comurrtees Ranking Mitty Member veaton THE ASSEMBLY STATE OF NEW YORK Aorta ars Og use Corporations, Autores ane Commissions ‘rvrormerial Conservation ALBANY PETER. LOPEZ MEMEER Ascambiyan, 2" AD. Black, Pueno Reon, Hisar and ‘elon Lepr Causa, Abary, Counble, Deawae, usta Ricanspane Tan Foes Greene, Oisega, Sehuhave are Fann, Food and Nuvo Potey Tat Force User Counter March 20, 2017 Mr. Gil C. Quiniones President and Chief Executive Officer New York Power Authority 123 Main Street White Plains, NY 10601 RE: Flood Mitigation Potential of the Schoharie Reservoir and the Blenheim/Gilboa Pumped Storage Project # 2685 Dear Mr. Quiniones: This letter is respectfully provided to you in regards to efforts related to flood mitigation of the Schoharie Reservoir and Blenheim/Gilboa Pumped Storage Project (BIG). On April 8, 2015 my office delivered a letter fo you outining the issues critical to the safety ofthe residents in the Schoharie Valley and other downstream communities and requested the establishment of protocols for dam operation in times of anticipated flooding. The letter, which was signed by more than 40 elected officials from federal, stale, and local municipalities, requested that *..the Schoharie Reservoir and the Bienheim/Gilboa dam be used preemptively for void creation to the fullest possible extent in any given predicted high-flow event’ (copy attached). On May 21, 2015 your office responded acknowledging the significance of this concem and highighted instances in which the B/G facility was successfully utiized to reduce the impacts of flooding on downstream communities (copy attached). In the same letter, you noted that NYPA had *...begun the federal reicensing process for the B/G faclity and is conducting 2 downstream flooding study that wil specifically model various scenarios during high-flow events and evaluate various upper and lower reservoir operation scenarios as well The results ofthis study will provide critical data to inform any decision on potential flood mitigation measures,” My office and others were understandably encouraged by the tenor of your reply and by the proactive response of the City of New York, which modified its operations in order to offer additional protections to downstream properly owners and residents during flood events. ALBANY OFFICE: Roo 402, Leaisative Orce Buldrg, Abany. New Yor 248” 513-455.5969, FAX S16-45. 5068 DISTRICT OFFICES: 45 Fe Mie Woods Rose Sule 8 Cal, New York 12“ ot6 940 1271, Pax Sr o.b00229 “13 Pan Place, Sute 6, Serchane, Now York i267 "518208 7250 Phone & PoxFlood Mitigation Potential of the Schoharie Reservoir and the Blenheim/Gilboa Pumped Storage Project March 20, 2017 Page 2 With that said, the downstream communities have become alarmed and frustrated by the recent actions of NYPA's staff that directly contradict the intentions stated in the May 2015 correspondence. These contradictions include: 1) On December 1, 2016, Mr. Robert Daly, Licensing Manager of the Blenheim-Gilboa Pumped Storage Project, fled a request with FERC requesting a waiver of the requirement that Exhibit F contain a supporting design report (SOR) for the Project (copy attached) Simply stated, Mr. Daly initiated a request asking FERC to keep an important flood impact report prepared by NYPA from being considered during the relicensing effort. As you know, this request ‘was offcally opposed by my office (copy attached) and the Schoharie County's Dam Concemed Citizens group through correspondence submitted to FERC. NYPA’s request was ultimately rejected by FERC on March 8, 2017 (copy attached). 2) Local confusion and constemation with NYPA's inconsistent behavior intensitied on Thursday, March 2, 2017 during their pubic information session held at Howe Cavems where the recently released flood analysis was presented to the Schoharie County Community, Mr. Daly punctuated his opening remarks by publicly stating that NYPA did not wish to discuss flooding as part of the pending licensing application before FERC. Given the magnitude of the devastation caused by Hurricane Irene and Tropical Storm Lee in ‘Schoharie Valley and the further impacts of such flooding on the Mohawk and Hudson River Corridors, | find Mr. Daly’s statement offensive and in stark contrast with NYPA'Ss stated intention of working “...closely with