Bumping Lake - Wymer
& the Yakima Basin
OVERVIEW
In December 2008, the federal Bureau of Reclamation issued a final report/EIS on the Yakima River Basin Water Storage Feasibility Study. This report/EIS found that massive new irrigation dams proposed for the Yakima River Basin, including Black Rock and Wymer, did not have a positive benefit-cost ratio under federal water project funding principles and standards. Other projects such as the Bumping Lake Enlargement, which would flood old-growth habitat adjacent to the William O. Douglas Wilderness Area, had too many problems to even include in the BuRec’s study.
Unfortunately, Governor Gregoire and the Department of Ecology then prepared a separate state supplemental EIS and are now pushing to authorize the Bumping Lake Expansion and Wymer dam projects.
1. YAKIMA RIVER BASIN
Background
Irrigation development in the Yakima River Basin came about from a combination of State and Federal actions:
According to the Bureau of Reclamation (BuRec):
“The development of storage was made possible by the Washington Legislature in March 4, 1905, by granting to the United States the right to exercise eminent domain in acquiring lands, water and property for reservoirs, and other irrigation works. Under this law, a withdrawal of the unappropriated waters of the Yakima River and its principal tributaries was filed by the United States on May 10, 1905. These actions led to the authorization of the Yakima Project on December 12, 1905.” Final Planning Report/Environmental Impact Statement, Volume 1, Yakima River Basin Water Storage Feasibility Study, Yakima Project Washington, Bureau of Reclamation, December 2008 (BuRec Final Report/EIS), page 1-14.
http://www.usbr.gov/pn/programs/storage_study/reports/eis/final/index.html
“Development of the Yakima Project progressed with the construction of Bumping Dam (1910), Kachess Dam (1912), Clear Creek Dam (1914), Keechelus Dam (1917), Tieton Dam (Rimrock Lake) (1925), and Cle Elum Dam (1933).” Yakima River Basin Water Enhancement Project, Washington, Draft Programmatic Environmental Impact Statement, Bureau of Reclamation (BuRec Draft PEIS), April 1998, page 7.
“The Yakima Project’s surface water supply comes from the unregulated runoff of the Yakima River and its tributaries, irrigation return flows, and releases of stored water from the five main reservoirs in the basin. Only 30 percent of the average annual natural runoff can be stored in the storage system. The Yakima Project depends heavily on the timing of unregulated spring and summer runoff from snowmelt and rainfall. The spring and early summer natural runoff flows supply most river basin demands through June in an average year. The majority of spring and summer runoff is from snowmelt; as a result, the snowpack is often considered a “sixth reservoir.” In most years, the five major reservoirs are operated to maximize storage in June, which typically coincides with the end of the major natural runoff. The reservoirs have a combined storage capacity of about 1.07 million acre-feet (maf).” BuRec Final Report/EIS, page xi.
1945 Consent Decree
The Yakima River Basin is an over allocated system, which means that there are more water right claims than can be supplied by the rivers and existing reservoirs in the basin, particularly during drought years. According to the BuRec:
“In 1945, the District Court of Eastern Washington issued a decree under Civil Action No. 21 called the 1945 Consent Decree. . .The water entitlements are divided into two classes-nonproratable and prorateable. Nonproratable entitlements are held by those water users with the earliest filed water rights, and these entitlements are to be served first from the total water supply available (TWSA).. . .Any shortages that may occur are shared equally by the proratable water users.” BuRec Draft PEIS, page 7.
According to the BuRec:
“In the spring of 1977, with a drought imminent, Reclamation predicted the proratable water users would receive only 15 percent of their normal water supply. Some proratable water users brought action in the U.S. District Court for the Eastern District of Washington to modify the 1945 Consent Decree and make all right holders proratable. The Yakama Nation sought to intervene and also filed a separate action in U.S. District Court to have its treaty-reserved water rights determined. In light of this dilemma, United States District Judge Marshall Neill suggested a State court general adjudication to finally determine water rights in the Yakima River basin.” BuRec Final Report/EIS, page 1-15.
The BuRec’s 1977 prediction was incorrect and not that dire, but ever since, eastern Washington irrigators have demanded more water storage dams, rather than review and revise their own crop patterns and water demands.
1977 Water Rights Adjudication
Because water allocation in a river basin depends on knowing who has valid water rights, it became important to determine the total legal water rights in the basin.
