News & Bulletins
December 31, 2012
RECREATIONAL USERS OF RESERVOIRS URGED TO USE CAUTION
With the onset of more seasonable temperatures, the Hudson River - Black River Regulating District reminds all recreational users of the Great Sacandaga Lake, Indian Lake, Stillwater, Sixth Lake and Old Forge river regulating reservoirs to use caution when recreating near a reservoir or when on the ice.
The elevation of each reservoir can change dramatically during the winter, creating variations in ice thickness and strength. As reservoir water levels fluctuate, and as water elevations are lowered in preparation for spring runoff, ice pressure ridges, voids, and pockets will form on the ice surface.
Changes in ice surfaces will occur as a result of the release of water during the winter. Recreational users of the reservoirs are urged to become familiar with the potential hazards and use caution when on the ice.
October 24, 2012
NEW PROCEDURE FOR RENEWAL OF ACCESS PERMIT
Dear Access Permit Holder:
We are pleased to offer you the opportunity to renew your Access Permit for one year, beginning March 15, 2013. The Access Permit affords you and your guests the use of a segment of New York State land under the jurisdiction of the Hudson River-Black River Regulating District (the Regulating District) for access to the waters of Great Sacandaga Lake.
Please use this procedure to renew your access permit:
-
*** Sign the enclosed application and return just the white copy. Retain (keep) the yellow copy for your records. ***
- PERSONAL signatures of all persons listed on the permit are required.
- Show any changes of address on the application.
- Return the total fee and white signed copy only in the return envelope provided. Make your check or money order payable to: Hudson River - Black River Regulating District or HRBRRD.
- If you propose to make changes to the individual(s) to whom the access permit is issued, please call (518) 661-5535.
Please note that permit renewal applications must be postmarked by March 15, 2013. Note also that if renewed, your Access Permit will be in effect from the date of its renewal through March 15, 2014. If the District has not received your application postmarked by March 15, 2013 your former permit area may become available to another eligible applicant.
If you neglect to renew by March 15 and the area is still available, you may renew on or before April 15, by including an administrative fee of $20.00 in addition to the renewal fee. If you neglect to renew on or before April 15, the permit will expire; however, you may reapply for the same area, if available, upon payment of the renewal fee plus an administrative fee of $50.00. This policy was established by Resolution 93-29-6 of the Board of the Regulating District.
Please complete and return your renewal application promptly.
Sincerely,
John M. Hodgson, Sr.
Permit System Manager
March 9, 2012
REGULATING DISTRICT RESERVOIRS PREPARED FOR SPRING RUNOFF
MAYFIELD, NY and WATERTOWN, NY - The river regulating reservoirs operated by the Hudson River - Black River Regulating District have been, and are prepared to, receive runoff which will be produced by this spring’s rainfall and melting snow. Systematic releases of stored water have readied each reservoir to capture spring runoff, consistent with our mission to regulate the flow of the Hudson River and Black River for the purposes of flood protection and flow augmentation.
Winter-time drawdown of the state’s river regulating reservoirs has occurred on schedule and as planned. The Great Sacandaga Lake was lowered according to the Upper Hudson/Sacandaga River Offer of Settlement and reached an elevation of 748.94 feet on March 5, consistent with the Offer of Settlement elevation target curve. The Stillwater Reservoir was lowered to an elevation of 1665.72 feet by March 5, consistent with its operating plan.
September 9, 2011
GREAT SACANDAGA LAKE HANDLES HURRICANE IRENE
AND SUBSEQUENT TROPICAL EVENTS/REDUCES FLOODING ON THE HUDSON
MAYFIELD, NY– Conklingville Dam and Great Sacandaga Lake minimized the effects of heavy rainfall associated with the remnants of Hurricane Irene, preventing flooding on the Hudson River from Hadley to Fort Edward, and reducing the severity of flooding from Fort Edward to Albany.
The Great Sacandaga Lake watershed received approximately 5.5 inches of rain from Irene causing the reservoir to rise about 3 feet. Precipitation from the storm produced sharp rises in the Sacandaga and Hudson River. Inflow to the reservoir peaked at more than 40,000 cubic feet per second (cfs) during the afternoon on August 28 and produced an average of 20,000 cfs for the day.
