HomeMy WebLinkAbout1982-04 April Hydropower Commission Report l
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HYDROPO
COMMISSION
REFERENCE
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Planning & Development Library
APRIL 1982
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HYDROPOWER
COMMISSION'
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MEMORANDUM
To: Mayor William R. Shaw
James Dennis, Chairman, Planning & Development Committee
Common Council Members
From: - Joey Pierce
Re: Proposed Fall CreekHydropower Plant: Report of the Hydropower Commission
Date: April 219 1982
' On March 3, 1982, Common Council created the Ithaca Hydropower Commission
in response to proposals to construct a hydropower facility at Ithaca Falls. The
Commission was charged with studying the hydro issue and reporting its findings and
recommendations to the Planning and Development Committee on or before April 28.
This memo and the enclosed information constitutesthe report of the Commission;
a verbal presentation of the highlights of the Commission's findings and recommen-
dations will be made to the Planning and Development Committee and to the full Council .
The Commission met for the first time on March 16 in what was primarily
an organizational meeting. If was decided that four individual reports were needed:
1 . an analysis of the regulations governing the hydropower
licensing process in an effort to understand the alternatives
for City response
2. an analysis of the environmental impacts of a hydropower plant
on the Ithaca Falls area
3. an analysis of the existing proposals to identify strengths,
weaknesses, and possible desired design modifications
4, an analysis of various options for City involvement in the
construction of the hydropower plant.
During the following six weeks, the Commission heard and discussed the above reports.
The review culminated in a meeting on April '20 during which the Commission reached
a consensus on its recommendations for Council . The following is a brief statement
of the recommendations, with greater discussion and detail provided later in this report:
1 . Common Council should authorize the submission of a protest
to the Federal Energy Regulatory Commission (FERC) in response
to the two proposals currently on file. The protest will identify
concerns of the Commission and weaknesses in the applications, and
then will suggest appropriate modifications in design and operation
of the plant to satisfy the concerns.
2. Common Council should file a notice of intent to file a license
application with FERC. This notice of intent is a non-binding
action which will allow the City 120 days to prepare and file an
' ! application.
3. Common Council should authorize the initiation of a -search
for an engineering consultant capable of preparing the pre-
liminary design of a hydropower plant necessary for the sub-
mission of the license application. A contract. with the
consultant should not be signed until the'Council makes .a
decision to actually prepare the license application.
4. Common Council should initiate, or authorize an agent to
initiate, negotiations with both Cornell University and
Synergics. Topics for negotiation include cost of land
and water rights, economic return to the City,: royalty pay-
ments in lieu of property taxes, a possible joint venture
with the City as a partner, etc.
The Hydropower Commission believes that these actions constitute positive
steps which should be taken at this time but which maintain maximum flexibility for
Council in terms of reaching a final decision concerning the issue.
Please find enclosed the following information for your review:
1 . Resolution creating the Hydropower Commission
S 2. Membership of the Commission
3. Chronology of major events in the hydropower issue
4: Statement of basic findings
5. Statement of recommendations
6. Statement -of City options at this time
7. Report on the federal regulations governing hydropower
8. Preliminary report of the environmental committee
9. Preliminary report of the proposals committee
10. Comparison of existing applications
11 . Report of the City involvement committee
12. Minutes .of the Hydropower Commission meetings
The Commission has generated much information about the proposed hydro-
power plant. Members- have worked diligently during the past six weeks, .often meeting
two to three times a week for committee work in addition to the weekly Commission
meetings. While this report officially completes the work of the Commission as set
forth in the March 3 Council resolution, many members have expressed a willingness to
continue to be involved in the process if Common Council desires.
If you have any questions or comments about the enclosed information, or
if you would like to get together to discuss the project, please feel free to call me.
JP/mc
Enclosures
Main Motion as Amended
WHEREAS, a hydropower plant has been proposed at Ithaca Falls on Fall
Creek, and
WHEREAS, the City of Ithaca will be .required to take a position con-
cerning the construction of such plant ;
NOW; THEREFORE, BE IT RESOLVED, That Common Council., acting upon the
recommendation of its Planning and Development Committee , does hereby
create and establish the Ithaca Hydropower Commission, and
BE * IT FURTHER RESOLVED, That said Commission shall consist of a
representative from each of the following organizations , said repre-
sentatives to be appointed by the President or Chairman of each
organization unless othe.rwise noted;
Planning and Development Committee*
Planning and Development Board
City Energy Commission (.2 representatives)
Conservation Advisory Council
Ithaca -lrandmarks Preservation Commission
Fall Creek Civic Association
Trout Unlimited
Ecology Action
- Circle Greenway Committee
Board of Public Works
Community at-large , with expertise in hydropower
or hydrodynamics (2 representatives to be recom-
mended by Chairman of the Planning and Develop-
ment Committee for approval by Common Council)
and
BE IT FURTHER RESOLVED, That the Ithaca Hydropower Commission be
charged to perform the following tasks :
_ 1. To make the Planning and -Development Committee and :Common
_ Council aware of relevant information and developments re-
garding the proposed hydropower plant.
2. To review and analyze the current proposals for . constructing
the plant and to inform Council of the major aspects and
impacts of each.
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HYDROPOWER COMMISSION MEMBERSHIP
1 . James Dennis, Chairman
Planning and Development Committee of Common Council
2. Martin Sampson
Planning and Development Board
3. Benjamin Nichols
City Energy Commission
Professor of Electrical Engineering and Director of the Division of Basic
Studies. in the College of Engineering, Cornell University
4. Jeanne Fudala
City Energy Commission
Coordinator of the Home Energy Assistance Program
Energy Educator/Coordinator in the Economic Opportunity Corporation
5. Richard Banks
Conservation Advisory Council
Associate Bursar at Cornell University
6. Frank Moon
Ithaca Landmarks Preservation Commission
Professor and Chairman of the Department of Theoretical and Applied
Mechanics at Cornell University
7. Dan Peterson.
Fall Creek Civic Association
Research Associate at Synchrotron, doctorate degree in high energy physics
8. Donald Henderson
'} Trout Unlimited
Acting Assistant Professor in Department of Materials Science and Engineering
President of Trout Unlimited
9. Richard Berg
Ecology Action
10. Bill Schmidt
Circle Greenway Committee
Former Council Member; local businessman
11 . Clarence Cleveland
Board of Public Works
12, Donald Zwiebel
Community-at-large
President of North Country Energy Systems (.energy conservation products) ;
degree in Design and Environmental Analysis
Staff assistance provided by Joey Pierce, Planning and Development, and
Bob Dowski , student intern in environmental studies
FALL CREEK HYDROPOWER PLANT PROPOSAL
Chronology
July 9, 1981 MacLeod Hydropower filed application for preliminary
permit to. study feasibility of proposed facility
Nov. 23, 1981 Cornell University, Synergics, and Western Hydropower :
r submitted notices of intent to file applications for
. license; Ithaca Gun submits notice of intent to file
an application for a preliminary permit
Jan. 15, 1982 Synergics filed an application for a license with FERC
Jan. 26, 1982 Joey Pierce discussed the licensing procedure with the
City Planning Board
Jan. 27, 1982 Joey Pierce discussed the hydropower plant issue and the
licensing procedure with the Planning and Development
Committee
'j Jan. 29, 1982 Cornell: University filed an application for a license
with FERC
Feb. 3, 1982 Common Council referred the idea of creating a Hydropower
Commission to the Planning and Development Committee
Feb. 8, 1982 Cornell University met with the Fall Creek Civic Association
to discuss the proposal
Feb. 24, 1982 Planning and Development Committee recommended to. create a
Hydropower Commission
Mar. 3, 1982 Common Council voted to create a Hydropower Commission
Mar. 8, 1982 Synergics met with the Fall Creek Civic Association to
discuss the proposal
Mar. 16, 1982 Hydropower Commission met for first time
Mar. 23, 1982 Commission members toured the existing Cornell power plant
Apr. 5, 1982 Common Council accepted recommendation of Commission to file
for an extension of time
Apr. 9, 1982 Request for an extension of .time mailed to FERC
Apr. 14, 1982 Joey- Pierce and Bob Dowski met with DEC officials in Albany
Apr. 20, 1982 Hydropower Commission prepared report and recommendations
for Common Council
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STATEMENT OF BASIC FINDINGS
I'. 1 . After discussion with state and federal officials and after much
research, the' Commission has concluded that the City does not have
the legal authority to prevent the construction of a hydropower
plant on Fall Creek if a license is awarded.
.2. The construction of a hydropower plant will generate a substantial
amount of energy, displacing 4,000 tons of coal per year or 10,800
barrels of oil per year.
