| Drought Management Plan
Kerr Dam operator PPL MT revealed in the 7 October 2004 press release below that the Bureau of Indian Affairs has resumed work on its environmental impact statement on the proposed drought management plan for Kerr Dam. We will provide additional details as they become available. 7 October 2004 PPL MT press release: Pursuant to PPL Montana's proposed Drought Management Plan (DMP), representatives from PPL Montana, U.S. Army Corps of Engineers, Bureau of Reclamation, Bureau of Indian Affairs (BIA) and the Bonneville Power Administration conferred on October 5, 2004 regarding current and projected operation of the Kerr Project. The current outflow is about 7,200 cubic feet per second (cfs) and the lake elevation, as of October 6, was 2892.17 feet, which is 0.83 feet from full elevation of 2893.0 feet. The current and forecasted operation is based on the most current information regarding precipitation and natural stream flows and historic trends. The natural stream flows for September averaged 200 percent of normal. The Pacific Northwest Coordination Agreement's latest regulation has Flathead Lake drafting to elevation 2891.0 feet by the end of October. The outflows during the month should stay well above the 3,200 cfs minimum allowed. PPL Montana's DMP has been pending approval by the Secretary of the U.S. Department of the Interior since its submission in March 2002 following the drought experienced in 2001. BIA has resumed work on the environmental impact statement for PPL Montana's proposal and the other alternatives being considered. Until issuance of a final DMP from BIA, Kerr Project operations will continue to be evaluated and adjusted, as appropriate, in consultation with the parties involved and with consideration of the PPL Montana's draft DMP criteria. For more information contact Lance Elias, PPL Montana, at 406-533-3510.
OFFICE OF THE GOVERNOR
State Capitol
PO Box 200801
Helena, Montana 59620 State of Montana Judy Martz
Governor January 28, 2003 Robert J. Beduhn, P.E. Vice President
Water Resource Environmental Manager
HDR Engineering Inc.
Minneapolis, MN 55416 Dear Mr. Beduhn: I thank the Bureau of Indian Affairs (BIA) and HDR Engineering for holding public meetings in Polson and Kalispell on the status of the draft EIS for the Flathead Lake drought Management Plan. Based on what my Administration heard about the meetings, I have the following comments. It is my understanding that the new methodology that was proposed for forecasting drought appears to have promise. I request the opportunity for Montana Fish, Wildlife and Parks (MFWP) and the Montana Department of Natural Resources (DNRC) to review the methodology, and the associated criteria used to initiate the drought management procedure specified in the plan after it is fully developed. I also request that you keep working with MFWP and the DNRC on these matters. Specifically, MFWP has offered the use of a model that could be updated to simulate VARQ flood control at Hungry Horse Dam. The model has the ability to simulate local conditions with Columbia River operations and could also be updated to simulate Kerr Dam discharge and lake elevations. Based upon recommendations of my departments, Kerr and Hungry Horse dams should coordinate operations, within the guidelines of the Columbia River System so that Flathead Lake fills to elevation 2893 by June 15 while still meeting Endangered Species Act requirements for threatened bull trout in the Flathead Watershed and listed anadromous fish species in the lower Columbia River. The BIA should work with the Bureau of Reclamation (USBR), MFWP and other agencies to assure that flows are scheduled to maximize local benefits as water from Hungry Horse is released and passed through Flathead Lake. Specifically, I recommend the BIA work with the Northwest Power Planning Council and pertinent federal agencies. The Northwest Power Planning Council is currently undergoing its Mainstem Rulemaking process. The current draft available for public comment contains operations that would stabilize operations at Hungry Horse and would have a positive effect on Flathead Lake levels. This includes VARQ and stable, flat flows during the summer months. The draft, if adopted, would help guide the federal agencies in the operations of Hungry Horse and other federal dams in the Columbia Basin. Departments of the State of Montana previously recommended a strategy to adjust water releases based on water availability, where more water is released during higher water years. During dry years, flows would remain higher than historic conditions as a result of the VARQ flood control strategy. The preferred alternative should consider VARQ-like operations for both Kerr and Hungry Horse to enhance the opportunity to fill Flathead Lake during drought. Flathead Lake should not be allowed to drop ten feet, but could drop to a more acceptable level based on inflow forecasting in the headwaters of the Flathead. Flathead Lake should be maintained at full pool throughout the summer. Model simulations have shown that implementing VARQ at Hungry Horse Dam improves Flathead Lake refill during dry ears by increasing inflows to the lake during spring. When Flathead Lake fills by June 15, water released from Hungry Horse Reservoir for downstream salmon passes through the lake without impacting lake elevation. I support the completion of the on-going instream flow evaluation downstream of Kerr Dam that is being conducted by the Confederated Salish and Kootenai Tribes (CSKT), PP&L, MFWP, and the U.S. Fish and Wildlife Service. The results from this evaluation should become an integral part of the preferred alternative for the drought plan. i trust these entities will agree upon realistic flow rates necessary to maintain the indigenous species such as the westslope cutthroat trout and bull trout, upstream and downstream of Kerr Dam. The preferred alternative must have sufficient flexibility to address unanticipated issues and concerns. I recommend the creation of a Flathead Lake Drought Committee to be convened whenever the drought trigger is reached. The Committee should consist of one representative from each of the following: the Corps of Engineers, USBR, CSKT, PP&L, MFWP, Flathead Lakers and upper basin agricultural water users. This Committee would ensure that the drought plan is followed, but would also be responsive to unanticipated changes in moisture and other conditions that warrant slight modifications to the drought plan. The Committee would also be responsible for disseminated water supply information and educating basin residents on the status of drought, reservoir operations, and drought mitigation activities. A thorough analysis of the biological and economic impacts for the range of alternatives must be included in the draft EIS. Please address the costs and benefits of maintaining the FERC recommended instream flows downstream of Kerr Dam during drought and the impacts of a lowered Flathead Lake. Furthermore, please address the costs and benefits of maintaining Flathead Lake as close as possible to elevation 2893. Montana Department of Commerce would gladly work with you