Baker River Hydroelectric Project FERC No. 2150 PDEA Initial Review Comments 1/16/04 The documents available to the general public, apparently Volume I, Part 1 of 2, and Volume II, Part 1 of 2, exclude key information including the results of numerous studies and other documents that are part of the license submittal. Because so many studies are incomplete and have therefore not been incorporated into the substantive compilation of factual material relevant to the current re-licensing effort, it is difficult to comment from the County’s perspective regarding addition of flood storage in the Baker Project. For example, there are several references to study “A09,” as yet incomplete, which will provide essential information regarding salmonid spawning and rearing habitat. It is also difficult to comment on a report that does not include the recommended conditions considered necessary to protect fish and wildlife from the federal resource agencies. In numerous instances, the PDEA refers to future actions that will be undertaken after the license is issued. (See page 5-117.) The mechanism to ensure these actions are completed is not clear. It should be noted that Puget Sound Energy (PSE) has refused to conduct a flood control study1 requested by Skagit County on December 2, 2002, to verify the County’s reservoir elevation recommendations, primarily based upon a concern that this study will not be complete in time to include with the license submittal. Yet in several other areas of the re-licensing effort, results of other studies are clearly late being produced. Volume I Page VI, (8 iii) While the Project is not physically located within a special purpose district, the operations of the Project can and will have significant impacts upon the following special purpose districts that are downstream: Dike District #1 Dike District #12 Dike District #3 Dike District #17 Dike District #4 Dike District #20 Dike District #8 Dike District #22 Dike District #9 Note that the above referenced special purpose districts have expressed interest in the application for the Baker Project per the letter to Stephen P. Reynolds, President, CEO and Director of PSE.2 1 Baker River Project Relicensing Study Request titled “Evaluation of Optimal Flood Control Storage in Baker Project,” submitted by Dave Brookings, Skagit County Public Works, Skagit County PUD #1, City of Anacortes, and the Town of Concrete to the Economics and Operations Working Group, December 2, 2002. Skagit County PDEA Initial Review Comments, FERC No. 2150 Page VI, (8 iv) There are other political subdivisions that would be affected by the operations of the Baker Project that are not identified. The following cities and towns have expressed an interest in the proposed license application for the Baker Project per the letter to Stephen P. Reynolds, President, CEO and Director of PSE (see footnote 2): Town of Concrete Town of Hamilton Town of Lyman City of Sedro-Woolley City of Burlington City of Mount Vernon Town of La Conner Page B-5, B.2.4 - Reservoir Operation Curves, B.2.4.1 Lower Baker Development While flood control storage is not legally mandated in the Lower Baker Project, both historic and recent (October 2003) flood events clearly demonstrate that if the reservoir in Lake Shannon was managed correctly at the onset of a given flood event that the resulting reduction in downstream flood damages would be significant. The spreadsheets and graphs3 illustrate that during the 1990 and 1995 flood events, Lake Shannon was held at elevation 438, which is nearly at full pool providing virtually no relief for the local inflow and spill coming from the Upper Baker reservoir when it exceeds its capacity. By keeping Lake Shannon full during these events, the result was an increase in downstream water surface elevations and damages. The 1990 and 1995 events were federally declared disasters causing over $60 million dollars in actual documented damages.4 At the February 2003 Executive Committee Meeting, Skagit County and the Army Corps of Engineers (Corps) agreed to hire a consulting firm, Pacific International Engineering (PIE), to perform a reconnaissance level reevaluation of the potential benefits of additional storage.5 The results indicated that a full optimization of flood storage should be evaluated. Skagit County in coordination with the Corps hired engineering consultant, PIE, to perform the study to evaluate how the reservoirs were being operated and whether they could be further 2 May 5, 2002 letter to Stephen Reynolds, President Chief Executive Officer and Director of PSE, signed by 41 Skagit County Government Officials including the Board of County Commissioners, City and Town Mayors and Special Purpose District Commissioners requesting additional Baker Project Flood Control Storage. 3 Hydrologic data spreadsheets and graphs illustrating 1990 and 1995 flood events and Baker Dam response prepared from data supplied by PSE to the Aquatic Working Group. Analysis and supporting graphs prepared by Skagit County Public Works and distributed to PSE working groups and Corps Flood Control Operations and Corps General Investigation personnel in September and October 2003. 