The Snohomish County Public Utility District (PUD) held discussion last week on the Sunset Falls Fish Passage and Energy Project, a new hydroelectric facility proposed for the south fork of the Skykomish River near Index.
The project would reroute water from the Skykomish River through a series of subterranean tunnels that would be blasted out of bedrock using controlled dynamite charges. The rerouted water would divert to a powerhouse at the base of Sunset Falls, creating a 1.1-mile bypass reach between the intake site and the base of the falls.-á -á
The process has been ongoing since 2012, when the PUD was granted a preliminary permit by the Federal Energy Regulatory Commission to study the project's feasibility. The PUD commissioned 17 separate studies to examine project impacts. The studies were completed in 2015 and a compilation study report was submitted to FERC.
FERC identified data gaps in three of the studies, requesting that the PUD provide supplementary addendums on aesthetics, recreation and downstream fish passage.
Last Tuesday's meeting was narrowed to allowing discussion and public comment pertaining to the three study plan addendums only and attended by PUD staff, consultants, FERC representatives and numerous project opponents.
Despite project revisions, opponents have remained steadfast in their belief the Skykomish River should be protected from hydroelectric development.
The Skykomish River is listed as a Washington State Wild and Scenic River, a designation that discourages hydroelectric development but does not prohibit it. The Northwest Power & Conservation Council added the area to a list of waterways to be protected from hydroelectric development in 1988 because "mitigation techniques cannot assure that all adverse impacts of hydroelectric development on these fish and wildlife populations will be mitigated.GÇ¥
The PUD submitted its Draft License Application to FERC in January. Submission of the Final License Application is tentatively scheduled for the end of this year.
The PUD estimates that project construction will cost $173 million, with a low-end estimate of $139 million and a high-end estimate of $225 million.GÇ¥
Aesthetics
The aesthetics addendum was primarily meant to assess compatibility of project infrastructure and natural surroundings from three Visual Key Observation Points (VKOPs) and conduct additional focus group workshops for analysis of river flows. The addendum was presented by Environmental Resources Management (ERM) Director of Hydraulic Licensing John Gangemi.
According to the addendum, the project is not anticipated to negatively impact scenic attractiveness at the three VKOPs targeted by FERC for further analysis.
"The project was intentionally designed to be as visually unobtrusive as practical,GÇ¥ states the report.
Project opponents disagree.
Jeff Smith owns eight lots in the Mt. Index Riversites area east of Sunset Falls. The home he's lived in for more than 28 years is situated directly adjacent to the proposed intake area, and a planned PUD access road goes through his property.
It's not about what the project is, but where it is, Smith said.
While much of the area surrounding Sunset and Canyon Falls is private property, popular nearby hiking trails to Bridal Veil Falls and Lake Serene annually draw about 25,000 people, who enjoy views of the surrounding landscape as they hike.
"My view is that it was a very myopic way of looking at the impact that this project will have on the surrounding area,GÇ¥ Smith said. "The fact is that this project is going into one of the most spectacular wild and scenic areas in the state of Washington.GÇ¥
To Smith, the area is priceless and not conducive to a large-scale industrial project. The aesthetic study only told part of the story, he said.
Whitewater kayaker Rob McKibbin questioned the section of the aesthetic addendum pertaining to Sunset Falls aesthetic flow preferences, which asserts the "preferred flowGÇ¥ for running Sunset Falls is approximately 10,000 cubic feet per second (CFS).
Gangemi said Tom O'Keefe of American Whitewater provided the number to them.
Sunset Falls is not the status quo for kayakers. The rugged waterfall drops 104 vertical feet through a 275-foot channel and features several potholes along the way. McKibbin, a well-known whitewater kayaker and eight-year guide at the Outdoor Adventure Center in Index, has run Sunset Falls three times. During his first run in 2008, he sustained minor injury after he-áwas ejected from his boat toward the bottom of the chute.
He was the first to run the falls in a kayak, and in 2008, was the first to venture down the falls on purpose since 1926. No kayaker or boater has ever run Sunset Falls anywhere near 10,000 CFS, McKibbin said.
"The highest flow Sunset Falls has been run is at 5,000 CFS, which is 50 percent lower than the number you were given,GÇ¥ McKibbin said. "The lowest is 85 percent lower, at 1,500 CFS. Should we expect a 50 to 85 percent variant on your numbers in the future?GÇ¥
McKibbin was dismayed that the PUD would include the 10,000 CFS assertion in their official report without researching its authenticity, he said, telling Gangemi it seemed as though the report was advocating that people run the falls at that level.
