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jP
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  Quote jP Replybullet Topic: Comment Period has Closed. Now What?
    Posted: 28 Apr 2016 at 12:57pm
Re: FERC Project # 14295, the So-Called Sunset Falls "Fish Passage" and Energy Project on the South Fk Skykomish River...

I'm starting this thread as a follow up now that the 90 day comment period regarding Snohomish County PUD's Draft License Application has come to a close. This thread will include a summary report of my own conclusions after reading nearly every single comment that has been posted to FERC Dockett #P-14295.This includes the filings from the various concerned agencies and NGO's who've had a stake or otherwise vested interest in this process and its outcome.

For now I want to thank anyone and everyone who filed a comment, mailed a comment, helped to engage others to comment, or otherwise actively contributed to the much needed opposition to this wrong headed idea to place a hydro project smack dab in the middle of a Wild And Scenic river. I feel that the best way to thank everyone is to shed light on some freshly tallied numbers. These numbers offer up some much needed encouragement and quite possibily point to some potential victory at some point in the future, though it is also important to note this thing is a long way from over. No chickens have hatched, so we can't really count them. The Fox has been in the henhouse since long before James G. Watt showed up on the scene and is apparently still at it. I was a kid then, still preoccupied w/ Star Wars but I remember sitting in front of the TV and clearly something was rotten in Denmark. My old man JR had an American Rivers sticker on the back of his S-10 pickup and informed me about what an ass hatt Mr. Watt was and his destructive policies.

So JR is the first person I want to thank for showing me the writing on the wall early, not to mention teaching me how to kayak. Actually DP is right beside him because she always taught me that principles of non violence were the guidelines to be followed whenever trying to get something meaningful done for the greater good. Turns out after life's many twists and turns and losing all of my worldly possesions at least twice, those tools are still in the toolbox afterall. They are indespensible and can't be taken away by anyone.

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  Quote jP Replybullet Posted: 28 Apr 2016 at 1:23pm
Ok- the rough number:

One of the Seven Samurai who I get my marching orders from is Andrea Matzke. Yesterday near the end of the deadline she dropped the mountain of petitions in FERC's already swamped lap. The combined total of paper and online signatures presses up against the 7,000 mark.

7,000 individuals have spoken out against this since 2012!

Add to that the appoximate numbers...

- 97 online comments from Sierra Club Members
- over 500 (easily. Accurate totals were had to keep a grip on- possibly 600 or more) Comment Cards. Those of you who helped us get those out to concerned people deserve a HUGE pat on the back!
- definitely more than 79 online comments during this last 90 day round, the majority of those are from paddlers. A notable amount of those paddlers from out of state.

That gets us within range of 8,000 voices of Opposition.

Another Sky Samurai, Lora Cox, summarized these totals nicely in one of her FERC comments.

Incidently I forgot the paper I wrote all those numbers so precisely on. Will come back and update this particular post, but suffice to say,

Like every ripple, wave and hydraulic adds to the symphonic choir of The River, FERC has now heard the Thunderous Roar of Mighty Mama Skykomish and her Indefatigable Spirit- THROUGH US! Because these suits who are charged with deciding her fate are far removed from her banks, and The River Can't Speak For Herself!
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  Quote jP Replybullet Posted: 28 Apr 2016 at 1:34pm
To those of you who did not comment at all for whatever reason, I am sorry you missed an opportunity to add your voice to this Floodstage of a Chorus. A sense of optimism is being felt right now. But if this beast lumbers on toward the Final License Application, those who missed this crucial comment period will absolutely be needed to weigh in later. Personally I hope this project gets SQUASHED NOW so none of us need such an opportunity. Here I gotta emphasize that our strong presence of expression was critical during this phase, and is now a solid documented expression to build upon moving forward.

With regards to where the agencies come down on, all this,
I plan to compile a summary of that too real soon. The main take away being that while the agencies obviously didn't just say no, several outlined requirements and procedures as of yet unfulfilled by the PUD with an unfavorable tone that, while vaguely detectable in some ways shows signs if encouragement.

The NWPCC outlined procedures required for PUD to obtain an "Exception" to their ruling that Sunset is within a Protected Area. As in Protected From Hydro. They noted that PUD has not begun to engage that process, and invited them to. So that's rather opaque to me but the process as outlined is detailed.

DOE came out saying it has no plans of loosening the Instream Flow Rule, meaning PUD can't leagally drain the bypass reach down to 250 cfs like they want to. Technically they can proceed, but it means less draw through the proposed intake and therefore less power generated, and at increased cost making the whole idea pretty silly.

