Court Room Updates of Appeal of Department of Ecology's
Decision to Allow Okanogan PUD Dewater Similkameen Falls
Courtroom Day #1: Local residents - Jere Gillespie and Joseph Enzensperger
On Tuesday our judges asked this question: what does 10 cubic feet per second of water (cfs) look like? Compare 10cfs with 500 cfs - the average monthly median flow over Similkameen Falls.
Today (Wednesday) our experts on aesthetic flows take the stand and we get into the science, methodology, and reason on how and why aesthetic flows should have been required and completed, and the importance of protecting water quality standards and all beneficial uses of rivers in Washington State.
Jere Gillespie with the Columbia River Bioregional Education Project, and Joseph Enzensperger (both local Okanogan County residents) did a great job of explaining and demonstrating in both testimony and cross examination (through video and photos) exactly why the Similkameen River and Falls are important cultural, historic, and aesthetic benefits to the community. Since conservation and recreation organizations are Appellants in this case before the Pollution Control Hearing Board (Ecology and the Public Utility District No. 1 of Okanogan County are Respondents) our witnesses were up first.
Our legal representatives Andrea K. Rodgers Harris and Kristen J. Larson did a great job of preparing our witnesses, evidence, and legal arguments, leading through opening comments, and setting the stage for the Board to find that the 401 Certificate is unlawful and invalid, and to remand the 401 Certificate to Ecology with specific instructions to comply with the Clean Water Act and all applicable state laws.
Courtroom Day #2: Waterfalls expert Doug Whitaker
What are the lessons from restoring water to Spokane Falls – the successful settlement between Sierra Club, CELP and Avista Corp. -- for at-risk waterfalls throughout Washington State, including Similkameen Falls? The 3 judges heard repeatedly about what worked at Spokane Falls – and how Department of Ecology failed to learn those lessons in reaching its decision to dewater Similkameen Falls.
On Wednesday our waterfalls expert Doug Whitaker with Confluence Consulting explained to the 3 judges with the Pollution Control Hearing Board why the Department of Ecology (“Ecology”) and the Okanogan PUD should have conducted an aesthetic flow study, but failed to do so. For waterfalls such as Similkameen Falls, the federal Clean Water Act and applicable state laws require aesthetic analysis. Since 2008 river advocates have asked for additional aesthetic flow information, and both Ecology and the PUD have responded that such a study is impossible.
Dr. Whitaker then went on to explain how such a study could have been done, and explained how he and others gathered critical aesthetic flow information in one afternoon during an October 2012 visit to Similkameen Falls. He demonstrated to the Board that not only was a more detailed study possible, but that an analysis could have been done quickly and without undue effort and expense.
Also addressed today were Ecology and the PUD’s contention that flow reduction in the Similkameen and over the falls to 30 to 10 cfs for more than eight months each year would be minimal. Testimony yesterday and today showed existing low-flow photos and videos (236 cfs is the lowest flow photographed) and then went to explain the impacts of reducing these historically natural low-flows by an additional 87 to 90 percent.
Witnesses explained important elements of our case:
•finding a more elegant solution (one that doesn’t sacrifice any of the important beneficial uses of the Similkameen),
•demonstrating how that solution could have been found,
•explaining why that did not occur since the driving goal of this process unfortunately centered on the economics of the project, and
•discussing how the minimum flows of 30 and 10 cfs were pre-determined based on this economic factor and not on a balance of public beneficial use – of which power production in just one use.
Once again our legal representatives Andrea K. Rodgers Harris and Kristen J. Larson did a great job of guiding everyone through what has become a grueling schedule; one that appears will require all of today and tomorrow, and perhaps additional days, to complete.
Courtroom Day #3: Department of Ecology
On Thursday, Department of Ecology staff took the witness stand. Ecology testified on the agency's decision to dewater Similkameen Falls that they:
•Never considered any flow that would make the project uneconomic for Okanogan PUD (so nothing over 100 cfs).
