WGFCI COMMENTS ALTERNATIVE OPTIONS

Mr. Kramer.

As you’re aware, Wild Game Fish Conservation International (WGFCI) is the only non-governmental organization to actively participate in the ongoing efforts of the Chehalis River Basin Flood Authority.

As such, we’ve expressed several concerns and clarifications during flood authority meetings, flood authority-sponsored public meetings, meeting with our elected representatives, and via local press. In 2010, WGFCI submitted two resolutions to the Flood Authority: 1. Immediate and permanent moratorium of steep slope clear cut logging and an immediate and permanent moratorium on floodplain development 2. Flood Authority-sponsored studies to be peer-reviewed by University of Washington/Washington State University After considerable participation with the Flood Authority and review of countless Flood Authority- sponsored studies and reports, it is our opinion that the proposed multi-purpose dam (water retention and hydropower) to be sited in the headwaters of the Chehalis River near Pe Ell would not provide basin-wide flood damage reduction, nor would it keep interstate 5 passable. This multi-purpose dam would be extremely expensive, would require decades to construct given the need for additional studies, lengthy permitting processes, expected litigation, would irresponsibly place residents and businesses in harm’s way and would devastate many Chehalis River basin fish and wildlife populations and their habitats.

Our concerns regarding the proposed multi-purpose dam in the headwaters of the Chehalis River are reinforced in the recently completed “Chehalis Basin Flood Mitigation Alternatives Report”: � “Major flood events can be isolated on a single tributary or set of tributaries, and not affect the whole Basin” - Throughout the Flood Authority meetings and processes it’s been documented that the proposed multi-purpose dam would capture approximately five percent of the basin’s storm water thus leaving ninety five percent in a 2007 type storm to impact downstream residents and businesses. � “A dam on the Chehalis main stem provides the most flood mitigation throughout the main stem Chehalis; it also

presents the most uncertainty and potential risk to natural resources particularly salmon and steelhead and has the highest cost of those projects that have been estimated.” – Residents and businesses in the Chehalis River basin deserve and expect flood damage protection via one or more effective projects that also protect the region’s highly-prized natural resources not a project that is the least likely to protect them while risking natural resources. � “A very different approach than reliance on major construction projects such as in the three project combinations described above would be to leverage local projects to remove key obstructions in the floodplain and use programmatic changes to address the flood damage. Such an approach could include widening of culverts, bridges, and dikes and levees that cause localized flooding, prohibiting any new development in the flood plain, raising or buying out structures already in the flood plain, improving other land use management practices, and improving forest practices to incentivize longer logging rotations, completing smaller construction projects in localized areas such as the Bucoda levee, and the Centralia-Chehalis airport levee, protecting livestock and farm investment with farm/critter pads, and ensuring effective detour routes around Interstate 5 to accommodate periodic closures during flooding.”

On page 3 is the statement that a dam would lower flood elevations by “ almost 2 feet at Montesano.” This statement is unclear as different modeling assumptions produce different estimates of the flood elevations throughout the basin. In reviewing Appendix F, we could find only one instance where the flood elevation would be reduced by this amount. This is in Table 8 in which a comparison is made between a 100-year flood and the 2007 flood. Given the challenges of understanding the 2007 flood, i.e. gages disappearing and the impact of down timber, we suggest that this estimate may well have a large error factor. We suggest that this statement needs to be highly qualified.

On page 3, reference is made to the Anchor QEA fish study. This study is problematic. There is barely a year’s worth of data. Based on conversations with fish biologists our conclusion that this amount of

data is not nearly sufficient. It does not take into account different water quality, water quantity, different return rates for salmon and other anadromous species over several years, nor does it include the wide range of salmon and other species that are in the Chehalis. The juvenile fish assessment project in Grays Harbor demonstrates the need for several years worth of data. This study, done by the Wild Fish Conservancy, is beginning its third year. When asked how many years worth of data were essential to reaching reasonable conclusions, the answer was a minimum of three years with the possibility that a fourth or even a fifth year was necessary.

During the workshop, three options were presented to the Flood Authority. It is not clear where these came from and we have heard Flood Authority members make the same comment.

On page 7 the reference to the cost of a dam states there is a $245 dollar estimate for the dam. This significantly underestimates the cost of a dam given the need for additional studies, lengthy permitting processes, likely litigation, and features such as fish ladders that are not included in the design to this point.

Again, on page 7, the statement is made that a dam would provide significant mitigation benefits in the South Ford Chehalis. There maybe some benefits to those living and farming on the south fork, but some specificity about those benefits would be beneficial.

On Page 8, there is a section entitled “Local Projects & Programmatic approaches: Another Way”. At the end of this section this statement is made “This kind of approach would be less expensive to implement; however the risk of flood damage to existing development in the floodplain would remain.” This statement, to a greater or lessor extent, can be made about any single project or any combination of projects that have been or could be proposed. It seems to us that this point should be made clear at the beginning of the report; there is no silver bullet.

On page 9, there is a bullet list that defines a Basin-wide solution to flooding. The first two bullets are the same. For comparison, on page 52, where they are part of the same paragraph.

On page 23, the 2007 flood is characterized. We suggest something that is

sometimes glossed over. Namely, this is the amount of debris and logged timber that came down from both the main stem and the south fork of the Chehalis. This should be discussed. From our perspective, this is one aspect of the 2007 flood that is difficult to estimate and model.

On page 52, at the end of the second to the bottom paragraph, you say the following “some participants, while understanding and supportive of the need to find effective solutions to the damage flood causes to human communities, were very skeptical of a dam and concerned about the potential for it to adversely affect fish and other natural resources.�

We are aware, that some refer to us as being more concerned about fish than people. This is exactly what this statement implies, thereby simplifying our (and others) motives and concerns. We do not pretend that we are not concerned about ecological damage, including to fish. However, we have stated any number of times that we are indeed concerned first about the residents of this Basin. There are a number of reasons to be skeptical about a dam. These range from the cost to the length of time it would take to build it and have it operational to the degree of effectiveness it would have in protecting people and reducing flood damage.

Thank you for the opportunity to comment on this report.

Sincerely, Bruce Treichler James Wilcox Wild Game Fish Conservation International