Like I said though...
More of that later. I was 100% caught up as of last night but there is a fresh mountain to read through that could easily keep me busy till early next week, including another DOE comment and another from AW. And meanwhile Mr. Rainey and the other Sky Samurai probably have more in there that I havent got to.Stay tuned as your interest level allows, but a major push has been achieved! Now its just a matter of sitting back and waiting for the other shoe to drop.

Edited by jP - 28 Apr 2016 at 1:54pm
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  Quote JoesKayak Replybullet Posted: 28 Apr 2016 at 3:13pm
Thank you, JP for spearheading the efforts for the paddling community. I'm very happy to see our community step up to speak for the river. I truly hope that this project is squashed at this stage (and looking though all the documents I've looked though I would certainly hope it does).

If not, the next stage we'll really need to reach out to other recreational groups. The anglers and the hikers especially. We are a small group. Those groups are much much bigger and have the same interest as us in keeping rivers and other natural places unspoiled. We had a nice spring snowmelt level of comments, but if this goes further we'll need a November pineapple express flood of comments.
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  Quote JoesKayak Replybullet Posted: 28 Apr 2016 at 3:18pm
Originally posted by jP

To those of you who did not comment at all for whatever reason, I am sorry you missed an opportunity to add your voice to this Floodstage of a Chorus. A sense of optimism is being felt right now. But if this beast lumbers on toward the Final License Application, those who missed this crucial comment period will absolutely be needed to weigh in later. Personally I hope this project gets SQUASHED NOW so none of us need such an opportunity. Here I gotta emphasize that our strong presence of expression was critical during this phase, and is now a solid documented expression to build upon moving forward.

With regards to where the agencies come down on, all this,
I plan to compile a summary of that too real soon. The main take away being that while the agencies obviously didn't just say no, several outlined requirements and procedures as of yet unfulfilled by the PUD with an unfavorable tone that, while vaguely detectable in some ways shows signs if encouragement.

The NWPCC outlined procedures required for PUD to obtain an "Exception" to their ruling that Sunset is within a Protected Area. As in Protected From Hydro. They noted that PUD has not begun to engage that process, and invited them to. So that's rather opaque to me but the process as outlined is detailed.

DOE came out saying it has no plans of loosening the Instream Flow Rule, meaning PUD can't leagally drain the bypass reach down to 250 cfs like they want to. Technically they can proceed, but it means less draw through the proposed intake and therefore less power generated, and at increased cost making the whole idea pretty silly.

Like I said though...
More of that later. I was 100% caught up as of last night but there is a fresh mountain to read through that could easily keep me busy till early next week, including another DOE comment and another from AW. And meanwhile Mr. Rainey and the other Sky Samurai probably have more in there that I havent got to.Stay tuned as your interest level allows, but a major push has been achieved! Now its just a matter of sitting back and waiting for the other shoe to drop.




I read the NW power and conservation council's commets with great interest as well.

Basically they're saying, they have say as to where projects like this get built, backed up by Federal law and they say no to development on this river.

And the only way they would grant an exception is if PUD can show that the project will cause a exceptional benefit to fish and wildlife. Yeah. Good luck with that. Like you said, PUD hasn't even applied for that exception.
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  Quote jP Replybullet Posted: 28 Apr 2016 at 3:50pm
Originally posted by JoesKayak

We had a nice spring snowmelt level of comments, but if this goes further we'll need a November pineapple express flood of comments.



well said dude-

UpDate: so I got a little more detail to dump on this thread about Agency Responses. I got all caught up on every comment submitted by individuals, not one of which supports the project, BTW. Next I skim read the final Agency Filings, most of which are a minimum of 3 pages.

The most encouraging input I've read so far comes from both the Snoqualmie and Tulalip Tribes. Snoqualmie simply took two pages to Clearly say "No Way".
Tulalip evidently took 25 pages, but I didn't read it all. I skimmed down a bit to get a sense of the content, then back up to page two where I read the following:"The Tulalip Tribes strongly recommend that the Federal Energy Regulatory Commission deny this application."

I find the stance of both Tribes VERY encouraging and welcome feedback from anyone on this forum who has any quantitative guage or impressions of how much weight this will have. Early next week I will retrace my steps and thoroughly read all these last minute Agency Filings with particular interest in what Tulalip has to say. It is a thorough report. And I sh*t you not if this thing gets stopped in its tracks at this phase I will most certainly compose a sincere thank you letter and send it to both Tribal agencies.

