Discussion in 'Fly Fishing Forum' started by Citori, Feb 9, 2014.
The fisheries impacts are only real if FERC doesn't require adequate instream flow for downstream fish passage, proper intake screens, and proper tailrace design such that adult fish don't readily find the fish ladder entrance. And none of those things will happen because the fisheries agencies will include mandatory terms and conditions in the project license that FERC will impose on the PUD.
It seems to me that the biggest problem this prospective project has is the NIMBY syndrome, which is really active.
I'm glad you're so certain Salmo G; wish I could be. Unfortunately when the "fisheries agencies" (WDFW, Tribes) are requesting studies, or additional study components, including downstream fish passage studies, and SnoPUD doesn't want to perform them, and FERC doesn't require them to--well, then I get a little concerned. Such is the case. Some concern is warranted.
What does anybody know about the Mini dam at Young's creek. This is the first I've heard of it.
SnoPUD applied years ago for a permit to build a small hydro project on Young's Creek - tributary to Ewell Creek, tributary to Skykomish R. They finished it about 3 years ago now I think. It's been running ever since. It's located upstream of the limit of anadromous fish use. There is a small population of resident trout. The license includes a minimum instream flow requirement sufficient to maintain the trout population, and the powerhouse has a flow bypass valve to satisfy downstream fish protection requirements.
Some parties are doing what is called "piling on" the list of study requests. I don't know why they do that, but some appear to feel like the more you study, the better. The law however, requires a study "nexus", that is, the proposed studies need to be reasonably related to the potential impacts the project might have.
An instream flow study is part of the package. It might not take a specific downstream fish passage study to figure out how to pass fish downstream. It's impossible to do an empirical test when you don't have the ability to dewater the river, i.e., reduce flows until fish can no longer safely migrate downstream over the falls. The agencies will recommend higher than necessary passage flows to err on the side of the fish. That shouldn't be an issue for the PUD because downstream migration occurs during spring runoff when flows exceed the proposed amount of water to be diverted into the power tunnel.
SnoPUD has already agreed to install a NMFS criteria fish screen to prevent juvenile fish from being entrained into the penstock.
It's OK to be distrusting. When the final license application is made, there is a public comment period for terms and conditions. You can recommend instream flow, downstream ramping rates, passage flow over the falls, and a fish screen. If the agencies should forget to do so, FERC will adopt some version of your recommendations. It's not like they are unaware of the resource protection responsibilities.