The NW Energy Coalition (“Coalition”) and the Save Our Wild Salmon coalition (“SOS”) appreciate the opportunity to comment on the Draft Climate Change Summary Report released by the U.S. Army Corps of Engineers, the U.S. Bureau of Reclamation and the Bonneville Power Administration.
The Coalition is an alliance of more than 100 environmental, civic and human service organizations, progressive utilities and businesses in Oregon, Washington, Idaho, Montana and British Columbia. We promote development of renewable energy and energy efficiency, consumer protection, low-income energy assistance, and fish and wildlife restoration on the Columbia and Snake Rivers.
SOS is a nationwide coalition of conservation organizations, commercial and sport fishing associations, businesses, river groups, and taxpayer advocates – all joined in a commitment to protect and restore Pacific Northwest wild salmon and the communities that depend on them.
We have been following the development of this report and the broader western regional basins study with which it is linked, and have participated as observers in the River Management Joint Operating Committee (RMJOC) with the assistance of the Northwest Power and Conservation Council.
We applaud the release of this draft report and commend the RMJOC Agencies for the depth and extent of the analysis. It is particularly noteworthy that this effort builds on the pioneering work of climate researchers at the University of Washington and elsewhere throughout the region, placing their data collections, analytical tools and assessments into an applied context where policy assessment and action can now start to occur.
The report shows that the Northwest does not face the drastic changes in precipitation, hydrology and temperature that are possible in the Southwest, but the projected changes are considerable and pose significant concerns for both long-term planning and short-term action. It is truly food for thought as we engage in both short- and long-run assessments of regional resource policy and management.
1. The projected changes in amplitude and uncertainty of temperature and precipitation quantity and timing, and decreasing relative forecast skill on an operational basis stand out:
- The report confirms previous findings that regional temperatures will increase moderately, total precipitation may not change much (under many scenarios), but the seasonal timing and shape of precipitation events and runoff will have significant impacts, including on the basic assumptions underlying the Columbia River hydrograph.
- Although changes in averages may not be trending at a fast pace, volatility appears to be increasing. Weather extremes cause the most problems and additional costs, as we have learned this year with very high flows, overgeneration and “environmental redispatch.” While some variability in the assessment may be model artifacts, it seems likely that uncertainty is growing on a planning basis, and this has significant consequences for policy efforts, including but not limited to: (1) revision of the Columbia River Treaty; (2) future editions of the Council’s fish program and Northwest Power Plan; (3) planning and implementation by federal agencies of the requirements for fish protection under Judge Redden’s recent decision; and (4) estimating future resource potential from renewable energy sources like wind and solar.
2. The report provides evidence in several places of increasing challenges to the effort to protect and enhance fish and other species at risk from changes in river flows and conditions. For example:
- Reduced ability to accurately forecast future water supplies (p. 19)
- “[E]arlier draft and refill of the projects could have late spring and summer impacts, such as lower river flows for fisheries objectives.” (p.44)
- “The change in runoff patterns at McNary Dam could also impact the ability to meet BiOp objectives during the summer. The ability to meet the fishery objectives could be reduced due to the lower average discharge available.” (p. 45)
- “Climate change might impact the ability to meet some BiOp objectives…so further review is necessary.” (p. 55)
The scope of the current report is summarized as assessing “how climate change could impact the hydrology and water supplies in the Columbia River Basin. It also identifies how supply-related impacts may affect how federal dams are operated in the future.”
We would like to suggest that the next phase of studies expand this scope to include two major additional components: effects on river temperatures as well as flows, and the effects on climate change in the northeast Pacific adjacent to the Pacific Northwest region.
3. Fish and wildlife, and especially anadramous fish, are especially sensitive to changes in temperature regimes. Many species experience significant reductions in viability when temperatures exceed their tolerance ranges. We strongly support adding an additional study component in the near future that assesses not only air temperatures but water temperatures as well. Determining where salmon and steelhead, as well as other species, may find refugia in the regional river and reservoir system as climate change advances in the coming decades is a critical focus for planning and action.
4. In addition, further and finer-grained flow projections will be helpful in assessing habitat changes, such as the impacts of changing winter flooding conditions on in-river spawning areas and redds.
5. The study scope should also be expanded to include assessment of changes in air temperatures, precipitation and sea surface temperatures in the northeast Pacific. Further study and understanding of the teleconnection between regional weather and climate patterns and the ENSO cycle, which itself may be undergoing significant structural change (as indicated in recent research on a second “El Niño” mechanism). This is a primary driver of regional weather at the decadal and smaller scale, as well as a direct determinant of ocean productivity which will be a major factor in supporting protection and recovery of oceangoing salmon and other species through the rest of this century.
Thank you again for the excellent work on this project and we look forward to further refinements and expansion. We believe this will show that despite the risks of climate change, effective assessment and action is possible. But there is no time to lose.
Questions may be addressed to Fred Heutte, Senior Policy Analyst, NW Energy Coalition, firstname.lastname@example.org or 503.757-6222, and Rhett Lawrence, Save Our Wild Salmon, email@example.com or 503.230-0421.