The issue is the devel­op­ment of Sun­set Falls. Sun­set Falls resides in a diverse com­mu­nity about 300 yards south of the Wild Sky National Wilder­ness area. Project Overview.

The ques­tion is the cost and ben­e­fit of this project. The process is gov­erned by FERC. The peti­tioner is Sno­homish County PUD. The major oppo­si­tion group is www​.savetheskyriver​.org

Why Dam?
Finan­cial con­sid­er­a­tions are summed up in I-​937.
A video primer to the con­cerns around the major energy issues fac­ing the SnoPUD were debated by Kath­leen Vaugh and Eric Tee­gar­den dur­ing the last elec­tion.(Tran­script here)

Please take our poll.

In response to the ques­tion Why Dam?

Tomas O’keefe of Amer­i­can White White Water states this:

Sun­set Falls Hydropower Development

On Sep­tem­ber 28, 2011, Pub­lic Util­ity Dis­trict No. 1 of Sno­homish County filed an appli­ca­tion for a pre­lim­i­nary per­mit propos­ing to study the fea­si­bil­ity of the Sun­set Falls Hydro­elec­tric Project to be located on the South Fork Skykomish River near Index in Sno­homish County, Wash­ing­ton. On March 21, 2013 Sno­homish PUD filed a Pre-​Application Doc­u­ment and Notice of Intent to seek a hydropower license to dam the South Fork Skykomish River. Amer­i­can White­wa­ter has joined a num­ber of river con­ser­va­tion orga­ni­za­tions in oppos­ing this project for the fol­low­ing reasons:

1) Min­i­mal Power

The esti­mated annual name­plate capac­ity for this pro­posed project is 30 MW. How­ever, as noted in the appli­ca­tion, the actual gen­er­a­tion will be depen­dent on min­i­mum stream flows. As such, the project’s actual capac­ity given lim­ited sea­sonal flows will be 13.7 MW.

While we under­stand that prox­im­ity to exist­ing Sno­homish PUD facil­i­ties makes this project attrac­tive to the PUD, given the num­ber of exist­ing dams in Wash­ing­ton State, and the num­ber of dams that cur­rently do not gen­er­ate elec­tric­ity or that are not oper­at­ing at peak effi­ciency, new dam con­struc­tion should not be con­tem­plated until we max­i­mize use from exist­ing dams and exist­ing hydropower projects.

2) Sub­stan­tial Envi­ron­men­tal Impacts

The Con­ser­va­tion Groups have dis­cussed with Sno­homish PUD ways to con­serve addi­tional energy, to uti­lize exist­ing dams and to pur­sue new hydropower tech­nolo­gies, all with the goal of avoid­ing the need to build new dams that have adverse envi­ron­men­tal impacts. We under­stand that Sno­homish PUD is actively pur­su­ing some of these strate­gies, which we sup­port. How­ever, con­tin­u­ing to explore new devel­op­ment at Sun­set Falls is incon­sis­tent with those strate­gies. Fur­ther, it is an inap­pro­pri­ate loca­tion for devel­op­ment of a new hydropower project.

Devel­op­ment of the Sun­set Falls Hydro­elec­tric Project would have many envi­ron­men­tal impacts, includ­ing impacts on aes­thet­ics, recre­ation, and res­i­dent fish and wildlife habi­tat and species. The project would greatly reduce flows on a scenic cascade-​and-​falls com­bi­na­tion and would result in con­struc­tion impacts from build­ing a new dam, a 1.1 mile bypass, a 2000 ft. by 19 ft. diam­e­ter intake tun­nel, a semi-​underground pow­er­house, a 2 acre reser­voir and a 8.5 trans­mis­sion line to the exist­ing sub­sta­tion in Gold Bar.

In addi­tion to the sig­nif­i­cant envi­ron­men­tal impacts, the project pro­posed in the PUD’s pre­lim­i­nary per­mit appli­ca­tion would be plainly incon­sis­tent with a num­ber of rel­e­vant com­pre­hen­sive plans that have pre­vi­ously been filed with the Fed­eral Energy Reg­u­la­tory Com­mis­sion. This incon­sis­tency runs counter to Sec­tion 10(a)(2)(A) of the Fed­eral Power Act (FPA) (16 U.S.C. § 803 (a)(2)(A)) that specif­i­cally requires the Com­mis­sion, when licens­ing a project, to con­sider “the extent to which [a] project is con­sis­tent with a com­pre­hen­sive plan (where one exists) for improv­ing, devel­op­ing, or con­serv­ing a water­way or water­ways affected by the project that is pre­pared by an agency estab­lished pur­suant to Fed­eral law that has the author­ity to pre­pare such a plan; or the State in which the facil­ity is or will be located.”

The Skykomish River is part of the Wash­ing­ton State Scenic River sys­tem (79A.55 RCW), the leg­isla­tive pur­pose of which is to “pro­tect and pre­serve the nat­ural char­ac­ter of such rivers and ful­fill other con­ser­va­tion pur­poses.” Rivers in the sys­tem “shall be pre­served in as nat­ural a con­di­tion as prac­ti­cal and that overuse of such rivers, which tends to down­grade their nat­ural con­di­tion, shall be dis­cour­aged.” In addi­tion the sec­tion of the Skykomish River that includes Sun­set Falls is in a North­west Power and Con­ser­va­tion Coun­cil Pro­tected Area from hydropower devel­op­ment, and has been rec­om­mended to Con­gress for des­ig­na­tion as a National Wild and Scenic River for its Scenic, Recre­ation, Fish, and Wildlife val­ues by the U.S. For­est Ser­vice. FERC has long rec­og­nized the impor­tance of regional and coor­di­nated plan­ning, and has declined to issue licenses in cases where the neg­a­tive impacts of a pro­posed project would run counter to these regional plans. Wild and Scenic suit­abil­ity, pro­tected area sta­tus, and sta­tus as a State Scenic Water­way each con­sti­tute rel­e­vant in-​place plans and strate­gies to enhance and pro­tect the aquatic, aes­thetic, habi­tat, recre­ational and con­ser­va­tion resources of the Skykomish River.

For the fore­go­ing rea­sons, we do not agree with the PUD’s repeated descrip­tion of the Sun­set Falls Project as a “low-​impact hydropower project” or that it will, with lim­ited avail­able sea­sonal flows, “pro­vide an envi­ron­men­tally sound, carbon-​free, sus­tain­able, and depend­able energy source.”

3) New Hydropower Dams Do Not Count as a Renew­able Resource in Wash­ing­ton State

In its descrip­tion of project ben­e­fits, Sno­homish PUD’s pre­lim­i­nary per­mit appli­ca­tion dis­cusses Wash­ing­ton State’s renew­able port­fo­lio stan­dard that requires large util­i­ties such as the PUD to pro­vide 15 per­cent of their load from new, renew­able energy resources by 2020. How­ever, as the PUD acknowl­edges, the Wash­ing­ton stan­dard does not count power gen­er­a­tion from newly con­structed hydropower projects such as the one it is propos­ing as eli­gi­ble under this stan­dard. There­fore the PUD’s spec­u­la­tive asser­tion that one of the project ben­e­fits will be to help the PUD meet the state RPS require­ments is inac­cu­rate and misleading.

A His­tory of Failed Proposals

A num­ber of devel­op­ers, includ­ing Sno­homish PUD, have inves­ti­gated the fea­si­bil­ity of hydropower devel­op­ment over the past sev­eral decades. The low power poten­tial of the site and high cost of devel­op­ment led con­sis­tently led to a deci­sion not to develop the site. At the same time the con­ser­va­tion value of the river in its free-​flowing state has received greater recognition.

A num­ber of hydropower projects have been pro­posed at Sun­set Falls over the years.

  • Puget Sound Energy explored the site early in the 20th century.
  • Sno­homish PUD had a project pro­posal (FERC P-​4786 and FERC P-​8574) in the early 1980’s.
  • Pacific Hydro sub­mit­ted a per­mit appli­ca­tion in Octo­ber 1984 (FERC P-​8644) that they with­drew in Sep­tem­ber 1985.
  • Sun­set Falls LP sub­mit­ted a per­mit appli­ca­tion in Sep­tem­ber 1991 (FERC P-​11195) that they with­drew in Sep­tem­ber 1993.
  • Tacoma Pub­lic Util­i­ties sub­mit­ted a per­mit appli­ca­tion in Decem­ber 1991 (FERC P-​11216) that they with­drew in May 1992.
  • Sno­homish PUD sub­mit­ted a per­mit appli­ca­tion for hydropower devel­op­ment in Sep­tem­ber 2011 (FERC P-​14295).

Dawn Presler of SnoPUD states this:

Why dam?
From Q&A, there are mul­ti­ple rea­sons to pur­sue SFPEP listed but I’ve cut/​pasted a few here…
· #19 Why a project at this loca­tion?
Sun­set Falls is one of the largest unde­vel­oped, non-​polluting, energy resources avail­able in the PUD ser­vice area and that is located out­side des­ig­nated wilder­ness areas. Hydro­elec­tric projects are long-​lived gen­er­at­ing resources, whose oper­at­ing life often spans 100 years, mak­ing this a viable resource option for the PUD. Hydro­elec­tric power poten­tial is depen­dent on water flow and a change in ele­va­tion of that water flow. At this pro­posed project, there is an approx­i­mate 150-​foot drop in ele­va­tion between the pro­posed intake and pow­er­house, with ample amounts of high flows. Sun­set Falls has his­tor­i­cally been a bar­rier to salmon pas­sage. The project is located in an area that is already devel­oped (with homes/​cabins, roads, cul­verts, dis­tri­b­u­tion lines), ½ mile from SR 2 and trans­mis­sion lines. The sec­tion of the river where the project would be located is on a 1.1 mile bend in the South Fork Skykomish River that is crossed by dis­tri­b­u­tion lines and the rail­road twice. The pow­er­house would be located on the site par­cel at the exist­ing Trap-​and-​Haul Facil­ity. The pro­posed project is within the PUD’s ser­vice ter­ri­tory. It is also in close prox­im­ity to the PUD’s other hydro­elec­tric projects in Sno­homish County. Ini­tial review of geol­ogy indi­cates the facil­i­ties would be sited on bedrock, and hydrol­ogy indi­cates nat­ural flows that match sea­sonal trends/​demand for energy. (Updated 3/​2013)
· #28 What is the aver­age energy pro­duc­tion of the pro­posed project?How many homes would the fin­ished project serve? What per­cent of the PUD’s cus­tomer load would be served by the project?
The actual aver­age energy pro­duc­tion will be a func­tion of the project’s final design (e.g., tur­bine unit capac­ity, effi­ciency, and required min­i­mum river flows). For pur­poses of prepar­ing the Pre­lim­i­nary Per­mit Appli­ca­tion, these fac­tors were esti­mated, indi­cat­ing aver­age annual power gen­er­a­tion of approx­i­mately 120,000,000 kWh. This equates to an aver­age plant out­put of 13.7 megawatts (MW), which is enough to serve approx­i­mately 10,275 homes. When gen­er­at­ing at full capac­ity (such as dur­ing winter/​spring), the 30 MW project would be enough to power over 22,500 homes.

Given rain­fall pat­terns in the region, gen­er­at­ing out­put would be at the same time the PUD has high energy demand (late fall and win­ter months into early spring).

The major­ity of the PUD’s load is served by the Bon­neville Power Asso­ci­a­tion (BPA) sys­tem, which comes in part from large hydro­elec­tric projects on the Colum­bia River. The Sun­set Falls project, by com­par­i­son to BPA resources, com­prises a small per­cent­age of the PUD’s over­all long-​term power sup­ply port­fo­lio. The PUD’s power sup­ply con­tract with BPA caps the amount of power the PUD is eli­gi­ble to pur­chase dur­ing the 2012 through 2028 con­tract term. To meet its future needs, the PUD needs to either develop or acquire addi­tional gen­er­at­ing resources on its own, or pro­vide 3–5 years advance notice to BPA that it would like to pur­chase a spe­cific quan­tity of energy from BPA. The rate that BPA would charge for this addi­tional quan­tity of power would not be known or estab­lished by BPA until a future period, intro­duc­ing an ele­ment of risk and uncer­tainty for the PUD.
(Updated 3/​2013)

· #29 Why would the PUD build this project when it only pro­duces 1% of its power needs?
The project is one of the largest unde­vel­oped, non-​polluting, energy resources deter­mined to be avail­able in the PUD ser­vice area, and that is located out­side des­ig­nated wilder­ness areas. This is enough energy to power 10,275 homes – or enough to serve the res­i­den­tial cus­tomers in the cities of Sno­homish, Mon­roe, Sul­tan, Index and Gold Bar com­bined. More impor­tantly, dur­ing times of high cus­tomer demand, out­put could sup­ply enough power for 22,500 homes – or enough energy to sup­ply power to the res­i­den­tial cus­tomers in the cities of Brier, Lyn­nwood, Mill Creek and Dar­ring­ton combined.

Small, locally-​generated energy projects reduce the PUD’s expo­sure to a fluc­tu­at­ing and often volatile whole­sale power mar­ket. Out­put from a project in the PUD’s ser­vice area also reduces the risk of deliv­ery to the PUD from and across the power grid.

The pro­posed project could pro­duce approx­i­mately 16% of the renew­able energy port­fo­lio (non-​BPA) dur­ing times of high demand.

(Updated 3/​2013)
· #34 Why is the PUD pur­su­ing this project?
For the PUD, the strong inter­est in more locally-​generated, renew­able energy resources is about cre­at­ing a diverse, carbon-​free energy sup­ply. The Board of Com­mis­sion­ers has made a com­mit­ment to meet­ing its grow­ing energy needs through all cost-​effective con­ser­va­tion, and to the extent the energy needs can­not be met com­pletely by con­ser­va­tion achieve­ments, then with renew­able energy resources. The util­ity faces poten­tial load growth of 10 per­cent by 2020. Its ser­vice area is expected to reach nearly 1 mil­lion res­i­dents in the next 20 years.

