The following is a summary introduction by Doug Verdier of the June 12, 2013 letter to FERC from Crown Hydro: (See below for the link to the letter.)
In the June 12, 2013 letter to FERC from Donald H. Clarke, Counsel to Crown Hydropower, LLC–in response to the April 15, 2013 letter from Edward A. Abrams, Director, Division of Hydropower Administration and Compliance–it appears that Mr. Clarke is ignoring Mr. Abrams’ statement in the very first paragraph of the April 15 letter, which states: “We have reviewed your request and staff believes for the following reasons [enumerated in detail in the remainder of the letter] that an amendment of license is not the appropriate vehicle for Crown Hydro’s current proposal.”
By titling his letter “Schedule of Consultation and Timeline for Filing Application for Amendment [emphasis added] of License,…” Mr. Clarke attempts to gloss over the fact that FERC has already noted that an amendment is not appropriate.
The proposed “schedule” contained in the June 12 letter can only be described as yet another attempt to delay revocation of the license, as FERC has threatened to do on several occasions.
The following is a summary by Doug Verdier of the June 18, 2013 letter from FERC to Crown Hydro: (See below for the link to the letter.)
On June 18, 2013, Edward A. Abrams, Director, Division of Hydropower Administration and Compliance, responded to the June 12, 2013 letter from Donald H. Clarke, Counsel to Crown Hydropower, LLC in a letter to Thomas Griffin, President, Crown Hydro, LLC.
Mr. Abrams stated that the proposed schedule given in Clarke’s June 12 letter was inadequate and does not include the full three-stage consultation steps that are required by federal regulations. He further noted that “…it is not clear that you can accomplish all of these steps in the time you have allocated for completing the pre-filing consultation requirements.” Crown was directed to file a new schedule with the Commission that included all needed pre-filing consultation steps.