WAWG submits comments on Columbia River System Operations draft EIS

Washington Association of Wheat Growers (WAWG) President Ryan Poe submitted the following comments to the U.S. Army Corps of Engineers in response to the Columbia River System Operations draft EIS on behalf of the organization. WAWG encourages all wheat farmers to submit their comments online as soon as possible as today is the last day comments will be accepted.

On behalf of the Washington Association of Wheat Growers (WAWG), I appreciate the opportunity to submit comments on the U.S. Army Corps of Engineer’s Draft Environmental Impact Study (EIS) on the Columbia River System Operations. We applaud the efforts of the U.S. Army Corps of Engineers, the Bonneville Power Administration, the Bureau of Reclamation, and others who put forth research and encourage movement forward with science-based decisions.

WAWG represent thousands of farmers across Eastern Washington and farm landowners throughout the region. We strongly support the Congressionally mandated multi-use functions of the Columbia-Snake River System and the preferred alternative brought forth in the EIS that rejects dam breaching measures as part of Multiple Objective Alternative 3. Maintaining a balance between the economy and the environment is critical to Pacific Northwest life and culture.

Regional wheat producers rely on a complex system of rivers, rail, and highways to transport our product. Of the nearly 143 million bushels of wheat produced in Washington, about 60% of it is transported via the Columbia-Snake River System. Barging is proven to be the most efficient and least carbon-intensive mode of cargo transportation available to us. Our economies are not prepared to function without the availability of barging. Our highway, rail, and grain elevator networks would need more than $1.1 billion in capital investments to adapt. This includes the cost to rehab hundreds of miles of shortline rail track that has been abandoned; new rail that would need to be built; major highway improvements that would be necessary; and retrofits required for grain elevators that do not have rail-loading capabilities. But that is only the tip of the iceberg. There will be additional safety costs, wear and tear on our county roads, etc., all of which will have financial repercussions to my farm and other farm operations.

In addition, having competing transportation options helps keep the overall cost of transporting grain in check. Without barging, the EIS estimates a 33% transportation cost increase. But with many factors at play, such as additional truck purchases that might be required in order to move grain further; freight rate increases; fuel, rail and road improvement expenses; and more that will assuredly be passed on to the farmer, we contend the increased cost to be much higher and request that the final EIS be updated to include these specific costs, including transition costs, that would be associated with no navigation on the lower Snake River. The current market price for a bushel of wheat is at or near the cost of growing that bushel. Any additional expenses, like increased transportation costs, could push farmers into the red and make farming an unviable livelihood.

Even though I move most of my wheat on the rails, not on the river, the loss of barging as a transportation option will still impact my bottom line. Without the competition, rail rates are likely to rise, making it more expensive for me to ship my wheat. And as more wheat is pushed onto the rails, availability may become an issue, leaving me with no way to ship my wheat or having to deal with significant shipping delays, which will incur additional storage expenses.

Not only is the river system essential to transport commodities to market, but farmers and others rely on barges to transport fuel, fertilizer, and other inputs upriver. Nearly 7.3 million gallons of liquid nitrogen alone were barged upriver in 2019 to just two river terminals, which equates to 516 rail cars or an additional 1,548 truckload deliveries. In the case of transportation, the river truly does flow in two directions. We request that the final EIS include the costs of lost barge service on all of the freight moving on the river, not just wheat moving downriver. At the same time, it must be recognized and accounted for in the final EIS, that rail rates throughout the Northwest for all commodities will rise as capacity is constrained. It will not only be the wheat that would have to transition from the river.

Our membership base largely resides, and industry partners are based, in rural communities. Communities that depend on power generated by river dams. If the dams on the lower Snake River, for example, were replaced by a combination of other energy sources, rates could increase as much as 19% as referenced in the EIS. The role of dams to produce affordable, reliable, clean, and renewable energy cannot be easily dismissed or replaced.

We do have some concern with some of the analysis contained in the EIS regarding dam breaching and believe many of the costs associated with dam breaching and thus lack of navigation are understated. WAWG maintains our strong opposition to any attempt to breach the lower Snake River dams and considers such a possible disruption to the river system to be an extreme—and unnecessary—measure. Dam breaching would have devastating and long-lasting impacts on our industry and many Northwest communities that rely on the clean power, irrigation supply, and navigable waters made possible by our federal system of locks and dams. Breaching would not only negatively affect agriculture, but also manufacturing, transportation, trade, and tourism businesses.

Fish and dams with fish by-pass systems can, and do, coexist. By using water management measures, fish recovery can continue while meeting the region’s needs for water, power, navigation, and trade. Fish passage facilities have benefitted from large-scale investments in recent years. These facilities now allow more than 95% of fish to pass each of the federal dams safely. Investments to improve fish passage results should continue, rather than taking extreme actions like breaching the dams, which would create substantial environmental and infrastructure challenges.

According to the National Oceanic and Atmospheric Administration, ocean conditions continue to have the greatest impact on salmon survival—whether they pass through dams or not. Ocean conditions need to improve for fish numbers to substantially increase. We agree with the EIS when it calls for further action outside the scope of the Columbia-Snake River System to accelerate the recovery of anadromous fish like salmon. We need to consider the whole ecosystem and not limit our focus to the dams on the Columbia-Snake River System.

For decades, the benefits of the Columbia-Snake River System have contributed to thriving communities in the Pacific Northwest. The system’s hydroelectric dams and locks provide us with clean affordable energy for our homes and businesses; irrigation water for agriculture; and navigable waterways in order to transport inputs and move our commodities to the rest of the world. We encourage the U.S. Army Corps of Engineers to finalize its report and support the Preferred Alternative as outlined in the Draft EIS.