Nushagak Cooperative is in the process of securing a federal license to operate a hydroelectric project at Nuyakuk River falls.
Securing this license would allow the project to operate and enable the Cooperative to construct:
Infrastructure in and around Nuyakuk Falls including multiple buildings;
An access road to connect the project facilities;
A new transmission line corridor between the project site running southeast to Ekwok,
then extending to Aleknagik and Levelock; and
An airstrip.
KEY CONCERNS
UTBB hired technical experts in the fields of:
Cultural resources and archaeology,
Fisheries, and
Hydroelectric licensing
These experts have reviewed Cooperative’s application to help ensure we fully understand the potential impacts of the proposed project as stated in the draft application. Just a few key concerns are outlined here. More detail and a full list of concerns will be posted soon.
Climate & river flows: The application ignores warming temperatures and variable river flows. Power estimates rely on recent average flows, with no consideration of year-to-year changes into the future.
Enforceable protections: Salmon protection is left to good-faith promises, with no binding commitments. Fixing problems after a license is issued is very difficult, so protections must be settled up front.
Tribal consultation: Commitments to consult with Tribes and elders are vague. Indigenous knowledge is not meaningfully included. No effort was made to document Traditional Cultural Places, including the falls.
Fish Survival: The turbines referenced as safe for fish in the application are not the type that would be used in the project. Smaller, faster turbines would likely be used, which are more dangerous to fish. The Cooperative has not committed to a certain turbine type, although fish survival varies widely by design. About half the young salmon migrating within the river could interact with the project.
Cost: Estimated costs are at least $500 Million, though economics aren’t clear. Fish screens, which are recommended to reduce risk to fish, could make the project uneconomical.
Cultural & historic impacts: Historic places are supposed to inform the design and selection of the transmission line route options, but the Co-op plans to finalize the route before working to identify these places.
Where we are in the “1-2-3” federal licensing process
There is currently an (1) open comment period on the Cooperative’s draft license application, which is the opportunity to express concerns such as those listed above and more. The comment period closes Nov. 16.
After the comment period, the Cooperative will review and respond to the comments in order to create its (2) final license application. The back and forth allows regulators to complete an environmental review that leads to them (3) issuing a license, along with any “conditions” the Cooperative must meet in order to proceed.
Lacking Meaningful Tribal Engagement
While the Cooperative may refer to several public meetings in its materials, most of these meetings occured years ago and were related to supporting the studies for project feasibility. Only a handful of meetings happened outside of Dillingham and do not equate to meaningful engagement of impacted communities, adequate Tribal consultation, and did not share enough information about the actual proposal.
Local Tribes are Opposed
New Koliganek Village Council, New Stuyahok Village Council, Ekwok Village Council, and Koliganek Natives Limited passed formal resolutions opposing the project, and all three communities have formally opted out of the project altogether.
How to Share Your Concerns
Encourage your Tribe, City, or Village Corporation to submit an official comment stating how this project would impact subsistence or other cultural activities. Have them contact dlarson@utbb.org for assistance submitting their comment.
Submit a comment yourself. We encourage you to add to your comment to share what concerns you most about the project. You may edit the pre-filled letter on this page.
All comments are due by November 16.
