North Sound treaty tribes were joined by county, state and federal agencies in persuading Seattle City Light to take stock of how the Skagit Hydroelectric Project blocks fish passage.

In December, the utility added fish passage to the study proposal for its relicensing process with the Federal Energy Regulatory Commission (FERC). The current license went into effect in 1995 and expires in 2025. Seattle City Light operates the Ross, Diablo and Gorge dams on the Skagit River, where salmon, steelhead and bull trout populations have continued to decline despite being listed under the federal Endangered Species Act (ESA).

Letters to FERC from the Upper Skagit, Swinomish and Sauk-Suiattle tribes, as well as the state Department of Fish and Wildlife, National Marine Fisheries Service, Skagit County Commissioners and conservation groups called for a fish passage study to be conducted as part of the relicensing process.

The Upper Skagit Indian Tribe has taken it a step further, and has requested the analysis be done for Gorge Dam removal, returning the Skagit River to the Gorge bypass reach and transporting fish into all three of the project reservoirs.

“In the Tribe’s view, the biggest natural resource issue not addressed is the continued blockage of anadromous fish passage by the Project,” according to the Upper Skagit Tribe’s letter to FERC, signed by Chairwoman Jennifer Washington. “The ongoing blockage of fish passage and lack of flow in the Gorge bypass is a severe harm to the Tribe’s Treaty rights and culture.”

Tribal member Janelle Schuyler has started a petition asking Seattle City Light to remove the dam:

Seattle City Light and FERC told the Skagit Valley Herald that removing the Gorge Dam is not within the scope of relicensing.

Washington’s letter further asked that the utility examine the impacts from a lack of floodplain connectivity, reduced flows, chum channel efficiency and drawdowns from the Gorge and Diablo facilities.

Letters from the Swinomish and Sauk-Suiattle tribes, federal agencies and conservation groups requested additional studies about water quality, fish and wildlife mitigation lands, climate change and cultural resources, among other topics.

“This holistic approach is the only way to uphold and honor the Tribe’s natural and cultural resources interests, Treaty rights and way of life and to comply with applicable law,” stated the Swinomish Tribe in a letter signed by Chairman Steve Edwards. “The Swinomish Tribe’s general concerns stem from the fact that all wild salmon populations spawning in the Skagit River, including ESA-listed Chinook and Steelhead, are not recovering, and key types of habitat for Chinook and Steelhead recovery have suffered and continue to decline as a result of ongoing Project operations. We view the relicensing process as an opportunity to correct these harms before it is too late.”

In urging FERC to require a fish passage study, the Swinomish letter cited National Marine Fisheries Service findings that salmon have been found upstream of the Gorge Dam, so there is potential benefit of providing access to that upstream habitat.

“(T)he reintroduction of anadromous salmonids above dams has become an increasingly common and necessary action for the recovery of ESA-listed salmon and steelhead throughout the Pacific Northwest,” the letter states.

The letter from Sauk-Suiattle Natural Resources Director Jason Joseph additionally requested that FERC consider the effects on wildlife from habitat loss, habitat quality, habitat fragmentation and disruption of migration pathways.

Both the state Department of Fish and Wildlife and Skagit County Commissioners expressed support for the tribes’ requests.

In its own comment letter, the National Marine FIsheries Service said that conditions at the hydroelectric project are not adequate to support survival and recovery of steelhead and salmon, which in turn endangers the southern resident orcas that feed primarily on chinook salmon.

The Gorge Dam blocks fish passage and dewaters the Skagit River. Photo by Jon-Paul Shannahan, Upper Skagit Indian Tribe.