•Did look at different waterfall flow scenarios, such as diverse flows, weekend flows and partial flows. However, this data disappeared early on, never to surface again. Diverse flow data were discarded with no additional input, even though stakeholders (Appellants) had asked for this exact aesthetic information since 2008.
•Throughout the process, no aesthetic information was gathered, only economic data in reference to what the project could afford to make a profit for the Okanogan PUD.
•Early in the process, Ecology supported no flows in the bypass, totally dewatering the Similkameen, and today believe that the recommended 30 to 10 cfs flow (for more than eight months each year) will provide a benefit for fishing in the river, and that 10 cfs is “adequate to protect the fishery” in the bypass. Staff also stated that “building the project is good for fish because the PUD has built in mitigation.” (Compare the 30/10 cfs decision with the average monthly median waterfall flows of 500 cfs.)
In testimony, Ecology staff recognized the “irony” of the situation. That PUD mitigation money was being proposed to improve access to the river, Enloe Dam and Similkameen Falls, to build public overlooks over the dam and falls, and to improve camping -- all while the project would effective dry up the waterfalls which is the primary public attraction, and replace the sound of falling water with the loud hum of turbines.
We learned that while Ecology staff can approve a 401 Water Quality Certificate, only the Director can deny a certification. We also heard Ecology staff state that only rarely does Ecology address aesthetics as a beneficial use (Snoqualmie Falls and Spokane River were the only examples Ecology staff could give), and that they do so only on projects located in populated areas.
Appellants note that the Department of Ecology is charged with protecting all beneficial uses of Washington’s rivers, and they cannot restrict this to just popular, urban or other subjective criteria. Does Ecology restrict in this manner regarding water quality or fishery issues. If not, why would you restrict aesthetics which is also a state-required beneficial use?
Ecology staff testified incorrectly that throughout the Enloe process, conservation groups never specified that they were unsupportive of the 30 to 10 cfs. minimum flow. To reach this conclusion, Ecology had to disregard years of comments, meetings, and involvement in both the Federal Energy Regulatory Commission and 401 Certification process.
On Friday we hear more from Ecology staff, then testimony from PUD witnesses, and finally closing arguments from all parties. The hearing is scheduled to end on Friday, April 19.
Courtroom Day #4: Similkameen Falls
On Friday, April 19, we continued to hear testimony from the Department of Ecology's in-stream flow scientist, who discussed how the decision was made to de-water Similkameen Falls. The Board also heard from Okanogan PUD's relicensing manager and a consultant who managed the aesthetic flow process.
What was clear from all testimony is that the PUD and Ecology very deliberately agreed to remove 90% of the water from the River during the lowest flow months of the year. As approved, the water quality certification would allow the river to be reduced from its average monthly median flow of 500 cubic feet per second (cfs) to just 30 or 10 cfs for more than eight months each year -- a mere trickle in the riverbed.
Washington's Dept of Ecology and the PUD also disregarded several requests to further study and protect aesthetic and recreational values, including requests from the National Park Service, Bureau of Land Management, Washington Department of Natural Resources, and the appellants.
By mid-morning on Friday it became clear that the three judges would not have time to hear from all witnesses by the end of the day. The hearing adjourned in late afternoon, with another 1-2 days of witness testimony to be scheduled in May or June. Still to come are the PUD's water quality, fisheries and recreation experts.
Appellants are the Center for Environmental Law & Policy, American Whitewater, Columbia River Bioregional Education Program, North Cascades Conservation Council, and Sierra Club (all members of the Hydropower Reform Coalition). Our legal representatives are Andrea K. Rodgers Harris and Kristen J. Larson. Testimony is being heard by a 3-judge panel of the Pollution Control Hearings Board.
Appellants are the Center for Environmental Law & Policy, American Whitewater, Columbia River Bioregional Education Project, North Cascades Conservation Council, and Sierra Club (all members of the Hydropower Reform Coalition). “Respondents” are the Washington Department of Ecology and Okanogan PUD #1.
Legal representatives for Appellants are Andrea K. Rodgers Harris and Kristen J. Larson, with support of many including CELP staff Suzanne Skinner and Rachael Paschal Osborn.
