Letter: Clean Chesapeake Coalition Intervenes in Exelon’s Petition to FERC

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Last week, the Clean Chesapeake Coalition (CCC), on behalf of its Maryland member counties, filed its Motion to Intervene in the Petition for Declaratory Order by Exelon Generation Company now pending before the Federal Energy Regulatory Commission (FERC). The CCC has been at the forefront of this issue for years, long before the current surge of interest in the threat the Conowingo Factor poses to Bay health, back when certain special interest groups were still calling the impacts of the Conowingo Dam a “red herring” in the context of saving the Bay.

CCC member counties and their county official remain disappointed at the lengths Exelon is willing to take to shirk environmental responsibility associated with the operation of this lucrative power station. This private, for-profit corporation which, according to its own website recorded $35.9 billion in revenues in 2018, claims that the Maryland Department of the Environment’s qualifications for a Water Quality Certification are “impracticable.” Meanwhile, Maryland counties with annual budgets that are a tiny fraction of Exelon’s revenues, are spending enormous amounts of taxpayer dollars to develop and implement their Watershed Implementation Plans (WIP) and help Maryland meet its Bay Total Maximum Daily Load (TMDL) goals; and the local economies of Bayside counties are hurt by the Conowingo Factor impacts on the seafood industry.

Well-supported by science and enforceable under the law, the Hogan Administration has embraced the once-in-a-generation opportunity to impose licensing conditions requiring the owner of Conowingo Dam to properly manage the vast quantities of nutrients, sediment and other contaminants that are accumulated in the reservoir above the Dam and scoured into the Bay, not just during major storm events but now, with increasing frequency, because of the loss of trapping capacity in the reservoir.

Consider the following: in 2016, according to United States Geological Survey (USGS) monitoring data, the average daily discharge at the Dam reached or exceeded 100,000 cubic feet per second (cfs) on a total of six (6) days throughout the year; in 2017, this happened 18 times; in 2018, this happened on 77 different days. In fact, in 2018, there was only one month, June, in which there were no days with an average daily discharge rate at 100,000 cfs or higher. Thus far in the first quarter of 2019 (January 1 – March 31), USGS provisional data has recorded 16 days with an average daily discharge at or above 100,000 cfs. We know that when the water is coming through the Dam at 100,000 cfs, scouring begins to occur, loading nutrient-laden sediment into the upper Chesapeake Bay in shocking proportions. At this rate, we are on track to reach our allowable nutrient levels for the entire watershed solely through the inability of the Conowingo Reservoir to keep upstream pollutants trapped behind the spill gates.

Exelon maintains that the Dam is not a source of pollution and while it may be true that the Dam does not itself create pollution, CCC and other intervenors contend that its operations have a severe negative impact on the health of the Bay and that the 14-mile reservoir behind the Dam, also the responsibility of Exelon, must be properly maintained so that the downstream cleanup progress made to date is not wiped out by the next major storm event. Given that there is an 80% chance of a 25-year storm occurring during the re-licensing period sought by Exelon, the billions that have already been spent downstream to improve the quality of our country’s largest estuary will be washed down the proverbial toilet if Exelon continues to dodge any meaningful role in Bay stewardship.

A copy of the Coalition’s recent Motion to Intervene in the FERC relicensing process may be found on its website: www.cleanchesapeakecoalition.org

Charles D. MacLeod
Clean Chesapeake Coalition

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Letters to Editor

  1. Frederick Patt says

    The CCC is a sham organization that exists solely for the purpose of deflecting responsibility for Chesapeake Bay cleanup from its member counties.

    The myth that the Conowingo Dam is a source of pollution is not “well-supported by science”, in fact quite the opposite. The source of the pollution is the Susquehanna River watershed above the dam.

    I am no fan of Exelon as a corporation, but their dam is not the problem.

    • Steve Payne says

      The dam isn’t the source but it acts as a trap for sediment. This is a good thing in principle but they have failed to maintain the lake behind the dam. The lake was created by the dam and is part of it’s design and is necessary for it to function. They need to clean it out now that it’s full of sediment.

    • James Long says

      Amen…we folks in PA need to get our heads out of the sand (or sefiment in this case) and clean uo our mess. We talk about it, we study it, we poor mouth about it, but are not taking responsibility for our unwillingness and or lack of wisdom to deal with the root causes of the problem. Maybe we are just too smart for our on good or living in denial. Our polution of all kinds is being collected behind the dam. Now we are wining and complaining because our neighbor to the south won’t clean up OUR mess. Get real my fellow Pennsylvanians. If the dam wsdn’t there, do think the problem wouldn’t exist anymore??? It would just reveal itself down stream. We preach about how important it is to remember we all live up stream from somebody but yet we let our neglectful ways continue to adversely affect our neighbor. This seems incrdibly hypocritical to me. We should be ashamed. We need to put our money where are mouths ste and God help us add regulations. Then ENFORCE them on ourselves and the industry having the greatest adverse affect on the wstershed.