neighbors, the DEP and the emergency management community to ensure suitable response plans are in place and that key personnel receive frequent proper training." (See NYPA May 21, 2015 correspondence). Prior to Tropical Storm Irene and Hurricane Lee, NYPA's B/G informal response to flood mitigation could be effectively summarized as "We do electric power storage, not flood contro), reinforced by the assertion that flood control was not part of NYPA's operational considerations under FERC’s licensing. Such a response is no longer acceptable given the near collapse of both the New York City owned Gilboa Dam and the 8/G Dam uring storms Irene and Lee. Dam fallures such as those in Nevada and California, which have threatened the safety of human life as well as the social and economic well being of the affected communities, have ony served to reinforce this assertion NYPA is presently requesting a 50-year license renewal by FERC. Part of this process should include working in partnership with FERC and the downstream communities to assess B/G's operational and structural capacity to withstand future flood events and assist with flood mitigation. ALBANY OF bistalcT OF oom 402, Legilive Ofc Buin, Atany, New York 12268 Si8485-5269, FAX 513-456-5856 ‘4 Five ble loss Rood, Sute 8, Cas, New York 12404" Si6649-1971, PAK 618.948.0028 'Patk Pace, Suiteb, Schoharie, New Yore 12157 "8205-7260 Prone & FaxFlood Mitigation Potential of the Schoharie Reservoir and the Blenheim/Gilboa Pumped Storage Project March 20, 2017 Page 3 {tis critically important for NYPA and FERC to recognize that the Blenheim/Gilboa pumped Storage Project was designed al a time when the annual mean precipitation for its catchment area was 16 % less than at Present, as measured at the Albany Airport from 1970 - 2005 by the National Weather Service, Further, a recent study conducted by the Northeast Regional Climate Center at Comell University, projects that site ‘specific precipitation for the Northern Catskills and B/G catchment will increase by a > 20% figure between 2010 and 2039, Specifically for reasons of public safety, the people, businesses, governments and frst responding agencies located down stream of B/G in the Schoharie Creek corridor, lower Mohawk Valley and Hudson Valley (Montgomery, Schenectady and Albany Counties) are entiled to know wiat the Inflow Design Flood is for Project # 2685. Unwilingness to disclose the design report by NYPA ard its stated intent to shield discussion of flooding andlor flood mitigation, has raised doubt and suspicion that the release works at B/G are not capable of safely passing a Probable Maximum Precipitation induced flood, resulting in an over topping of the earthen dam impounding the lower reservoir at BIG. tis critical for NYPA to take the necessary measures to ensure the safety of thousands of residents living in the Schoharie Valley and surrounding regions who would be affected by a dam failure, including the City of Amsterdam in Montgomery County and the City of Schenectady in Schenectady County. | strongly urge NYPA to take immediate action to ensure the safety of the general public and provide the folowing: * Disclose Inflow Design Flood estimates and the methodologies used to obtain the same. + Reconcile and/or explain the 40% disparity between the NYPA PMF and that of the NYCDEP at the ‘Schoharie Reservoir 5 miles upstream of B/G; recognizing the use ofthe site specific method to justify the difference is not responsible, and that the difference in PMF using the site speciffc method versus using the non-site specific method is too large to ignore, [tis my understanding that NYPA conducted its own study using the non-specific method and arrived al number much closer to the NYCDEP number. Many believe NYPA is using the site method to make the PMF calculation “tthe existing spillway at BIG, thus avoiding any potential capital expense required to harden the facilty against future flood events. ‘+ Institutionalize operational and structural changes as well as implement a coordinated program of flood mitigation with other regional stakeholders that will include "Pumping Up" fo attenuate out flow from BIG. By establishing a "Pump Up* protocol during a flood and pre-empively creating @ void in both the upper and lower reservoirs, B/G woul reduce its discharge by up to 10,000cis for c. 10 hours. This flood mitigation practice, i initiated, would be of mutual benefit to NYPA and communities, downstream of their operations during time of flood ALBANY OFFICE: Room 402. Legis Ofice Bullrg, Altar, New Yor, 12248 * 516-455-5969, FAX 516-455 595 DISTRICT OFFICES. 