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`August 8, 2006 Sl
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`T Tl
`Mr. Marty Douglas 0l A 1y p 27
`Public Affairs Manager
`Eugene Water & Electric Board M e e
`500 East 4th Street Seil it e
`Eugene, OR 97401
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`RE: Commenis on Carmen-Smith Hydroelectric Project Draft License Application
`FERC No. 2242
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`[ have been closely following the DLA process for Carmen-Smith for some time. I had
`myself placed on the interested parties list to receive updates on the development of the
`license; 1 am a citizen of Eugene, EWEB rate payer, and civil/ structural engineer with 32
`years of experience. [ am interested that EWEB address environmental impacts caused
`by the project over the past 50 years to the highest possible extent. Please accept this
`letter of interest and place me on EWEB's interested parties list for DLA, FLA, and
`FERC and NEPA processes for project licensing.
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`EWEB's mission statement for licensing is:
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`"Obtain a new federal license for the Carmen-Smith Hydroelectric Project so that the
`project can continue o operate in an environmental, socially and economically
`sustainable manner."
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`Throughout the draft license, EWEB tends to minimize the past and current
`environmental impacts of the project. In Exhibit "A" and elsewhere, EWEB calls the
`project a "run-of- the- river” hydroelectric project. Run-of-the-river hydroelectric plants
`use the power in river water as it passes through the plant without causing an appreciable
`change in the river flow. Carmen-Smith project dewaters approximately 7 miles of the
`main stem of the McKenzie River (via Carmen Diversion and tunnel) and dewaters
`approximately 3 miles of the Smith River (via Smith Dam and tunnel). This is in no way
`a run-of-the-river project and references that it is should be eliminated throughout the
`applicati
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`The draft license application does not quantify what EWEB is proposing. The executive
`summary in Exhibit "A" provides of condensed list of proposed actions; there is no where
`in the document that I could find a detailed (or even simplified) description of the action
`proposed. In order words, it's an executive summary drawing on ... nothing, For
`example "Make one time payment for..." or "Develop plan to...(woody debris and ather
`enhancements)” are overly subjective. Make a $50,000 payment or $19.997 [s EWER
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`Mr. Marty Douglas
`Page 2
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`only planning to place woody debris, placing woody debris (or not), and how much? 1f
`the details of enhancements are buried in the Appendix E environmental reports, say
`where, develop reasonably understandable summary descriptions, and provide cost break
`down for and magnitude of work proposed.
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`Currently EWEB is only proposing upstream fish and lamprey passage at Trail Bridge
`Dam. Downstream passage is "to be determined”. No up or downstream passage at
`Smith Dam and Carmen Diversion is proposed. Economics alone should not determine if
`populations of species behind dams not planned for any passage should continue to be
`isolated from others of its kind. No mention of the study of up and downstream fish and
`lamprey passage, environmental impacts, or costs has been provided for Carmen and
`Smith dams in the DLA. How can the public understand the decision not to provide
`passage? In a typical NEPA process, these critical issues would be fully addressed.
`Attached 15 a concept for Smith passage that [ believe has not been looked at for your
`information.
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`EWERB is proposing to provide 200 cfs minimum year around flow in the Carmen by-pass
`reach and 1o divert excess over that amount to Smith Dam "to protect cut throat fish®. It
`is my undersianding that only very minimal studies have been performed on the Carmen
`by-pass reach. How does EWEB know 200 cfs is the correct amount? The resource
`agencies feel up to 350 cfs should be considered. How does EWEB know not bypassing
`higher flows would not be beneficial to Beaver March wetlands and/ or other species?
`Obviously, the more water bypassed, the less can be used for generation in the Carmen
`plant. Ramping of bypass flow may mitigate the effect on cut throat trout and provide
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`EWEB 15 propasing to provide 20 efs minimum year around flow in the Smith by-pass
`reach. [ have all of the same comments as the Carmen by-pass. The flow is extremely
`minimal by any measure. In addition, there is no description of how the flow will be
`provided.
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`In Trail Bridge Reservoir, draw down limits and pool and river ramping rates may have
`to be made more resirictive to protect fish. Sweetwater Creek needs year around fish
`passage from Trail Bridge Reservoir pool and is often stranded. These environmental
`improvements may require EWEB to generate less overall and peaking power from
`Carmen and Trail Bridge Plants.
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`EWEB indicates that many envircnmental improvements may not be practical or cost
`effective. in terms of short term effects on species and cost. Much of this has to do with
`1) not listening to the resource agencies concerns, 2) the extremely conservative and non-
`innovative engineering EWEB is having performed, and 3) cost estimating inefficient
`designs. Some of these types of issues can be resolved by using underwater construction
`techniques, innovative design, input from experienced heavy civil contractors, and peer
`review. Itis my understanding that none of this is occurring for this crucial EWER
`project. I recommend that the resource agencies require or hire experienced consultant
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`Mr. Marty Douglas
`Page 3
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`peer review all of EWEB's preliminary engineering for fish passage, or EWEB provides
`it before it being excepted as fact by the resource agencies.
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`In Exhibit "D", project finances, a better break down of costs is needed. I believe there is
`a blending of environmental and life extension costs. EWEB indicates that licensing will
`cost $65M. For example, where is the new proposed access road to Smith Dam; in fish
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`and agquatic resources (environmental) or life extension improvements? One reason this
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`is important is that the public needs to understand how much EWEB is spending on the
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`environment and how much on normal and deferred O&M so that the total cost does not
`get represented as the environmental costs. [ don't think $20M to place worn out runner
`blades at Carmen Plant should be counted as an environmental licensing cost.
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`In closing, the licensing of this project will probably not be win-win for EWEB in term of
`paying for environmental improvements by generation of more power to offset the cost. |
`believe EWERB may have to generate less power and pay a high cost for environmental
`enhancement, especially if EWEB continues to not listen to the resource agencies
`concemns, and not follow its mission statement for licensing.
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`Ay & B
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`2373 Washington Street
`Eugene, OR 97405
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`C.C. M Sehs Feec -%.4,,:7;{., 2
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