A project at Sun­set Falls would be:
· Clean, renew­able resource in our ser­vice territory

· Close to exist­ing trans­mis­sion lines to min­i­mize trans­mis­sion line losses

· Non-​polluting resource with no heat or nox­ious gas releases

· Com­pet­i­tive (or bet­ter) in price to other green resources for PUD ownership

· Com­ple­men­tary to vari­able gen­er­at­ing energy resources, such as wind and solar

· Pro­duces energy out­put when the PUD’s energy needs are highest

· Using a proven tech­nol­ogy that has a long life, up to 100 years or more

· In an area already developed

· #37 Why is the PUD look­ing at new hydro projects when they are being removed in other parts of the state? Isn’t it an old tech­nol­ogy?
The use of water to irri­gate crops, to turn mills, and to con­duct other essen­tial daily work has been around for thou­sands of years. Over time, peo­ple started using the power of water to pro­duce elec­tric­ity. Although the con­cept is old, hydro tech­nol­ogy is a tried and true tech­nol­ogy that con­tin­ues to have applic­a­bil­ity for meet­ing today’s power gen­er­a­tion needs. http://​www1​.eere​.energy​.gov/​w​a​t​e​r​/​h​y​d​r​o​_​h​i​s​t​o​r​y​.​h​tml.

The pro­posed tech­nol­ogy for the intake at this site, should the project be con­structed, is a pneu­matic gate (such as an Ober­meyer gate). The Ober­meyer tech­nol­ogy was first patented in 1988 and not avail­able for con­sid­er­a­tion when pre­vi­ous stud­ies of the site were con­ducted in the early 1980s. This type of tech­nol­ogy uti­lizes an inflatable/​deflatable weir that can be low­ered or raised allow­ing water, sed­i­ments, large woody debris, etc. to flow the nat­ural course of the river. There are two to three weir sec­tions which make up the diver­sion; each sec­tion inflates or deflates to main­tain the depth of water upstream at a steady level. Each would be capa­ble of over­top­ping with water, typ­i­cally by a min­i­mum of 1 foot of water, to pro­vide instream and aes­thetic flows. As flows in the river increase, the weir would be grad­u­ally low­ered to allow more water to spill over the top while hold­ing the water depth the same. When flows are very high, the weir would lay flat. When the project is not gen­er­at­ing, the weir would lay flat.

Many of the hydro projects in Wash­ing­ton state were devel­oped in the first half of the 20th cen­tury, before envi­ron­men­tal pro­tec­tions were required. Today’s hydro projects are built with very strin­gent require­ments for envi­ron­men­tal pro­tec­tion, enhance­ment and mit­i­ga­tion mea­sures. These mea­sures often sur­pass the impacts that the caused by the projects; thereby, pro­vid­ing a pos­i­tive ben­e­fit to the envi­ron­ment and community.

· #40 Why is the PUD look­ing at small hydro projects when they do not qual­ify under the state renew­able port­fo­lio stan­dard (I-​937 man­date)? Does it vio­late I-​937?
While most hydropower does not qual­ify under I-​937 (RCW 19.285) as an “eli­gi­ble renew­able resource,” it pro­vides a clean, locally-​generated, energy source that com­ple­ments other resources, some of which may have inter­mit­tent out­put (such as wind). Addi­tion­ally, as shown in the Fig­ure 6-​1A in response to Ques­tion #46 below, low impact hydro is a low cost renew­able resource which helps keep rates low for the PUD’s 320,000 cus­tomers. Adding more or new hydropower to the PUD’s port­fo­lio does not vio­late I-​937, as that law does not reg­u­late or pro­hibit what types of resources util­i­ties can use. While some hydropower (effi­ciency improve­ments) is counted under I-​937, new hydropower projects are not included because the intent of the law was to encour­age the devel­op­ment of new renew­able sources.

It diver­si­fies the utility’s energy port­fo­lio and gives it greater con­trol with its energy sup­ply. More­over, as a back­yard resource, it min­i­mizes con­straints on the trans­mis­sion sys­tem as well as addi­tional trans­mis­sion upgrades.

The PUD is meet­ing I-​937 require­ments with a diverse mix of energy sources, includ­ing wind, bio­mass, land­fill gas and solar. The PUD also con­tin­ues to be a leader in the research and devel­op­ment of geot­her­mal and tidal energy in the Pacific North­west. It has met, even exceeded, the require­ments of its 2012 goals under I-​937 and is on track to meet require­ments in future years.

For the PUD, the push for more locally gen­er­ated green energy resources is less about state man­dates and more about cre­at­ing a diverse, carbon-​free energy sup­ply, for future resource needs. Small hydropower facil­i­ties are designed as run-of-the–river projects, which divert a por­tion of the water to a pres­sur­ized pipeline that deliv­ers it to a tur­bine down­stream for energy pro­duc­tion. Given rain­fall pat­terns in the region, the gen­er­at­ing out­put is nat­u­rally max­i­mized dur­ing times of high energy demand (late fall and win­ter). It also com­ple­ments other inter­mit­tent energy sources, such as wind and solar. New small hydropower sites will require approval by the Fed­eral Energy Reg­u­la­tory Com­mis­sion after con­sul­ta­tion by the PUD with fed­eral, state, local and tribal gov­ern­ments; non-​governmental orga­ni­za­tions; and the pub­lic. Envi­ron­men­tal pro­tec­tion, mit­i­ga­tion and enhance­ment mea­sures are devel­oped through con­sul­ta­tion, and then required by a project license.

Small hydro projects are valu­able resources within our ser­vice ter­ri­tory that can pro­duce energy for our local needs, pro­vide local jobs and stim­u­late the local economy.

· #46 The project’s cost esti­mate of between 150 and 170 mil­lion dol­lars seems high for a facil­ity that would not gen­er­ate elec­tric­ity through­out the year and would only pro­vide an esti­mated 1% of SnoPUD’s total energy pro­file. In addi­tion I won­der if the costs include the cap­i­tal costs for an ini­tial upgrade to the trap and haul and also for annual costs to oper­ate and main­tain the trap and haul?
The updated cost of the pro­posed project is esti­mated between 110 and 175 mil­lion and includes pro­posed upgrades and main­te­nance to the exist­ing WDFW Trap-​and-​Haul Facil­ity and also ongo­ing oper­a­tion and main­te­nance. The Sun­set Project is one of the largest unde­vel­oped, non– pol­lut­ing, energy resources deter­mined to be avail­able in the Sno­homish PUD ser­vice area, and is located out­side des­ig­nated fed­eral wilder­ness areas. This is enough energy at full capac­ity to sup­ply power for 22,500 homes – or enough energy to sup­ply power to the res­i­den­tial cus­tomers in the cities of Brier, Lyn­nwood, Mill Creek and Dar­ring­ton com­bined.

The Bon­neville Power Admin­is­tra­tion (BPA) has no more capac­ity in the fed­eral hydro sys­tem. Cus­tomers of BPA are now assigned a max­i­mum share of the hydro sys­tem by way of long term con­tracts. Sno­homish PUD under­stands that the util­ity can no longer look to BPA to fill our future power needs. As a sup­ply deficit util­ity, the PUD must ful­fill its energy demand from addi­tional power gen­er­at­ing resources. The Sno­homish PUD Board of Com­mis­sion­ers pledged to its cus­tomers to bring no new fos­sil fuel into our energy port­fo­lio to play our part in address­ing global cli­mate change.

The Dis­trict has already imple­mented the fol­low­ing actions to ensure no new carbon-​emitting resources:
· An over $20 mil­lion energy con­ser­va­tion pro­gram.
A power port­fo­lio that includes 217 MW of wind – which can com­prise as much as 8% of the PUD’s total energy sources, as well as land­fill gas, and bio­mass. We also installed small micro wind tur­bines in Sno­homish County to study the local wind poten­tial and appli­ca­tion of local cit­i­zen owned wind gen­er­a­tion tech­nolo­gies.
· One of the most suc­cess­ful small scale solar pro­grams in the state. We will have 300 rooftop solar sys­tems installed on res­i­den­tial and busi­nesses by the end of March 2013.
· The PUD leads the nation in the research and devel­op­ment of tidal power and we have lever­aged a pow­er­ful team of part­ners that include the Uni­ver­sity of Wash­ing­ton and the Depart­ment of Energy (DOE), among oth­ers.
· We con­tinue to explore oppor­tu­ni­ties for geot­her­mal energy and com­pleted a series of deep exploratory wells in east­ern Sno­homish County in part­ner­ship with the Depart­ment of Energy and Wash­ing­ton State Depart­ment of Nat­ural Resources.
· The PUD recently launched a major project with indus­try part­ners to trans­form the energy stor­age mar­ket through stan­dard­iza­tion and com­modi­ti­za­tion to bring down the cost and make stor­age more viable from an oper­a­tional per­spec­tive. This effort will attempt to solve the vari­abil­ity prob­lem that most new renew­ables cre­ate when they gen­er­ate at times when you don’t need it and sit idle when you do.
· We recently launched an inno­v­a­tive Small Renew­ables Pro­gram to encour­age the devel­op­ment of small, dis­trib­uted renew­able gen­er­at­ing resources. Local devel­op­ment of these resources diver­si­fies Sno­homish PUD’s power sup­ply port­fo­lio and pro­vides a vari­ety of mea­sur­able ben­e­fits to Sno­homish PUD ratepay­ers.
· We were one of only two util­i­ties in the State to receive an ARRA Smart Grid Grant which allowed us to move aggres­sively for­ward to make sure our elec­tric sys­tem can appro­pri­ately inte­grate elec­tric vehi­cles, demand response, small vari­able local cus­tomer gen­er­a­tion, dis­trib­uted stor­age, cyber secu­rity and other impor­tant appli­ca­tions well into the future.

Even with these activ­i­ties, the PUD must main­tain reli­a­bil­ity and develop firm energy resources. One of the low­est cost renew­able resources is hydro­elec­tric power, which emits very low to no green­house gases.

While the ini­tial costs of this project may seem high, over time, the costs will decline because the con­struc­tion of the project will be paid off. This will result in very inex­pen­sive power because the resource (water) is essen­tially free (mit­i­ga­tion for the impacts will still be a part of the cost of power).
(Added 3/​2013)
· #48 Wouldn’t the impact be lower and also the over­all eco­nom­ics be bet­ter to use the funds required to build the Sun­set Fish Pas­sage and Energy project to build an equiv­a­lently sized pho­to­voltaic project?
The Sun­set Fish Pas­sage and Energy Project is supe­rior to an equiv­a­lently sized pho­to­voltaic project for four rea­sons. First, the Sun­set Project has only an approx­i­mate 4.2-acre foot­print, much of which is under­ground, and is expected to pro­duce an aver­age annual out­put of 123 GWh. Gen­er­at­ing this much energy from a solar pho­to­voltaic plant would require approx­i­mately 800 acres (over one square-​mile) of land use.

Sec­ond, the Sun­set Fish Pas­sage and Energy Project is more advan­ta­geous to the peo­ple of Sno­homish PUD because it is located close to where we need the energy. The trans­mis­sion for this project can be pro­vided along the exist­ing SR2 dis­tri­b­u­tion cor­ri­dor. In con­trast, an eco­nom­i­cally opti­mized utility-​scale solar array would be cited in east­ern Wash­ing­ton (because they get more sun), which would cre­ate a need for much greater trans­mis­sion infra­struc­ture than the Sun­set project.

Third, in the Sno­homish PUD ser­vice ter­ri­tory, we uti­lize much more energy in the win­ter than we do in the sum­mer because we are heat­ing our homes and busi­nesses. As a result, we need resources that pro­duce energy coin­ci­dent with this demand. Unfor­tu­nately, a utility-​scale solar instal­la­tion would gen­er­ate more energy in the sum­mer months when the Dis­trict already has excess energy. In addi­tion, solar pro­duc­tion is inter­mit­tent and can stop very sud­denly when a cloud bank passes over the array, caus­ing power fluc­tu­a­tions that the Dis­trict must mitigate.

Finally, we have con­sid­ered both inde­pen­dent reviews of renew­able energy cost and esti­mates from the Dis­trict engi­neers. The eco­nomic analy­sis reveals that the cost for a com­mer­cial pho­to­voltaic plant could be as much as three times the cost of the Sun­set project and the ser­vice life would be shorter. There­fore, the Sun­set Fish Pas­sage and Energy Project is a supe­rior resource for the Dis­trict and will also help strengthen the health of the local fish pop­u­la­tion by mod­ern­iz­ing the exist­ing infra­struc­ture. (Added

Fur­ther scop­ing doc­u­ments can be found at the SnoPUD site.

This is an exert from that doc­u­ment
Scop­ing Meetings

Com­mis­sion staff will hold two scop­ing meet­ings in the vicin­ity of the project at the time and place noted below. The day­time meet­ing will focus on resource agency, Indian tribes, and non-​governmental orga­ni­za­tion con­cerns, while the evening meet­ing is pri­mar­ily for receiv­ing input from the pub­lic. We invite all inter­ested indi­vid­u­als, orga­ni­za­tions, and agen­cies to attend one or both of the meet­ings, and to assist staff in iden­ti­fy­ing par­tic­u­lar study needs, as well as the scope of envi­ron­men­tal issues to be addressed in the envi­ron­men­tal doc­u­ment. The times and loca­tions of these meet­ings are as follows:

Evening Scop­ing Meet­ing Date:

Wednes­day, June 12, 2013 Time: 6:00 p.m.
Loca­tion: Town of Index Fire Depart­ment 512 Avenue A, Index, WA 98256
Phone: (360) 793‑0866

Day­time Scop­ing Meet­ing Date: Thurs­day, June 13, 2013 Time: 10:00 a.m.
Loca­tion: Wash­ing­ton Depart­ment of Ecol­ogy Head­quar­ters 300 Desmond Drive SE, Lacey, WA 98503
Phone: (360) 407‑6000
Scop­ing Doc­u­ment 1 (SD1), which out­lines the sub­ject areas to be addressed in the envi­ron­men­tal doc­u­ment, was mailed to the indi­vid­u­als and enti­ties on the Commission’s mail­ing list. Copies of SD1 will be avail­able at the scop­ing meet­ings, or may be viewed on the web at http://​www​.ferc​.gov, using the “eLi­brary” link. Fol­low the direc­tions for access­ing infor­ma­tion in para­graph n. Based on all oral and writ­ten comments,a Scop­ing Doc­u­ment 2 (SD2) may be issued. SD2 may include a revised process plan and sched­ule, as well as a list of issues, iden­ti­fied through the scop­ing process.