“On October 12, 1977, the State of Washington Department of Ecology filed an adjudication of the Yakima River system in the Superior Court of Yakima County naming the United States and all persons claiming the right to use the surface waters of the Yakima River system as defendants. The purpose of this adjudication was to determine all existing surface water rights within the basin, and to correlate each right in terms of priority with all other rights.” BuRec Final Report/EIS, pages 1-15, 1-16.
An Amended Partial Summary Judgment Entered as Final Judgment Pursuant to Civil Rule 54(b) was entered on November 29, 1990 (Re: Washington State Department of Ecology v. James J. Acquavella, et al., Case No. 77-2-01484-5) and affirmed by the Washington State Supreme Court in 1993 (Ecology v. Yakima Reservation Irrigation District, 121 Wn.2d 257 (1993). BuRec Draft PEIS, page 13.
2. BUMPING LAKE
Background
The current Bumping “Lake” is a small BuRec reservoir (33,700 acre-feet) formed by a dam at the site of a formerly existing natural glacial lake. It is located just above Goose Prairie on the Bumping River. It has been the source of dam enlargement studies including in 1966, 1979 and 2006. Two enlargement alternatives, a 458,000 acre-foot reservoir and a smaller 200,000 acre-foot reservoir have been proposed.
According to the BuRec:
“Bumping Lake Dam is an earthfill structure on the Bumping River about 29 miles northwest of Naches. The dam, completed in 1910, is 60 feet high and contains 253,000 cubic yards of material. In 1973, the road crossing the spillway was replaced and a new concrete T-beam bridge was installed to replace a wood-truss bridge. Situated at the lower end of a natural lake, the dam formed a reservoir with an active capacity of 33,700 acre-feet constructed over a natural lake having unknown dead storage capacity.” http://www.usbr.gov/projects/Facility.jsp?fac_Name=Bumping+Lake+Dam
1966-1979 Bumping Enlargement Proposal
“The Bumping Lake Enlargement Joint Feasibility Report was prepared in 1966 by Reclamation and the U.S. Fish and Wildlife Service. The purpose of this feasibility study, authorized by the Act of September 7, 1966 (Public Law 89–56) and the Fish and Wildlife Coordination Act (FWCA), was to address the water related problems and needs of the Yakima River basin. A preliminary feasibility report was completed in March 1968 on construction of a new dam about 1 mile downstream from the existing Bumping Lake Dam on the Bumping River, a tributary in the Naches River drainage. The report was forwarded to the Secretary of the Interior for consideration. During this process, recreation development in the recommended plan became a concern as to its compatibility with the Cougar Mountain (William O. Douglas) Wilderness Area then under consideration. It was determined that the recommended plan should be reevaluated and modified.”
“Following appropriations for the reevaluation work in 1974, the revised feasibility report was resubmitted to the Commissioner of Reclamation and the Director, U.S. Fish and Wildlife Service, in 1976. It was approved by the Secretary of the Interior in 1979. Reclamation filed the Proposed Bumping Lake Enlargement, Final Environmental Impact Statement with the Council of Environmental Quality August 23, 1979 (Reclamation, 1979). Bills were introduced in the Congress in 1979, 1981, and 1985 to authorize construction of the Bumping Lake enlargement, but the Congress did not take action.” BuRec Final Report/EIS, pages 1-17, 1-18.
Although pushed by then Senator Henry Jackson and Representative Mike McCormack, conservation and environmental groups generated strong opposition to any Congressional authorization of the Bumping Lake Enlargement Project because of lack of water conservation by Yakima River Basin irrigation districts, loss of old-growth habitat adjacent to the existing reservoir, evaporation rates, and lack of assurances that any stored water would be allocated to in-stream flows for anadromous fish.
