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ACTION ALERT: Opportunity to Comment on Proposed Sunset Falls Hydro Project (WA)

Posted: 10/28/2011
by Thomas O'Keefe

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. 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 for designation as a Wild and Scenic River for its Scenic, Recreation, Fish, and Wildlife values by the Forest Service.

The proposed project will consist of the construction of the following:
(1) a 140- foot-wide, 45-foot-high v-screen intake;
(2) a 2,000-foot-long, 19-foot-diameter unlined rock penstock;
(3) a semi-underground powerhouse with twin 15-megawatt turbines;
(4) an 8.5-mile long, 115-kilovolt three-phase overhead transmission line extending from the powerhouse to an existing substation.
The estimated annual generation of the Sunset Falls Hydroelectric Project would be 120 gigawatt-hours.

The sole purpose of a preliminary permit, if issued, is to grant the permit holder priority to file a license application during the permit term. A preliminary permit does not authorize the permit holder to perform any land-disturbing activities but does allow the applicant to undertake a more comprehensive review of the site for a period of 3 years prior to submitting a formal license application. On October 21, 2011 FERC issued a notice opening a 60 day comment period on the application for the preliminary permit. Comments are due December 20, 2011.

American Whitewater will be filing a motion to intervene in this project. Individuals and other organizations can also provide comment or intervene. We anticipate that FERC will issue the preliminary permit in the spring of 2012 and conclude that concerns raised could be addressed with the filing of a license application (typically 3 years from the date of preliminary permit issuance). Comments that identify impacts of the proposed project are important to raise at this stage as they are critical to building the public record. FERC will likely state however that concerns related to resource impacts and construction of the project are premature at the preliminary permit stage because they address the potential effects of constructing and operating the proposed project which will be evaluated following the filing of a license application.

There are three options available to file comments:
1) For those who wish to file comprehensive comments or a motion to intervene you can register on the FERC website for eFiling. Registering allows you to sign up for the docket (in this case P-14295-000) and you will be notified of all filings and future opportunities to comment on the project. We recommend this option for those who want to carefully track the development of this project.
2) For those who do not wish to register but who would like to file a comment of less than 6,000 characters you can use the eComment system. You will want to file your comment with docket P-14295-000. You must still include your name and contact information at the end of your comments.
3) For those who wish to mail a hard copy of comments you can mail your comments to Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426. Be sure to reference the docket number (for this project it is P-14295-000) in your introductory paragraph so that your comment is filed correctly.

Additional Information

For those who wish to review additional information on the project, the following documents can be accessed from the FERC website:
Preliminary Permit Application, filed September 28, 2011
FERC Notice Soliciting Comments and Motions to Intervene, issued October 21, 2011

Thomas O'Keefe
3537 NE 87th St.
Seattle, WA 98115
Phone: 425-417-9012


Associated Projects

Sunset Falls Hydropower Development
Sunset Falls on the Skykomish River has been proposed for hydropower development.

Associated Rivers

Skykomish, S. Fork WA
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