45 Fhe Mie Woo Rose, Suto Casi, New Yor 12614 "516.962-7971, FAX STB 969-0028 “13 PancPace, Sate 6, Senohane, Now York :2167 "510.208-7260 Phone & anFlood Mitigation Potential of the Schoharie Reservoir and the Blenheim/Gilboa Pumped Storage Project March 20, 2017 Page 4 ‘Thank you for your prompt attention to this serious concem. It is time to collaboratively address this critical ‘ssue and ensure the safety of our people. My office looks forward to continued communication with NYPA and FERC to seek the best possible solution, just as it continues to work with other federal, state and local stakeholders to find ways to reduce the devastating impacts we have previously experienced due to natural disasters; events that will undoubtedly occur in the future. Respectfully, . fae) Peter D. Lopez. Assemblyman, 102nd AD Enclosures NY Governor Andrew Cuomo US Senztor Charles Schumer US Senator Kirsten Glliorand US Congressman John Faso, 18 CD US Congressman Paul Tonko, 20" CD NY Senator George Amedore, 6th SO CCrstopher Tague, Supervisor, Town of Schohatis Charies Johnston, Nayor, Vilage of Esperance Matthew Avitabile, Mayor, Vilage of lideleburgh John Borst, Mayor, Village of Schohevie Anthony Desmond, Shertf Michael Hartel, Director, Offce of Emergency NY Senator James Seward, 51% SD Services NY Assemblyman John McDonald Il, 108th AD + Georgia Van Dyke, Executive Director, Chamber of NY Assemblywoman Paticia Fahy, 10h AD Commerce NY Assemblyman Angelo Santabarbera, 111% AD NY Assembyman Pi! Sto, 1146 AD Montgomery County Ms, Kimberly Bose, Secretary, FERC + Mathew Ossenfot, County Execute + Roy Dimond, Chairman of he Legislatire Schoharie County + Michael Vile, Mayor, City of Amsterdam ‘+ Eari Van Wormer Il, Chainan, Board of Supervisors + Steve Wison, County Administrator Schenectady County + Shety Largeteau Cetk, Board of Supervisors + Kathleen Rooney, County Manager + Indica Jayoox, County Clerk + Anthony Jasenski, Chal, County Legislture + Wiliam Chery, Treesurer + Gary MoCarthy, Mayor, City of Schenectady + Shawn Smith, Supervisor, Town of Blenheim + Philip Skowe, Jr, Supervisor, Town of Fullon Albany County + Anthony Ven Giad, Supenisor, Town of Giboa + Daniel WeCoy, County Executive + Gerald Pete Coppaio, Sr, ‘Supervisor, Town of + Sean Werd, Chairmen ofthe Legislature WMdclerburgh + Katty Sheehan, Mayor, Cy of Albany ALBANY OFFICE: Reom 402 LegisiireOice Bulcng, Albany, New Yok 12248 518-455-5089, FAX S18-485. 8058 DISTRICT OFFICES: 45 Five Mie ioods Rose, Sut 8 Catal New Yar tana “st a-e4e-e7%, PAN E18 9489209 "19 Patk Pate, Sue, S2hahare, Now vax 12167 “8206-7260 Prone & FaxChris Gibson Pete Lopez James L. Seward 19" Congressional District 102" Assembly District 51" Senate District Honorable Emily Loyd Commissioner NYC DEP 59-17 Junction Blvd Flushing, NY 11373 Gil Quiniones President & Chief Executive Officer New York Power Authority 123 Main Street, 10-8 White Plains, N.Y, 10601-3170 Re: Flood Mitigation Potential of the Schoharie Reservoir and she Blenheim/Gilboa Pumped Storage Project April 8, 2015 Dear Commissioner Lloyd and President Quiniones: This letter is respectfully provided to address an issue of critical concern to Schoharie County and the collective communities downstream of the Schoharie Reservoir and the Bienheim/Gilboa Pumped Storage Project, As you know, the storm events of 2011 created unprecedented devastation in the Northern Catskill, rendering thousands homeless, destroying roads and bridges, crippling schools and ether public institutions, while threatening the wellbeing of whole communities. At the peak of the event in Gilboa and Blenheim, clase to 30 billion gallons of water was in storage between the two dams, and the flow of the Schoharie Creek crested some & feetover the spillway of the Gilboa Dam at a rate of some 135,000 cubic feet per second ~a rate roughly equivalent to Niagara Falls. During this event, the City of New York declared a “Class 8” alert, notifying the Schoharie Valley community of the potential