3. 1979 YAKIMA RIVER BASIN ENHANCEMENT PROJECT
Instead of constructing more storage dams, Congress passed the Yakima River Basin Water Enhancement Project (YRBWEP) in December of 1979. A Phase I report was issued by the BuRec in August 1982 recommended early implementation of fish passage measures. Phase II focused on issues including waterbanking, potential storage site, and water conservation measures and a Phase II status report was issued in 1985. BuRec Draft PEIS, page 11. According to the BuRec, “Fish ladders and fish screens have been completed at diversions on the Yakima and Naches Rivers and at tributary diversions.” BuRec Final Report/EIS, page 1-19. It is less clear how many unscreened non-irrigation district diversions remain and Ecology states: “. . .there are still unscreened irrigation diversions. . .” Ecology Yakima River Basin Integrated Water Resource Management Alternative, June 2008 (Ecology FEIS), page 1-11.
http://www.ecy.wa.gov/programs/wr/cwp/cr_yak_storage.html#seis
1994 Title XII
To help carry out the recommendations in the Phase II report, Congress passed P.L. 103-424, Title XII in 1994. In 1998, the BuRec issued a draft Programmatic EIS According to the BuRec, the purpose of Title XII was on water conservation, although raising the gate elevation at Cle Elum Reservoir was also authorized. The BuRec claimed that the additional water from increased storage at Cle Elum would not be part of the Yakima River Basin TWSA. BuRec Draft PEIS, pages 19, 29.
Water conservation
According to the BuRec:
The Yakima River Basin Water Conservation Program (the centerpiece of Title XII legislation), is a voluntary program structured to provide economic incentives with cooperative Federal, State, and local funding to stimulate the identification and implementation of structural and nonstructural water conservation measures in the Yakima River basin. Improvements in the efficiency of water delivery and use will result in improved, reach-specific streamflows for aquatic resources and improve the reliability of water supplies for irrigation. The Basin Conservation Plan, prepared by the Yakima River Basin Conservation Advisory Group (1998) which was charted under the Federal Advisory Committee Act and appointed by the Secretary of the Interior, was submitted to the Secretary of the Interior in 1998 and published and distributed in October 1999. The Basin Conservation Plan sets forth the mechanism for implementing water conservation measures, including eligibility requirements for Federal- and State-sponsored grants, standards for the scope and content of water conservation plans, criteria for evaluating and prioritizing conservation measures for implementation, and administrative procedures. BuRec Final Report/EIS, pages 1-19, 1-20.
Despite the fact that a decade has passed since the “voluntary” Basin Conservation Plan was published, it is difficult to pin down what efforts, if any, Yakima River Basin irrigators have taken to actually conserve water.
For example, in September 2004, the BuRec issues a Finding of No Significant Impact and Environmental Assessment on a water conservation program for the Sunnyside Irrigation District. The program consisted of three re-regulation reservoirs and automated gates, but no installation of drip irrigation or canal lining. http://www.usbr.gov/pn/programs/ea/wash/sunnyside/ea.pdf
According to the BuRec:
“Ecology has developed an inventory of more than 500 conservation projects and is currently developing, screening, and ranking criteria to determine which projects best meet the goals of the CRBWMP. Potential projects may address issues such as incentive payments to reduce water use and full or partial water banking, improvements to municipal water infrastructure, use of reclaimed water, improved water delivery efficiency at the irrigation district level and on farm conservation, improved industrial infrastructure, and pump exchanges. Ecology would manage the use of conserved water.” BuRec Final Report/EIS, pages 1-25.
In December 2007, Ecology issued a Technical Report on the Enhanced Water Conservation Alternative for the Yakima River Basin Water Storage Feasibility Study, No. 07-11-044. While the report did not identify any past irrigation district water conservation measures that have been implement, the report estimated the total water savings in the Yakima River basin for all water conservation projects listed in the report to be 229,199 acre-feet per year, while warning that those water savings do not result in a corresponding increase in water supply. Ecology, Technical Report No. 07-11-044, December 2007, page 15.
http://www.usbr.gov/pn/programs/storage_study/reports/07-11-044/Enhanced_Conservation_Report.pdf
And as part of its 2009 “Integrated” FEIS (see below), Ecology has prepared a list of “potential” water conservation projects for water uses that divert from the Yakima and Naches River. There is no explanation of why these water conservation projects have not been carried out over the past thirty years. Ecology FEIS, page 3-51.
4. 2003 CONGRESSIONAL AUHORIZATION OF YAKIMA STORAGE STUDIES - NO COST FEASIBLE DAM PRJOJECTS
Although there was little evidence from irrigation districts of water conservation implementation, reductions in high volume water demand crops or surplus crops, or analysis of water spreading, Congress authorized the Bureau to study more irrigation dams in the Yakima River Basin as part of the Yakima River Basin Water Enhancement Project.
