As many of you know, on December 23, 2016, the Woodland Pulp LLC, in a letter to FERC (Federal Energy Regulatory Commission), submitted an application for surrender of its minor license to operate the Forest City dam (FERC Project No.2660). Woodland Pulp wrote, we do “not propose to remove the dam as part of the surrender, and such removal is not necessary or appropriate.” Rather, Woodland proposes to “remove the [two US] gates at the dam down to the bulkhead.”
Removing the dam gates is tantamount to a complete dam removal and would result in permanent lowering of the water level of East Grand Lake by six to eight feet, a lowering of North Lake, and loss of the ability to manage lake levels and stream flow volumes. Potential impacts on the lakes could be widespread affecting biological life, aesthetic concerns, commerce, recreational opportunities, property values and a changed landscape in terms of conserved lands, to name just a few.
In a statement released March 7, 2017, the Woodie Wheaton Land Trust stated, “the potential outcomes from surrender and abandonment of that facility are unacceptable. A reasonable long-term solution must be found.” Public response is mounting, triggered largely by Chiputneticook Lakes International Conservancy (CLIC) President David Townsend, whose critical overview (February 19th) of Woodland’s application lucidly presents the core issues. The first public organizing meeting in opposition to the surrender application took place on April 1st in Fosterville, NB. For reasons unknown, Woodland’s application distribution list for its December 23, 2016 application did not include a single Canadian entity or person.
This is not Woodland’s first effort to get out from under its Forest City FERC license. Over the years, they have unsuccessfully argued that the Forest City dam should not require a license at all. Today, Woodland “has concluded that it is not economic for the company to continue to operate the project.” Much of this argument’s underpinning is the fact that the incremental power attributed to the Forest City dam, at its hydro facilities in Woodland, is negligible and expensive. But it is the prospect of future, mandated fish way construction as well as requirements related to the development and execution of Historic Properties Management Plans, related to the Forest City dam, that they believe will make the license prohibitive to hold. Despite the complexities of FERC licensing and numerous contentions with it over the years, Woodland has continued to operate the Forest City dam in a cooperative and responsible manner.
The WWLT has joined and agreed to support other organizations and stakeholders in pursuing dialogue to influence regulatory decisions that lead to acceptable solutions for all parties. In a worst case scenario, should FERC accept Woodland’s wish to surrender its license, strict conditions must be stipulated that protect all interested parties and the beautiful lakes and river environment of this region. Before the gates of the Forest City dam are open wide, careful evaluation of the dam’s present value and serious measuring of the effects of its loss … on public safety, water quality, fish and other species, recreation, commerce and cultural values … must be made.