Honorable Kimberly D. Bose,
Secretary Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426
VIA Electronic Filing
Re: Draft Environmental Assessment for Crown Hydro Docket No. P-11175-025
Dear Ms. Bose,
Thank you for the opportunity to comment on the Draft Environmental Assessment (“EA”) for the Crown Hydro, LLC Crown Mill Hydroelectric Project (“Crown Hydro”).
We are writing on behalf of the 50,000 members and supporters of the Sierra Club North Star Chapter. The Sierra Club objects to the efforts of Crown Hydro, LLP. (“Crown”) to acquire rights to use land in the Central Mississippi Riverfront Regional Park (“Regional Park”) in Minneapolis to construct and operate a hydroelectric plant. The Sierra Club has long advocated for city planning that combines dense, sustainable, land use development with parks and open space, particularly development that is bicycle, pedestrian and transit friendly. Redevelopment of the Minneapolis central riverfront has proved an immensely successful example of exactly this type of development. The driving force behind its success is the riverfront park centered on Saint Anthony Falls.
The Sierra Club is a strong proponent of statutory environmental review. Rigorous environmental review is standard for this area in Minneapolis. It develops information that is essential for decision makers to consider when making decisions that impact our environment. After analyzing the EA for the Crown Hydro, we have the following serious concerns:
- Licensing Crown Hydro is a major federal action that could have serious adverse effects on the landmark Saint Anthony Falls. This project has been an extremely controversial for decades and given this controversy, the issues surrounding Crown Hydro need to be given the scrutiny that a full EIS would afford. A full EIS would insure the community, the City of Minneapolis, and the Federal Government that all issues were given the highest level of review and alternatives considered before a decision on a license was made.
- The EA fails to address the cumulative impact of all the hydro projects on the flow of water over the Falls. Crown Hydro is the tipping point project that has the capacity to dewater the Falls. The impacts from reduced flow on recreation, parklands and other social and economic aspects need to be studied and quantified.
- The EA fails to understand the recreation issues surrounding the project, and if they are mentioned the EA fails to seriously analyze these issues.
- Alternatives were not considered. Given the circumstances, the “No Action” option needs to be seriously considered.
The EA fails to adequately consider the impact on aesthetic flow of water appropriation by Crown on the vibrancy of this area. The EA states that any minimum flow requirements would not apply “during the winter months (November 15 through March 15) and during nighttime hours (dusk till dawn) in all months.” This area, however, is active all year round, with visitors enjoying views of the Falls during the day and night. Without the centerpiece of the regional park, Saint Anthony Falls, the future growth of this area may stall. In addition, the Falls encourages people to use bikes and their feet to travel rather than cars. The EA does not adequately consider the impact of removing or reducing this major attraction.
In addition to threatening the flow over the Falls, the physical presence of the Crown Hydro facility would have a significant negative impact on recreational resources. The EA fails to address how the structure would restrict access from Downtown, Water Works and the Stone Arch Bridge to the Lock and Dam building, thereby subverting key elements of the Minneapolis Park and Recreation Board (“MPRB”) Master Plan calling for improved bicycle and pedestrian connections to the riverfront and a new visitor center at the Lock and Dam with spectacular views of the Falls. Friends of the Lock and Dam have put forward a proposal that could turn the Master Plan concept of a visitor center into a reality with a transformative design to repurpose the lock and dam into a visitor center. This bold vision would be precluded by the Crown Hydro project.
Trail connections around the Stone Arch Bridge on the west side of the river are identified as a Key Focus Area in a Major Gateway of the Regional Park in the Regional Park Master Plan (p. 7-9). The EA fails to adequately address this issue and ignores how the project will impede, frustrate or otherwise preclude year round 24/7 trail usage after construction of the project. Further, the project will preclude the use of the intake and outlet areas near the lock and dam as a kayak/canoe landing and portage location, another significant goal in the Regional Park Master Plan (p. 7-7).
The Crown Hydro project would be built on public land owned by the U.S. Army Corps of Engineers which is subject to a perpetual easement held by the MPRB for park purposes, including bicycle and pedestrian facilities. MPRB has been a consistent project opponent and previously denied Crown access to Park property. Although no details are presented in the EA, this project appears to require access to public land used for park purposes.
The Sierra Club is a strong supporter of green and alternative energy. However, the energy that would be produced by Crown is very expensive compared to other green energy sources. The Federal Power Act requires equal consideration of power production, energy conservation, the protection of fish and wildlife, the protection of recreational opportunities, and the preservation of other aspects of environmental quality.
To properly balance the small amount of expensive energy that would be generated against the major negative impacts on the central riverfront park and continued economic growth of this dense pedestrian, bike and transit friendly area, Sierra Club requests preparation of an Environmental Impact Statement.
Sierra Club North Star Chapter