Basic science is not being accomplished – any EIS needs to look at the overall picture – Too many proposals have had the EIS/EIR tailored to support the desired goal.  There is a requirement to attach costs to all of this and evaluate from there.  The competition for the fish is substantial. Their behavior as well as the predation needs to be fully quantified before any decisions are made.

                                Regarding the Salmon

-          What is the range of these fish

-          What is the take by fisheries outside of the 200 mi economic zone?

-          What is the impact of both the domestic and international marine fisheries operating in this zone

-          Marine Mammals Protection Act – what is the impact on the returns of  the sea lions congregating at the bases of the Columbia River dams.

-          What is the impact of the explosive growth of the sea lion population without indigenous hunting to keep their numbers in check.

-          How does removal of the four snake river dams that drain into the Columbia watershed connect to a Puget Sound Orca pod?

-          What has been the overall fish population trend for the various salmon populations – historic to present?

-          What are the factors contributing to the salmon runs?

-          The issue is likely one of competition for the food resource, if the sea lions are fishing out the population the Orca’s need to change their dinning habits, eat more sea lions.

Regarding the Orcas – similar questions

Regarding Sea Lions/Sea Otters/Harbor Seals – definition of fish take

Avian Populations of sea gulls, pelicans, eagles, ospreys, etc – definition of fish take

US marine fisheries – definition of fish take

Foreign fisheries – definition of fish take

Other predation – definition of fish take

                Regarding the removal of the power plants

                                They are green renewable power – cost of replacing the resource

                                Impact in dry years of not having water storage

                                Impact of not having flood control

                                Impact of sediment flows

                                Costs of breeching

-          Sediment flows similar to the Washington reservoir breached can be anticipated.

o   How many years before the eco system recovers?

o   Impact on the lower Columbia in sediment flows into Grand Coulee and down river?

o   Impact on sediment flows and costs of dredging to maintain the Astoria to Portland navigational channel?

o   What hydrodynamic modeling of these flows has been accomplished?

§  How does it impact the power generation of the Columbia Basin?

Based on the bad science and cherry picking of data that was used to Justify the removal of the Kamath River Power Plants I have very low confidence that the Department of Interior will accomplish a science based review when the Secretary of Interior has stated the Interior Department’s goal is to remove these facilities.  The National Science Foundation has severely criticized the various agencies for their lack of good well thought out science in their wild life decisions. The federal and state court system have similarly had issues with their failing to adequately quantify impacts and provide thorough cost/benefit analyses of their proposals.

 

We do not need a knee jerk response to this problem.  The situation needs to be fully understood.  If the power plants were the problem, it would have been apparent 60 to 70 years ago.  Something else is at play here.

 

Sincerely,

Werner Hoyt, PE

Lake Shastina