Envi­ron­men­tal Site Review

Sno­homish PUD will con­duct an envi­ron­men­tal site review of the project on Wednes­day, June 12, 2013, start­ing at 2:00p.m. All par­tic­i­pants should meet at the Gold Bar Park and Ride, located at Inter­sec­tion State Road 2 and 2nd Street, Gold Bar, WA 98251. All par­tic­i­pants are respon­si­ble for their own trans­porta­tion. Any­one with ques­tions about the site visit should con­tact Ms. Dawn Pressler of Sno­homish PUD at (425) 783‑1709 on or before June 6, 2013.

Meet­ing Objectives

At the scop­ing meet­ings, staff will: (1) ini­ti­ate scop­ing of the issues; (2) review and dis­cuss exist­ing con­di­tions and resource man­age­ment objec­tives; (3) review and dis­cuss exist­ing infor­ma­tion and iden­tify pre­lim­i­nary infor­ma­tion and study needs; (4) review and dis­cuss the process plan and sched­ule for pre-​filing activ­ity that incor­po­rates the time­frames pro­vided for in Part 5 of the Commission’s reg­u­la­tions and, to the extent pos­si­ble, max­i­mizes coor­di­na­tion of fed­eral, state, and tribal per­mit­ting and cer­ti­fi­ca­tion processes; and (5) dis­cuss the appro­pri­ate­ness of any fed­eral or state agency or Indian tribe act­ing as a coop­er­at­ing agen­cy­for devel­op­ment of an envi­ron­men­tal doc­u­ment. Meet­ing par­tic­i­pants should come pre­pared to dis­cuss their issues and/​or con­cerns. Please review the PAD in prepa­ra­tion for the scop­ing meet­ings. Direc­tions on how to obtain a copy of the PAD and SD1 are included in item n. of this doc­u­ment. Project No. 14295–001 5Meeting Pro­ce­dures The meet­ings will be recorded by a stenog­ra­pher and will be placed in the pub­lic records of the project.

The fol­low­ing is a pub­lic document.

This noti­fi­ca­tion is served on you in accor­dance with the require­ments set forth in Sec­tion 385.2010 of the Commission’s rules.

On 5/​20/​2013, the Fed­eral Energy Reg­u­la­tory Com­mis­sion (FERC), Wash­ing­ton D.C., pub­lished the fol­low­ing issuance:

Docket(s): P-14295–001
Descrip­tion: Let­ter cir­cu­lat­ing Scop­ing Doc­u­ment No. 1 for the Sun­set Fish Pas­sage and Energy Project under P-​14295.

You can view the issuance at: http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20130520–3012

You may also eSub­scribe to the docket number(s) in the issuance by click­ing on the fol­low­ing link to login to FERC Online.

Ini­tia­tive 937 and The Pro­posed Hydro­elec­tric Project at Sun­set Falls


Update Jan 30th 2013: SnoPUD in a work­ing ses­sion of the Sen­ate Energy, Envi­ron­ment & Telecom­mu­ni­ca­tions Com­mit­tee . Openly requests a change in the law I-​937 which would allow the energy gen­er­ated at the pro­posed Sun­set Falls Hydro­elec­tric Project to apply to their I-​937 require­ments. Cur­rently the SnoPUD has to pur­chase the major­ity of these RECS (Renew­able Energy Cred­its) from other sources at a sig­nif­i­cantly higher cost then non-​REC power.

A renew­able port­fo­lio stan­dard (RPS) requires elec­tric­ity retail­ers to acquire a min­i­mum per­cent­age of their power from renew­able energy resources. Ini­tia­tive 937 is an RPS.

Ini­tia­tive 937

Approved by vot­ers in 2006, the Energy Inde­pen­dence Act, also known as Ini­tia­tive 937, requires an elec­tric util­ity with 25,000 or more cus­tomers to use “eli­gi­ble renew­able resources” to meet the fol­low­ing annual targets:

at least 3 per­cent of its load by Jan­u­ary 1, 2012, and each year there­after through Decem­ber 31, 2015;

at least 9 per­cent of its load by Jan­u­ary 1, 2016, and each year there­after through Decem­ber 31, 2019; and

at least 15 per­cent of its load by Jan­u­ary 1, 2020, and each year there­after1.

Does the ini­tia­tive 937 pro­hibit devel­op­ment of Sun­set Falls?

Lets first look at how the I-​937 could be applied. Ini­tia­tive 937 allows util­i­ties to use ”renew­able energy cred­its” (RECS) to meet their annual targets.

Lets take a look at what makes a REC.

Char­ac­ter­is­tics of a REC

The price of renew­able power has two com­po­nents: the price of the elec­trons plus a pre­mium for the renew­able value of the elec­trons. The pre­mium exists because of renew­able energy man­dates or because of pur­chases dri­ven by vol­un­tary pro­grams to pro­mote renew­able power, such as Washington’s “green power” pro­gram.2

Where can my power com­pany get RECs?

REC Mar­kets

Buy­ers of large vol­umes of RECs, such as util­i­ties, can find it dif­fi­cult to deter­mine the price of RECs. Unlike the mar­kets for elec­tric­ity and nat­ural gas, there are no cen­tral clear­ing houses for RECs, nor is there a futures mar­ket. In addi­tion, con­tracts for large vol­umes of RECs often con­tain con­fi­den­tial­ity clauses that pro­hibit price dis­clo­sure for the term of the con­tract. For these rea­sons, insti­tu­tional buy­ers typ­i­cally use request for pro­pos­als (RFPs) and bro­kers for price discovery.

The mar­ket for RECs can be divided into vol­un­tary and com­pli­ance mar­kets. The vol­un­tary mar­ket is the source of RECs for the var­i­ous green power pro­grams oper­ated by util­i­ties and for per­sons and com­pa­nies inter­ested in sup­port­ing renew­able energy.For exam­ple, the Wash­ing­ton Util­i­ties and Trans­porta­tion Com­mis­sion reports that all three investor-​owned util­i­ties in the state use RECs for their green power pro­grams. REC aggre­ga­tors like the Bon­neville Energy Foun­da­tion and 3Degrees are the main source of RECs in the vol­un­tary mar­ket, although many pub­lic util­i­ties in Wash­ing­ton pur­chase their voluntary-​market RECs from the Bon­neville Power Admin­is­tra­tion.3

Does my power com­pany need to pro­duce its own RECs to make it’s REC target?

No, your power com­pany can meet its I-​937 tar­get goals by trad­ing them on a cer­ti­fied mar­ket; pos­si­bly for a “non-​green” power con­sid­er­a­tion, some­thing else that has a “price” or value. An exam­ple of this is the long term power pur­chase agree­ment that Sno­homish County PUD entered into with var­i­ous “Green Power Providers” to acquire approx­i­mately 14 mil­lion dol­lars in RECs for the year 2012.

If my power com­pany wanted to pro­duce its own RECs how could it do that?

Your power com­pany would have to be able to pro­duce elec­tric­ity with an “eli­gi­ble renew­able resource”.

What is an “eli­gi­ble renew­able resource”?

Wash­ing­ton State Law cur­rently defines “eli­gi­ble renew­able resource” to be from ESB 5575.

(10) “Eli­gi­ble renew­able resource” means:
(a) Elec­tric­ity from a gen­er­a­tion facil­ity pow­ered by a renew­able resource other than fresh­wa­ter that com­mences oper­a­tion after March 31, 1999, where: (i) The facil­ity is located in the Pacific North­west; or (ii) the elec­tric­ity from the facil­ity is deliv­ered into Wash­ing­ton state on a real-​time basis with­out shap­ing, stor­age, or inte­gra­tion ser­vices; ((or))
(b) Incre­men­tal elec­tric­ity pro­duced as a result of effi­ciency improve­ments com­pleted after March 31, 1999, to hydro­elec­tric gen­er­a­tion projects owned by a qual­i­fy­ing util­ity and located in the Pacific North­west or to hydro­elec­tric gen­er­a­tion in irri­ga­tion pipes and canals located in the Pacific North­west, where the addi­tional gen­er­a­tion in either case does not result in new water diver­sions or impoundments;

Can they do that with hydro­elec­tric resources?

Well, this is where it gets a lit­tle tricky. If you have an exist­ing hydro facil­ity you could improve the facil­ity accord­ing to the def­i­n­i­tion. Improve­ment could in Sun­set Falls case be an improve­ment on it is fish spill­way or con­sid­ered improve­ments on the diver­sion of water cur­rently used by the trap and haul facility.

Could the PUD still develop the Sun­set Falls Hydro­elec­tric Project?

Depends on what you clas­sify the project as; Green ( REC com­pli­ant, how­ever it would require a change in cur­rent Wash­ing­ton State law. ), tra­di­tional ( non­REC com­pli­ant )or upgrade to cur­rent trap and haul. ( REC com­pli­ant and just a upgrade )

SnoPUD com­ments at the Wash­ing­ton Sen­ate Energy, Envi­ron­ment & Telecom­mu­ni­ca­tions Com­mit­tee can be found at 1:06 of this link

1,2,3 –The ital­i­cized para­graphs are from the fol­low­ing doc­u­ment.

Project Overview


Update: Jan 30th 2013

The new “cav­ern” design moves the large fish screen com­plex under­ground and also cre­ates three cor­ri­dors of traf­fic. Though still in the design phase the cav­ern will be nearly 365x142x76 ft approx­i­mately a large 7 story com­mer­cial build­ing under­ground. The Hatch design analy­sis doc­u­ment ( named after the com­pany which com­pleted it ) can be found here

The Sun­set Falls Hydro­elec­tric Project as pro­posed in a pre­lim­i­nary draw­ing:

The pro­posed design would divert a sig­nif­i­cant por­tion of the rivers cur­rent flow and divert it into a 19 ft Horse­shoe shape tun­nel. At the tunnel’s end there will be a ten story pow­er­house ( cur­rently pro­posed to be mostly sub­ter­ranean three story build­ing above ground ) which con­tains the tur­bines and tur­bine inlets. The diver­sion weir would cross the river. At its max­i­mum; it would rise the water level of the river eight feet from the weirs base. The intake described in the pre­lim­i­nary draw­ing is approx­i­mately 280 ft in length ( sim­i­lar size to a foot­ball field ) and pos­si­bly a three story high ( intake struc­ture 15 ft tall and a 15 ft foot trash rack clean­ing sys­tem ). The intake would and its sup­port­ing struc­tures would dis­place mem­bers of the Canyon Falls Home Own­ers Asso­ci­a­tion and the Mount Index River­sites Community.

A short HD video from the east­ern side of Canyon Falls look­ing up river.< click­be­low >

This image would sig­nif­i­cantly change if there was only half the cur­rent flow was allowed to flow under the rail road bridge.

Fur­ther down the river Sun­set Falls itself would be affected as the diverted water would not fall over the falls. < click below >

Infor­ma­tion for this arti­cle was sup­plied by
Sno­homish County PUD pre­sen­ta­tion to FERC

Next Steps? The Race

Oct 17, 2012 KSER
Spe­cial Pre­sen­ta­tion: A Con­ver­sa­tion with Two of Our Can­di­dates for Sno­homish County PUD

Host Ed Beamer with Kathy Vaughn and Eric Teegarden

Music Intro: Power, sung by Peter, Paul, and Mary. (Writ­ten by John and Johanna Hall)

EB: Good after­noon, good evening. Wel­come to KSER. I’m Ed Bre­mer. Tonight we are pre-​empting Law and Dis­or­der to give you the oppor­tu­nity to talk with the two can­di­dates for PUD Com­mis­sioner, Dis­trict 2: the incum­bent, Kathy Vaughn, and her chal­lenger Eric Tee­gar­den. The PUD Com­mis­sion has three mem­bers and the elec­tion is non-​partisan, so an R or D behind the name is irrel­e­vant. What is rel­e­vant is the individual’s vision of the energy future of Sno­homish County and the abil­ity to move that vision for­ward. To that end, we invite you to lis­ten to the pro­gram and, if ques­tions or con­cerns come to mind, don’t hes­i­tate to call and talk directly with the can­di­dates this evening. We’ll open up the phones a lit­tle bit later. This is not a debate. What this is is a wide-​ranging con­ver­sa­tion of phi­los­o­phy and vision between the two can­di­dates, with you hold­ing an invi­ta­tion to join that con­ver­sa­tion. And again, I will give out the phone num­ber a lit­tle bit later for you to join the con­ver­sa­tion. So rather than open­ing state­ments in this con­ver­sa­tion, let me briefly intro­duce the two can­di­dates. Kathy Vaughn is seek­ing her third term as PUD Com­mis­sioner. First elected in 1995 [sic], the first woman to be elected to the PUD, and she is cur­rently serv­ing as the Commission’s Pres­i­dent. In her other life, she is owner of Gold­mark Finan­cial Cor­po­ra­tion, a Sno­homish County mort­gage com­pany, so maybe later we can talk about the health of the hous­ing mar­ket if things get dull talk­ing about the PUD. And Eric Tee­gar­den is chal­leng­ing Ms. Vaughn. He is a civil engi­neer and envi­ron­men­tal sci­en­tist. He has a Mas­ters in Envi­ron­men­tal Sci­ence and a Bachelor’s in Civil Engi­neer­ing. He ran for PUD Com­mis­sioner, if his name is famil­iar to you, about 6 years ago.

First of all, may I call you Kathy and Eric?

KV: Please.


EB: Just a cou­ple of ques­tions for you Kathy. Is the posi­tion of Pres­i­dent rotat­ing or is the office voted on by the other two Commissioners?

KV: It is a rotat­ing position.

EB: OK. And, um, we’re talk­ing about the posi­tion of Dis­trict 2 Com­mis­sioner. Are the bound­aries of Dis­trict 2 easy to define on radio and does the con­cept of “dis­trict” have a sig­nif­i­cance once some­one gets on the Com­mis­sion? By that I mean are the respon­si­bil­i­ties and the work­load divided up by dis­trict among the Commissioners?

KV: First of all, the dis­trict is South County, mostly Edmonds, Wood­way, Mount­lake Ter­race, parts of Lyn­nwood, Muk­il­teo, kind of dodg­ing into Everett there. We’ve just re-​done the bound­ary dis­tricts you know, so re-​districting also hit the PUD. Now, as far as our duties, each Com­mis­sioner rep­re­sents all of Sno­homish County and Camano Island and we do not divide up based off of any territories.

