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April 19, 2000
Mark Walker
Director of Public Affairs
Northwest Power Planning Council
851 SW Sixth Avenue
Suite 1100
Portland, OR 97204
RE: Amendment to Fish and Wildlife Program
Dear Mr. Walker:
Public Utility District No.1 of Douglas County, Washington (Douglas PUD) submits the attached amendment for consideration in the Regional Power Council’s Fish and Wildlife Program Amendment process. We will also submit our proposed amendment via electronic mail as requested. If you have any questions concerning the District’s amendment, please contact Dr. Robert W. Clubb of my staff at (509) 884-7191.
Sincerely.
William C. Dobbins
Manager
Proposed Amendment to the Regional Power Council’s
Fish and Wildlife Program
The Council’s Fish and Wildlife program should be amended to require Federal reservoir storage to be managed with greater flexibility about flood control elevations to optimize flows and reduce flow fluctuations in the Columbia River.
Inflexible interpretations of Biological Opinion and flood control requirements by BPA and various other Federal agencies frequently create unnecessary or untimely flows or flow fluctuations and other environmentally detrimental effects such as spill at hydroelectric projects. A common sense and more balanced approach to managing the Columbia River reservoir storage should be used to improve water management basin-wide, to the benefit of fishery needs and other uses of the Columbia River.
Last year for example, Grand Coulee was operated to exact flood control levels despite an abundant snowpack and indications that the flow objectives under the ESA Biological Opinion would be exceeded. This resulted in widely fluctuating flows early in the spring and low flows during the month of April when juvenile salmonids were outmigrating in the mid-Columbia. A common sense approach would have been to allow flexibility to operate Grand Coulee below flood control requirements to prevent such undesirable river operations.
During years when the winter snowpack is below normal and target flows are not expected to be met, there should be greater flexibility in managing the Federal storage system to prevent spill and to reduce river fluctuations. BPA should be allowed flexibility to manage generation in reaching a flood control point, rather than a straight line draft from one flood control point to another. In doing so, BPA should not be considered in violation of its responsibilities if these operations result in Grand Coulee operating below an established flood control point.
A more balanced and common sense management approach for Federal storage is also expected to complement functional coordination of Federal and non-federal projects. A fully coordinated system can also help further reduce flow fluctuations and provides for stable reservoir levels at run-of-river hydroelectric projects. This translates into reduced impacts to shoreline erosion, protection of archeological and cultural resources, and protection of wildlife and submergent aquatic vegetation. Reduced flow fluctuations are also beneficial to emergent fry by reducing stranding and entrapment opportunities, particularly in the Hanford reach.