in assessing economic impacts. I have been advised the drought plan should identify mitigation measures to offset the effects of the drought. For example, if the fisher is impacted, mitigation measures need to be identified to help the fishery. As well, if Flathead Lake does not fill, mitigation measures will need to be identified to address the impacts to the tourism industry, fishing activity, in-lake biological resources and fishery, and the economies of local communities and residents around the lake including impacts to the CSKT. Deteriorating water quality in Flathead Lake has been documented over the past 25 years and there is an enormous ongoing effort to improve the quality of the lake. If the lake is lowered significantly during drought in the summer, water temperatures will probably rise. Please address the effects of increased lake temperatures on productivity and lake biology. I would like to see the USBR, BIA, the CSKT, PP&L, and the State of Montana reach agreement on a new drought management plan for Flathead Lake that addresses the conflicting requirements found in the existing FERC license. Further, I hope the parties will submit an amended condition for a drought management plan to FERC, and that FERC will accept the new condition and include it in the existing FERC license for the Dam. Sincerely, JUDY MARTZ
Governor c: Gale Norton, Secretary of the Interior
By Judy Martz
Governor, State of Montana Flathead Lake and the surrounding area is truly Montana at its best. The lake, mountains, rivers, and streams are not only beautiful; they provide wonderful recreational opportunities for Montanans and tourists alike. The economy in the Flathead, and across Montana, depends on these resources. That is why water levels at Flathead Lake have been a source of concern and controversy. Last summer's drought and resulting water shortage in the Flathead basin affected thousands of Montanans. PPL Montana, which operates Kerr Dam in conjunction with the Confederated Salish and Kootenai Tribes, tried to make the best of a bad situation. But as a licensee of the dam, PPL must deal with a number of requirements that are often in conflict. For example, they are required to release a mandated amount of water downstream. At the same time, they are required to ensure that Flathead Lake reaches its full pool level in June. Last year, there was simply not enough water to meet all the demands and requirements placed on the dam's operator. Recently, PPL Montana proposed a plan to prevent such a disaster from happening again. The Department of Interior's Bureau of Indian Affairs has ordered a full environmental impact statement (EIS) to study PPL's drought management plan. I encourage the Bureau of Indian Affairs to conduct a fair, open, and inclusive process on this contentious issue. The Bureau should work closely with the Confederated Salish and Kootenai Tribes, the Montana Department of Fish, Wildlife and Parks, the Montana Department of Commerce, the National Organization to Save Flathead Lake, the Flathead Lakers, and all other property owners and citizens of the Flathead valley. If a final solution is to be credible and accepted by all parties, the process by which it is created must be credible as well. In the end, the drought management plan should be able to meet all license conditions in all years. Lower Flathead River flow targets must be attained every year, as should a full-pool summer level for Flathead lake of 2893=, while recognizing that a few inch variation is unavoidable. Anything less poses a danger to fish, wildlife, and navigation; reduces recreation, and threatens the tourism-based economy of the Flathead region. To accomplish all these goals over the long-term, we must learn to manage and coordinate Hungry Horse Reservoir, Flathead Lake, and Kerr Dam together in order to balance the water resources and needs of this unique drainage. Federal resource agencies and the Northwest Power Planning Council (NWPPC) are also working on this issue. For example, NWPPC, which oversees hydropower facilities in the Columbia River basin, is currently revising its rules to improve how dam operations address the needs of both fish and hydropower. NWPPC is also developing a Flathead Sub-basin Plan. This 10-15 year management plan is designed to provide increased opportunities for local input in how water resources in the basin are allocated between fish and hydro-power. All of these efforts -- the Flathead EIS, the new hydropower rules, and the sub-basin plan -- will benefit greatly from public participation. Our administration encourages everyone who lives, works, or plays in the beautiful Flathead basin to take part in determining its future.
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July 9, 2002 Ms. Michelle Bissonnette
HDR Engineering
6190 Golden Hills Dr
Minneapolis, MN 55416 Re: Scoping Comments for Kerr Dam Hydroelectric Project Drought Management Plan Environmental Impact Statement Dear Ms. Bissonnette: The Flathead Lakers were pleased to learn that an Environmental Impact Statement (EIS) is being prepared to provide a thorough review of the options for managing Kerr Dam operations during droughts, and of potential environmental and economic impacts of those options. We believe an EIS can help ensure that an effective and fair Drought Management Plan (DMP) for Flathead Lake and the Kerr Hydroelectric Project will be adopted. The Flathead Lakers is a nonprofit, grassroots organization working for clean water, healthy ecosystems and lasting quality of life in the Flathead Watershed. Our organization currently has over 1,000 members. Information about the organization can be found on our web site at www.flatheadlakers.org. The Flathead Lakers recommend that the following be considered in the EIS process: ** Consider as one option the DMP1 rule curve described in the 2001 Army Corps of Engineers' (Corps) Flathead Lake Drought Management Study: Final Report. According to the Corps, DMP1 achieves lake refill and river minimum flow requirements in nearly all drought years and meets flood prevention requirements. ** Determine the impacts of the Bureau of Reclamation adopting VAR-Q rule curves for Hungry Horse Dam and explore opportunities to use the DMP to improve coordination between Hungry Horse Dam and Kerr Dam operations. We understand VAR-Q would improve the probability of sufficient water reaching Flathead Lake to meet lake level and minimum river flow requirements during droughts. Together, DMP1 and VAR-Q would allow a "greater than 99 percent chance of filling into the top half foot [of Flathead Lake]."(p. 15, Corps' Flathead Lake Drought Management Study: Final Report.) This supports the Flathead Lakers' previously stated position supporting "stable, predictable, and useable (2892.5 minimum) lake levels during the recreation season (June 15 through September 30)." (10/4/01 Flathead Lakers Position Statement). ** Analyze environmental and economic impacts of DMP options that includes answering the following questions:
- At what summer lake level are shoreline property owners, area businesses and boaters significantly affected? What are the economic impacts?