EB: This will become impor­tant because a lit­tle bit later we will want to talk about Eric’s idea of expand­ing the Com­mis­sion to five, with two at-​large. But we’ll hold that for a lit­tle bit later. For both of you: Pres­i­dent Obama is widely quoted as say­ing his goal for the United States is energy inde­pen­dent and his method of obtain­ing it is an All-​Of-​The-​Above pol­icy, which I take to mean coal, nat­ural gas, and alter­na­tive energy sources—even nuclear—as viable options for achiev­ing that goal. So Eric, let me ask how you feel about an all-​of-​the-​above pol­icy and then I will also get Kathy to talk about that.

ET: Well let me start out by say­ing that there is no such thing as Clean Coal. I think Kathy and I can both agree on that. That said, you’ll hear the coal indus­try say that we have a 200 year sup­ply for our coun­try. This is also a delu­sion. The real­ity is we have about maybe a decade or two decades left of low cost coal. The high qual­ity coal was burned way back in the ‘50’s. We’ve actu­ally run out of anthracite. This was the high­est qual­ity of coal. That was burned for indus­trial uses pri­mar­ily back at the turn of the cen­tury on to the 1950’s. The kind of coal we’re get­ting out of the ground now is low qual­ity, high sul­fur, coal in Mon­tana, Wyoming, much of the west. The coal we’re get­ting out of Appalachia is requir­ing blast­ing entire moun­tains to get at coal seams maybe 10 feet thick. When you fold in the envi­ron­men­tal costs, that’s why I say there is no such thing as clean coal. You can scrub the exhaust, get the nas­ties out, the mer­cury and the heavy metals-​cadmium. You’re still going to be dump­ing lots of CO2 in the atmos­phere. So short answer: Coal is not the answer. As far as renew­ables go, my approach is that each type of renew­able energy has its Best Use, has its advan­tages and its dis­ad­van­tages. What I would want to focus on, if I were Com­mis­sioner, would be find­ing the Best Use for the sit­u­a­tion, whether it’s solar, wind, geot­her­mal, or hydro. There is such a thing as good hydro.

EB: We’ll talk about that later because PSE is quoted as say­ing that even Hydro is not Green. We’ll talk about that. Kathy, where does the President’s con­cept of All-​Of-​The-​Above fit into the PUD’s approach towards energy for Sno­homish County?

KV: Well, inter­est­ingly enough we’ve diver­si­fied our­self out of coal when we owned a per­cent­age of the Cen­tralia Cal Pack back in the 90’s. So we don’t have that in our coal mix other than when you look at your bill any time you’re trad­ing power on the open mar­ket to bal­ance the State requires us to not….. we don’t know where all those elec­tions are com­ing from so if you look on the bill for the mix of what we have, you will see that coal is rep­re­sented there because we can’t acknowl­edge or under­stand what is in …. where the elec­tions are com­ing from at that point in time for any­thing that we’re trad­ing on the mar­ket for bal­anc­ing for our load. But I would say that Sno­homish PUD con­sid­ers them­selves, umm, very diver­si­fied and when you say All And Every­thing I think you’re going to find that’s what you’ve seen our util­ity do. Besides our hydro and all of the hydro projects that we have, we also have wind, we also have solar, we also have bio­mass, we also have bio­gas, we also have, umm, let’s see I don’t want to for­get any­thing. We have a lot of energy renew­able cred­its, we have, ahh, we’re search­ing for geot­her­mal, we look­ing at—we’re work­ing on a pilot project on tidal, umm, we’re also look­ing, or have looked a lit­tle bit, at pump stor­age areas for that and we’re right now also work­ing on bat­tery stor­age for the inter­me­di­ate resources such as wind and solar that you can’t use as a base load.

EB: A lit­tle bit later we’ll get into tidal and we’ll also touch on geot­her­mal as well this evening. We’re talk­ing with the two can­di­dates for Sno­homish County PUD Com­mis­sioner, Eric Tee­gar­den and Kathy Vaughn. Eric, you said at your web page that it’s time for new ideas and new lead­er­ship on the PUD. What are some of the old ideas that you think it’s time to replace?

ET: Well let’s start with a Com­mis­sion of three peo­ple mak­ing deci­sions for an 816 mil­lion dol­lar oper­a­tion which is 3½ times larger than Sno­homish County Gov­ern­ment which has five coun­cil mem­bers that make those deci­sions for our county. I think that back in the ‘40’s and ‘50’s when this was a much smaller county, it made sense to have three peo­ple in rota­tion every two years being elected. The prob­lem with our cur­rent style of com­mis­sion is that any res­i­dent liv­ing in the county has to wait six years to run for PUD because you have to run in your dis­trict. You can­not, if you’re liv­ing in, say, Dis­trict 2, you can’t go for Dis­trict 3 because it’s in the two year rota­tion. So that pro­vides a real length of time, I’d say almost an overly long length of time, for some­one to be in office because the longer you’re in office—this is the nature of our polit­i­cal system—there is a tremen­dous advan­tage to incum­bency. Incum­bency in and of itself has its own strength and so that’s why I’m proposing—we’ll talk about this later—but I think that adding two at-​large Com­mis­sion­ers who would be elected every two years adds a lot more vari­ety and oppor­tu­nity to the cit­i­zens of Sno­homish County.

EB: Kathy, what do you think of the idea of expand­ing the Commission?

KV: It’s a fine idea but there’s a cer­tain way it has to be pro­posed. Basi­cally it’s out­lined in the Revised Code of Wash­ing­ton of how we add it on. In Sno­homish County, any time you have a pop­u­la­tion of over half a mil­lion, we would be allowed to do that in this county. The other way that they can have five Com­mis­sion­ers is if they have gen­er­at­ing prod­ucts that gen­er­ate over 300 megawatts of power. That’s why you’ll see that Grant County and Chelan County have five Com­mis­sion­ers at that point.

EB: Who set those rules?

KV: Well, it’s the law.

EB: It’s in the legislature?

KV: Yes. So there is a sys­tem. We’ve been over the 500,000 pop­u­la­tion for a long time. This isn’t a new issue that’s com­ing up. It’s come up before, but it has to start with the pub­lic and so far there hasn’t seemed to be, umm, the pub­lic hasn’t been inter­ested in doing it. They have to do a peti­tion drive first out of a cer­tain per­cent­age based off of the last vote of a gen­eral elec­tion and then have to bring that to the PUD Board and the Board then moves it on and asks it be put on the bal­lot and then it has to be elected on the bal­lot. So there is some steps that have to be taken to be able to do this. It was some­thing that has been brought up many dif­fer­ent times over the years but it hasn’t seemed to be that the pub­lic seems to be inter­ested in going that route.

EB: Eric?

ET: Well, I would say that there is inter­est out there. There are peo­ple I’ve met with that think the three per­son Com­mis­sion is too lim­ited. I met with a 70 year old gen­tle­man in Stan­wood recently who couldn’t even reach the PUD. He didn’t have a com­puter. He’s kind of Old School when it comes to tech­nol­ogy and com­mu­ni­ca­tion. He couldn’t find a phone num­ber that he could call a Com­mis­sioner directly. So he was com­plain­ing about lack of accessibility.

EB: Well, is there any groundswell of inter­est in expand­ing the Com­mis­sion? Is there any­body who has put together a peti­tion and is plan­ning to go to the PUD, or is this anec­do­tal infor­ma­tion from peo­ple who just think, “Maybe it would be a good idea if it was bigger?”

ET: Well, I guess I’ll go on the record. If I fail to win this elec­tion, I’ll be one of those advo­cat­ing for this five per­son Com­mis­sion because I think it’s time to open it up and bring some new peo­ple, and some new ideas into the Commission.

EB: Just stay­ing with the idea of expand­ing the Commission…It’s been pro­posed and sug­gested for the Port of Everett sev­eral times that the Port expand to more than three Port Com­mis­sion­ers. One of the argu­ments that is raised against the idea is that if there are three Com­mis­sion­ers, then no two of them can get together and have a con­ver­sa­tion because that’s a meet­ing, that’s a quo­rum if two can­di­dates get together.

ET: So let me get this straight….If there are two that are rid­ing in the ele­va­tor together, say Kathy and David Aldrich are both in the ele­va­tor, they can­not talk to each other because essen­tially they’re a quorum?

EB: Can you talk busi­ness if there are two Com­mis­sion­ers together?

KV: We cer­tainly can’t make any deci­sions and nor­mally we do not talk busi­ness when we’re together about some­thing like that, no.

ET: So I would actu­ally call that a prob­lem because it seems to me that is a very low level for a quo­rum, two peo­ple stand­ing in the same room together is a quorum?

EB: Well, if there’s only three…..

ET: Well pre­cisely, so if we go to five now sud­denly three is a quo­rum. It has to be a tri­aloque essen­tially, you have to have three peo­ple talk­ing for it to become a quorum.

EB: But that’s the argu­ment that is advanced to keep it at three so that there no oppor­tu­nity for just two peo­ple to get together and make a decision.

KV: Right, kind of the back­room, smoky room kind of thing that peo­ple were con­cerned about. But it cer­tainly isn’t some­thing that we’re against. It’s some­thing that would be up to the cit­i­zens to come up with the funds to run a peti­tion drive, get enough sig­na­tures to make it work, to be able to get it to be put on the bal­lot, and then it has to be a vote of the people.

ET: You know my expe­ri­ence is that, and this is hav­ing run for City Coun­cil a few times and observed city gov­ern­ment is most of the back room deals, if you want to call it that, the smoky room you know things that are out of the pub­lic eye, are occur­ring in Exec­u­tive Ses­sion and with the staff. The staff often will pro­mul­gate things to the Com­mis­sion­ers, or to the City Coun­cil. And so those are deci­sions being made, those are dis­cus­sions that are not open to the pub­lic. So this hap­pens all the time with our local gov­ern­ment. I don’t think this is some­thing that is a prob­lem nec­es­sar­ily but I don’t think we should say that it doesn’t hap­pen or shouldn’t hap­pen, because it does happen.

KV: Well first of all, I take excep­tion to that that’s in any local gov­ern­ment and I’m here to tell you it does not hap­pen at the PUD, that we do not, umm, we do not per­form or dis­cuss any­thing in Exec­u­tive Ses­sion that’s not allowed by the law and we cer­tainly don’t dis­cuss busi­ness out in the halls, etc.

EB: There’s more to what I said though. I also said you often have the case where there is pro­fes­sional staff are pro­mul­gat­ing things to the Com­mis­sion­ers because in many cases city coun­cil peo­ple and Com­mis­sion­ers are not full time employ­ees. They sim­ply do not have the time to really delve into the engi­neer­ing and into the issues that are being dis­cussed and so they assume the infor­ma­tion is cor­rect com­ing from the staff, do not give due dili­gence to what is being pro­moted to them or pro­mul­gated to them, and make deci­sions based on par­tial infor­ma­tion. This does hap­pen all the time.

KV: Well, umm, at the PUD we are part-​time Com­mis­sion­ers, num­ber one, and we have hired expert staff. We have very good, tal­ented, staff and, umm, we do get infor­ma­tion from them. I mean that’s how you make a deci­sion. We are a pol­icy board to set pol­icy. We’re not there to tell them how many screws goes into a board for what­ever they’re going to fix. We are a pol­icy board and we want to be able to get the infor­ma­tion and decide how we’re going to do pol­icy. That does not mean that we do not do our own out­side research, or check with other util­i­ties, or check with other devel­op­ers, or check with some other things. We do our own due dili­gence also.

EB: Would you sign a peti­tion to expand the board to .…

KV: Cer­tainly.

EB: to five, it it came to you?.

KV: Sure. Absolutely.

EB: There’s your first sig­na­ture Eric.

KV: So I’m here to tell you …..

ET: No, she’ll be the sec­ond sig­na­ture. I’ll be sign­ing it first.

EB: (laughs)

KV: Like I said, it’s been brought before. I brought it up pre­vi­ously. I’m cer­tain the board is not will­ing to not be for it at that point.

EB: We’re talk­ing this evening with the two can­di­dates for Sno­homish County PUD, Eric Tee­gar­den and Kathy Vaughn. In a few moments we’ll invite you to join the con­ver­sa­tion. Kathy, you’ve been on the Com­mis­sion for 18 years, this is ….

KV: Right.

EB: This is your third term.

KV: My fourth term.

EB: Fourth term, excuse me.

KV: It would be my fourth term.

EB: You’re also the longest serv­ing Commissioner…

KV: That’s cor­rect.
EB: At what point does time on the Com­mis­sion become, “We’ve always done it this way, this is why we have to do it?” At what point does the Com­mis­sion become hide-​bound, that they’ve all been on the Com­mis­sion so long that new ideas are sus­pect because they are new ideas?

KV: Well, umm, I don’t think you’ll find that that’s been my think­ing over the years and I’ve had five dif­fer­ent make-​up of boards in my 18 years and I don’t believe that we ever come about to the point where we don’t re-​look at issues if there’s some­thing new to look at. And I think you’re going to see that we’ve been very pro­gres­sive on every­thing that we’ve done and how we’re mov­ing for­ward with the util­ity. We have received a lot of awards region­ally and nation­ally for how pro­gres­sive we are, and are always look­ing at new ideas, and I guess you’d have to take it from each indi­vid­ual Com­mis­sion­ers to make a deci­sion if you feel they’ve been there too long and they have no new ideas, or they’re not will­ing to go along with new ideas and take a look at issues.

EB: Eric, that brings us back to your idea of the at-​large Com­mis­sion­ers. Can some­one really get a han­dle on what needs to be done in two years? Can they even find where the bath­room is in two years to be on that Com­mis­sion and then maybe they’re voted off again and then there’s a brand new per­son with no expe­ri­ence com­ing on for just two years?

ET: Let me just say that I think pol­i­tics is one of the few pro­fes­sions where too much expe­ri­ence can be a prob­lem. One of the great­est prob­lems with Amer­i­can, espe­cially Fed­eral, pol­i­tics is that we have Sen­a­tors and Rep­re­sen­ta­tives that have been in it for more than a gen­er­a­tion. In some cases, Strom Thur­man for exam­ple, was in …. He ran against Harry Tru­man in 1948 for Pres­i­dent and he was in the US Sen­ate for, I think, close to 70 years or some ridicu­lous num­ber like that. I think at that point, yes, you can say that, “That per­son is out of touch with real­ity”, hon­estly when they’ve been there that long. So there is some­thing to be said for hav­ing fresh ideas, fresh peo­ple, a cycle, I mean that’s the whole idea of hav­ing an elec­tive gov­ern­ment is we have the oppor­tu­nity for new peo­ple and new ideas.

