Jan Borchert, Current Hydro
Applying for the Small Hydropower Exemption (4 of 4)
Preparing the exemption application
The main difference – content wise – between the ICD and the exemption application, is that the latter contains deficiency corrections, revisions, supplements, responses to additional information requests, and amendments as well as any written correspondence from FERC asking the applicant to correct a deficiency or provide additional information.
In our case content changes were mainly related to technical design optimizations: we proposed to install a 30-feet long auxiliary spillway to address and reduce upstream flooding and we changed the layout of the hydropower intake structure, to reduce the amount of in-water dredging within the Annandale impoundment. Based on conversations with the US Fish and Wildlife Service, we decided to further investigate the optimal location for our eel ladder before committing to a specific design. The suggestion was that the stream dynamics will change with the micro hydro project and how to attract eels will vary on based these new hydraulics. These changes were presented and shared in the Draft Application document, that we sent out to stakeholders at the end of April 2019.
The layout of the draft application is identical to the ICD, changes between the two documents are clearly marked to make review easier for project stakeholders. The draft application contains all information the final exemption application will contain; similarly to the ICD, FERC provides a (12-page) template for the 10-MW exemption application. All applications for a hydroelectric project require maps and drawings; FERC specifies the requirements for drawings and maps and even provides a guidelines document.
With an exemption application FERC requires the exhibits A, E, F and G: Project description, environmental report, project drawings and project maps. Versions of these exhibits had already been included in the ICD but now contain engineering stamps and updated information.
Next Steps after finalizing the exemption application
At this stage, we’re waiting for stakeholder comments on the draft-application before submitting the exemption application to FERC and all resource agencies and tribal nations involved in the process. FERC requires us to certify that this has been done and that copies of the final application have been mailed to these agencies and stakeholders.
We will also need to provide public notice of the filing of the application on the filing date of the application in a daily or weekly newspaper in Dutchess County. The paper we will use is the Poughkeepsie Journal.