A Note From Andy:
For 58 years, Tikchik Narrows Lodge has been built on one thing: a river system that works exactly as nature designed it. Many of you have fished the water around Nuyakuk Falls with us, and you know what it holds.
We understand that Bristol Bay communities face some of the highest power costs in the country, and we support efforts to find reliable alternatives to diesel. At the same time, we believe this project, at this site and on its current timeline, warrants careful consideration. The co-op’s studies have identified potential risks to sockeye, while several key studies and analyses remain incomplete. Communities closest to the falls have also formally expressed opposition to the project. We encourage our guests, friends, and others who care about this region to review the available information, consider the potential impacts, and, if they choose, submit an informed comment to the public record.
The Salmon
The Nuyakuk feeds the Nushagak, one of the most productive sockeye salmon systems in Bristol Bay. The co-op’s own studies identified potential reductions of up to 35% in Nuyakuk River sockeye, depending on the amount of water diverted. UTBB’s review provides additional details on these findings.
According to the Draft License Assessment (DLA), 42–55% of salmon smolt will be pulled into the turbines. The DLA also states that the proposed final design will include a Kaplan-style turbine with a minimum-gap runner, which has reportedly demonstrated 95% survivability in both turbine survival and delayed-mortality assessments, citing Martinez et al. (2019). However, Daniel Schindler of the University of Washington notes that the 2019 study conducted at Ice Harbor Dam on the Columbia River did not study mortality rates; it studied injury rates. The study also involved much larger turbines that are not representative of the smaller Kaplan-style turbines proposed for this project. The Columbia River turbines can achieve very low mortality rates, but the turbines proposed for this project are approximately five times smaller and have a smaller diameter. A recent study in Spain found mortality rates closer to 62–87% for turbines of this size.These differences raise significant questions about the applicability of the research cited in the DLA. They also highlight potential gaps in the assessment and raise concerns about what the true long-term impact of the project could be on the salmon run.
Native Communities
The villages closest to the falls have spoken. New Koliganek Village Council, New Stuyahok Village Council, Ekwok Village Council, and Koliganek Natives Limited have passed formal resolutions against the project. When the people who live nearest a river and depend on it for food say no, that should carry weight.
The Park
Certain sections of Wood-Tikchik are considered wilderness, and its existing management plan did not contemplate a project of this scale or type. Before the necessary studies could begin, the co-op had to seek legislative changes to the park’s management plan. A diversion, powerhouse, and transmission corridor would permanently alter a landscape that was intentionally set aside to remain largely undeveloped.
Where Things Stand
The co-op has filed its Draft License Application with the Federal Energy Regulatory Commission (FERC). Under FERC's process, a draft application is opened to the public for comment before the final application is filed. This is the public's chance to put concerns into the official record FERC will weigh when it decides whether to license the project. Comments are due 11/16/2026.
How To Comment
Anyone can comment. You do not need to live in Alaska or register with FERC. Step one. Go to FERC Online [SEE BELOW] and choose eComment. Brief comments up to 10,000 characters need no prior registration, just your name, email, and mailing address. Step two. Search for docket number P-14873, the Nuyakuk River Hydroelectric Project. Step three. Write your comment in your own words. Step four. Submit before 11/16/2026.
POINTS TO RAISE (In Your Comment)
- -The co-op's own studies show potential sockeye losses of up to 35%, with no plan to prevent them.
- -FERC found the subsistence and cultural resources studies incomplete, and Tribal consultation under Section 106 has not been completed.
- -The cost, output, and savings figures have changed repeatedly and need independent review.
- -The closest communities have formally opposed the project, and so do we.
- -The co-op has no deadline. FERC should require the missing work before this moves forward.
UNIVERSITY OF WASHINGTON & UTBB: MISSING GAPS
SOURCES TO REFERENCE
Considerations
- The question is not whether renewable energy is needed. The question is whether the available science and economic analysis are sufficient to understand the project's full costs, benefits, risks, and alternatives. Before a project of this scale moves forward, communities should have access to clear, site-specific information about salmon survival, annual and seasonal power production, construction costs, long-term operating costs, subsistence and cultural resources, and realistic alternatives. We need more science. Stronger evidence. Clear answers.
- Subsistence and cultural resources: The DLA should provide a complete and transparent assessment of potential effects on subsistence, cultural resources, and the communities and Tribes that rely on the Nuyakuk and surrounding landscape. Where information remains incomplete or where Tribal concerns differ from the project sponsor’s conclusions, those differences should be clearly documented rather than treated as resolved.
- Construction & Logistics: Building a major hydroelectric and transmission project in this remote location raises serious questions about feasibility and cost. Even if these issues fall outside FERC’s direct review, they cannot be sidelined in discussions with local communities. Beyond salmon, science, and cultural impacts, the co-op must clearly demonstrate that the project can be built, what it will cost, and whether it is financially viable for the communities and individuals expected to pay for it. Questions surrounding transportation by boat, seasonal access, equipment mobilization, material delivery, and overall construction logistics should be supported by documented engineering analyses and reliable cost estimates before permits are issued and before local communities are asked to commit or spend substantial co-op funds. We know from personal experience how difficult it is to access the falls and portage equipment in this area. The DLA has also indicated that a runway at the site is not feasible. Yet we have not received a clear answer from the Co-op on what seems like one of the most basic questions any major infrastructure project should be able to answer: How will the dam actually be built, and what will it cost to get the necessary people, equipment, and materials to the site? Those questions should be answered with documented engineering and cost estimates before communities are asked to continue investing in the project. These are not conclusions we should make without evidence; they are questions that deserve clear answers because they could materially affect the project's total cost and feasibility.
- Power generation and climate: The project’s ability to provide reliable power throughout the year depends on river flows, project operations, and the amount of energy actually available during periods of lower flow. Nushagak Electric should provide clear, independent analysis of expected generation by season and how that generation compares with the communities’ current and projected electricity needs. It is also important to understand how seasonal restrictions or changes in project operations intended to protect salmon migration would affect the project’s long-term power output. If May through July are periods when communities have a significant need for hydroelectric generation, but also coincide with critical salmon migration periods when the facility may need to operate differently or at reduced capacity, those competing demands need to be clearly evaluated. What would that mean for the amount and reliability of power the project can actually provide, and what are the long-term costs and tradeoffs for the communities?
- Salmon and turbine passage: The available studies do not yet establish a project-specific survival rate for juvenile salmon passing through the proposed turbines. The Cooperative has acknowledged that turbine selection and project design remain subject to further development and that additional analysis may be needed to establish a project-specific survival estimate. We believe the licensing record should provide clear, site-specific science on direct mortality, injury, and potential delayed mortality before the project's impacts on salmon can be fully understood.
- Alternatives: The DLA should clearly explain how the proposed project compares with other ways of reducing diesel dependence, including combinations of solar, battery storage, energy efficiency, existing generation, and other renewable resources. Solar alone may not provide equivalent year-round reliability in the region, so the relevant question is not simply whether solar can replace hydro one-for-one. The relevant question is whether a diversified energy portfolio could meet the communities' reliability and energy needs at a different cost or with different environmental impacts.