Jan Borchert, Current Hydro
Introduction
Dams affect more than just the property they are located on. They can impact the upstream community in one way and the downstream community in another. Often, upstream and downstream communities have conflicting interests and goals when discussing the future of a dam, leaving the dam owner literally in the middle while bearing the infrastructure liabilities. This is why it is important for every hydro project to acknowledge and include the existing concerns and agendas in the design and decision-making process.
The public meeting and site visit on October 30, 2018, was the ninth stakeholder engagement meeting since the Bard-NYSERDA Project kicked-off in 2016. We presented the current plan and project ideas and received dozens of informal questions and comments both during and post-meeting. This is where we want to answer those questions in more detail and invite stakeholders who weren’t able to attend that night to participate in the project. The comments and responses are collated into thematic groups: Flooding, Greenhouse Gas Emissions, Safety, Communication, Cost/Benefit, Federal Jurisdiction, Cultural, Environmental and Miscellaneous.
Flooding
The topic of flooding was brought up during the public meeting, specifically referring to the Flood Mitigation Assessment Study from March 2018 (short Flood Study), funded by the New York State Department of Environmental Conservation (DEC) Hudson River Estuary Program and carried out for the Town of Red Hook. The question is paraphrased as follows: The study’s #1 recommendation is to remove the Annandale Dam; so why do we propose to install microhydro instead of removing the dam, and why were the negative impacts of the Annandale Dam (like flooding) not part of the public meeting presentation?
The #1 recommendation of the Flood Study is the Annandale dam removal, and #2 is replacing and upgrading the NY-9G Bridge. The study says implementing both alternatives together would reduce flood levels in the Kelly Road neighborhood by (only) up to 1.5 feet for the current 50-year flood event, and potentially cost more than $6,000,000 (without a clear source of funding). Removing the dam without upgrading the bridge would possibly reduce the project cost to around $1 million, but would also reduce the overall flood reduction benefit.
The Flood Study acknowledges alternatives to dam removal, like widening the spillway (cutting of the top of the dam, called the dam crest) or preemptively draining the Annandale impoundment – both could be combined with microhydro installation. The study fails to quantify the overall flood reduction benefits achievable by these alternatives. Despite our requests (verbally and in writing) during the Flood Study’s stakeholder engagement process to estimate, based on their flood model, the benefits of these and other alternatives to dam removal at Annandale, these alternatives were not further addressed in the study. The authors of the study were aware at the time of the ongoing Bard-NYSERDA project and the local interest in microhydropower, but opted to focus on alternatives that exclude hydropower installation, leaving us with an incomplete assessment of options and alternatives.
So, yes, the Flood Study’s #1 recommendation is to remove the Annandale dam, but it is #1 of a limited pool of alternatives whose selection criteria are unclear; although estimated costs were included, neither a cost-benefit analysis nor realization likelihood has been published and has presumably not been part of the ranking.
On our end, a possible removal of the Annandale dam was considered since the beginning of the project. Our objective was always to figure out what is best for the stakeholders, the environment and the Saw Kill. Considering the many environmental, financial and social aspects as well as the dam removal feasibility study (The Chazen Companies, 2016), the Flood Study (mentioned above) and prior stakeholder meetings, we focused on installing microhydro as the preferred option. For more detail, please see Section 3.5 of the Initial Consultation Document.
Greenhouse Gas Impacts
A statement during the Public Meeting was that dam impoundments emit greenhouse gases and hydropower should thus not be considered a clean renewable energy source.
Besides increasing climate resilience by providing base load renewable energy generation, the ultimate goal of the microhydro project is to fight climate change by substituting large centralized fossil fueled power generation and its transmission losses by local, decentralized renewable hydropower and thus decreasing the state’s overall greenhouse gas (GHG) emissions. A goal that is aligned with New York’s Green New Deal, which statutorily mandates New York’s power be 100 percent carbon-free by 2040.