3. The construction of the facilitywill have several potential environ-
mental impacts on' the Ithaca Falls area. The three most important
�`. concerns are the aesthetic changes in the Falls, the possible adverse
effects on fishing and aquatic life below the Falls, and the guarantee
of public access to the Falls area after the plant is constructed.
4. There are several modifications which can and should be made to the
proposals submitted by Cornell University and .Synergics which would
eliminate or at least minimize nearly all of the environmental im-
pacts of the project.
5. The best way for the City to insure that it has control over the
design of the facility is to .receive the license to. construct from FERC.
6. There is economic gain to be made from the operation of a hydropower
plant on Fall Creek. Since Ithaca Falls is a public resource it seems
appropriate that the public should be compensated for the use of the
resource. Consequently, the City should attempt to maximize public
return from the plant.
STATEMENT OF RECOMMENDATION
1 . Protest/Comments
It is recommended that Common Council authorize the submission of a
protest to the Federal Energy Regulatory Commission in response to the
two proposals currently on file. The protest would not protest the
construction of a hydropower plant per se, but rather would protest
the construction of a facility as currently designed and proposed. The
submission would identify the concerns raised by the Hydropower Commission
during its study and would focus on the aesthetic nature of the falls .area,
the impacts on aquatic life, the availability of public access to the creek
and falls, the safety and noise of the power plant, and the protection of.
historical and archeological resources. The' report of the Proposals
Committee, as modified by the full Commission (included in packet) , is
recommended as the basis for the protest/comments to FERC.
It is important that such submission be filed with FERC so that the City
will have some say in how the plant is built if the City does not con-
struct the plant. If at a later time the City decides to build the plant,
then it would also have to abide by the above comments.
2. Notice .of Intent
It is recommended that Common Council authorize the submission of a
notice of intent to file an application for a license with FERC. This
notice of intent allows the City 120 days to then prepare and file the
application. The filing is a non-binding action which the City could
decide to abandon at a later time. However, if the City is at all inter-
ested in constructing the plant, in investigating a possible financial
arrangement or joint venture with a second party, or in having more time
to study the possibility of City involvement in the plant, it should file
the notice of- intent to maintain a maximum .number of options.
3. Consultant Search
If Common Council decides to file a notice of intent, then it is recom-
mended that Council should authorize the initiation of a search for
an engineering consultant capable of _preparing the preliminary plant
design and cost estimates necessary for the submission of a license
application. The Department of Public Works or the Department of Plan-
ning and Development appear to be the most appropriate for conducting
such a search. It is recommended that a contract with the consultant
not be signed until Council reaches at least a preliminary decision to
move ahead with City construction. The search for a consultant now
while that issue is being discussed will save up to 30 days of the 120
day period for application preparation.
4. Negotiation
It is recommended that Common Council initiate, or authorize an agent
to initiate, negotiations with both Cornell University and Synergics.
Such negotiations must be substantially completed before an application
is submitted to FERC at the end of the 120 days,. thus the recommendation
for early authorization. Many issues must be addressed, including the
cost of land and water rights, the possibility of litigation, the possi-
bility of royalty payments ,in lieu of taxes, the option of a joint venture
with the City as a possible partner, and others. Information on these
options is needed before Council can fully assess the feasibility of
City construction of the plant. The Mayor, the City Attorney, the
Director of Planning and Development; or a coalition of Hydropower
Commission members may be an appropriate agent if Council members
prefer not to negotiate themselves.
RECOMMENDED COMMENTS TO FERC
III (taken from the Proposals Committee report)
A. Impact on Aquatic Life
1 . The minimum rate of flow proposed to be.maintained over Ithaca Falls is
inadequate to fully mitigate impacts on aquatic life and to maintain a
scenic quality of the falls satisfactory to City.residents'. It is
recommended that both the initial minimum flow rate and the flow necessary
for turbine start-up be increased at least 30% of the current proposals.
2. It is recommended that studies be initiated prior to the time of plant
operation to determine the full impact of reduced natural flow over .the
falls on the aquatic life. A before-operation and after-operation com-
parsion should be made to determine the impact of the hydropower plant
on fish mortality and aquatic habitats. The ultimate minimum rate of
flow should be subject to modification if necessary to mitigate impacts
identified in the studies.
3. The "best available technology", as identified by New York State Department
of Environmental Conservation, should be incorporated in the design of the
facility to reduce the number and mortality of migrating salmon smolts
entering the penstock.
4. The tailrace shall be designed to enter Fall Creek above Plumbers Pool
at an attitude so as to minimize negative impacts on streambed morphology
and the character of the pool .
B. Impact -on Aesthetic Quality of Site
1 . The increased rate of flow indicated in M . will reduce the damage to the
aesthetic quality of Ithaca Falls.
2. , The power house should be located as close as possible to the hillside in
the southwest corner of the development site, as far removed .from the
stream bed as possible.
3: The powerhouse should receive exterior facade. treatment so as to blend the
facility into the natural surroundings. Landscaping should also be used to
restore the naturalness of the area. Said facade treatment and landscaping
plan should be subject to review by the City Design Review Board.
4. The penstock from the end of the tunnel to the powerplant should be buried
to prevent vandalism and defacement.
5: The switching yard should be built as an attachment to the powerplant, with
appropriate exterior treatment and landscaping as identified in 5.3.
6. All transmission lines from the powerhouse should be placed underground to
reduce intrusion into the natural area.
Ir 7. The developer should be required to create a scenic distribution of water .
over the dam and over the falls. Appropriate engineering design should be
incorporated to minimize the amount of equipment in sight.
C. Preservation of Public Access
insure safe and
easy access for the general -public
blic to
1 . The developershall Y 9 P
the stream banks and to the falls.
2. The tailrace should be covered at grade to allow public access to the stream
on- both sides of the race.
3. Access to the powerhouse and to the intake structure should be unimproved
and should be incorporated into the landscape design plan for the area. No
permanent parking on the site is to be provided.
4. All land surrounding the powerhouse and associated development and at the
falls itself should be deeded to or otherwise formally reserved -for the City
residents as a public scenic and recreational resource.
5. The developer should be responsible for the enhancement of the recreational
potential of the area, with all plans for recreation subject -to approval by
the City of Ithaca.
D. Public Safety
1 . The open channel upslope of the powerplant should be replaced by penstock to
minimize safety concerns.
2. The tunnel constructed by Ezra Cornell should be utilized rather than filled,
with appropriate provisions to prevent unauthorized access to the tunnel .
3. The tailrace should be buried, with appropriate provisions at its terminus to
prevent unauthorized access into the tailrace.
4. An automatic bypass system should be incorporated into the design of the
powerhouse to prevent a surge of water over the dam or through the overflow
channel in the event of an automatic turbine shutdown.
5. An appropriate warning system should be installed to warn-area users of ex-
pected increased flow rates associated with plant shutdown.
6. The powerhouse and all associated development should be designed in such a
way as to minimize the possible adverse impacts of flooding in Fall Creek.
E. Noise
1 . The "best available technology" should be incorporated into the design of the
powerhouse and tailrace to minimize the noise emanating from the development.
The City noise ordinance standards will be enforced on the site.
2. The powerhouse shall be designed so that the noise which escapes the building
does so in a direction away from the residences near the site.
F. Historical and Archaelogical Resources
1 . Negative impacts to potential archaelogical resources should be mitigated
techniques as prescribed b the State
I' through appropriate constructionq p Y
DEC. Artifacts should be salvaged where possible and preserved.
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OPTIONS FOR CITY INVOLVEMENT IN THE
FALL CREEK HYDROPOWER PLANT APPLICATION PROCESS
1 . Do Nothing. The City could decide to do nothing,. to not get involved
in the process and to leave the decision to the FERC.
2: Intervention. The City may file a petition to intervene on behalf of
the. citizens and residents of- the City. If granted, the petition to
intervene would .allow the City to be a party at any official hearing
concerning the hydropower plant and to make official comments on the
record.
3. Protest
A. The City could file a protest objecting to the construction of a
hydropower plant per se on Fall Creek. It could seek a ruling by
FERC that the Ithaca Falls area would be substantially impacted
by the facility and that the impacts cannot be mitigated suffici-
ently. It would be necessary to discuss in great detail the
environmental impacts anticipated and their long-term effect on
the City.
B. The City could file a protest objecting to the construction of a
hydropower plant on Fall Creek as currently proposed by Ithaca
Falls Development Association and Cornell University. It would be
necessary to identify the weaknesses/problems in the two applica-
tions and to point out more appropriate design parameters. The
Commission and the Common Council would have to decide exactly how
the plant should be designed. The report of the Proposals Committee
will in all likelihood form the basis for this "preferred design." .
