So this thread does not cover the actual details on how to file an eComment w/ FERC. See the other thread for that which outlines the process. This thread is devoted to writing the actual eComments, or letters to FERC.
¡---The deadline for filing comments is 4/27/2016---!

I have filed two comments with FERC so far, and will post them up in this here thread. Since an individual may file more than one comment, it may be helpful to write a different comment for each different issue. There are many reasons why Hydro Development on the Skykomish River is a bad idea.

My first comment focused on three different existing protections for that stretch of river, because those are aleady legally established and therefore that should be the beginning and the end of this issue.

The second comment is focused on the ongoing landslide. Both how it may be potentially destabilized by blasting the tunnels, and also a county survey that indicates the slide area is on a "Buried Valley" which could eventually re route the river around Sunset Falls itself.

Anyway, yall can mine these two comments for the figures that are there, copy it or whatever just put it in your own words. I will make each comment I files a separate post.

So that was my first comment, focused on the Existing Protections that should be legally adhered to.

This next one is focused on the landslide...I posted pictures of it in the gallery here on PP.

By the way, Since I am subscribed to FERC docket #P-14295, I get an email notification each time a new document is uploaded to the docket. So I get a little chime on my phone every time a comment card or eComment is filed, and subsequently have read most of the comments filed so far, so for those of you who pulled the trigger and submitted comments by now, I appreciate it.

If you want to do like I did and post what you submitted here that would be great too and maybe help others draft something up.Some of the comments paddlers have made have been fantastic- well reasoned arguments that make a substantive point.

Here's what I wrote,
Sorry for the slow response JP! Keep pushing buddy!

Greetings,

I am writing to express my sincere disappointment that a dam is being considered on the Skykomish River near Sunset falls. As a PUD user, I can't help but feel there must be some sort of private interest that stands to gain from this ridiculous project. I say this because it seems like a terrible idea in every regard. Some wealthy interest making money seems like the only plausible motivation.

I have read quite a bit of literature on the effect of dams for fish and other aquatic life. The results are often appalling. We have already decimated the Northwest fish population with dams, clear cutting (soil erosion), and pollution amongst other things. How can we even be considering adding a dam when we are removing them all around the Northwest? Fishermen as well as many other species rely on the fish for their survival, well being, and enjoyment.

Another concern that comes to mind is our pristine Northwest scenery. The Northwest is moving away from dams, logging, and mining. Those industries are no longer economically feasible. Only a few wealthy citizens benefit from widespread destruction. The contemporary/future industry that will be successful in rural areas is tourism. We will run out of rivers to dam, trees to cut, and minerals to mine but we will always have our beautiful scenery if we are careful to protect it. Eco-tourism is the future for rural Northwest communities, it is time to embrace that. I myself know hundreds of people who use the Skykomish River for various forms of recreation. Adding a dam to POSSIBLY lower electricity costs is an incredibly ill conceived idea.

Thank you for reading and for giving the opportunity for public comment. I sincerely hope rational and logical minds will prevail to cancel this project. Although I am sure the idea had good intentions, when one considers all the factors, costs, and benefits; it becomes clear that a dam has no place on the Skykomish River.

Kind Regards,
Colby Bishop

Hey PP! It's really awesome to see how many people have put time and effort into writing to FERC and going to that meeting on Tuesday! We have such an amazing community here!
THANK YOU JP for encouraging us and pushing us so hard to Save The Skykomish!

Here's a copy of what I sent to FERC:

Dear Secretary,

I am writing in regards to docket # P-14295-001, the Washington Sunset Fish Passage and Energy Project. I strongly oppose the Washington Sunset Fish Passage and Energy Project.

Please read the Washington State Legislature’s webpage on the Skykomish river and the river’s Wild and Scenic designation. Here is a link to the website: http://apps.leg.wa.gov/rcw/default.aspx?cite=79A.55&full=true

The Washington State Legislature’s webpage under section 79A.55.070 states “The Skykomish river from the junction of the north and south forks of the Skykomish river to (b) Upstream approximately twenty miles on the south fork to the junction of the Tye and Foss rivers.” This description of the south fork Skykomish river clearly indicates what sections are covered under the Scenic River System and is indeed on the same section of river as the above proposed hydroproject. I am extremely surprised this project has gotten as far as it has without more simple notice of this FACT. Documentation posted by FERC in August 2013, resisted comments by outsiders and tried to confirm the fact this is not a protected section of river, but it very well is.

The Skykomish river is one of the most beautiful areas in the state of Washington. Why would you want to potentially ruin it with a hydroproject that is not projected to make an immense impact in the amount of power it can produce at a reasonable cost? There are more cost effective and less environmentally impactful options like solar and wind power, available at our fingertips. Multiple millions of dollars are needed to just make this project happen. These millions of projected dollars do not clearly state how much this facility will cost to maintain over it’s time in use either. The cost started at $170 million dollars and has only continued to rise since the initial estimation.


