Jan Borchert, Current Hydro
Applying for the Small Hydropower Exemption (3 of 4)
With the Initial Consultation Document (ICD) distributed and a successful public meeting behind us, the next phase of our stakeholder engagement is responding to the comments, questions, suggestions and recommendations we received. Some short answers could be given during the meeting, but not all topics could be discussed as deeply as wished on that evening.
Responding to stakeholder comments the FERC way
As part of the exemption pre-application consultation, we are expecting comments and recommendations, mainly from resource agencies like the Department of Environmental Conservation, Fish and Wildlife Service and Dam Safety, to improve the design plan of our project. These comments could include simple suggestions or requests for additional studies.
Either way, stakeholder comments within the FERC process need to fulfil certain requirements as resource agencies need to identify the missing information, and explain how the requested information will be useful to the stakeholder in furthering its resource goals and objectives, that are affected by the proposed project. In short: it is not enough to request information, stakeholders also need to explain the relevance of that missing information.
Stakeholders have 60 days from the day of the public meeting to submit comments in writing. We would ideally like to have these comments create a collaborative way to improve the project proposal. The resulting changes to the project, the results of additional studies and the responses to the received comments will need to be part of the draft application document.
Responding to the community
But we also want to respond to comments, statements and questions that are coming from the community. There are a variety of topics that came up during and subsequent to the public meeting, that we would like to talk and inform about in more detail.
The topics that people were most interested in were related to the Cost/Benefit of the Annandale/NYSERDA project; Flooding and Greenhouse Gas Emissions of the impoundment; Cultural Aspects of the Historic Annandale Dam; American Eels, Sediment and Water Quality and all of that in contrast to a possible dam removal scenario.
To discuss these topics, we have started a Q&A-blog post, summarizing the questions/comments received, answering and discussing the context of these issues and referring to additional resources.
Most of the comments so far, where communicated verbally on the day of the public meeting, but we would like to invite you to contact us if you have additional topics you want to see discussed, related to the Annandale project.
Next Steps after the responding to stakeholder comments
With stakeholder comments addressed, the consultation goes into its next phase: after additional requested studies have been conducted, resource agencies, tribal nations and other organizations involved in the first stage of consultation will receive the exemption draft-application to review the information gathered since the ICD. The review period is 90 days, hoping that all resource agencies and participating stakeholders can agree with the project’s proposed construction, operation and environmental considerations.
The final stage of the consultation process is filing the actual application for an exemption, providing copies of all materials to resource agencies and tribal nations.