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C.

Engle 1

Caroline Engle
Professor Wildermuth
ENVIR 485
14 March 2016
Final Exam
In March 2012, the Washington State Department of Ecology and United States
Department of the Interiors Bureau of Reclamation released the Final Programmatic
Environmental Impact Statement for the Yakima River Basin Integrated Water Resource
Management Plan. Contrary to a lot of the Environmental Impact Statements studied in class,
these agencies chose the more environmentally sound alternative: implementing the Yakima
River Basin Integrated Water Resource Management Plan. This Plan is supposed to improve fish
levels back to a healthy equilibrium, improve water storage in case of droughts, increase water
conservation efforts, and protect and enhance watersheds. The plan received approval in the
Department of the Interiors Record of Decision on July 9, 2013.
The lead agencies for the Yakima River Basin Integrated Water Resource Management
Plan were the Department of the Interior (specifically its Bureau of Reclamation) and the
Washington State Department of Ecology. The Department of the Interior has been involved in
the Yakima River Basin Water Enhancement Project since the agency conducted a feasibility
study for the basin in 1979. The Washington State Department of Ecology was a lead agency
because it filed an adjudication of the Yakima River system that named all people claiming the
right to use the surface waters of the Yakima River System to be defendants, including the United
States. This adjudication is intended to determine surface water rights and how to prioritize other
water rights in the basin and remains ongoing. Together, these two departments conducted the
Yakima River Basin Water Storage Feasibility Study to find doable ways of expanding water
storage in the basin. This led them to release a joint Storage Study Draft Planning Environmental
Impact Statement.
Two agencies acted as cooperating agencies for the Yakima River Basin Integrated Water
Resource Management Plan: the United States Department of Agriculture and the United States
Department of Energy. The Department of Agriculture was involved because one of the main
purposes of the Yakima River Basin Integrated Water Resource Management Plan was to lessen
the effects of years with low rainfall, which affected farmers and their crops heavily. The
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Department of Energy acted as a cooperating agency because one of its aims is to address the
United States environmental challenges with scientific and/ or technological solutions. The
Department of Energys knowledge about different methods of conservation, storage, and
irrigation were probably very useful for the Yakima River Basin Integrated Water Resource
Management Plan. Hydropower is also affected by the Yakima River Basin Integrated Water
Resource Management Plan because projects will affect the Roza and Chandler Powerplants, so I
imagine that contributed to the Department of Energys interest in the project as well.
The main federal action needed for the Yakima River Basin Integrated Water Resource
Management Plan is Congressional authorization for the plans implementation and funding. To
make the argument for the Yakima River Basin Integrated Water Resource Management Plans
necessity, the Environmental Impact Statement lists its purpose and need as meeting the aquatic
resource demands for fish and wildlife as well as preparing for dry-year irrigation and municipal
water supply demands. The Yakima River Basin Integrated Water Resource Management Plan is
designed to address all of these issues. Although it is largely beneficial to the environment, the
responsible agencies still had to conduct an Environmental Impact Statement instead of an
Environmental Action because of how many facets of the plans there are and how all those
projects will affect and change the Yakima River Basin.
The Environmental Impact Statement only listed two alternatives: the Yakima River
Basin Integrated Water Resource Management Plan and the No Action Alternative. The Yakima
River Basin Integrated Water Resource Management Plan was designated as the agencies
preferred alternative. The agencies claimed the Yakima River Basin Integrated Water Resource
Management Plan was the only alternative that addresses the purpose and need for the proposed
action through ecosystem restoration, watershed enhancement, water supply, and climate change
flexibility issues in the basin. Conversely, the No Action Alternative perpetuates current trends
affecting habitat and water supply, meaning this alternative does not meet the purpose and need
of the agencies and would result in adverse environmental impacts.
The No Action Alternative and the Yakima River Basin Integrated Water Resource
Management Plan differ greatly. The No Action Alternative would only include projects already
authorized and funded, scheduled for implementation, and/ or planned and designed outside the
Integrated Plan developed for the preferred alternative. The Environmental Impact Statement
wrote this as an all-or-nothing scenario, with no third alternative that included only some of the
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projects suggested by the preferred Yakima River Basin Integrated Water Resource Management
Plan. Although I cannot pretend to be an expert on water resource management, I believe the
responsible agencies could have developed some alternatives that included only some of the
provisions proposed in the Integrated Water Resource Management Plan. I think I would have
proposed an alternative that focused solely on improving water storage through conservation
efforts and projects that created more groundwater and surface water storage. This alternative
would lack the Yakima River Basin Integrated Water Resource Management Plans projects that
helped fish and wildlife populations and habitats. This alternative seems like a fair one to
consider because the responsible agencies discussed mitigating the effects farmers and those in
