On February 26, 2014 Doug Verdier submitted a letter to FERC requesting that FERC immediately terminate the existing Crown Hydro License. The complete text is below.
Co-founder of Park Watch
Douglas L. Verdier
401 S. 1st St., #222
Minneapolis, MN 55401
February 26, 2014
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, D.C. 20426
SUBJECT: Crown Mill Hydroelectric Project,
Project No. P-11175-024-Minnesota
RE: Letter, Feb. 25, 2014, from Law Offices Duncan, Weinberg, Genzer & Pembroke, P.C. to FERC in regards to Schedule for Development of License Amendment for the above subject project.
Dear Secretary Bose:
In reviewing the responses to agency and public concerns outlined in the referenced letter, I note the omission of any mention of the concerns presented in a March 15, 2012 letter from the Department of the Army, St. Paul District, Corps of Engineers to Mr. Richard M. Greenlee, Engineering Partners, Int’l, LLC, representing Crown Hydro. This letter was a follow-up to a March 1, 2012 meeting between Corps and Crown representatives. I can find no evidence that Crown has ever responded to the concerns raised by the Corps about the project’s proposed relocation.
In addition, a letter dated April 15, 2013 from Mr. Edward A. Abrams, Director, Division of Hydropower Administration and Compliance, to Mr. Thomas H. Griffin, President, Crown Hydro, LLC, with copy to Mr. Donald H. Clarke, Counsel to Crown Hydro, LLC, has likewise been ignored. Mr. Abrams in his letter states very clearly “an amendment of license is not the appropriate vehicle for Crown Hydro’s current proposal.” He goes on to say: “The differences between the licensed project and Crown Hydro’s current proposal are great enough to conclude that it is essentially a different project than the one analyzed in the 1990s and would require a new technical, engineering, and environmental analysis.”
It appears that Crown is deliberately continuing a pattern of repeatedly ignoring responding to concerns raised by the Corps of Engineers and a number of concerned individuals and organizations, as well as FERC’s notification that pursuit of an amendment for what is essentially a new project is not appropriate.
I urge FERC to immediately terminate the existing Crown Hydro license. The new Crown Hydro proposal constitutes an entirely new project at a new location, and should require a new license.
Douglas L. Verdier