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Tom Uncher is the vice president of Brookfield Renewable’s New England operations.
Eight years ago, relicensing of the Ellsworth Hydro Project began before the Federal Energy Regulatory Commission. This project consists of Ellsworth and Graham dams and Leonard Lake and Graham Lake. While the relicensing process was expected to conclude three years ago, the path forward remains uncertain and, absent a balanced solution, removal of the Ellsworth and Graham dams may be an unfortunate but necessary outcome. We hope to shed light on what Brookfield Renewable’s Black Bear Hydro Partners proposes under the new license, outline potential outcomes and address stakeholder concerns.
The Ellsworth hydro project was constructed nearly a century ago for electric generation. Graham Lake is a manmade reservoir consisting of 9,383 acres. Out of Maine’s 20 largest lakes, Graham ranks 14th in acreage, fifth in shoreline perimeter, 20th for total elevation (106 feet), and 20th for maximum depth (47 feet). These attributes make Graham Lake very susceptible to minor elevation changes and the overall natural hydrological cycle.
In recognizing that Graham Lake is a large, very shallow water body, we understand stakeholders’ desire for limited drawdown levels. In response to these concerns and delays in the relicensing process, we are pleased to announce that, for 2021, we are voluntarily implementing a summer drawdown limitation of 4.5 feet for Graham Lake, with elevation restrictions of 98.5 to 103 feet. We are committed to this voluntary limitation from Memorial Day through Labor Day.
Our relicensing proposal includes multimillion-dollar investments for robust upstream and downstream fish passage systems at the Ellsworth and Graham dams. This includes installing trash racks, a fish boom, eel passage methods and upgrades to existing passage facilities, with meaningful improvements occurring within the first two years of the new license. While we understand the preference for immediate action, designing and installing fish passage facilities requires multiple engineering and biological opinions, a series of reviews from state and federal regulatory agencies, and final permitting.
Before Brookfield Renewable acquired the Ellsworth facility, few measures existed to improve fish passage and mitigate mortality events. Since 2015, we implemented voluntary mitigation measures with examples that include shoreline surveys, daily inspections and shutting down the generating units from several hours to more than a month during outmigration periods.
Our vision is to safely and sustainably generate clean, renewable energy to support Maine’s renewable energy and climate goals while supporting reservoir levels for recreation and investing in appropriate fish passage systems that enhance Union River restoration. We believe the next phase of this process should include project relicensing consistent with applicable standards. However, if a water quality certification is not issued, Black Bear Hydro Partners would be forced to consider decommissioning both Ellsworth dam and Graham dam.
It is unclear what this would mean for the future of Graham Lake as dam decommissioning plans vary by project. However, priority is given to dam safety and environmental issues and recent U.S. decommissioning projects have typically prioritized fish passage and incorporated the removal of dam structures, restoring rivers to their natural states. In this case, the river may be restored from above Graham Lake to the ocean.
Owning and operating a Federal Energy Regulatory Commission-licensed facility includes significant responsibilities and often involves multimillion-dollar investment to meet future compliance and dam safety requirements. To date, no third-party has expressed interest in acquiring the Ellsworth assets. Even if a party identified itself, it is uncertain if they would be permitted to take on this responsibility.
Shoreline owners envision the future Graham Lake to exist solely as a recreational lake, while fish advocates envision dam removal and river restoration. These two long-term visions do not align and cannot realistically coexist. The Ellsworth hydroelectric facility provides the reason for Graham dam. Without the hydropower facility, the costs of maintaining Graham dam would have to be borne by somebody if Graham Lake is to be maintained.
Local stakeholders should fully consider what’s at stake for the future of the Ellsworth dam and Graham Lake and adopt a balanced approach in what they envision for the water quality certificate and future Federal Energy Regulatory Commission license.
We also urge the Maine Department of Environmental Protection to consider these divergent stakeholder interests in adopting a water quality certificate that will support a long-term sustainable future for the Ellsworth hydro project.