On April 15th, AW volunteer Charlie Vincent filed comments to the Federal Energy Regulatory Commission formally objecting to a proposed dam on southern Idaho's Bear River.  The Onieda Narrows would be flooded if the new dam were constructed, devastating the ecological and recreational values of this last flowing reach of the Bear River in Idaho.  The dam would also interfere with a settlment agreement that AW is part of on an upstream dam owned by a different utility.   Recreational releases on the Bear River's spectacular Black Canyon are scheduled to begin next year, based on this settlement.

AW is joined by a host of other agencies and groups, including Idaho Rivers United, in fighting this dam. Our comments on a key document proposing the dam are below:

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Re: Bear River Narrows Hydroelectric Project No. 12486-001.

COMMENTS ON PRELIMINARY PERMIT AND PRE-APPLICATION DOCUMENT AND RECOMMENDED STUDIES

Dear Ms. Posey:

American Whitewater (AW) hereby reiterates our opposition to the issuance of the preliminary permit, provides comments on the pre-application document, and study requests for the proposed Bear River Narrows Hydroelectric Project No. 12486-001.

 

Of particular concern to AW is the fact that issues identified in several earlier letters from the Bear River Project Environmental Coordination Committee (ECC; AW is a member) regarding this project have yet to be addressed.  We understand that the purpose of issuing the Preliminary Permit is to allow clarifications of license issues and plans, but the project proponent has not proactively engaged in this sort of dialogue with AW as a committed stakeholder. As a result, AWs concerns regarding the continuation of this license process are further magnified. Therefore, we request that the FERC ensure these original issues, including interference with the existing Bear River project license (FERC No. 20), are addressed prior to any further progression of the current project proposal.

 

Statement of Interest

 

Founded in 1954, American Whitewater is a national organization with a mission “to conserve and restore America’s whitewater resources and to enhance opportunities to enjoy them safely.” American Whitewater is a membership organization representing a broad diversity of individual whitewater enthusiasts, river conservationists, and more than 100 local paddling club affiliates across America. The organization is the primary advocate for the preservation and protection of whitewater resources throughout the United States, and connects the interests of human-powered recreational river users with ecological and science-based data to achieve the goals within its mission.

 

AW is a signatory to the 2002 Bear River Settlement (FERC # 20, 2401, & 472) and is a member of the Bear Environmental Coordination Committee (ECC).

 

 

Enclosed please find our specific comments on the Pre-Application Document, as well as our additional study requests.

 

Contact information on this project is:

 

Charles L. Vincent, PE

Regional Representative

American Whitewater

1800 E 3990 So

Salt Lake City, UT 84124

charliev@xmission.com

801-243-4892

 

Thomas O'Keefe, PhD

Pacific Northwest Stewardship Director

American Whitewater

3537 NE 87th St.

Seattle, WA 98115

okeefe@amwhitewater.org

425-417-9012

http://www.americanwhitewater.org

 

 

Sincerely,

 

Charles L. Vincent, PE

American Whitewater

Regional Representative

 

CC via email Mary Lucachick, Warren Colyer, Marv Hoyt, Kevin Lewis, Thomas O’Keefe, Kevin Colburn, Jeff Seamons, Mark Stenberg

American Whitewater’s comments on the Pre-Application Document and Scoping Meeting, Bear River Narrows Hydroelectric Project (FERC Project No. 12486-001)

 

AW has the following comments on the information presented in the PAD and in the March 2007 scoping meetings:

 

1)      AW is a signatory to the Bear River Hydroelectric Project Settlement Agreement (SA) and license. We are gravely concerned that the proposed project will result in disruption in the proposed improvements to native Bonneville Cutthroat trout, other aquatic species, and their habitat resulting from implementation of the SA under the existing new PacifiCorp licenses. For example, the PAD fails to include discussion on several relevant plans including, the Northwest Power Plan, the Bear River Compact, the Range-wide Bonneville Cutthroat Trout Conservation Agreement and Strategy, the 1995 Bear Lake Settlement, the IDFG Fisheries Management Plan, and, last but not least, the 2002 PacifiCorp Settlement Agreement. The PAD should fully discuss possible project conflicts with these plans. More specifically, this proposed project will require “Substantial Alteration” to the existing PacifiCorp FERC license No. 20 located upstream of this proposed project. Articles #2, 3, 4, 5, 7, 8, 9, 11 and 13 of the Bear River Settlement Agreement and associated license would likely be affected by this proposed project along with a modification to the project boundary.  The costs resulting from this alteration, as well as those necessary for mitigation, should be explored.

 

2)      The Oneida Narrows site on the Bear River is of special ecological, social, and recreational value since it is one of the last remaining undeveloped free-flowing stretches of the Bear River. The Bear River is a heavily developed stream with irrigation diversions and hydropower developments all along the river. This section of the Bear River, including the proposed Oneida Narrows dam site, provides great beginning and intermediate whitewater boating as well as canoeing and tubing opportunities. Non-motorized boating opportunities in a scenic canyon such as the Oneida Narrows exist nowhere else on the Bear River, or in this area of the state. The recreational use data provide in the PAD is from 1982 – 1985. Population growth, changing recreational interests, and changing demographics make the application of 25 year-old data sets inappropriate. Further, the 1990 whitewater boating assessment is inconsistent with our current knowledge and use of this reach.

 

3)      Construction of a hydropower project on this section of the Bear River would interfere with the environmental, social, and recreational values discussed previously and it would not be possible to mitigate for such impacts. For example, no mitigation has or could be proposed for the flooding of the this recreational section of the Bear River Oneida reach, the only section of the river in the entire state of Idaho with public access along the river (on BLM and PacifiCorp lands). The Bear River is already in significantly degraded condition due in large part to existing hydropower development and construction of the TLCC hydropower project would preclude the possibility of adequately mitigating for current impacts on the river, much less future impacts from the proposed project. The proposed project would also eliminate fly fishing and whitewater boating opportunities in the area that could not be replaced.