Oregon Department of Environmental Quality Notifies Portland General Electric of "Serious Shortcomings" in R2 Resource Consultants Report on Insects and Algae in Lower Deschutes River
Citing flawed laboratory methodology and inappropriately applied statistical analysis, the Oregon Department of Environmental Quality (ODEQ) informed Portland General Electric (PGE) in a May 23, 2016 letter that PGE's report by R2 Resource Consultants has been deemed inadequate and deficient in several key components.
The primary purpose of the R2 Resource Consultants study, titled “Final Report: Lower Deschutes River Macroinvertebrate and Periphyton Study” and mandated by the dam operators’ Clean Water Act Section 401 Water Quality Certification, is to determine whether or not operation of the Selective Water Withdrawal Tower at Round Butte Dam has had an impact on the ecology of the river below the dam complex. A baseline study was done in 1999-2001. The present study was intended to compare current in-river conditions in the lower Deschutes River to prior conditions as they were documented in the baseline study.
ODEQ has given PGE until June 30, 2016 to “respond with a plan for mitigating or eliminating the shortcomings of the study.”
As a result, the study’s conclusion that water quality and overall health has improved in the lower river has been rendered an assertion without scientific support. The ODEQ review even went on to say that there are indications that the study supports the opposite conclusion and that water quality has been reduced.
The ODEQ review of the study also expressed the same concern that the DRA had previously described regarding the collection of water quality data and the suggestion by the authors that unfavorable water quality results in the report were due to poorly calibrated instruments.
DRA Analysis of the Report
The DRA had asked four highly qualified individuals (each has a PhD in a field specific to the R2 report) to critique the study. We recently received the first of those critiques back. It is critical of the statistical methodology employed by R2 Resource Consultants and confirms ODEQ’s analysis.
We sought these four reviews as we had major concerns about the R2 report. Almost all of our concerns are mirrored in the ODEQ analysis.
How Did This Happen?
The macroinvertebrate and periphyton study is a highly important component of the monitoring of the Pelton-Round Hydroelectric Complex impact on the Deschutes River. The installation and implementation of the Selective Water Withdrawal Tower was the single largest anthropogenic change that has been imposed on the lower Deschutes River in the past fifty years. The impacts of that change have to be monitored effectively using appropriate methodology and analysis. This sort of monitoring is mandated by the Water Quality Management and Monitoring Plan, a part of the Clean Water Act Section 401 Certification that sets standards for operations at the Pelton-Round Butte Hydroelectric Complex.
This is the only way to determine if tower operations are having harmful effects on the lower river.
The dam operation permits and certification call for “adaptive management” in the event that there are problems created by Selective Water Withdrawal. To date, the only "adaptive management" invoked by PGE has been to seek agreements from ODEQ not to enforce various water quality requirements imposed on dam operations. The intent of the macroinvertebrate and periphyton study is to determine if that has or has not resulted in damage to the ecology of the lower river.
So the stakes are high for PGE. If this report were to document a decline in water quality and unfavorable changes to the ecology of the river below the dam complex, changes in dam operations would need to be made.
R2 Resource Consultants seem to be highly qualified to conduct studies such as this. But the work was done as a paid service to PGE.
PGE has been entrusted with the responsibility of monitoring for adverse changes to the river system as a consequence of the SWW Tower and its operation. This responsibility needs to be undertaken with a rigorous and transparent approach to assessing the state of a public resource affected by their operations. Anything else is a violation of that responsibility.
Deschutes River Alliance: Cooler, cleaner H2O for the lower Deschutes River.
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