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4. Pre-emption
f'. A. The City could decide to construct the hydropower plant itself.
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In this case, the City would need to go through the following
process:
j 1 . File a Notice of Intent with FERC.
2. Hire an engineer to begin preliminary design on
the plant; the selected engineer should identify
expected construction costs as soon as possible to
allow a true economic feasibility study to be conduc-
ted.
3• The Department of Planning and Development could pre-
pare the application for the license.
4. Common Council would have to pass local law establish-
ing the method of construction, financing and operation,
as well as a maximum and estimated cost of construc-
tion. This local law would .not take effect until
approved by the City voters- -in a mandatory referendum
held at least 60 days after passage of the local
law.
5. Once the license is granted, the City must complete
project design and begin construction within 24 months.
B. The City could attempt to delay the project completely by filing
a Notice of Intent, receiving the license from .FERC, but not
initiating construction within the required-period of time. The
City would then lose its license, and the licensing process would
begin ,agai.n.-. The delay could cause currently involved parties to
lose interest.
C. The City could attempt to arrange a deal with a developer of its
choice. The FERC regulat-ions make provision- for the transfer of
a license to another developer, subject to FERC approval . The
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transferee must meet all the qualifications of the original
licensee, and it must be in the public interest to make the trans-
fer. The transfer can be contested and a rehearing held. Notwith-
standing the potential problems, the City could secure. the license
for itself,- 'work out an arrangement with- a developer of' its choice,
then attempt to transfer the license to the developer. The City
must also transfer all property rights necessary for the project at
the same time. The legal issues involved in this option could be
considerable, but so could the economic return to the City.
MEMORANDUM
To: Hydropower Commission
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From: Bob Dowski
Joey Pierce
Re: Federal Regulations Governing Small. Scale
i Hydropower Development
Date: March 30; 1982
In order to fully understand the process in 'which the City of
Ithaca is currently involved concerning the proposed hydropower plant, it is
necessary to understand the federal laws and regulations which govern the
licensing and development of hydropower facilities. Following is a discussion
of these laws, their background, their implementing regulations, and their
effects on the City relative to the existing situation.
Historical Background
i
American legal attitudes concerning waterpower can be traced
back to the riparian doctrine and its roots in English Common Law. Under riparian
doctrine, ownership of the water is conceptually separated from the right to use the
water. The water is owned by the state, on behalf of the public. The right to
use the water is vested primarily.-in the individual owners whose land abuts, or is .
riparian to, the watercourse. Because of these concurrent ideas of public owner-
ship and private use rights, riparian law was developed with explicit reference to
the often conflicting private and public aspects of water resource use.
Contemporary involvement in water power regulation is based on
the paramount authority of Congress to regulate interstate commerce under the
commerce clause of the United States Constitution. The U. S. Supreme Court has
interpreted the reach of this authority in an expansive manner. It has also
accepted a highly inclusive definition of what constitutes navigable waters for
purposes of federal law.
Enabling Federal Legislation
Current government regulation of water power development is
authorized by two primary statutes - the Federal Power Act of 1920 (FPA) , and the
Public Utilities Regulatory Policies Act of 1978 (PURPA) .
The FPA created -and empowered the Federal Power Commission, now
known as the Federal Energy Regulatory Commission (FERC) , to develop a 'comprehensive
and effective administrative scheme for developing the energy potential of our
water resources. The FPA has. been amended numerous times since its inception in
an effort to improve its effectiveness and provide increased development of water
power potential .
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In its role as coordinator of_waterpower development, FERC,
through the FPA and subsequent court decisions, appears to have been given
preemptive authority over state and local government actions. The FPA estab-
lishes a dual system of control , under which state regulations may function only
if they can be enforced without impairing the federal superintendence of the
field.
In 1978 PURPA,.removed barriers. that Congress .believed were
inhibiting the development of small hydro projects. , Section 202 of PURPA
authorized FERC to require that private utilities connect their transmission
facilities- with qualifying hydro facilities. Section 210 requires utilities
to purchase electricity generated by hydro and other small producers and
prescribes rules governing the price that utilities :must pay the developers.
Also, under Section 210 FERC may wholly or partly exempt qualifying hydr6.
facilities with a maximum capacity of 30MW from federal and state laws and
regulations governing rates, finances, and organization of utilities.
In 1980, the Energy Securities Act (ESA) amended several sections
of PURPA, giving FERC discretion- to exempt projects of 5MW or less from all or
part of the licensing process.
A recent federal court decision has struck down some of the
rules. FERC has issued pursuant. to PURPA concerning the rate utilities have to
pay developers for their power and the requirements pertaining to interconnection.
The full impact of the court's action is not yet clear.
In addition to these primary statutes, FERC must respond to the
provisions of -at least five other major federal statutes in the process of
reviewing license applications.
Licensing Procedure for Small Scale Hydroplants
FERC, under the statutory authority of the Federal Power Act and
PURPA, has promulgated comprehensive regulations governing the licensing of hydro-
power projects. The following description outlines the process for small scale
hydropower projects of less than 5MW.
1 . File declaration' of intention -
Failure to inform FERC of potential development of a
site subjects the developer to the penalty provisions -
of the FPA if construction proceeds without a license.
2. Determination of jurisdiction -
FERC reviews the declaration of intention to determine whether -
it has: jurisdiction over the project.
3. Preliminary permit (optional ) -
A preliminary permit allows a prospective developer to
study a potential hydropower site for up to three years
while maintaining priority to file an application for
license.
4. License application .-
The license application describes in greater detail the
dimensions and potential impacts of the proposed develop-
ment. Consultation with a variety of federal , state and
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local resource agencies is required prior to submittal of an application.
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5. Exemption application -
If a potential developer has sufficient real property
interests; he may file for an exemption from .all or part
of the licensing process. Exemption applications, all
other things being equal , have the highest priority in
the licensing process.
F 6. Filing applications with FERC -
Potential developers may file fora preliminary permit,
license application or an exemption application. A
number of regulatory provisions encourage applicants
to file the "best plans" they can the first time they
file. The timing and type of application filed affect
the applicant's initial standing. Notice of all filings
iare published in the Federal Register and in local news-
papers. A public comment period extends for 60 days from
the date of issuance of the notice.
7. Processing and review of applications -
FERC reviews the application and the issues raised by
consulted agencies and in public comment. FERC may
require a developer to address the issues raised during
consultation and comment. Technical analysis of the
advantages and disadvantages of competing applications
by the potential developer is encouraged. Within the
review process, FERC must respond to the mandates raised
by seven other federal statutes ensuring protection of
environmental values.
8. Commission acts on license application -
'; FERC seeks to ensure comprehensive development of a given
t water resource, consistent with protection of environ-
mental values. Competing applications are judged on the
relative merits of development plans, nature' of application,
time of filing of application, and ability to develop. The
project deemed "best adapted" to develop the "full waterpower
potential of a site" will prevail . FERC may issue a license
with conditions attached in order to satisfy some of the
concerns raised by consulted agencies or interested parties.
The issuance of the license is an authorization to proceed,
assuming other necessary permits are obtained.
City Options for Involvement
There are several options for City action in the licensing process,
depending upon the outcome which the City desires. The following is an outline
of the various alternatives for .City involvement.
1 . Complaint
The City may file a complaint with the FERC regarding
anything done or omitted to be done by any licensee,
P public utility or natural gas company .in contravention
of an act, rule, regulation or order.-administered or
issued by the Commission. For example, if the plant is built
by a developer but not in strict accordance with the approved
design, the City could file a complaint to force compliance.
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2. Petition
The City may file a petition for relief under any statute
or authority delegated to the FERC for .any of the following
. .purposes:
a. for the issuance, amendment, waiver or repeal of
a rule by the Commission
b. for the issuance, in the discretion of the Commission,
of a declaratory order to terminate a controversy or.
remove uncertainty
c. for the appeal from the actions of staff which would other-
wise be final .
The City could, for example, file a petition that the FERC
make a declaratory ruling that the Ithaca Falls area not be
developed for hydropower use because of the environmental
impacts involved.
3. Intervention
The City may file a petition for intervention on the grounds
that the City is a consumer of electrical energy from NYSEG
and that it is a protector of the public interest through
land use and zoning control . If granted, the petition to
intervene would allow the City to be a party at any official
hearing concerning the hydroplant and to make official
comments on the record.
4. Protest
Any person, group or municipality objecting to the approval
of- an application, etc. , under review by the Commission may
file a protest. The City could, for example, file a protest
to the construction of the power plant, or it could protest
the proposed design- and suggest modifications or conditions
which should be attached.
It should be noted that the filing of a protest -does not make
the protestant a party to any legal proceeding; a separate
petition to intervene is required for that.