—Court notes prepared by John Osborn and Rich Bowers.
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Oroville. On Tuesday, January 24, 2012, the Columbia Bioregional Education Project (Columbiana), joined by several conservation groups, issued a new economic analysis of Okanogan Public Utility District's (PUD) proposal to restart hydropower generation at Enloe Dam on the Similkameen River. The analysis, prepared by Rocky Mountain Econometrics (RME) of Boise, ID, concludes that it is not possible for the PUD to sell power from Enloe Dam at or above the cost of producing it, and that the PUD will lose $26 for every megawatt hour produced at the dam.
More information about the Hydropower Reform Coalition and member groups, as well as Recent History of Enloe Dam Relicensing and Similkameen Falls Picture Record. Here you can view booklet on the Similkameen River Trail to Enloe Dam.
Addiional articles of interest:
The Pacific Lamprey, close to extinction, could
bring down Northwest salmon too.
• Community Cultural Center of Tonasket
• Conservation Northwest
• Conscious Cultural Festival
• Farmers Markets - Okanogan County
• Ferry County Co-op
• Friends of the Trees Society
• Green Okanogan
• Jackrabbit Newsletter
• Kettle Range Conservation Group
• Lake Roosevelt Forum
• LA Catholic Worker Agitator
• Methow Naturalist
• Methow Valley Citizens Council
• Okanogan Highlands Alliance
• Okanogan Land Trust
• Planet Drum Foundation
• SHAWL Society
• Slow Food Okanogan County
• SolWest Renewable Energy Faire
• Tonasket Natural Foods Co-op
• Wisdom of the 13 Grandmothers
• June 1 - Great Green Stock Exchange, 8 am to 5 pm, Chesaw, WA. sponsored by Chesaw Wild
• June 21-23 - 4th Annual Conscious Cultural Festival, Tonasket WA.
• July26-28 - SolWest Renewable Energy Fair, John Day OR, visit www.solwest.org for info.
• Sept 21 - International Day of Peace Celebration, "Roadmap to Apartheid," CCC Tonasket, 5:30 pm dinner
Ratepayer Issues with the
Proposed Enloe Dam Facilities Rebuild
1. The PUD will spend over $2 million in 2012 for Enloe Dam, even though they have not produced an updated cost/benefit analysis for the project since 2007, and it is not clear the project will be a sound economic investment.
2. The PUD is pushing ahead with Enloe Dam without obtaining the approval of the ratepayers, even while the PUD has tripled the long term debt of the PUD in the last three years, and angered the ratepayers with large rate increases.
3. The PUD has not recalculated projected costs for re-building the power producing facilities. The initial estimate of $28 milion was calculated in 2007, nearly five years ago. A fiscal evaluation of the PUD's costs forecasts construction costs of $40 million.
4. The value of the power produced at the proposed Enloe Dam has declined by more than one-half since the original 2007 estimate of $66/MWhr.
5. The PUD has told the public that Enloe power will qualify to be "green power" under the state's Initiative 937, Requirements for New Energy Resources, and thus have an increased value, but our investigations show that Enloe power does not qualify now, nor will it likely qualify in the future.
6. The bulk of Enloe power will be produced in the spring when the northwest market already has a glut of cheaper power available.
7. Enloe Dam facilities will destroy the scenic values of the Similkameen Falls canyon which is a feature of great value on the new Similkameen River Trail, part of the Pacific Northwest Trail. Thus the dam could reduce tourism revenues associated with trail use in north Okanogan County.
8. Enloe Dam is 90 years old. How long do concreate walls last? The dam is a liability for its owners. This is why the BLM, owner of the dam site, wants dam removed if the license is not awarded or the PUD decides not to build the new power generating facilities.
9. If the dam is removed, the Similkameen River will become a valuable steelhead fishing river. The fisheries agencies do not consider Similkameen Falls to be a barrier to fish migration during the spring freshet.