Without the benefit of flood protection and storage capacity at Great Sacandaga Lake, the Hudson River would have exceeded flood stage at Fort Edward by more than 5 feet. By reducing the flow in the Hudson River by at least 20,000 cfs, the flood protection benefit provided by the reservoir reduced the flood stage at Waterford, Green Island, and Troy by nearly 2 feet.
The elevation of the Great Sacandaga Lake was lowered more aggressively, consistent with the Offer of Settlement operating rules, to an elevation of 762.6 feet by the morning of August 28 in anticipation of significant inflow. Increasing the release of water from the reservoir for about four days before the storm provided an additional 700,000,000 cubic feet of storage capacity.
Great Sacandaga Lake is poised to efficiently deal with current tropical rain events following Irene. The peak elevation of the reservoir resulting from the most current rainfall is estimated to be approximately 770 feet above sea level. Release of water from Great Sacandaga Lake will begin as soon as the flow rate of the upper Hudson River allows.
The Hudson River - Black River Regulating District is a State of New York public benefit corporation which provides river regulation, including flood protection and low flow augmentation, in the Hudson and Black River watersheds through the operation of water storage reservoirs, including the Great Sacandaga Lake, Indian Lake, Stillwater Reservoir and the Fulton Chain of Lakes.
May 9, 2011
CONKLINGVILLE DAM
MAYFIELD, NY- On Saturday, May 7, as a precautionary measure, the Hudson River – Black River Regulating District activated the Conklingville Dam Emergency Action Plan (EAP) in response to an unusual change in a measurement taken at one of the monitoring points within the dam. Beginning immediately and continuing around the clock, the Regulating District’s Engineering staff has conducted intensive, physical and visual inspections of conditions at the Conklingville Dam. The Regulating District has determined that the unusual change in measurement triggering the alert resulted from a data reading error. As a result, the emergency action plan has been deactivated.
May 8, 2011
CONKLINGVILLE DAM
MAYFIELD, NY-On Saturday, May 7, as a precautionary measure, the Hudson River – Black River Regulating District activated the Conklingville Dam Emergency Action Plan (EAP) in response to an unusual change in a measurement taken at one of the monitoring points within the dam.
Readings taken at the monitoring point require the measurement of the water table within the dam using electronic equipment designed to sense the presence of water. The surface elevation of the water within the dam is measured with a sensor that is lowered into a 1-inch diameter pipe which extends approximately 75 feet below the surface of the dam. Consistent with the Regulating District’s dam safety plan and its procedures for monitoring during high reservoir elevation events, the frequency of measurements was expanded to include weekend monitoring.
Saturday’s unusual readings lead engineering staff to prudently activate the EAP as a precautionary measure. Condition B of the EAP is intended to notify emergency responders of a potentially hazardous situation.
Since the activation of the EAP, Regulating District engineering staff have re-evaluated and thoroughly reviewed the monitoring point data and the data collection process used by field personnel during the past week. Regulating District officials have been in contact with their geotechnical engineer and dam safety engineers from the Federal Energy Regulatory Commission (FERC) to make a preliminary assessment of the situation. At this time engineers are focusing on the accuracy of the data and possible shifting of the monitoring equipment or reference point as the cause for the unusual change in measurement.
Regulating District engineers plan further consultation with federal dam safety officials and the project geotechnical engineer on Monday, May 9, to rule out any other possible cause for the unusual measurements. At that time, it is likely the emergency action plan will be deactivated.
May 8, 2011
MONITORING OF THE CONDITION OF CONKLINGVILLE DAM CONTINUES
MAYFIELD, NY-The Hudson River – Black River Regulating District continues to monitor the condition of the Conklingville Dam on an hourly basis as part of its response to the unusual change in the water pressure measured Saturday afternoon at one of the monitoring points within the dam.
The unusual pressure measurement prompted the Regulating District to activate the Conklingville Dam Emergency Action Plan (EAP) at approximately 8 p.m. yesterday as a precautionary measure.
Water pressure at the monitoring point appears to have stabilized and no additional changes in the condition of the Conklingville Dam have been observed.
Failure of the dam has not occurred and there appears to be no imminent threat of failure.
An update on the condition of the dam and the status of the emergency condition is planned and will be provided to local and state emergency management officials early Sunday afternoon.
Water continues to be discharged through outlet valves and the E. J. West hydroelectric facility at Conklingville Dam in response to the emergency condition.
