District Engineer Colonel Ralph H. Graves
U.S.
Army Corps of Engineers, Seattle District
P.O.
Box 3755
Seattle,
WA 98124
May
3, 2002
Re:
Implementation of VARQ flood control in Columbia River storage reservoirs
Dear
Colonel Graves:
Thank
you for the opportunity to comment on the implementation of the variable flow
flood control strategy (VARQ) at Libby and Hungry Horse Dams in Montana. The
Montana Chapter of the American Fisheries Society (MCAFS) has reviewed VARQ and
agrees that implementation is warranted because of the benefits for resident and
anadromous fish species. The VARQ flood control strategy is important for
coordinating anadromous fish recovery actions in the lower Columbia River with
the requirements of resident fish species, including those listed under the
Endangered Species Act (ESA), in upper Columbia River basin.
Modeling
results show that VARQ allows the reservoirs to remain more full prior to spring
runoff during average or low water years. This improves reservoir refill and
produces a more natural flow pattern downstream of the dams. Improved storage
reservoir refill resulting from VARQ flood control will increase the number of
years in which water will be available for summer flow augmentation for
anadromous fish, while simultaneously improving river flows and reservoir
conditions for listed resident fish species.
Both the National Marine Fisheries Service (NMFS) and the U.S. Fish and
Wildlife Service (FWS) called for the implementation of VARQ in their respective
2000 Biological Opinions (BiOps) on the operation of the Federal Columbia River
Power System. The Reasonable and Prudent Alternatives
specified in the BiOps constitute an emergency action to prevent the further
decline of endangered species. Since failure to implement VARQ impacts
reservoir refill and damages ESA listed fish in the Columbia River Watershed,
the Corps should use its authority to implement VARQ immediately while the
long-term EIS proceeds to assure compliance with the requirements of the
ESA.
Dam operations should first prioritize ESA listed species inhabiting habitats immediately upstream and downstream of the dams. Libby Dam is the only federal storage project that can be operated to help recover the endangered Kootenai white sturgeon (Acipenser transmontanus), which has been reduced to less than 2000 individuals, and assure their ultimate delisting. The threatened bull trout (Salvelinus confluentus) exists upstream and downstream of Hungry Horse and Libby Dams. These populations represent two of the most important strongholds for the species in the United States. Other species of special concern in Montana, such as the westslope cutthroat trout (Oncorhynchus clarki lewisi) and the redband trout (Oncorhynchus mykiss gairdneri), are also directly impacted by dam operations and should be considered in decisions by the federal operating agencies.
Restoring native fish and wildlife is largely dependent on reservoir and river operations, including VARQ flood control. Scientific evidence clearly shows that VARQ will benefit Columbia River fish species with little or no impact to human uses and should therefore be implemented as soon as possible.
Sincerely
Pat
Clancey, President
Montana
Chapter American Fisheries Society
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