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.
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:
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.
· #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.
· #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/water/hydro_history.html.
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).
· #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
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.
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:
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.