| - What are the environmental impacts of a lower summer lake level?
| - What are the environmental impacts of reducing flows in the Flathead River below the minimum license requirements?
| - What are the environmental and economic impacts of providing water from Hungry Horse Reservoir to supplement Flathead Lake levels and/or lower Flathead River flows during a drought?
| - At what winter lake level, and during what specific time period, are docks and other property and the lake shoreline put at significant risk of storm damage? What are the potential economic impacts of not maintaining the lake at a level that will prevent significant damage?
| - What sources of information and models best predict streamflows and lake levels?
| - What are the opportunities for a phased approach to alternate reducing lake level targets with allocating supplemental water from Hungry Horse Reservoir?
|
** Revise and refine the DMP1 option to reflect a thorough analysis of probabilities of various drought scenarios, flow volume forecasts, and the new information about economic and environmental impacts generated through the EIS.
The Flathead Lakers believe that, at a minimum, a DMP must: 1) Spell out the conditions that would require implementation of DMP provisions ("trigger criteria"); 2) Establish specific rule curves for a full spectrum of potential drought scenarios; 3) Maximize chances for achieving both lake refill and minimum river flow license requirements; 4) Provide clear definitions, explanations and justifying evidence for all provisions and requirements; 5) Identify the best sources of information and models to predict streamflows and lake levels, and require their use (with provisions for updating as better tools become available); 6) Base tradeoffs among competing water uses on sound environmental and economic information and analysis, with opportunities for public review and comment on thatinformation and analysis.
The Flathead Lakers were pleased that PPL Montana's proposed DMP recognizes a full range of water uses and their potential for conflict during a drought. The Flathead Lakers believe, however, that the March 4 PPL Montana proposed DMP would institutionalize a process that proved ineffective during 2001. We believe an ad hoc process of monthly reviews of runoff forecasts during a drought by numerous independent entities and jurisdictions under the pressure of immediate competing demands for water will not lead to the best decisions regarding drought management. Nor will it provide the public adequate advance notice of decisions that will affect them. We recognize the need for flexibility in the plan to allow response to changing conditions. But we believe the plan should clearly delineate a dam operating plan (rule curves) for various drought conditions. Sincerely, Sid Rundell President Robin Steinkraus Executive Director cc: PPL Montana, LLC David R. Poe, Counsel for PPL Montana, LLC Robert H. Grieve, FERC Jeffery Loman, BIA Confederated Salish & Kootenai Tribes Senator Conrad Burns Senator Max Baucus Representative Dennis Rehberg Governor Judy Martz
The Bureau of Indian Affairs has concluded that an Environmental Impact Statement is required for the Drought Management Plan for Kerr Dam and Flathead Lake. HDR Engineering, Inc., on behalf the BIA, has scheduled two scoping meetings for the EIS in early July: | Kalispell | | Tuesday 9 July | | 6:30 - 9:30 p.m. | | West Coast Outlaw Hotel | | | | Charlo Wednesday, 10 July |
| | 6:30 - 9:30 p.m | | Ninepipes Lodge |
According to HDR Engineering: These meetings are designed to provide an opportunity for public input on the scope of issues to be considered during the preparation of a Drought Management Plan while complying with the National Environmental Policy Act and Article 60 of the Kerr Hydrolelectric Project license. Representatives from the Bureau of Indian Affairs, other federal agencies and HDR Engineering, Inc. will make presentations at 6:30 p.m. These presentations will be followed by question and answer sessions and an opportunity to voice your concerns. Written statements or comments about this project must be faxed, e-mailed or hand-delivered by Tuesday, July 30, 2002 to: Ms. Michelle Bissonnette HDR Engineering 6190 Golden Hills Dr Minneapolis, MN 55416 Fax: (763) 591-5413 E-Mail: mbissonn@hdrinc.com
March 19, 2002 Gale Norton, Secretary
U.S. Department of the Interior
1849 C Street NW
Washington, DC 20240
Magalie R. Salas,
Secretary Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426
Re: PPL Montana's proposed Drought Management Plan for Kerr Hydroelectric Project No. 5 Dear Secretary Norton and Secretary Salas: The Flathead Lakers urge the Department of Interior and the Federal Energy Regulatory Commission to require a thorough review of the options for managing Kerr Dam operations and their potential environmental and economic impacts before approving a Drought Management Plan (DMP) for Flathead Lake and Kerr Hydroelectric Project 5. The Flathead Lakers previously encouraged adoption of an interim DMP to govern dam operations in 2002 should the drought continue (see Flathead Lakers' October 4, 2001 Drought Management Plan and Flathead Lake Levels Position Statement). And we believe a DMP is long overdue. However, PPL Montana reports, in a press release dated March 13, 2002, that "The current forecast for the Kerr Project predicts adequate volume into the system to meet the license conditions for flow releases and lake elevation during summer." Since a DMP will not be triggered this year, there is time to conduct a careful evalution of options and impacts. The Lakers assert that this evaluation and a DMP should be completed by the end of 2002. The Flathead Lakers recommend that the following be considered in the evaluation and revision of PPL Montana's March 4, 2002 proposed DMP: - Base the DMP on the DMP1 rule curve described in the 2001 Army Corps of Engineers' (Corps) "Flathead Lake Drought Management Study: Final Report." DMP1 achieves lake refill and river minimum flow requirements in nearly all drought years and meets flood prevention requirements.