  2. William Herb says

    The Clean Chesapeake Coalition (CCC) is back to cleaning what it cleans best: the wallets of taxpayers in Kent County and other counties who are gullible enough to continue to fund the activities of this sham organization. A review of its website shows no evidence that it is doing anything to clean the Chesapeake, but rather devotes its time, efforts, and (my) money to continuing to promote the “fake news” about the dreaded “Conowingo Factor”. The CCC is expected to reach out for further taxpayer subsidies from Kent County in the next couple of months.
    I am a hydrologist who understands sediment and nutrient transport, and the interactions between the Conowingo Dam and Pond and the Susquehanna River. Just to be perfectly clear, I have no financial connections (other than paying my electric bill) to Delmarva Power or Exelon. Unlike those who have a financial stake in continuing to demonize the Dam and its ownership, I have no dog in the fight. As a matter of fact, until I recently met a tour guide for the Conowingo Dam, who describes himself as the “lowest-paid employee of Exelon”, I had never even knowingly met anyone associated with the corporation.
    This letter uses well-established propaganda techniques to conflate the overall revenue of Exelon ($39B) with the revenue from the power-generating facility at the Conowingo Dam, which is $120 M (revenue not profit; based on an independent study in 2017). This clever demagogic application of “new math” exaggerates the economic value of the Conowingo Hydropower Station by a factor of about 325.
    The article further bemoans the fact that counties draining to the Chesapeake bay are spending considerable funds on Watershed Implementation Plans (WIPs), and implies that if only that “old Debbil Conowingo”, through the actions and expenditures of Exelon, would clean up its act, all these dollars would be saved. That conveniently disregards the fact that the WIPs are needed because of the pollution originating in these counties, that is combined with the contamination from Pennsylvania and New York that is coming down the Susquehanna River. This contamin in theSusquehanna River water simply passes through the Conowingo Pond and Dam with a bit of a delay. The real boogeyman in this story is either the “Susquehanna Factor” or the “Pennsylvania-New York Factor”.
    The letter then goes into an accurate discussion of the water flows that are coming through the dam, but continues with statements that would lead its readers to the conclusion that the contaminants from the scour are the sole problem for the Bay. In actuality, during the large flows (floods) that are discussed, the contribution of contaminants from scour is generally only a fraction of that coming down the river from Pennsylvania and New York. In the case of Tropical Storm Lee, the sediment load from the scour was only about 20 percent of that originating from runoff in Pennslylvania and New York.
    Just to be perfectly clear, virtually all of the contamination in the Susquehanna is coming downstream from those two states, and for 80 years, the Conowingo Dam and Pond have prevented (at no cost to the residents along the Bay) vast quantities from entering the Bay. Only now, that the sediment storage capacity of the pond has been exhausted, will the Pond no longer be able to provide this benefit.
    While I disagree with much of the mis-information provided by the CCC, I do agree that something must be done about the contaminants from Pennsylvania and New York that are reaching the Bay. Even the CCC agrees that the Pond and Dam are not the source of the contaminants, but then both they and our Governor make the leap of illogic to presume that a private utility, which produces none of these contaminants, should be financially responsible for cleaning up the transgressions of the residents of these upstream states. Exelon’s largest environmental crime seems to be the apparent depth of its pockets. The CCC and the Governor are engaged in what looks a lot like a shakedown of Exelon, but it is probably all perfectly legal ,even if leaves a bad taste in the mouths of a lot of informed citizens. Perhaps Michael Cohen can find some work here.
    Over the past 6 or 7 years, nearly $1,000,000 in taxpayer money has been frittered away by the CCC without, as far as I can tell, cleaning up one ounce of contamination. It is time that the voters in the member counties of the CCC and my Kent County Commissioners finally tell these pretenders to take a hike when they ask for more of our money.
    Taxpayers also need to be cognizant of any attempts to “launder” contributions to the CCC through other organizations requesting funds from our counties.

  3. Gren Whitman says

    FOLLOW THE $$$
    During Fiscal Years 2013-2017, the Kent County Board of Commissioners allocated $25,000 annually to the “Clean Chesapeake Coalition,” totaling $125,000. This plus two more allocations of $17,000 for both Fiscal 2018 and Fiscal 2019 brings the total amount to $159,000 over the past seven years.
    Then, of course, there are those five other counties that also allocate money to the CCC. Assuming that each of these counties also contributed an amount equal to Kent’s, the cumulative amount so far is $954,000.
    Almost a million dollars in seven years?
    And for what?

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