The Hydropower Reform Coalition (HRC) submitted the following comment to the Federal Energy Regulatory Commission (FERC) on the proposed rulemaking governing the safety of hydropower projects licensed by the Commission under the Federal Power Act.
The HRC appreciates this effort by FERC to improve dam safety at hydropower projects, and supports the changes proposed. We also see larger structural issues that unfortunately are not addressed by this proposed rulemaking, and through these comments we wish to encourage FERC to undertake broader changes in this area. There are three key issues that must be resolved to fully address dam safety issues. The first is the disconnect between the licensing process and the dam safety process at FERC, the second is the lack of public transparency about the condition of dams (and risk to the public) across the country due to the veil imposed by Critical Energy Infrastructure Information (CEII) restrictions, and the third is the insufficient consequences for hydropower project operators who fail to adequately maintain their facilities and, in so doing, expose the public to downstream risk.
Read our full comments.
FERC docket RM20-9-000: Proposed Rulemaking on Safety of Water Power Projects and Project Works. Document accession number 20200923-5003.