According to the BuRec:
The Yakima River Basin Water Storage Feasibility Study (Storage Study), as authorized by the Omnibus Appropriations Act of 2003, Public Law 108–7, examines the feasibility and acceptability of storage augmentation for the benefit of fish, irrigation, and future municipal water supply for the Yakima River basin. The State of Washington, represented by the Department of Ecology (Ecology), and the Bureau of Reclamation (Reclamation), as joint lead agencies, prepared the Draft Planning Report/Environmental Impact Statement for the Storage Study (Draft PR/EIS), released in January 2008. The Draft PR/EIS contained Joint and State Alternatives. Because Public Law 108–7 only authorized storage as a means to augment the water supplies, Reclamation focused its analyses on storage alternatives only and did not address fish habitat restoration, fish passage, or other nonstorage water supply or management issues. The State Alternatives were nonstorage concepts that could be addressed by Ecology through its legislative authorization. BuRec Final Report/EIS, page p. ix.
December 2008, BuRec Final Report/EIS
The BurRec (initially jointly with Ecology) studied the following three potential dam projects: A Black Rock Alternative; a Wymer Dam and Reservoir, and a Wymer Dam plus Yakima River Pump Exchange project. In December 2008, the BuRec issued its Final Report/EIS and concluded that none of these projects had a positive benefit-cost ratio:
•Black Rock Alternative – The benefit-cost ratio is 0.13. [Black Rock Dam involves a diversion and partial exchange of Columbia River water for Yakima Project water currently diverted by the Roza and Sunnyside Divisions (Roza and Sunnyside) of the Yakima Project for irrigation. Roza and Sunnyside have been identified as potential willing water. Columbia River water pumped from Priest Rapids Lake would be stored in a Black Rock reservoir to be constructed in the Black Rock Valley.]
•Wymer Dam and Reservoir Alternative – The benefit-cost ratio is 0.31. (See Below)
•Wymer Dam Plus Yakima River Pump Exchange Alternative – The benefit-cost ratio is 0.07.” BuRec Final Report/EIS, pages 2-43, 2-127.
In addition, the BuRec early on decided to drop the Bumping Lake Expansion from its study and summarized the problems with the Bumping Lake Expansion:
The William O. Douglas Wilderness Area, approximately 170,000 acres, is adjacent to the existing Bumping Lake. None of the reservoir enlargement options that have been considered were within the Wilderness Area boundary. However, a common concern voiced was that the enlarged reservoir would be visible from various vantage points and detract from the scenic vistas and aesthetic value of the Wilderness Area through reservoir drawdown and exposure of the reservoir bottom area.
About 2,800 acres of terrestrial habitat, including approximately 1,900 acres of old-growth timber, would be inundated if Bumping Lake were enlarged to a capacity of 400,000–458,000 acre-feet. Old-growth timber serves as habitat for the spotted owl, an ESA-listed endangered species.
Enlarging Bumping Lake would inundate approximately 10 miles of perennial and intermittent stream habitat downstream from the existing dam and upstream of the existing reservoir, affecting the aquatic ecosystem and fishery resources. This is compounded by the recent designation of Deep Creek and Bumping River as critical habitat for bull trout.
The larger-capacity reservoir would not fill on a regular basis and would not be a reliable source of water. Previous studies identified approximately 14 summer homes within the impact area of the enlarged reservoir. It was proposed that these summer homes would need to be relocated downstream from the new dam. A number of the owners opposed downstream relocation. The enlarged reservoir also would inundate existing recreational facilities and approximately 9 miles of U.S. Forest Service road, plus approximately 17 miles of road that would be closed, terminating all vehicle traffic above the damsite and road access to campgrounds above the existing reservoir. In addition to the roads, about 4 miles of trails would be inundated. These actions would hamper accessibility to areas above the reservoir. Increased traffic associated with construction activities at the new dam, including logging of the enlarged reservoir area, would have an adverse impact on the community of Goose Prairie. Further, increased recreation use at an enlarged reservoir also could adversely affect the community. While the concept of a natural (unregulated) hydrograph was not a primary issue in the past, it has become a significant concern in recent years. Representatives of the Washington Department of Fish and Wildlife and others expressed considerable reluctance at the spring 2007 Storage Study Roundtable discussions to include an enlarged Bumping Lake as a storage alternative to be carried into the planning report and environmental impact statement phase of the Storage Study.” BuRec Final Report/EIS, p. 2-129
5. 2006 WASHINGTON STATE -
THE COLUMBIA RIVER BASIN WATER MANAGEMENT ACT
In response to eastern Washington irrigators’ demands for more storage and new irrigation dams, Governor Gregoire and the Washington State Department of Ecology supported passage of state legislation in 2006 to study additional dam sites in eastern Washington.
According to the BuRec, the Washington State Legislation authorized studying a number of massive new irrigation dams:
“Potential storage projects that may be approved for study and funding include new large storage facilities (more than 1 million acre-feet), new small storage facilities (less than 1 million acre-feet), modification of existing storage facilities, and groundwater storage. Examples of potential storage projects include: Black Rock reservoir (new large facility), Wymer reservoir (new small facility), reoperation of Banks Lake (modification of existing facilities), and the City of Kennewick Groundwater Storage.” BuRec Final Report/EIS, page 1-25.
Wymer
As part of its Final Report and EIS, the BuRec studied a 450-foot high dam on Lmuma Creek with a storage capacity of 162,500 acre-feet filled by pumping from the Yakima River (See above). Later as part of Ecology “integrated” EIS, an alternative proposal was put forward of filling Wymer via gravity flow through either an expanded Kittitas Reclamation District or a separate set of canals or pipes, or a pipeline option between Cle Elum Dam and Wymer Dam. (See below) Ecology FEIS, pages 2-31 to 2-33.
According to the BuRec:
“Both habitat generalists and shrub-steppe obligates occupy the Black Rock and Wymer Dam and reservoir sites. . . The Wymer site provides core habitat for bighorn sheep (Ovis canadensis), Townsend ground squirrel, golden eagle (Aquila chrysaetos), ferruginous hawk, short-eared owl, long-billed curlew, loggerhead shrike, sage sparrow (Amphispiza belli), Brewer’s sparrow (Spizella breweri), sage thrasher, greater sage-grouse, black-tailed jackrabbit, Merriam’s shrew, mule deer, pallid bat, and small-footed myotis. Peripheral habitat exists for the white-tailed jackrabbit. Other species that may live in the diverse habitats within the affected areas include the coyote (Canus latrans), badger (Taxidea taxus), western kingbird (Tyrannus verticalis), western meadowlark (Sturnella neglecta), mourning dove (Zenaida macroura), western rattlesnake (Crotalus virdis), Great Basin spadefoot toad (Spea intermontana), and northern sagebrush lizard (Sceloporus graciosus) (Service, 2007b).” BuRec Final Report/EIS, page 4-80.
“The Wymer Dam and Reservoir Alternative would have direct and indirect impacts on shrub-steppe vegetation and wildlife within the Lmuma Creek drainage. Many of the impacts would be similar to those described for the Black Rock Alternative and include: inundation of shrub-steppe habitat, impacts to movement corridors, possible exotic plant species invasion, possible
increase in fire susceptibility, and indirect impacts associated with the construction of facilities.
Habitat acreage within the footprint includes the following: 1,055 acres shrub steppe habitat; 167 acres grassland; 62 acres barren land; 50 acres riparian area; 30 acres of cliff/canyon; 11 acres of agricultural cropland; 7 acres developed land; 6 acres forest habitat; 4 acres wetlands (Service, 2007b).” BuRec Final Report/EIS, page 4-95.
6. 2009 ECOLOGY YAKIMA RIVER BASIN INTEGRATED WATER RESOURCE MANAGEMENT ALTERNATIVE – FEIS
Because the BuRec had dropped the Bumping Lake Expansion and determined that the Wymer pumped storage project failed to generate a positive benefit/cost ration, irrigators demanded that Ecology prepare its own “Supplemental” draft and final EIS. This “integrated” alternative included the following elements: Fish passage at existing reservoirs; structural changes at reservoirs; new storage, including Bumping Lake Expansion and an alternative Wymer project; groundwater storage; fish habitat improvements; enhanced water conservation; and market-based reallocation of water resources. Ecology FEIS, page 2-8.
Ecology’s FEIS did not apply the BuRec’s principles and standards nor did Ecology generate a benefit/cost ratio for either the Bumping Lake Expansion or the alternative Wymer project. However, Ecology’s FEIS did not further consider Black Rock and appears to agree that this project is too expensive and threatens the Hanford Nuclear Reservation with ground water seepage. Ecology also identified 30 additional basin storage sites that BuRec has previously reviewed and not carried forward for additional study. Ecology FEIS, pages 2-68 and 2-69.
