LIHI Pending Application--- [ON HOLD] Conowingo Hydroelectric Project, Pennsylvania ***Public Comments Received ***

Exelon Files for LIHI Certification of its Conowingo Project

(August 19, 2011) - Portland, Maine - We recently discovered that in several places in the text we have said that the facility is located on the Susquehanna River in Pennsylvania and of course it is in Pennsylvania and Maryland.  We have gone through the web site documents and believe we have corrected the text to reflect the correct statement.  We apologize for any inconvenience this may have caused --Fred Ayer, Executive Director.

Conowingo Hydroelectric Project (FERC No. 405).

PUBLIC COMMENTS

Can be found at the bottom of this page

Conowingo Hydroelectric Project (FERC No. 405).

Facility Owner: Susquehanna Power Company and PECO Energy Power Company, subsidiaries of Exelon Generation Company (Exelon)

Facility Location: Susquehanna River in Pennsylvania and Maryland.

Installed Capacity: 573 Megawatts (MW)

Annual Generation: 1,800,000 MWH for the period 1997-2006.

Regulatory Status: Current FERC License expires on September 1, 2014

Public Comment Period: January 15, 2008 through March 15, 2008

Point of Contact:

Ms. Colleen E. Hicks

Exelon Power

Tel: 610-765-6610

Email: colleen.hicks@exeloncorp.com

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January 15, 2007 - (Portland, Maine) Today, the Low Impact Hydropower Institute (LIHI) received an application from Exelon for Certification of their Conowingo Hydropower Project.

LIHI certification means that the hydropower facility has been found to meet or exceed the Institute's Certification Criteria which address eight key areas: river flows, water quality, fish passage and protection, watershed protection, threatened and endangered species protection, cultural resource protection, recreation, and facilities recommended for removal. Certification is designed to provide consumers with assurance that a facility has avoided or reduced their environmental impacts pursuant to the Low Impact Hydropower Institute's criteria.

Once certified, the owner or operator can market the power from the facility to consumers as produced by a LIHI certified Facility. Certification from the Institute may also qualify the power produced for other "green" energy certification programs.

Introduction - The Conowingo Hydroelectric Project is located on the Susquehanna River (at river mile 10) in Pennsylvania and Maryland. The project has a total drainage area of 27,510 square miles and an average annual discharge of 35,500 cfs.

Conowingo Dam is located in Maryland connecting Cecil and Harford counties, as is the lowermost 6 miles of the project reservoir, Conowingo Pond. The remaining 8 miles of Conowingo Pond are located in Pennsylvania, within York and Lancaster counties.

The nearest metropolitan area within the Susquehanna River watershed is Lancaster, Pennsylvania, approximately 32 miles to the northeast, with a population of about 55,351 people. Baltimore, Maryland with a population of approximately 628,670 lies 45 miles to southwest of the Conowingo Project.

Lands within the presently approved boundary for the project comprise approximately 3,700 acres, and generally extend along Conowingo Pond and the Susquehanna River from Holtwood Dam to Havre de Grace, Maryland.

The Conowingo Project is the most downstream of the five hydroelectric projects located on the Lower Susquehanna River. The upstream projects (York Haven, Safe Harbor, Holtwood, and Muddy Run) are located at river miles 56, 32, 24, and 22, respectively. Tidewater reaches up the Susquehanna River within four miles of the Conowingo Dam, and the river is navigable by large vessels to Port Deposit, Maryland, located four miles downstream of the dam.

Project History - On February 20, 1926, the Federal Power Commission licensed The Susquehanna Power Company and Philadelphia Electric Power Company to develop the Conowingo Project, and construction commenced in March of that year. In March 1928, construction of the Conowingo Dam was completed and operation began with seven 36-MW Francis turbine units. The capacity of the Conowingo Project was expanded in 1965, when four additional 65-MW Kaplan-type turbine units were installed. Two house units, with a total capacity of 2.4 MW, were also added at that time.