The Sunset Falls area is already riddled with it’s own landslide issues that have been progressing naturally over time. How can PUD protect the people’s home’s and properties along the river during this project? Can the PUD protect the lives of their workers and people contracted to do the project? Can the PUD guarantee they won’t further the landslides while they drill and blast through bedrock and river rocks? Can PUD guarantee protection of the Skykomish river waters from pollution from drilling, blasting, and disturbing local mines? Last year the Animas River in Colorado suffered a huge disaster when a mine was “accidentally” disturbed. What happens when large amounts of rain and snowmelt make the Skykomish flood? Can the PUD provide it’s project from being destroyed by 100,000 cfs (cubic feet per second) of water, boulders, rocks, and trees making their way down the river, naturally?

Today, across the United States, South America, and other countries, we are striving to rid our rivers of dams we thought would change our energy future. Only to discover these dams are not cost effective, they require daily maintenance, and staff around the clock to keep them in working form. Over time these dams and hydroprojects become more of an eyesore, money traps, unstable, and cause a huge environmental blockade to natural processes only a free flowing river can provide.

Granted this is not a proposed dam, this is a hydro-electric project that would include a 7 foot high, 260 foot long diversion weir and intake structure. PUD is proposing to build a tunnel that would divert 2 naturally occurring waterfalls, Canyon Falls and Sunset Falls, and about 1.1 miles of the south fork of the Skykomish River. The PUD has tried to state they have the natural habitats and inhabitants of the Skykomish drainage kept in mind during the project’s formation, but so far I have only heard information that is not directly pertinent and does not make sense to me. The PUD was asked to provide clear documentation on the effects the bypass for salmonoids (baby Salmon), but they only provided documentation on the adult fish, which are much bigger and durable and able to sustain a more “unnatural” journey over the bypassed waterfalls. Currently the salmonoids safely fall over Canyon Falls, recover in a pool, then fall over Sunset, and recover, again, in a pool before journeying downstream. If the salmonoids were expected to go through the diversion, they would lose out on the much needed “recovery time” between pools and this would likely cause an increase in salmonoid deaths, decreasing the salmon population. The project also mentions decreasing natural water levels and increasing the natural water temperatures. Both of these actions will largely change the water habitat and finitely affecting the inhabitants which are already in need of our watch and care, so they don’t disappear (Bulltrout, Chinook, and Steelhead are examples).

I am also an avid whitewater enthusiast amongst thousands of whitewater enthusiasts that have learned the ropes on the Sky. The Skykomish river has helped me transform my abilities in a kayak by providing a beautiful environment that offers class 1 to class 6 rapids and features. The Skykomish has offered me a beautiful spectrum of mother nature that no other place can provide. The “Sky” is a place I can escape to, to avoid the city, get my whitewater, and nature fix. I have seen eagles, herons, ducks, and countless salmon along my river travels.    There’s also a community of river people that love the Sky just the way it is and would hate to see any detriment or harm come to such a beautiful area or it’s above water and underwater inhabitants.

Please respect the Skykomish river’s Wild and Scenic designation and protect it from further damage and unnatural modifications. Please help to protect our waterways and our future!

Sincerely,

Megan Paige Kelly

So you see there are many angles to approach this. And as boaters, you know that more often than not, how your line through a rapid goes is all about the approach.

I'd be interested to hear what they had to say about the fishies yesterday!

Again everyone who is taking the time to comment is awesome and thank you!

yep, Tom and others have done great work on this.

I do want to point out that the Sky *IS NOT* a Wild And Scenic river. That's part of the problem. If it was a Federally Protected Wild And Scenic River, this proposal could'nt have gotten this far.

But It is Eligible for Federal Wild And Scenic status . It no longer will be if this project goes through. Some comments I've read confuse this distiction, but I almost think it helps, rather than hurts, our case. Because the Sky is in this blurry limbo zone between being protected and not. People think it is already protected and so they are shocked this is happening, and should be.

It is a State Scenic River, which does afford it some protections, and it does state the area under contention is protected from hydro development. But the language is softer than the more iron clad Wild and Scenic designation.

Read my eComment that I posted upstream in this thread. It enumerates the three ways that aleady legally protects Sunset from hydro. SnoPud is basically ignoring actual laws on the books and essentially FERC is a potential enabler of this, "aiding and abetting" snoPUD.

That's why we have to hold both of these agencies accountable by weighing in on this idiocy.

Anyone who wants help drafting an Iron Clad eComment, send me a PM over the next few days or so. Time is running out. I will be glad to help in any way I can.

So, that's starting to get above my pay grade real fast, but I think we need to include it in the dialog for sure.

Now we are expanding the scope of this issue to also encompass letters to our representatives in the Senate and in Congress. Sounds like a great little side project for the summer after this comment period ends. Wanna help, Megan? Haha! Anyone else who is keen too- send me a PM let's switch to email mode.

For now though, let's focus on writing our own comments and helping others to write and file theres. Outreach.
See my next thread titled:

Copy, Paste, Remix and Send

jP and others

Thanks for taking the lead in this matter

I have certainly done my tiny tiny bit by adding my voice to the rest of your voices

Thanks for the sample comment

I dont get to paddle the Sky as much as you guys do, but absolutely love the river and it's drainage

Bump.  Great resources for having a voice in this, thanks to JP and everyone else.  

Below are my comments to FERC. Feel free to use anything you like for crafting your own comments.




I write today as a Snohomish County PUD ratepayer and lifetime resident of the beautiful Pacific Northwest to voice my strong opposition to Snohomish PUD's plan to build a hydropower project on the SF Skykomish River. I have spent my life rafting, kayaking, fishing, swimming, and hiking in and around rivers and know the Skykomish to be a truly special place. Please DENY this license application for the following reasons:

PROTECTIONS IGNORED:
Washington's State Scenic River System lists several sections of the Skykomish River watershed. This act was enacted to protect rivers which " possess outstanding natural, scenic, historic, ecological, and recreational values of present and future benefit to the public" from exactly this kind of project.  RCW 79A.55

Washington State Dept. of Ecology Minimum Steamflows for fish habitat will be violated by the removal of water from the 1.1 mile section of river. WAC 173-507-020

The Northwest Power and Conservation Council lists this section of river as one that should remain free of hydropower development.

In addition, the USFS has recommended the Skykomish for inclusion in the National Wild and Scenic Rivers System. THIS is what the Skykomish deserves.

DETRIMENTAL TO RIPARIAN ECOSYSTEM
The Skykomish is a large river with a diverse ecosystem. The PUD's assertion that the project will not affect the fish and other species that rely on the river is ludicrous. The river is host to not only the migrating salmonids, but also hosts many native fishes, and a wide variety of smaller animals from insects to crustaceans. The river is also home to many species of birds, reptiles, amphibians, and mammals that rely on the river and the greater ecosystem it provides. This project will dewater over a mile of river. This will increase water temperatures and lower oxygen levels. Both factors contribute to higher mortality for a number of the fish and animals who live in and around the river.

Additionally, this project involves blasting an enormous tunnel under the river bed, and will increase turbidity and contamination of the water, leaking heavy metals and other contaminants into the river system. The pool below Sunset Falls is very large and it is known to be a rearing pond for many species of fish, including the small population of Sockeye salmon that migrate every year to the Skykomish. Putting this project just above this spot is a dangerous proposition for the fish and those species that depend on them such as otters.

POOR SOURCE OF POWER
By PUD's own estimates this project will provide an amount of power that will equal only a percentage of their power needs in the low single digits. That is a best case scenario. The project will not provide year-round power.  In summer and early fall water is almost always too low for power generation. In the rainy season, from November to March levels are sporadic and dependent upon rainfall. Being a run of river project there is no way to hold back water from storms to keep power going, so there will be high enough water for power a few days at a time at best. Monthly averages do not tell the full story here. The river rises and falls quickly. The only real consistent time when power can be counted on would be during spring snowmelt time in May and June. OH WAIT! Consider for example in 2015 there was a very low snowpack. Had the project been online last year, there would have been insufficient water for power generation for most of the year.

FISCALLY IRRESPONSIBLE
PUD's original estimate was $170 million for just the construction of this project. At this time the estimate is now up to $225 million AND they've already wasted at least $5 Million in scoping alone. If the past in any indicator, that number is sure to rise and doesn't take into account the cost of maintaining and running this project. The recent public outcry over billing issues does not inspire confidence in the PUD's ability to manage the ratepayer's money. Neither does the PUD's recent small hydro project on Youngs Creek, which is currently costing the ratepayers plenty with very little power generated.

GEOLOGICALLY UNSOUND
This proposal, by the PUD, calls to use explosives to blast a huge two story high tunnel, underneath the riverbed of one of the most powerful rivers in Western Washington in a very close proximity to an active landslide. Also, the river takes a turn though a horseshoe bend at the proposed site that has the geological markings of a spot a river could cut through, especially if the river is dammed by a slide. If that happens the river will bypass the projects' intake and render the project utterly useless. Waterfalls are geologically active areas. Do we really know what will happen when you start blasting a giant hole underneath the river bed here? I fear the potential catastrophic aftermath of blasting at the site of these waterfalls and the active landslide. To blast near an active slide is irresponsible at best. To do so in Washington, in the wake of the Oso disaster is unconscionable.



As I've illustrated, there are many reasons why this proposed project is a horrible idea and is not in the best interest of the public, the environment, or the otters, damn it! In this day and age we have finally started to learn the errors of the past and are working to correct the mistakes we've made. We have begun removing hydropower projects in favor of truly renewable and green energy sources and conservation. Why is Snohomish PUD hell bent on replicating the errors of the past and destroying what is good, clean and beautiful for a paltry bit of energy that will be much more expensive to produce than our current avenues for power?

Our wild and wonderful places are getting fewer and farther in between. The Skykomish is one of the best. It is truly special and to desecrate it with this ill conceived horror is a legacy we will all regret.

Please DENY the license for Snohomish PUD's Sunset Falls project license.

Thank you.