Northwest Environmental Advocates--Programs

March 8, 2000

Louis Caldera
Secretary of the Army
101 Army Pentagon
Washington, D.C. 20310-0101

Re: Columbia and Willamette River Navigation Improvement Project:
Request for an Independent Economic Evaluation

Dear Secretary Caldera:

The Portland District of the Army Corps of Engineers has proposed a project to deepen the Columbia and Willamette River Navigation Channels (Navigation Project) from 40 feet to 43 feet over a total of 115.1 miles. During the development of the Final Environmental Impact Statement (Final EIS) last fall, hundreds of comment letters were received by the Corps. Issues related to the overall economic benefit of this project were raised in those comments but were largely ignored. Since the close of the public comment period, various agencies have raised additional issues that affect the cost of the Navigation Project, and therefore its cost/benefit ratio. Given recent reports concerning problems with the Corps' economic justification process, we believe it is appropriate for the costs associated with the Columbia/Willamette Navigation Project to be revisited. By this letter we are requesting an independent economic review of this Navigation Project. Such an analysis should include, at a minimum, the following essential factors:

1. The Corps Has Grossly Underestimated Dredging Volumes for Columbia River Channel Deepening.

The Corps has grossly underestimated the volume of dredged materials that will be generated by the proposed Columbia/Willamette Navigation Project. There are three primary reasons for this. First, the Corps bases the dredging estimates in its Final EIS on a period with atypically low river flows, thereby significantly underestimating dredging volumes. (Dredging volumes are directly correlated with sediment transport which are directly correlated with flows.) Second, the Corps fails to account for new sand entering the Lower Columbia River, arguing that its dredging activities will almost exclusively address existing sand that is moving around in the system. This premise is contrary to measurements made by the U.S. Geological Survey in the 1960s that demonstrate substantial levels of sand transport into the Lower Columbia River; it is also contrary to estimates made by a number of other scientists. These two faulty premises result in the likelihood that actual dredging volumes of the Navigation Project would be 80-200 percent greater than volumes projected by the Corps in its Final EIS. Third, channel deepening is likely to reduce the ability of the river system to transport materials out of the estuary and into the ocean.

The inconsistency between the Corps' estimates and reality is already obvious. Actual dredging in the last four years (1996-1999) has averaged more than 175 percent of the average dredging volumes predicted in the Final EIS for the Navigation Project. Likewise, the Final EIS estimates for the Navigation Project dredging volumes are approximately 10 percent lower than actual maintenance dredging volumes from an unusually dry fifteen-year period (1980-1995).

The Corps' dredging estimates for the Navigation Project appear to be seriously flawed. As a result, the Final EIS fails to consider the true economic costs of dredging, dredged spoil disposal, and disposal sites, as well as the environmental costs of dredged spoil disposal and its effects on fish and wildlife. This issue requires independent analysis.

2. The Corps Fails to Address the Effect of Postponing or Eliminating the Willamette River Portion of the Project.

The Portland Harbor area of the Lower Willamette River is significantly more contaminated with toxic chemicals than was previously believed during the scoping, data collection, and analysis phases of the Navigation Project's review pursuant to the National Environmental Policy Act (NEPA). In fact, the Portland Harbor is now known to be contaminated sufficiently to be designated a federal Superfund site, unless the U.S. Environmental Protection Agency (EPA) finds that a State-led equivalent can meet the legal requirements of CERCLA. Despite this information, the Corps concluded in its Final EIS that this dredging project will pose no harm to human health and the environment.

Although the Chief of Engineers' report notes that the Corps has opted to delay the Portland Harbor portion of the Navigation Project, it fails to tell Congress that the Corps also has requested reviewing agencies (e.g., Oregon Department of Environmental Quality Clean Water Act '401 certification, National Marine Fisheries Service Endangered Species Act '7 consultation) to withhold consideration of that portion. In fact, since investigations by state and federal agencies into the scope, nature, and extent of the toxic contamination are just beginning, it is premature to evaluate whether channel deepening will be appropriate for or compatible with this part of the river system. Uncertainty surrounding the status of the proposed action to deepen the Portland Harbor calls into question the accuracy of the cost-benefit analysis contained in the Final EIS. First, according to both the Corps and to EPA, if the Portland Harbor is designated under CERCLA, the Corps will not include it in the Navigation Project. However, the Corps has never adjusted the economic analysis of the Final EIS to address the possibility that that portion may be removed entirely from the project. Second, the Corps has not evaluated the significant additional expenses of dredging the Portland Harbor by preparing a contingency budget or a disposal plan to address the matter of contaminated sediments, should the EPA approve a state alternative to Superfund designation.

Clearly the Final EIS does not adequately address the economic implications raised by the pending remediation decisions for the Portland Harbor. As such, the economic justification of the Navigation Project is seriously flawed.

3. The Corps Has Not Evaluated the Costs of Extensive Ecosystem Restoration Now Required by the National Marine Fisheries Service (NMFS).

