C:\FERC.WP5 Re-written For Washington Trout 3/30/1992 In 1984, Crown-Zellerbach's Port Angeles mill was sold to Daishowa America, a world leader in recycling technology, who have since installed $41 million in new machinery and turned it into the largest recycler of telephone books in the US. Because of uncertainties involved in relicensing the dams, C-Z retained ownership of the dams, but supplies 100% of their power to the Daishowa mill. In 1987 C-Z's assets were absorbed into James River II, a subsidiary of James River Corporation, the largest papermaking company in the U.S. Power from the James River dams amounts to over 30% of the Daishowa mill's annual electricity consumption, and replacement power will be expensive, even if it all comes from conservation instead of other sources. The electricity these dams produce would power Seattle's Columbia Tower skyscraper. Life, as a process, has existed on this planet for about four billion years. During this period, entire classes of organisms have come and gone. We would do well to remember that the Oxygen we now depend upon was once a pollutant, a poisonous byproduct of a few careless, self-centered organisms, something awful that other lifeforms had to learn to live with before Life itself learned to exploit it. Meteors have struck the earth. Geological processes have begun and ended. Even in the last 20,000 years vast floods have covered tens of thousands of square miles, and transported tens of millions of cubic yards of rock and top-soil to the sea. Equilibrium is an illusion, an artifact of the tiny window of time our lives allow us to observe. Stability is simply something we imagine, something we made up. This does not free us of the responsibility to make wise decisions. The hydroelectric dams on the Elwha River are an example of bad planning, the kind of political process that we can only hope we will someday learn to outgrow. The lower dam, built in 1914, barely five miles from the mouth of the river, usurped a vast public resource for private gain. It blocked the richest source of free food in the Olympic northwest, and the project was so poorly managed and the dam itself was so poorly constructed that it collapsed the first time it was filled, scouring the channel, destroying property downstream, and bankrupting the company that had built it. This one dam completely unraveled a process that had run, uninterrupted since the retreat of the Vashon Ice sheet, nearly 12,000 years ago. Since that time, the forested lands and the rivers that drain them, and the salmon that return to them year after year, have been developing together. People have been here the whole time, and have left a telling record in their garbage dumps. We find them exposed in landslides and dig them up when we excavate the foundations of our homes: firepits and middens, the remains of the campsites the Indians left behind. We see another record in the pollen layers preserved in lake-bottoms and bogs. This shows the pattern of forest fires, and the slow parade of flowering plants that gradually recolonized these mountains and shorelines. The salmon return from the sea to spawn and die, carrying back to the upper reaches of our rivers the richness of their bodies, ions of metals not found in the rocks of our mountains, proteins built from nitrogen and carbon, all collected during the years they spend foraging in the estuaries and oceans. In the blind passion of their return they bring these nutrients from the sea back to the land and in their death they leave them behind, to be distributed into a vast food-web containing at least 22 vertebrate species. Nothing else in nature does this. Every other natural process eventually depletes the land, drains its riches to the sea. The glaciers abrade it, the fires release it to the rain. The rain erodes it away and flushes it downstream, hurrying it back to the sea. It is very probable that in the wake of the retreating ice-sheet, the salmon prepared the barren mineral surface of the land for the forest we now see. Run after run of salmon fertilized the upper reaches of the streams and built up the nutrient supply until trees could take root and grow here. The forests appear to be very young on the Olympic Peninsula. According to the records left by the Indians, the big trees have only returned during the last 3000 years, and some of them are over 1500 years old. After there were big trees, the people on the north coast could build boats and take to the sea themselves, and they hunted for seals and whales. Until then, they lived off the land, off the salmon and deer, and other, smaller mammals. The Elwha drains a watershed of over 291 square miles, and is supported by [11] major tributaries. The geology of the central Olympics is some of the most complex on earth, and defied mapping until the middle of this century. The mountains here are composed of uplifted layers of ancient sea-floor, of basalts from undersea volcanos and sediments deposited during 40,000,000 years of continental erosion. Some of these ancient sediments remain as shales and sandstones, others have been metamorphosed into slates and schists. Each layer responds differently to erosion. About 15 million years ago, the material which became the Olympic Mountains was scooped off the bottom and slowly uplifted by a great ongoing collision. The horseshoe-shaped basalt crescent of mountains that flanks the peninsula on the north and east flanks, from near Neah Bay around the end of Discovery Bay to well south of the Skokomish River, represents the remains of a series of seamounts, great undersea volcanos, containing over [10,000] cubic miles of material. These enormous basalt mountains became caught in the subduction zone, the area where the eastward advance of the sea-floor runs under the lip of the north-american subcontinent. Behind them, the sea-floor continued to advance and the crust, which is thinner at the bottom of the ocean than it is at the surface, buckled and broke into gigantic slabs, the advancing sea-floor sliding under each broken plate and tilting it on edge. This happened dozens if not