failure of the Gilboa Dam and consequently the Power Authority Dam. Collapse of these structures would have released a tidal wave of destruction through the whole valley as well as impacted the Mohawk River Valley, including the cities of Amsterdam, Schenectady and even Albany. While an extreme, this event and other lesser events which have impacted the Valley, have called into question the use of the dams for Possible flood control purposes. Research and climate studias predict similar, devastating events will occur in our near future. it’s not 3 question of "if", but rather, “when”. We must ‘therefore address the potential use of these dams as an immediate priority in order to protect life and property. While neither the Schoharie Reservoir/Gilboa Dam (owned and operated by the NYC- DEP) nor the Blenheim/Gilboa Pumped Storage Project (owned and operated by the NYPA) were designed with the intention of being used for flood control, itis in the best interest of the Public if these structures can be used for this purpose to their maximum possible capability without impeding their prime objective of water or electrical supply, respectively. These twe dams on the Schoharie Creek, and their respective reservoirs, offer substantial flood mitigation to the valley downstream of their infrastructures, if the measures as discussed herein are taken prior to a major rain/snowmelt or tropical storm event. Void creation in the Schoharie Reservoir and lower and upper reservoirs of Blenheim/Gilbos has the potential to delay or attenuate excessive discharge events downstream of their locations along the river. Precedent for preemptive void creation in these reservoirs was set in the days preceding the landfall of Hurricane Sandy in October 29", 2012. On October 26%, 2012, Governor Andrew M. Cuomo declared a State of Emergency in New York in preparation for the potential impact of Hurricane Sandy; a copy of which accompanies this letter. Asa part of this declaration, the siphons at the Gilboa Dam were started to draw down the water in the Schoharie Reservoir and voids were created in both the upper and lower reservoirs at Blenheim/Gilboa. Creation of void in both the upper and lower reservoir of the Blenheim/Gillboa pumped Storage project had the additional ability to attenuate discharge along the Schoharie River by Pumping water up hill during high-flow events. Water diverted up hill to the upper reservoir at Blenheim/Gilbos has the effect of sequestering weter from the main stream fora time, thereby recucing the rate of water flowing through the system at that point. This process was initiated uring the flood of January 18/19", 1996, during which water wes pumped up hill ata rate inexcess of 10,000cfs for an undetermined period of time. Such ad hoc efforts should be lauded 8s they offer substantial flood mitigation to the valley downstream of the dams. Further documentation of the use of preemptively created voids at these reservoirs can be found in the attached documents. The time has arrived for the development of an established protocol for dam operation in times of anticipated flooding along the Schoharie River. The planned, cooperative and coordinated use of the reservoirs along the Schoharie River for flood mitigation is an issue of importance to the public and the innovative use of existing infrastructure, for purposes beyond their original design, should be encouraged. We are not asking either the NYC-DEP or the NYPA to in any way exercise flood mitigation at the expense of their respective primary goals of water supply or elactrical generation. Rather, we are requesting that the two existing dams and thelr release works be used preemptively for void creation to the fullest possible extent in any given predicted high-flow event. This is not an unreasonable request, and merits a serious response from both parties. It is the intention of this coalition to pursue these goals to a successful conclusion and hope to work with both the NYC-DEP and the NYPA to achieve the maximum benefit of these structures to the public at large. All of us have learned much from the recent storm events, and recognize that all of our collective efforts are need to protect life and property in the future. We have every confidence in your leadership and look forward to a productive