5. Preemption
The City, as a municipality, is provided the opportunity
to preempt a private developer and receive the license itself.
The City would have to file its own application for a license,
have its plans considered at least "equally well adapted" to the site,
prove its legal ability to develop such a site, and be prepared
to proceed with construction within a designated time period,
usually 24 months. A notice of intent to file an application for
a license should be submitted by May 6, 1982 if this option .is
pursued; the City would then have 120 days to develop its application.
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6. Extension
The City could file for an extension to the 60nday public
review period currently going on. Application for exten-
sions must be filed before 4/5 of the time period in question
has expired. Action. by the Commission typically requires 2-3
weeks. A 30- or 45-day extension might be possible for the
City. FERC does not usually grant extensions except under
extenuating circumstances; on-the other hand, the Commission
has recognized that municipalities require a 'longer period
to act than .does a private citizen. If an extension of time
is not granted, then any action by the City must occur on or
before May 6, 1982.
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PRELIMINARY REPORT AND RECOMMENDATIONS
OF THE ENVIRONMENTAL SUBCOMMITTEE
OF THE ITHACA HYDROPOWER COMMISSION
April 6, 1982
The Environmental Subcommittee was charged with evaluating the
environmental impact of the construction and operation of a hydropower electricity
generating plant below Ithaca Falls. Though the Falls -area is privately owned,
its use as a public park and .fishway resource and its status as one of Ithaca's
major natural landmarks makes the future of the Falls area development of great
concern to the citizens of Ithaca.
The Committee recognizes the contribution such a plant would make
to the national and state goal of securing clean energy sources. These benefits
are summarized in an appendix to this report. The benefits of such a plant however
must be weighed against the possible environmental costs.
The Committee ha's identified three major concerns, as, well as other
environmental issues that should be considered in any decision regarding the building
of,a hydroplant at Ithaca Falls. These major concerns are i) aesthetic and scenic
impact on the Falls, J i) the possible adverse effects on fishing and aquatic life
below the falls, and iii) the guarantee of public access to the Falls area and safety
should a plant be built. .
These issues are discussed in the Appendix of this report. On the
basis of site visits of the Committee to the existing Cornell hydro plant and the
Falls area itself and discussion with local fishing experts and local Conservation
and landmark representatives the Committee makes the following recommendations:
1 . The Committee believes that the proposed flow. rates-of 30-32 cubic
feet per second (cfs) by the two potential developers will signi-
ficantly affect the scenic quality of the Falls for nearly 200
days each year. The Committee recommends that if a plant is built
that -the minimum flow be no lower than 50 cfs during plant operation.
2. The Committee believes there is cause for concern- for the effect
of a decreased flow rate on- the passage over the Falls of land
locked salmon and rainbow trout smolts from a major State frye
stocking program in the spring and early summer of the year.
3. There is also reason to believe that low flow rates in the winter
months will increase the amount of frazzle and anchor ice between
the Falls and the plant outflow which might threaten the insect
population that is necessary for the production of fish in the
Falls area.
-2-
4. The Committee recommends that, if a plant is built, it not be
located along the edge of Fall Creek. A creek edge plant site
would detract from the scenic beauty of the Ithaca Falls gorge
entrance and would prevent the movement of people along the creek.
5. The Committee was also concerned that public access to the Falls
by crossing an open channel with fast moving water, might-eventually
lead to fencing and closing public access due to insurance require-
ments on the developer. The Committee recommends that any outflow
channel be covered to avoid unsightly fencing and insurance problems.
For example, the plant might be able to use the old outflow tunnel .
6. The Committee recommends that the City explore ways to guarantee
permanent public access to the Falls and to maintain this site as
a natural scenic and recreation area such as through long-term
lease,- purchase of easements or outright purchase of the property
by the City or State.
7. Finally, the -Committee recommends that for the best protection of .
the Falls scenic and ecological environment, that if a hydroplant
is built, there be some degree of community ownership or control .
-3-
DISCUSSION
Uniqueness: A Scenic Landmark_Within The City
What is not made clear to the Federal Energy Regulatory Commission by
the two potential developers in their application is .the fact that Ithaca Falls
and its gorge is located within the City and adjacent to a residential neighborhood.
The views of the Falls and fishing are within easy walking- distance of the young
and the elderly as well as others in the Fall Creek neighborhood.
Low Flow Impact:
The primary impact of the operation of a hydroplant will be the decrease
of water flow over the falls. Low flow days of less than 40 cfs will increase for
both the Synergics and Cornell plans by from 190-200 days ra-ising the sub 40 cfs
to 270 days or about 9 months of the year. This can be seen in three graphs
(Figures 1 , 2, 3. ) The horizontal axis gives the flow rate and the vertical axis
represents the number of days at a given flow rate, Figure 1 shows the natural
distribution (based on data from the last five years) and Figures 2, 3 show
the Cornell and Synergics operation respectively. What is immediately clear is
that the occurrence of the flows over the falls between 80 and 600 cfs will de-
crease sharply under the operation of either hydroplant and the number of sub
40 cfs days increases in both plans.
What this plan does not show- is that periodic surgency of the falls
-and the plunge pool in the summer, due to scattered heavy rain storms, will not
occur under either plan. One plan that has been discussed by the Committee is for
a plant, if built, not to operate during the summer months for both tourist reasons
and to allow high flows to purge the falls area on those rare days if greater than
50 cfs.
.Fishing:
There are at least three areas of concern as regards the effects of a
hydroplant on fishing along Fall Creek. With the dredging of the north end of
the creek bed for flood control , the best fishing will remain near the falls
above the Lake Street bridge. The location of the plant and its outflow can
affect access of fisherman and movement along the creek. For this reason, the
Committee recommends that ,a plant not be built directly alongside-the creek edge.
The second concern is the effect the low flow over the falls will have
on the passage of land-locked salmon and rainbow. trout down Fall Creek, over the
falls, and into Lake Cayuga. The State DEC has a major frye stocking program up-
stream along the tributaries of Fall Creek. An estimated 200,000 frye are stocked
each year. An estimated 20,000 smolt survive to come down Fall Creek in late
spring to go over the falls on their journey to Lake Cayuga. -Low flow over the
falls of 32 cfs during late April , May and each June, when normal flows might
range from 50-200 cfs, might mean a higher mortality rate of the. smolt in trying
-4-
to get over the rocky cliffs of the Falls. The Committee was unable to obtain
definitive data on survival rate of fish over the falls for different flow rates,
but the matter is an important one for study and concern.
Another possible effect on the fishing is the low flow rates over the
falls during the winter months. There is some speculation that a lower flow
_ might result in a higher amount of frazzle ice in' the plunge pool and that ice
could eventually increase the anchor ice lining the rocks beneath the- creek bed
below the plunge pool . A build up of anchor ice might affect the insect ecology
in this area .and deplete part of the food chain necessary for.fish production.
Insect larvae and other aquatic life live among the rocks along the bottom during
the winter months. For certain species such as the small mouth bass, the plunge
pool in Fall Creek provides a significant supply of fish for the southern end of
Lake Cayuga.
Public Assess:
Continued public access to the Fall Creek gorge from the Lake Street
bridge to the base of the falls is a major concern of the Committee. As was
I already mentioned, the proximity of the falls area to a city neighborhood and
school enables the young "Huck Finn" to find fishing and adventure within easy
walking or biking from many parts of downtown Ithaca. Access not only means
the present Youth Park along Lake Street but the ability to walk along the creek
right up to the base of the falls. As one Committee member put it, "If we can't
get our face wet, we're not close enough." The falls are part of the bicentennial
Circle Greenway hiking trail and the ability to walk into the gorge up to the base
is a unique attraction of this hiking trail .
The Committee was particularly worried that the construction of a
tailrace open channel from the plant to the creek would prompt City and insurance
officials to require fencing around the channel . Fencing and a single foot bridge
over the channel was deemed unsightly and aesthetically unacceptable to the
Committee. Thus we recommend that a covered channel be used or. that the developer
explore the use of the old tunnel that parallels Lake Street.
Some members of the Committee were also worried about required fencing
along the open channel above the falls which might detract from the- lovely falls
overlook area off of Willard Way.
Liability and insurance threats to close or restrict public access to
the falls area, if it is used for industrial purposes, was another worry of the
Committee since similar cases have occurred in the City's Six Mile Creek Water-
shed area.
k
To guarantee public access to the falls over the life of the hydroplant,
the Committee believes some arrangement with a potential developer (if not the City
itself) should provide for public use of the area without legal liability or in-
surance restrictions. One member'has .suggested that the developer (private or
public) deed the site to the City*or State for a natural recreation area as a
...... .. ... .. ... . ........ ............................... ..>,:,......,.,.,..,,>,:..,.........,...