| - Encourage the Bureau of Reclamation to adopt VAR-Q rule curves for Hungry Horse Dam, which would improve the probability of sufficient water reaching Flathead Lake to meet lake level and minimum river flow requirements during droughts. Together, DMP1 and VAR-Q would allow a "greater than 99 percent chance of filling into the top half foot [of Flathead Lake]."(p. 15, Corps' "Flathead Lake Drought Management Study: Final Report.") This supports the Flathead Lakers' previously stated position supporting "stable, predictable, and useable (2892.5 minimum) lake levels during the recreation season (June 15 through September 30)." (10/4/01 Flathead Lakers Position Statement).
| - Undertake an environmental and economic assessment or Environmental Impact Statement to analyze environmental and economic impacts of DMP options that includes answering the following questions: - At what summer lake level are shoreline property owners, area businesses and boaters significantly affected? What are the economic impacts? - What are the environmental impacts of a lower summer lake level? - What are the environmental impacts of reducing flows in the Flathead River below the minimum license requirements? - What are the environmental and economic impacts of providing water from Hungry Horse Reservoir to supplement Flathead Lake levels and/or lower Flathead River flows during a drought? - At what winter lake level, and during what specific time period, are docks and other property and the lake shoreline put at significant risk of storm damage? What are the potential economic impacts of not maintaining the lake at a level that will prevent significant damage? - What sources of information and models best predict streamflows and lake levels? - What are the opportunities for a phased approach to alternate reducing lake level targets with allocating supplemental water from Hungry Horse Reservoir?
| - Revise and refine DMP1 to reflect a thorough analysis of probabilities of various drought scenarios, flow volume forecasts, and the new information about economic and environmental impacts.
|
The Flathead Lakers believe that, at a minimum, a DMP must: 1 - Spell out the conditions that would require implementation of DMP provisions ("trigger criteria"); | 2 - Establish specific rule curves for a full spectrum of potential drought scenarios; | 3 - Maximize chances for achieving both lake refill and minimum river flow license requirements; | 4 - provide clear definitions, explanations and justifying evidence for phrases and claims (i.e., "minimum required" p. 13, "certain consequences" p. 13, "based on a review of historical data, drought conditions requiring a revised target elevation have occurred in only one out of every eighteen years." p. 14, "drought conditions" p. 15; all in PPL Montana's March 4 proposed DMP); | 5 - identify the best sources of information and models to predict streamflows and lake levels, and require their use (with provisions for updating as better tools become available); | 6 - base tradeoffs among competing water uses on sound environmental and economic information and analysis, with opportunities for public review and comment on that information and analysis. |
The Flathead Lakers are pleased that PPL Montana's DMP recognizes a full range of water uses and their potential for conflict during a drought. The Flathead Lakers believe, however, that adopting the March 4 PPL Montana proposed DMP would institutionalize a process that proved ineffective during 2001. We believe an ad hoc process of monthly reviews of runoff forecasts during a drought by numerous independent entities and jurisdictions under the pressure of immediate competing demands for water will not lead to the best decisions regarding drought management, nor will it provide the public adequate advance notice of decisions that will affect them. We recognize the need for flexibility in the plan to allow response to changing conditions. But we believe the plan should clearly delineate a dam operating plan (rule curves) for various drought conditions. Sincerely, Sid Rundell President
The plan was filed by PPL Montana on March 4, 2002. You can download a copy. Reversing its earlier decision to grant the Confederated Salish and Kootenai Tribes (CSKT), co-licensee of the Kerr Dam Hydroelectric Project, an extension to December, 2002 to submit a Drought Management Plan (DMP), the Federal Energy Regulatory Commission (FERC) ordered two changes on February 1. First, it charged PPL Montana (PPLM) with sole responsibility to submit the DMP. Second, it advanced the due date to March 4, 2002 On March 4, PPLM filed its DMP proposal with Secretary of the Interior Gale Norton and FERC Secretary Magalie R. Salas. PPLM proposed provisions to allow commentary on the plan from interested parties and a target date of May 15, 2002 for finalizing the plan.
Essentially, PPLM proposes an annual process for monitoring water conditions in the Flathead River and Lake system in order to spot threats of drought at the earliest opportunity. The plan proposes various procedures involving adjustments in the customary operation of the Kerr Project and certain terms of its license to mitigate the consequences of drought on all affected interests. The core of PPLM's proposals for drought conditions involves four sequential steps: 1. PPLM proposes raising the target drawdown to a lake level elevation "at or about 2888 feet" by December 31 of each year. Commentary in the Plan represents that, historically, only in one year out of ten would additional DMP measures have to be taken if the reduced drawdown target level is implemented. 2. Next, when deemed necessary per estimates suggesting drought conditions (not defined in the plan), PPLM proposes establishing an annual plan (operating rule curves) which minimally satisifies all license requirements of the Kerr Dam project. This plan would become an interim baseline. At any sequential point when the updated monthly forecast falls below the baseline, a drought would be declared and all provisions of the DMP would be activiated. Operating curve adjustments might lead to "certain consequences with respect to the way the project is operated in certain months." 3. If the accomplishments per Steps 1 and 2 are projected to be inadequate "to resolve a drought situation in a given year," PPLM proposes reducing the target lake level as of June 15 from 2893 to 2892 feet. Commentary in the plan states that, historically, such reduction of the target lake level would have occurred only once in eighteen years. 4. If these three steps are inadequate, PPLM proposes "Interior's approval to take additional measures at Kerr Dam, and seek additional inflows, to resolve the situation without causing additional reduction in lake levels." These measures would involve: [a] either revising license requirements for "minimum flow releases, ramp rates, and between-day flow changes" at Kerr Dam; [b] or arranging for "additional water to be released" from the Hungry Horse Project [governed by the federal Bureau of Reclamation]; [c] or establishing some combination of such adjustments sufficient to maintain lake levels at approximately the 2892 foot level.
