I. INTRODUCTION: This resource page provides a review and summary of the federal agencies' recent public comment period for the 2020 Columbia River Systems Operation (CRSO) Draft Environmental Impact Statement (DEIS). A short introduction to the process is followed by (1) a partial list of the official comments submitted by sovereigns, stakeholders and independent experts, (2) a select list of press stories and (3) links to other resources. As reflected here, the federal government's DEIS has come under heavy criticism from many quarters due to its significant shortcomings on both process and substance.
On process: Even before the COVID health crisis, the government's 45-day comment period was woefully inadequate for an 8,000 page document that deals with issues of critical importance to the people of the Northwest and nation: the fate of endangered salmon populations and Southern Resident orca; the health of fishing and farming communities; and the future of the Bonneville Power Administration and regional energy grid. In response to the pandemic, all public meetings were (rightly) cancelled. However, despite many requests (see letters below) for comment period extensions and modifications, the federal agencies refused to make any further adjustments to accomodate meaningful public involvement and feedback under the unprecedented circumstances.
On substance: The comments below highlight in myriad ways the agencies' flawed analyses: indefensible assumptions, over- and understated costs and benefits that skew to support the agencies' Preferred Alternative, incomplete or ignored science and economics, and much more.
II. BACKGROUND: On April 13, 2020 the U.S. Army Corps of Engineers, Bureau of Reclamation, and Bonneville Power Administration closed a 45-day comment period for their Draft Environmental Impact Statement (DEIS) for endangered Columbia Snake River salmon and steelhead. This National Environmental Policy Act review was ordered by the U.S. District Court in 2016 when it invalidated the agencies’ latest plan for Columbia Basin salmon. The 8,000-page DEIS considers five salmon/dam management alternatives, including one that would restore the lower Snake River by removing its four federal dams. Though the federal agencies' own analysis finds that restoring a free-flowing lower Snake River will deliver the greatest salmon survival and recovery benefits, the federal agencies instead recommend a 'Preferred Alternative' that, if adopted, will perpetuate a status quo approach has for 25+ years proven to be illegal, unaffordable and inadequate - and has brought Columbia-Snake River salmon and steelhead populations in recent years to some of their lowest returns on record.
A new approach is urgently needed: This 'new' Draft EIS closely resembles five previous federal salmon plans that have all been rejected by courts as inadequate and illegal. Frustrated by a 25 year-old federally-led process that has failed salmon and orca, and our communities and energy system, growing numbers of people - including stakeholders, sovereigns and policymakers across the Northwest - are calling for a new, collaborative and regionally-centered approach that recovers abundant salmon populations, invests in prosperous fishing and farming communities, supports an affordable, reliable energy system and upholds our nation's responsibilities to tribal communities.
III. PUBLIC COMMENT: Nearly 100,000 people submit comment supporting a restored lower Snake River and community solutions: Despite the inadequate public comment period and process, many people, organizations, issue experts and sovereigns submitted official public comment. Approximately 100,000 people from the across the Northwest and nation submitted comments calling for leadership from Northwest policymakers to support the development of a comprehensive solution that restores the lower Snake River through dam removal, meets the needs of farming communities and maintains an affordable and reliable energy system.
In addition to citizen comments, several dozen entities and experts also submitted detailed comments highlighting issues of critical concern as the agencies move forward to finalize the EIS. Below find a select list of comments from Tribes, States, NGOs and independent experts raising serious concerns about the Draft EIS and calling on the federal agencies to, among other things, carefully, thoroughly and fairly consider the costs, benefits, opportunities and tradeoffs associated with the removal of the four federal dams on the lower Snake River before they issue a Final EIS (though few expect any meaningful changes or improvements). The federal agencies will issue a Final EIS in June, a "new" Columbia-Snake salmon plan ('Biological Opinion') in July, and an official Record of Decision in September 2020.
IV. LETTERS REQUESTING EXTENSION/MODIFICATION OF THE DEIS PUBLIC COMMENT PERIOD DUE TO COVID-19 PANDEMIC:
- Letter sent by 13 Congressmembers and Senators from Washington and Oregon requesting that the DEIS public comment period be extended until after the COVID-19 threat to public health has passed. (March 2020) PDF
- Letter sent by 24 NGOs based in the Northwest states to Federal Agencies requesting that the CRSO DEIS public hearings be postponed and rescheduled at a later date after the public health risk caused by the coronavirus has passed. (March 2020) PDF
- Letter sent by 22 NGOs based in the Northwest states to Federal Agencies requesting that the CRSO DEIS public comment period be extended from 45 days to 120 days to allow for meaningful public review and feedback. (March 2020) PDF
V. OFFICIAL PUBLIC COMMENTS FOR THE 2020 CRSO DEIS: Below is a partial list of the formal comments that were recently submitted by sovereigns and organizations and others to the federal agencies.
Confederated Tribes and Bands of the Yakama Nation
Columbia River Inter-Tribal Fish Commission
Governor Brown of Oregon: cover letter and full comments
Governor Little of Idaho: cover letter and full comments
Governor Inslee of Washington: cover letter and full comments
Governor Bullock of Montana and the Kootenai Tribe of Idaho
Pacific Fisheries Management Council
Conservation NGO Sign-on Comment Letter
Earthjustice comments, on behalf of 16 NGOs
Great Old Broads for Wilderness
Natural Resources Defense Council
Northwest Energy Coalition: 4-page comment summary and full comment letter
Northwest Resource Information Center
Southern Resident Orca Scientists
Northwest Guides and Anglers Fisheries Restoration Initiative
V. OTHER RELEVANT INFORMATION:
- Save Our wild Salmon Coalition Factsheet: Why the CRSO Draft EIS will not bring people together or deliver solutions for Northwest salmon, communities or energy system (March 2020) PDF
- Fish Passage Center: Chapter 2, Comparative Survival Study Annual Report for 2019
- SOS Resource Page: Summary of the Federal Agencies' NEPA Public Scoping Comment Period (Feb. 2017)
- Visit this page for links to recent court decisions, related fact sheets and media coverage (Feb. 2016)
- Collection of comments made by concerned citizens with pictures. PDF
VI. SELECT MEDIA COVERAGE:
Idaho Press: Don't let politics drive salmon, steelhead into extinction (April 13, 2020)
Lewiston Morning Tribune: Idaho fishing towns object to Columbia River study (April 11, 2020)
Lewiston Morning Tribune: Groups want more time to comment on river plan (March 7, 2020)
E&E News: Spotlight turns to states as critics slam feds' salmon plan (March 3, 2020)
AP/Seattle Times: Feds reject removal of 4 Snake River dams in key report (Feb. 27, 2020)
Contact Carrie Herrman if you have questions or would like to get more involved.
You can visit the federal agencies' CRSO DEIS page for further information, to access the 2020 Draft EIS and to review additional comments here.