-5-
"quid pro quo" for losing the year .round scenic beauty of the falls. Other
arrangements could involve long-term lease of the land to the City for
natural scenic area or park.
It was also agreed that the land now designated as a Youth Park be
cleaned up.
Noise:
Another potential problem .is plant noise. The Committee during its
visit to -the present Cornell plant, measured 100 decibels at the generator and
over 90 decibels sound level inside the building housing the turbine and generator.
This condition was with only one turbine in "operation. Since both proposed- plants
are closer to Lake Street than they are to the falls, the possibility of noise
leaking out of the building through ventilation duct"s or windows or through the
building itself could detract from the natural ambiance of the gorge setting.
Noise control should be addressed in any plant design proposal .
Architectural Compatibility:
Some members of the Committee felt strongly that the plant building
should be aesthetically compatible with the natural beauty of the gorge setting
and should not stick out visually. Several members have suggested stone or
brick facing material be used, particularly if the building is placed alongside
r the south wall of the gorge.
i
DIS'T,ACEMENT OF FOSSIL FUELS--THE POSITIVE ENVIRONMENTAL IMPACT
. Is the proposed hydroelectric facility at Ithaca Falls worth the sacrifice,
at .least in part, of a•major scenic and recreational resource in the City of Ithaca?
At first blush it may appear not because the- 1.75 to 3 Megawatts peak power it
would generate under current proposals is small compared with the approximately
25MW drawn by each of the City of Ithaca or Cornell University,alone. 'By the same
token, the 8 to 8.6 million kilo-watt hours (kwh) it would produce on the average
annually seems small compared with the 150 million kwh (approx) used by each of
the city or university,alone.
However,small scale hydroelectric facilities have a number of virtues and
benefits. These include:
1. The fact that such plants can be developed and controlled on "a local scale--
by "a city,university/institution or business industry.
2.Locally controlled hydroelectric plants are not vulnerable to the policies and
politics ofoutside suppliers; the resource cannot be depleted or delieberately with-
held.
3. Small scale_hydroplants avoid the* large scale land use impacts of large nuclear_,
fossil and hydro facilit:4es. -
4. Small hydroplants, though each indivdually displacing only a small fraction of
i, fossil/nuclear-generated power can have a significant cumulative impact in displacing
these health and environmentally hazardous sources.
5. The development of a small hydroplant by one community/instituU on/business
can serve as both an example and incentive to others, and help set in motion more
serious consideration of energy alternatives in general by federal/state governments
and utilities.
6 In its application, Cornell University stated that its" proposed facility
t; would displace 4000 tons of coal annually that NYSEG would otherwise have had to
burn. Over the approximate (low side) 30 year lifespan of the plant, 30x4000-12000O
tons of coal would be displaced--another "cumulative" benefit. Synergics, the "Ithaca .
Falls Development Assoc." describes its proposal in terms of .oil displa cement--10800
barrels annually or 324,000 over 30 years would potentially be displaced.
CU (Application p Eiv-Ella,EII-Ella) states: "The most beneficial environmental
effect of the proposed hydroelectric plant is the reduction in coal-fired pollution. The
I{ plant will produce approximately 8,600,000 kilowatt hours a year, using a method of
generation that,along with solar power, is considered the "cleanest" type of energy.
This clean energy will directly replace about 4000 tons of" coal that New York State
Electric and Gas would have to burn to supply this amount of energy. Although the
energy the hydroplant would produce is only a small percentage of NYSEG's total output,
it is environmentally significant z'eductioa in coal use and its associated sulfur,
._ nitrogen oxides and carbon monoxide pollution./new para. The proposed hydropower
plant would produce enough electri(ity to equal about 5% of the University's consumption.
Togehher with the upstream Cornell University Hydroplant I, the electricity generated
by hydropower at Fall Creek, would supply almost 10% of the University's consumption."
P Synergics states:"If the project is not approved, the additional power
generated from the proposed installation would be generated from fossil fuel. The
proposed plant will 4ave approximately 10,800 barrels of oil per year".
In a letter to Henry Doney dated 12/31/81 City Planning Director H.M Van Cort
stated: "Anything that promises to reduce dependency on non-renewable resources deserves
to be given a chance - to prove itself".
Alderman Dan Hoffman (5th Ward) in a statement before the Ithaca City Energy
Commission's January 21 meeting noted: "Most of our electricity in New York State. . .is
now generated by large coal,oil and nuclear-powered plants. . Coal and nuclear especially
have devastating health and environmental impacts associated with their mining and use
as 'fuels. . I 'bel`ieve we must find safer alternatives that can reduce our dependence on
fossil fuels--the sooner the better. .. -I think the future of- fossil fuels as a reliable,
affordable energy source is uncertain,at best,due to economic-,political and supply
questions beyond our control. Development" of. local,renewable power sources could give
our community a new measure of self-reliance and security that could be invaluable in.
the event of major disruptions of energy supply". Hoffman ended his statement by noting
that while Fall Creek may not .be the right or- best location for hydroelectric power,"we
should guard against an attidtuee that fails to take- into account the big picture, that'
_protects our own backyards for now, but which avoids the unpleasant consequences of our
present energy path"..
Problems Associated With Fossil Fuels
1. Carbon Dioxide. (CO2) Build tip--considered by some experts to be the worst and
least manageable problem associated with coal combustion. "The Greenhouse Effect"--C62
content in the atmosphere has increased 7% since 1958 and 15-25% since 1800 (the begin-
ning roughly of the- Industrial Age). The greenhouse effect is when CO2 allows incoming
shortwave radiation to pass through thethe earth and traps outgoing infrared heat radia-
ted by the earth. Unless this is offset by other climate-related factors, increased stmos_
pheric concentration of CO2 will eventually raise average temperatures of *the earth's surface.
It is estimated that a doubling of atmospheric -CO2 combustion could raise average global
temperatures almost 3 degrees C (5.4F). and increase the winter average in the north polar
region 7-10 degrees. CO2 build up could cause changes in wind direction and speed,ocean
currents and precipitation patterns. Polar ice could melt,sea levels rise forcing gradual
evacuation of heavily populated coastal areas. Agricultural patterns could change as well.
According to the New York State Energy Office in its March 1980 State Energy Master
I Plan (chart attached), the generation of 1000 kwh of electricity by coal would result in
the emission of .42 lbs of Carbon Monoxide CO), and by oil 36 lbs. CU's 8,600,000
kwh would displa4be .3612 lbs of CO( I:8"-tons�'cr�E-ited-bY -boar and-3092_(1.5 tons_ ) .created
by oil. For Synergies, the CO emission displacements for coal and oil are 3360 and 2880,
rrspectively. Those are annual figures;multiplied by a 30 year lifespan, a yet more
significant is obt
gures n d.
(fi A aTn 00 by dividing 8600000 qnd 80000 by 1000 and multiplying the
,; results, 8600 and 8000 by the amounts given in the State Energy Master Plan--SEMP).
.2. Acid Rain. Effects on aquatic ecosystems,soil systems,vegetation ,buildings and
sculptures;also heavy metals released by acid rain may effect human health. (EPA 14-18;
. 24-27).
According to The Energy Factbook (p,39) by California University::Professor of
Electrical Engineering Richard C. Dorf, the U.S. produced 650 million metric tons of coal
in 1977. For that same year, the Environmental Protection Agency (EPA) in its booklet
"Acid Rain--ref. above) stated that 27000000 metric tons of Sulfur Oxides(SOX), one of the
two primary ingredients of acid rain,were put into the atmosphere by U.S. "man-made" ..
sources. 70% of that, or 18,900,000 metric tons resulted from coal combustion. (6 % of
that was electric generating stations--12,285,000 tons--slightly u&der half). Petr�um
combustion as responsible for 16% of SOX emissions approximately 4,320,000 metric tons.
Sate Energy Office figures show that 1060 kwh of coal-generated electricity.
caused 'emissions of 30,18 lbs of SOX; of oil generated, 11,58 lbs of SOX. Again,multiplied
:by 8600, the CU displacement figures are 259,548, lbs(130 tons) for coal; 99,588 (50 tons)
of SOX for oil. For Synergies, yearly SOX displacement figurs for coal and oil,respectively,
are 241,000lbs and 92,640 lbs.
( A metric ton is 2,205 lbs or 1000 kilograms;a ton is .907 metric tons).
The EPA states that 56% of all NOX emissions in the U.S. were from "stationary" as -
opposed to mobile sources (44%); one-half of the emissions from stationary sources were
i. fossil-electric plants, or 28% of the total. This comes out to a total of 6,400,000 metric
tons out of a total of 23000000 metric tons of NOX.