hundreds of times and created a unique landscape: alternating layers of harder and softer rocks. Eventually, the subduction zone moved west, off the coast this entire tortured landscape floated above the surface, and in the process, folded like a strudel. Millions of years of glaciation and mechanical erosion created the jagged high elevation terrain while rivers carved deep valleys along the veins of softer rock, carrying away millions of yards of material. The Elwha is only 45 miles long, the shortest, steepest of the radial rivers draining the central Olympics, and it carried much of the sediment away. Differential Erosion has exposed these layers, which are sometimes lying at shallow angles to the surface, and sometimes are tilted steeply. Where hard impervious strata are lying flat, the river spills out into broad reaches, where softer layers are tilted steeply, it has cut aggressive narrow channels. Those broad reaches provided the spawning gravels for the salmonids, while the chasms provided the challenges, the engine for evolution. To reach the headwaters, the fish had to navigate the hazards of the Elwha's gorges and canyons. To reach the headwaters of the Elwha and its tributaries, fish had to have incredible power and stamina. Ultimately, the stress of these obstacles [demanded the development of] {or alternately} [excluded all but] the Elwha's most unique creatures: its tribe of enormous fish, The Tyee or June Hogs, the legendary 100 lb. Spring Chinook. Mitigation is a word that comes from the Latin mitis, meaning "soft or smooth". The verb mitigare thus means "to smooth". A mitigation plan is simply an attempt to smooth or soften the blow we have dealt to the [life-forms][world] around us]. To be successful, mitigation for the impact of the Elwha dams on Salmonids must be designed around the different utilization patterns of the various salmonid species. The Timing of these runs reflects a wide variety of evolutionary strategies used by different tribes of salmon. Coho salmon spawn in the main-stem gravels, they hang out in the Elwha's pools, and don't move much until they begin to smolt, and then they move down-stream rapidly. Spring chinooks, including the Tyee, followed the runoff peaks to the upper reaches of the tributaries, and spawned there. Chinook fry as small as 30-40 mm long begin to move down river almost immediately, following the melt, before the streams run out of water. They spend about a year moving down river and because they are so small, they can't afford to stay any place very long, for fear of predation . When the turbidity goes up in the summer, from glaciers melting, the milky water provides a form of cover for the fry, protecting them from predators. Because of their unique migratory strategy, the impact of the dam on Spring-Summer Chinook runs is very difficult to mitigate. To get the seaward-migrating fish past the turbines, water must be diverted into bypasses, or over the spillway, and in either case, its power-generating potential is lost. A 6-8 month spill regime could be required to allow all the fish to migrate, but James River, the Corporation that owns the dams, maintains that a one month spill is the maximum that they can allow if they are to ensure economic operation of their dams. In 1970's the Lower Elwha Tribe, recognizing that the 50 year permit for the Glines Canyon dam would expire in 1976, went to Congress to seek Intervenor status in the relicensing procedure, and carried the issue thru committees and subcommittees. In the mid 80's they were granted intervenor status. The tribe's scoping document called for the full restoration of fish runs. The Tribe maintained that full restoration of fishery is guaranteed by treaty and by law, and that full restoration of self-sustaining runs to the Elwha requires dam removal. The most important and possibly most contentious point in this document appears to be the claim that genetically related remnants spring chinook still return to spawn in the Elwha. If this is true (and the fact that the Joint Fish and Wildlife agencies including the National Marine Fisheries Commission and the National Park Service, every agency except Washington Department of Fisheries, have endorsed this position clearly implies that the bulk of the scientific community believes that it is true) then time is probably running out fast. According to a former tribal biologist, the total number of wild Chinook returning in 1990 may have been as low as 12 fish. Dick Goin is a PA fisherman-turned-activist. He grew up on the river and has carefully followed the failures of the hatchery programs and the abuses of the Corporations for many years. Impatience fills his voice when he reminds us that "the wild fish cannot wait much longer. It is easy to forget," he maintains, "that there is this very critical time factor. We are looking back on at least 10,000 years of evolution of our native salmon stocks. All the efforts to introduce other strains of fish into this river have failed miserably. And these failures have always been extremely hard on the wild fish." FERC's FEIS on the Elwha projects will be released this year. In view of the comments received from the Joint Fish and Wildlife Agencies, I expect it to include a more realistic financial analysis than last year's draft. The DEIS called for a 10-year payback period for the mitigation, even though the permit for the Glines dam expired 15 years ago, the Aldwell Dam has built illegally and has never been licensed, and the proposed 2-dam Elwha project might have been licensed for 50 years. The general form of the current dam-removal strategy appears to be consistent with the "win-win" proposal offered by Friends of the Earth: the Feds buy the Dams from James River and then pay for the difference between what the power they would have produced during the license period is worth and what the mitigation required to make them legal would have cost, with credit against future electrical power. Bonneville would be called upon to supply Daishowa with "purchaser credits" against the cost of replacement power. Purchaser credits would equal the value of the dams minus the cost of the necessary mitigation, and the Feds would then pay for dam removal. This looks like an attractive solution on the surface, but in an equation this simple, which completely ignores the cost of dam removal, the cash value of the required mitigation (set by FERC at a mere $39,000,000) becomes the critical variable. This probably goes a long way toward explaining why the mitigation that FERC proposed in the DEIS was so minimal. More expensive mitigation, designed to fulfill the needs all 5 species, and capable of guaranteeing self-sustaining fish runs, would substantially reduce the net value of the dams. In fact, it could easily reduce their value to a large negative number. If make your way to the south end of Lake Mills, and look closely at the stratified sediments in the exposed cliffs and hillsides, you will see that this has all happened before. 