And then there are GHG emissions from dam impoundments.“Following flooding of landscapes to create any kind of reservoir, terrestrial plants die and no longer assimilate carbon dioxide (CO2) by photosynthesis, resulting in the loss of a sink for atmospheric CO2. In addition, bacteria decompose the organic carbon that was stored in plants and soils, converting it to CO2 and methane (CH4), which are then released to the atmosphere.” (St. Louis, Kelly, Duchemin, Rudd & Rosenberg, 2000). How much GHG are emitted by an impoundment depend on factors like the age of the impoundment (“[…] because newly flooded labile carbon, such as that found in leaves and litter, should decompose rapidly, followed by slow decomposition of older, more recalcitrant organic carbon such as soil carbon and peat”, St. Louis et. al., 2000), water temperature and climate, water velocity, sediment transport, shape and size of the impoundment, and primarily the organic carbon that is flooded to create the reservoir. A primarily rocky area in the northern US, flooded over a century ago is believed to emit fewer GHG than newly flooded peatlands in South America. But there are also publications questioning that belief.
Dam removal to eliminate the impoundment’s emissions is an argument that can be used on all of the 6,600+ dams in NYS; but with limited funding for dam removal, dams with the highest GHG emissions should be removed first – especially if there aren’t any concrete plans yet on how to otherwise offset the impoundment’s emissions. To tackle this issue efficiently, we need to evaluate and rank the existing impoundments from highest emissions to lowest emissions and find solutions on how to offset or eliminate the GHG emissions.
With regard to the Annandale Dam, as for most already existing dams, information on the type and amount of carbon flooded centuries ago and how beaver dams impacted the historic GHG emissions before the dam was built is unknown. We know the stream is naturally rather rocky, the impoundment is old and the impoundment hosts a lush marsh that still acts as a carbon sink (absorbs carbon from the atmosphere). Whatever net-amount of GHG the Annandale impoundment emits, is being emitted whether microhydro is installed or not – as dam and impoundment are already in existence. The Bard-NYSERDA project offers a concrete plan and funding to use micro hydropower to offset the impoundment’s emissions and furthermore offset fossil fuel power generation to fight climate change.
Safety
One complaint about the public meeting was that downsides of dams, particularly concerns with safety, were not presented. Looking at dam safety concerns, every dam is at risk of failure. Hazard classifications of dams (A = low, C = high) don’t evaluate the probability of dam failure but the impact a potential failure might have on downstream properties, structures and lives. The latest engineering assessment of the Annandale Dam recommended that the dam be classified as a low-hazard dam. On a state-wide scale, the focus of dam removal efforts should lay on high-hazard dams first to address dam safety concerns.
Adding microhydro will not increase the risk of dam failure. In fact, the alterations necessary to add hydropower to the dam include structural improvements and will upgrade the overall condition of the dam – an added benefit of microhydro installation.
Communication
After the meeting we received feedback wishing for a more balanced presentation with regard to microhydro vs. dam removal.
A possible removal of the Annandale dam was considered since the beginning of the project. Our objective was always to figure out what is best for the stakeholders, the environment and the Saw Kill. Considering environmental, financial and social aspects as well as a dam removal feasibility study (The Chazen Companies, 2016), the Flood Study (mentioned above) and prior stakeholder meetings, we focused on installing microhydro as the preferred option. For more detail, please see Section 3.5 of the Initial Consultation Document.
The reason dam removal was not part of the presentation is that the focus of the Public Meeting was intended to inform stakeholders about the planned microhydro project, the federal permitting process and the expected environmental impacts from its installation and operation, as well as to receive comments about the project proposal to further refine the design plans.
FERC Jurisdiction / Federally Regulated Project
We’ve heard a lot of comments about the federal jurisdiction process and background since and during the Public Meeting. Why is a project this small federally regulated? Who has jurisdiction? How can I comment/participate? Is every microhydro project under federal jurisdiction?
These and other questions are answered in the permitting section of this website; for a summary of the process, please refer to our permitting blog (Saw Kill Project: Permitting – Step 2). Answering the questions above and documenting the exact steps necessary to install microhydro on an existing non-powered dam are two of the outcomes of the NYSERDA funded Bard project: through website and engagement process, the project will help educate the myriad stakeholders who are unaware they have the ability to be part of a sustainable process for energy generation. The stakeholder process includes the local community and watershed groups, environmental non-governmental organizations (NGOs) as well as local, state and federal resource agencies. We’re happy to hear from you!
