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Comment in Support of Whitewater Recreation on the Montreal River (WI/MI)

Posted: 11/13/2024
By: Thomas O’Keefe

The Federal Energy Regulatory Commission (FERC) has provided public notice that they will be reviewing license applications for the Gile Flowage, Saxon Falls, and Superior Falls hydroelectric projects. Their review will impact the future of whitewater opportunities on the West Branch Montreal and Montreal Canyon, including flow management, flow data, and public access.

The good news is Northern States Power Company has filed license applications that include accommodations for whitewater recreation. If you are interested you can read the full license application here:

Saxon Falls P-2610-012 and Superior Falls 2587-066 covering public access and whitewater recreation measures for the Montreal Canyon: <https://elibrary.ferc.gov/eLibrary/docinfo?accession_Number=20221230-5395>. See in particular pages E-101 to E-110 of Exhibit E that covers whitewater recreation.

Gile Flowage Storage Reservoir Project P-15055-001 covering public access and whitewater recreation on the West Branch Montreal: <https://elibrary.ferc.gov/eLibrary/docinfo?accession_Number=20230818-5221>. See in particular pages E-84 to E-88 of Exhibit E that covers whitewater recreation.

The Northern States Power plan includes the following measures:

  1. Real-time Flow and Operational Information: The Montreal Canyon and West Branch both experience spring flows, but it can be difficult to track these opportunities without information about operations, such as the operations schedule of the dam that forms Gile Flowage.

  2. Scheduled Releases: In addition to the natural spring flows, Northern States Power proposes two scheduled releases each year for the West Branch and Montreal Canyon in June and September of 1200 cfs beginning in the morning so the West Branch could be paddled early in the day and the Canyon could be paddled later in the day. Our preliminary assessment finds this plan appropriate given the limited storage capacity at Gile Flowage. These releases will complement the natural spring flows.

  3. Improvements to Public Access: Northern States Power proposes to formalize access to the stairway at the Tailwaters below Saxon Falls and to allow boaters to request a key card for the gate at the top of the stairs. We will recommend that the gate be open on weekends during daylight hours when the river is at optimal levels for whitewater boating. The utility also plans to relocate the take-out access further down the reservoir and create an additional put-in point at the dam that forms Gile Flowage, serving as a new access point for the West Branch. 

Comments can play a crucial role in documenting the whitewater boating community’s interest in this river and in advocating for accommodations in a future license order. American Whitewater will submit detailed technical comments, but the most effective action our members can take is to provide a brief personal comment—just a paragraph or two—highlighting local support for the river. Please address the following:

  • Share what the Montreal River means to you, specifically the West Branch Montreal or Montreal Canyon. Explain why recognizing whitewater recreation in the new license is important to you.

  • Express your full support for hydropower license measures that include the development of a whitewater recreation plan, which should cover flow releases, real-time flow information access, and improved access to the river.

American Whitewater will be filing detailed comments in support of whitewater recreation on the Montreal River. Members who are familiar with the river are encouraged to reach out and share their input on our comments before they are submitted. This is the first opportunity to submit comments. There will be another important chance after FERC issues its draft environmental review, and we will notify you when that opportunity arises.

How to File Your Comments:

There are three ways to submit your comments:

  1. eComment System (Recommended)

  • The easiest method is to use the FERC eComment system (6,000 character limit).

  • To begin, fill out your contact information using this online form: eComment Form.

  • FERC will send you an email with a link to the form where you can enter your comment.

  • We recommend drafting your comment first and then copying and pasting it into the form. Note that the form accepts plain text only, so avoid any special formatting.

  • In the form, you’ll select the relevant docket and sub-docket for each project: P-15055 for Gile Flowage Storage Reservoir Project (sub-docket 001), P-2610 for Saxon Falls (sub-docket 012), and P-2587 for Superior Falls (sub-docket 066). You can prepare one comment and select multiple dockets at once or you can go through the process three separate times for each docket. [we asked FERC to consolidate this proceeding into one docket but they chose not to].

eFiling System (For Comprehensive Comments)

  • If you prefer to file more detailed comments, you can register for an account on the FERC website for eFiling: eFiling Login.

  • Registering allows you to subscribe to the docket (P-2587, P-2610, and P-15055), so you will be notified of all filings and future comment opportunities.

  • This option is recommended if you want to track the status of the project and receive updates.

Mailing Hard Copy Comments

  • If you prefer to mail a physical copy of your comments, send them to: Debbie-Anne A. Reese, Secretary, Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426

  • Be sure to reference the docket number in your introductory paragraph to ensure your comment is filed correctly: P-2587 for Superior Falls, P-2610 for Saxon Falls, P-15055 for Gile Flowage Storage Reservoir Project

 

Thomas O'Keefe

3537 NE 87th St.

Seattle, WA 98115

Phone: 425-417-9012
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