Columbia River Salmon and Other Native Fish Information

The American Public Power Association (APPA) appreciates the opportunity to comment on the Columbia River Salmon and Other Native Fish Request for Information. APPA is the voice of not-for-profit, community-owned utilities that power 2,000 towns and cities nationwide. APPA represents public power before the federal government to protect the interests of the more than 49 million people that public power utilities serve, and the 96,000 people they employ. Public power utilities range in size, from very large to very small; approximately 67 percent of public power utilities serve communities of 10,000 people or less. They own, operate, or use generation and transmission infrastructure, as well as distribution infrastructure directly serving homes and businesses. Public power has a strong presence in the Pacific Northwest and a long and proud history of providing low-cost, reliable electricity that has been a bedrock of the region's growth and prosperity, much of which can be attributed to hydropower. Many of APPA's members buy power produced by the LSRDs, which are part of the broader Columbia River Power System, or own and operate their own hydropower projects. Making full use of the nation's hydropower resource is key to ensuring that the nation's – and the Pacific Northwest's – grid remains reliable and resilient, and that utilities can meet emission reduction goals. Hydropower is an abundant source of emissions-free, baseload power. Furthermore, hydroelectric generators can be started or stopped quickly, which make them more responsive than most other energy sources for meeting demand for electricity at its "peak" or highest volume. Hydropower's "black start" capability makes it especially valuable in restoring power when there are widespread outages or disruptions on the system—this capability allows the generating units to cycle back on quickly if they have been tripped off in a power outage. APPA membership approved in March 2022 the attached resolution, "In Support of Hydropower, the Federal Columbia River Power System, and Opposing Breach of the Lower Snake River Dams." It is difficult to overstate how critical it is to maintain the LRSDs as the region – and the nation – seeks to lower emissions while maintaining electric reliability and affordability over the long-term. Moreover, recent extreme weather events have demonstrated that the LSRDs are an irreplaceable resource not just in the future but right now– both in terms of energy, capacity, and other grid services key to maintaining reliable electricity. Public power utilities are committed to scientific, cost-effective mitigation for the impacts of the federal hydropower system. Costs related to fish and wildlife mitigation, including the cost of lost power generation, comprise a quarter or more of the Bonneville Power Administration's power rates. The LSRDs feature state-of-the-art fish passage technology that greatly improves in-river fish survival, achieving spring juvenile survival at 96 percent and summer migrating fish survival at 93 percent. Removal of the LSRDs is not a clear path to recovery of endangered species or overall abundance of salmon. More attention is needed to the threats of ocean conditions, avian predation, and over-fishing. Removal of the LSRDs may prove to be a tipping point, nudging the Northwest system into acute scarcity of electric supply. The federal hydropower system, and particularly the LSRDs, are in a critical position to maintain grid reliability and prevent blackouts in the West. Moreover, no existing alternative technologies can provide the same combination of low cost, reliable, and flexible attributes, and it is far from clear that dam removal will result in meaningful fish recovery commensurate with costs. Finally, losing the LSRDs could increase consumer electricity rates by 25 percent or more and threaten the economic future of the region and its citizens. Thank you for the opportu…