response to, and resolution of, this serious challenge. See Attached Signatures, Enclosures Cc, Federal Energy Regulatory Commission Governor Andrew M. CuomoChris Gibson Poised Seward Member of Congress (NY-19) enator, Sst S.D. District Peter D. Lopez Patricia Fa Assemblyman, 102 District Assemblywoman, 109" District Cy Gn£ ifford Crouch Assemblyman, 122™ District Claudia Tenney 7 Assemblywoman, 101“ District Qa rye Jdhn T. McDonald It Assemblyman, 108" District Tt. Matthew Ossénfort Montgomery County ExecutiveFlood Mitigation Letter to DEP/NYPA. Signatures ee Luthar. F herman ‘ Anthond F. DEsmars | Dannele E VAVBR, PE Sehohavre Lovaty Sheri Pl Cowmssivtn fete ltl Tansee Fo Falsaasite © deck Fim Gf SHARED Aegllary Sop oce Daniel p. Mccoy aye Albeny County Executive ee Mina Lilla __ Siete Wek Scented ivaey Mame Asnupind Ieee hs Q. Vel Welham A, Federsce Sepewiser, lira of Gnesusde Bon eteg teak ree Tickk . Le KSA LEMAR, PETER Aichats Sch ohap ig Cousry son fwarte f SOustvAriog Disreier STEAM Program MaAVAsee ee P ‘ : Shia tlem— sarap See County Administrator Sehohin’ Coun y Sass dware- eeeene coanty, gouservaring Oarrier mavAcen : Seeeeaeeeeeaae Kevin Lewis Charan, Greene County LegislatureFlood Mitigation Letter to DEP/NYPA Signatures : 122 banger RO Mur £ (anelak M100 BURGH,N Af. 1222 Dera 8 RrraeraRe TES Hct Prreten rows, Ob Ltt Hedlebaggh AY 1212 2 dahn P Fetiz zi yoo Stoke RKITQ” Nha fey YAR Mop Le Mh 1218-5 Btracd i Larger 4 Loreke psc tiff ea A a a oe pal burel Wo 2sae Claude F Cows Bz (feb. /233 Seuree Hollow AS Bren "Crod bella dest Fu Toy PY 2144 a 152 Rossman Valley Dd. WAT FuLtow WY 12) 9.5% : : Mba Lei iges fet Dhue: Maecenas Pitegy — Sued taal ly 1207,Flood Mitigation Letter to DEP/NYPA Signatures deste ple Beet E1y Tan Sted fa CHBISINA SwY PERE SLEMHEIN LoMé TERM CMa et REM ERY coumiree i an Carclhe Rasa Blonhkavn sone Coptnanrty, Kean yor QM 1 f (iret an OB (ER HS RLeditein Lees TER! formuact Frecovang Cmmittee, eB. Bi COLES CE Pawnee % de Blenhew aca Tarren mate HOS Resove vey es Melissa l. Graham Blea Nein Long Term Community Recovers Committee yok Uno RE Cake Ong EE + Fee ee Gastar Dahaar. “Barbecs Wehne= [bot WOsen flentein Long Tom. Coe Waidasr vee Wilsow Blewretin resides pea Wehnem Blenherm mm mani + Re Lata 2 Ola’ Baeece a. Orsi Biewhesmn Teh, son: He. Dew CHA a - BL7CBSFlood Mitigation Letter to DEP/NYPA. Signatures - Phe WO fn hehnel J Hawrzel Colleen 1. Feit “Director OF FICe.OF . Guneg aver Seewces Every sy ecteaee eee Schohasie. Qunty Schohanin. County GES ETE a Destvae, Day Comemna 2 C2: bob pute, avd tl af StS, Or Be, Sethe ace! ab yp210? Marearer Mer © Deeury HayoR Nitines OF” 7 OI Sinton) SER AS AH Ylor Solo RQ tigapel chan bn N.OdFlood Mitigation Letter to DEP/NYPA. Signatures T2145 “pe Curses Eugene hile Hanld Vraman Sehaharie Siemmit Picket eipe, Sarnes Bz cin middle barg (ichmeaduille. dey & Oued Sit life hd Carry Bradt Wilia Sebeo Fo. > Fe Me Sandra Man Ko Sharan Len Van. Worrnev x Earl Vanwornmer Espera nee, (hh Mili. Pe thi lla te Srey Brome Leo the kiliste i Cables ileFlood Mitigation Leiter to DEP/NYPA Signatures Heated R Bobhlrar —Lauitet Dam Cornet Cty) howar dar. bactralomes © gai l-com POBeXZIO Midllebagh NY Wiar~a UA lehns Rradmon@ Hly wl Wika tah bly Ph Srcectary Bon Kee (ye sho Ex), hen PO Bantis NA Bon Aehund) Hep 1x2 Anttalye Dest Sh, BLixntim AY /207)Flood Mitigation Letter to'DEP/NYPA Signatures WM, Lead Bekah W. Goodrek fe W. faducka Co-Chair, Nec Uork. Csi Comnunites BelonSeittion Frege OV Dhe GeorNin F. Van Dede Cos eMate parse = SOL i ease eertye A, Von Dy re co chair, NY Risin Co ramualiy RB esnees oonFlood Mitigation Letter to DEP/NYPA Signatures Dawit Pl Daniel P. MeCoy Albany County ExecutiveSEWYORK | NY Power suieor a | Authority ANDREW M. CUOMO JOHN R. KOELMEL SILC. quINIONEs Governor Chatman President and Chief Executive Offcor May 21, 2015 Assemblyman Peter D, Lopez New York State Legislature 113 Park Place, Suite 6 Schoharie, NY 12157 p. AK, Dear Assemblynrén Lopez, ur local communities very seriously, ! NYPA recognizes the importance of flood mitigation and is interested in coordinating a response with the DEP, the emergency management community and local leaders. it is of it ‘measures. This study will be available to the pubiic once completed pe, Schoharie Valley is a beautiful region to