Enloe Dam on the Similkameen River could be licensed to resume power production after 50 years of inactivity, sometime in 2012. The Okanogan PUD is nearly finished with its required reports to FERC, the Federal Energy Regulatory Commission. FERC has issued a final Environmental Assessment greenlighting the project.
Conservation Groups, including American Rivers, American Whitewater, Sierra Club, CELP, and Columbiana, working together as the Hydropower Coalition, are official parties to the FERC licensing procedure.
A final permit, the 401 for water quality, has just received the last round of scoping comments, and could be issued by the WA State Dept of Ecology.
Two major issues await resolution. The 54 foot Enloe Dam completely blocks fish passage for steelhead, salmon and lamprey into the upper portion of the 3,600 sq. mile Similkameen Basin. Fish passage on the Similkameen has been proposed as mitigation for fish habitat losses incurred with Grand Coulee Dam since 1941. Enloe Fish Passage was authorized by Congress in 1976. In particular the endangered Upper Columbia River Steelhead would benefit from the large increase in upstream spawning and rearing habitat. Given the recent decision by Judge Redden that more habitat must be secured for listed stocks, fish passage at Enloe Dam is the best opportunity in the upper Columbia River region to secure the wild native steelhead stock. Spring Chinook salmon and Pacific Lamprey are also at extreme risk and would gain significant habitat opportunities above Enloe Dam.
The second major issue is loss of scenic values in the canyon which holds Enloe Dam and the Similkameen Falls. This site is now a destination viewpoint for the new Similkameen River Trail, a segment of the PNT, Pacific Northwest National Scenic Trail.
The design of the new facilities calls for diverting the Similkameen from its riverbed, piping into turbines to make electricity, then returned to the riverbed below Similkameen Falls. A 400 foot section of the river, referred to as the “by-pass” reach, will be dewatered for eight months of the year; reducing flows from median 500 cubic feet per second (cfs) to 30 and 10 cfs. Conservation groups are calling for more water over Similkameen Falls, citing the requirements of the Clean Water Act to protect aesthetic uses of a river.
This license for Enloe Dam is the 4th request by the Okanogan PUD since Enloe was taken out of operation in 1958, because costs of continued operation outweighed the economic benefits of producing power at the dam. Three previous licenses have been rejected by FERC because the dam would have not been economically viable, especially given the requirements of fish passage.
In January, Conservation Groups sponsored an economic evaluation of the PUD’s costs and benefit statement for Enloe, which was produced in 2007. The analysis, by Rocky Mountain Econometrics (RME), shows that Enloe Dam will be an economic loss for the PUD. It will not be possible to produce power at Enloe for less than the costs, and for less than the open market price for power. RME’s analysis also pointed out the potential loss of tourism revenue from scenic viewing of Similkameen Falls on the new Similkameen River Trail.
Enloe Dam is 90 years old. It has not produced power in 50 years. If PUD does not license and build this time, BLM, which owns the land Enloe sits on, wants a study of dam removal.
If the dam comes down, the Similkameen River will run free its entire 320 mile length – and welcome home the native fish. —Jere Gillespie
Oroville – On July 13, 2012, public interest organizations criticized the Washington State Department of Ecology for certifying that a proposed hydropower project would meet state water quality standards, when the project would instead effectively dewater a historic waterfall on the Similkameen River in Okanogan County. The state agency’s decision, known as a “401 Certification (with Appendices A-J)” under the federal Clean Water Act, will move forward a proposal by Okanogan PUD to reactivate Enloe Dam for a small amount of hydropower by diverting almost all the water from Similkameen Falls. Ecology’s decision ignores the tremendous public benefit of the Falls for tourism, aesthetics and recreation. The beauty of the Falls has made them the focal point of the newly developed Similkameen River Trail, which will become part of the 1,200-mile Pacific Northwest National Scenic Trail. If Enloe Dam is reactivated, the viewpoint of this new trail will be a trickle of water. Moreover, Ecology’s decision runs roughshod over the Falls cultural and historical importance to the region’s First Nations and Native American Tribes.
