Jason
I have been involved in one TLP involving a project similar to the one Dave
provided information on, with the primary difference being the water source was
surface water. The fishery and hydrology impacts where straightforward and more
importantly the applicant operated with integrity and open communication like
Gerrit described. I also knew that I could address the hydrology impacts
through the water right process as my agency had instream flow rights on the
source stream. TLP worked well in that case.
Presently I am working on a re-licensing where the project owner has proposed
TLP. We tried to push back on TLP because the owner is making it clear they do
not believe fisheries mitigation is any longer necessary. We were unsuccessful
in attempting to oppose TLP for internal reasons (that is what happens when the
project owner is a sister agency that has the Governor’s ear). We see TLP as a
way of lessening FERC involvement thus decreasing the likelihood that fisheries
mitigation will be required as part of the new licensing. During the original
licensing FERC pushed hard on the fisheries issues which was not lost on the
owner in requesting TLP this time around.
Andy
________________________________________
From: ifc_mail-bounce@xxxxxxxxxxxxx <ifc_mail-bounce@xxxxxxxxxxxxx> on behalf
of Jason Persinger <Jason.Persinger@xxxxxxxxxx>
Sent: Wednesday, March 27, 2019 7:27 AM
To: IFC_mail@xxxxxxxxxxxxx
Subject: IFC_mail: FERC Relicensing question
Hey everyone.
We have a FERC Relicensing that is just getting starting and yesterday the
Licensee indicated there preference for using the traditional process instead
of the integrated process. I am hoping some of you that have been through
these efforts before can help inlighten me on the differences between the two
processes. So the agency can better determine whether or not we are ok with
the traditional process in this case or if we should push for the intergrated
process.. Any help would be appreciated. I can provide more specific details
if needed, but at this stage was really just wanting to improve my
understanding of the pro's and con's of each process.
Thanks
Jason
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