7. PHASE III - YAKIMA RIVER BASIN WATER ENHANCEMENT PROJECT 2009 WORK GROUP
Even though the BuRec failed to even include the Bumping Lake Enlargement in its 2008 final report and EIS, and found that the Wymer pumped storage reservoir had a negative benefit-cost ratio, Ecology and the Governor continue to promote new storage reservoirs at these sites.
In 2009, the BuRec and Ecology formed a “Yakima River Basin Water Enhancement Project Workgroup” made up of resources agencies, the Yakama Nation, irrigation districts, city and county jurisdictions, and one environmental organization to develop an “integrated plan” and achieve “consensus,” which is being pegged as Phase III of the YRBWEP.
The Workgroup included the following:
Name Affiliation
Brad Avy/Tom Davis, Washington Department of Agriculture
Dale Bambrick NOAA, National Marine Fisheries Service
Max Benitz, Benton County
Alex Conley, Yakima Basin Fish & Wildlife Recovery Board
Rick Dieker, Yakima – Tieton Irrigation District
Dave Fast, Yakama Nation – Yakima/Klickitat Fisheries Project
Michael Garrity, American Rivers
Urban Eberhart, Kittitas Reclamation District
Mike Leita Yakima County
Bill Lover, City of Yakima
Mark McClain/Paul Jewell, Kittitas County
Sid Morrison, Yakima Basin Storage Alliance
Scott Revell, Kennewick Irrigation District
Phil Rigdon, Yakama Nation – Natural Resources
Derek Sandison, Washington Department of Ecology
Jeff Tayer, Washington Department of Fish and Wildlife
Jeff Thomas, US Fish and Wildlife Service
Jim Trull, Sunnyside Valley Irrigation District
Ron VanGundy, Roza Irrigation District
Dawn Wiedmeier, Bureau of Reclamation
Workgroup meetings were held in Yakima throughout 2009 and 2010. In November 2009, the Workgroup prepared a discussion draft integrated package that included building a new Bumping Lake dam below the existing dam, as well as the Wymer Dam, and study of pumping water out of the Columbia River.
See: http://www.usbr.gov/pn/programs/yrbwep/reports/iwrmp/index.html
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8. 2010 INTEGRATED PLAN
In December 2010, a majority of the Workgroup agreed to support a Proposed Integrated Water Resource Management plan with a $5+ billion price tag that included seven elements:
1.Fish passage
2.Structural and operational changes
3.Surface water storage (including a new Bumping Lake Dam, Wymer Dam, and study of pumping water from the Columbia River)
4.Groundwater storage
5.Fish habitat enhancement
6.Enhanced water conservation
7.Market reallocation
In March 2011, the Workgroup agreed to add a “Watershed Protections and Enhancements” element involving land preservation elsewhere in the Yakima River Basin. Workgroup members appear to consider this land preservation element as mitigation for the loss of endangered species habitat due to the construction of additional dams in the Yakima Basin. The Workgroup also created an Implementation Subcommittee with the following members: Phil Rigdon (Yakama Nation), Mike Leita (Yakima County), Michael Garrity (American Rivers), Ron VanGundy (Roza Irrigation District), and Derek Sandison (Washington State Department of Ecology). The Department of Ecology became the sponsoring agency for the project, while the BuRec has moved into the feasibility report/EIS stage.
During 2009-2001, the Sierra Club submitted statements of concern about the Workgroup process and the integrated plan on July 15, 2009; November 9, 2009; July 28, 2010; and March 9, 2011.
9. SCOPING, FEASIBILITY REPORT, DEIS, FEIS
The BuRec has set out a timeline of issuing a notice of intent to prepare an draft environmental impact statement and call for scoping comments by the end of March or early April; the issuance of a draft environmental impact in September 2011, and a final environmental impact statement by January 2012. In addition to the billion of dollars of costs and loss of endangered species habitat at the Bumping and Wymer dam sites, concerns include the failure to take seriously water conservation and market allocation as a non-structural alternative, the BuRec’s refusal to evaluate the benefit/costs of each proposed new dam; and the transformation of the Department of Ecology into a new state dam building agency.
[David E. Ortman, 7043 22nd Ave N.W., Seattle, WA 98117]