I'm hopeful, but as we all know there is always another sequel to "Friday The 13th", "Halloween" or, the most horrific movie of all for the Sky to have to star in, "A Nightmare on California Street"

I will not be satisfied until I can dance on the grave of P-14295.

Edited by jP - 28 Apr 2016 at 4:52pm
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  Quote jP Replybullet Posted: 28 Apr 2016 at 4:45pm
Haha that last image conjures up the lyrics of Dillon's Masters of War, though actually I think I prefer Eddie Vedder's rendition. Dillon definitely has the corner on the market as far as "Last Thoughts On Woody Guthrie" is concerned.

Anyway, regardless of the outcome of this Draft License Application is concerned, if we truly want to ensure that a sequel to "A Nightmare On California Street" doesn't come "soon to a river near you", we have more work to do for sure.

Megan mentioned this not long ago (one of many reasons why you are awesome, Megan!)-
As far as the Sky goes, we need to get out of reactive mode and shift into proactive mode. We need to push and get the Sky the federal protection is qualifies for so this can't ever trouble us again. Yup this is a discussion to have w/ AW. Not trying to reinvent any wheels here.

To succeed with that effort is going to require involvement from us. So this is the answer to the question in the title of this thread "What Now?" Not that its gotta happen right-the-FERC-Now!, but it needs to happen. This is abzurd (say that w/ a british accent- that's why the z is there. FERCin Brits! When are they gonna learn to speak English, anyway?)

And, the last answer to the "What Now?" question beyond Joe's answer concerns Ernies Gorge on the N fk Snoqualmie.
I say kill two Dams with one letter, more or less. I regret I have been so focused on Sunset that the DLA for Ernies recently blew right past us. I'm not even informed of where things are at in that process, but no boater thus far has really stayed on top of it. I know the FLA phase for Ernies has not yet approached.

I pledge right here and now to help in that effort as well, but someone has to legitimately rally on that one. Its harder to engage because it almost seems like the class II-IV demographic has a (shrug)"What's in it for me?" Attitude awhile back when I tried to beat that drum.

So like it or not- and this is aimed at the Class V boaters: this is soley their baby and they will need to approach me or I'll just say "FERC it. If these FERC'n Class V kidz don't care about saving one of washington's class V crown jewels, let it go" but in reality I can't really adopt that attitude that's just me talking sh*t to reintroduce a dash of "jP classic" into the dialog.


Edited by jP - 28 Apr 2016 at 4:48pm
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  Quote jP Replybullet Posted: 28 Apr 2016 at 4:47pm
Seriously, whether the comments influence the outcome or not, its our only mechanism to effect change.

So my closing statement for now is that despite my sh*t talkin ways, I have always valued the ecclectic and rich mix of demographics that comprise our sport and the culture that is a product of it. And I firmly believe with every molocule of water in my body that We as a collective group are intrinsicly predisposed to be able to effect change in regards to these matters. Why? Because our time on the river changes us in subtle yet powerful ways. Not only as individuals and how we respond and approach situations, but perhaps more noticably as loose groups of semi autonomous units. Think about it.

Our time on the river quickly bonds us to one another out of necessity. As we adapt to an environment historicaly hostile to humans, over time without even being aware of it, these adaptations are habit forming and expand as we move through the world off the river.

I'm saying as a soft counter point to Joe's point that we are a small group, that we all share unique untapped potential to be a very focused, and productive group. But since we don't attempt to tackle these larger goals often, perhaps few of us within our (paddling) community are aware of just what our combined energies and strengths really are.

Somebody please feel free to copy any of this if it resonates with you and sling it out over FB. I don't require credit for having said it. But I believe deep down there really is something to this, and I would encourage the entire paddling community to reflect on this, and more importantly explore it through action.

We would never want to reverse the river's flow, but we can influence the flow of public opinion more than we realize. But we gotta step out of our myopic focus of our selfish Pursuits Of Boof and talk to the "normal people" we meet along our adventures. I am now getting into the topic of public engagement. Because thats how we make stuff happen.

Writing "peace, love, and save the river because I love kayaking" is great if you want to write one letter. I'm asking just a few of you (because I know most of you won't put down the bong or stop playing Super Mario Bros or Ok Cupid or whatever video game being fixated upon long enough to even read this.) to take a flight with The Eagle with me for a second and look down upon the big picture. If YOU have read this far, perhaps YOU also believe something about this.