For NOX emissions per 1000 kwh, the SEO gives the same figures for coal and oil, ,
7.64 lbs._ Displacement of either by CU's planned generation would prevent 65,704 lbs of
emissions (appro 33 tons) and 61,126 for Synergies.
emEff cts of sulfur oxides on human respiratory systems -contributory to lung cancer,
emphya e c
For every ondo coa urn sm fcufistFeetml,Z grleee a sposoalof coal waste afterwards,
3
5. Coal mining is one of the most hazardous of occupations. Coal miners have
suffered 2 times as many disabilities as other high-injury industries. At the rate of
fatal accidents occurring in the 19601s, a person working a lifetime in an underground mine has
a Lin 10 chance of being killed on the job. Black Lung contributes to 3000-4000 deaths in the
U.S a year.
Nuclear--briefly
Although nuclear generation would not be directly displaced by the proposed facility,
there are 5 nuclear plants currently "operating" in NYS (3 are shut down for varying periods
of time ranging from a month to a year) and 2 being built--both of which have had vast cost
overruns. NYSEG owns 18%, of the under construction(and .controversial Nine Mile Two.
1. Proliferation--it is increasingly being seen as doubtful as to whether the "peaceful
-and "warlike" atom can ever be completely separated. Related concerns are nuclear diversion,
theft, getting into the hands of terrorists etc.
2. Radioactive waste disposal--longevity of toxicity of fission products, incertainty
regarding best geologic medium,wate encapsulation storage etc.
3. Accident possibilities--Three Mile Islan�,Brown's Ferry, RE Ginna. Smaller mishaps
tesulting sometimes in "small" radioactive release. Long outage periods etc.
4. Low level radiation in nuclear fuel cycle from mining and milling to transportation
of waste from reactor. R. Pohl has done work showing Radon : gas"decayed" from Thorium causes
lung cancer.
5. occupationa
l exposure. Incidents of radioactive spills, "hot" areas, deaths of*
Uranium miners--not same magnitude as coal but lung cancer has taken or is expected to
take 600-1100 according to Union of Concerned Scientists.
Small Hydro Potential In NYS
The State Energy Master Plan (SEMP) states that the potential for small scale
hydro in NYS is 725MW according to its Base Plan,with an additional potential mf 325 MW,
for a total of 1050MW, the size of one large power plant. According to the New York
State Energy Research& Development Authority (NYSERDA), 1129 MW of hydro can be developed
j at 05¢hour or less. The NYS Energy Office estimated that 1050 MW of small hydro can
be developed by 1996 at a cost of 7.5¢/kwh.
Among the potential sites listed in a study by the Polytechnic Institute of
New York were 7 in Tompkins County including.the .Beebe Lake hydro plant,which has been
re-activated, and the Ithaca Falls site, the largest of the 7. The PINY study was used
as a basis by NYSERDA and the NYSEO.
I
'REFERENCES
NEW YORK STATE ENERGY MASTER PLAN AND LONG-RANGE ELECTRIC AND GAS REPORT:Final Report
March 1980 NYS Energy Office--James L. Larocca , Commissioner
NEW YORK STATE ENERGY MASTER PLAN: Master Plen II DRAFT Report August 1981
THE ENERGY FACTBOOK Richard C.' Dorf,University of California 1981
ENVIRONMENTAL QUALITY: THE ELEVENTH ANNUAL REPORT OF THE COUNCIL ON ENVIRONMENTAL QUALITY
December 1980
ENERGY: THE NEXT TWENTY YEARS--A Report Sponsored by the Ford Foundation and Administered'
by Resources for the Future 1979
OUR ENERGY:REGAINING CONTROL Marc H Ross and John H Ailliams 1981
ANEW ALTERNATIVE TO COMPLETING NINE MILE POINT UNIT 2 NUCLEAR STATION: Economic and Technical
Analysis Environmental Defense Fund 11/81
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION COMPETING APPLICATION FOR LICENSE FOR A
MAJOR WATER POWER PROJECT, 5 MEGAWATTS OR LESS Cornell University 1/28/82
Ithaca Falls Development Association
(Synergies) 1 :/82
AIM
FIGURE.V-F-29
IMPACT OF ELECTRIC GENERATION PLAN ON ENVIRONMENTAL RESIDUALS
A f 1978 1984 1994
Non-Radiological
? Sox (1 55 tons) 5.520 5.527 6.61'
NOx(10s tons) 2.687 2.412 3.22
AA
0 CO (104 tons) 1.418 1.344 1.9a
Particulates (104 tons) 4.698 5.403 8.32,
4.953 4.573 6.18,
J Hydrocarbons (103 tons)
Solid Waste-Ash'(105 tons) 8.340 17.26 44.17
• Solid Waste-Sludge(10s tons) -- 1.607 40.30
Solid Waste-Land Use (acres) 15.85 35.91 161.2
Thermal Rejection-Air(1014 Btu) 1.505 1.371 2.29(
` Thermal Rejection-Water(10" Btu) 6.390 6.172 7.58
Radiological
Liquid Effluents' (102 curies) 17.64 18.79 21.29
Atmospheric Gaseou52(103 curies) 67.32 69.54 82.41
Atmospheric Particulates(curies) 5.694 4.891 .7.49
Lowy-level Waste, Volume(103 cubic meters) 3.817 3. .82'
Low-level Waste, Activity(104 curies) 1.618 1.5448 2.04,
Spent Fuel, Volume (cubic meters) 73.20 73.38 90.78
Whole Body Dose (102 Man-rem) 3.547 3.560 4.39
f -
'Tritium and non-tritium.
2Tritium, C-14, Radioiodine, Noble Gases (Krypton-85 and others).
FIGURE V-F-30
ENVIRONMENTAL RESIDUAL FROM GENERATION OF 1000 KWH ELECTRICITY
i Fossil
j
Coala RDF- Oilb
Wood 1 2 3 Coal 1 2 3
Water-Thermal (106-BTU) 6.0 5.0 4.7 5.0 5..2 5.1 4.4 -
Atmospheric
Particulates (Ibs) .38 2.24 ,3 2.3 .32 .94 .66 .6
NOx(Ibs) 7.52 7.64 5.87 7.64 5.54 7.64 2.78 8.2(
Sox (Ibs) .92 30.18 5.87 16.24 6.50 11.58 7.40 1.7(
HC (Ibs) 3.1 .12 .12 .12 - .1 .1 .61
CO (Ibs) 3.1 .42 A_ .42 - .36 .32 1.81
Thermal (106 BTU) - 2.0 1.7 2.0 - 2.2 1.4 11.7
Solid Wastes
Ash (Ibs) 52.9 108.0 102.0 108.0 178.0 - - -
Sludge(Ibs) - - 342.5 - 298.1 - - -
- Nuclearc
1 2
Radiological
Liquid Effl.-Tritium & Non-H3(10-6 curies) 12.2 11.9 59.2
Low-level waste volume (10-4 cubic meters) 1.4 1.4 0.6
Spent Fuel Volume (10-b cubic meters) 1.7 1.7 1.7
Atmospheric Gases (10-4 curies) 10.4 10.2 19.2
Atmospheric Particulates(10-8 curies) 3.5 3.5 0.8
Dose-Whole Body-Population (10-6Man-rem) .8.5 8.3 8.5
Thermal-Atmospheric (106 BTU) 6.8 - -
-Water(106 BTU) .12 6.7 6.7
'Coal Plants: 1-Existing;2-New Source Performance Standards;3-Conversions from oil.
boll Plants: 1-Existing Steam; 2-Old NSPS; 3-Gas Turbines.
cNuclear Units: 1-BWR;Cooling Towers, New; 2-BWR, Once Through, New; 3-PWR, Once Through, New.
dH3, C14, Radioiodine, Krypton-85, Other Noble Gases.
159
Energy and the Environment 181
D ANNUAL EMISSIONS OF A 1,000 MEGAWATT COAL-FIRED
POWER PLANT USING EASTERN U.S.COAL
Cast Gaseous and Liquid
r of Dollars) Carbon Monoxide(Tons/Year) 640
Carbon Dioxide(Tons/Year) 6,710,000.
5 Sulfur Oxides(Tons/Year)
.7 No Controls 111,000
Wet Limestone Scrubbers 15,000
7 Aritrogen'Oxides(Tons/Year)
9 No Controls 20,300
Wet Limestone Scrubbers 17,900
r 16 Released Particulates(Tons/Year).
32 No Controls 45,200
Precipitator 5,226
Solid
Fly Ash or Slag(Tons/Year)
brced draft No Controls 280,000
it and cool- Wet Limestone Scrubber 89.7,000
' y climates.