15,000 thousand years ago, the Cordilleran ice-sheet swept down out of Canada and as the Puget lobe spread south across Puget Sound Basin, the San Juan Lobe forked west, out the straits to the Pacific. A tongue called the Vashon Lobe dammed Morse Creek, and the Greywolf, Dungeness, Elwha and Lyre Rivers, forming a series of enormous lakes. The ice reached above the 3500 foot level on north flanks of the Olympics and blocked the rivers for thousands of years. The ice dam on the Elwha, near the current site of Lake Mills, created Glacial Lake Elwha, over [900] feet deep. Sediment hundreds of feet deep accumulated behind the ice-dam, and when the glacier finally retreated, the river re-cut its channel through the bottom of that lake. High up Boulder Creek you can find enormous stones, called erratics, left by the glacier, that were carried here from mountains far to the north, and dropped along the tributary streams by icebergs which had broken off and floated across the ancient lake. The DEIS released last spring disappointed almost everyone. It flatly stated that there was no way to restore all the runs, unless the dams are removed, and it predicted that the dams themselves could be removed for about $64,000,000, far less than James River's earlier studies had predicted. However, more than 16 million cubic yards of sediment has accumulated behind these dams and FERC's dam-removal proposal leaves most of it in the river. The last time the Elwha was dammed and freed, there were no salmon using the river. The best laboratory we have for studying massive disturbance and recovery, and its impact on salmonids, is the Toutle River, which drains the area devastated by the eruption of Mt. St. Helens. In spite of the obliteration of their habitat, the gravels have cleared and wild fish have already returned to the river. Because of the rush of "rural electrification" half-a-century ago, FERC will have nearly 300 dams up for relicensing in the near future and some of them will undoubtedly have to be removed. No one has ever tried this before: people have altered the landscape at enormous scale, but we know very little about how to restore it. The removal of the Elwha dams is seen by many as a perfect laboratory environment, because Lake Mills is located within Olympic National Park, and the NPS sees "ecosystem restoration and public education" as major components in its mission statement, and appears willing to exchange the opportunities restoration presents for the loss of recreation and scenic resources that will accompany the draining of Lake Mills. However, in spite of the optimism raised by the Toutle's recovery, removal of these dams presents very serious risks, and the possibility that the most vulnerable runs of wild fish will not survive the aftermath. 67% of FERC's [$224,000,000] estimate for dam removal is assumed to be the cost of providing replacement power for the Daishowa Mill. Many observers feel this assumption is based on a misunderstanding of [both FERC's and] James River's responsibility in this matter. If the public is to be liable for James River's loss of unlimited, uncompensated access to a public resource, it is argued, then surely James River is responsible to compensate the public for the loss of 80 years of fish and the vast amounts expended by State, Tribal and Federal Agencies to date in their efforts to maintain and rebuild the stocks and fisheries damaged by these dams, and perhaps even the $8,000,000 that has been spent over the past 20 years by the Army Corps of Engineers and other agencies in the armoring and nourishment of Ediz Hook to protect Port Angeles' harbor. This entire line of discussion is dismissed on page 2-29 of the FERC DEIS with the following statement (2.7.2): "The three elements included in the economic analysis were: (1) the dollar value of constructing (or removing) project facilities (including plant outage costs during construction); (2) incremental increases or decreases in the base operation and maintenance costs attributable to the alternatives; and (3) the value of power generation foregone as a result of implementation of the alternatives. Because of the absence of generally accepted methodologies, no attempt as made to assign dollar estimates to nondevelopmental values such as fish production, recreational use, terrestrial resources, or aesthetics. This takes us directly to a fundamental question: who is FERC really working for? For the past hundred years, hydroelectric power has been promoted as a free ride, as the one source of cheap, clean power on the planet. This myth is rapidly fading in the face of the conflict between our need to produce electricity and our responsibility to protect the northwest's remaning stocks of wild anadromous fish. Until a few months ago, things were moving along smoothly toward dam removal, based on scenario described above. Brock Adams was sponsoring a bill that would have transferred the dams to Federal ownership, and paid for the replacement power by juggling paper, by simply erasing it from Bonneville Power Administration's vast debt to the U.S. Treasury. In the wake of Adam's recent fall from power, it is not clear what will happen to this legislation. 3097