Cultural
The questions relating to cultural and historic aspects of the Annandale dam and hamlet focused on the alteration of its character, its mill history and the planned fate of the historic pump, currently located in old pumphouse. One member of the audience voiced the wish for a visual simulation of the project in the Annandale setting.
If you are interested in the mill history of the dam, please refer to Section 4.14 of the Initial Consultation Document, where we summarized the available information, starting in the mid 18th century. The current project plan intends to fuse the microhydro facility into the dam aesthetics. We can imagine information signs at the project site, displaying images and stories of the history of the Annandale Dam and its historic uses to increase awareness of the rich history of the Annandale hamlet. The Red Hook Historian will assist with this process.
The old irrigation pump is currently still located inside the concrete pump house, which is part of the overall structure of the dam. Either while it was in use or since then, the pump has not drawn any specific public or historical interest. It is currently in a rusted and inoperative condition. We would not be opposed to the pump being refurbished and displayed at a publicly accessible site, but it seems to be a low priority for funding, since public interest is limited.
The Draft Application (the next iteration of the Initial Consultation Document) includes the following site rendering to visualize the planned installation.
Environmental
This section about the environmental aspects of the project should be seen in the context of the detailed description and discussion of impacts in Chapter 4 of the Initial Consultation Document.
We’ve received comments stating that they think the environmental studies for the Annandale project are overdone and that studies of this extent prohibit others from considering microhydro on their own site. We understand how the efforts we have conducted so far can be seen that way, but the Bard-NYSERDA project is in a unique position with Bard as dam owner, community member, research and educational facility and public entity. Moreover, this work is funded by the NYSERDA Energy to Lead Competition, which is part of the Reforming Energy Vision Campus Challenge, supporting not only the implementation of clean energy project but also their use as a teaching tool and example for other projects. Smaller projects can certainly proceed with fewer studies, but the environmental and technical assessment of the Bard-owned stretch of the Saw Kill includes multiple waterfalls, two dams, a drinking water intake and a wastewater outflow which increased the research-area well beyond the Annandale Microhydro Project’s immediate project boundary. At the same time, the project aims to provide additional data on the state of the Saw Kill. The new Bard College Center for the Study of Land, Air & Water is committed to long-term monitoring of Saw Kill water quality. This project contributes to that goal and builds on the dataset currently being generated by the Saw Kill Watershed Community citizen science monitoring program and the Bard Water Lab (since 2016) as well as data from 1976-1982 (collected by the former Saw Kill Water Quality Surveillance Program). In addition, the Hudson River National Estuarine Research Reserve has maintained a water quality monitoring site in the Saw Kill that has been in continuous operation since 1995. The availability of this data and Bard’s ongoing research and educational efforts related to the Saw Kill are an invaluable resource for the Annandale project. By conducting more detailed studies than what is possible by other dam owners, this project will provide actionable information to facilitate the decision making process of others.
We’ve received questions about the project’s impacts on Bard’s drinking water, sediment quality, the presence of heavy metals and the planned dredging above the dam. These topics are discussed in detail in the Initial Consultation Document, page 66 – 69.
What is not discussed in such detail is planned tree removal efforts as part of the installation. We would like to distinguish these efforts between tree removal that is necessary to ensure the safety of the dam – as part of overdue dam maintenance and as requested by the DEC – and tree removal to allow the installation of the hydrofacility. As the local stakeholders might have seen when driving by the Annandale site, the trees that were too close and a danger to the dam have already been removed. The additional tree removal is almost exclusively limited to trees of a few inches in diameter and shrubs, as the microhydro facility has a very small footprint. Erosion concerns are being minimalized by stabilizing the downstream channel between the hydrosystem and the main stream of the Saw Kill and by the use of silt fencing during construction.
We have received a few technical questions with environmental implications regarding the threat to eels, the fish passage plans and the impact of the hydroturbine on water temperature. The last question can be answered quickly: we are proposing a low-pressure, low-speed turbine and there is no measurable temperature increase induced by the proposed turbine to be expected. Diverting water on the other hand, might have an impact on stream temperature. To evaluate these and other potential impacts on water quality, we will be deploying monitoring equipment to continuously measure temperature (as well as other parameters) around the Annandale Dam, including the tail race discharge into the Saw Kill. The other two questions need a little bit more detail. Section 4.7 of the Initial Consultation Document discusses Fish, Benthos, and Aquatic Plants possibly affected by the project.