Thermal
ugh finned Waste Heat (Megawatts)
ive-to con- No Controls 1,560
to the cost Wet Limestone Scrubbers 1,860
360
a 340 f
87 Billion
00 0 � 00
o go
320
c
A
v
c
During the past decades, the combustion of
_ fossil fuels has increased the atmospheric con-
3 00 centration of carbon monoxide from 300 parts
per million (ppmy.to 320 ppm in 1970. The
dotted line projects the increase of the mean
rojected) value of CO2 in the atmosphere.A debate con-
tinues regarding the effects on the earth's
' climate of this increase of CO in the atmo
for fossil 1955 1965 1975 1985 1995 sphere.
L.
77
... ;..,....
HYDROPOWER COMMISSION
Preliminary Report of the Proposals Committee 1
Introduction•
The Proposals Committee reviewed the Environmental Committee's report on
the proposed hydroelectric facility at Ithaca Falls and identified five primary
areas of concern. These. concerns were reviewed and mitigating measures were dis-
cussed. A "Best Possible Design" plan was formulated, incorporating the most
desirable mitigating measures identified.
Each proposal was then compared to this "Best Possible Design" and the
specific areas of -concern raised by the Environmental Committee. Proposals were
assigned a numeric value of 1 , 3, or 5, depending on the extent the areas of concern
were addressed in each, proposal . A value of 1 indicates the proposal does not
address a given area of concern at all . A value of 3 indicates the proposal does
address a given area, but not, in our opinion, sufficiently. A value of 5 indicates
the proposal addressed a given area of concern as well as the "Best Possible_ Design".
Proposals are evaluated only once for each concern, even though the concern may be
expressed under several topical headings.
Major Areasof Concern:
1. Scenic Impacts
a. Reduced flow rates over the Falls
b. An increase in the number of days of reduced flow
c. Uniqueness -of the Falls within the City
d. Design, placement, and external appearance of the powerhouse
2. Aquatic Life
a. Increased mortality of migrating salman smolts
b. Decrease in quality of habitat in plunge pool and adjacent stream bed
C. Reduced access by aquatic life to plunge pool through the. riffles
area due to lower flow rates
d. Increase in anchor ice formation and subsequent negative impacts on
aquatic invertebrates
3. Public Access
a. Siting of plant away from streambank to minimize negative impacts
b. Access over tailrace by visitors and fishermen
c. Access to plumbers pool and streambank area to east .and west of pool
d. Formal assurances of continued public access
4. Safety and Noise
a. Open tailrace and open channel upslope at� powerplant, use of Ezra's
tunnel
b. Placement and design of powerhouse
c. Variable flow rates of water over dam; water surges
d. External noise levels at powerhouse during operation
-2-
5. Historical Archeological Resources
a. - Preservation of the historical character of the area
b. Sensitivity to archeological potential of area and- preservation of�
any artifacts found during development
"Best Possible Design"
1 . Scenic
a. Flow rates increased from a' minimum of.32 cfs to 50 cfs to mitigate
adverse scenic and aquatic impacts associated with low flow conditions
CU - 3. Syn. - 3
I
b. Powerhouse located as close as possible to embankment in southwest
corner of development site
CU - 3 Syn. - 1
c. Exterior treatment and landscaping used to blend facility into
natural. surroundings, Architectural and landscape designs should
be subject to review and approval of City Design Review Board
t J PP Y 9
CU - 3 Syn. - 3
d. Penstock from the end of Ezra's tunnel to the should
powerplant
be buried to prevent vandalism and defacement
CU - 3 Syn. - .3
e. Switchyard should be built as an appendage to the plant, with
exterior treatment and landscaping
CU - 1 Syn. - 5
f. Transmission Line from the switchyard to utility interconnection should
be underground
CU - 3 Syn, - 1
g. Low flow release weir should be placed to maximize distribution of
Water over falls during low flows. Associated structures may be
used on creekbed between dam and fall 's edge to ensure even dis-.
tribution of low flow water over falls
CU - 1 Syn. - 1
2. Aquatic
a. "Best available mitigating technology" be used to reduce mortality
of migrating salmon smolts through hydro facility, based on NYSDEC
recommendations
CU - 3 Syn. - 3
r � b. Continued monitoring and research of facility's impact on fisheries
resource. Subsequent changes in design and operation based on re-
search findings and NYSDEC recommendations,
CU - 1 Syn. - 1
c. Increased flow to 50 cfs will mitigate impacts on plunge pool and
downstream riffle zone and those associated with anchor ice
d. Tailrace shall be designed to enter stream above plumbers pool at
an altitude so as to minimize negative impacts on streambed morphology
-3-
and. character of pl.umber's pool
CU - 5 Syn, - 1
3. Public Access
a, Siting of powerhouse as close as possible to embankment will
minimize access restrictions
b. Tailrace should be covered and buried below grade, or area regraded
to accomplish the same, to eliminate access problems of safety
P concerns
CU - 1 Syn. - 1
c. Access road to powerhouse and. to intake structure (if needed) should
be unimproved and incorporated into landscape design plan of area,
subject to review and approval by City Review Board. No parking
lots are recommended
CU - 3 Syn, - 5
d. All land area surrounding the powerhouse, associated developments
and the Falls itself should be deeded or otherwise formally trans-
ferred to the city as ,a public scenic and recreational resource
{ CU - 1 Syn. - 1
i
e. The area between the Falls and the Lake Street bridge should be
improved and subsequently maintained by the developer to increase
I its recreational potential , accessibility and safety
CU - 3 Syn. - 3
4. Safety and Noise
a. Open channel upslope of powerplant should be replaced by penstock
to minimize safety concerns
CU - 1 Syn. - 5
b. Ezra's tunnel should be utilized, with appropriate provisions
to deny unauthorized access, to preserve historic character of site
CU - 5 Syn. - 3
c. Tailrace should be buried, with appropriate provisions at its terminal
end to prevent unauthorized access and to minimize safety concerns
associated with an open.tailrace
d. "Best available control technology" be used to minimize noise
eminating from the powerhouse in order to meet city noise ordinance
requirements
CU - 3 Syn. - 3
Ir
e. Automatic bypass system be used to prevent a surge of water over
the -dam in the event of an automatic turbine shutdown
CU - 5 Syn. - 1
f. An audible warning system be installed to warn area users of in-
creased flow rates associated with plant shutdown
CU - 5 Syn. - 1
COMPARISON OF PROPOSED HYDROPOWER PROJECTS
Issue
Cornell University. Ithaca Falls Development Association'
,
I. Project proposal
1. Plant energy capacity 1. 3 Megawatts 1. 1.75 Megawatts
2. Estimated annual .energy production 2. 8,600,000 kilowatt hours 2. 8,000,000 kilowatt hours
3. Generating units 3. Two generating units: 3. Two generating untis:
a. 2000 - KW capacity synchronous unit a. 750 _ KW capacity unit
b. 1000 - KW capacity synchronous unit b. 1000 - KW capacity•unit'
4. Turbines 4. Two turbines, a Francis horizontal type 4. Two turbines, both Ossberger crossflow types
and a crossflow type
S. Design head 5. 145 feet net _ 5. 1 150 feet net
6. Hydraulic capacity 6. 300 cfs;.minimum operating flow is 6. 197 cfs; minimum operating flow is approx-
approximately 20 cfs imately 8 cfs
7. Use.of existing tunnel and walkway 7. Tunnel would be cleaned, deepened and 7. Tunnel entrance will be sealed and penstock
utilized; a new intake structure will laid in tunnel; existing intake structure
be installed; walkway will be rebuilt will be modified to connect with penstock; .
walkway will be removed
8. Use of.open channel 8. The channel will be widened from existing 8. The penstock will lay .in the open channel
6-foot width to-10 feet; new gate structure
will be constructed at end of channel
9. Penstock 9. . 670 feet in length; diameter of 4.75 feet; 9. 1065 feet in length; diameter of 5 feet;
supported above ground by anchor blocks flexible as to whether to bury penstock
and saddle supports or leave above ground
10. Power plant building 10. 59 ft. wide, 28 ft. long, 38 ft. high; 10. 60 ft. wide, 30 ft. long, 16 ft. high;
much of building underground; located located at junction of creek and hillside;
against adjacent.hillside behind park willing to consider an alternate location;
will design observation deck on roof of
building
i
Issue Cornell University Ithaca Falls Development Association
Environmental Impacts
1. Rate of flow over Ithaca Falls 1. Minimum flow of 32 cfs; would not remove 1. . Minimum flow of 30 cf's; would not
any water from creek when flow 'is less remove any water from creek when flow is
than 52 cfs; would remove 300 cfs at less than 38 cfs; would remove 187 cfs
maximum capacity at maximum capacity .
