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Sultan River: Public Comments Regarding Boating

Posted: 04/04/2006
by Thomas O'Keefe

Over the last month the public has had an opportunity to comment on the issues of importance as Snohomish PUD and City of Everett initiate planning for studies that are required as part of relicensing of the Jackson Hydroelectric Project on the Sultan River. We want to thank all those who participated in public meetings and filed written comments. Major issues of interest that appeared in the majority of comments including those filed by American Whitewater included fishery and aquatic resources, aquatic and riparian habitat, terrestrial lands management, and river-based recreation. Resource agencies representing the public interest have noticed the whitewater interest in this project and FERC formally recommended that a controlled whitewater flow study be conducted. Specifically FERC Staff stated the following in a letter (read the full letter with FERC Staff Comments) to the co-licensees:

Project operations affect flows in an 11-mile-long reach of the Sultan River that could be used for whitewater boating if sufficient flows were available. After reviewing the information presented in the PAD and the comments provided during the February 27 and 28 scoping meetings, we have identified a gap between existing information and the information needed to conduct the required analysis. We need to know the range of flows that would provide whitewater boating opportunities in the project bypassed reach of the Sultan River. Please note that we can further discuss the extent of the information gap and the relative scope of this study at the study plan meetings after review of all available information.

The National Park Service weighed in and formally requested a Recreation Needs Analysis Evaluating Recreation Access and Trail Needs and and Integrated Analaysis of Recreational Flows and River Access. See full National Park Service Comments.

The US Forest Service commented (read full US Forest Service Comments) on river recreation stating:

The Informal Single Flow Whitewater Boating Opportunity Survey Summary Report, based on a release in December, 2005 and recent public comments at the Scoping Meetings of February, 2006, demonstrate that the bypass reach can provide acceptable whitewater kayaking and rafting opportunities, and that there is a lot of public interest in providing this opportunity. Therefore, we believe a higher level of study such as a Controlled Flow Whitewater Boating Study is warranted... We encourage you to work with American Whitewater in crafting a workable study that provides the desired information.

Washington Department of Ecology (read full DOE Comments) made the following comments on river recreation stating:

American Whitewater intends to submit a study request of instream flow needs for recreation. The Department of Ecology supports this request, and believes that the information produced from this study request will be applicable to other users with the inclusion of a flow comparison survey of river users... State and federal law, including statutes administered by the Department of Ecology, mandates protection of river-dependent recreation. The information will be required for Ecology's review of request for water quality certification pursuant to Section 401 of the federal Clean Water Act, and will provide information necessary to develop conditions suitable for water quality certification.

As part of the Jackson Project relicensing on the Sultan River, American Whitewater has a direct interest in river and riparian conservation and resource protection, appropriate public access to the river that protects resource values, and instream flows for the benefit of fishery resources, river and riparian condition, and recreation. You can read the complete version of American Whitewater's Comment Letter, but the higlights of specific issues we outlined are below.

  • The current proposal to continue current operations would justify a 30 year license and not a 50 year license as requested.
  • Current recreation needs should be examined for the development of a revised recreation plan.
  • Forest management for early successional species should be reevaluated.
  • Dam gate operations need to be described in more detail.
  • Instream flow needs must be studied and specifically the current practice of releasing 20 cfs into the bypass reach.
  • Fish habitat and fish passage should be studied at the City of Everett's Diversion Dam.
  • Off-channel habitat connectivity needs to be reviewed.
  • Gate hours and current access restrictions need to reviewed and a recreational needs analysis needs to be completed that addresses trail improvements necessary to access the Sultan River.
  • A controlled flow study needs to be conducted to provide quantitative information on flow needs for river-based recreation.
  • Effectiveness of current procedures to communicate project operations must be reviewed.

Please note that American Whitewater has not established positions and at this point we are just making sure that the right studies are done to collect information for informed decision making. A big thanks to the more than 50 individuals who have contacted us about this project and offered specific input. We hope we have captured the issues you have raised and if you have additional thoughts please contact Tom O'Keefe or Andy Bridge. We will continue to work on this project and will take part in a formal study plan meeting scheduled for June 8th. Andy Bridge and the folks at Werner Paddles deserve a big thanks for their investment and support of this project.

The links below include the transcripts for the public meetings along with additional comments identifying specific issues that need to be considered:

Evening Public Meeting Transcript

Daytime Public Meeting Transcript

Washington Kayak Club Comments

Washington Recreational River Runners Comments

Snoqualmie Tribe Comments

Tulalip Tribe Comments

North Cascades Conservation Council Comments

Snohomish PUD Comments

Snohomish County Fire District Comments

WA DNR Comments

Washington State Department of Fish and Wildlife Comments

US Fish and Wildlife Service Comments

US National Marine Fisheries Service Comments

Washington Prospectors, Department of Ecology, and Washington State Interagency Commission for Outdoor Recreation Comments

The following indivduals also submitted comments describing their experiences paddling the Upper Sultan: Eric Bessette, Andy Bridge, Jeff Bowman, Stephen Cameron, David Chatham, James Contos, Jennie Goldberg, Christopher Lambiotte, Hillary Neevel, Will Robens, Nick Silverman, Devin Smith, and David Wilson.


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

Associated Projects

Sultan River (WA)
AW is working to improve flows and public access for the benefit of fish, wildlife, and paddlers as part of hydropower relicensing on this river.