If you have already commented on this project it is important that you weigh in again. Last year's opportunity for comment was based on the decision of whether to issue a preliminary permit to investigate the site. American Whitewater and others attempted to make the argument that the permit should not be issued because the river has been identified for its conservation value (read our complete commments). The river section proposed for development has been found eligible and recommended for designation as a Wild and Scenic River by the United States Forest Service, and is identified as a protected area from hydropower development by the Northwest Power and Conservation Council. The river forms the border for the Department of Natural Resources Mt. Si Natural Resources Conservation Area that includes some of the best remaining intact old-growth riparian forest at low elevation in the western Cascades. Finally, the lands along the river are protected by a conservation easement held by King County that specifically prohibits hydropower projects of the scale proposed. Despite these concerns, FERC concluded that these issues could all be evaluated once a formal application was filed.

 

FERC concluded that the concerns raised in the comments were premature at the preliminary permit stage because they address the potential effects of constructing and operating the proposed project. FERC further noted that the permittee would need to address these issue when filing a license application, and that would be the appropriate forum to address the issues. That opportunity is now upon us with a new comment period now open and public meetings scheduled. You can attend either the daytime or evening scoping meeting to raise issues and concerns. The virtual site review will provide an opportunity to get a more in-depth overview of the project.

 

Daytime Scoping Meeting

Date and Time: Tuesday, June 19, 2012, 11:00 a.m.

 

Virtual Site Review

Date and Time: Tuesday, June 19, 2012, 2:00 p.m.

 

Evening Scoping Meeting

Date and Time: Tuesday, June 19, 2012, 6:00 p.m.

 

Location for all meetings:

Cedar River Watershed Education Center Auditorium,

19901 Cedar Falls Road SE, North Bend, WA  98045

 

While the developer has assured us that he would mitigate for whitewater recreation the details are extremely vague and proposed studies appear inadequate. Furthermore, we believe this river should remain in its natural free-flowing condition and industrial development of this canyon is not in the public interest. For additional background there are a few documents that may be helpful to review.

 

The first two documents are the Pre Application Document and the Notice of Intent Developed by the developer.

 

Pre Application Document, filed March 26, 2012

Notice of Intent to File for Original License, filed March 27, 2012

 

The next document is produced by FERC and outlines the issues they believe need to be evaluated through studies and analysis. It appears that whitewater recreation is not adequately considered in this document. Under studies, a very general reference to a Recreation and General Land Use study is noted that is characterized as follows: "Recreation monitoring and evaluation to determine the amount and types of recreational use in the project area." FERC notes however that "further studies may need to be added to this list based on comments provided to the Commission and Black Canyon from interested participants" and we encourage paddlers to attend the meetings to make sure FERC staff and the applicant understand the value of this reach for whitewater recreation.

 

Letter Inviting Parties to Participate in the Black Canyon Hydroelectric Project, issued May 25, 2012

 

American Whitewater will be filing detailed comments and study requests for this project. Individuals and other organizations can also provide comment and raise issues. There are three options available:

 

1) For those who wish to file comprehensive comments or request studies you can register on the FERC website for eFiling. Registering allows you to sign up for the docket (in this case P-14110) 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-14110. 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-14110) in your introductory paragraph so that your comment is filed correctly.