PUD preparing application for hydroelectric development

Editor's Note: This story has been amended since publication to reflect changes in the public utility district's schedule for applying for licensure with the Federal Energy Regulatory Commission.

It's been 2 1/2 years since a procession of Snohomish County Public Utility District employees and representatives from the Federal Energy Regulatory Commission (FERC) wound its way through the prospective site of the PUD's Sunset Fish Passage and Energy Project, a new hydroelectric facility proposed for the south fork of the Skykomish River near Index.

Now, after years of planning and executing feasibility studies to examine the project's potential impacts, the PUD is poised to submit its Draft License Application (DLA) to the FERC.

It was anticipated that PUD commissioners would pass a resolution regarding DLA submission in January, but the PUD has since determined that only the Final License Application (FLA) will require a resolution. Once the DLA is filed, a 90-day review and comment period will be triggered, giving stakeholders the opportunity to provide written feedback. The PUD must address all comments in order to compile the FLA, which is tentatively scheduled for submission at the end of 2016.-áPUD plans to file the DLA by Jan. 15.

The project is contingent on licensure by the FERC, the federal agency tasked with licensing hydropower projects.

PUD principal engineer Mark Flury gave an overview of the project during the commission meeting last Tuesday, prior to commissioners hearing public comment.

The commission chamber was packed with dozens of opponents to the proposed hydroelectric development occurring on a designated Washington State Wild and Scenic River that is also protected from such development through a Northwest Power and Conservation Council designation.

Additional concerns were raised about the ongoing landslide south of Sunset Falls, directly adjacent to the project's vicinity.

The Sunset Fish Passage and Energy Project is a run-of-the-river hydroelectric project that would use rerouted water from the Skykomish River to create power. The intake site design takes advantage of a natural pool in the river, sending diverted water through a series of subterranean tunnels to a powerhouse located at the base of Sunset Falls.

This would create a 1.1-mile "bypass reachGÇ¥ between the intake site and the base of Sunset Falls. Fish would be screened out from inside the tunnel and returned to the bypass reach, while the diverted water would travel to the powerhouse and then be dispelled at the base of the falls through a submerged tailrace.-á -á -á

"The headrace tunnel would consist of a 22-foot diameter, 600-foot-long tunnel that leads from the intake to the fish screening facility, and then a 19-foot diameter tunnel for 1,500 feet, from the fish screen facility to the powerhouse,GÇ¥ Flury said.

The tunnels would be blasted out of existing bedrock using controlled dynamite charges.

The powerhouse would be co-located with the existing state-operated trap-and-haul facility on the north side of Sunset Falls. In operation since 1958, the trap-and-haul facility transfers migrating salmon above Sunset, Canyon and Eagle Falls, which create natural barriers for fish. Fish spawning takes place upstream, after which juvenile salmonids traverse the waterfalls as they swim out to sea.

In order to help mitigate the project, the PUD would perform extensive upgrades and renovations at the trap-and-haul facility.

The project features no weir or cross-river structure, instead taking advantage of the south fork's Z shape, which includes two sharp 180-degree turns. The 30-megawatt facility would produce an average of 13.7 megawatts of power ' enough to serve 13,200 homes annually ' and would cost approximately $145 million to build.

Based on approximate license issuance of mid to late 2018, Flury said the construction process could begin in late 2019. Construction would be spread out over five separate phases, with trap-and-haul improvements slated for 2022. The project footprint is less than five acres and primarily underground. The facility would begin operating in 2023.

According to the PUD, the project would create approximately 480 jobs over a 30-month period and provide a temporary increase in sales tax revenue.

The PUD filed its Compilation Study Report with the FERC in January, including data from 17 individual studies meant to examine project impacts. In June, the FERC requested additional data and analysis on three separate studies, including aesthetics, recreation opportunities and access and downstream fish passage/fish injury over the falls.

The bypass reach contains two significant waterfalls, Canyon and Sunset Falls. Opponents have long been concerned that less water going over the falls will negatively impact juvenile fish traveling downstream. Opponents argue less water means a more jarring the trek over the rocky falls for the fish. Flury told commissioners the PUD specifically looked at hydraulic parameters associated with injury to fish and determined lower flows would actually result in less injury.

Flows ranging from 250 cubic feet per second (CFS) to 5,000 CFS were studied. Initial downstream studies were based on natural flows, while the supplemental study requested by FERC was done through computer modeling.-á -á

"Our determination was that lower flows through the Canyon to Sunset Falls reaches would result in less potential for injury than the higher flows. This correlates well with our studies with live tagged fish that we conducted with the initial study plan,GÇ¥ Flury said. "Generally, there's a reduced likelihood of injury and mortality with the lower flows.GÇ¥ He added reduced flows would provide increased habitat in the reach.-á

Eleven people came forward to provide testimony following Flury's presentation.

