A federal agency is the latest entity to see potential problems with the proposed removal of Condit Dam.
On May 16, the U.S. Army Corps of Engineers filed three pages of comments to the Federal Energy Regulatory Commission. The comments were in response to the "draft supplemental final environmental impact statement" (DSFEIS), which FERC issued earlier this year.
Advocates of maintaining Condit Dam in place said the report supported their positions on a number of key issues related to possible removal of the dam, which is located on the White Salmon River, about three miles upstream from the Columbia.
"I read this Corps document as an indictment of the Settlement Agreement and all the parties thereto, as well as a vindication of the arguments and concerns we've been raising for months," said Jim Rhoads, a Husum resident and one of the leaders of those who want to see the dam maintained. "Where things will go now remains to be seen."
The Settlement Agreement, signed in 1999, describes a process for removal of the dam. The deal was entered into by PacifiCorp, owner of the dam, in concert with tribal representatives, government agencies, and environmental groups. However, the Settlement Agreement's validity is being challenged.
Terry Flores, director of hydro-licensing for PacifiCorp, said the Settlement Agreement recognized that there would be concerns such as these that needed to be addressed.
"The agreement recognized there may be a need to get certain permits, and public processes need to be worked through. This is one of those processes," she explained.
Included among the 11 specific comments offered by the Corps were the following:
Potential impacts of discharging sediment and debris into the Columbia River and Bonneville Pool. The estimate of the amount of the debris ranges from 1.68 million cubic yards to 2.4 million cubic yards.
"The Corps has multiple facilities and missions that could be impacted by this sediment, and while the impacts are uncertain, it should be clear that any such impacts are the responsibility of the applicant," read an excerpt from the document, which was signed by Michael B. White, director, Civil Works and Management, from the Corps' Portland office.
Sediment impacts to four Corps-related project facilities, including the Underwood and Cooks in-lieu fishing sites and other such sites, the Spring Creek Fish Hatchery, and Bonneville Lock and Dam.
"It is inappropriate to expect the Corps to remedy the adverse impacts on Corps and Corps-built facilities caused by the removal of Condit Dam," the document stated.
Portions of the sediments contain DDE (a breakdown of DDT), that would be discharged from behind the dam instead of removed.
Portions of the project will require additional remediation, including "reburying or armoring of a 14-inch water line and a 26-inch gas pipeline, and armoring of the Northwestern Lake bridge piers." Under provisions of the Clean Water Act, a Department of the Army permit would be required for these actions.
The Corps' report also points out an error in PacifiCorp's 1994 "sediment characterization study." The error is in the DDT/DDE data. The chemical was analyzed in "parts per billion," but the data was later transcribed in "parts per million," and the mistake was not caught.
"The error appears to have carried forward into the DSFEIS," read the Corps' report. "The presence of DDT/DDE in the parts per million range would mark this area as highly contaminated and in need of remediation. In the parts per billion range, these chemicals are above concern levels and should be evaluated with further sediment sampling and testing."
Rhoads pointed to the Corps' study as proof of some of the serious problems dam removal could bring.
"We have been asserting all along that the Settlement Agreement transferred the cost of sediment removal to the Corps and us taxpayers," said Rhoads. "It's nice to see that the Corps is not in cahoots with the other government agencies that signed the SA, thereby maintaining a legitimate claim to integrity and objectivity."
Rhoads blasted the U.S. Forest Service -- one of the signatories to the Settlement Agreement -- for downplaying possible adverse impacts of dam removal.
"It is no wonder that the Forest Service did not want to open its comments to scrutiny, for it is a shallow, transparent avoidance of significant environmental issues," Rhoads said.
Dan Harkenrider, area manager of the U.S. Forest Service/Columbia River Gorge National Scenic Area in Hood River, said his agency has not suggested there would be no impacts from dam removal.
"We've tried to describe, as best we can, that there will be some impacts. We're not trying to say there won't be short-term impacts," Harkenrider said. "But the benefit of restoring the ecology of the river outweighs the short-term impacts."
Harkenrider added that he agrees with the concerns about how any mitigations will be paid for.
"We should figure out the correct way to get it paid for," he explained. "That's ultimately got to be part of the solution."
PacifiCorp's Flores said the points raised by the Corps of Engineers were expected, and defended the Settlement Agreement.
"These are issues we would expect to see in a letter from the Corps," she explained. "We've had a follow-up conversation, and have set up a meeting to walk through what some of the Corps' concerns are."
Flores said she expected PacifiCorp and Corps of Engineers officials to have a meeting on the concerns within two or three weeks.
Rhoads called for the Columbia River Gorge Commission to get involved in the Condit Dam process by doing its own review. He pointed out that one of the Gorge Commission's responsibilities is to protect the environment and recreational facilities within the National Scenic Area.
"I suggest that if the dam is removed and a parade of environmental horrors ensues, the [Gorge] commissioners are going to be mightily embarrassed they did not meet their ultimate responsibility under the NSA, relying instead upon a corrupt agency," Rhoads said.