In 1972, the west fish lift was constructed and began operation. On June 24, 1972, the maximum flood of record, which was a result of Tropical Storm Agnes, was recorded at Conowingo Dam (972,000 cfs).

To increase spillway capacity and upgrade the structures to meet stability requirements, the dam was anchored into foundation rock by a post-tensioned anchorage system in 1978. The upgrades increased the spillway design flood to 1,170,000 cfs, which corresponds to a reservoir level of 117.2 feet, eight feet above normal pool elevation.

The original 50-year license for the Conowingo Project expired in 1976, and the Project was operated under successive annual licenses until August 14, 1980 when FERC issued the current license. Subsequently on January 24, 1989, FERC approved a settlement agreement between the project owners and resource agencies resolving issues related to minimum flows, water quality and fish passage. These issues had been outstanding since the beginning of the relicensing process.

During 1990-91, the east fish lift was constructed and began operation. In 1997, the east lift became the primary means of conveying American shad and other fish species upstream past the dam.

PROJECT COMPONENTS

Reservoir - The Conowingo Pond serves many diverse uses including hydropower generation, water supply, industrial cooling water, recreational activities and various environmental resources. Relative to hydropower generation, the Conowingo Pond serves as the lower reservoir for the 880-MW Muddy Run Pumped Storage Project (FERC No. 2355), located 12 miles upstream of the Conowingo Dam. It also serves as the source of normal cooling water for the 2,186 MW Peach Bottom Atomic Power Station located eight miles upstream of the Conowingo Dam. Conowingo Pond is used as a public water supply source, with the City of Baltimore and Chester Water Authority having permitted withdrawals of 250 MGD (387 cfs) and 30 MGD (46 cfs), respectively.

Dam - The Conowingo Dam is a concrete gravity dam with a maximum height of approximately 94 feet and a total length of 4,648 feet. The dam consists of four distinct sections from east to west: a non-overflow gravity section; an ogee shaped spillway; an intake-powerhouse section; and an abutment section. The tailrace and spillway sections of the dam are separated by a dividing wall extending 300 feet downstream of the powerhouse. The dam and powerhouse also support U.S. Highway Route No. 1. Flow over the ogee spillway sections is controlled by 50 stony-type crest gates and two regulating gates.

Powerhouse - The first seven turbine/generating units (1-7) are completely enclosed within the powerhouse, while the last four units (8-11) are an outdoor type of construction thereby eliminating a superstructure in this area. Additionally, two house turbines provide station service and "black-start" capability.

Fish Passage Facilities - The project currently operates two fish lifts. The west lift, adjacent to the right abutment, is currently operated in cooperation with the United States Fish and Wildlife Service (USFWS) for American shad egg production and other research purposes. The newer east lift, which uses regulating gate bays for attraction flow, is used primarily to pass American shad and other migratory fishes during the April – June migration season. The gates in front of the fish lift can vary flow from 200 to 500 cfs.

Current Project Operation

The Conowingo Project is characterized as a modified run-of-river hydroelectric facility in that limited active storage is available owing to reservoir size and the relatively small allowable variation in headwater level.

Safe Harbor Corporation's operation of Safe Harbor Dam (FERC No. 1025), a peaking facility located 24 miles upstream, primarily determines the operation of the Conowingo Project in terms of energy generation timing. Maximum hydraulic capacity of Safe Harbor Dam (110,000 cfs) is more than that of the Conowingo powerhouse (86,000 cfs). There is approximately a two-hour lag time for the arrival of water released at Safe Harbor to reach Conowingo.

The FERC license for Conowingo allows for the Conowingo Pond to normally fluctuate between elevation 101.2 feet and 110.2 feet (NGVD 1929). A number of factors (described in Applicant's filing) also influence the management of water levels and flows.