work, live and visit. NYPA wil continué to work closely with neighbors, the perecand the emergency management community to ensure that suitable response plore re place and that key Personnel receive frequent, proper traning vel caret’ Geclcated staff working to ensure open lines of communication Between NYPA, our frends and our Qolleagues. Please feel free to let your constituents know to reach out to our Community Relations, Manager Mario Roetfaro with any questions, concems, of comments, Sincerely, $8 ¢. Dorman : Git Quinones Ce: Senator James Seward Congressman Chris Gibson 123 Main Strect Whee Piains, NY 10801 | 914-681-8621 | wawaypagovNEWYORK | NY Power SIATEOR ert | Authority ANDREW M. CUOMO JOHN R, KOELMEL Governor Chairman GIL ¢. QUINIONES, President and Chief Execute Oticar VIA Electronic Filing December 1, 2016 Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, 0.C, 20426 Re: _Blenheim-Gilboa Pumped Storage Project, FERC No. 2685-026; Filing of Draft License Application for Comment; Request for Treatment of Exhibit F as Critical Energy Infrastructure information; ‘and Request for Waiver of Supporting Design Drawing under Exhibit F Dear Secretary Bose: The Power Authority of the State of New York (Power Authority) is relicensing the Blenheim-Gilbos Pumped Storage Project (FERC No. 2685) (Project) using the Federal Energy Regulatory Commission's (Commission) Integrated Licensing Process (ILP). Pursuant to the Commission's ILP regulations, 18 CFR. §5.16(c), the Power Authority hereby files its Draft License Application (DLA) that seeks a new license for the Project. In accordance with 18 C.F.R. § 5.16(e), by filing this DLA with the Commission, the Power Authority Is seeking comments on the DLA from Commission staff, federal and state resource agencies, Indian Tribes ‘and other licensing participants. The Commission's ILP regulations, 18 CFR. § 5.16(e), as well as the ‘Commission's Revised Process Plan issued on September 6, 2016, require all comments on this DLA to be filed with the Commission by March 1, 2017. The contents of this DLA were prepared in accordance with 18 CFR. § 5.18, § 4.51 and § 4.41, a5 applicable, The information contained in Exhibit F, the design drawings of the principal Project works, Comprises Critical Energy Infrastructure Information (CEII) that is exempt from mandatory disclosure under the Freedom of Information Act. § U.S.C. § 552(b)(3}; 18 C.F.R. § 388.113(c)(1). The information in Exhibit F contains detailed engineering drawings of key infrastructure of the Project. Accordingly, as required under 18 C.F.R. § 388.112(b), the Power Authority requests that the Commission treat Exhibit F a5 CEll. Also as required by the Commission’s regulations, the information in Exhibit F has been marked as CEll and removed from the public version of the attached DLA. 18 C-F.R. § 388.112(b). Exhibit Fis being filed with the Commission as a separate CEll electronic document, through the Commission’s efiling system With regard to the Final License Application (FLA) for the relicensing of the Project, the Power Authority respectfully requests a waiver of the requirement that Exhibit F contain a supporting design report (SDR) for the Project. See 18 C.F.R. §§ 4.52(g}, 4.41(@)(3). The Project is already subject to FERC Part 12 Dam Safety regulations. In addition, all SDRs are currently on file with the Commission's Division of Dam Safety and Inspections in the New York Regional Office, 129 Main trl, White Plas. NY 1060% | $12-88%-4200 | wivw-nype.go”NEWYORK | NY Power oe | Authority GIL C. QUINIONES: ‘ANDREW M. CUOMO. JOHN R, KOELMEL President and Chief Executive Governor akrnan Ofest Finally, with regard to the Exhibit G maps included in this DLA, the Power Authority notes that the Commission’s regulations require Project boundary information to be filed in a shape file or similar format. See 18 CFR, §§ 4.51(h), 4.41(h). The Power Authority will submit the shape file or similar format with the FA, If you have any questions regarding this filing, please direct them to me at (914) 681-6564 or Rob.Daly@nypa.gov. Sincerely, bth Robert Daly Licensing Manager 12 Main Steet, White Plains, NY 1060% | 914-681-8200 | waw-nypa.gorTHE ASSEMBLY ‘conmirrees Rankeng minoriy Mars -Eoueaton route STATE OF NEW YORK Aleonates onde Abuse Corporations. Authors