EB: We’re going to open up the tele­phones and invite you to call us at 425–303-9070 this evening. We’re talk­ing with the two can­di­dates for Sno­homish County PUD Com­mis­sioner. Again, if you’d like to join the con­ver­sa­tion, the phone num­ber is 425–303-9070. I know that on the list of many peo­ple to talk about is Sun­set Falls and I want to hold that con­ver­sa­tion. But I want to talk first about geot­her­mal because the PUD recently gave up on their geot­her­mal effort in the Index area because you hit bedrock. You spent about 3 mil­lion dol­lars for that search in the Index area. Now, as I under­stand it, you’re look­ing into the Mt. St. Helens area and the Colum­bia River area, is that cor­rect, for geothermal?

KV: Umm, well we haven’t given up on geot­her­mal at all. If you look at our resource port­fo­lio issued, Inte­grated Resource Port­fo­lio Plan, we see geot­her­mal as a good base load that we will use in the future for the PUD to help with our growth. And we are look­ing in dif­fer­ent areas, part­ner­ing with the Depart­ment of Nat­ural Resources in the State of Wash­ing­ton. There’s been a lot of research on geot­her­mal in the last 30–40 years that stud­ies have been done in Wash­ing­ton State and we are look­ing in areas such as in the Mt. Baker region. We’re look­ing at the Mt. St. Helens region, maybe down in the Ska­ma­nia area. When we talk about our back­yard, we’re talk­ing about West­ern Wash­ing­ton can be part of our back­yard as we look for a geot­her­mal source.

EB: Eric?

ET: So I think we should really look in our back­yard lit­er­ally. There are plenty of back­yards in Sno­homish County that could be great for geot­her­mal. I’m talk­ing about geot­her­mal with a small “g” ver­sus deep geot­her­mal with a cap­i­tal “G”.

EB: You’ll have to explain the difference.

KV: All right, so umm, basi­cally the core of the earth is a giant fis­sion reac­tor. It’s radioac­tive; ura­nium sank to the cen­ter of the earth and it’s been basi­cally fis­sion­ing for close to five mil­lion (??bil­lion??) years. That’s the source of the heat that causes vol­ca­noes and such but the thing is, there is also a ther­mal gra­di­ent. You go down two meters into the earth, six feet approx­i­mately, and you have a uni­form tem­per­a­ture year around. It’s roughly 50–55 degrees. Now you can run flu­ids right down there in those trenches, antifreeze typ­i­cally, like a _​_​_​_​_​_​_​_​_​_​antifreeze, absorb that heat and now you’ve got a ground source loop for a ground source heat pump that uses about half as much energy as a con­ven­tional heat pump. That’s some­thing you can install in almost any back­yard. If you’ve got land, it’s great because you could do shal­low trenches but you could actu­ally go down in the earth 200 feet, 150 feet down, do a shal­low well, and run the closed loops that way. Same thing, you’re get­ting heat out of the earth. That is some­thing you can do almost any­where in Sno­homish County. You don’t have to make these gigan­tic projects that require mas­sive invest­ments of pub­lic funds. We can actu­ally allow home­own­ers to front the money. Maybe the PUD will cover a good chunk of the cost, or give it a nice rebate like we do for Solar Express and we pro­vide ways for peo­ple to get over the hump and actu­ally do these projects, thou­sands of projects through­out the county. This is a bad econ­omy; it’s prob­a­bly going to get worse. I say that because we’re going through petro­leum deple­tion and our entire econ­omy rests on that.

EB: Kathy, can the Solar Express con­cept where small loans are made avail­able for the instal­la­tion of solar power be extended to geot­her­mal or do you have to do these mas­sive projects?

KV: Well, it’s inter­est­ing that you bring that up because we have that pro­gram for small geot­her­mals, for geot­her­mal heat pumps for indi­vid­ual homes, and we have that already. We have either an incen­tive of $800.00 towards it, or we will do a loan up to $6,000.00. So it’s the same con­cept that we’re doing for solar. And it’s been going on for a long time, and it’s available.

EB: What’s the cost for doing that? Where does that $800.00 or that $6,000.00 fall with regards to what the over­all cost is?

KV: Well, I think the cost is prob­a­bly, umm, as I under­stand, it runs some­where between $12,000.00 and $20,000.00 depend­ing on how big you’re dig­ging and it depends on how big your lot is, and where you’re going to run it, if you’re doing it with a well or if you’re run­ning deep trenches.

EB: I don’t think you could do it in my back­yard. I’ve got a pretty small backyard.

KV: Not a lot of them can do it. It’s prob­a­bly bet­ter use for new con­struc­tion and usu­ally bet­ter use out in the rural areas for new con­struc­tion. Actu­ally my hus­band and I are get­ting ready to build our retire­ment home up on prop­erty that we have out in Dar­ring­ton, and we’re putting in a geot­her­mal system.

ET: So I guess what I was talk­ing about was the scale. I was aware that what she was talk­ing about already has some incen­tives through PUD, but I want to basi­cally expand it, to pro­vide bet­ter incen­tives because $6,000.00 doesn’t go very far if we’re talk­ing about a $12,000 — $18,000.00, maybe a $24,000.00 sys­tem. We could per­haps have larger loans, up to maybe $20,000, cap to $20,000, and per­haps the rebate could be extended to a big­ger chunk, maybe instead of $800.00 we go could to $2,400.00. So now you’re talk­ing about 10% of a $24,000.00 sys­tem; that’s essen­tially a 10% rebate on the sys­tem. The thing is, the money is there. If we’re going to spend 3.4 mil­lion on one sin­gle geot­her­mal project, if that money had been spread around over to, say, 100 projects, that’s some seri­ous money being spread around.

EB: What about that, 3 mil­lion dol­lars to come up empty?

KV: Well I wouldn’t say it was so much we came up empty. We learned a lot from it and that’s what it was. It was an explo­ration that we were doing to take a look and see where we’re at for this kind of resource. For­tu­nately we had been using grant funds to be able to do that and with a lot of dif­fer­ent funds that have come in from the state and the fed­eral gov­ern­ment, they’re inter­ested in see­ing for geot­her­mal here in the State of Wash­ing­ton. There’s new geot­her­mal plants being built in the State of Ore­gon and some in Idaho and they wanted to see if there was _​_​_​_​_​_​_​_​_​_​_​_​(?search?) there and they came to us as the largest PUD in the State and one of the larger util­i­ties in the State. We were work­ing together to see where we’re at. And we learned a lot from it. There was a lot of, you know, we did our, ahh, the begin­ning drilling that we did for tem­per­ate tem­per­a­tures at about 5–700 feet (might have meant 500 to 700 feet) and it said it was good tem­per­ate cli­mate for it but you never know what’s below that. We couldn’t move out of the foot­print we were in because of the Wild Sky lim­its within that area where we were drilling at that point.

EB: Eric, had that money been spread out over other projects, they wouldn’t know that they couldn’t do geot­her­mal in that region?

ET: Well, again I think the geol­ogy would have….if we had done a lit­tle more back­ground research ahead of time…and this is where per­haps hav­ing some­one with a lit­tle more geo­log­i­cal background…my first Bachelor’s was actu­ally in geo­physics from Texas A&M before I got my Civil degree from New Mex­ico State Uni­ver­sity. That said, I would have been very skep­ti­cal about these deep geot­her­mal projects because even if you find geot­her­mal heat, the ques­tion is, How do you har­ness it? If you’re talk­ing about a closed loop to run flu­ids down and cap­ture that heat, this is a really cor­ro­sive envi­ron­ment down, a mile down perhaps.

EB: Isn’t Ice­land entirely geothermal?

ET: Absolutely, but you’ve got to real­ize Ice­land is smack in the mid­dle of the mid-​Atlantic rift where basi­cally the whole ocean is being ripped apart and they’ve got fresh access to con­stant vol­can­ism. And then you’ve got a hot spot that is sit­ting right there on that rift and it’s gen­er­at­ing a lot of heat.

EB: Well, we have Mt. St. Helens. We’ve have Mt. Baker.

KV: Right. We’re in the Ring of Fire within this area.

ET: That’s a very, very dif­fer­ent geol­ogy. The geol­ogy we’re talk­ing about here is the Juan de Fuca Plate sub­duct­ing under the North Amer­i­can Plate. That’s a very cool strata; it’s oceanic junk basi­cally with sed­i­ment going under­neath the North Amer­i­can Plate so the kind of vol­can­ism you’re get­ting is much richer and moister. It has a lot of water, it has a lot of alu­minum, a lot of sil­ica. It gen­er­ates more of a granitic style of rock which is much more vis­cous than the kind of Hawai­ian style high iron, high mag­ne­sium, rock you get which has a very low vis­cos­ity; it runs eas­ily down the vol­cano. Because it has such a high vis­cos­ity, that’s why you have these hor­ri­bly vio­lent erup­tions like Mt. St. Helens where they are explo­sive. Because the pres­sure builds and builds and builds, because it’s such high vis­cos­ity it can’t escape; and then when it finally does break through, it’s an explo­sion. So, yeah, the geol­ogy is not the right kind of geol­ogy to be doing geot­her­mal here in West­ern Washington.

EB: We’re talk­ing this evening with the two can­di­dates for Sno­homish County PUD and we’ve got a caller on the line with us. Andrea is join­ing us, from Index inter­est­ingly enough. Andrea, thank you for talk­ing with us tonight.

Caller Andrea: Hi. My ques­tion is for Kathy. I was won­der­ing why, with some many other oppor­tu­ni­ties for renew­ables, $150,000.00 to study some­thing that gives so lit­tle power, I’m talk­ing about Sun­set Falls. I think the FERC appli­ca­tion has like 14 megawatts. That’s over 10 mil­lion dol­lars a megawatt where I know that Bon­neville, for instance, did upgrades that came in at 1.5 mil­lion dol­lars a megawatt. I’m just won­der­ing why such a huge expen­di­ture when there’s so many bet­ter deals out there.

EB: Andrea, you were look­ing ahead at my notes, weren’t you?

Caller Andrea: I saw them, yeah.

KV: First of all, let me explain….That that would be great if Bon­neville could do their incre­men­tal hydro re-​winding and improve­ments to the tur­bines. We have noth­ing to say about that. We are a Bon­neville cus­tomer; we are their largest cus­tomer; we get 11% of the power that comes out of that. That’s not a deci­sion we’ve made. We feel that, as a board, we feel as though it’s impor­tant for us to own some of our own resources and we are look­ing around. We’ve actu­ally devel­oped two other small hydros. We have two more in King County that we’re tak­ing over to re-​develop and the rea­son we’re doing that is because we believe it is going to be very impor­tant in the future to have the base load. We have a pop­u­la­tion growth pro­jec­tion that shows that we’re going to have a mil­lion peo­ple here in Sno­homish County in the next 20–30 years and there needs to be base load to be able to bring in the renew­ables that we have. As you look at a new con­struc­tion of a dam, this is low impact dams that we’re talk­ing about, their life spans are going to be 50–100 years. When you look at that, you’re going to have very low costs, espe­cially as rates and costs for the incre­men­tal new resources that we’re going to need are going to be there. So, as we look at all these dif­fer­ent projects, we have our lit­tle low impact dams that are com­ing in at about $61.00 a megawatt hour. That’s lower than any other new resource that we can come up with. Our _​_​_​_​_​_​_​_​_​_​(?avoid a?) cost seems to be run­ning some­where between $70.00 and $90.00 amongst that, and that’s what we’re using such as our Solar Express. That’s run­ning about $85.00 a megawatt hour. You know, a lot of our other things are run­ning more. Wind is run­ning approx­i­mately $97.00 a megawatt hour. Farm-​based solar is going to run from $150.00 to $200.00 a megawatt hour. So we’re look­ing to be able to have resources that we can own, that we can add to our Bon­neville load which is the basis for all of our electricity.

EB: Eric?

ET: Well let me just men­tion that there is no such thing as low impact hydro, if we’re talk­ing about the project such as the Sun­set Falls hydro project. To build this dam, they’re going to have to dyna­mite through about a mile of solid gran­ite [actu­ally about 2,000 feet], a 17 foot diam­e­ter tun­nel [a 19 foot tun­nel is in SnoPUD’s pro­posal]. They’re also going to have to siphon off as much as 90% of the river at cer­tain times of the year to gen­er­ate power with 15 megawatt twin tur­bines. This is if we can actu­ally see this built as it has been pro­posed. What I’ve heard, and this is second-​hand infor­ma­tion, but what I’ve heard is that they can­not reach bedrock on one side of where they plan to put this weir that’s been adver­tised as the pre­ferred design. If so, they can­not build it there, because they can­not build a load-​bearing struc­ture with­out actu­ally being able to anchor into bedrock. So the ques­tion arises: Where are they going to build it if they can’t build it there? The other issue is, even if they can build it where they’re propos­ing to build it, the Skykomish is a dirty river. It’s loaded with sed­i­ment; it’s loaded with whole trees com­ing down the river. What’s a tree going to do to this metal weir, this steel weir, repeated bat­ter­ing over time? It’s going to def­i­nitely cause some dam­age to the weir. I’m skep­ti­cal that this dam, as it’s cur­rently pro­posed, could last 50–100 years.

KV: Well inter­est­ingly enough we are in our study phase for Sun­set Falls. Those are ques­tions that are going to be answered as we go through our study phase. We were given a per­mit by the Fed­eral Energy Reg­u­la­tory Com­mis­sion to do the study. There’s plenty of work that we are work­ing on and being done. A lot of it has to do with what is bedrock where we’re at. We have many agen­cies that we’re work­ing with. We work with the Wash­ing­ton State Fish and Wildlife. We’re hav­ing to work with the U.S. Fish and Wildlife. We’re work­ing with the local tribes. We’ve been work­ing with the Depart­ment of Ecol­ogy. We have a lot of non-​governmental groups that are dis­cussing a lot of dif­fer­ent projects. So, we’re in the Study Phase, there’s no deci­sion made, we haven’t made a deci­sion to know whether it can be done or it can’t be done. This is a lit­tle dif­fer­ent design than any of the times that it was pro­posed back in the ‘40’s, 50’s, ‘70’s, ‘80’s by dif­fer­ent util­i­ties, includ­ing Sno­homish PUD have looked at it back in the ’70-’80 period.

EB: I’ve read that you have made some strate­gic land pur­chases for this. That seems more con­fi­dent than just, “We’re doing the study for it.”