Regulating District engineers will consult federal dam safety officials and the project geotechnical engineer on Monday, and develop a plan to investigate the unusual condition.
May 8, 2011
REGULATING DISTRICT ACTIVATES CONDITION B OF THE
CONKLINGVILLE DAM EMERGENCY ACTION PLAN
MAYFIELD, NY–The Hudson River – Black River Regulating District has activated the Conklingville Dam Emergency Action Plan in response to an unusual change in the water pressure within the dam at Conklingville, Town of Hadley, Saratoga County.
At 8:00 pm, this evening the Regulating District declared a “Condition B” emergency. A Condition B emergency means that a potentially hazardous situation is developing. Failure of the dam has not occurred, but the Regulating District is taking action to minimize the potential for dam failure.
Notification of the emergency condition has been given to emergency management agencies in Saratoga, Washington, and Warren County, the state emergency management office, dam safety agencies, and to emergency response personnel downstream of the Conklingville Dam.
The Regulating District has maximized the release of water from Great Sacandaga Lake in response to the emergency condition.
Regulating District staff will continue conducting hourly monitoring of the condition of the Conklingville Dam until the emergency condition is no longer necessary.
April 28, 2011
REGULATING DISTRICT RESERVOIRS STORE SIX TIMES
MORE WATER THAN IS RELEASED
MAYFIELD, NY – Precipitation received and forecast during the next several days, when combined with the last of the melting mountain snow, is producing expected increases in the reservoir elevations at the New York State reservoirs operated by the Hudson River-Black River Regulating District. While many of the Regulating District’s reservoirs are now at full capacity, the design of those impoundments ensures that only a small fraction of the water flowing into the reservoirs will get released over the dam. For example, even when water crests the spillway, only one sixth of the water flowing into Great Sacandaga Lake in the next few days will immediately flow over the Conklingville dam spillway down to the Sacandaga and Hudson Rivers. The rest is retained for release once the natural flow of the Hudson River returns to predetermined target elevations. While the torrent of water flowing over the Conklingville Dam makes for interesting photography, the volume released over the spillway is a fraction of the water typically released through the dam’s Dow valves and the adjacent E.J. West hydropower plant.
Winter-time drawdown of the state’s river regulating reservoirs occurred on schedule and as planned. The Great Sacandaga Lake was lowered according to the Upper Hudson/Sacandaga River Offer of Settlement and reached a minimum elevation of 749.07 feet on March 5, 2011 consistent with the Offer of Settlement elevation target curve. Since that date, above average steady rain and snow melt has brought the elevation of the Great Sacandaga Lake to nearly 773 feet. Weather and river forecasts by the National Weather Service (NWS) and the United States Geologic Service (USGS) yield a prediction of a peak elevation at Great Sacandaga Lake at 774.4 feet on Sunday May 1, 2011. This elevation will be an all-time high. Because natural flow of the Hudson River is already above flood stage, the Regulating District will continue to impound as much water as possible until the weather improves.
Once the weather does improve, the inflow into the Hudson River’s headwaters in the Adirondacks will decrease. At that time, the Regulating District will begin daily Reservoir releases to drawdown Great Sacandaga Lake in anticipation of continued spring and summer rains. Significant additional rainfall, which could be expected to cause the Great Sacandaga Lake’s elevation to rise, may require immediate release of water at Conklingville to the Sacandaga and Hudson Rivers at or near flood stage in order to prevent triggering larger volume releases designed to protect the impoundment itself. None-the-less, even should additional significant rainfall occur, the Reservoir’s remaining storage capacity and design ensure that the Reservoir will continue to mitigate the potential for widespread flooding by limiting releases at Conklingville to levels below the inflow to the Reservoir from the headwaters of the Sacandaga River.
April 21, 2011
REGULATING DISTRICT RESERVOIRS PREPARED FOR SPRING RUNOFF
MAYFIELD, NY and WATERTOWN, NY - The river regulating reservoirs operated by the Hudson River - Black River Regulating District have been, and are prepared to, receive runoff produced by recent rainfall and melting snow consistent with our mission to regulate the flow of the Hudson River and Black River for the purposes of flood protection and flow augmentation.
