New Snoqualmie Falls (WA) license issued
The Powerhouse run on the Snoqualmie River is one of the most treasured assets for whitewater paddlers in Western Washington, convenient to a population of over 2 million people. The river is less than an hour drive from downtown Seattle, making it a popular after work destination. The whitewater is class II and only a mile in length making it the region's best beginner training site, and one where you can easily jog the shuttle. Although the run is short, there are several excellent features for instruction making it possible to spend hours on the water; whenever you've had enough for the day, it is always a short paddle back to the car from anywhere on the run. In short it is an ideal teaching site, with several kayak schools, clubs, and a number of local businesses that depend on whitewater recreation and the resources this particular river provides.
The runs starts at the base of Snoqualmie Falls, a dramatic and awe inspiring 268 foot waterfall, and the second most popular natural attraction in Washington State after Mount Rainier. Well over a million visitors come to the site each year. The power from the falls has been harnessed for hydroelectricity since 1898. Flows that bypass the falls are run through one of two powerhouses operated by Puget Sound Energy (PSE): Powerplant 1 is located in the bedrock near the base of the falls and Powerplant 2 is located a short distance downstream just around the corner from the falls. The project has the ability to divert 2500 cfs and on an annual basis approximately 65% of the river's natural flow is diverted. In all but the driest summer months however there is generally enough water for paddlers both upstream of Powerplant 2 in the bypass reach and downstream below the tailrace.
The best rapid on the river is located on the upstream side of Powerplant 2 and it is here that most paddlers begin their run. The rapid provides a natural classroom with a generous eddy where beginners can enter the water, and then begin to practice on a couple of strong jets where many of the region's paddlers learn the basics of peel outs and eddy turns. To challenge the eager learners, this site also includes the best surf wave on the run, a modest wave but still a fun feature. A new license recently issued by FERC would block access to this popular site and redirect paddlers to the downstream side of the powerhouse.
Background and History
On November 25, 1991, Puget Sound Power & Light Company (later changed to PSE) filed an application pursuant to sections 4(e) and 15 of the Federal Power Act (FPA) for a new license authorizing the continued operation and maintenance of the 44.4-megawatt (MW) Snoqualmie Falls Hydroelectric Project No. 2493 (Snoqualmie Project), located on the Snoqualmie River, in the City of Snoqualmie, King County, Washington. The original license for the Snoqualmie Project was issued on May 13, 1975, effective as of March 1, 1956. That license expired on December 31, 1993.
As the long relicensing process began, whitewater paddlers raised concerns regarding the future of river access at the project. Several different scenarios were explored by the utility including a major expansion of the project. At the same time the Snoqualmie Tribe expressed a strong desire to retire the project, noting their strong spiritual ties to the river and a desire that the full flow of the river be allowed to flow over the falls.
Brooke Drury, at the time the Hydropower Coordinator for Rivers Council of Washington and subsequent to that an American Whitewater board member, filed comments on behalf of whitewater recreation (read her comments). Rich Bowers, American Whitewater's Conservation Director at the time, also participated in a site visit and public meeting prior to the publication of the Final EIS. Additionally, many members of affiliate clubs including the Washington Kayak Club, Paddle Trails Canoe Club, University Kayak Club, and The Mountaineers attended public meetings and filed comments. Primary concerns were protecting public access to the river and maintenance of flows in the bypass channel between the falls and Powerplant 2.
In her comments filed in January 1995, Brooke noted, "Under current circumstances, the put-in for the Powerhouse Run (just below and just above Plant 2) is adequate. This may not remain the case once new construction starts on the project as proposed by Puget (and as recommended in the DEIS)." Given this concern over the future of river access, FERC responded in the Final EIS (published in September 1996) that the preferred alternative was "not expected to significantly restrict boater access to the river".
Given this understanding that access to the river would not be significantly reduced or altered, the whitewater community waited as several years passed while PSE continued to work towards obtaining a license for the project.
With a license decision still pending in 2002, FERC's safety office in Portland ordered PSE to reconstruct their boardwalk upstream of Powerplant 2 to create a barrier to river access all along the river on the upstream side of the powerhouse. This action, running counter to the decision to preserve access as published in the Final EIS, was taken with no public or agency consultation despite the fact that the FEIS states: "WDNR owns the riverbed up to the natural high-water mark, therefore, much of the shoreline is located on public lands that are available for public use". Paddlers were unaware of the implications of this order by FERC until after construction activity was already underway in 2003.