4 Upper Baker Flood Control PowerPoint presentation by Wayne Wagner, Corps, November 16, 2000, Page 22. Presented to the PSE Aquatic Work Group. 5 Technical Assessment of additional flood control storage at Baker River Project prepared by PIE at the direction of the Executive Committee of the Skagit River Flood Hazard Reduction Feasibility Study, completed April 9, 2003. Page 2 of 15 C:\Documents and Settings\briany\Local Settings\Temporary Internet Files\OLK1C4\PDEA (2).DOC Skagit County PDEA Initial Review Comments, FERC No. 2150 optimized for flood control.6 The Board of Skagit County Commissioners (Board) then sent a letter on May 5, 2003 to PSE, signed by 41 Skagit County government officials requesting that additional flood control be included as part of the re-licensing process. The early results of the Baker River Storage Study investigation indicated that the existing Corps hydrological data under-estimated the Baker River hydrology by 25%. The Corps is currently in the process of reevaluating and revising this data. Further results of the flood control optimization produced a model using an Excel spreadsheet which helped demonstrate the amount of additional storage available at the Baker River Project.7 This study clearly concluded that the Lower Baker reservoir could be operated differently by creating additional storage at the initial threat of a flood and at the beginning of the flood season to augment the flood control storage in Upper Baker.8 This minor adjustment in operating procedure could result in fewer downstream levee failures, reduce flood damages and save lives. In September 2003, the Board sent a letter to the Solution Team members to explain the County’s position on requesting that additional flood control be included as part of the re- licensing process.9 The Board was convinced of these findings and sent the attached letter10 to PSE on October 14, 2003, specifically requesting that the Lower Baker reservoir be maintained at an elevation of 430 (NGVD 29) from November 15 to January 15, and upon notification from Skagit County based on a National Weather Service forecast of an approaching storm event with significant flood potential, Lake Shannon be dropped an additional five feet to elevation 425 (NGVD 29) to make room to attenuate a flood event. The County also requested that generation at both of the Baker Dams be curtailed when flood flows exceed 120,000 cfs at the Concrete gage. On October 21, 2003, the Skagit River and many of its tributaries experienced heavy rainfall resulting in a 50-year flood event. PSE and the Corps collectively operated the Lower Baker11 in a manner consistent with the Boards request which resulted in a lower water surface elevation12 6 Baker River Dams Storage Evaluation scope of work prepared by Corps, revised June 11, 2003, as a delivery order to participate in and provide hydraulic engineering expertise for an evaluation for the optimal flood storage that can be utilized for Lower and Upper Baker Dams to reduce flood damages for the Skagit River floodplain. 7 Draft Executive Summary for the Baker River Dams Storage Evaluation Numeric Modeling of Historic Flood Events and illustration of model output prepared by PIE. 8 PowerPoint presentation by Corps, October 18, 2002, titled “Information and Coordination Meeting with Skagit County, Upper Baker Flood Control Project.” 9 September 9, 2003 letter to Solution Team members from the Board of Commissioners on the additional flood storage and revised operation of the Baker Hydroelectric Project. 10 October 14, 2003 letter to Stephen P. Reynolds, President, Chief Executive Officer and Director of PSE from the Board Commissioners requesting that PSE modify the operation of Lake Shannon pool during the upcoming flood season. 11 October 2003 Skagit River Flood Control PowerPoint presentation prepared by Marian Valentine, P.E., Corps, and presented to Burlington City Council on December 11, 2003. Page 3 of 15 C:\Documents and Settings\briany\Local Settings\Temporary Internet Files\OLK1C4\PDEA (2).DOC Skagit County PDEA Initial Review Comments, FERC No. 2150 and reduced damages that otherwise could have occurred.13 While Skagit County is very appreciative of this recent action,14 it clearly demonstrates the need for PSE, Skagit County and the Corps to reevaluate the reservoir operation curves and operations at both reservoirs for flood control as part of the licensing process.15 While we understand the challenge that PSE faces with balancing competing interests, we feel that the optimization of flood control should be assigned the highest priority and be given adequate consideration in the licensing process. To date, as PSE diligently tries to persuade the resource agencies to sign a settlement agreement that addresses environmental concerns, they have continually delayed any analysis of the flood control issue by withholding information and failing to act upon the County’s December 2002 study request for a thorough review of improving flood control.