PPLM has arranged for a public forum on the DMP proposal to be held at 5:30 p.m. on March 20 at The Outlaw Inn, Highway 93 South, Kalispell. PPLM proposes that a formal public comment period ending April 18, 2002 be approved by the Secretary of the Interior. It is not yet known whether such comments would be filed with PPLM or Interior. Also, PPLM has indicated that "the revised annual operating curves prepared as part of the DMP will be made publicly available in a timely matter." You can download PDFs of the plan and the letters to the Secretary of the Interior and the Secretary of FERC (Note on downloading. Mac, click and hold; Windows, right click. Netscape, use "Save Link As," Internet Explorer, "Save Target As." ). Top of page.
19 March 2002 For Immediate Release
Contact: Robin Steinkraus, 406-883-1346 The Flathead Lakers announced today that they are pleased that progress toward adoption of a Drought Management Plan for Flathead Lake is finally occurring and that PPL Montana's March 4 proposal for a Drought Management Plan recognizes a full range of water uses and their potential for conflict during a drought. The Flathead Lakers believe, however, that the PPL Montana proposal needs further input and refinement in order to prevent the confusion and misunderstandings that resulted during last year's drought. A Drought Management Plan for Flathead Lake must provide the public with a clear understanding of when drought conditions could trigger management changes that will harm Flathead Lake water users, according to the Lakers. And, it must base the tradeoffs among water users on a careful evalution of the environmental and economic impacts of those tradeoffs. PPL Montana's proposal fails to do either of these. PPL Montana's plan does not provide clear "trigger criteria" for when its recommended drought responses would kick in. Lakers President Sid Rundell said the Lakers believe "the proposed ad hoc process of monthly reviews of runoff forecasts during a drought by numerous independent entities and jurisdictions under the pressure of immediate competing demands for water will not lead to the best decisions regarding Kerr Dam operations. Nor will that proposed process provide the public with adequate advance notice of decisions that will affect them." The Lakers agree the plan should allow flexibility for responding to changing conditions, but the plan should clearly delineate a dam operating plan (rule curves) for a range of drought conditions. Decisions about when the dam's license requirements for lake levels and river flows can be relaxed must be based on sound information about the environmental and economic impacts of those changes. Questions such as at what summer lake level shoreline property owners, area businesses and boaters are significantly affected and what are the associated economic impacts are not answered in this proposal. The Flathead Lakers believe that, at a minimum, a Drought Management Plan must: (1) spell out the conditions that would require implementation of its provisions ("trigger criteria"), (2) establish specific rule curves for a range of potential drought scenarios, (3) maximize chances for achieving both lake refill and minimum river flow license requirements, (4) provide clear definitions, explanations and justifying evidence for its provisions, (5) identify the best sources of information and models to predict streamflows and lake levels, and require their use, (6) base tradeoffs among competing water uses on sound environmental and economic information and analysis, with opportunities for public review and comment. The Flathead Lakers continue to support "stable, predictable, and useable (2892.5 minimum) lake levels during the recreation season (June 15 through September 30)" as stated in an October, 2001 position statement. No evidence is provided in PPL Montana's plan to justify a proposed drought level of 2892.0. And no explanation is given about what conditions (forecasted runoff volumes) would trigger this reduction in lake levels.