KV: There were some parcels that we pur­chased that were going to tax sale, that we felt that if this does come through we were going to need those pur­chases to put either a power house or an intake area, or some­thing like that. But if not, then they’ll go back on the market.

EB: Well let me ask you this before we go…..Andrea, have we answered your ques­tion for you?

Caller Andrea: Well the basic ques­tion, I guess. I was won­der­ing as a follow-​up, why not use some of the data from the other stud­ies. Why study it again?

KV: Well because those stud­ies are out of date, num­ber one, and num­ber two, this is a dif­fer­ent design. This is not a con­crete dam that is going to go in there and block the water. And we aren’t talk­ing about de-​watering the river at any time. There will be times that we will not be pro­duc­ing power out of that river, espe­cially dur­ing the sum­mer time. First of all, the lead agency is the Depart­ment of Fish and Wildlife and the Fish­eries. They cer­tainly are going to require us to have water in there for the fish. So it’s not as though we are going to be run­ning power through there con­stantly, 365, 24/​7. This will really be used when we really need the excess power, mostly dur­ing the win­ter time when the river is high and some­times even dur­ing flood times. This would help con­trol some of those floods as the water comes through.

EB: Andrea, thank you for call­ing this evening. We’ve got Lynne wait­ing from Index and also Terry in Marysville, so we want move for­ward but I want to give Eric an oppor­tu­nity to respond.

ET: Well, I’ll just say that I’m con­cerned that the fry are going to fry at cer­tain times of the year because even a small diver­sion of water at cer­tain times of the year will pre­vent the fry from return­ing down the river if there’s not enough vol­ume of flow in that crit­i­cal area such as Canyon Falls. The water tem­per­a­ture is going to rise and the fish are going to die.

EB: Well OK. Then let me ask you this Kathy. Why this river, this spot? This is a river, the Skykomish river, that accord­ing to the State, is one of only four rivers that are labeled as a state scenic water­way. It is the last free-​flowing river in the County and it has been called one of the most beau­ti­ful sets of falls in Wash­ing­ton State. So why that river, and all the cor­re­spond­ing headaches that you’re going to have to deal with to go for­ward with the project?

KV: Well because the river has poten­tial to work with­out de-​watering it, with­out ruin­ing the aes­thet­ics of it, with­out cre­at­ing dead fry, cook­ing the fry in the river. I guess that’s kind of what Eric was say­ing. Well, we can fry it, or cook it, or boil it, or how­ever you want to do it. The point is that’s what we’re going to do.

EB: There’s also endan­gered bull­head at that river site as well.

KV: Well we’re work­ing with Fish and Wildlife and they’re the ones who would instruct where we would be and where we wouldn’t be. Like I said, this isn’t a done deal. We’ve had two small dams that we’ve put up lately, low impact hydro dams and all of them are above fish bar­ri­ers. That’s where this would be. They would still have the trap and haul issues so we would be able to con­tinue that and restore that which was devel­oped in 1950 [1958] and is in dis­re­pair and not doing very well for the fish at the moment. We also have looked at other projects. I mean there’s more than this one that we’ve looked at. We’ve prob­a­bly looked at 100 dif­fer­ent projects within the Puget Sound, not even the Puget Sound, but the Cas­cade area. As a mat­ter of fact we’ve had one project that we just looked at that would pro­duce a lot more water but we , as a board, we elected not to…you know the fea­si­bil­ity of it wasn’t that good, the cost of it wasn’t that good. Those are items that we will go through once you get full facts and all the infor­ma­tion. You can’t make a deci­sion with­out that, and that’s what we will do. We’ll take a look at it, and that’s why we’re going through the study period.

EB: Mary, or rather, Terry in Marysville has been very patient and Lynne in Index is being very patient as well. But let’s invite Terry from Marysville to join us this evening. Thank you for join­ing us tonight.

Caller Terry: Oh, thank you for hav­ing me on. Partly my ques­tion has been answered to some degree but, again, I’d like to say given the four pre­vi­ous stud­ies for via­bil­ity using hydro power at Sun­set Falls, they were all deter­mined to be un-​usable and the voter man­dates of I-​937 specif­i­cally exclude new impound­ments. There is also wide­spread pub­lic oppo­si­tion. So, my ques­tion is, how Kathy Vaughn can approve spend­ing 1.7 mil­lion ratepayer dol­lars to do another study on a dam that’s des­ig­nated Wild and Scenic?

EB: All right, let’s see if we can find an answer to that.

KV: OK, well as I said, we’re look­ing at the study. We are using resource funds that we have that we have put away for new resources and we plan to do a thor­ough study and make sure that we have every­thing cov­ered before there’s a deci­sion that would be made. I think it is very impor­tant that we look at all resources that we are going to use. Now, you talk about I-​937, umm, the I-​937 ini­tia­tive did not include hydro because oth­er­wise you wouldn’t have to have other new renew­ables built because we’ve got plenty of hydro. We, at Sno­homish, still feel that hydro­elec­tric power is renew­able but it’s not I-​937 eli­gi­ble. It doesn’t need to be eli­gi­ble for us to be able to build it as a base load that we need for future growth within the community.

EB: I should just inter­ject here that I-​937 was a voter approved man­date that, by 2020, 15% of the power needs to be from renew­able resources and fresh water was excluded from that. So putting a dam here doesn’t give you addi­tional cred­i­bil­ity for that I-​937.

ET: How­ever, improve­ments to exist­ing hydro built prior to, I think it was a date in 1999, prior to that date any improve­ments to those old hydro facil­i­ties like Jack­son Hydro for exam­ple, do qual­ify for REC’s, Wash­ing­ton credits.

KV: Right, and we also received that. We will get approval with our Woods Creek which we did do, which was a pre­vi­ous hydro that we pur­chased, we rebuilt, and we are get­ting I-​937 cred­its for that. Now, at the PUD because we have always been pro­gres­sive and looked for­ward we have brought on a lot of the Solar Express. We’ve brought on our wind. We’ve brought on a lot of dif­fer­ent things that already meet the qual­i­fi­ca­tions for I-​937 up to the year 2019. So these projects we’re look­ing at as long term, base load, needed in the future projects that we’re putting together. This isn’t even a project that we’re talk­ing about that would be done within the next 2–3-4 years. This is fur­ther out than that.

EB: Terry, thanks for call­ing tonight. I want to give Lynne an oppor­tu­nity. Also, Lynne is call­ing from Index tonight. Lynne, thank you for your patience.

Caller Lynne: Thank you for the opportunity.

EB: You have a ques­tion for Eric or for Kathy?

Caller Lynne: Well my first ques­tion is in two parts if I may and it’s for Com­mis­sioner Vaughn. The gen­eral man­ager, Steve Klein’s web page states that PUD will not even con­sider hydro power any­where where there are endan­gered species and yet it’s given that there at least seven species in the South Fork of the Skykomish. I under­stand the trap and haul facil­ity at Sun­set Falls could cre­ate a huge loop­hole for you and enhances the fish pop­u­la­tion above the falls. I have yet to have to have it explained to me how the smolts and fin­ger­lings that are hatched above the falls will make it back down­stream past the pro­posed dam, and tur­bines, and the tun­nels, and the grate to com­plete their life cycle. Do you plan to mit­i­gate this loss with hatch­ery fish? The sec­ond part of my ques­tion is: How can you jus­tify seiz­ing pri­vate prop­erty under emi­nent domain for such a small amount of power? Thank you.

EB: Thank you.

KV: Well, first off I can’t answer that ques­tion regard­ing hatch­ery fish because I don’t have the infor­ma­tion in front of me yet because we’re not done with the study. As far as emi­nent domain, I don’t believe that we have any rea­son to take any pri­vate prop­erty for emi­nent domain. That’s why we pur­chased some of the lots that we did that were avail­able to make sure that we had prop­erty that was pre­pared and nec­es­sary for what our pur­poses were going to be.

EB: We’re talk­ing this evening with the two can­di­dates for the PUD Com­mis­sion, dis­trict 2, Eric Tee­gar­den and Kathy Vaughn. If you’d like to join our con­ver­sa­tion, 425–303-9070. I under­stand that the Grand Coulee Dam is going under some upgrades and there’re going to get, for about 300 mil­lion dol­lars, about 240 addi­tional megawatts. Are all of the dams in Wash­ing­ton State at max­i­mum capac­ity and have been upgraded to the great­est extent pos­si­ble to get the most megawatts from them?

KV: I can’t tell you that for sure because we don’t oper­ate those dams.

EB: Well…

KV: There’s a lot of dams on there. I know they’re going to work on Grand Coulee. I’m not sure if they’re look­ing at Chief Joseph. A lot of those dams are owned by dif­fer­ent enti­ties. Some are the Corps of Engi­neers, some of them are owned by PUD’s over in East­ern Wash­ing­ton, some of them are owned by Seat­tle City Light [and the Bon­neville dam] (???).

EB: Should that be explored before new dams are built, that the dams we have have peak oper­at­ing effi­ciency, Jack­son for example?

KV: Well Jack­son, we upgraded that back in the late ‘80’s and we have looked at that. We have Jack­son. We have two dams we’re work­ing on in King County which is Cal­li­gan and Han­cock that are going to be devel­oped. We’re also….those are the only ones we have. We have Youngs Creek that we just did that we received a national award for and then we’ve taken care of Woods Creek also which we bought as a dilap­i­dated pre­vi­ous hydro sys­tem that we did upgrade and renew, and we are get­ting energy cred­its for that.

EB: We are on KSER tonight with the two can­di­dates for Sno­homish County PUD Com­mis­sioner. If you’d like to join us, it’s 425–303-9070. Eric, you set out as one of your pri­or­i­ties, if elected, bet­ter incen­tives for home­own­ers to replace inef­fi­cient appli­ances, upscal­ing Solar Express, and adding 25 megawatts of renew­able energy to the PUD mix over the next ten years. Where does the money come from for these incen­tives to replace inef­fi­cient appliances?

ET: Well bulk of the money will come from the indi­vid­ual home­owner or busi­ness. The bal­ance of it will come from the PUD as incen­tives, or as loans. The loans will be repayable over time.

EB: Where does the PUD get the money to give out more money as incentives?

ET: By not build­ing a 170 mil­lion dol­lar dam and putting some of that money into these small pro­grams, thou­sands of projects through­out the County.

EB: Have you peaked out in terms of, to coin a phrase, incentives?

KV: Not at all, we’ve got plenty of incen­tives. We have incen­tives for appli­ances. Actu­ally, over this year, we dis­trib­uted over 70,000 com­pact flu­o­res­cent light bulbs, we’ve done 19,000 of what we call E-​Kits. Those are the ones that have energy effi­cient kits that con­tain the low-​flow shower heads, the faucet heads, and the com­pact flu­o­res­cents. And also we’re look­ing at LED lamps and going into those too. We’ve done 14,000 effi­cient appli­ance rebates for installed new appli­ances, that peo­ple are pur­chas­ing them. We do have incen­tives for that. Over the last decade, with our com­pact flu­o­res­cent bulb, we’ve put out over 4½ mil­lion bulbs. That’s almost 10+ per home within the county and Camano Island. So we have all these incen­tives. We’re still run­ning those pro­grams. We also have the incen­tive for the extra garage refrig­er­a­tor, you know, where you take your old refrig­er­a­tor and put it in the garage and use it to store your pop and your beer and extra things like that. We have an incen­tive pro­gram for that, for those and freez­ers to be picked up and removed and paid for for them and they get a cash incen­tive for that one. You know we have our Grass Roots pro­gram which is com­mu­nity power which helps sup­port energy effi­ciency in under­served areas. Most of those are going to be in low income apart­ment houses and things like that. We go in and work with the low income peo­ple them­selves to reduce their bill. These are part of our con­ver­sa­tion programs.

EB: Well let me ask Eric, What are they not doing that they should be doing?

ET: We need a deeper level of care and com­mit­ment. We need to go a lot deeper into where the energy load and the energy usage is. Ear­lier we were talk­ing about win­ter time….

EB: What does that mean?

ET: I’m almost there…Earlier we were talk­ing about how we need to increase win­ter base load to cover the demand. That’s because so many peo­ple are still using incred­i­bly inef­fi­cient ways of heat­ing their homes. Base­board heat­ing, for exam­ple, turn­ing your house into a giant toaster oven essen­tially. Peo­ple who have, and I see this every day work­ing with cus­tomers, I look at their power bills. In the sum­mer they’re using maybe 12 kilo­watt hours per day. In the win­ter time I see this gigan­tic spike, up to four or times as much power usage. I know right away that’s a pro­file of some­one who’s got base­board heat­ing in their homes. These are ‘50’s and ‘60’s homes, and back then power was so cheap it made sense to use base­board heat­ing to heat homes as a mod­u­lar way, a room-​by-​room heat­ing sys­tem. Now, it’s incred­i­bly waste­ful, incred­i­bly expen­sive. So what if we actu­ally pro­vide seri­ous incen­tives for folks to rip those sys­tems out and replace them with much more effi­cient heat­ing sys­tems? That’s what I’m talk­ing about, putting sig­nif­i­cant chunks of money, thou­sands of dol­lars, per home­owner poten­tially, as incen­tives to get this old stuff out and get much bet­ter heat­ing sys­tems in. Imag­ine the jobs through­out the county that would create.

EB: We’re run­ning close to the end of the pro­gram. I do want to get Howie in. Howie is join­ing us from Everett this evening. Howie, thanks for join­ing us tonight on KSER.

Caller Howie: You’re wel­come. Thank you for hav­ing both can­di­dates. I have a ques­tion about Hat Island for Kathy. I’ll try to be real quick. I know the Hat Island peo­ple are very con­cerned about their power rates going up. Would it be pos­si­ble for the PUD to issue 100 year bonds? I know I’ve read about some munic­i­pal­i­ties issu­ing 100 year bonds. At this low, low, inter­est rate that might be as low as they’ll be for 100 years, then as long as the PUD and the bond peo­ple _​_​_​_​_​_​_​_​_​_​_​_​_​(???), you could lower the rates…you wouldn’t have to raise the rates to the home­own­ers on Hat Island as much.

