Umatilla Hatchery Programs (Umatilla River Spring Chinook, Fall Chinook, and Coho)
The following comments were submitted in response to the open comment period described below.
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Bonneville Power Administration (BPA) is proposing to continue funding the Oregon Department of Fish and Wildlife (ODFW), the Confederated Tribes of the Umatilla Indian Reservation (CTUIR), and Westland Irrigation District (WID) to implement the ongoing Umatilla River Spring Chinook, the Umatilla River Fall Chinook, and the Umatilla River Coho hatchery programs. The Umatilla Summer Steelhead Program was previously assessed in an environmental assessment completed in 2022, and no changes are proposed as part of this environmental review.
BPA would fund activities such as broodstock collection, egg incubation, juvenile rearing, and release to support the three programs. Umatilla Hatchery Programs currently target the production and release of up to 810,000 spring Chinook smolts and 600,000 juvenile Umatilla fall Chinook. The Umatilla Coho Program acclimates and releases up to 500,000 Umatilla coho salmon. BPA has provided funding to these programs since the Umatilla Hatchery began operations in 1991 and proposes to continue funding within current production limits.
Other elements under consideration for BPA funding related to the ongoing operations of these hatchery programs include the development of new long-term hatchery water sources at the Umatilla Hatchery; routine facility maintenance; equipment upgrades; and research, monitoring, and evaluation activities. Because the Umatilla Hatchery and most of its associated facilities have operated for over 30 years, hatchery infrastructure is currently outdated or deteriorating. For this reason, the hatchery and some satellite facilities need non-recurring maintenance actions to maintain, repair, or replace equipment. Equipment identified for replacement includes a water-chilling system, water-intake system, components of adult holding and sorting facilities, upgrades to support buildings and electrical systems, and other similar components. In addition, the Umatilla Hatchery uses a water supply system originally designed and constructed to produce 15,000 gallons per minute, which has declined in volume over time. This has limited the ability to meet fish production goals. Therefore, this proposal for continued BPA funding also considers additional options to remedy the declining water supply, including potential development of new wells, hatchery water-reuse systems, or improvements at acclimation sites to reduce water use.
For More Information:
https://www.bpa.gov/learn-and-participate/public-involvement-decisions/project-reviews/umatilla-hatchery
Close of comment: 3/14/2024
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paceThe draft EA,p. 16, states ODFW, CTUIR, and Westland Irrigation District could acquire funding from other sources and proceed with these actions. For the purposes of this EA, however, the No Action Alternative describes the effects if there were a
decision to not proceed with these actions and hatchery production of all stocks at the hatchery and the satellite facilities would cease." For consideration, this statement makes it clear the BPA has conflated the no action alternative for BPA funding, which is the concern of the EA, with the failure by any and all other responsible parties (CTUIR, Westlands Irrigation, and ODFW) to fund any of the activities proposed for BPA funding. This conflation is not accord with the requirements of NEPA. BPA funding this project is the issue. The assumption that if BPA does not fund the facility then none of the actions will be taken by any other party is not the issue for purposes of NEPA documentation. The fact is BPA funding of upgrades, new water supplies, facilities would be "in lieu of funding" by the parties that are actually responsible for carrying out these actions. Put differently, BPA funding these activities would violate the provisions of the Northwest Power Act, which limit ratepayers, obligations to funding ONLY the protection, mitigation and enhancement of fish and wildlife to the extent that hydropower is responsible for declining resources. BPA is not a charitable organization. The Northwest Power Act specifically forbids saddling BPA ratepayers with costs that are the responsibility of CTUI, ODFW and Westlands. The combination of inappropriate characterization of the no action alternative with violations of the Acts, in lieu funding provisions renders this analysis fatally flawed, notwithstanding the fact that such a characterization is overused, often abused, and just plain tiresome.
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paceThere are several provisions of the Northwest Power Act that counsel against BPA funding the development of new long-term hatchery water sources, routine facility maintenance, equipment upgrades, non-recurring maintenance actions to maintain, repair, or replace equipment, and development of new wells, hatchery water-reuse systems, or improvements at acclimation sites to reduce water use. Section 839b(h)(6)(A) of the Power Act requires that funding for fish and wildlife complement the existing and future activities of the Federal and the regions State fish and wildlife agencies and appropriate Indian tribes. Section 839b(h)(8)(B) of the Act mandates that consumers of electric power shall ONLY bear the cost of measures designed to deal with adverse impacts caused by the development and operation of electric power facilities. Section 839b(h)(10)(a) restricts expenditures of the Administrator to be in addition to, not IN LIEU OF, other expenditures authorized or required from other entities under other agreements or provisions of law. I respectfully submit that none of the items listed above can be funded by ratepayers given these provisions, in whole or in part, of the Act. These matters should--perhaps must--be addressed in the environmental analyses before this proposed action can proceed. On the other hand, activities such as broodstock collection, egg incubation, juvenile rearing, and release can and should be funded as these are clearly protection, mitigation and enhancement actions for fish and wildlife. Everything else should be the responsibility of CTUI, ODFW and/or the Irrigation District.
- UMA-Hat240003 -
paceIn the event that BPA decides to proceed with funding for this project, section 839b(h)(10)(B). it must submit budgets to the Congress pursuant to 16 U.S.C. 838 et seq. and be funded in the same manner and in accordance with the same procedures as major transmission facilities under the Federal Columbia River Transmission System Act
- UMA-Hat240004 -
Krajcik/CTUIRSection 3.2.3.3: No action option could negatively impact native plants by removing any control of invasive plants done by facility staff.
Section 3.2.8.3: No action could lead to buildings being overgrown by plants, and building degradation, leading to an eyesore in the landscape.
Section 5.4.3: There will not be additional activity requiring a section 404 permit. Current intake and outfall maintenance does require a permit, which would continue to be necessary with continued funding of the project.
Chapter 5 Intro: Refers to Chapter 6 as a list of agencies and businesses contacted for comment. The list is actually in Appendix 2.
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Michelsen Correa/Environmental Protection AgencyThank you for the opportunity to review the Bonneville Power Administration’s February 2024 Draft Environmental Assessment for the Continued Funding for Umatilla Hatchery Programs (Umatilla River Spring Chinook, Fall Chinook, and Coho). EPA has completed its review and did not identify significant public health, welfare, or environmental quality concerns to be addressed in the Final EA. EPA includes the following recommendations to help strengthen the section on climate change impacts.
Declining water levels on the Umatilla River, in part attributed to climate change, is driving the need to find alternative water sources (i.e. new wells, recycling water, etc.) for the hatcheries. EPA recommends the FEA include a discussion about the project’s improvements and their sufficiency to meet continued declines in the Umatilla River water levels under future climate change scenarios. Also include a discussion about how climate change may impact the survival of hatchery-produced chinook salmon, which may experience increased mortality due to climate change.
On January 9, 2023, CEQ published interim guidance to assist federal agencies in assessing and disclosing climate change impacts during environmental reviews.? CEQ developed this guidance in response to Executive Order 13990 on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis. This interim guidance is effective immediately. CEQ indicated that agencies use this interim guidance to inform the NEPA review for all new proposed actions and may use it for evaluations in process, as agencies deem appropriate, such as informing the consideration of alternatives or helping address comments raised through the public comment process. EPA recommends the FEA apply the interim guidance as appropriate, to ensure robust consideration of potential climate impacts, mitigation, and adaptation issues.
Thank you again for the opportunity to review the BPA’s Draft EA for the Continued Funding for Umatilla Hatchery Programs. We look forward to reviewing the Final EA when it becomes available. If you have any questions, please reach out.
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