Project Environmental Management System

Exelon's Environmental Management System (EMS) is based on the international standard ISO 14001:2004. This recognized international standard specifies requirements for an EMS to enable an organization to develop and implement a program for effective management of environmental performance. The EMS establishes the framework to not only comply with environmental laws and regulations but to go beyond that in seeking to protect the environment. Through ongoing support of Exelon's EMS program, stakeholders can expect to see continued improvement in Exelon's environmental performance.

Exelon decided to pursue certification as a means to demonstrate its commitment to continual improvement. The Conowingo Project's EMS program is part of a larger corporate initiative fostering a culture where compliance is a minimum expectation and greater environmental responsibility is seen as good business.

The Conowingo Project established and implemented a comprehensive EMS that addressed each element of the ISO 14001 standard. The process to become certified to the ISO standard consisted of a rigorous three stage audit by NSF International Strategic Registrations, Ltd. (NSF-ISR), an accredited registrar. The audit process spanned nearly four months and consisted of a desk audit, an onsite readiness review, and a final registration audit. That examination process included reviews of policies and procedures, observation of site practices, interviews of employees, and close examination of records to verify that the Project's environmental management system was implementing each required element of the ISO standard.

On November 9, 2005, based on the successful independent verification of the processes and procedures, the International Organization for Standardization (ISO) certified the Conowingo Project EMS. The Project maintains its certification by demonstrating compliance to the ISO standard in an annual surveillance audit conducted by NSF-ISR.

Public Comment

A 60-day public comment period for the Conowingo Hydroelectric Project runs to March 15, 2008. We encourage public comment on this application. Specifically, we are interested in knowing whether you think the Project meet the LIHI criteria. Review our program and criteria (click on the "LIHI Certification Program" to the left), and then review the detailed information on the Project. Comments that are directly tied to specific LIHI criteria (flows, water quality, fish passage, etc) will be most helpful, but all comments will be considered. Comments may be submitted to the Institute by e-mail (preferred) at info@lowimpacthydro.org with the Project name in the subject line; by fax at (206) 984-3086; or by mail addressed to LIHI, 34 Providence Street, Portland, ME 04103. Comments must be received at the Institute on or before 5 pm pacific time on March 15, 2008 to be considered. All comments will be posted to the web site and the Applicant will have an opportunity to respond. Any response will also be posted.

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March 10, 2008 - (Portland, Maine) - Public Comments received from:

Elisabeth Lynch-McCoy, Tourism Planner

Clinton County Planning Commission

Clinton County CleanScapes

This correspondence and attachments are in reference to Excelon's application for Low Impact Hydropower Institute (LIHI) certification for the Conowingo hydroelectric project on the lower reach of the Susquehanna River (www.lowimpacthydro.org). On March 5, 2008 I sent a quick note to you and I would like to recap a few points from that e-mail. It is this e-mail and attachments that I am requesting your governing board of directors take into consideration when reviewing Exelon's application for LIHI or "green" certification.

1. It may be premature for Excelon to be applying for "Green Tag" or REC (Renewable Electricity Program) status prior to their upcoming FERC re-licensing since their current eel passage capabilities are in question & may be required to be improved at that time (attachments), 2. the turbines that are currently in operation may have a unnecessarily high rate of "chumming" (e.g. as fish swim downstream and through the current turbines they may be mortally wounded vs. newer turbine technologies that have effectively reduced the "chumming" effect). It is requested that this factor be researched and a determination made on whether or not the current turbines meet "acceptable" mortality rates, and 3. if the above listed items are indeed not performing to today's conservation/restoration/environmental standards then it can be assumed that if Exelon acquires "green" certification prior to FERC re-licensing, FERC may have an artificially elevated perception of Excelon's conservation/restoration/environmental performance and mitigation efforts and in turn, Excelon may not be required to upgrade their current American shad & eel fish passage facilities.

