50,000 cfs. (Historically, a flow of 50,000 cfs had a statistical probability of 

 occurring once in 100 years). Up to 40,000-45,000 cfs will be released routinely 

 into the reregulating reservoir. 



Discharges from the proposed reregulating dam will apparently conform to those 

 criteria established by the Corps and now in effect below the main dam. As stated 

 previously, those criteria include a minimum discharge limit of 2,000 cfs. 



The Corps has stated on numerous occasions, both orally and in writing, that 

 flows below 4,000 cfs will occur infrequently or in emergency situations only. In 

 its Design Memorandum 50, the Corps stated that a minimum flow of approximately 

 4,000 cfs will be considered below the reregulating dam during the summer months 

 in order to maintain the aesthetic value of Kootenai Falls. Yet, in the same docu- 

 ment, water release from the proposed reregulating dam during the summer is charac- 

 terized in terms of being reduced from 46,000 cfs to 2,000 cfs in 49 hours 45 min- 

 utes. 



Furthermore, in an invitation for bids for Phase I of reservoir clearing, a 

 revised minimum discharge limit of 1,500 cfs was recently introduced by the Corps. 

 The Fish and Wildlife Service, having received no forewarning, questioned the re- 

 vised limit, and the issue was raised again at the last meeting of the Environ- 

 mental Coordinating Committee, May 9, 1978. No response has yet been given. The 

 intent or validity of 1,500 cfs as a newly established discharge limit is simply 

 not known, but it is vital to this issue. Such inconsistencies should be clari- 

 fied. 



Throughout the Corps' planning process for additional generating units and re- 

 regulation at Libby Dam, it has generally been feared that the reregulating dam 

 and reservoir will not be used primarily for smoothing out the wild fluctuations 

 caused by peaking operations. The Corps has attempted to allay this and other fears 

 on numerous occasions and has responded to countless inquiries into its operating 

 assumptions; however, the fears have not been allayed and questions continue to 

 arise. Senator Hatfield's recent letters to the Governor of Montana and the Corps 

 bear witness to these doubts. 



The adequacy of the existing minimum discharge limit and maximum fluctuation 

 criteria--from both an operational and environmental viewpoint--is unsettled. With- 

 in the last month, the Department of Fish and Game, based on experiences to date 

 with fluctuations below Libby Dam, has revised its recommendation regarding maximum 

 fluctuations and minimum discharge limits. Prompted by Senator Hatfield's query 

 "Is Montana satisfied with the criteria"? the Department of Fish and Game has rec- 

 ommended: 



1. Fluctuations not in excess of three feet per day, one-half foot per 

 hour, year around 



2. A minimum instantaneous discharge of 4,000 cfs 



3. A steady flow three hours before sunset until dark and a steady flow 

 during weekends. May through October. 



The third recommendation was made to accommodate fishermen. The second is part- 

 icularly important during the periods of April through June and October through Nov- 

 ember, as they represent the spawning periods of the most abundant fishes in the river 

 and it is believed that continuous flows of at least 4,000 cfs will ensure inundation 

 of spawning beds. 



The timing of fluctuations is as important as the magnitude of those fluctuations- 

 perhaps more important. The Corps has given assurances that the reregulating dam, 

 whether equipped with generators or not, will permit peaking operations and that the 

 resulting fluctuations below the reregulating dam will conform to the established cri- 



8 