“We are very disappointed with this decision,” said Rich Bowers of the Hydropower Reform Coalition. “A major purpose of the certification is to protect and maintain public values and existing and designated uses of the river. This decision ignores the outstanding aesthetic, recreational and tourism values, which bring significant revenue to the Oroville area. On top of this, we lose the waterfalls itself.”
“It is even more disappointing considering that the proposed project, even with dewatering the Falls, is an economic loser for the utility, for local ratepayers, and for the state,” said Thomas O’Keefe, Northwest Stewardship Director for American Whitewater. “An economics analysis released earlier this year showed that the utility will lose $26 for every megawatt hour produced at the dam. This has been a major concern for both local ratepayers and Northwest river advocates.”
Okanogan PUD has asked the Federal Energy Regulatory Commission (FERC) to issue a license to install turbines at the existing Enloe Dam, which blocks the Similkameen River about four miles west of Oroville, Washington. Originally built in the early 1900’s, Enloe Dam has not generated hydropower since 1958. The current license application, pending with FERC since 2008, is the PUD’s fourth attempt since the mid-1980’s to add power generation to the dam. Previous licensing efforts failed due to poor economics and fish passage issues.
“Similkameen Falls is a pivot point in our area’s past and future,” said Jere Gillespie with the Columbia Bioregional Education Project. “It is important that the state take the public values provided by Similkameen Falls into account, and not just issue a blanket approval for a proposal that will destroy these values year round, and will at the same time increase electric bills for every Okanogan ratepayer. The price that ratepayers will pay is to gaze at a dried-up waterfall and lost tourist opportunities. How wrong this is.”
“Enloe Dam has not operated for 50 years, and has been controversial for both environmental and economic reasons since it was first built,” said Suzanne Skinner, with the Center for Environmental Law & Policy. “Allowing a utility to dry up Similkameen Falls and to kill local tourism revenue from the Falls is a poor decision for all of Washington State.”
For more information:
Rich Bowers, Hydropower Reform Coalition, 360.303.9625
Jere Gillespie, Columbia River Bioregional Education Project, 509.485.3844
Suzanne Skinner, Center for Environmental Law & Policy, 206.456.3827
Thomas O'Keefe, American Whitewater, 425.417.9012
Oroville – Today, several national, state, and Okanogan County-based public interest organizations appealed a decision by the Washington State Department of Ecology that would allow a proposed hydropower project on the Similkameen River to move forward. The project, proposed by Okanogan PUD, would reduce Similkameen Falls to a trickle. The Falls are located immediately downstream of the dam and could potentially attract thousands of visitors to the area each year, bringing up to $516,000 to the local economy. The groups appealed the decision because Ecology failed to adequately consider the water quality and aesthetic impacts of the project, which are an important part of the state’s water quality standards under the Clean Water Act.
Enloe Dam blocks the Similkameen River approximately four miles west of Oroville, Washington. The dam, which was originally built in the early 1900’s, has not generated hydropower since 1958. This is Okanogan PUD’s fourth attempt since the mid-1980’s to add power generation to the dam, and previous licensing efforts have failed due to poor economics and fish passage issues. An economic study completed in 2012 by Rocky Mountain Econometrics shows that the project is still economically unsound, and that the Okanogan region would lose $20 million over the term of the license while simultaneously dewatering the Falls.
“The Falls are important to this community,” said Jere Gillespie with the Columbia Bioregional Education Project. The group, which is based in North Okanogan County, filed the appeal along with the Center for Environmental Law and Policy, the North Cascades Conservation Council, American Whitewater, and Sierra Club. “Ecology’s decision ignores not only the Clean Water Act, but the tremendous public and economic benefit of the Falls for tourism, aesthetics and recreation.”
The beauty of the Falls against the stark landscape has made them the focal point of the newly developed Similkameen River Trail, which will become part of the 1,200-mile Pacific Northwest National Scenic Trail. If the dam is reactivated under Ecology’s present certification, the viewpoint of this new trail will be a dried up reach of boulders. Ecology’s decision also ignores the Falls’ cultural and historical importance to the region’s First Nations and Native American Tribes.
