Over the objections of the paddling community and several other stakeholders, the Federal Energy
Regulatory Commission (FERC) issued a preliminary permit last fall for the Black Canyon
Hydroelectric Project. If constructed, this project would construct a new dam on the North Fork
Snoqualmie diverting the river around Ernies Gorge to a powerhouse at the bottom of the canyon.
The developer is moving ahead with their plans and earlier this spring filed a Notice of Intent
to seek a license for the construction and operation of the project. The Federal Energy
Regulatory Commission (FERC) has announced the start of the formal process to evaluate this
proposal and has begun scoping to identify issues they will need to analyze to determine if
constructing this project is in the public interest. As the first step in that process, FERC will
be holding a set of public meetings this month to solicit community input on the project. A
public comment period is now open with comments due by July 24, 2pm (PDT).
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
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 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.
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
1) For those who wish to file comprehensive comments or request studies you can register on the
FERC website for eFiling
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.