The Navigation Project, as envisioned in the National Marine Fisheries Service (NMFS) Biological Opinion, is far more costly than the project as described in the Final EIS. Pursuant to the Endangered Species Act (ESA) consultation, NMFS is requiring a package of studies, on-going monitoring, and habitat restoration not contemplated originally. The Final EIS does not estimate the costs of this package, because it was completed prior to development of the Biological Opinion and the Corps' amended Biological Assessment.

In addition, the Corps has not analyzed the risks of consultation being reinitiated by NMFS pursuant to the ESA during implementation of the Navigation Project. NMFS' Biological Opinion clearly indicates that the agency retains authority to reinitiate consultation and potentially withdraw its approval of the project. The prospect of taxpayers' footing the bill for a partially deepened river requires evaluation.

Further, because the Corps has delayed the Portland Harbor portion of the Navigation Project, the Biological Opinion evaluates only the impacts of deepening the Columbia River and fails to consider the impacts of dredging the Portland Harbor. Therefore, potential measures that may be required to ensure that deepening the Portland Harbor will not jeopardize the continued existence of ESA-listed species have not yet been identified and as such, no estimation of the costs of such measures has been developed by the Corps.

4. The Corps Has Not Assessed Losses to the Crabbing Industry and Commercial and Sport Fisheries.

According to the Columbia River Crab Fisherman's Association, plans to dump dredged sediments over 9,000 acres of productive benthic habitat on the ocean floor will cause an estimated loss of 87,230,000 pounds of crab to the local crab fleet over the life of the project. The excessive size of the ocean disposal site more than doubles the potential for loss of prime marine habitat and mortality to crab and bottom fish. Ocean disposal will have a highly significant cumulative impact to the unique and irreplaceable near shore marine environment. Likewise, loss of both shallow- and deep-water habitat in the estuary from dredging and dredged spoil disposal will cause losses to declining fish populations of species including salmon, sturgeon, and smelt. Despite these known losses, the Final EIS included no economic evaluation of impacts to crab, groundfish, or salmon from ocean disposal, flow lane disposal, or estuarine island disposal. Likewise, the Final EIS did not consider the effect on the economy of the Lower Columbia River that would be sustained by the commercial and recreation fishing and shellfishing industries. Since these human and natural resource impacts were not included in the economic justification, the benefits of the project have been overestimated. A quantitative analysis of these adverse impacts must be conducted to fully understand the economic costs associated with this project.

It is worth noting that the net economic benefits of this project are minuscule compared to the federal tax dollars spent each year on salmon recovery. According to the Corps' Final EIS, this project will contribute an additional $17 million each year to the region's economy. In contrast, the federal treasury is spending nearly $500 million each year on salmon recovery efforts in the Columbia River Basin. According to NMFS, this Navigation Project will unquestionably further degrade an already malfunctioning estuarine ecosystem system. In other words, this project will make current salmon recovery efforts more difficult and therefore will require yet even greater funds for salmon restoration.

It is clear from the foregoing that the economic analysis for the Columbia and Willamette Rivers' channel deepening project is not complete. Therefore, we urge you to include these omissions in an independent economic review of the current channel deepening project, including the recent amendments made to meet Endangered Species Act concerns. We further request that you withdraw the Chief Engineers Report that represents to Congress that such analysis has been completed until such time as these issues are fully evaluated.

We look forward to hearing from you soon. Please feel free to call either one of us at 503/295-0490 if you have any questions about the substance of this letter.

Sincerely,

Nina Bell, Executive Director
Northwest Environmental Advocates

Brett Swift
American Rivers, Northwest Office

Encl. Science Center Report

cc: Senator Slade Gorton
Senator Patty Murray
Representative Jay Inslee
Representative Jack Metcalf
Representative Brian Baird
Representative Richard 'Doc' Hastings
Representative George Nethercutt
Representative Norm Dicks
Representative Jim McDermott
Representative Jennifer Dunn
Representative Adam Smith
Senator Gordon Smith
Senator Ron Wyden
Representative Earl Blumenauer
Representative Peter DeFazio
Representative Darlene Hooley
Representative Greg Walden
Representative David Wu
Representative Joe Knollenberg
Representative Peter Visclosky
Representative Ron Packard
Representative Rodney Frelinghuysen
Representative Wayne T. Gilchrest
Jennifer Belcher, Washington Commissioner of Public Lands
Kelly D. White, Chair, Washington Fish & Wildlife Commission
Governor John Kitzhaber
Governor Gary Locke
Donald Sampson, Columbia River Inter-Tribal Fish Commission
Kathy Taylor, Columbia River Estuary Study Team
Christine Valentine, Oregon Division of State Lands
Colonel Randall J. Butler, Portland District, Army Corps

133 SW 2^nd Ave., Portland, OR 97204-3526 (503) 295-0490 FAX 295-6634