KV: The peo­ple on Hat Island, when they came to the Sno­homish County PUD in the 1970’s, signed agree­ments that said, because it costs more to serve them being on a pri­vate island, that they would pay a cer­tain per­cent­age over their rates. That they still do, and we’re not rais­ing their rates. What we are doing is, there also in that agree­ment was stat­ing that they would also be pay­ing a sur­charge to replace that under­wa­ter marine cable that serves them. We took a look at where we were at on that and it looks like it’s going to cost them $17.86 a month to be able to go into the fund to be able to replace that under­ground [sic] cable. They are a pri­vate island. We don’t really have…..you know peo­ple don’t have a lot of con­trol for that. As this became an issue in the news­pa­per, I’ve had many peo­ple from Sno­homish PUD that do not have prop­erty on there tell me they did not feel it was their respon­si­bil­ity to have to pay for this under­ground [sic] cable. We came up with a pro­gram that we would inject that cable that they have now that is start­ing to fail and it would keep it going for ten years, and we are going to pay for that part. But the $17.00 sur­charge, or the $17.56 sur­charge, it does not affect their rates, their rates are not going up, umm, that would be billed monthly to be put away for when the cable does have to be replaced, prob­a­bly in ten years. That cable then would have a 60 year life. I mean the one they have now has had almost a 50 year life, but it is wear­ing out and it needs to be replaced.

EB: What about the idea of the 100 year bonds though?

KV: I don’t know much about that. We haven’t bonded out that far on almost any­thing we’ve done.

EB: Howie, thanks.

Caller Howie: May I just men­tion Kathy that, in ten years you won’t have the rates you have now. This is a very unusual sit­u­a­tion where the rates are prob­a­bly as low as they’ll ever be, or as they might be for 100 years, and so get­ting the job done now should be looked into I would think.

KV: Well I don’t know if we can bor­row money on some­thing that’s pro­posed ten years from now, but I will check into it. I agree, rates are low. We have done that, we….I under­stand how low the rates are.

EB: Howie, I want to get on to Laura, so I appre­ci­ate your call, really.

Caller Howie: You’re welcome.

EB: Howie from Everett join­ing us. Next we have Laura from Gold Bar. Laura, thanks for join­ing us this evening.

Caller Laura: Oh, thank you for let­ting me come on. I’m respond­ing and ask­ing a ques­tion based on I think a state­ment about the trap and haul need­ing to be updated and SnoPUD doing that. My ques­tion is, The Depart­ment of Fish and Wildlife, as I under­stand it, has said they have funds set aside to improve the trap and haul. That seems to be in con­flict with the pre­vi­ous state­ment, so you could give me some clar­i­fi­ca­tion on that?

KV: I wouldn’t say it’s in con­flict because, if Snohomish….once the stud­ies are done and if there’s a deci­sion made that this project would move for­ward, Sno­homish would be the one that would be doing the improve­ments. I don’t know if the State has funds or not. We were told by the Fish and Wildlife that they don’t have a lot of funds to work with because the bud­gets have been so tight and that’s where they’re at. I don’t know….I’m not in the State leg­is­la­ture and I’m not with the Fish and Wildlife so I don’t know what their funds are.

EB: Laura, thanks for join­ing us this evening.

Caller Laura: OK, thank you.

EB: Appre­ci­ate your time. We are unfor­tu­nately run­ning very close to the hour. It’s been a remark­ably quick hour but Eric I’m just curi­ous from your per­spec­tive, do you think the other two Com­mis­sion­ers are sym­pa­thetic with some of your goals and are you in a posi­tion to per­suade them, to influ­ence them, if you were to be elected?

ET: Well, I believe that all three are sym­pa­thetic to many of my ideas. Both Kathy and I see con­ser­va­tion as an essen­tial role of the PUD. I think that cer­tainly being on the Com­mis­sion has much more lever­age that sim­ply being a cit­i­zen speak­ing to the Com­mis­sion which is why I’m run­ning. I wanted to have the chance to actu­ally have a voice among the three, or poten­tially five.

EB: OK. As we’re com­ing towards the end of here, let me ask me both of you, and we’ll start with Kathy. Your three pri­or­i­ties to be re-​elected to the PUD Com­mis­sion, what would be your three priorities?

KV: Well first of all, the pri­or­ity of any Com­mis­sioner is to keep the rates low, keep the lights on, and the water run­ning. And I have done that through all these years. And we’ve done it with a lot of chal­leng­ing issues that have come before us. But we’ve been able to do that and man­age fairly well to make sure that we keep our util­ity in good shape, that we’re meet­ing all the man­dates that are above and in front us with leg­is­la­tion. So as far as what are my three priorities….My three pri­or­i­ties are to develop for the future, to do that with con­tin­u­ing con­ser­va­tion, umm, one of the things I’m most proud of is since I’ve come on the board I have cham­pi­oned for con­ser­va­tion for all these years. We have gained 100 megawatts of con­ser­va­tion since I’ve come on this board. 100 megawatts of con­ser­va­tion is 1/​8th of our load. So we have saved a lot of money with con­ser­va­tion and a lot of resources, and also being stew­ards of the environment.

EB: Eric, your three pri­or­i­ties if elected to the PUD?

ET: Num­ber one, I want to really go after some of the tremen­dous wastes of energy we have in the win­ter time with these inef­fi­cient heat­ing sys­tems that I talked about ear­lier. I’m call­ing this the Green Express. The focus would be really to pro­vide good incen­tives for peo­ple to replace their old base­board heat­ing or other types of elec­tric heat­ing sys­tems with more effi­cient ones. Num­ber two, I do want to expand the Solar Express pro­gram. I want to make it even eas­ier for peo­ple to make the right deci­sion to make the invest­ment in renew­able energy and use their home as a power plant. And then num­ber three, I believe in not just afford­able power pro­duc­tion but also respon­si­ble power pro­duc­tion. So we need to look at the cost to the envi­ron­ment and to the pub­lic as well as the bal­ance book of PUD.

EB: Kathy Vaughn, thank you for join­ing us tonight. It’s been a plea­sure talk­ing with you.

KV: Well thank you for hav­ing me and I ask for those out there in the lis­ten­ing area, I would appre­ci­ate your vote.

EB: And Eric, thank you very much for join­ing us this evening as well. It’s been a delight talk­ing with you and both of you tonight.

ET: Thank you Ed. And I also ask for your vote. Thank you.

EB: Our guests this evening on KSER have been Eric Tee­gar­den and Kathy Vaughn. They are seek­ing your vote to be the PUD Com­mis­sioner, Dis­trict 2. Your bal­lot should be arriv­ing in the home this week.

Elec­tion 2012 Your Opin­ion Matters

We are now in the study phase of the Sun­set Falls Hydro­elec­tric Project.
The chal­lenge of the study phase is to col­lect all rel­e­vant infor­ma­tion and make it avail­able to all project stakehold­ers in order to make the best pos­si­ble deci­sion. The stakehold­ers include local res­i­dents, PUD employ­ees and sub-​contractors, envi­ron­men­tal groups, mul­ti­ple Amer­i­can Indian tribes, your elected offi­cials and YOU.

How can YOU effect the deci­sion as to whether to pro­ceed or halt devel­op­ment of hydropower at Sun­set Falls? Let the stake­hold­ers hear from you. One PUD Com­mis­sioner and sev­eral elected offi­cials are up for re-​elec­tion. Please vote. YOU decide.
Please check back soon; we will be post­ing can­di­date posi­tion papers as they per­tain to the devel­op­ment of a hydropower plant at Sun­set Falls.
Cur­rent hold­ers of those posi­tions up for elec­tion in 2012 are.

Kath­leen Vaughn
Send an email to Kath­leen Vaughn

United States Sen­a­tor Maria Cantwell
Con­tact Page
North­west Wash­ing­ton Office
2930 Wet­more Avenue, Suite 9B
Everett, WA 98201
425–303‑8351 FAX

Con­gres­sional Dis­trict 1 Con­gress­men

Can­di­dates you need to know:

Offices Up for Elec­tion 2012

The South Fork of the Skykomish river put on the most endan­gered river list.

The South Fork of the Skykomish river earned a dubi­ous dis­tinc­tion today as it was placed on Amer­i­can River’s Most Endan­gered Rivers list. The plan is to divert a sig­nif­i­cant amount of water from Canyon and Sun­set Falls. The South Fork is one of the last un-​dammed rivers in the state of Wash­ing­ton and has gain pro­tected sta­tus by the North­west Power and Con­ser­va­tion Coun­cil.

The Sno­homish County PUD is work­ing it’s way through the Fed­eral Energy and Reg­u­la­tion Com­mi­tee three phase process. Which will decide whether or not to grant the per­mit to indus­tri­al­ize this nat­ural resource. The cur­rent com­ment period is over but they can be read here and SnoPUD’s FERC appli­ca­tion here.

To sign the peti­tion to stop fur­ther devel­op­ment of the South Fork of the Skykomish River, Canyon Falls and Sun­set Falls press below.

Pure Green: Money Bet­ter Spent

Free energy, that is the promise of small hydro­elec­tric projects now being planned to dot the north­west. These projects look small in the­ory, but the one pro­posed for Sun­set Falls includes a foot­ball field by three story intake. It also includes a ten story pow­er­house build­ing ( three sto­ries above ground). It in the­ory will pro­duce 30 megawatts; NOT small.

Here is the catch. Trans­mit that power on what. Cur­rent power line infra­struc­ture is NOT capa­ble of trans­mit­ting all the FREE energy pro­vided by small hydro, wind farms, tidal or bring large hydro up to date. The fact of the mat­ter is cur­rently we are shut­ting off wind farms and other green resources for the lack of trans­mis­sion capacity.

Truly free energy is energy not spent. Turn­ing off exist­ing viable sources and not pro­vid­ing max­i­mum trans­mis­sion effi­ciency of that power is inef­fec­tive. A waste. Money would be bet­ter spent on trans­mit­ting what we have ver­sus mak­ing more. Pure Green money bet­ter spent.

Related Arti­cle the Upgrade of Grand Coulee

Hydropower Reform Coali­tion On Small Hydro

The Hydropower Reform Coali­tion pro­duced a video explain­ing some of its con­cerns around “Small Hydro”. The Hydropower Reform Coali­tion pro­duced a video explain­ing some of its con­cerns around “Small Hydro”. Cur­rently the Sun­set Falls Hydro­elec­tric is in its plan­ning stages and this video in by no means sug­gests a sim­i­lar design ‚rec­om­men­da­tion or result by the Sno­homish County PUD at Sun­set Falls

Small Hydro Power from Tom11 Films on Vimeo.

About Hydropower Reform Coalition

Who Is the Hydropower Reform Coalition

We are a coali­tion of more than 150 national, state and local con­ser­va­tion and recre­ation groups that care about rivers and work hard to pro­tect them from harm­ful hydropower dams.

Why hydropower reform

When we use a river to gen­er­ate elec­tric­ity we harm the river, often badly. The good news is that we can keep our rivers healthy and keep the lights on by bring­ing hydropower projects up to mod­ern standards.

Friends of The Skykomish River Start A Peti­tion Campaign.

Ear­lier this week the group called “Friends of the Skykomish River” started a peti­tion to cam­paign have Sno­homish County Pub­lic Util­ity Dis­trict aban­don the Skykomish River /​Sun­set Falls Hydro Project. Cit­ing var­i­ous con­cerns the peti­tions goal is for SnoPUD to stop future hydro-​electric devel­op­ment of the South fork of Skykomish River. To sign the peti­tion click here

Glac­i­ers con­tribute 50 CFS into the sum­mer flow of 300 CFS. Is that enough to turn turbines?

Pro­fes­sor Mauri Pelto of the Nichols col­lege has been study­ing the Skykomish river for nearly 30 years. In his own words he writes.

To ratio­nally man­age water resources requires under­stand­ing how cli­mate change is alter­ing stream­flow. In the North Cas­cades and Skykomish Basin this requires con­sid­er­a­tion of glac­ier change. For 30 years we have spent every sum­mer observ­ing glac­i­ers in the basin from 1958–2009 glac­ier area declined from 3.8 km2 to 2.1 km2, with most of the loss occur­ring since 1985. The main change for the Skykomish River has been changes in the tim­ing of flow, with increased win­ter flow and reduced sum­mer flow. In par­tic­u­lar the num­ber of sum­mer days with crit­i­cally low flow have increased from 1 day from 1950–1985 to 218 days from 1986–2010. Glac­i­ers are not a sig­nif­i­cant player in the Skykomish except dur­ing the low flow peri­ods. Four of the last five win­ters have had a La Nina sig­nal, and this makes us for­get about the low flow sum­mers that dom­i­nated from 2003–2007 and will return soon
Pro­fes­sor Pelto’s paper can be read here.

FERC Grants Pre­lim­i­nary Per­mit –30 Day Clock Starts

FERC announced today that it will grant a Pre­lim­i­nary Per­mit to the Sun­set Falls Hydro­elec­tric Project. Per­sons would would like to chal­lenge this rul­ing have 30 days to appeal and ask for a new hearing.


Pub­lic Util­ity Dis­trict No. 1 of Sno­homish County Project No. 14295–000


(March 2, 2012)

1. On Sep­tem­ber 28, 2011, Pub­lic Util­ity Dis­trict No. 1 of Sno­homish County, Wash­ing­ton (Sno­homish PUD) filed an appli­ca­tion for a pre­lim­i­nary per­mit, pur­suant to sec­tion 4(f) of the Fed­eral Power Act (FPA),1 to study the fea­si­bil­ity of the pro­posed Sun­set Falls Hydro­elec­tric Project No. 14295 (project) to be located at Sun­set Falls on the South Fork Skykomish River near the city of Index in Sno­homish County, Washington.

I. Project Pro­posal

2. The pro­posed project would uti­lize the exist­ing works of the Wash­ing­ton Depart­ment of Fish and Wildlife’s (Wash­ing­ton DFW) fish trap-​and-​haul facil­ity. The pro­posed project would include the con­struc­tion of the fol­low­ing: (1) a 140-​foot-​wide, 45-​foot-​high v-​screen intake; (2) a 2,000-foot-long, 19-​foot-​diameter unlined rock pen­stock; (3) a semi-​underground pow­er­house with twin 15-​megawatt tur­bines; (4) an 8.5-mile-long, 115-​kilovolt three-​phase over­head trans­mis­sion line extend­ing from the pow­er­house to an exist­ing sub­sta­tion; and (5) appur­tenant facil­i­ties. The esti­mated annual gen­er­a­tion of the project would be 120 gigawatt-​hours.