"That's what it says to me when I look at it,GÇ¥ McKibbin said. "You're almost encouraging people to run those falls, which as you probably know, is one of the most dangerous drops to run and that's why it doesn't get run very often.GÇ¥
Gangemi conceded.
"Based on your comments, we'll update as we move forward with the final license application and update that data point and say we've been corrected,GÇ¥ Gangemi said. "So, thank you very much.GÇ¥
Recreation
ERM also prepared the recreation addendum, which analyzed potential recreation enhancement opportunities north and south of Sunset Falls, on trails between Canyon and Sunset Falls and at Canyon Falls.
In the initial study, it was determined that because the area surrounding Sunset and Canyon Falls is largely private property or state-owned land, the project would not impact existing recreation opportunities. FERC requested additional information, including deeper analysis of lands that could potentially be available for recreational enhancement and cost projections.
The addendum concluded that each of the four alternatives offered limited viability due to constraints associated with private property, state-owned property access restrictions, inadequate parking and safety concerns.
Susan Rosebrough of the National Park Service said she appreciated the additional study, but felt it lacked in-depth analysis of the issues. She questioned why recreation was noted as incompatible with the Washington State Department of Fish and Wildlife (WDFW) trap-and-haul facility, since public access had been allowed there in the past.
The WDFW formerly allowed the public to view the falls from that vantage point, but discontinued the practice.
"My understanding of that issue was there was a vehicle basically blocking the fish truck,GÇ¥ Rosebrough said. "There's ways that design can help with addressing some of those issues. I'm not really understanding why it isn't compatible.GÇ¥
She added that access criteria could be set, such as prohibiting vehicles and allowing only pedestrian traffic.
"We didn't get into the history of why it had closed,GÇ¥ Gangemi said. "The issues today are security, vandalism, public safety and liability, and those are applicable whether you're in a vehicle or whether you're on foot.GÇ¥
Downstream fish passage
Downstream fish passage has been a sticking point for project opponents, who were bothered by PUD's assertion in December that "lower flows through the Canyon to Sunset Falls reaches would result in less potential injury than the higher flows.GÇ¥
But the addendum drew the same conclusion.
Sunset Falls creates a natural barrier for fish. In order to mitigate this, the WDFW trap-and-haul facility transfers migrating salmon upstream above Sunset, Canyon and Eagle Falls, where spawning takes place. Salmon fry and adult steelhead then come back down the falls on their way out to sea. Opponents have long asserted that less water in the bypass area would negatively impact salmon fry and adult steelhead as they navigate the rocky falls on their way out to the ocean.
Ed Zapel, hydraulic design lead for HDR Engineering Inc., presented the addendum that featured data gathered primarily through computational fluid dynamics (CFD) modeling.-á
CFD modeling uses mathematics to create a computer simulation depicting hydraulic conditions throughout a specific water column. To create the model, engineers surveyed Canyon and Sunset Falls using laser-scanning equipment and hand probes to collect data on topography and bathymetry ' the study of underwater depth. They created three-dimensional models of both falls, and then incorporated neutrally buoyant particles into the models to represent migrating fish.
Several sizes of fish were depicted, including 40, 150, 400 and 750 millimeter. The 750 mm inclusion was important to tribal representatives, who faulted the initial study for not including adult steelhead.
Different river flows were then simulated in the models.-á -á -á
"The intent was to document the frequency and degree of direct physical injury or trauma incurred by these downstream migrating fish as they pass Canyon Falls and Sunset Falls under the conditions created by the project operations,GÇ¥ Zapel said.
They conducted review of parameters critical to fish injury, including velocity, turbulence, shear and pressure, establishing a threshold of conditions conducive to fish injury and mortality. Flows of 250, 500, 1,500, 2,500 and 5,000 CFS were examined. The results indicated that in both Sunset and Canyon Falls, the injurious threshold values were exceeded more frequently at higher flows than lower flows.-á -á
"This indicates that lower flows develop fewer areas of potential injury,GÇ¥ the report states.
Kayaker Jon Prentice marveled over the sheer volume of data and questioned the conclusions, which sometimes seemed contrary to common sense, he said.
"I'm very, very skeptical about this entire study,GÇ¥ Prentice said. "Yes, I'm just a layperson, but it seems like the study seeks to sort of obscure the truth more than it does to illuminate it.GÇ¥
To learn more about the project and review the study addendums, visit www.snopud.com/PowerSupply/hydro/sfpep.ashx?p=1956.
Photo by Chris Hendrickson The Sunset Falls Fish Passage and Energy project would re-route water from the south fork of the Skykomish River here, a short ways west of Canyon Falls.
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