Recommendation 11 Footnotes

Footnote 1: We hasten to add that there are true physical emergencies which cannot be solved with money, and we do not object to the declaration of an emergency in those narrowly defined circumstances. However even these types of emergencies can be reduced in the long run if strategies of type "C" and "D" were utilized.
 

Footnote 2: From the 2000 TMT Emergency Protocol: "It is appropriate to define emergencies as they apply to the operation of the FCRPS. As evident from previous actual events, emergencies are a unique situation having the potential for many types of impacts, generally requiring some type of action or response to minimize or eliminate impacts. An emergency may involve the need to operate the FCRPS outside of the requirements contained in the 1995 Biological Opinions or the associated Records of Decision (ROD) issued by the operating agencies. These events may increase fish mortality above levels in the 1995 Biological Opinion and RODs.

"However, it is important to distinguish emergencies from "planned risks." In operating a complex system such as the FCRPS, certain risks are assumed every day. Future conditions are uncertain. Operational decisions rely on predictions, forecasts and probabilities. If an extreme circumstance occurs, it is not necessarily an emergency even though it was sudden and urgent, and caused an immediate action to be taken.

"For this protocol, emergencies are categorized into three types. They are restricted to power-type emergencies only. Each type is described below and illustrated with several examples.

1. Generation Emergency - the potential for or actual insufficiency of electrical generation to satisfy electrical demand or load in a particular geographical area. The insufficiency can be of short duration (a capacity shortfall) or have the potential to persist for a period of time (an energy shortfall) and is usually spread over a defined geographical area as determined by the interconnectivity of the transmission and distribution system. For example, a generation emergency may be caused by an unanticipated loss of a generating resource - a project/unit forced outage; or by a restriction in the amount of water available for project discharge - reducing on-site generation; or by a loss of electrical transmission capability used to import electricity into a particular geographic area - a transmission line restriction or shutdown.

2. Transmission Emergency - the potential or actual loss or limitation in the ability to move electricity from the site of generation to the actual consumer or end-user. For example, a transmission line may fail, shutdown or otherwise be unavailable to transmit any electrical energy - a line outage; or a physical condition may exist that prevents or limits effective and reliable transmission - - insufficient reactive power (VARs) to overcome the inherent losses in long-distance transmission; or a temporary limitation on transmission line capability that restricts the export of electricity - which causes a generation surplus in one area, thus reducing overall generation levels but causes a shortage in another area as noted above in the description for a generation emergency.

3. Other Emergency - the existence or result of extenuating circumstances which fall outside the range of normal operations, was unanticipated, and may have resulted in catastrophic impact, physical damage or failure to part of the physical power system. For example, all natural disasters fall under this category of emergency - earthquakes, floods, and fires; or human caused failures - ship or barge strandings, facility failures (e.g., locks, gates, outlets, etc.), chemical spills into the river, train derailments impacting the river and terrorist acts; or overriding circumstances or needs that require operations to exceed normal limits such as a police investigation, a rescue operation, and a project operation specifically designed to prevent damage to or protect other parts of the FCRPS."
 

Footnote 3: The RFP would, for example, cite the Criteria under which the reserves could be called upon. We predict that once monetary consequences must be accounted for, those Criteria would have to be defined much more specifically. As written they are exceedingly vague and open to arbitrary interpretation.