TMT Issues for the IT

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TMT Issues for the IT

MATERIAL FOR IMMEDIATE REVIEW

POSTED: 5 March 1997 0908

1) Issues on Emergency Protocols

2) Issues on SOR97-2

Please get your comments in to Cindy Henriksen as soon as possible. The IT is meeting tomorrow. Thanks

ISSUES ON EMERGENCY PROTOCOLS

As requested by the IT, the TMT had prepared a draft for Emergency Protocols, which is dated November 18, 1996. The salmon managers provided a re-write of the protocols on March 3. This new document led to the following issues being raised to the IT for further guidance.

Issue 1: definition of "emergency". The TMT needs further clarification on the definition of an emergency. A planned operation should not cause an emergency declaration; similarly a variation of an operation outside the Biological Opinion should not require the need to declare an emergency. One position is that any fish loss in excess of the 1995 Biological Opinion measures requires mitigation. The question then becomes: what was that fish loss measurement in 1995, and how does that loss translate to other water years?

Issue 2: overall objective. This issue is a follow-on to the first one: There is concern that the overall tone of the emergency protocols suggest that the system can be in emergency status continuously. There is concern that this was not the intent.

Issue 3: Mitigation: The TMT has agreed that once an emergency has been declared, a team will meet to ameliorate the situation as soon as possible. Once the action has taken the place, the TMT will go to the IT with a description of the emergency, the action taken, and quantify the fish losses during the emergency. The salmon managers first priority is to determine in-kind, in-place mitigation measures. The salmon managers would like sole responsibility for determining mitigation measures. Resident Fish managers would like to have an input to any mitigation measures to determine if the mitigation has an effect on resident fish. The full TMT would like to have the opportunity to discuss an array of possibilities of operations should mitigation be required by the IT.

Issue 4: Who can declare an emergency? The draft Emergency Protocols dated November 18 states that an action agency can declare an emergency at the executive level. These agencies are those that are responsible for the emergency and can take an immediate action to respond to the situation. The salmon managers would like Tribal Managers to have the ability to declare an emergency over those situations where they have statutory authority over the resource at risk.

Issue 5: What is the appropriate order of actions to take in the event of a generation emergency? In the event of a generation emergency, the November 18 draft had an action plan. The Action plan was separated into three groups. Group 1 was the same in both the TMT and Salmon Managers documents. In the November 18 document the group 2 and Group 3 lists were shown as follows:

Group 2 Actions:

Operate units outside 1%

Operate projects outside MOP

Reduce spill at one or more projects

Adjust flows outside planned targets

Group 3 Actions:

Restrict intertie capacity

Shed other non-BPA non-firm contracts

Reduce firm loads

Violate flood control or other first priority non-power requirements

Buy energy/capacity at any price

In the salmon managers document, groups two and three were reversed in priority, where all the actions in group 3 would be taken before the actions defined in group 2.

In an effort to have only one document for TMT use, Phil Thor has agreed to try to combine both documents into a legislative draft for further discussion by March 17, 1997.

POC for this draft: Cindy Henriksen

503/326-3745

ISSUES ON SOR 97-2

SOR 97-2 was distributed by the salmon managers on March 3 and discussed at the TMT meeting on March 4.

Montana had some overall objections to the SOR. These objections include the salmon mangers' desire for daily/instantaneous flow objectives. Montana objects to a requirement for a flow objective other than seasonal. Montana also objects to a required flow objective at Priest Rapids. The basis for this objection is that it might shift spill to Hungry Horse at some future date. Montana has written a companion document outlining their objections. This document will be available at the IT meeting.

The TMT found three issues resultant from the SOR, including:

Issue 1: End of March reservoir elevations at projects.

Issue 2: A lack of commitment on the part of the operating agencies to meet daily minimum flow targets.

Issue 3: What is the basis for the 134 kcfs requirement at Priest Rapids, and what is the biological effect if it is not met.

POC for this draft: Cindy Henriksen

503/326-3745

Montana Comments on SOR #97-2

This SOR was prepared by the salmon managers and presented to TMT on March 4, 1997. It is essentially a reworking of SOR #97-1 and our comments on SOR #97-1 also apply to SOR #97-2.

Montana stated at the TMT meeting it's objections to the request. These written comments supplement our oral objects at the meeting.

Montana opposed the request for three primary reasons:

1) It sets a precedent for daily, average or monthly flows. It was unclear from the opinions stated by the various salmon managers what the requested flow targets were. Some salmon managers stated explicitly that daily flows were requested. Others would not commit to what the targets were but stated that a seasonal flow average or a monthly flow average would not meet the intent of the request. This lack of intent between the signators of the request raise questions on how the precedent of anything less than seasonal averages would be used. Further more the request contains no biological justification nor citations for any flows other than seasonal averages.

