CITIZENS OF OREGON FOR ENERGY SECURITY

PO Box 375, Walterville, OR 97489
To: Oregon Decision Makers
RE: Potential closure of Leaburg Hydroelectric Plant 2031
Preface:
The State of Oregon has been required by the Infrastructure Investment and Jobs Act, commonly
referred to as the Bipartisan Infrastructure Law (BIL), to submit State Energy Security Plans (SESP) in
section 40108 to receive federal financial assistance.
The State Energy Security plan is broad in scope and seeks to provide vital information to State
Planners and responders in time of crisis.
A principle of being able to minimize impacts from wildfires, earthquakes, weather, terrorism and
cyber-attacks are to have multiple options.
In 2031 EWEB plans to begin decommissioning Leaburg Dam. It is their stated intent to purchase
additional power required from the Bonneville Power Authority (BPA).
Power is transmitted from Bonneville by means of long power lines which are exposed due to
traversing many miles of open country. The ice storm of January 13, 2024, showed that lines on poles
can be defeated by weather alone.
Executive Summary
There is a compelling case for retaining the Leaburg generating facility for energy security reasons.
Retaining the dam makes economic and practical sense. Retaining the facility in an operational state
would bolster regional resistance to systemic attack or failure.
Background
Historically Leaburg Dam hydroelectric plant and Camp Creek hydroelectric plant have reliably
produced clean, green power. The Leaburg plant has been in existence for approximately 90 years.
EWEB plans now to close the dam because some expensive repairs to the canal are necessary. They
determined that when weighed against the remaining license period (then around 17 years), insufficient
revenue would be generated to cover the costs.
The world political landscape has changed greatly over the past years. Global tensions have escalated,
but at the same time new types of warfare and hostility have arisen as part of asymmetric warfare. This
puts almost anything in scope for deliberate disruption. To some extent, computers and the internet
have facilitated that, allowing actions to be conducted from thousands of miles away. Long standing
bad actors have escalated their actions - often in consequence to sanctions or other actions. Newer
threats have also emerged at the same time from formerly regional conflicts. The combination of both
of these elements pose an increased threat to energy supply. Active and passive defense mechanisms
are now very necessary.
Hacking electrical companies is one form of hostility, but there are many possibilities. In Ukraine one
can see how energy supply is a key issue. Power stations are a key objective and threat. Modern
thinking on large power stations providing power over large areas extends the radius of damage that
can be caused by targeting one facility. This is very visible in Ukraine, were the Zaporizhzhia power plant
to be lost, seven nations and millions of people would be without power. However, it is not just threats
from bad actors which are present. Today and increasingly, climate change is producing more extreme
weather events.
Analysis
• Today most utilities in Oregon purchase their power from BPA. From a security perspective, this
represents an elevated risk, placing all eggs in one basket. Hostile actors who might seek to do ill to
Oregon has to be considered in today’s world.
• On January 13, 2024, an unexpected ice storm greatly impacted the Springfield area. Power lines and
poles were downed over large areas. The damage was extensive, and revealed conclusively how
fragile and exposed power lines can be in some conditions. On resumption of service some locales
started later than others, depending upon the extent of pole damage. Bonneville Power Authority was
also impacted, and power was locally lost for a while.
• In reviewing written submittals from EWEB, no discussion was seen on the lower reliability of power
lines stretched over many miles from the generating point, or on security. We were unable to find an
assessment on reliability, subsequent to reducing the number of generating points in a system. There
was no discussion about the sudden loss of power over a wide area which could happen if Bonneville
Power Authority (BPA) lines were downed.
• The Leaburg Hydroelectric dam was paid for with public money which over 90 years has been
providing power - as intended when the project was set up. If the dam and hydroelectric plant is
demolished that money will be lost - and additional significant costs incurred.
• Should the Dam and hydroelectric plant be demolished, there would be significant costs for both the
State, and Lane County. The Dam removal would probably require a bridge to be constructed and
roads. The highway and neighborhood would be subjected to upheaval for a prolonged period of
time. Traffic flow would be impacted, and no plan has been submitted for that. The EWEB studies
show the canals to be in poor repair (outside this analysis), the proposal is to use them for drainage
and not to return the land to the condition it was in prior to Dam construction. This would be typical
for such a project, and it would be a costly undertaking. However, abandoning the canals leaves them
for the county to maintain in perpetuity.
• When FERC grants a license to a power generator it is for a 40-year time period. When considering
high-cost items, such as power plants, more time is needed to amortize costs. The decision analysis
by EWEB is based on the end of the current license period - which is shown by them as 2040, or 16
years. This is quite a short time period for amortizing expenditures necessary to refurbish the dam
and canals. FERC will likely offer a 10-year extension to complete the work, making a total of 26 years.
That extra 10 years would significantly alter the economics. Full facility renewal becomes much more
attractive. This fact has not appeared in the presented decision information.
• The memoranda (October 6, 2022) upon which the commissioners' decisions were based show that
not returning the canals to pre-existing conditions is crucial to their cost analysis. Leaving the canals
open will not return the landscape to its state prior to construction. It will leave deep scars for miles
across the landscape. Those scars - and the streams running through them will require maintaining.
EWEB operates outside of the county planning process, and the state goals - such as goal 5. The
provisions of that goal allow wildlife to more freely roam the countryside, without falling into empty
canals.
• If alternative 4 (Decommission to stormwater conveyance) is not considered for acceptability reasons,
the costs are much closer for all alternatives.
• Costs for the citizens of Eugene as an overall exercise are massive - they funded the construction of
the Dam in 1927. That would appear to be $50 million in today’s dollars, baseline costs for demolition
were stated as $175 million in the October 6, 2022, EWEB memoranda. Costs for the County and State
are not included by EWEB but would be borne by the taxpayer. After demolition and all that
expenditure Eugene would have no assets to show, and less protection from the perspective of
energy security. EWEB hope for some grant money from Federal and State sources, which would
amount to other taxpayers subsidizing EWEB.
• EWEB decision making excluded State or County interests and costs as part of the discussion.
• There has been much discussion over the numbers of returning fish, and that being a factor in Dam
removal. Evidence from local residents who have occupied areas where fish used to gather suggests
that this is not the dominant factor. It was reported that the fish continued to come in large numbers
for about 40 years after Dam construction. They used to gather by the Bellringer launch ramp, but
stopped coming upstream to that point around 1971. There are suggestions that in fact modern fishing
techniques deep sea, have had more of an impact, than the Dam’s existence. Demolishing a Dam
without full investigation could be premature.
• There has been an expression of interest from a third party potentially interested in purchasing the
dam.
Recommendations
There are many factors which weigh in as part of a monumental decision such as Dam removal. EWEB
does not follow the usual procedures a body such as the county does. We would urge that holistic
investigation be done utilizing nonaffiliated experts to assess the EWEB decision. None of the EWEB
commissioners have the technical expertise to assess the complicated data knowledgeably. They were
not presented with the picture outside the EWEB fence, and there was no discussion about local energy
security.
It is recommended that the State mandate a pause to all further efforts to decommission the Leaburg
hydroelectric plant. To ensure the complete picture is better understood, a diligent and all
encompassing public inquiry should be initiated. Citizens for Energy Security believes that there seems
to be an increasingly strong case to retain the dam.