“Ecology acknowledges in its certification that aesthetics are a designated use under state law for the Similkameen River, but fails to protect the beauty of the falls,” said Thomas O’Keefe of American Whitewater. Average natural flows in June are 7,580 cubic feet per second, and fall to 500 cubic feet per second during the driest month of September. Ecology’s certification allows for flows of 10 cubic feet per second - 50 times lower than the lowest natural flow. “This would have a significant impact on the falls and water quality downstream,” said O’Keefe.
“Ecology cannot ignore its responsibility to protect aesthetics on behalf of all citizens,” said Suzanne Skinner, with the Center for Environmental Law & Policy. “Allowing this utility to dry up Similkameen Falls sets a terrible precedent that ignores the law and is bad policy for the people of Washington State.”
The waterfalls advocates are represented by attorneys Andrea Rodgers Harris and Kristen J. Larson.
Links & Contacts:
• Columbia River Bioregional Education Project, Jere Gillespie, 509.485.3844, email@example.com
• Center for Environmental Law & Policy, Suzanne Skinner, 206.456.3827, firstname.lastname@example.org
• American Whitewater, Thomas O'Keffe, 425.417.9012,email@example.com
• North Cascades Conservation Council, Rick McQuire, 206.363.6954, firstname.lastname@example.org
• Columbia River Future Project—Sierra Club, John Osborn, 509.939.1290, email@example.com
Similkameen River flow July through May is shown by the green line in the graph at right. Flows range from a high spring runoff in July to low flows in September, coming up again in the Fall, low again in Winter, and then rising with the Spring snow melt in April to June.
This is an average low water year. The red dashed line at bottom of graph shows the PUD's proposed low flows of 30 cfs and 10 cfs.
The WA Dept. of Ecology has granted a permit to the PUD that authorizes the proposed low flows.
Hearing begins to determine if State Department of Ecology disregarded public interest duty, violated laws, and ignored economic data in approving Public Utility District (PUD) diversion
On Tuesday, April 16, the Pollution Control Hearings Board (PCHB) will begin a four day hearing to decide whether Washington State Department of Ecology (ECY) can allow a utility to effectively dry up a river in order to generate only a few megawatts of power. River advocacy groups are asking the Board to require ECY to fully assess the aesthetic and recreational values of the Similkameen River and its falls as required under the Clean Water Act, before deciding whether the Okanogan PUD’s proposed power generating project can reduce Similkameen Falls to a trickle for more than eight months each year.
Two days after the hearing concludes, on April 21, elders of the Upper and Lower Similkameen Indian Bands will share the history of their people and their connection to Similkameen Falls. Similkameen Sunday will take place at the Community Cultural Center in Tonasket.
The appellants are Columbia Bioregional Education Project, Center for Environmental Law & Policy, North Cascades Conservation Council, American Whitewater, and Sierra Club. The groups are represented by attorneys Andrea Rodgers Harris and Kristen J. Larson.
Enloe Dam blocks the Similkameen River approximately four miles west of Oroville, Washington. The dam, which was originally built in the early 1900’s, has not generated hydropower since 1958. This is Okanogan PUD’s fourth attempt since the mid-1980’s to add power generation to the dam, and previous licensing efforts have failed due to poor economics and fish passage issues. The PUD’s proposal also ignores the Falls’ cultural and historical importance to the Upper and Lower Similkameen Indian Bands.
If approved, the power generating project proposed by the Okanogan PUD would reduce Similkameen Falls to a trickle, and undermine the aesthetic and recreational values of the Falls which are located immediately downstream of Enloe Dam. The beauty of the Falls against the stark landscape has made them the focal point of the newly developed Similkameen River Trail, which will become part of the 1,200-mile Pacific Northwest National Scenic Trail. The new river trail is projected to attract thousands of visitors to the area each year -- bringing up to $516,000 to the local economy. By contrast, an economic study completed in 2012 by Rocky Mountain Econometrics (www.rmecon.com) shows that if the PUD's project is implemented, the Okanogan region would lose $20 million over the term of the license.