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Date: November 26, 2001
For Immediate Release The Flathead Lakers have requested a rehearing of the Federal Energy Regulatory Commission's October 18 order granting an extension of time until December 31, 2002 to complete a drought management plan for Flathead Lake. Given the conflicts during spring and summer, 2001 and the apparent inability of PPL Montana and the Confederated Salish and Kootenai Tribes (CSKT) to voluntarily reach agreement on a joint interim drought management plan this fall, the Flathead Lakers fear the Flathead Basin could face another drought in 2002 without a plan to guide Kerr Dam operation. That would not be in the public interest. The Lakers are asking that the Federal Energy Regulatory Commission (FERC) amend its order to require the dam's licensee, PPL MT, to develop, in cooperation with the CSKT, an interim drought management plan for the period January 1 through December 31, 2002. The Flathead Lakers support FERC's extension of time until December 31, 2002 to complete a drought management plan for Flathead Lake to allow time for an environmental review of proposed new flood rule curves. In the meantime, it is imperative that an interim drought management plan for 2002 be adopted to prevent confusion, uncertainty and conflict if the drought continues. The Flathead Lakers is a nonprofit conservation organization with over 1,000 members, working for clean water, healthy ecosystems, and lasting quality of life in the Flathead Watershed. During 2001, the low snowpack of the multi-year drought resulted in Flathead Basin streamflows that were not sufficient to satisfy all demands for generating electric power, maintaining and restoring healthy fisheries, irrigation, and water-based recreation and tourism. The scarcity of water initiated a contest over its allocation. That contest, complicated by conflicting and inaccurate predictions for streamflows and lake levels, would not have been necessary had the required drought management plan for Kerr Dam been in place. These events underscore the need for a drought management plan that provides (a) the highest probability of attaining both the required Flathead Lake levels and Flathead River minimum flows, and, (b) mechanisms for allocating water fairly, wisely, and quickly should a shortfall develop. A drought management plan to guide Kerr Dam's operations during a drought is required by the operating license for the dam granted by FERC. Originally, the plan was to be completed by June 25, 1998 by the dam's licensees, Montana Power Company (now PPL MT) and the CSKT, in consultation with the Bureau of Reclamation, the Bureau of Indian Affairs (BIA), and the Montana Department of Environmental Quality. That deadline was not met. The Commission then granted an extension to December 31, 2000. That deadline, too, was not met. Consequently, during a drought of historical severity, ad hoc processes controlled the allocation of scarce water. Last August, CSKT asked FERC to approve a request for another extension, to December 31, 2002, to allow time to prepare an Environmental Impact Statement on proposed new flood rule curves for Kerr Dam's operation. The new rule curves were prepared by the U.S. Army Corps of Engineers, at CSKT's request, to examine opportunities for maintaining higher winter lake levels during varying drought conditions. At an August 21 meeting in Polson, CSKT, PPL MT, and BIA informed the Flathead Lakers that an interim drought management agreement would be developed by mid-October to direct Kerr Dam management in case of continuing drought. Response to recent Flathead Lakers' inquiries to PPL MT , CSKT, and the BIA regarding the status of the interim drought management plan disclosed that these parties have not reached agreement on an interim plan. "If drought conditions continue or worsen this winter and next spring," said Flathead Lakers President Sid Rundell, "we believe there will be insufficient water to meet the license requirements for both minimum flows in the Flathead River below Kerr Dam and lake levels. If an interim drought management plan has not been agreed on, conflicts regarding how to operate the dam will arise again." Those conflicts could result in harm to lakeshore property owners, businesses and aquatic resources. The Flathead Lakers realize that during a severe drought some sacrifices may be necessary. The consequences of natural events should not, however, be compounded by preventable uncertainty and confusion about how dam operations will affect lake levels.
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Flathead Lakers board members, staff, and webmaster attended a meeting on August 21 regarding plans for improving Kerr Dam operation in future drought years. The meeting was hosted in Polson by the Confederated Salish & Kootenai Tribes and the Department of Interior. At the Tribes' request, the Army Corps of Engineers developed a new set of "rule curves" for the dam. These rule curves show, for various snowpack scenarios, how far the lake should be lowered in the winter for flood control. In a drought year like this one, the lake could be held higher in the winter, allowing both full pool lake level and river flow requirements to be met. If implemented, these rule curves would result in the lake reaching full pool in June 99% of the time, according to Brian Lipscomb, Director of Fish, Wildlife, Conservation and Recreation for the Tribes. More analysis will be done this year to better correlate snowpack and weather conditions with when spring runoff occurs, and to explore how to better maintain the full pool lake elevation through the summer in drought years (matching upstream flows to flows released at Kerr Dam). The Pacific Northwest Coordinating Agreement, an agreement among power producers including PPL Montana, will also be factored in to make sure PPL Montana can meet its contract obligations under the various scenarios. Following is a copy of the August 9 letter to the Flathead Lakers from the Department of Interior in response to the Lakers request for authorization to participate in developing a drought management plan. Interior's reply says that the public, including the Flathead Lakers, will have opportunities to comment during the EIS process, which will be required to adopt the new rule curves. It appears that eventual adoption of the new rule curves will allow dam operations that will - in the long term - resolve the lake level/river flows problem in all but the most extreme drought. But they won't be adopted in time to solve the problem if we have another drought next year. Lipscomb said the Tribes, PPL Montana and the agencies involved will meet to craft an interim agreement on managing for droughts that may occur before the new rule curves are adopted. They hope to have that agreement finalized by mid-October. They don't expect the negotiation process for the interim agreement to be open to public participation. The Flathead Lakers encourage the Tribes, PPL Montana and the agencies to put their best effort into cooperatively developing an interim plan that incorporates the new rule curves and addresses local concerns. In response to the Flathead Lakers question about what will happen to lake levels after August 31, Lipscomb and PPL Montana representative Lance Elias agreed their best prediction for the lake level is 2891.25 feet on Labor Day where it will hold steady for the remainder of September. In mid-September, flows at Kerr Dam will be reduced to around 3,350 cubic feet per second which should closely match incoming flows at that time. Others represented at the meeting included the Federal Energy Regulatory Commission, Bureau of Indian Affairs NW Regional Office, County Commissioners for Lake and Flathead Counties, staff from the offices of Senators Baucus and Burns, and citizens. -- Robin Steinkraus, Executive Director
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- Stable, predictable, and useable (2892.5 minimum) lake levels during the recreation season (June 15 through September 30).
- Completion of an interim drought management plan by mid-October, 2001. That plan should address economic and environmental impacts, local concerns, and be based on flood rule curves that provide the highest probability of attaining both lake refill objectives and minimum flows in the lower Flathead River.
- Development, with full public disclosure, review and input, of a final drought management plan.
- Signed the Memorandum of Understanding (written in 1962, amended in 1965 and approved by the Federal Energy Regulatory Commission (FERC) in 1966) which outlines seasonal guidelines for Kerr Dam operation to manage lake levels.
- Intervened in the Kerr Dam relicensing process in 1990 to ensure that an environmental impact statement would be prepared to: (1) provide FERC with the information needed to make informed decisions on dam mitigation, (2) require FERC to identify and assess a full range of alternatives for minimizing the adverse effects of the dams operations, and (3) allow the public to participate fully in a decision of vital concern.