II. Back­ground

3. The Com­mis­sion issued pub­lic notice of Sno­homish PUD’s per­mit appli­ca­tion on Octo­ber 21, 2011. The National Marine Fish­eries Ser­vice (NMFS) and Wash­ing­ton DFW filed timely notices of inter­ven­tion on Octo­ber 31, 2011 and Novem­ber 2, 2011, respec­tively.2 Timely motions to inter­vene were filed by Tulalip Tribes of Wash­ing­ton (Tribes); the Canyon Falls Home­own­ers Asso­ci­a­tion (CFHOA); Lora Cox; Jeff Smith; Matt Walsh; and the Alpine Lakes Pro­tec­tion Soci­ety, Amer­i­can Rivers, Amer­i­can White­wa­ter, North Cas­cades Con­ser­va­tion Coun­cil, Sierra Club– Wash­ing­ton State

1 16 U.S.C. § 797(f) (2006).

2 A timely notice of inter­ven­tion filed by a state fish and wildlife agency is granted by oper­a­tion of Rule 214(a)(2).

Chap­ter, the Moun­taineers, and Wash­ing­ton Wild (col­lec­tively the Con­ser­va­tion Groups).3

4. Com­ments were filed by a num­ber of agen­cies, com­mu­ni­ties, orga­ni­za­tions, and individuals.

III. Dis­cus­sion
A. Issues Related to Project Con­struc­tion and Operation
5. Many com­menters are con­cerned with pos­si­ble effects of project con­struc­tion and

oper­a­tion to aquatic, ter­res­trial, threat­ened and endan­gered species, cul­tural, recre­ation, land use, and aes­thetic resources in the area. A pre­lim­i­nary per­mit does not autho­rize a per­mit­tee to under­take con­struc­tion of the pro­posed project. The pur­pose of a pre­lim­i­nary per­mit is to study the fea­si­bil­ity of the project, includ­ing study­ing poten­tial impacts. The con­cerns raised in the com­ments are pre­ma­ture at the pre­lim­i­nary per­mit stage, in that they address the poten­tial effects of con­struct­ing and oper­at­ing the pro­posed project. Should the per­mit­tee file a license appli­ca­tion, these issues will be addressed in the licens­ing process.

B. Pub­lic Interest

6. The Con­ser­va­tion Groups stated that pre­vi­ous devel­op­ers in the area were unable to com­mence con­struc­tion on sim­i­lar projects due to min­i­mal eco­nomic and power ben­e­fits and numer­ous site-​specific issues. They con­clude that the grant­ing of a pre­lim­i­nary per­mit would begin a time and resource con­sum­ing pro­ceed­ing which would not be in the pub­lic inter­est. The FPA does not con­di­tion issuance of a pre­lim­i­nary per­mit upon a find­ing that it is in the pub­lic inter­est because to make such a find­ing would require the infor­ma­tion and con­clu­sions that are to be devel­oped dur­ing the per­mit phase.4

C. Other Com­ments

7. Sev­eral com­menters stated that the Skykomish River is a des­ig­nated part of the Wash­ing­ton State Scenic River sys­tem and part of a North­west Power and Con­ser­va­tion Coun­cil pro­tected area. The Com­mis­sion is not barred from issu­ing a per­mit on a water­way des­ig­nated part of the Wash­ing­ton State Scenic River sys­tem, and a permit

3 Timely, unop­posed motions to inter­vene are granted by oper­a­tion of Rule 214 of the Commission’s reg­u­la­tions. 18 C.F.R. § 385.214 (2011).

4 See, e.g., Wind River Hydro, LLC, 115 FERC ¶ 61,009, at P 10 (2006).

appli­cant is not pro­hib­ited from pur­su­ing a pro­posed project in a Council-​designated pro­tected area.5 Con­cerns about the pro­posed project con­flict­ing with these des­ig­na­tions can be prop­erly addressed in the licens­ing process.

  1. Other com­menters stated that the South Fork of the Skykomish River is being rec­om­mended for des­ig­na­tion as a Wild and Scenic River. The Wild and Scenic Rivers Act pro­hibits the Com­mis­sion from licens­ing a project “on or directly affect­ing” any river des­ig­nated as a com­po­nent of the Wild and Scenic Rivers Sys­tem.6 Since the South Fork of the Skykomish River sys­tem is not a des­ig­nated com­po­nent of the Wild and Scenic Rivers Sys­tem, the Com­mis­sion is not barred by the Wild and Scenic Rivers Act from issu­ing a license or a per­mit in the South Fork of the Skykomish River system.
  2. Con­ser­va­tion groups stated that the pre­lim­i­nary per­mit appli­ca­tion would be incon­sis­tent with cer­tain regional and coor­di­nated com­pre­hen­sive plans. Again, these com­ments are pre­ma­ture at the per­mit stage, as con­sis­tency with com­pre­hen­sive plans is deter­mined dur­ing the licens­ing process.

IV. Per­mit Information

10. Sec­tion 4(f) of the FPA autho­rizes the Com­mis­sion to issue pre­lim­i­nary per­mits for the pur­pose of enabling prospec­tive appli­cants for a hydropower license to secure the data and per­form the acts required by sec­tion 9 of the FPA,7 which in turn sets forth the mate­r­ial that must accom­pany an appli­ca­tion for license. The pur­pose of a pre­lim­i­nary per­mit is to pre­serve the right of the per­mit holder to have the first pri­or­ity in apply­ing for a license for the project that is being stud­ied.8 Because a per­mit is issued only to allow

5 The Com­mis­sion does not require per­mit appli­cants to pro­vide a demon­stra­tion that their pro­posed project would take North­west Power and Con­ser­va­tion Coun­cil Plan­ning Pro­gram for “pro­tected areas” into account since the pur­pose of a per­mit is to pre­serve the permittee’s pri­or­ity of appli­ca­tion while it under­takes the stud­ies needed to answer most of the ques­tions that will apply to any even­tual license appli­ca­tion, includ­ing how the pro­posed project would take into account the Council’s des­ig­na­tion of the water­way as a pro­tected area. See, Cowlitz Basin, 62 FERC ¶ 61,165, at 62,134 (1993).

6 16 U.S.C. § 1278(a), (b) (2006).

7 16 U.S.C. § 802 (2006).

8 See, e.g., Mt. Hope Water­power Project LLP, 116 FERC ¶ 61,232 at P 4 (2006) (“The pur­pose of a pre­lim­i­nary per­mit is to encour­age hydro­elec­tric devel­op­ment by afford­ing its holder pri­or­ity of appli­ca­tion (i.e., guar­an­teed first-​to-​file sta­tus) with respect to the fil­ing of devel­op­ment appli­ca­tions for the affected site.”).

the per­mit holder to inves­ti­gate the fea­si­bil­ity of a project while the per­mit­tee con­ducts inves­ti­ga­tions and secures nec­es­sary data to deter­mine the fea­si­bil­ity of the pro­posed project and to pre­pare a license appli­ca­tion, it grants no land-​disturbing or other prop­erty rights.9

  1. Dur­ing the course of the per­mit, the Com­mis­sion expects that the per­mit­tee will carry out pre­fil­ing con­sul­ta­tion and study devel­op­ment lead­ing to the pos­si­ble devel­op­ment of a license appli­ca­tion. The pre­fil­ing process begins with prepa­ra­tion of a Notice of Intent (NOI) and Pre-​Application Doc­u­ment (PAD) pur­suant to sec­tions 5.5 and 5.6 of the Commission’s reg­u­la­tions.10 The per­mit­tee must use the Inte­grated Licens­ing Process unless the Com­mis­sion grants a request to use an alter­na­tive process (Alter­na­tive or Tra­di­tional Licens­ing Process). Such a request must accom­pany the NOI and PAD and set forth spe­cific infor­ma­tion jus­ti­fy­ing the request.11 Should the per­mit­tee file a devel­op­ment appli­ca­tion, notice of the appli­ca­tion will be pub­lished, and inter­ested per­sons and agen­cies will have an oppor­tu­nity to inter­vene and to present their views con­cern­ing the project and the effects of its con­struc­tion and operation.
  2. Arti­cle 4 of this per­mit requires the per­mit­tee to sub­mit a progress report no later than the last day of each six-​month period from the effec­tive date of this per­mit. A progress report must describe the nature and tim­ing of what the per­mit­tee has done under the pre-​filing require­ments of sec­tion 4.38 and Part 5 of the Commission’s reg­u­la­tions for the spe­cific report­ing period. A per­mit may be can­celled if a per­mit­tee fails to file a timely progress report or if the report does not demon­strate that progress is being made by the per­mit­tee. The late fil­ing of a report or the sup­ple­men­ta­tion of an ear­lier report in response to a notice of prob­a­ble can­cel­la­tion will not nec­es­sar­ily excuse the fail­ure to com­ply with the require­ments of this article.
  3. A pre­lim­i­nary per­mit is not trans­fer­able. The named per­mit­tee is the only party enti­tled to the pri­or­ity of the appli­ca­tion for license afforded by this pre­lim­i­nary per­mit. In order to invoke permit-​based pri­or­ity in any sub­se­quent licens­ing com­pe­ti­tion, the

9 Issuance of this pre­lim­i­nary per­mit is thus not a major fed­eral action sig­nif­i­cantly affect­ing the qual­ity of the human envi­ron­ment. A per­mit holder can only enter lands it does not own with the per­mis­sion of the land­holder, and is required to obtain what­ever envi­ron­men­tal per­mits fed­eral, state, and local author­i­ties may require before con­duct­ing any stud­ies. See, e.g., Three Mile Falls Hydro, LLC, 102 FERC ¶ 61,301 at P 6 (2003); see also Town of Sum­mersville, W.Va. v. FERC, 780 F.2d 1034 (D.C. Cir. 1986) (dis­cussing the nature of pre­lim­i­nary permits).

10 18 C.F.R. §§ 5.5 and 5.6 (2011).

11 See 18 C.F.R. § 5.3 (2011).

named per­mit­tee must file an appli­ca­tion for license as the sole appli­cant, thereby evi­denc­ing its intent to be the sole licensee and to hold all pro­pri­etary rights nec­es­sary to con­struct, oper­ate, and main­tain the pro­posed project. Should any other par­ties intend to hold dur­ing the term of any license issued any of these pro­pri­etary rights nec­es­sary for project pur­poses, they must be included as joint appli­cants in any appli­ca­tion for license filed. In such an instance, where par­ties other than the per­mit­tee are added as joint appli­cants for license, the joint appli­ca­tion will not be eli­gi­ble for any permit-​based pri­or­ity.12

The Direc­tor orders:

A pre­lim­i­nary per­mit is issued for the Sun­set Falls Hydro­elec­tric Project No. 14295 to Pub­lic Util­ity Dis­trict No. 1 of Sno­homish County for a period effec­tive the first day of the month in which this per­mit is issued, and end­ing either 36 months from the effec­tive date or on the date that a devel­op­ment appli­ca­tion sub­mit­ted by the per­mit­tee has been accepted for fil­ing, whichever occurs first.


This pre­lim­i­nary per­mit is sub­ject to the terms and con­di­tions of Part I of the Fed­eral Power Act and related reg­u­la­tions. The per­mit is also sub­ject to Arti­cles 1 through 4, set forth in the attached stan­dard form P-​1.
This order con­sti­tutes final agency action. Any party may file a request for rehear­ing of this order within 30 days of the date of its issuance, as pro­vided in sec­tion 313(a) of the Fed­eral Power Act, 16 U.S.C. § 8251 (2006), and sec­tion 385.713 of the Commission’s reg­u­la­tions, 18 C.F.R. § 385.713 (2011).

Jen­nifer Hill, Chief North­west Branch Divi­sion of Hydropower Licensing

12 See City of Fayet­teville, 16 FERC ¶ 61,209 (1981).

Form P-​1 (Revised April 2011)



Arti­cle 1. The pur­pose of the per­mit is to main­tain pri­or­ity of appli­ca­tion for a license dur­ing the term of the per­mit while the per­mit­tee con­ducts inves­ti­ga­tions and secures data nec­es­sary to deter­mine the fea­si­bil­ity of the pro­posed project and, if the project is found to be fea­si­ble, pre­pares an accept­able appli­ca­tion for license. In the course of what­ever field stud­ies the per­mit­tee under­takes, the per­mit­tee shall at all times exer­cise appro­pri­ate mea­sures to pre­vent irrepara­ble dam­age to the envi­ron­ment of the pro­posed project. This per­mit does not autho­rize the per­mit­tee to con­duct any ground-​disturbing activ­i­ties or grant a right of entry onto any lands. The per­mit­tee must obtain any nec­es­sary autho­riza­tions and com­ply with any applic­a­ble laws and reg­u­la­tions to con­duct any field studies.

Arti­cle 2. The per­mit is not trans­fer­able and may, after notice and oppor­tu­nity for hear­ing, be can­celed by order of the Com­mis­sion upon fail­ure of the per­mit­tee to pros­e­cute dili­gently the activ­i­ties for which a per­mit is issued, or for any other good cause shown.

Arti­cle 3. The pri­or­ity granted under the per­mit shall be lost if the per­mit is can­celed pur­suant to Arti­cle 2 of this per­mit, or if the per­mit­tee fails, on or before the expi­ra­tion date of the per­mit, to file with the Com­mis­sion an appli­ca­tion for license for the pro­posed project in con­for­mity with the Commission’s rules and reg­u­la­tions then in effect.

Arti­cle 4. No later than the last day of each six-​month period from the effec­tive date of this per­mit, the per­mit­tee shall file a progress report. Each progress report must describe, for that report­ing period, the nature and tim­ing of what the per­mit­tee has done under the pre-​filing require­ments of 18 C.F.R. sec­tions 4.38 and 5.1–5.31 and other applic­a­ble reg­u­la­tions; and, where stud­ies require access to and use of land not owned by the per­mit­tee, the sta­tus of the permittee’s efforts to obtain per­mis­sion to access and use the land. Progress reports may be filed elec­tron­i­cally via the Inter­net, and the Com­mis­sion strongly encour­ages e-​filing. Instruc­tions for e-​filing are on the Commission’s web­site at http://​www​.ferc​.gov/​d​o​c​s​-​f​i​l​i​n​g​/​e​f​i​l​i​n​g​.​asp. To paper-​file instead, mail four copies of the progress report to the Sec­re­tary, Fed­eral Energy Reg­u­la­tory Com­mis­sion, 888 First Street, N.E., Wash­ing­ton, D.C. 20426.

P-​14295-​000Order Mish59.DOC.….….….….….….….….….……1–6