The US Fish and Wildlife Service formally commented on our proposal noting that “[…] current fishway engineering criteria for American eel (Anguilla rostrata) include the use of 0.75″-clear-spaced trashracks rather than the 1″ clear spacing identified in the PAD. Studies have demonstrated that some adult eels are persistent enough that they eventually force themselves through the 1″ openings rather than using a passage facility. The 0.75″ spacing excludes adult eels from the turbines.” Based on that we will update the design and reduce the screen spacing to 0.75’’ to ensure that downstream migrating, adult eels cannot get into the hydrosystem.
At the same time we want to help upstream migrating eel to pass the Annandale dam. The proposed eel ladder combines current design standards with proven technology. Eels will be able to pass the dam and then continue their journey upstream. One stakeholder asked about the risk of upstream migrating eel mistakenly swimming into the hydrosystem once they’re above the dam; we went on to ask the US Fish and Wildlife Service that exact same question to confirm our assumption: eels are naturally swimming upstream, against the flow and not with the flow. Remember, eels that made it this far already surpassed two significant waterfalls and two dams; the relatively slow moving water in the impoundment will not keep them from migrating further upstream, and USFWS deems there is little risk that eels exiting the ladder at the top of the dam might accidentally end up in the hydrosystem.
Related to eels in hydrosystems: There are stories about the old Montgomery Place hydropower system, located near the mouth of the Saw Kill (on Bard property) and visible from the Saw Kill Trail, that had problems with eel entering the facility from downstream and clogging up the system. Upstream migrating eel entering the Saw Kill at that time probably tried to climb up the 35-feet high, steep waterfall first, before turning around and trying the hydropower outlet instead. The Annandale system is different in two ways: it will have a working eel ladder (easy upstream passage) and the outlet of the hydrosystem will have an air gap to prevent eel from entering the system from the downstream side.
To elaborate further on the written comments from the US Fish and Wildlife Service (from December 12, 2018), they also included technical assistance pursuant to the Endangered Species Act of 1973. For your reference, endangered species are discussed in Section 4.11 of the Initial Consultation Document. The Service directed us to its website for project review with their Information for Planning and Consultation Tool (IPaC) naming the species potentially affected by activities at the Annandale site to be Indiana Bat, Northern Long-eared Bat and the Dwarf Wedgemussel – as already discussed in the ICD. The USFWS added to the ICD with regard to the bald eagle, which “was removed from the Federal Endangered Species List on August 8, 2007, and is no longer protected under Section 7 of the ESA; however, bald eagles remain on the New York state list as a state-listed threatened species. Bald eagles are also protected under the Migratory Bird Treaty Acts […] and the Bald and Golden Eagle Protection Act. If bald eagles are present in the Project area, the Service recommends that you follow the Bald Eagle Management Guidelines found on the Service’s website prior to commencement of work.” Which we will do to protect these majestic creatures.
The final question of this section is: Is this project good for the Saw Kill? The answer to that question depends on the definition of “this project”, the definition of “good” and the definition of “the Saw Kill”. If “the Saw Kill” includes the adjacent communities and its inhabitants the answer might be very different from a more literal definition that only includes stream life. Is the Saw Kill the current state of the Saw Kill, including dams, culverts, waste treatment plants, etc.,? Or a theoretical construct of a re-naturalized, historically possible condition? If “this project” is defined as the search for the best (feasible) solution to an existing dam, or defined as the investigation of how to use the existing fleet of dams in NYS to fight climate change, or defined as simply upgrading the Annandale Dam with a micro hydro-electric generation facility, then again the answers might look very different from each other.
