Please Help Us Save St. Anthony Falls
The Federal Energy Regulatory Commission (FERC) has started proceedings to terminate the license for Crown Hydro LLC to construct a hydroelectric facility on the Downtown Minneapolis Riverfront. The license was applied for in 1991 and granted in 1999. 24 years later, Crown Hydro has been unable or unwilling to abide by the terms set by FERC, and is facing termination.
Under the terms of the current license, Article 404, Crown Hydro LLC, a private developer, would for all practical purposes be able to shut off St. Anthony Falls for 12 months per year during times of low flow. (Details at bottom of page)
This project also threatens major design elements of the upcoming Water Works Park. Hear MPRB President Liz Wielinski:
Please help us save St. Anthony Falls and protect the future of the Central Riverfront, the birthplace of Minneapolis.
**SUBMIT YOUR COMMENT IN 3 EASY STEPS / DOCKET NO. P-11175-024**
Step 1 - Create your comment. Create your comment in a Word or Text file, or copy/paste the sample comment below. Your comment doesn't need to be lengthy - it could be as simple as "I support terminating the existing Crown Hydro License".
Step 2 - Submit an eComment request to FERC. Follow this link to request access to the FERC Quick Comment system: https://ferconline.ferc.gov/QuickComment.aspx
Step 3 - Post your comment. Remember to use Docket No. P-11175 for all comments regarding Crown Hydro. After you submit an eComment request, you will receive an email from ferc.gov with a link to the comment system.
"Never doubt that a small, group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has."
-- Margaret Mead
**Short Sample Comment to FERC - Just Copy/Paste**
Re: Project No. 11175 / Crown Mill Hydroelectric Project
I am writing in support of terminating the existing Crown Hydro license. The new Crown Hydro proposal constitutes an entirely new project at a new location, and should require a new license. This project as licensed also threatens the aesthetics of St. Anthony Falls, the integrity of the Stone Arch Bridge, $300m in public investment, and future investment including the approved the MPRB approved $27m plans for Water Works Park adjacent to the project.
Respectfully,
**BACKGROUND**
Download Letter to FERC from Minneapolis Park & Recreation Board
More than 24 years have passed since Crown Hydro applied for a license to construct a hydropower generation facility on the Central Riverfront of Minneapolis on August 2, 1991. Two plus decades later, Crown Hydro has yet to provide FERC with most of the requested operational plans, studies, and stakeholder approvals required of a project of this type. Crown Hydro has delayed, or ignored, dozens of FERC requirements and deadlines for 22+ plus years. This fact alone supports termination of the existing Crown Hydro license.
Three major issues which support terminating the Crown Hydro license:
1. This is a Completely New Project
The new proposed location and design of this project differs in every way from the current license held by Crown Hydro, issued in 1999, including:
- Location of the Headrace
- Location of the Powerhouse
- Location of the Discharge Tunnel
- Location of the Tailrace
- Location of the Transmission Line
The new proposal bears no resemblance to the currently licensed project. The public record supports defining the new proposal as a new project, including positions taken by both the FERC and the MPRB below:
- FERC Letter to Crown Hydro Dated April 15, 2013:
"The difference between the licensed project and Crown's current proposal are great enough to conclude that it is essentially a different project than the one analyzed in the 1990's..."
- FERC Letter to Crown Hydro Dated July 15, 2013:
"Rather than refurbishing existing buildings, canals, and tunnels as contemplated in your license, your proposal involves construction of a powerhouse on lands outside the current project boundary and construction of underground tunnels from the new powerhouse to a new point of discharge."
- MPRB Letter to FERC Dated August 14, 2013:
"Crown's latest attempt to style a completely new project as a license "amendment" is disingenuous at best. Crown has proposed a completely new project on a new site that requires a new headrace, tunnel and tailrace, and it should be considered as such."
The facts in the public record support FERC terminating the existing Crown Hydro license.
2. Crown Hydro Has Not Fulfilled FERC Requirements
There is no evidence that Crown Hydro has addressed stakeholder concerns, or complied with the Information Needs: Schedule A, both of which were set forth in the FERC letter to Crown Hydro dated April 15, 2013. In fact, most of the issues and concerns in the FERC letter were raised, and left unanswered, at the public meeting held by Crown Hydro on November 26, 2013. A video recording of that meeting can be found at:
The 60 day deadline set by FERC on April 15, 2013 has long since passed with seemingly no effort by Crown Hydro to comply with FERC mandates. This is just the latest of many deadlines Crown has missed or disregarded in the 22+ years since their original license application.
The long established pattern of inability or unwillingness to comply with FERC mandates and deadlines supports terminating the existing Crown Hydro license.
3. This Project Threatens the #1 Tourist Attraction in Minneapolis
The area surrounding the new project boundaries proposed by Crown Hydro – the Central Riverfront of Minneapolis – has undergone an amazing transformation in the 22+ years since the original license application. $2.3B in in combined public/private investment has transformed the Central Riverfront from a desolate wasteland of abandoned buildings and empty surface parking lots into the #1 tourist attraction in Minneapolis, attracting over 1.6 million visitors each year, drawn largely by St. Anthony Falls and the Stone Arch Bridge.
St. Anthony Falls. Article 404 of the Crown Hydro license allows for St. Anthony Falls to, for all practical purposes, be shut off 12 months per year during low flows. Back in the 1990’s when this project was conceived and licensed the economic impact of a dry falls would have been negligible, given the fact that the Central Riverfront was not yet a major tourist attraction and public amenity. Today, a dry falls would be devastating to both the tourism industry and the use and enjoyment of the Central Riverfront by the general public.
The Stone Arch Bridge. The other main attraction on the Central Riverfront is the historic Stone Arch Bridge, under which Crown Hydro proposes to build a 930 foot long discharge tunnel, which was not part of their existing license. The geology of the riverbed in this section of the river is highly fragile. This area is also well known for having a history of catastrophic tunnel collapses due to the geologic instability of the area. Should the Stone Arch Bridge suffer a collapse or even major structural damage, it may not be possible to repair this National Historic Landmark, and no contingency has been made to fund such remediation even should it be possible.
Summary. Given the fact that the new Crown Hydro proposal constitutes a new project; and considering the inability or unwillingness of Crown Hydro to follow FERC requirements and deadlines; and taking into account the actual and potential negative impact on the #1 tourist attraction in Minneapolis, the public good would be best served by terminating the existing Crown Hydro license.
**Article 404 - Crown Hydro License**
CROWN HYDRO LICENSE ARTICLE 404 FEDERAL ENERGY REGULATORY COMMISSION (FERC): The licensee shall operate the Crown Mill Hydroelectric project so that some water always flows over St. Anthony Falls except as follows: (A) during any periods of very low flows when the project could not operate at 200 cfs without drying up St. Anthony Falls, the project will operate only from nightfall until dawn; (B) between December 15 and March 15 the project will operate with whatever flows are available even if it dries up the falls; and (C) during low flows in July and August, the project will operate with up to 500 cfs during daylight hours even if it dries up the falls...
Source: FERC License issued to Crown Hydro, Article 404 (Pg. 20) - Download:
