For what it’s worth, here’s the email I sent to ODFW yesterday:
I oppose providing a fish passage waiver for the proposed hydroelectric plant at the base of Bowman Dam. While the cost of installing a ladder may be prohibitive, the proposed mitigation measures do not come close to providing a greater benefit to fish than opening up 500 miles of habitat and reconnecting fish in the upper Crooked River with fish in the lower Crooked River as well as other upper Deschutes Basin waterways. Further, a 50-year FERC license would preclude passage for the same amount of time.
The applicants state they will realize $300,000 in profits a year or $15,000,000 over the 50-year license period. In contrast, they will spend $390,500 initially on mitigation measures at Ochoco Preserve and the small dam on Ochoco Creek, and between $265,000 and $471,000 on spawning gravel placement over the next 50 years. This is not close to being proportionate. Further, they do not propose a realistic solution to the gas bubble disease problem that periodically decimates fish populations in the Crooked River below Bowman Dam. The Bureau of Reclamation analysis states that there is much uncertainty on the subject but makes it clear that along with the installation of the Howell Bunger valves, a rock weir would have to be installed one mile below the dam to raise and slow the river to allow for gas dissipation. A rock weir is unlikely to be allowed in the Wild & Scenic section of the river, could block fish passage, and is not included in the application.
In short, the applicants have offered very little that will benefit fish in the Crooked River, certainly nothing remotely close to greater benefit than access to the upper Crooked River watershed. It is within the applicant’s power to increase flows in the lower Crooked River, the single greatest problem the river faces today. They could use a significant amount of the $15,000,000 in projected lifetime profits to purchase and restore more wetlands. They could address the serious water quality issues in the Crooked River caused by agricultural runoff from Ochoco Irrigation District patrons. They could follow the example of Deschutes Valley Water District who found partners to fund the recently completed ladder at the Opal Springs hydro facility.
In short, they are asking for much and offering very little.