The City of Miami and other stakeholders are currently reviewing the recently submitted Revised Study Plan by GRDA in the FERC relicensing process of the Pensacola Project.

MIAMI – Monday, the Grand River Dam Authority (GRDA) filed a Revised Study Plan (RSP) with the Federal Energy Regulatory Commission (FERC) in the relicensing process of the Pensacola Project for the operational licensing. The 120-megawatt (MW) Pensacola Hydroelectric, owned and operated by the GRDA), is licensed by the FERC as Project No. 1494.

The existing license for the Pensacola Project was issued to GRDA on April 24, 1992, and will expire on March 31, 2022. GRDA is applying for a new license for the Pensacola Project.

GRDA filed the RSP last week in accordance with FERC's Integrated Licensing Plan in the next step of the relicensing process. GRDA's Vice President Darrell Townsend II filed the RSP along with a letter to FERC's Secretary Kimberly D. Bose on Sept. 24 that was also sent to a distribution list of stakeholders and interested parties.

“This RSP provides FERC, resource agencies, Native American tribes, and other relicensing participants with a study plan, submitted to FERC for approval, which incorporates – based on the many comments received – substantial changes from the original PSP,” Townsend wrote in the letter to Bose.

The City of Miami and other stakeholders are currently reviewing the recently submitted Revised Study Plan.

Comments on GRDA's Revised Study Plan must be filed by Oct. 24, 2018.

FERC's Study Plan Determination is expected by Nov. 8, 2018

PSP to RSP

GRDA received a total of 19 comment letters from federal and state resource agencies, Native American Tribes, non-governmental organizations, and other interested parties with 22 study requests made as part of the comment process on the Proposed Study Plan.

In their filing, GRDA states in response there are several new proposed studies included in the Revised Study Plan not included in the Proposed Study Plan, and GRDA has also expanded studies that are “more robust” versions of studies included in the PSP.

These additional studies address remaining data gaps by looking at existing information as well as researching and reviewing other sources of information identified by relicensing participants.

“GRDA then analyzed the information and extracted any additional, relevant data that could be gleaned to determine what supplemental studies are needed to meet ILP objectives,” GRDA states in the RSP.

GRDA’s Proposed Study Plan included just five studies. The Revised Study Plan includes eight studies; Hydrologic and Hydraulic Modeling Study, Sedimentation Study, Aquatic Species of Concern Study, Terrestrial Species of Concern Study, Wetlands and Riparian Habitat Study, Recreation Facilities Inventory and Use Survey, Cultural Resources Study and Socioeconomics Study.

The Aquatic Species of Concern, Terrestrial Species of Concern, and Wetlands and Riparian Habitat studies were the three additional studies added.

Hydrologic and Hydraulic Modeling Study

GRDA claims substantive changes have been made to the Hydrologic and Hydraulic Modeling Study since the PSP, including identifying areas inundated during current operation of the Project, as well as during any operational changes that may be proposed as part of the relicensing effort. In addition to the inundation area, the study will provide other flood routing specifics such as the frequency, timing, amplitude, and duration of the inundation.

Sedimentation Study

GRDA claims substantial changes have been made to the Sedimentation Study expanding it to a two-year study and will analyze the existing data and the newly collected data to determine the potential effects of Project operations on sediment transport, erosion, and deposition in the lower reaches of the tributaries to Grand Lake upstream of Pensacola Dam within the project boundary.

Specifically, this study will determine the amount of sedimentation that has occurred in the reservoir since the construction of Pensacola Dam; evaluate sediment transport, erosion, and deposition in Grand Lake and its tributaries; and characterize the impact that any sedimentation may have on flood extents and duration in upstream tributaries.

Aquatic Species of Concern Study

In the Aquatic Species of Concern Study species that will be assessed during this study are the following: Paddlefish, Neosho Smallmouth Bass, Neosho Madtom, and Neosho Mucket.

Terrestrial Species of Concern Study

Terrestrial Species of Concern Study is a desktop study that will provide information needed to assess potential Project-related impacts to the gray bat, the northern long-eared bat, and the American burying beetle

Wetlands and Riparian Habitat Study

The goals of the Wetlands and Riparian Habitat Study is associated with the tasks of conducting the study through desktop mapping of distribution of wetland and riparian vegetation, a review of existing information; and potential field verification of wetland maps. Part of the goal of this study is to estimate the total acres of wetlands and riparian habitats that currently exist within the study area; use results of the H&H Study to determine potential Project effects based on the seasonal variability of hydrologic conditions related to Project operations; and to determine potential changes to habitat in currently designated Wildlife Management Areas (WMA) in the Project area.