In addition to these three items I have attached articles and documentation on this region's efforts on restoring American shad and eel populations to the West Branch and Main Branch of the Susquehanna River. And I must add that our regional efforts are not just based on conservation-restoring the American shad and eel populations to this area will also effect our regional economic growth potential (e.g. tourism and economics linked to sport fishing), and the Chesapeake Bay clean water initiatives (water filtering capabilities of mussels and the importance of eels in the life cycle of mussels).

Thank you for this opportunity to comment and we look forward to your organization's upcoming comments and decision on this matter.

(Downloadable attachments to Ms. Lynch-McCoy's letter can be found at the bottom of this page in the FILES section)

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On 3-14-08, LIHI, at the request of the USFWS, extended the closing date for Public Comments from March 15 to March 21.

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March 14, 2008 - (Portland, Maine) - Public Comments received from:

George Hansell

11 Fox Lane Newark,

DE 19711-2011

Hello Low Impact Hydro. I'd like to comment on an impact Conowingo has although I'm not sure how it fits into your survey. The impact is a significant amount of debris which is present in the Upper Chesapeake nearly every Spring. Much of this debris comes over Conowingo when the flood gates are opened to release the stuff which has floated downstream and been caught behind the dam.

I believe there are two approaches to minimizing the debris and the damage it can do to boats and the mess it creates along the shores. One would be to institute an aggressive cleaning procedure to keep the area just above the dam as free of debris as possible. A second would be to gather the debris which makes it over the dam and remove it. It seems that cleaning above the dam could be done by Exelon but it would take cooperation among boaters, and others to gather and dispose of the stuff in the Upper Bay.

If a way could be found to turn the debris economically into something useful it would be a major contribution to reducing the impact of what's now at least a nuisance and often a hazard. Perhaps some collection stations could be established and the whole trees and large pieces converted to chips or mulch. I believe that communities around the edges of the Upper Bay would organize "clean ups" by volunteers if such stations and recycling could be sponsored by Exelon and/or local governments.

Thank you for considering this comment.

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Please accept the following comments on behalf of the Commonwealth of Pennsylvania Department of Environmental Protection on the Conowingo Hydroelectric Project LIHI application.Please contact me if you have questions concerning the Department's comments.

Duke Pepper, Esq.

Counsel for the Department of Environmental Protection

717-783-0366

a pdf file of Mr. Pepper's letter Excelonltr.pdf (51kb) can be found below.

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On behalf of the 100 individual and organizational members of Stewards of the Lower Susquehanna, Inc., please accept these comments regarding the Conowingo Hydroelectric Project (FERC No. 405) application. Thank you.

From the Mighty Susquehanna, Michael R Helfrich
Lower Susquehanna RIVERKEEPER®

Stewards of the Lower Susquehanna, Inc.
324 W Market St
York, PA 17401
717.779.7915 (cell)
lowsusriver@hotmail.com
www.LowerSusquehannaRiverkeeper.org

Lower Susquehanna Riverkeeper® is a member of Waterkeeper® Alliance.
Riverkeeper is a registered trademark and service mark of Riverkeeper, Inc. and is licensed for use herein.
Waterkeeper is a registered trademark and service mark of Waterkeeper® Alliance, Inc. and is licensed for use herein.

a pdf file of Mr. Helfrich's letter ConowingoLIHIapplicationLSRcomments.pdf (2mb) can be found below.

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March 20, 2008 - (Portland, Maine) - Public Comments received from:

Marvin F. Moriarity*

Acting Regional Director

United States Department of the Interior

Fish and Wildlife Service

300 Westgate Center Drive

Hadley, MA 01035-9589

* the letter was signed by Wendi Weber as Acting Regional Director for Marvin E. Moriarty

The Interior Department was unable to complete their comments during the 60-day comment period and asked LIHI to extend the comment period, which we did. LIHI did not receive late comments from any other parties. The Service's letter can be accessed and downloaded using this link

USFWS 3-19-08 Conowingo LIHI Final.pdf

or the link below in the FILES section.

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Response to Public Comments from Exelon - June 23, 2008

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Files: