Seattle City Light is not required to study effects of removing the Gorge Dam as it seeks to relicense its Skagit River Hydroelectric Project [P-553], FERC ruled July 16.
The decision is based on the agency's study criteria and came as part of its determination of what studies will be required—and which will not—following months of proposals and meetings between Seattle and its stakeholders.
SCL spokeswoman Julie Moore told Water Power West the current cost estimate for these studies is now just under $27 million.
Of 33 studies SCL agreed to conduct, FERC approved 20 as proposed and 12 others with additional recommendations from its staff. The commission said one study of the 33 is not required.
Eight additional studies sought by stakeholders—including the study on impacts of removing Gorge Dam—are also not required, FERC said. However, the agency noted in a cover letter, nothing in the study plan should limit any agency from exercising its independent authority to require additional studies.
Gorge Dam is one of three in the Skagit project that together produce about 2.5 million MWh a year, or 285 aMW. In 2019, SCL began collaborating with more than 30 licensing participants—including tribes, state and federal agencies, local governments and nonprofit organizations—to develop an application for a new FERC license for the next 30 to 50 years.
SCL's license to operate the dams expires in April 2025. Since the projects were last licensed in 1995, Skagit River Chinook salmon, steelhead and bull trout have been listed as threatened under the Endangered Species Act.
FERC's study plan ruling is a "major milestone" in the relicensing process, Moore said in an email to Water Power West. That decision, along with agreements SCL made with its licensing participants that go beyond the agency's requirements, charts a path for the studies that SCL will conduct over the next two years.
"Ultimately, this study program will inform the development of protection, mitigation, and enhancement measures for the Skagit River watershed to be implemented during the next FERC license," she wrote.
Moore also said Seattle City Light will implement study modifications as agreed to with stakeholders even if they were not required under FERC's decision.
"It's been City Light's position that we are not going to limit our research and stewardship activities to the FERC relicensing process, and we continue to engage with [licensing participants] and other organizations on caring for the watershed," she wrote.
In early June, SCL modified its revised study plan after resolving some of the differences with stakeholders on the scope and methods for certain studies. SCL asked FERC to settle any outstanding issues.
One of those issues was a request by the Upper Skagit Indian Tribe to include a study on the impacts of removing the Gorge Dam, which the tribe says prevents access to 2.9 miles of essential fish habitat, 158 miles of suitable salmon habitat and 40 percent of the watershed for anadromous fish.
The tribe wanted SCL to identify potential options for dam removal, including engineering feasibility and cost estimates, along with the benefits of dam removal on salmon and steelhead, and several other analyses.
In comments, American Whitewater said it was not actively advocating for the removal of the Gorge Dam, but was interested in better understanding the alternative and supported the tribe's request.
SCL countered that there is no connection between its relicensing effort and a study on removing the dam, noting that the request is for a mitigation measure which has not been deemed necessary or warranted.
FERC found that "decommissioning is not a reasonable alternative to relicensing in most cases," and said it waits until an applicant proposes to decommission a project or a participant in relicensing demonstrates there are serious concerns that cannot be addressed with appropriate license measures.
"Here, the Gorge Development generates approximately 998 gigawatt hours per year, which accounts for 40 percent of the Skagit Project's overall generation. In turn, the Skagit Project supplies approximately 20 percent of the City of Seattle's overall generation needs," FERC wrote.
The dam is also used for flood control and to maintain flows needed for fish downstream.
"City Light does not propose decommissioning, nor does the project record demonstrate that there are serious resource concerns that cannot be mitigated if the project, including the Gorge development, is relicensed with appropriate salmonid protection measures, and no detailed decommissioning proposal has been proposed," the decision states.
Seattle City Light did agree to include a genetics baseline study on native reservoir fish that will be completed despite FERC's ruling that it was not required. While genetic information would be useful for management purposes, it is not needed for FERC to assess the project's effects or passage of species for licensing, FERC wrote.
Moore told Water Power West that the reservoir native fish genetics baseline study grew out of a discussion about the adequacy and accuracy of existing genetic information describing the origins of fish communities in the three reservoirs.
"In particular, existing information suggests that bull trout in Ross Lake are from a different origin than the bull trout residing in the Skagit River below Newhalem," she said. "Understanding and preserving such differences can be important for long-term population viability and preservation of rare adaptations to local conditions, and can be critical to effective management."
She said while existing information appears to be sufficient to characterize genetic diversity for FERC's purposes, Seattle City Light and license participants agree that consolidating and synthesizing relevant data and studies would be valuable. They will establish a common baseline for genetic native fish populations of rainbow trout, bull trout and Dolly Varden in the three reservoirs; help SCL understand where population boundaries may exist to provide a foundation for identifying data gaps; and support a future reservoir fish management plan.
FERC determined that eight studies requested by other entities are not required. In addition to analyzing the impacts of removing the Gorge Dam, these studies include analysis of reservoir shoreline and riparian habitat; aquatic and riparian productivity; reservoir fish populations; angler creel surveys; mitigation lands costs and benefits; mitigation lands access, stewardship and habitat; and terrestrial wildlife habitat connectivity.
Some of the nearly three dozen studies that will be conducted include modeling for operations and instream flows; fish stranding and trapping risks; vegetation mapping; and assessments on everything from rare and endangered plants, wetlands and amphibians to habitat for beavers, golden eagles, northern goshawks and northern spotted owls.