Curlew Drawing
Lower Columbia Basin Audubon Society

CONSERVATION NOTES by Rick Leaumont
Black Rock Dam & Reservoir

LCBAS Home Page



Black Rock on the rocks!!!!!!!!!!!!!!

Published Jan. 2009 in the Curlew
The US Bureau of Reclamation (BOR) has just released its mammoth Final Planning Report / Environmental Impact Statement Yakima River Basin Water Storage Feasibility Study which I will simply refer to in this article as the FEIS.

The preferred alternative recommended in the FEIS is the No Action Alternative, meaning the study does not recommend building the Black Rock Reservoir or the Wymer Dam and reservoir further upstream on Yakima River. This is an enormous victory for the environment of the Mid-Columbia, fish and wildlife of both the Hanford Reach and the Yakima Basin, as well as the health and safety of our community and avoids squandering billions of dollars of the taxpayer’s hard earned money.

The two volume report was released on December 19th and there has not been sufficient time to fully review the report, so some of my initial impressions may change after further review.

The Black Rock Alternative was not the preferred alternative for one reason – cost benefit ratio. The FEIS estimates the cost of the project at between $4.95 and $7.73 billion dollars and predicts $5.69 billion as the most probable cost. The cost benefit ratio in the FEIS fell to a new low of $.013 which means the value of each dollar spent on the project’s construction would return only 13 cents in benefits. The Bureau of Reclamation simply could not recommend proceeding with a project whose costs so far outweigh its benefits. Unfortunately the BOR continues to view the Black Rock project as having the potential ability to meet the needs of irrigators, and municipal water needs in the Lower Yakima Valley as well as enhancing fish passage but at a prohibitive price. The objections we raised in our comments to the draft Environmental Impact Statement remain unanswered save the prohibitive cost of the project.

BOR mistakenly holds to the fallacy that excess water is available in the Columbia River for diversion to Black Rock. The proposal calls for major withdrawals of water from the Columbia during September and October, when maximum flows are needed for fish migration. The FEIS contains a statement by the US Fish & Wildlife Service which notes if Black Rock were built it would destroy and further fragment the regions scarce shrub-steppe habitat, increase fire danger, disrupt migratory corridors used by large and small mammals and cause flow alterations in the Yakima River that might be harmful to fish. These concerns have led the USF&WS to recommend adoption of the No Action Alternative while encouraging the BOR to seek water conservation measures to increase water available to native aquatic species in the Yakima River.

We raised concerns about 30 to 52 thousand acre feet of water seeping annually from Black Rock into the aquifer and moving under the Hanford reservation pushing contaminated ground water into the Columbia River. The BOR responded to these concerns with a proposal to drill shallow wells to retrieve this water and construct an enormous dam on the Arid Lands Ecology Reserve portion of the Hanford Reach National Monument to further collect this water and funnel it into a pipeline to drain into the Yakima River. This proposal violates the purposes for which the Monument was established and could be construed to violate the Congressional prohibition on dams and diversions in the Hanford Reach. The groundwater mitigation proposal was added to the FEIS after the draft EIS’s comment period closed. The mitigation proposal
was not available for public review prior to its inclusion in the FEIS. The proposal is questionable and should be viewed as nothing more than a possible solution. The failure of BOR to present their proposed groundwater mitigation plan in the draft EIS is a fatal flaw and the report should not be considered an Environmental Impact Statement for the purposes of the National Environmental Policy Act.

The proposed Black Rock dam would be located on two faults. In responding to the draft EIS, we expressed major concerns that the dam would not be able to withstand an earthquake associated with these underlying faults. We also expressed concerns over the ability of Horsethief Hill to withstand an earthquake. The right shoulder of the proposed dam would rest on Horsethief Hill, which has a long geological history of landslides. We fear seismic activity would cause Horsethief Hill to crumble and allow a wall of water hundreds of feet high to come crashing down on the Hanford Reservation. Although the FEIS attempted to address these concerns we feel they remain unresolved and much research remains to be done.

We are apparently in good company as the FEIS includes a statement from the US Department of Energy who raised the same geological questions. The statement signed by DOE’s Assistant Secretary, Ines Trairy concludes “In summary, DOE believes that the development of the Black Rock Reservoir has the potential to cause severe environmental injury to the Hanford Site and the Columbia River that has not been fully evaluated. Therefore, DOE believes that the Black Rock Alternative should not be selected.”

These concerns are far more serious than mere cost benefit ratios and should end further consideration for the project.

We encourage you to write the BOR and express your support for the NO Action Alternative and your concerns over the environmental threats posed by Black Rock.

You can submit comments on the FEIS until February 3, 2009.

These comments should be submitted to:

Bureau of Reclamation
Attn: Mr. David Kaumheimer, Environmental Programs Manager
         Upper Columbia Area Office
1917 Marsh Road, Yakima, Washington 98901-2058.

Mr. Kaumheimer’s telephone number is 509-575-5848 ext 612
Return to Top of Page