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National Hydropower Reform Coalition Requests Study Process Improvements from FERC


by Chris Shutes, FERC Projects Director
February 4, 2010 -- The national Hydropower Reform Coalition has asked the Federal Energy Regulatory Commission to change important parts of the way it does business in relicensing hydroelectric projects.
In a letter addressed to Ann Miles, Director of the Division of Hydropower Relicensing at FERC, Coalition members including CSPA request that FERC set policies to improve the Integrated Licensing Process that was adopted by FERC in 2003. The letter asks for standardization and transparency in documents that announce decisions about studies, a broader and clearer interpretation of what studies are allowed in relicensing, a protocol for sequencing studies where appropriate, and greater cooperation between FERC and other agencies.
No specific relicensing processes are referred to in the letter, since many of the best examples of problems are occurring in ongoing proceedings. However, several processes in California heavily informed the letter.
Over the last three years, CSPA and its relicensing allies have been working to change FERC’s narrow interpretation of the criteria by which studies are considered. This interpretation has been encouraged and reinforced by a number of project operators and their consultants. The most egregious consequence in California is that project effects on salmon and steelhead downstream of dams are sometimes not quantified, and opportunities for fish passage are not considered. Evidence that is not collected cannot be used to support proposals to make conditions better for fish and other resources.  
Using process to ignore the effects of hydroelectric projects on fish, and especially on anadromous fish, is unacceptable. CSPA and Coalition members nationwide will continue to press for a fair and responsible application of study criteria by FERC, both within individual relicensings and on a policy level.
In addition to trying to change the way FERC does business, CSPA is involved in over a dozen FERC proceedings in California.


HRC Letter to FERC