Elsewhere the TMT has debated the emergency protocols. Based on face value reading of the salmon managers request, failure to meet the BiOp flow targets results in an emergency situation. By this new definition, daily flow targets, and based on the salmon managers concept of emergency protocols, acceptance of a daily flow target would guarantee that river management operations would be in an emergency status every year.

2) The SOR introduces a flow measurement point different than the BiOp. The additional Priest Rapids flow control point, while consistent with the Council's program, has a higher magnitude flow request than the Council's program and an earlier start date (April 1 vs. April 15). No justification or citation to support either of these changes is included.

3) Spill is expected to occur in 1997 in the lower river. The projected federal operations which the SOR seeks to modify creates more storage space for runoff than the SOR. Increased storage space is a legitimate method for reducing gas levels and reduces the need to shift spill (export the problem) to projects such as Hungry Horse Reservoir in Montana. Montana has requested in comments on the Water Management Plan that Montana projects not be included on the spill priority list. That request has not been incorporated into the revised WM plan. This leaves Montana to believe that the salmon managers by this SOR knowingly place Montana at risk to an increased likelihood of facing spill operations again in 1997. In 1996 use of the hollow jet valves created gas levels in the Southfork and Flathead Rivers that exceeded state water quality standards. This spill occurred during both salmon operations and over-generation situations. Over-generation was at least in part related to BiOp hydrosystem operations. Montana is genuinely concerned about the ability of project operators to manage gas levels and the potential to again exceed state water quality standards.

The SOR is based on a premise that a cold April may occur and flows will be correspondingly low. The converse was not evaluated. No analysis was performed to asses the risk associated with a warm wet April on flows and the need to further draft for flood control. The Corps projected operations appear to have considered this scenario. The salmon managers failed to even consult the National Weather Service to investigate their projected 30-day - 60-day or 90-day forecast. They commented that such longer range forecasts are unreliable. This suggests that reacting to no data or no forecast is better than having at least the professional judgment of weather experts.

Other factors in the discussion validate our objection to this proposal:

During discussion (and in the previous SOR #97-1) it was stated that the SOR is intended to address primarily hatchery stocks, although some wild stocks will also be present. Montana objects to native wild populations being placed at risk in an attempt to aid hatchery stocks. Especially when the wild stocks here are already the subject of ESA processes, subject to pre-ESA activity or already listed as species of special concern by the state. It is not that Montana is un-sympathetic to Washington's hatchery stocks, but these stocks will certainly benefit from other ESA operations later during the migration. In contrast, later ESA operation will only deflect more risk towards resident fish stocks in Montana and elsewhere.

Also during the discussion, the question was asked what the typical effect of cool a April was on fish migration. The salmon managers could not provide a definitive answer on the effects. They did not know if it would delay migration, stimulate migration, or have no effect. The issue of the BiOp logic to match flows with fish was also raised. The salmon managers could not definitively state that their proposed April flow demands would optimize fish flows.

During the 1996 fall chinook portion of the migration, the salmon manager's rejected a request to protect the September portion or the tail-end of the out-migration. This refusal was based on the assumption that more fish would be in the river in August and thus the flows volumes should be used then. However, SOR #97-2 is based on the opposite logic. It requests assurances for the protection of the front-tail of the run, at the risk of higher gas levels later when more fish will be in the river. The salmon managers should be asked explain this contradictory logic.

Other such logic contradictions exist. The salmon managers insist that the route to the April flood control elevation is as, or more, important than the final flood elevation. Thus they argue for flexibility. This is precisely the argument that Montana made last fall when it asked that flows be protracted into September. We asked for the flexibility to shape the flows to create more natural shaped hydrographs during the peak of the resident fish productivity season. Our request was denied as mentioned above because of the number of fish present. However, our request was also questioned, by at least some of the salmon managers, because we would ultimately end up at the same reservoir elevation. They were uncompelled by our concern that the route to the ending elevation was as important at the final elevation.

During the TMT salmon managers argued that the flood control operational flexibility should be allocated to benefit fish. However their request had no assessment of the benefits or risks to the broad spectrum of fish present in the system.

For these reasons, Montana objects to SOR #97-2.

C:\WINWORD\97OPS\SOR#2.DOC (MT)

If there are any questions on the material posted above, please contact Bolyvong Tanovan at 503/326-3764.

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  E-mail your comments and questions to: Nancy Yun (Nancy.9.Yun@usace.army.mil)
  File TMT/1997/info.htm Last Modified 02/27/97