WHAT IF you could transform your comment to FERC into twenty, or a hundred more? Its not a what if because many of you out there have helped us do just that these last 30 days. It is PROOF that it works. Its an effective strategy. But let's not kid ourselves: few off us strayed very far from our insular bubble within our lovable paddling community.

Engaging Non boaters is essential. Your tree huggin kayak brother or sis is low hanging fruit, dawg. And of noticeable yet limited impact. Tp accomplish these noble goals and reap their rewards it takes engaging the public. And this is easier than most of you think. That last summer like sunday we had I got about 60-80 cards out there without hardly even trying. Yeah, I was targeted about it but it was easy. It was the slightly not-as-low hanging fruit abundantly found in the PNW's cultural values.

If you love this sport, you need to realize you have the ability to be an embassador and you have way more influence than you realize simply by being friendly and engaging people spontaneously. They are often fascinated by our quirks and our exploits. You can't say you don't know what Im talking about.

All you gotta do is let them in. Now, once you have them and the ice is broken up, you need to have your facts straight and some articulate ability to get a message across. So the caveat is you need to know the issue.

Sorry this took so long to express but the bottom line is if you can relate to them, they will be receltive to your cause because they are already further along in their beliefs than you may give them credit for.

Hows that for a long post?

Much later yall

Edited by jP - 28 Apr 2016 at 5:17pm
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  Quote megspk Replybullet Posted: 28 Apr 2016 at 7:04pm
Originally posted by jP

To succeed with that effort is going to require involvement from us. So this is the answer to the question in the title of this thread "What Now?" Not that its gotta happen right-the-FERC-Now!, but it needs to happen. This is abzurd (say that w/ a british accent- that's why the z is there. FERCin Brits! When are they gonna learn to speak English, anyway?)


JP! I just want to say again THANK YOU for working so hard on this! If it weren't for your encouragement, I don't think FERC would have gotten nearly the number of comments that it received. I have ready MANY of the letters from residents, whitewater enthusiasts, general river lovers and dam/hydroproject haters, the local Native Tribes, and even our National Park Service. I was impressed at many of the letters and the definite effort that was made. There were some real heart wrenchers in there and some awesome in your face factual stuff that is key. I would have to say the majority of the letters were against the hydroproject happening or addressed the fact that SNOPUD still has yet to answer many of the same repeated questions about the water levels and accurate information on the how it will affect the fish population and how much power this thing can actually provide for the cost it will take to build and maintain. I didn't read all the letters, but I never read one that was for it.

I'm not sure how to go ahead on the doing the next step. There's still some questions to be answered and people to talk to, but I am IN on making that happen!! We gotta get the Sky protected so these types of permits are null and void.

Are there are other rivers out there that need our help too? I am local to the PNW since 2012, but I am still learning about all the rivers and watersheds here. I'd love to learn more about how to get engaged in helping the rivers of Washington stay the way they are or working towards an improved state of being (i.e. dam removals, habitat clean ups, etc). I think education is the key, especially when we are trying to get our non whitewater eco friends to join the crusade!

Again thanks JP!!! I really think everyone made a dent in the SNOPUD's project advancement!! Thanks to everyone that submitted a comment, no matter how big or small. Just letting FERC know that people out there are aware of what's going on is important.
“A strong person and a waterfall always channel their own path.” -Unknown

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  Quote megspk Replybullet Posted: 28 Apr 2016 at 7:12pm
Originally posted by JoesKayak

If not, the next stage we'll really need to reach out to other recreational groups. The anglers and the hikers especially. We are a small group. Those groups are much much bigger and have the same interest as us in keeping rivers and other natural places unspoiled.



You are correct on this! I didn't notice a lot of voice or presentation at the meeting I went to from fisherman or other outdoor enthusiasts outside kayakers.

One of the best letters I read on FERC was from a local outdoor lover than mentioned the surrounding hikes and beauty.   I have been very narrow-minded in my thinking about saving the rivers. We definitely need to reach out to the hikers that love Lake Serene and the other places accessible by the same access road as the project. We also need to push the Index loving crowd that includes our rock climbers and boulderer's that climb right at Boulder Drop. Snowboarders and skiers not being able to get to Steven's Pass to ride because of huge delays in traffic, would be another group I didn't think to target.

We will have to remember them if the fight continues on, but I truly hope FERC realizes how important and beautiful the Skykomish river is and stops the project.

“A strong person and a waterfall always channel their own path.” -Unknown

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