Pete Rainey owns a home on Loop Road, a quarter mile downstream from the landslide and Sunset Falls. He zeroed in on instream flows, faulting the PUD's power production estimations for being based on historical flows gathered from 1928-2014 and not taking climate change into consideration.

"To know if this is going to be a winner or a loser, you need to do your best to figure out what they will be in the future, not what they were in the past,GÇ¥ Rainey said.

Rainey also questioned the project's economics.

"The biggest beneficiaries are liable to be a few consultants and contractors who are probably already doing very well financially,GÇ¥ Rainey said. "This project will cause a redistribution of wealth from the pockets of ratepayers into the bank accounts of a few. If you are acting as fiduciaries for the ratepayers, and if you believe that helping to widen income inequality is not right, stopping this project is your chance to support your beliefs with action.GÇ¥

He acknowledged that commissioners might worry about repercussions from stopping the proposal.

"But today you have excellent justification,GÇ¥ Rainey said. "A major problem developed that did not exist when this project started, and I'm referring to the ever-growing landslide immediately adjacent to the project site. This slide has been getting bigger and bigger for over two years now. At least a quarter-mile of the proposed original access road to the intake site is totally destroyed.GÇ¥

Mt. Index River Road, used by PUD and FERC officials during the 2013 site tour, is barely recognizable. Severely damaged in the initial landslide in December 2013, the stretch of roadway at the base of Sunset Falls has continued to deteriorate.

Recent flooding created further deterioration. Downed trees now block the west end of the damaged road, making the hike into Sunset Falls precarious and challenging to navigate. The journey must be made on foot, as vehicular access is restricted.-á

Rainey cited what he called the PUD's own criteria for choosing potential hydropower sites, which includes having no known geological hazards or unstable areas.

"Sunset Falls most definitely does not meet that criteria,GÇ¥ Rainey said.

Snoqualmie Indian Tribe Water Quality Manager Matt Baerwalde reminded commissioners the south fork of the Skykomish River has been protected from hydroelectric development by the Northwest Power and Conservation Council since 1988 because there is no way to mitigate its impacts.

Baerwalde voiced concerns about the downstream fish passage studies, which he said failed to address steelhead kelts. Unlike salmon, which spawn once and die, steelhead can spawn two or three times in an average lifespan. The fish return to the ocean in between spawning events, so kelts are defined as adult steelhead that have spawned and are returning to the ocean.-á

"When steelhead spawn, a certain percentage of them will go downstream, go back out to sea and then come back to spawn again,GÇ¥ Baerwalde said. "Large adult fish were not accounted for in the downstream fish passage study, even though we asked over and over for that.GÇ¥

He was concerned by the limitations of the studies conducted using computer modeling, expressing dissatisfaction with the level of study conducted using live fish. He disputed Flury's assertion that the reduced flows in the bypass reach would provide more habitat.

"That's false,GÇ¥ Baerwalde said. "All aquatic species will have less habitat. They live in water; when there's less water in the channel, they have less habitat.GÇ¥

Tulalip Tribes Natural Resources Liaison Daryl Williams also expressed concerns about heavy reliance on computer modeling for the downstream fish passage studies without "real dataGÇ¥ to back them up. Approximately 20 percent of the fish produced in the Snohomish Basin come through that stretch of river, Williams said, including endangered bull trout, chinook and steelhead. He also discussed the intricacies of the Northwest Power and Conservation Council's 1988 designation of the south fork as protected from hydroelectric development because of its "importance as critical fish and wildlife habitat.GÇ¥

"They do have an exemption process that allows you to build there, if you can show that the project provides substantial benefit for fish or wildlife resources,GÇ¥ Williams said.

Williams said developing a hydroelectric project in a protected area without an exemption could render the PUD ineligible to receive power from the Bonneville Power Administration, under the Northwest Power Act. Currently, the PUD obtains about 80 percent of its power from Bonneville. The Tulalips loosely supported the project initially, because there was concern whether funding for the trap-and-haul would survive the Legislature during the recession.

Weathering that storm, Williams said they are actively concerned about the survival of the fish traveling through the project area. He questioned whether an exemption through the council would be feasible.

"We have a lot of concerns about how juveniles are going to survive going through this bypass reach if the project is built, and without being able to answer those questions very well, we don't see that substantial benefit is there to get an exemption,GÇ¥ Williams said.

To learn more about the Sunset Falls project, visit www.snopud.com/PowerSupply/hydro/sfpep.ashx?p=1956.