On September 28, 2011, Public Utility District No. 1 of Snohomish County filed an application for a preliminary permit proposing to study the feasibility of the Sunset Falls Hydroelectric Project to be located on the South Fork Skykomish River near Index in Snohomish County, Washington. On March 21, 2013 Snohomish PUD filed a Pre-Application Document and Notice of Intent to seek a hydropower license to dam the South Fork Skykomish River. American Whitewater has joined a number of river conservation organizations in opposing this project for the following reasons:
1) Minimal Power
The estimated annual nameplate capacity for this proposed project is 30 MW. However, as noted in the application, the actual generation will be dependent on minimum stream flows. As such, the project’s actual capacity given limited seasonal flows will be 13.7 MW.
While we understand that proximity to existing Snohomish PUD facilities makes this project attractive to the PUD, given the number of existing dams in Washington State, and the number of dams that currently do not generate electricity or that are not operating at peak efficiency, new dam construction should not be contemplated until we maximize use from existing dams and existing hydropower projects.
2) Substantial Environmental Impacts
The Conservation Groups have discussed with Snohomish PUD ways to conserve additional energy, to utilize existing dams and to pursue new hydropower technologies, all with the goal of avoiding the need to build new dams that have adverse environmental impacts. We understand that Snohomish PUD is actively pursuing some of these strategies, which we support. However, continuing to explore new development at Sunset Falls is inconsistent with those strategies. Further, it is an inappropriate location for development of a new hydropower project.
Development of the Sunset Falls Hydroelectric Project would have many environmental impacts, including impacts on aesthetics, recreation, and resident fish and wildlife habitat and species. The project would greatly reduce flows on a scenic cascade-and-falls combination and would result in construction impacts from building a new dam, a 1.1 mile bypass, a 2000 ft. by 19 ft. diameter intake tunnel, a semi-underground powerhouse, a 2 acre reservoir and a 8.5 transmission line to the existing substation in Gold Bar.
In addition to the significant environmental impacts, the project proposed in the PUD’s preliminary permit application would be plainly inconsistent with a number of relevant comprehensive plans that have previously been filed with the Federal Energy Regulatory Commission. This inconsistency runs counter to Section 10(a)(2)(A) of the Federal Power Act (FPA) (16 U.S.C. § 803 (a)(2)(A)) that specifically requires the Commission, when licensing a project, to consider “the extent to which [a] project is consistent with a comprehensive plan (where one exists) for improving, developing, or conserving a waterway or waterways affected by the project that is prepared by an agency established pursuant to Federal law that has the authority to prepare such a plan; or the State in which the facility is or will be located.”
The Skykomish River is part of the Washington State Scenic River system (79A.55 RCW), the legislative purpose of which is to “protect and preserve the natural character of such rivers and fulfill other conservation purposes.” Rivers in the system “shall be preserved in as natural a condition as practical and that overuse of such rivers, which tends to downgrade their natural condition, shall be discouraged.” In addition the section of the Skykomish River that includes Sunset Falls is in a Northwest Power and Conservation Council Protected Area from hydropower development, and has been recommended to Congress for designation as a National Wild and Scenic River for its Scenic, Recreation, Fish, and Wildlife values by the U.S. Forest Service. FERC has long recognized the importance of regional and coordinated planning, and has declined to issue licenses in cases where the negative impacts of a proposed project would run counter to these regional plans. Wild and Scenic suitability, protected area status, and status as a State Scenic Waterway each constitute relevant in-place plans and strategies to enhance and protect the aquatic, aesthetic, habitat, recreational and conservation resources of the Skykomish River.
For the foregoing reasons, we do not agree with the PUD's repeated description of the Sunset Falls Project as a “low-impact hydropower project” or that it will, with limited available seasonal flows, “provide an environmentally sound, carbon-free, sustainable, and dependable energy source.”
3) New Hydropower Dams Do Not Count as a Renewable Resource in Washington State
In its description of project benefits, Snohomish PUD's preliminary permit application discusses Washington State’s renewable portfolio standard that requires large utilities such as the PUD to provide 15 percent of their load from new, renewable energy resources by 2020. However, as the PUD acknowledges, the Washington standard does not count power generation from newly constructed hydropower projects such as the one it is proposing as eligible under this standard. Therefore the PUD's speculative assertion that one of the project benefits will be to help the PUD meet the state RPS requirements is inaccurate and misleading.
A History of Failed Proposals
A number of developers, including Snohomish PUD, have investigated the feasibility of hydropower development over the past several decades. The low power potential of the site and high cost of development led consistently led to a decision not to develop the site. At the same time the conservation value of the river in its free-flowing state has received greater recognition.
A number of hydropower projects have been proposed at Sunset Falls over the years.
- Puget Sound Energy explored the site early in the 20th century.
- Snohomish PUD had a project proposal (FERC P-4786 and FERC P-8574) in the early 1980's.
- Pacific Hydro submitted a permit application in October 1984 (FERC P-8644) that they withdrew in September 1985.
- Sunset Falls LP submitted a permit application in September 1991 (FERC P-11195) that they withdrew in September 1993.
- Tacoma Public Utilities submitted a permit application in December 1991 (FERC P-11216) that they withdrew in May 1992.
- Snohomish PUD submitted a permit application for hydropower development in September 2011 (FERC P-14295).
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