The way we see it, we are looking at 6,600+ dams in NYS, over 80,000 dams in the US. Many of these dams were built for flood control, navigation, potable, irrigation, fire, recreation or other purposes; taking them all out might be “good” for the respective streams, but totally neglects societal aspects. It also devalues the existing ecosystems created by a “dam [that] has been in place for over a hundred years allowing habitats to evolve both behind the dam and downstream” (received comment after the Public Meeting, referring to the Annandale Dam). This is why we need a comprehensive national water assessment and formal analysis of the role dams play in our water future (as advocated by Ho et. al.), why we need a concrete dam-removal roadmap – ranking dams by removal priority considering environmental, technical and societal aspects – and why we need more projects to evaluate the potential of upgrading historic dams to provide decentralized base-load renewable energy generation for our communities in combination with fish migration facilities. Even though the Annandale Dam does not serve a primary purpose anymore, it is a good candidate for hydropower installation as it is a low-priority for dam removal compared to other dams in the Hudson River Watershed.
Cost / Benefit
During and after the Public Meeting, stakeholders asked about the cost and benefit of the Annandale and Bard-NYSERDA project. The cost here are either the cost for installing the microhydro facility at the Annandale dam, or be related to the $1 millon NYSERDA grant, which is ultimately paid for with tax money and splits this topic really into two different questions.
The goal of the NYSERDA project is to advance clean energy in New York State by increasing the use of micro hydropower as a distributed renewable energy resource. The project will demonstrate the viability of micro hydropower as a realistic and attractive alternative at some of the 6,600+ non-powered dams located across NYS. The on-campus natural resources will be used to create a standardized process for evaluating potential micro hydropower sites and streamline the process for working with the watershed community and to educate the myriad stakeholders who are unaware they have the ability to be part of a sustainable process for energy generation. As part of the project, the microhydrony.org-website was founded to provide information about environmental considerations, legal aspects and permitting, as well as technical requirements. The “Project is an opportunity to correct lack of resources for dam owners” (comment during the Public Meeting). To create a full image of all dam and microhydro related topics, a variety of stakeholders have been asked to contribute to the content on the website. The goal is also provide insight into dam removal efforts, cost and regulation as well as and to provide a blog to document the Annandale Microhydro Project step by step, throughout the whole process. We believe this cause is worth the investment and so does the New York State Energy Research and Development Authority, NYSERDA. We all hope this project can help inform the discussion about dams, dam-removal and climate change to the benefit of all New Yorkers and not just Bard’s local community.
Talking about the cost affiliated with installing the Annandale Microhydro Project, one objective of the Bard-NYSERDA project is to document and publish all actual cost and to create cost transparency. These costs will include assessment, permitting, dam safety, design, engineering, grid connection, project management, construction and environmental mitigation. As there is no streamlined microhydro process out there, the cost for this demonstration project are expected to be higher than future installations. And while the energy output of the Annandale facility might financially not justify its installation cost, the expected benefit to other communities and other microhydro projects throughout the state definitely does.
Bard itself also benefits: “Innovation is at the core of Bard’s mission,” Bard President Leon Bottstein said in a statement to the Poughkeepsie Journal, “and this award helps us to continue to innovate in environmental issues and energy conservation, and to signal the importance of these issues to the entire higher education community.” Additional water quality monitoring equipment is being installed as part of the project; thorough assessments of the Saw Kill uncovered many aspects of the streams ecology and history as part of the Annandale Hamlet. An ongoing process.
Miscellaneous
The comments we grouped in this section are all statements and opinions rather than questions. We would like to share them as part of the engagement process, intended to help other dam owners with their public meetings.
We’ve received feedback that the public meeting was not inclusive enough. The commenter suggests breakout discussion groups to give more space for individual comments and discussions.
We’ve also received requests for a more (dam removal-) inclusive messaging on this website, which we appreciate and support.
“Dams are expensive – restoring/maintaining/micro hydro and removing“. All dams are unique in how they impact ecosystems and fish” [and the local community].
“Remove barriers first and foremost, fish passage secondarily in places where there is an existing use of a dam.”
“Dams that have an existing use may be candidates for micro hydropower”. As mentioned earlier in this post, we would like to see the dam-removal efforts to go even one step further by assessing dams on a statewide level, ranking and prioritizing them to make sure the limited dam removal funding is spent on the right dams and that we get those dams out as fast as possible. A comprehensive dam-removal plan and timeline can dictate which dams are high-priority targets for removal (from an environmental and societal perspective) and which dams can be utilized (at least for a few decades) to generate hydropower and to fight climate change (from an environmental and technical perspective).
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