Precipitation received and forecast during the next several days, when combined with melting snow, is producing expected increases in reservoir elevations. In response to such increases, the Regulating District will be increasing the release at Stillwater later this afternoon from 600 cfs to 1000 cfs. The Beaver River Flow at Croghan will increase from approximately 1800 cfs to 2200 cfs. Similarly, the Regulating District will increase the release at Indian Lake from 400 cfs to over 750 cfs. Additional releases from the Regulating District's Conklingville Dam will commence early next week as outlined under the Offer of Settlement.
Winter-time drawdown of the state’s river regulating reservoirs has occurred on schedule and as planned. The Great Sacandaga Lake was lowered according to the Upper Hudson/Sacandaga River Offer of Settlement and reached a minimum elevation of 749.07 feet on March 5, consistent with the Offer of Settlement elevation target curve. The Stillwater Reservoir was lowered to an elevation of 1665.50 feet by March 5, consistent with its operating plan.
April 6, 2011
HUDSON RIVER - BLACK RIVER REGULATING DISTRICT
WINS DECISION IN 5 COUNTIES APPORTIONMENT LEGAL CHALLENGE
ALBANY, NY – The Saratoga Supreme Court dismissed a challenge to the Regulating District’s March 30, 2010 apportionment of costs. Supreme Court Justice Stephen Ferradino granted the Hudson River – Black River Regulating District’s motion for summary judgment dismissing the Article 78 Petition brought by Albany, Saratoga, Warren, Washington and Rensselaer Counties challenging the Regulating District’s methodology for spreading the cost to operate the District among those who benefit. The Court’s ruling restores the revenue source funding the Regulating District’s operation, including the obligation to pay school and real property taxes. The Regulating District’s Acting Executive Director, Michael Clark, had this to say about the decision: “We are pleased with the decision. I’d like to express the Board’s appreciation for the effort put forth by the Regulating District and DEC staff, as well as the excellent support provided by the Attorney General.”
March 11, 2011
REGULATING DISTRICT RESERVOIRS PREPARED FOR SPRING RUNOFF
MAYFIELD, NY and WATERTOWN, NY - The river regulating reservoirs operated by the Hudson River - Black River Regulating District have been, and are prepared to, receive runoff produced by recent rainfall and melting snow consistent with our mission to regulate the flow of the Hudson River and Black River for the purposes of flood protection and flow augmentation.
Precipitation received during the past 30 hours, when combined with melting snow, has produced small increases in reservoir elevations. Reservoir elevation increases of 1.4, 2.1, and 1.6 feet have occurred at Great Sacandaga Lake, Indian Lake, and Stillwater Reservoir, respectively, since March 5.
Winter-time drawdown of the state’s river regulating reservoirs has occurred on schedule and as planned through March 5. The Great Sacandaga Lake was lowered according to the Upper Hudson/Sacandaga River Offer of Settlement and reached a minimum elevation of 749.07 feet on March 5, consistent with the Offer of Settlement elevation target curve. The Stillwater Reservoir was lowered to an elevation of 1665.50 feet by March 5, consistent with its operating plan.
* * * * *
The Hudson River - Black River Regulating District reminds all recreational users of the Great Sacandaga Lake, Indian Lake, Stillwater, and Fulton Chain of Lakes reservoirs to use caution on or about the reservoir as the water elevation fluctuates and ice cover shifts. Changes in ice surfaces will occur as a result of increased inflow and water releases during the next month.
November 30, 2010
SIGNIFICANT RAINFALL PREDICTED ON RESERVOIR WATERSHEDS
MAYFIELD, NY and WATERTOWN, NY - Forecast rainfall over the next several days has the potential to produce significant runoff and an increase inflow to the Great Sacandaga Lake, Indian Lake, Stillwater, and Fulton Chain of Lakes Reservoirs. The National Weather Service (NWS) forecast indicates the potential for three or more inches of rainfall across both the Hudson River and Black River Watersheds by Thursday.
Runoff and increased inflow to the Great Sacandaga Lake could result in an increase in the reservoir water elevation of between 3 to 6 feet by December 8. Indian Lake Reservoir elevation could increase 2 to 4 feet during the next 8 days. Stillwater Reservoir water elevation could increase 2 to 3 feet. Actual increases in reservoir elevation will be dependent upon the actual rainfall, runoff, and inflow received by each reservoir, and the Regulating District’s need to store water to provide flood protection.
