The study plans were presented at meetings last week at the GRDA Ecosystems and Education Center at Pensacola Dam in Langley.
Editor’s Note: This is the first article of two parts on GRDA’s Proposed Study Plan for relicensing. Part two will cover the proposed Recreation Facilities Inventory and Use Survey, Socioeconomics Study, and a Cultural Resources Study.
LANGLEY – Two days of meetings for the presentation of GRDA's Proposed Study Plan for their relicensing request for the operation of the Pensacola Hydroelectric Project 1494-438 to FERC (Federal Energy Regulatory Commission) ended in some frustration for City of Miami and Tribal attendees.
FERC is the independent federal regulatory agency that under the Federal Power Act regulates and oversees energy industries for the protection of economic, environmental, and safety interests of the American public. FERC is responsible for licensing and inspecting private, municipal, and state hydroelectric projects. FERC’s authority applies to the lands, waters, and structures within the FERC hydropower project boundary.
The hydropower license was first issued in 1939 for the Grand Lake O’ The Cherokees, and GRDA's 30-year license expires March 31, 2022.
As part of the relicensing process, GRDA is required to provide study plans and hold meetings for the presentation, feedback, and discussion of the proposals. The study plans were presented at meetings last week at the GRDA Ecosystems and Education Center at Pensacola Dam in Langley.
“During the hearings related to GRDA’s proposed study plan, I was thinking of my, and many other, comments that were filed with FERC earlier this year,” Miami City Manager Dean Kruithof said, after the meetings. “In summary, we noted that the relicensing process could be a positive time in which all parties can come together to resolve the long-standing issues related to the development and operation of Grand Lake. These issues can be summed up in the opening comments of Greg Estep of the US Army Corps of Engineers when he noted the lake never had proper easements, there was a backwater flooding effect, and the operation of the lake from their perspective was a ‘nightmare’.”
The study plan information was presented by GRDA's Brian Edwards and Darrell Townsend, and Mead & Hunt representatives. FERC Project Manager Rachel McNamara and staff, Tribal leaders and staff, City of Miami leaders and staff, Oklahoma State Wildlife staff and others filled the facility both days.
Although the relicensing could be granted for the project and lake’s operations from 20 to 50 years, arguably a hugely important decision for upstream, downstream and the lake area, questionably absent from the meeting were Grove area officials and other media.
Townsend began the meetings by explaining GRDA may be requesting a potential license extension of about one year from FERC due to FERC's “unprecedented event” at the loss of a quorum earlier in the process for 7 to 8 months.
If GRDA is not granted an extension, GRDA’s Legal Counsel Chuck Sensiba said, “This means we won't have all the information from a second year of studies when we file the application.”
The study plan meetings objectives were to review the Proposed Study Plan and offer open discussion regarding studies GRDA proposes are deemed necessary for relicensing.
“This helps ensure the appropriate studies are being performed in support of issuance of a new license,” Townsend said. “In four years there's going to be numerous opportunities to comment on this process and get your comments on record.”
Of the formal study plans requested by agencies and relicensing participants and public commentary received several study requests were not adopted.
“Many of those, we feel like, there's enough data and enough information out there to satisfy the requests,” Townsend said.
GRDA is proposing five separate studies for relicensing purposes; a Hydrologic and Hydraulic Modeling Study, Sedimentation Study, Recreation Facilities Inventory and Use Survey, Socioeconomics Study, and a Cultural Resources Study.
“For years, FERC has told Miami that many of these issues should be addressed during relicensing. However the proposed studies, in my opinion, fall short of addressing obvious and serious problems, “Kruithof said later in response. “Two areas that significantly surprised me were the proposed studies that related to recreation and socioeconomic effects. The recreation studies only seem to revolve around the five access areas operated by GRDA and not state parks like Twin Bridges. This seems very shortsighted and ignores issues that have been raised about sedimentation and the health of the fish population. The socioeconomic study is a simple “desktop” review of current conditions. It ignores historical data and does not ask questions about the economic and social health of upstream versus downstream communities along the Neosho River System.”
The City of Miami and local Tribal officials expressed during the meetings and after that, the proposed studies are inadequate to address concerns raised in the relicensing of the project.
“Of course it was continually noted that we can submit comments which will be done, but it would have been nice to feel that GRDA is addressing long-standing issues seriously instead of proposing what appears to be a minimal effort, forcing all stakeholders like the City, County, and Tribes to make a case of filling in the blanks,” Kruithof said.
“The information that we were given from two days of meetings with GRDA and FERC - it seems to me not enough emphasis will be put on one of the major problem areas and that is the Twin Bridges area. The studies they are proposing to do seem to be concerned with the lower part of the lake. Sedimentation I believe is one of the problems along with a higher variance that has caused many recent flooding events,” Wyandotte Nation Second Chief Norman Hildebrand, Jr. said.
Key Regional Locations Pensacola Project Map
U.S. Army Corps of Engineers
Before beginning their presentations U.S. Army Corps of Engineers Chief Hydrologist Greg Estep spoke on the Arkansas River System Operations and the reservoir and river system's water control plan, The 'Arkansas River Basin Water Control Master Manual'. The manual was created in July of 1980 and last updated in October of 2007. To make changes to the manual takes years of study costing from $4 million to $8 million.
Estep explained the entire operation system for the Tulsa District Water Management and flood control must balance the needs of 50 projects, 12 Section-7 lakes, 23 lakes with gated spillways, 8 COE Hydropower, five navigation locks and one chloride control project. The Arkansas River System includes 35 Projects and the Red River System 15 Projects.
