the Army Corps or USBR either. CSRIA reports they told Jessup through email what WATCO and U.P. had said about never having spoken to him. Jessup never responded to CSRIA about WATCO and U.P. A month later, Jessup was asked for TOM model information and the role WSU had in preparing the analysis. Jessup’s response was to refer CSRIA to the Army Corps of Engineers.

As mentioned by CSRIA, Jessup’s WSU bio lists the Idaho Department of Transportation and the Idaho Wheat Commission as clients he has worked for as a consultant.

CSRIA’s memos conclude by saying,

“The navigation and transportation portion of the draft EIS is one of the most important sections in the document. The final EIS should rigorously analyze the impacts of breaching the Snake River dams on the movement of grain and other products downstream. Among the alternatives that the EIS should discuss are the transportation of grain by rail from Lewiston to Portland using the WATCO and U.P. lines. The TOM model — and more importantly, the narrative — should reflect the potential use of these lines to transport wheat if the dams were breached or if deep pool drawdowns were analyzed in the final EIS.

In my opinion, it will be difficult, if not impossible, for the federal agencies to develop a new regional alternative with stakeholders and end 25 years of litigation in federal court if the final EIS does not contain a more thorough and transparent analysis of the navigation and transportation impacts.”

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