November 10, 2010
REGULATING DISTRICT REQUESTS ASSISTANCE
PAYING SCHOOL AND COUNTY TAX BILLS
MAYFIELD, NY – By Resolution adopted on November 9, 2010, the Hudson River – Black River Regulating District Board has asked the Governor, the NYS Senate and the NYS Assembly for assistance paying outstanding school and county tax obligations.
Pursuant to NY ECL §15-2115 the Regulating District is obligated to pay taxes to several school and county taxing jurisdictions in connection with the acquisition of state land for reservoir operations. Acting Executive Director Michael Clark said “The District’s inability to pay the school tax bill is the most visible part of a fiscal crisis brought on by a United States Court of Appeals decision. The court’s decision eliminated the state statutory authority to impose an assessment on the FERC licensed merchant hydropower companies lining the Hudson River between the Conklingville Dam and Troy. While the Regulating District is pursuing all available avenues to replace those revenues, including a concerted effort through the Federal Energy Regulatory Commission to have the hydropower companies pay their fair share and a state based re-apportionment of costs pursuant to the State Environmental Conservation Law, the lack of revenue makes it impossible for the Regulating District to meet the obligation to pay tax on the state lands under its control”.
Last May, the Regulating District laid off nearly a third of its staff in its on-going effort at cost containment. It has advanced legislative proposals for introduction at the state level placing the obligation to pay taxes on state land upon the state, and sought state statutory authorization to transfer funds between the Hudson and Black River areas. The District has advanced legislative proposals for introduction at the federal level seeking a change in the federal power act. That proposal would permit facilities such as the Regulating District which control costly impoundments, but not the electricity and revenue generating facilities associated with those impoundments, to collect the costs of such impoundments from the merchant hydropower companies benefitting there from. Despite these efforts, the Regulating District has insufficient funds available to pay the school and county taxes now due and owing. Therefore, the Board of the Hudson River-Black River Regulating District has requested that the state assume the obligation to pay real estate taxes imposed upon the Regulating District by virtue of the Environmental Conservation Law and the Real Property Tax Law or that it lend the Regulating District the funds to do so.
The Hudson River - Black River Regulating District is a State of New York public benefit corporation which provides river regulation, including flood protection and low flow augmentation, in the Hudson and Black River watersheds through the operation of water storage reservoirs, including the Great Sacandaga Lake, Indian Lake, Stillwater Reservoir and the Fulton Chain of Lakes.
October 1, 2010
STATE'S RESERVOIRS STORE HEAVY RAINFALL
MAYFIELD, NY and WATERTOWN, NY - Heavy rainfall which fell during the past twenty-four hours has significantly increased the inflow to the Great Sacandaga Lake and Indian Lake reservoirs in the Hudson River watershed and the Stillwater, Sixth Lake, and Old Forge Reservoir in the Black River watershed.
The Great Sacandaga Lake and Indian Lake Reservoir received 4.2 and 3.3 inches of rainfall, respectively, overnight, while the Black River area reservoirs received about 3.5 inches of rainfall. This substantial rainfall has produced sharp rises in river flow throughout each watershed. The unusually high flow of water into the reservoirs will cause continued increases in reservoir elevation during the next several days.
The elevation of the Great Sacandaga Lake is forecast to rise 3.0 feet to approximately 764.0 feet by Wednesday, October 6. Indian Lake Reservoir is anticipated to rise 3.8 feet to an elevation of approximately 1649.0 feet during the same period. Stillwater Reservoir is anticipated to rise 3.4 feet by October 7. Old Forge reservoir is forecast to rise to an elevation of 1707.7 feet by Monday, and Sixth Lake is estimated to rise to elevation 1786.8 feet by Sunday.
During the next week the Hudson River area reservoirs will store approximately 3.9 billion cubic feet, or 29,200,000,000 gallons of water, and reduce the peak flow in the Hudson River by more than 25,000 cubic feet per second (cfs). Stillwater Reservoir will store approximately 0.7 billion cubic feet, or 5,200,000,000 gallons of water over the next week and reduce peak flow in the Black River by approximately 4,000 cfs.
Operating in accordance with the Upper Hudson / Sacandaga River Offer of Settlement plan, the Great Sacandaga Lake reduced flood elevations along the Hudson River at Fort Edward by 1.5 feet and at Troy by 1.0 feet.
