Tell FERC you support the Seneca Project

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March 21, 2011

Tell FERC you support the Seneca Project. Submit comment letter below.

The Federal Energy Regulatory Commission (FERC) is accepting comments regarding the relicensing of the Kinzua Dam hydroelectric facilities. The competitive bids for the license include,

1) Project No. 13889-000 Pennsylvania Seneca Pumped Storage Project by The Seneca Nation of Indians;

and 2) Project No. 2280-013 Pennsylvania  Kinzua Pumped Storage Project by FirstEnergy Generation Corporation.

The Seneca Project addresses the ecosystem upstream from the Kinzua Dam (which includes the Allegheny River and Reservoir in the Allegheny National Forest), and proposes twenty-two important studies that must be conducted during the relicensing process.

See also: FERC Scoping Document; More information on the Seneca Project; For The Seneca Project Pre-Application Document (PAD), sections  4 and 5 have the most relevant data for Scoping Comments. More Seneca Project documents.You can also attempt to use the FERC site to find documents (Good Luck!). First Energy PAD. See also comment letters submitted by ADP and other groups at February 23rd Scoping hearings, and transcripts from the February 23rd and 24th scoping hearings.

Send in the letter below: Copy and paste the letter below into the "eComment" system on the FERC website at this link. The system will make you register with your name and email, and make you verify your email before you can submit the letter. Make sure you include both project numbers in the "docket" area (use "quick entry" tab) above the text box. The project numbers are: P-13889-000, and P-2280-013.

Please feel free to review the documents above and add to the letter below to make it more personal to your concerns.

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Re:    Comments for Pre-Application Documents and Scoping Document 1 for the Seneca Pumped Storage Project, Project No. P-13889-000 from the Seneca Nation of Indians, and Project No. P-2280-013 for FirstEnergy Corp.

Dear Secretary Bose:

I am writing to provide comments concerning the above-referenced competing hydropower relicensing projects.

 I have reviewed the Pre-Application Documents, as well as Scoping Document 1 from FERC.  It is my understanding that it is FERC’s responsibility to grant a hydropower license only for the best use of this precious energy resource called the Allegheny waterway.  Therefore, it is my overall comment that the Seneca Nation of Indians is best suited to hold the privilege of this federal license.  FirstEnergy is not looking to improve the conditions of the environment affected by the Project.

It is imperative to expand the project boundary, as the Seneca Nation has proposed.  The current project definition does not include the waters of the Allegheny River and transmission lines that are integral to the operation of the pumped storage project.  This means for the last 45 years, the project, and the private utilities that have operated the project, have ignored its environmental effects and have erroneously attributed all environmental degradation to the operations of the Kinzua Dam.

The Seneca Nation proposes to study the effects of project by first correctly analyzing the scope of the project.  By doing so, the Seneca Nation can properly analyze the environmental effects of the project directly and cumulatively.  FirstEnergy takes no accounting of the Allegheny River or the transmission lines.

Furthermore, the twenty-two studies proposed by the Seneca Nation of Indians are inclusive of the overall environment of the Allegheny water system and the life dependent upon it, both upstream and downstream.  The Seneca Nation’s studies holistically address fish and wildlife and their habitat, fish entrainment at the dam, water temperature, erosion, sedimentation, and cultural resources.   FirstEnergy’s proposal of three studies is limited to invasive species, mussels and temperature problems downstream only.

The Allegheny River and its reservoir are major features of the Allegheny National Forest (ANF). The ANF is the most industrialized forest in the USFS system with between 12,000 to 15,000 active oil and gas wells (and un-numbered and un-surveyed abandoned oil and gas wells) and all of the infrastructure that goes with this type of industrial extraction including tank batteries, electric lines, gas lines, brine pits, and over 2,300 miles of OGD roads (on top of 1,500 miles of USFS system roads). Now, the forest also is suffering the impact from unconventional shale drilling on forestlands and private in-holdings, including illegal massive water withdrawals, and wastewater disposal.

A couple of years ago, there was a massive spill in the ANF from one of the drilling areas which dumped over 40,000 gallons of oil into Chappel Bay and the Allegheny River Reservoir. There is currently a whole regime of EPA regulations, the SPCC regulations, which appear to be consistently ignored on the ANF, ensuring future major disasters like the one of several years ago (and regular less severe spills).

On top of this impact we have the incredible impact of industrial clear-cut logging on the ANF with over 20,000 acres of clear-cut proposals being pushed through the system in the past year—which includes over 10,000 acres of glyphosate herbicide application.

I find great comfort that the Seneca Nation of Indians is willing to invest in the health of the region’s environment, and is confident in the Nation’s capacity to develop positive environmental opportunities for our region. I support the Pre-Application Document and the Study Proposal of the Seneca Nation of Indians for Project No. 13889. I cannot support the status quo presented by First Energy’s Pre-Application Document.

Sincerely,