Coley,

If it's not too late, your citizen group - called an NGO (non-gov. org.) needs to petition to intervene in the permit proceeding. I think the project is in the "preliminary permit" stage, where the applicant does studies and prepares a draft license application. This is important, because FERC will issue a notice of receipt of application for license, and another opportunity to intervene opens. You cannot miss that, or any of your work will not even be looked at by FERC, let alone given any consideration.

Next, you say there are anadromous fish above the dam site. I previously read that it was upstream of anad. fish usage, at least of any significance. Again, vital, if significant salmon usage occurs upstream of the dam site, NMFS and USFWS can prescribe MANDATORY fish passage facilities for the project, and have heavy influence on downstream instream flow levels in any license issued. These can be vital because many hydro projects are economically marginal under the best of circumstances, and economically infeasible if instream flows are not favorable to the project and if upstream and downstream fishways are too expensive. Rest assured that NMFS criteria fish screens on a river like the big Su with heavy glacial silt will likely kill the project. Think like putting NMFS criteria screens on Grand Coulee. Next stop, contact NMFS and USFWS regional AK offices and ask their current position on the project regarding fish and wildlife conservation measures.

Properly mitigated, the project likely isn't economically feasible. So why worry? Politics, my friend. Is AK going to lean on its Senators and Rep. to lean on NMFS and USFWS to minimize the mitigation? Your group needs to be planning ahead to sue the fed agencies (FERC, NMFS, and USFWS) if they are politcally pressured to back off on mitigation. The law and justice can win in situations like this, but only if the good guys work harder and smarter than the politicos.

Good luck!

Sg