All flows in the Arkansas River System above must be adjusted to the restricted flow of 150,000 cfs or less at Van Buren, Arkansas, where a bottleneck occurs. The Pensacola reservoir holds 525,000, or 7 to 8 percent of the 7,687,055 ac-feet of flood storage in the 11 reservoirs within the system.
There are three Grand Lake Storage Zones; an Inactive Pool to 705 feet, the Conservation Pool (Hydropower pool) up to 745 feet managed by GRDA, and the Flood Control Pool to 755 feet managed by the Corp. The top of the Pensacola Dam is at 757 feet.
Under the 'Pensacola Letter of Understanding,' in effect since 1992, the physical operation and operations for storage and release of waters below 745 feet PD and above 755 feet are the responsibility of GRDA, according to Estep.
Estep explained the goal of flood risk management operations are to not exceed the downstream bankful capacity and are not based on potential rainfall.
“Releases from reservoirs are based on water on the ground,” Estep said. “The Corps may direct GRDA to make releases to draw the pool down below 745 feet to maximize flood control benefits as long as the reduction in the power storage will be replenished by inflows.”
For that to happen the Corps must have forecasts to indicate Grand Lake will rise above a 745 feet elevation and NWS forecasts indicating the Neosho River at Commerce gage to rise above flood stage at 15 feet.
Estep said the Corps involvement in the relicensing process is only to provide information and data.
“Our lawyers say that’s GRDA and FERC for the relicensing legal process,” he said.
Upstream flooding is not the responsibility of the Corp to manage, according to Estep
“We all know back in the 1930s when they built the Dam they didn't buy enough real estate,” Estep said.
Asked if there were any plans to purchase additional easements, Estep replied, “Grand Lake is the only Project that I'm aware of that the Corps had to pull easements, every other Section 7 Project going to the to the dam was responsible for their own easements... It’s been sort of a real nightmare.”
Estep said there is only a certain amount of flood storage in the system to work with to manage flood control and the flood plan is still a good plan.
GRDA proposed H&H Study
GRDA Proposed Hydrologic and Hydraulic Modeling Study as explained by Mead & Hunt’s Nick Hathaway and Ryan Greif has four main goals and objectives.
Mead & Hunt specializes in hydrology and hydraulics and FERC licensing by providing consulting services and expertise with offices across America including Tulsa.
The study will determine duration and the extent of inundation under the current license operations of the Project during several measured inflow events.
The study will determine the duration and extent of inundation under any proposed change in operation that occurs during measured synthetic inflow events.
The Mead & Hunt Study will provide the model results in a format that can inform other analyses of the Project effects, if any, in several resource areas.
Lastly, the study will determine feasibility of implementing alternative operation scenarios, if applicable, that may be proposed by GRDA as part of relicensing.
During their presentation, Mead & Hunt’s Hydrologists referred to the City of Miami’s commissioned 2015 Tetra Tech Study as “the most robust to date,” which will be used as a base model.
No pre-dam data is included in the proposed study and the existing conditions will set the baseline.
GRDA proposed Sedimentation Study
GRDA’s proposed Sedimentation Study, a possible two-year study, was presented by FreshWater Engineering’s owner Laura Roxumalski.
FreshWater Engineering of Madison, Wisconsin specializes in water resources engineering and waterway restoration.
The goals and objectives of the study are to improve understanding of the sediment transport process and patterns upstream of Grand Lake.
The study year one will evaluate long-term interactions between; Grand Lake water levels, sedimentation patterns and processes in the watershed, and project operation and sedimentation.
A contingent second-year study will collect and analyze field data contingent upon the results of study year one. The second-year study will use data to further evaluate the relationship of the Project operations and sedimentation to the extent and duration of inundation.
The sedimentation study does not include the sampling for study of the contents of contaminates or metals in the sedimentation.
Tetra Tech’s Hydrologist Dai Thomas attended both days of meetings and asked several technical questions during the first day of presentation regarding the H& H Study and Sedimentation Study.
“The hydraulic model will be used, in part, to evaluate the effects of flooding due to the operation of Pensacola Dam along Grand Lake, Neosho, Spring and Elk Rivers and Tar Creek over a range of historic flood events. The sedimentation study is intended to evaluate sedimentation processes, sediment deposition patterns, and the impacts of sedimentation on flooding. The City has reviewed both study plans and will be submitting comments and recommendations to FERC,” Thomas said later.
Public and stakeholder comments
GRDA reported in the last scoping comment period in March of 2018 in addition to oral comments gathered at meeting, written comments were filed with FERC by 41 individual residents or business owners, the Oklahoma Water Resources Board, BIA, seven Native American Tribes, GRDA, the City of Grove, City of Miami FERC, Southwestern Power Administration, U.S. Fish and Wildlife Service, Oklahoma Department of Wildlife Conservation, Attorney Larry Bork on behalf of 445 plaintiffs, U.S. Environmental Protection Agency, Corps, the Oklahoma Archaeological Survey and the LEAD Agency and Grand Riverkeeper.
The next step is for comment on GRDA's Proposed Study Plan are due to be filed with FERC by July 26, 2018.
“When submitting comments please be sure to include the Project docket and sub-docket number on all filings, P-1494-438,” Townsend said.
Melinda Stotts is the associate editor of the Miami News-Record. She can be emailed at email@example.com or followed on Twitter @MelindaStotts1.