and Cision. ErvrormenstConsenaton ALBANY PETERD. Lone ewer Aesembyman, 12°40, Bact, Pueto Alcan, Hespanic and Asian Legsleve caucus Abery, Coluréla, Delaware, Puro Ricarispane Task Fore Greene! Otsogs Senonare ana Food, arm and Nutiton Poly Task Face ise" Ceantes February 21, 2017 Ms. Kimberly D. Bose Secretary Federal Energy Regulating Commission 888 First Steet NE Washington, DC 20426 RE: Blenheim Gilboa Pumped Storage Project FERC No. 2685-026 DLA Waiver Request Dear Secretary Bose, re Now York Power Authorty is seeking to releense the Blenheim-Gilboa Pumped Storage Power Project (B/G) {through your agency using the Integrated License Process (LP). In ts raft License Appication, NYPA has requested & \waiver ofthe requiement thet Exhibit F contains a supporting design document (SDR) As the NYS Assemblyman representing the affected community, | respectuly request that NYPA's request be denied, Moreover, | further request that NYPA be dtected by FERC to make any design information which may have an impact Caae Saiely of the Schoharie Valley and other downstream communtes readly avaiable to the public and properly vetted wth community stakeholders as part of any effort seek relcensing of as fecty under your auspices Given the recent flooding events that devastated this region and compromised the safe operation ofthe B/G ‘acllty tself (ie, Hurricane irene and Tropical Storm Lee), it is imperative that all pertinent facts be placed on the table ard that NYPA be compelled by FERC to make any necessary structural or operational changes Necessary to ensure the continued structural integrity of the BIG facty as well as ensure the protection of lfe and property of downstream residents, A key consideration in this process wil be the need for NYPA to disclose it inflow Design Flood to ensure the ‘adequacy ofthe BIG release works to handle the Probable Maximum Flood. Please be advised that my ofc is part of a broad coaiton of local, state and federal organizations and elected officials ‘who are intimately fair withthe reported malfunction ofthe B/G Tainter Gates during Hurricane rene and have been Working to pursue flood mitigation 2 the BIG faclty 2s wel as New York Citys Giboa Dam to help guard ageinst the horrfic damage caused by these storm everts, To this effect my office wil be spearheading the submission of father testimony to FERC to addressing the adequacy of NYPA’s response to flood mitigation concems ‘Thank you for your kind attention to this important submission. [ look forward to further constructive ‘engagement with ‘your agency as you continue to consider NYPA's request for reauthorization, Sincerely, =D. Dy Peter D. Lopez NYS Assemblyman - 102nd AD20170308-3004 FERC PDF (Unofficial) 03/08/2017 FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426 March 8, 2017 OFFICE OF ENERGY PROJECTS Project No. 2685-026—New York Blenheim-Gilboa Pumped Storage Project New York Power Authority Mr. Robert Daly Licensing Manager New York Power Authority 123 Main Street White Plains, NY 10601 Reference: Request for waiver of an Exhibit F requirement Dear Mr. Daly: On December 1, 2016, the New York Power Authority (NYPA) filed a draft license application (DLA) for the Blenheim-Gilboa Pumped Storage Project (Blenheim- Gilboa Project or project). In the DLA cover letter, you request a waiver of the requirement that Exhibit F contain a supporting design report (SDR), pursuant to sections 4.51(g) and 4.41(g)(3) of the Commission’s regulations. You state that the project is already subject to the Commission's Part 12 Dam Safety regulations and that the relevant information is on file with the Division of Dam Safety and Inspection’s New York Regional Office. While we understand that your project is subject to the Commission's Part 12 requirements on an on-going basis, relicensing is a once every 30-50 year opportunity for a comprehensive review of a project. As such, we believe there is a benefit to having as much of the project’s relicensing information consolidated within the relicense application as is possible. Therefore, your request is denied and a SDR must be filed as part of the final license application for the project. Ifyou have any questions, please contact Andy Bernick at (202) 502-8660. Sincerely, Terry L. Turpin Director Office of Energy Projects