As I wrote about last November, Ochoco Irrigation District is in the preliminary stages of applying for a FERC license to add a hydroelectric plant to Bowman Dam.  Here is OID’s “Pre-Application Document“.  The first of multiple comment periods ends on Monday.  There is a significant amount of design work left to be done, studies that need to be undertaken, and many unanswered questions about how this project will impact the Crooked River below Prineville Reservoir.  A fair amount of negotiation will need to take place between OID and various agencies before final approval is granted.  Nevertheless, the latest Central Oregon Flyfisher newsletter states that the board voted to send a letter of support for the project which will include language that throws away the most important bargaining chip for the conservation community.

Adding a hydroelectric facility to Bowman Dam triggers an Oregon law that requires fish passage.  That requirement can be met, be waived by the ODFW Commission if it is deemed unnecessary, or be replaced with other mitigating activities that would be of equal or greater value.  In principle, the hydro project already has broad support, even up to the Governor’s office.  It is also assumed that a fish ladder will be very expensive.  So, other mitigating actions are certainly a potential outcome.

Nevertheless, studies need to be undertaken to understand the benefits of fish passage, if nothing else to ascertain what actions of equal or greater benefit can be taken below the dam.  Passage would have enormous positive impact.  It would reconnect wild, native resident species, including redband trout, below and above the dam.  It would also provide access to significant spawning habitat for anadromous fish currently being reintroduced into the Crooked River Basin.  Historically, the majority of Deschutes steelhead spawned above Prineville Reservoir.

To minimize the importance of fish passage or suggest that it not be considered before appropriate studies be undertaken is simply mind boggling.  Nevertheless, here is what the COF newsletter stated:

The COF BOD will write a letter in support of the hydroelectric plant to be built at Bowman Dam, We will also state that the fish ladder is not needed and that we would like redd reparations below the dam.  (sic)

I’m not sure what the details of “redd reparations” are, but to state that a ladder is not needed at this early stage of the process in an attempt to take it out of the discussions is unjustifiable.  How expensive would a ladder be?  How valuable would it be?  What sort of mitigating actions should OID take?  Habitat improvements are clearly on the list but what about dam modifications that would reduce or eliminate gas bubble disease during high flows?  Could flows be increased during key lifecycle stages?  (Extreme low and high flows are currently the biggest issues for healthy trout in the Crooked.)  There are so many unknowns at this point it is completely premature to take positions, that’s why it’s a “pre-application document”.