Recreation Facilities Inventory and Use Survey

The Recreation Facilities Inventory and Use Survey was originally proposed to include only the five FERC-approved recreation sites. Based on comments received on the PSP, GRDA has expanded the study area to include the state parks around Grand Lake and immediately below the Project Dam, Connors Bridge, and Riverview Park.

Also GRDA has the added task to collect recreation observation data to document informal recreation uses downstream of the Project and a task to collect boat launch elevation data at several boat launches around Grand Lake to assess potential Project effects of operating the Project at varying water levels.

Cultural Resources Study

The revised plan for the Cultural Resources Study based on comments on and consultation with Native American Tribes, THPOs, the Oklahoma SHPO, OAS, ACHP, BIA, and FERC clarified additional consultation and coordination with Native American Tribes and THPOs and described a schedule for continued consultation and meetings with the CRWG, and provided additional information on GRDA’s commitment to sharing information with the CRWG while protecting confidential information.

Other substantive changes include the addition of subsurface testing. the inclusion of certain archaeological site evaluations and assessments, a description of GRDA’s approach to developing and implementing an inventory of Traditional Cultural Properties and additional information regarding how GRDA proposes to address tribal monitoring, inadvertent discoveries, curation, site documentation, the eligibility of unevaluated archaeological resources, and archaeological sites identified on lands that are not owned by GRDA.

Socioeconomics Study Plan

The Socioeconomics Study Plan has been revised due to comments received to provide more detail on the approach that will be used to report available information on the socioeconomic effects of the Pensacola Project.

The methodology has been expanded to detail the types of existing socioeconomic data to be used to present qualitative assessment of the four-county study area. This will be done through information gathering that includes a direct query of relicensing participants, as well as local organizations and businesses, for available and objective data to inform the socioeconomic impacts of the Project in the Grand River Basin. GRDA is proposing to conduct a Socioeconomics Study to gather, synthesize, and report on existing information necessary to qualitatively evaluate the cumulative socioeconomic effects of the Pensacola Project in the study area.

The objectives of the study are to describe baseline economic conditions in the Project area and to identify the socio-economic contribution of the Project in the region.

In the RSP document, GRDA gives response to all study requests received.

GRDA states in the document, “Some of these study requests did not provide all of the information required by FERC’s ILP Study Criteria, as set forth in Section 2.1 of this RSP. Regardless, in an effort to be complete, GRDA has attempted in this RSP document to identify and evaluate all study requests submitted, including those that may not have fully complied with FERC’s Study Criteria."

Rejected study requests include Project Boundary and Federal Lands Study, Sediment Transport Model Study, Contaminated Sediment Transport Study, Flora and Fauna Impacts Study, and an Infrastructure Improvement Study

Relicensing Process timeline to date

GRDA filed a Notice of Intent for relicensing for the Pensacola Project in Feb. 2017, comments were received in February and March of 2018 and GRDA filed their Proposed Study Plan on April 27, 2018.

As required Study Plan Meetings were held in May of 2018 with stakeholders to discuss GRDA's proposed studies and other parties' study requests.

GRDA also met with a Cultural Resources Working Group, an Advisory Council on Historic Preservation,, the Oklahoma State Historic Preservation Office, the Oklahoma Archaeological Survey and participant Tribes in consultation meetings.

An opportunity from interested parties for commentary on the Proposed Study Plan was also available until July 26, 2018.

Comments on GRDA's Revised Study Plan are being accepted now and must be filed by Oct. 24, 2018.

The Revised Study Plan document can be accessed on GRDA’s relicensing website (http://www.grda.com/pensacola-hydroelectric-project-relicensing/) or FERC’s eLibrary system (https://ferc.gov/docs-filing/elibrary.asp) under FERC Docket No. P-1494-438.

Melinda Stotts is the associate editor of the Miami News-Record. She can be emailed at mstotts@miaminewsrecord.com or followed on Twitter @MelindaStotts1