Uma-Birch Floodplain Reconnection Project
The following comments were submitted in response to the open comment period described below.
Comments are numbered consecutively as they are received. Breaks in the number sequence result when comments are deleted because they
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BPA proposes to provide funding to the Confederated Tribes of the Umatilla Indian Reservation to enhance fish and wildlife habitat on about a 275-acre area along a one-mile stretch of the Umatilla River (between river miles 48.7 and 49.7) and along Birch Creek (river mile 0.0 to 0.75) at its confluence with the Umatilla River, near the town of Rieth, in Umatilla County, Oregon. Your comments will help BPA determine the issues that should be addressed in the environmental review.
For More Information:
https://www.bpa.gov/learn-and-participate/public-involvement-decisions/project-reviews/uma-birch
Close of comment: 10/19/2022
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ReedPlease see the attached.
View Attachment
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Ramos Scott/Mid Umatilla River CoalitionThank you for the very informative open house. It looks like a massive and very interesting project. I look forward to seeing the flow modeling to see how it will actually impact the properties downstream. I am also interested in seeing what method you utilize for flood control if you are indeed able to remove a portion of the USACE levee. Also, I'd like to know who is legally liable if this project causes adverse effects to property owners up or downstream from the project and if the impact to adjacent properties has been fully considered. Since our group is working on a wholistic long term project for our reach of the river, I will be curious to see how this works. Some property owners may be interested in this type of a restoration project on their portion where appropriate. There needs to be a good balance between restoration for habitat and flood control and protection for the crop lands as well as homes and infrastructure. We all want a healthy river system, and landowners are some of the best stewards of the land and habitat, so we need to do these projects taking all aspects into consideration, including flood protection. Thank you for your time and the opportunity to comment.
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KernsThe Pendleton levee has functioned very well for many years and prevented flood damage. An abnormally large flood (100-500 year) damaged the levee. Now instead of fixing the damage the solution is to remove it? I’m sure the funds used are slated for repair of the damage, not causing more damage. In typical government fashion, an expensive government project will be undertaken to undo a previous expensive government project. In turn this project will necessitate an even more expensive government project to repair the significant changes being proposed. Meanwhile the very real damage done by the flood there and at many other locations along the river will go unfunded, and unrepaired, while a useless and damaging project sucks up all the funds and dumps it into special interests hands.
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BarnettPlease see the attached.
View Attachment
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pace1. BPA’s environmental review should explain how removal of the zone 2A dike in the west end of the city Pendleton, OR, as well as preparing the area where a new dike will be built, is ratepayers’ responsibility?
2. Parties potentially responsible for funding this proposal include the city of Pendleton’s water/sewer fund, the county of Umatilla, the state of Oregon and/or the Corps of Engineers. BPA ratepayers aren’t even on the short list.
3. For example, the city of Pendleton funds eastern Oregon’s annual running of the goats. Pamplona on the Umatilla. Prescriptive goat grazing reduces fuel loads and opens up views of the Umatilla River for recreationalists.
4. Annual goat grazing also helps with weed control and, perhaps most important, contributes to keeping the City in compliance with the US Army Corps of Engineers Rehabilitation Inspection Program.
5. Funding for goat grazing (operation, maintenance and repair) along the levee comes from the city’s sewer fund and, if the city fails to comply with inspection and rehabilitation, ensuring compliance is the responsibility of the Department of Defense, not the Department of Energy and certainly not BPA’s ratepayers.
6. The state of Oregon’s responsibility for funding dike maintenance was in response to the February, 2020, flooding of the Umatilla River. Amid much fanfare on the part of the then-governor, Kate Brown, the city of Pendleton received a $1.8 million emergency loan for repair of the levee. Nobody looked to BPA ratepayers to contribute anything, and with good reason. The dike is simply not ratepayers’ responsibility. BPA’s environmental analysis should address this concern.
7. Using BPA ratepayers’ resources for habitat rehabilitation and restoration work in the Birch Creek basin is also problematic. Birch Creek habitat has been severely degraded by industrial waste ponds and impoundments.
8. Lands in the Birch Creek drainage have been hammered by a history of logging, grazing, dairy farming and large-scale factory farming. The phosphates discharged into the Umatilla River result in eutrophication problems. However, none of these environmental damages are in any way related to the hydroelectric system. Consequently, ratepayers’ have ZERO responsibility for restoring habitat in the Birch Creek drainage.
9. Apparently this project is undertaken pursuant to the 2008 accord, as extended, BPA struck with the Umatilla Tribe. The essence of the “buy a deal” approach BPA took with the Umatilla Tribe (and other parties to NWF v. NMFS) was to initially pay over $1 billion USD to tribes to ‘shut the f*ck up’ (STFU) in every forum related to threatened and endangered species.
10. The ‘hush money’ was laundered thru the Northwest Power Council’s fish and wildlife program, which BPA parasitized, under the guise of habitat improvement projects. BPA thus monetized its ESA (and Magnuson-Stevens Act) obligations by paying tribes, including but not limited to the Umatilla, to ignore infirmities in the mainstem in exchange for money, with the money siloed for habitat projects.
11. This arrangement provides say, 27% to 30% of total project costs in the form of indirect costs, which accrue to tribes’ general fund and are available to tribal leaders–the same leaders who are signatory to the accord and their successors–to expend as they see fit.
12. Aside from the statutory violations, this approach has a fundamental problem akin to a ‘short squeeze’ in habitat funding. There isn’t all that much rickety habitat in the basin (outside the mainstem) that can be classified as ratepayers’ responsibility. That appears to be the case with this project. BPA may be caught in a short squeeze and funding projects that are rightly the responsibility of other parties may be the only way to keep shoveling the money out the door so that the Umatilla and other tribes continue to STFU.
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