- Gathered information about lake levels and associated problems from a variety of sources throughout 2001, sharing it with members, the public, agencies, and decision makers.
- Encouraged agencies, Pennsylvania Power & Light (PPL MT) and the Confederated Salish & Kootenai Tribes(CSKT) to (1) cooperate in determining how best to manage for lake levels and river flows during this years drought, and (2) keep the public informed about what was being done and why.
- Asked FERC and the Department of Interior (DOI) to allow the Flathead Lakers to participate in the development of the drought management plan (letter dated July 12, 2001).
- Expressed our concerns to Senator Baucus and Senator Burns and urged them to stay involved in this issue as an interim plan is developed (ongoing communications including letters dated August 24, 2001).
During 2001, the low snowpack of the multi-year drought resulted in Flathead Basin streamflows that were not sufficient to satisfy all demands for generating electric power, maintaining and restoring healthy fisheries, irrigation, and water-based recreation and tourism. The scarcity of water initiated a contest over its allocation. That contest, complicated by conflicting and inaccurate predictions for streamflows and lake levels, would not have been necessary had the required drought management plan for Kerr Dam been in place. A drought management plan to guide Kerr Dams operations during a drought is required by the operating license for the dam granted by FERC. Originally, the plan was to be completed by June 25, 1998 by the dams licensees, Montana Power Company (now PPL MT) and CSKT, in consultation with the Bureau of Reclamation, the Bureau of Indian Affairs (BIA), and the Montana Department of Environmental Quality. That deadline was not met. FERC then granted an extension to December 31, 2000. That deadline, too, was not met. Consequently, during a drought of historical severity, ad hoc processes controlled the allocation of scarce water. On August 15, 2001, DOI asked FERC to approve CSKTs request for another extention, to December 31, 2002, to allow time to prepare an Environmental Impact Statement on proposed new flood rule curves for Kerr Dams operation. The new rule curves were prepared by the U.S. Army Corps of Engineers (USACE), at CSKTs request, to examine opportunities for maintaining higher winter lake levels during varying drought conditions. The USACE released the Flathead Lake Drought Management Study on August 10, 2001. At an August 21, 2001 meeting in Polson, CSKT, PPL MT, and BIA informed the Flathead Lakers that an interim drought management agreement will be developed by mid-October, 2001, to direct Kerr Dam management in case of continuing drought.
August 9, 2001 (received 8/15) Dear Mr. Rundell: On behalf of the Secretary of the Interior, we are responding to your letter of July 12, 2001, in which the Flathead Lakers request authorization to participate in the development of the Drought Management Plan (Plan) required by Article 60 of the Kerr Project license. In addition, the Flathead Lakers encourage the Secretary of the Interior (Secretary) to require completion of the Plan. The Department of the Interior (Department) shares your concerns regarding the effect of low lake levels on the economy of the Flathead region. Due to the extreme drought conditions prevailing this year in western Montana, the Department granted PPL Montana authorizations to deviate from the minimum instream flow requirements of Article 56 of the Kerr Project license. Throughout this summer season, the Department has given careful consideration to competing interests and has continued to seek solutions that would accommodate recreational and other demands relating to lake levels while protecting Tribal trust resources of the Confederated Salish & Kootenai Tribes of the Flathead Nation (Tribes) in the lower Flathead River. Most recently, the Department reached an agreement with PPL Montana regarding an althernative plan of operations that will further help stabilize lake levels for the remainder of the season. These actions reduced outflows from the Kerr Project and retained more than 195,000 acre feet of water in Flathead Lake, raising the level of Flathead Lake approximately 19 inches. The Department also shares your desire for expeditious completion of the Plan. The Department, PPL Montana, and the Tribes have expended significant time and resources this summer in determining the appropriate response to this year's drought. It is my understanding that the Army Corps of Engineers (Corps) and the Tribes are completing a study to identify new rule curves that may resolve future conflicts between minimum instream flow requirements and Flatheaad Lake refill targets. Implementation of new rule curves through the Plan may help avoid a repeat of the issues that arose this summer. Given the requirements of the National Enviornmental Policy Act (NEPA), however, it does not appear that the Plan can be completed by next winter as your letter urges. The Deparmtent has been advised that implementation of the new rule curves may require preparation of an Environmental Impact Statement (EIS), a process that can take over a year to complete. Accordingly, the Department recently agreed with the Tribes' request to extend the deadline for completion of the Plan. Although the result of this extension is another summer without the benefit of a Plan, the additional time necessary for compliance with NEPA will provide the Flathead Lakers opportunities for meaningful participation and input regarding the Plan and its effect on lake levels. This would include the opportunity to participate in scoping meetings and to provide comments on the draft EIS. We strongly encourage the Flathead Lakers to participate in these public processes. Because there is still uncertainty as to the time line and structure of the NEPA process, we recognize the need to address the community's immediate concerns surrounding this issue. As such, we propose that the Department, in conjunction with the Tribes, host a meeting on Tuesday, August 21, 2001, for members of the Flathead Lakers and other interested partiies. The Federal Energy Regulatory Commission and the Corps will also be invited to participate. Similar to the presentation by Jeffrey Loman of the Bureau of Indian Affairs at the Flathead Lakers annual meeting on June 24, 2001, such a meeting will provide information on the current status of the Plan and offer your organization and others an opportunity to provide input and voice concerns. Thank you for your continued interest in this matter. If you have any questions concerning this letter, please contact Mr. Jeffrey Loman, (202)208-7373. Sincerely, Assistant Secretary - Indian Affairs
Office of the Secretary
U.S. Department of Interior
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Under current rules, Flathead Lake is drawn down to 2883 feet above mean sea level by 15 April to ensure that the lake can absorb a large volume of water in a flood year without exceeding elevation 2893. If that drawdown requirement can be relaxed for drought years, there will be a higher probability that the lake can refill in years such as 2001. At the request of the Confederated Salish and Kootenai Tribes, The U.S. Army Corps of Engineers studied the issue and produced a report that now is available. We are making the text portion of the report (184K PDF) and the first appendix (466K ZIP) available online. To download, hold and click on the Macintosh, right click on the PC, and select the option that is equivalent to download to disk. The ZIP file can be expanded with PK Zip (Windows) or Stuffit Expander (Macintosh). Go to www.versiontracker.com to find expansion utilities. Stuffit Expander is freeware that can be downloaded from www.aladdinsys.com. An additional 45 megabytes of supporting files can be downloaded from the USACE's FTP site using an FTP client such as Fetch (Macintosh) (go to www.versiontracker.com to find FTP clients for Windows and Macintosh). You cannot use your browser to do this; you will reach the directory, but you won't be able to access the files. Use your FTP client to go to this directory: ftp://ftp.nws.usace.army.mil/pub/ Then, select the folder Flathead DMP. Top of page.
