The following commentary by Doug Verdier is an astute observation of Crown Hydro’s latest submission to FERC.
A COMMENTARY ON CROWN HYDRO’S LATEST FERC FILING
This is a serious effort on Crown’s part. The filing is in response to the Nov. 4, 2014 letter from FERC directing them to “file a complete amendment application for Commission approval with all needed information as described in previous correspondence by April 30, 2015, as proposed by your most recent September 30, 2014 progress report.”
I sense that the 470 page document is intended to overwhelm anyone at FERC who is reviewing it with masses of data, charts and other information, some useful, some not. What continues to bother me, however, is their statement that “Crown Hydro proposes to retain most of the project components as licensed” and goes on to list the same intake channel, the same intake design,the same overall powerhouse design, the turbines and generators previously purchased, the same draft tubes, and the tailrace tunnel is routed to the essential same outlet location on the river. “While retaining most of the as-licensed project design, the project site is moving north approximately 250 feet….”
Anyone who has followed this project from the beginning when it was originally licensed to be in the basement of the Crown Roller Mill Building would see that the proposed relocation in no way resembles the original project as-licensed. It clearly is a new project and, as FERC has pointed out repeatedly, it should be submitted as a new project. An amendment of the existing license is not appropriate.