Sunset Falls Project on SF Skykomish Cancelled (WA)
Posted: 04/13/2018
By: Thomas O’Keefe
Earlier this week the Snohomish County PUD Board of Commissioners directed their staff to cease
the effort to pursue a final federal license for the Sunset Falls hydropower project on
Washington’s South Fork Skykomish River. (View the filing with the Federal Energy
Regulatory Commission here.) In a
recent news
release, the utility announced that it will continue to emphasize cost-effective conservation
and renewable energy resources. (Listen to the announcement at the April 10th BOC
meeting here,
with relevant discussion starting at 1:08:30; Everett Herald Op-Ed "How a
Lightbulb Saved Sunset Falls")
For the past decade, American Whitewater has been directly engaged in the dialogue about the
Sunset Falls Project, which was proposed on a river segment with multiple state and federal
protections. The South Fork Skykomish is a State Scenic Waterway, the Forest Service has
recommended it for Wild and Scenic designation, the reach is protected from hydropower
development by the Northwest Power and Conservation Council, and instream flows are protected by
the State of Washington. Despite these protections and overwhelming public opposition, Snohomish
County PUD decided to move forward with a project proposal. American Whitewater agreed to accept
the possibility of a project and was the only non-governmental organization to join settlement
discussions convened by Snohomish PUD with agencies and tribes over the past two years.
"While we appreciate the efforts of staff at Snohomish County PUD who took our concerns
seriously and worked in good faith to address them, we support the decision by the Board of
Commissioners to move on from this project," stated Thomas O'Keefe of American
Whitewater. "Sunset Falls will continue to roar with life over the massive granite slab and
we hope to someday restore access to this inspirational and powerful site."
Background and History
American Whitewater has been engaged in discussions over this project for the past decade. In
2008, Snohomish County PUD developed a list of 140 sites for new hydropower development in a
four-county region and identified 40 small hydroelectric projects located either in or near the
utility's service territory that could be developed, constructed and operated by the utility
to meet its growing customer demand. The list was further narrowed to approximately a dozen sites
and American Whitewater was invited to provide input on these sites along with partners in the
conservation community that included American Rivers, Conservation Northwest, North Cascades
Conservation Council, and Sierra Club. In our 2009 joint comments, we expressed specific concerns
with the Sunset Falls site noting that it was on the only State Scenic Waterway in Western
Washington. We wrote that "dewatering this scenic and popular falls just above the
confluence of the South and North Forks of the Skykomish River would be a tragedy." In
addition to the issues of aesthetic impacts on the falls, we expressed concerns with impacts to
salmon and bull trout.
Snohomish County PUD proceeded forward with the project and filed for a Preliminary Permit to
develop the site. In December 2011, American Whitewater took the lead in drafting comments in
opposition and we were joined by Alpine Lakes Protection Society, American Rivers, North Cascades
Conservation Council, Sierra Club – Washington State Chapter, The Mountaineers, and
Washington Wild (view
comments).
The permit was granted and Snohomish County PUD next proceeded with filing of a Notice of Intent
to develop a project and this kicked the public dialogue into high gear. In June 2013, American
Whitewater attended the public scoping meeting in Index, Washington and as the first speaker
invited to the microphone Stewardship Director Thomas O'Keefe stated, "I have tremendous
respect for my colleagues here at the PUD; we have worked with these folks for over decade, but
sometimes your friends make mistakes, and this project is simply inappropriate." As the
evening continued, additional concerns were raised by local residents who expressed an interest
in a future for the community based on resource conservation (meeting
transcriprt).
We followed the meeting with formal written comments (view
comments) and were joined by Alpine Lakes Protection Society, American Rivers, Conservation
Northwest, North Cascades Conservation Council, Sierra Club – Washington State Chapter, The
Mountaineers, Washington Wild, and Wild Washington Rivers. In our comments we noted that the
river was a State Scenic Waterway, recommended for Wild and Scenic designation by the Forest
Service, and in an area protected from hydropower development by the Northwest Power and
Conservation Council. With the support of the Hydropower Reform Coalition we also conducted a
formal economic analysis of the project concluding that it would not be price competitive
relative to other renewable energy sources and would not provide ancillary services to complement
other renewable energy sources.
American Whitewater actively engaged in an extensive study process to further evaluate the site
over a two year period and in April 2016 we filed comments on the Draft License application. We
were joined by Alpine Lakes Protection Society, American Rivers, Center for Environmental Law
& Policy, Conservation Northwest, North Cascades Conservation Council, Sierra Club –
Washington State Chapter, The Mountaineers, Washington Wild, Wild Steelhead Coalition, and Wild
Washington Rivers (view
comments). We reiterated past concerns we had with the project and the development of
hydropower on a currently free-flowing river, and also noted the existence of a state instream
flow rule that would prevent diverting water from the river at levels necessary to support a
hydropower project. The Tulalip Tribe expressed deep concerns with impacts to salmon writing that
"the project creates a new source of mortality which impairs the Tribe’s ability to
achieve salmon recovery and maintain resources of cultural importance. The Tulalip Tribes
strongly recommend that the Federal Energy Regulatory Commission deny this application."
(view
Tulalip Tribe comments)
Following the deep concerns with the project as proposed in the Draft License Application,
American Whitewater joined settlement discussions convened by Snohomish PUD that included
resource agencies and tribes. Snohomish PUD felt they could still refine their proposal in a way
that would meet stakeholder concerns. We agreed to accept the possibility that the project would
be constructed to join the dialogue over how the project would be constructed. Snohomish County
PUD committed to work with the group and proceed with a Final License Application if a settlement
agreement could be reached.
Through the settlement process, we were strong advocates for aesthetics and recreation as well as
fishery resources that were a primary concern for the Tulalip and Snoqualmie Tribes and resource
agencies. We were also concerned with any new precedent that would be created to allow a project
in a Northwest Power and Conservation Council Protected Area or modifications to the instream
flow rule that would have been required to divert the water necessary for the project. This
week's decision by the Board of Commissioners ends the process to seek an agreement that
would form the basis of a Final License Application. While we committed to the settlement process
in good faith, we are pleased with the decision to emphasize cost-effective conservation and
alternative renewable energy resources as alternatives to the development of a hydropower project
at Sunset Falls.
Thomas O'Keefe
3537 NE 87th St.
Seattle, WA 98115
E-mail: okeefe@americanwhitewater.org
Phone: 425-417-9012
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