July 7, 2001 David P. Boergers, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426 Gale Norton, Secretary
U.S. Department of the Interior
1849 C Street NW
Washington, DC 20240 Re: Kerr Hydroelectric Project No. 5
Dear Secretary Boergers and Secretary Norton: The Flathead Lakers hereby requests authorization to participate in the development of a drought management plan for Flathead Lake required by Article 60 of the Kerr Dam license as described in the June 25, 1997 Federal Energy Regulatory Commission Order Approving Mitigation and Management Plan. The Flathead Lakers is a nonprofit, citizens organization working for clean water, healthy ecosystems and lasting quality of life in the Flathead Watershed in northwest Montana. Many Flathead Lakers members are lakeshore property owners who have serious concerns about the lake level predictions and accessibility for Flathead Lake during this summer of drought. Among those concerns is the effect of below normal lake levels on the economy of the Flathead Lake region. Reasonably stable lake levels are very important to the well being of various commercial businesses located around Flathead Lake. The Flathead Lakers signed the Memorandum of Understanding, written in 1962, amended in 1965 and approved by the Federal Energy Regulatory Commission in 1966, which instructs the power company on how to manage lake levels. The Flathead Lakers also intervened in the Kerr Dam relicensing process in 1990. The Flathead Lakers organization has a long history of encouraging full public disclosure and public involvement in resource development and management decisions and government actions which may impact the waters of the Flathead Basin. The Flathead Lakers expected that the required drought management plan would resolve the potential conflict between the lake level targets outlined in the Memorandum of Understanding and the Flathead River flows below Kerr Dam required in Article 56, and would provide the public with information about how the lake levels and lower river flows would be managed in a drought year along with the reasons for that decision. The December 31, 2000 deadline for completing the plan has passed and the plan is not yet completed. The plan has not been available to guide the operation of Kerr Dam this year when it was needed. We understand that the Confederated Salish & Kootenai Tribes and the U.S. Army Corps of Engineers have undertaken an effort to revise the rule curve governing Kerr Dam operation. We applaud this effort and believe it will yield useful information to better manage for both lake levels and river flows in future drought years. However, forecasts that low mountain snowpack conditions last winter would exacerbate an already existing drought situation, warranted, we believe, development of an interim, provisional drought management plan. We encourage you to require the completion of a drought management plan before next winter when it may be needed again. The drought management plan will affect lakeshore property owners, area businesses, recreation opportunities, and fish and other aquatic life. We therefore believe the public interest will be best served by open public discussion about policies that affect our public waters such as the drought management plan. Thank you for your consideration of this request. Sincerely, Sid Rundell
President Robin Steinkraus
Executive Director
cc: Sen. Conrad Burns
Sen. Max Baucus
Rep. Dennis Rehberg
Robert H. Grieve, FERC
Jeffery Loman, B.I.A.
Brian Lipscomb, CS&KT
Kerr Project Service List Top of page.
14 July 2001 On 12 June, PPL MT and the Confederated Salish and Kootenai Tribes agreed on what amounts to a temporary drought management plan for Kerr Dam, Flathead Lake, and the Flathead River. As reported by Kalispell's Daily InterLake, the plan contains these elements: Outflows from Kerr Dam will be ramped-down to 4,000 cfs at 1,000 cfs per day. PPL MT had wanted to ramp down to 3,200 cfs, the minimum flow allowed by the license, while the CSKT had wanted to ramp down to 5,000 cfs to compensate for low May and June outflows that were a departure from the license.Outflows from Hungry Horse Dam will be ramped-up earlier than planned. The value was not reported by the newspaper, but by the morning of 14 July, the outflow had increased from 510 cfs to approximately 1,600 cfs. PPL MT's managers for Kerr Dam were reported as expecting that inflows would equal outflows by the close of the weekend of 14-15 July, expressing cautious optimism that the lake might refill slightly. Before the compromise was reached, the lake had fallen to approximately 2891.7 feet. In the license, full pool is 2893 feet, but in practice, the lake's average summer elevation is approximately 3 inches lower. The lake had been falling faster than predicted by the Department of the Interior (below). Initial indications are that the DOI's lake levels model was in error because the consultant (Stetson Engineers, out of California) assumed lake inflow values for an "average" drought instead of for a drought on the order of 1977. Reportedly, the model was run again recently with updated values, but the results have not been made available to the Flathead Lakers. Senators Max Baucus and Conrad Burns helped broker the compromise.
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