American Rivers, The Pacific Rivers Council (formerly The Oregon Rivers Council) and Oregon Trout (Conservation Intervenors) hereby submit their comments and recommendations pursuant to section 10(a) of the Federal Power Act (FPA), 16 u.s.c. S 803 (a), as amended, on the application of Pacificorp Electric Operations (PP&L or the Applicant) to relicense the Bend Hydroelectric Project.
I. Introduction: Background of the Bend Project
The Bend Hydroelectric Project was constructed in 1913 at River Mile (RM) 166 on the Deschutes River within the City of Bend, Deschutes County, Oregon. The project’s 14-foot high, 252 footlong dam impounds the 40-acre Mirror Pond Reservoir. The powerhouse contains three turbine generator units with a total installed capacity of 1.1 megawatts; however, the project generates only approximately .60 average megawatts annually.
Prior to dam construction, trout populations were abundant in the upper Deschutes River. These fish migrated freely through the upper Deschutes River to reach spawning grounds in the upper mainstem and tributaries. Today, however, rainbow and brown trout have declined significantly from their former numbers in the upper Deschutes, both below and above the Bend Project. While there are many reasons for this decline, the oregon Department of Fish and Wildlife (ODFW) has found — and PP&L admits — that the Bend Project has contributed significantly to it.
Recreational use of the Deschutes River also has been impaired by the Bend Project. There is limited recreational access to the river in the area of the Project, and reduced flows in the Project bypass reach limit recreational opportunities.
The Bend project license, which has controlled project operations since 1965, however, contains no conditions for fish passage, fish protection devices, such as a tailrace barrier, or minimum instream flow requirements for the bypass reach of the project to support fish spawning, rearing, and migration; nor have recreational flows ever been set for the bypass reach. What is worse, the Applicant has offered essentially to do nothing to improve conditions for migratory fish or recreationists, despite the fact that it has had free use of the river for decades and is asking for license to use it for yet another 30 to 50 years for private gain.
Full Document: American-Rivers (PDF)