As construction activity around the powerhouse began to ramp up as part of maintenance activities and in apparent anticipation of a new license, paddlers began to express concerns regarding the future of river access and whether a new license would incorporate the important public river access as described in the FEIS. PSE invited paddlers to the river on March 20th, 2004 and completed a site visit with representatives from American Whitewater, Washington Kayak Club, PaddleTrails Canoe Club, The Mountaineers, and University Kayak Club. Discussions with PSE were positive and representatives from the company expressed a strong willingness to work with the whitewater community in continuing to provide public access through construction of a new road and replacement of a runner in one of the turbines. The work, expected to last through early fall 2004, has limited access at certain times, but PSE made a strong commitment to minimize disruptions to access and keep the boating community informed. At the same time they noted that any decisions related to the details of river access and safety issues were in the hands of FERC. PSE followed up with a second meeting and discussion of the project with representatives from local clubs that was hosted by The Mountaineers on March 24th.
On April 1st, American Whitewater filed a comment on the directives issued by the FERC safety office in Portland that ordered reconstruction of the boardwalk and created barriers to access that conflict with the terms and conditions originally outlined in the Final EIS (read comment). While the comment was entered in the public record, the whitewater community no longer had formal standing in the proceeding, since the Rivers Council of Washington no longer exists as an organization; in January 2004, they formally withdrew from the proceedings. On May 26th, American Whitewater filed a motion of late intervention (read filing). The basis for our intervention was that whitewater recreation interests had been previously represented in the proceeding by Rivers Council of Washington and on June 25th, American Whitewater's request for intervenor status was granted (read FERC's notice).
On June 29th, 2004, FERC issued an order issuing a new 40 years license for the Snoqualmie Falls project (read new license). Unfortunately conditions in the new license are less than favorable to whitewater boaters. Instead of protecting the access that was recognized in the FEIS and utilized by whitewater paddlers for many years, the new license formally closes access upstream of the powerhouse. Specifically the license states the following:
American Whitewater notes that kayakers and pedestrians have used a 20-foot gap in two sections of boardwalk as an informal access point to reach the bypassed reach just upstream of Powerhouse 2, but that in 2002 the Commission's Regional Office directed that the gap be spanned with a section of boardwalk, high railings, and chain-link fencing, preventing further such use. American Whitewater argues that recreational concerns mandate either that an environmental review precede this change or that the informal access be restored. The informal access at the location upstream of Powerhouse 2 was eliminated as a safety measure. Moreover, such access would be disruptive to Snoqualmie religious practices. However, the new license requires construction of an access point immediately downstream of Powerhouse 2, which will improve boating opportunities in the area without endangering safety or intruding upon Snoqualmie religious practices.
Unfortunately, FERC never discusses how this determination based on safety was made. There is also no evidence in the public record that this access disrupts Snoqualmie religious practices, and follow up conversations with the tribe confirm that this is a misrepresentation of the tribe's position (their issue is restoration of flows to the river and providing access for "all people, for all time"). Further, eliminating a key access site and constructing an alternative access on the downstream side of the powerhouse does not "improve" boating opportunities. In fact an access is already available at this location and utilized when flows above the powerhouse in the bypass reach are too low. Boating opportunities would not be improved but instead will be lost.
On July 28th, American Whitewater filed a request for rehearing on the issue of access upstream of the Powerhouse (read filing).
There may be additional opportunity to comment on these issues through the Recreation Resource Management Plan (Article 417 in the new license). Within one year and after consultation with the Washington Department of Fish and Wildlife, National Park Service, City of Snoqualmie, Snoqualmie Tribe, and King County, PSE must file a recreation plan with FERC. The plan will include a naturally-landscaped carry-in boat access in the Powerplant 2 area, a restroom, and an improved parking area. The licensee will allow a minimum of 30 days for the agencies to comment before filing the plan with the Commission. Upon FERC approval, PSE will implement the plan, including any changes required by FERC.