municipalities feel during drought was a top priority. While I personally prefer the Yakima River
Basin Integrated Water Resource Management Plan in its entirety, I also think having a third
alternative besides the Preferred and No Action Alternatives is important when conducting
environmental review. I understand why every aspect of the Preferred Alternative was in that
plan, but also know that the government receives a lot of criticism for the way it uses taxpayers
money and see this as a way to show government agencies are at least cognizant of that and
consider lower-cost alternatives to what they might ideally propose.
Public controversy did arise from the lack of any other alternatives, but the public seemed
most concerned about how little detail was given for the Yakima River Basin Integrated Water
Resource Management Plan. Numerous comments stated that the Draft Programmatic
Environmental Impact Statement analysis did not contain enough detail to evaluate potential
impacts. Comments also stated that the projects were not sufficiently developed to allow for
adequate analysis and requested additional details in the analysis of the projects. The Department
of the Interior and Washington State Department of Ecology responded by saying that the
Yakima River Basin Integrated Water Resource Management Plan was composed of a lot of
smaller programs. These programs each have a different focus, such as habitat enhancement or
domestic conservation. Each program is then composed of smaller projects, many of which have
details the responsible agencies have yet to determine. The responsible agencies acknowledged
this was something they will have to rectify, but said further definition and analysis before the
projects implementation would accomplish that. The responsible agencies contention is that the
Yakima River Basin Integrated Water Resource Management Plan was still in its early stages
and, as a result, it made sense for the Programmatic Environmental Impact Statement to be
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prepared and analyzed more broadly. Specific projects would be analyzed with more detail if
Congress authorized and funded the plan. Because these detail-oriented analyses would occur
later, the agencies urged the public to look at the basin-wide, cumulative effects of the plan, not
its specific details. The the responsible agencies expanded their analysis on No Action
Alternative to make comparing the alternatives easier. The Washington State Department of
Ecology also determined that the alternatives presented in the Draft Programmatic
Environmental Impact Statement were too narrowly focused, so Ecology prepared a separate
Supplemental Draft Environmental Impact Statement under SEPA to evaluate a way to manage
the Yakima River Basins water in a more integrated way. I determined these were key points of
controversy because of the number of public comments received on the Draft Environmental
Impact Statement and also because it was an aspect of the Yakima River Basin Integrated Water
Resource Management Plan that frustrated me. While I understand the responsible agencies
argument that the level of detail sought by the public was not feasible until the Yakima River
Basin Integrated Water Resource Management Plan was approved, it is frustrating that these
agencies wanted to pass a bill while still knowing so few of the project details. Plans with this
many aims affect a lot of people because the projects have far-reaching effects and are also very
expensive, and I think the public deserves to know more about how those projects will actually
affect them and their environment rather than just having to take everything the government says
in good faith.
The public will eventually learn more of this information, though, because the
Department of the Interior approved and decided to go forward with the Integrated Plan. This
Record of Decision matches the preferred alternative given in the Environmental Impact
Statement and was determined to be the alternative with the least environmental impact. The
agency cited the ecosystem and water resources of the Yakima River Basin as the two main
factors it took into account, both of which are environmental concerns. This Plan was
encouraging to read compared to a lot of others discussed in class because the agencies actually
seemed concerned about the environment more than other interests. This may be due in part
because there were not a lot of other interests around to compete with the environment,
especially since agricultural interests also benefit from the water storage aspects of the plan. The
fact that an Environmental Impact Statement is really needed at all is a little interesting to me;
this appears to be a case where an EIS is necessary more due to the scale of the project than
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because of what the project actually seeks to do. Once construction is complete, this Plan really
only benefits the environment, so it seems weird that it would need to undergo environmental
review unless there was some doubt that it would actually be environmentally beneficial. I
would guess this is a matter of politics where the Environmental Impact Statement had to be
conducted to prove the funding for this project was necessary for the well-being of the area.
While I believe the public deserved more alternatives and details about each alternative during
the environmental review process, I do think the agency made the right decision by choosing to
implement the Yakima River Basin Integrated Water Resource Management Plan instead of the
No Action Alternative.

* I did not seek out or use any sources other than the Environmental Impact Statement and
Record of Decision for the project, which can be found at
http://www.usbr.gov/pn/programs/yrbwep/reports/FPEIS/fpeis.pdf and
http://www.usbr.gov/pn/programs/yrbwep/2011integratedplan/iprod.pdf, respectively.

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