Comments are due on March 26 for the U.S. Army Corps of Engineers Draft Environmental Impact Statement (DEIS) for the Lower Snake River Programmatic Sediment Management Plan (LSRPSMP). Send them to email@example.com or mail them to U.S. Army Corps of Engineers, Walla Walla District, PSMP/EIS, Attention: Sandy Shelin, CENWW-PM-PD-EC, 201 North Third Avenue, Walla Walla, Washington 99362-1876.
Talking Points To Consider
1. In the LSRPSMP the Army Corps of Engineers makes constant reference to the “authorized purposes” of the Lower Snake River Project. The Corps assumes, and states thus in the DEIS, the agency is mandated to maintain a 14 ft. by 250 ft. navigation channel through the confluence of the Snake and Clearwater Rivers to the Port of Lewiston. This navigation channel depth and width appears only in the Flood Control Act of 1962. Flood control is NOT one of the authorized purposes of the Lower Snake River Project. The Corps further erroneously asserts that Congressional authorization to maintain this navigation channel at 14 x 250 is the same as a requirement from which it cannot vary no matter the circumstances.
2. The 2002 legal settlement that addressed dredging on the lower Snake River required that the Army Corps consider a number of alternatives to perpetual dredging. NEPA also requires the agency to consider such alternatives. Instead the Army Corps identified dredging as the only acceptable alternative by defining a major purpose of the LSRPSMP as maintaining the navigation channel. Since this channel is now less than 14 x 250, the only possible means of reestablishing and maintaining the channel, given the regular deposition of sediment in the channel, is to dredge. The LSRPSMP DEIS therefore fails to consider other alternatives to managing sediment in the Lower Snake River Project by definition of the purpose of the LSRPSMP.
3. NEPA requires the inclusion of a “no action” alternative. The “no action” alternative should serve as the benchmark for measuring all other alternatives, but the Corps has failed to provide that necessary tool for evaluation. The Army Corps defines the no action alternative as continuing to maintain the navigation channel. Without dredging they state they would first raise the minimum operating pool (MOP) to maintain a 14 x 250 channel. Once the maximum pool level was reached, the Corps states they would then need to dredge anyway. Raising the MOP and then dredging is NOT a “no action” alternative. Further, the Army Corps has failed to consider other available alternatives, and the Corps has not paid even paid lip service to the fundamental NEPA requirement of a robust discussion of such alternatives. The list of alternatives needs to include divesting the Columbia-Snake River System of a navigation channel to the Port of Lewiston, which by itself requires about 90% of the sediment removal at the confluence of the Snake and Clearwater Rivers and on the Clearwater itself. Another alternative the Corps fails to consider is the removal of the four lower Snake River dams and the replacement of waterborne transportation on the lower Snake with rail and other means of freight transport.
4. The DEIS fails to provide a full or even adequate accounting of the costs and benefits of dredging, of maintaining a navigation channel to the Port of Lewiston, or of maintaining and operating the lower Snake River transportation waterway. The Corps further fails to provide any analysis or comparison of the overall costs of dredging and barging with alternative transportation options like trucking and/or rail. There are simply no numbers or data of any kind specifying the total cost (or benefit) of the proposed 50-year project.
5. The LSRPSMP DEIS includes no assessment of the value and priority of this project compared to other proposed projects, costs, benefits and the likely priority of dredging and freight transport on the lower Snake River given the non-sustainability of the Corps’ extensive national system of dams, locks and levees. This issue deserves particular attention given the fact that ton-miles of freight on the lower Snake River amount to only 1/10 of 1% of waterborne commerce in the United States. In an era of severe spending reductions by the federal government, local communities need to understand how this project compares with other regional and national ACOE projects and be able to fully assess the likelihood of funding for dredging from the federal government over time.
7. The LSRPSMP DEIS fails to adequately address and incorporate the accumulating impacts from climate change. Climate change is here. It is raising water temperatures, changing the hydrologic cycle, and is widely predicted to significantly and steadily increase sediment loading into the reservoir. These anticipated impacts need to be adequately described and fully analyzed in terms of costs, impacts on reservoir capacity, flood control, and levee raising.
8. The DEIS fails to adequately assess the risk of flood in Lewiston, Idaho over time and the likely costs associated with levee-raising to address the flood risks created by the dam and levee system. Climate change is already affecting flood control capacity, options, and costs, as well as increasing the need for further action sooner than would be needed outside of a changing climate regime.
9. Dredging is bad for salmon. Dredging the lower Snake-Clearwater Rivers is harmful to salmon and steelhead and the habitats they depend on for survival, and this EIS fails to fully consider these impacts and ways to mitigate and minimize them. The DEIS states without justification that the dredging alternatives are the most ecologically friendly, but dropping dredging spoils in rivers cannot be justified as a salmon/steelhead habitat improvement measure. Wishing for dredging to be beneficial to salmon/steelhead does not make it so.
10. The DEIS fails to address the impact of carbon dioxide emissions and other greenhouse gases that would result from maintaining a navigational channel on the lower Snake River. The Ninth Circuit Court of Appeals, in Center for Biological Diversity v. National Highway Traffic Safety Administration, unanimously ruled that federal agencies must assess carbon dioxide emissions in review documents prepared under NEPA. A major 2001 study of grain transport from the inland Northwest concluded that ending commercial navigation on the lower Snake River would result in a significant savings in fuel and greenhouse gas pollution. (Casavant and Ball, Impacts of a Snake River Drawdown on Energy and Emissions, Based on Regional Energy Coefficients) The DEIS largely ignores this issue.
Comments are due March 26th!