417 



"Any increase in water use and energy consumption due to 

 reduced rates for irrigation carries with it potential 

 environmental consequences. Increased surface water 

 withdrawals reduce the ability of streams to assimilate 

 pollutants and decrease the water available for fish and 

 wildlife. Irrigation runoff increases the load of silt and 

 agricultural chemicals." 13) 



The Franklin Conservation District has recently identified 

 "cheap electricity compared to management time" as a contributing 

 factor in excessive irrigation on 221,000 acres in that county, 

 and, together with the USGS, identified irrigation runoff as a 

 source of nitrate contamination in local residential wells, 46% of 

 which now show contamination levels in excess of the 10 ppm 

 standard. 14) 



Contaminating effects of irrigation runoff in all tributaries 

 of the Columbia River system have been identified in a recent 

 survey by the Environmental Protection Agency. 15) 



Several federal agencies are involved in anadromous fishery 

 habitat restoration efforts in the Yakima River Basin, where tribal 

 fishing and water rights are also at issue. A modeling study of 

 the relationship between crop budget inputs and reductions in 

 surface water contamination was done on the Yakima in 1976 by 

 Whittlesey et alia, in which it was demonstrated that relatively 

 small changes in cost inputs could decrease irrigation-related 

 contamination by as much as 50%. 16) 



The Yakima Basin currently has 36,000 acres of alfalfa and 

 over 75,000 acres of other low-return forage crops under sprinkler 

 irrigation, where pumping energy costs currently exceed 20% of crop 

 budgets. A 1990 modeling study done at Washington State University 

 has shown alfalfa to be a water- intensive crop most responsive to 

 energy price increases in relation to reductions in water 

 application, with decreases from 28 to 15- acre-inches motivated by 

 pumping price increases in the 33% to 66- range. 17) BPA's 

 irrigation discount is demonstrably related to continuing levels of 

 surface water contamination and depletion in the Yakima Basin, 

 bringing the agency's policies in conflict with the purposes of the 

 federal and state agencies attempting habitat restoration in that 

 area. 



2.3 Die irrigation discount lowers the threshold of 

 groundwater depletion. 



Washington limits withdrawals from groundwater by means of a 

 criterion of "reasonable and feasible" pumping lift, in practice 

 and in principle a pumping rate-related standard. 18) In Doherty 

 V. Oregon Water Resources Director, 308 Or 543,783 P2d 519 (1989), 

 plaintiffs argued, unsuccessfully, that pumping rates should 

 determine the practical definition of sustainable yield as applied 