The Regulating District will maximize the release of water from each reservoir and lower reservoir elevations as quickly as possible and as natural river flow decreases.
The Hudson River - Black River Regulating District is a State of New York public benefit corporation which provides river regulation, including flood protection and low flow augmentation, in the Hudson and Black River watersheds through the operation of water storage reservoirs, including the Great Sacandaga Lake, Indian Lake, Stillwater Reservoir and the Fulton Chain of Lakes.
September 17, 2010
HUDSON RIVER - BLACK RIVER REGULATING DISTRICT
APPROVES HUDSON RIVER AREA ASSESSMENT
ALBANY, NY – At the September 14, 2010 Board Meeting of the Hudson River-Black River Regulating District in Saratoga Springs the Board adopted the Hudson River Area 2010-2011 fiscal year Assessment. This Assessment is based on the Apportionment of costs adopted by the Board at its March 30, 2010 meeting. The March 30, 2010 Apportionment previously shifted certain costs from hydropower companies along the Hudson and Sacandaga Rivers to Albany, Rensselaer, Saratoga, Warren and Washington Counties, as these counties derive a flood benefit from the Conklingville Dam on Great Sacandaga Lake, maintained and operated by the Regulating District. Prior to acting on the March 30th Apportionment, the Board conducted an Apportionment Grievance Hearing at which the affected Counties and others interested in or aggrieved by the Apportionment sought modifications to the Apportionment. The NYS Department of Environmental Conservation (DEC) approved the Apportionment by letter dated April 2, 2010. Based on the Apportionment the Assessments for the five counties is as follows:
ID No |
County |
Proportion of Total Cost |
Annual Expense |
|
|
|
Year Beginning July 1, 2010 |
1 |
Albany |
0.392563628 |
$2,121,201.08 |
2 |
Rensselaer |
0.215951341 |
$1,166,884.00 |
3 |
Saratoga |
0.285389349 |
$1,542,089.36 |
4 |
Washington |
0.039353465 |
$0,212,644.80 |
5 |
Warren |
0.066742217 |
$0,360,638.77 |
|
|
|
|
|
Totals |
1.00000000 |
$5,403,458.00 |
On November 28, 2008, the nation’s second highest court, the United States Court of Appeals in the District of Columbia, issued a decision against the Federal Energy Regulatory Commission (FERC) which impacts the Regulating District’s authority to assess some downstream beneficiaries. The result has been a revenue shortfall, approaching $4.0 million of the Regulating District’s Hudson River Area $5.4 million budget, making it impossible for the Regulating District to pay the annual $2.4 million in school and property taxes as required by NYS statute. As a result, the Regulating District had to shift a significant portion of its $5.4 million Hudson River Area costs from the hydropower companies to the downstream counties with flood-protected properties.
In 2000, a comprehensive “Offer of Settlement” for the operation of Great Sacandaga Lake (GSL) and the EJ West hydroelectric plant was negotiated among and signed by 29 entities, including state and federal agencies, municipalities, non-governmental organizations and hydroelectric project operators in the Hudson River basin. FERC approved the settlement in 2002. Although Section 8.4 of the settlement states that “The Signatories to this settlement offer understand the assessment of charges is done by the Board of the Regulating District in a process defined within Article 15, Title 21 of the New York State Environmental Conservation Law”, the United States Court of Appeals determined that the Federal Power Act (FPA) preempts the Regulating District’s use of NYS law. As a result, the Regulating District can no longer collect assessments from the FERC-licensed hydropower plants to cover operating expenses, including school and property taxes that the Regulating District is required to pay by NYS statute. Prior to the court’s decision, these hydropower plants paid approximately 82% of the Hudson River Area assessment.
In February 2009, the Regulating District petitioned FERC to convene settlement proceedings and to establish Interim Headwater Benefits charges, but FERC did not establish interim charges. In May 2009, FERC appointed a Settlement Judge and scheduled settlement conferences; however, in July 2009, the Judge declared an impasse. FERC ordered Oak Ridge National Laboratory to conduct a Headwater Benefit Determination to quantify the benefit received by the hydroelectric projects downstream from the Conklingville Dam and Great Sacandaga Lake, so the Regulating District can assess them via Section 10(f) of the Federal Power Act. FERC expects this study could take more than a year and the Regulating District is not allowed to assess these hydros until the FERC study is completed.
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