2.. .Water quality 2..` States that "no significant impact on 2. States that "the proposed operation of
dissolved oxygen and temperature in the. hydrolectric project will not re-
the stream pools below the Falls is duce the waste assimilitative capacity
expected. Preliminary determination or significantly lower the existing
by the NYSDEC is that water quality dissolved oxygen content of the creek."
will, not be a project related issue."
3. Vegetation 3. Very slight impact; most impact during 3. Anticipates no impact beyond construction
construction; some trees would be re- short-term impacts
moved as a ,result of construction access,
access road, and parking area; land-
scaping proposed
4. Aquatic life 4. Potential for negative impacts exists; 4. Anticipates no significant effect on habi-
entrainment, reduction of river flow tat conditions; may install screen to
from Plunge Pool to Plummers Pool, and reduce entrainment; will work with
possible changes in temperature and NYSDEC to reduce impacts
DO are primary problems; plans in-
stallation of"baffles or screens during
peak periods of smelt outmigration and
return of water to creek upstream of
Plummers Pool to minimize impacts
5. Non-aquatic life 5. No significant effect expected 5. No displacement anticipated
6. Aesthetic quality of area 6. Primary impacts are reduction in flow over 6. . Indicates impact to be-primarily a result
falls and introduction of building into of reduction of flow over falls, which it
area. Reduction in flow partially mitigated proposes to mitigate by maintaining min-
by maintaining minimum flow of 32 cfs. In= imum flow of 30 cfs. Building originally
troduction of building offset by an unob- placed in a very prominent location with
trusive siting, landscaping and exterior roof designed as an observation deck
treating of building. Switchyard, fence and
parking area will be additional intrusions
Issue Cornell University Ithaca Falls Development Association
7. Fishing 7. Access of fishermen will be enhanced by 7. Access of fishermen not fully addressed;
construction of bridge across tailrace; fishing quality may be reduced in Plunge
fishing quality may be reduced in Plunge Pool but improved in tailrace and
Pool but may be improved in tailrace and Plummers Pool
Plummers Pool
8. Other recreational activities 8. Sightseeing would be affected by reduction 8. Sightseeing would be affected by reduction
in flow over falls; use of Youth Park may in flow over fal.ls but improved if obser-
be reduced by construction of access road vation deck constructed; use of Youth
and parking area Park will be enhanced by construction of
facilities at developer's expense
9. Historical integrity 9. Site has history of hydropower use; would 9. Site has history of hydropower use; would
utilize existing tunnel and improve the close existing tunnel; willing to work with
walkway City to document historical resources
during construction; willing to develop
exhibits comparing past use and future
use of site
10. Noise 10. Soundproofing of building to be implemented 10. Soundproofing of building to be implemented
11. Energy production 11. 8.6 million KW hours would displace 4,000 11. 8 million KW hours would displace 10,800
tons of coal per year barrels of oil per year
I. External issues
1. Taxes to City 1. No taxes paid; recently a mention that per- 1.' Assuming an assessed value of $2.5
haps a payment in lieu of taxes could be million and a City tax rate of
provided $12.50/1000, annual taxes would 'be
$31,250. Possibility exists for a
royalty payment in lieu of taxes which
could generate more revenue
2. Zoning approval required 2. Special permit required 2. Variance or re-zoning required
3. Jobs created 3. No new jobs anticipated 3. One part-time position anticipated
' 4
Issue Cornell University Ithaca Falls Development Association
11. Tailrace 11. Excavated area 100 ft. long, 30,40*ft. wide, 11. Very small tailrace shown; water dis-
and 10 ft. deep would serve as tailrace; charged directly into Fall Creek
concrete walls likely along sides; wooden
footbridge proposed for pedestrian access
across tailrace
.12. Maintenance accessibility 12. Access road provided; entrance to power 12. No access road provided; entrance to
plant through roof hatches power plant by doorway on 'south side
of-building
.13. Switchyard 13. Separate switchyard to be located adjacent 13, Switchyard made an.appendage to
to parking lot; enclosed by fence to prevent building
trespassing; transformer to be provided
14. Transmission lines 14. 8.3-KV cable to be placed underground be 14. 8.3-KV cable to be placed underground
tween power plant and switchyard, and be- between power plant and Lake St.
tween switchyard and Lake St.; utility
pole to be placed on east side. of Lake
St., where above-ground connection will
be made to NYSEG grid on west side of -
Lake St.
15. Parking 15. Access road and parking lot adjacent to 15. No access road or parking area provided
power plant to be.provided; parking for for power plant
4 cars
16. Landscaping - 16. Landscaping will be used to screen building 16. Landscaping to screen building and to '
and parking area; no plan included enhance park to be provided; no plan
included
17. Project cost 17. $3,800,000 17. $3,000,000 (does not include acquisition
of rights to develop)
18. Construction period 18. Approximately 18 months after issuance of 18. 24 months after issuance of license
license
April 13, 1982
TO: Hydropower Commission
FROM: City Involvement Committee
Our committee has 'considered various issues concerned. with City involvement
in hydropower development in Fall Creek. In particular we have considered the
economic consequences to the City of development by Synergics, or .Cornell, or
direct City ownership.'
We have had communications from Synergics and Cornell and a luncheon meeting
with Henry Doney, Director of Facilities-Engineering at Cornell. We have also
communicated with George Oliger of the engineering consulting firm of Parsons,
Brinckerhoff, Quade, and Douglas. We have also consulted with the City controller.
It is our conclusion that it would be financially feasible for the City to
build and own the hydropower plant. Further, even if the City decided at some
later date not to exercize that option, its bargaining position relative to the
other developers is considerably strengthened if it proceeds towards such owner-
ship. Consequently we recommend that the City file with FERC a letter of intent.
to apply for a license. We further recommend that the City begin formal negotia-
tions immediately with Cornell University to see what possible mutually satisfactory
arrangements can be made for ownership and operation of a hydropower plant in Fall
Creek.
City Hydropower Commission
April 13, 1982
Cost and Payback Considerations-:
City Owned Plant
City construction of a hydropower plant would require a cash invest-
, ment 'in our estimation of between $3.5 . and $4:0 million . We base
these estimates on the Cornell plan , which we feel to be reasonable
and representative of such an undertaking. In our cash flow and pay-
back analyses we used both the $3.5M and $4.OM. figures as ` the.. cost
of construction , including any land purchase price . The design and
licensing costs are not included in these estimates .
According to the City Controller' s Office, the most reasonable method
of financing the project would be through a bond issue . The Local
Finance Law sets the useful life of- a utility project at 30 years ;
hence the bonds would be retired over a 30 year period. The interest
rates for such bonds vary weekly, with the most recent City issue
i` done in late January at a rate of 9 .4%. The Controller' s Office
estimates that current rates would fall between 9 . 5% and 10. 07o.:
At the present time, the City is at 50% of its bonding capacity ;
however it may not be necessary. to include a hydroplant issue within
this limit due to the revenue producing nature of the project .
The attached schedules are simple models of estimated cash flows and
'payback periods for plants costing $3. 5M and $4. OM with a flow rate
of. 32 cfs and 50 cfs . In order to produce these schedules the follow-
ing assumptions were made :
1. The chart for energy production developed by Ben Nichols
was used for obtaining the power generated at the two flow
rates. The 32 cfs power generated is assumed to be 8, 600 ,000
kWh annually and the 50 cfs power is assumed to be
f 7,962, 500 kWh annually.
2 . Power generated is assumed to be constant through -the life
of the project.
3. The selling price is assumed to be 60 per kWh.
4. Water rights' are priced at 5% of gross revenues.
5 . Operating costs are set at $25,000 per year ; fixed through
the life of the project.
6. Inflation (and the time value of money) is not considered
in these . schedules. It is assumed that any change in variable
costs will be offset by changes in the selling price of power.
Schedules I and II reflect 'a project where the bonds are repaid on
a level annual basis of $133, 333 principal paid per year plus interest.
This was the method suggested by the City Controller's Office. The
breakeven points noted show where the project ceases to cost any
additional money and shows a cumulative profit.
........ ... .................. ....... ...... ...\................\...1.I.......,...\.............................\........\...\..i.J\)\).•\>.):1:i.1:):),I:1:1.1.1:>:1f\!).\.1.\..\I\:.\e\n.\.\.\...\..n\.\.\.\...:\)::Q
A second form of payback analysis was also done where no additional
money was expended by the City after the initial costs of construction .
I.n this method, after water rights and operating expenses were deducted
and the annual bond interest was paid, the balance of the revenue
was used to retire as much principal as possible. Since the interest
costs are so high in the beginning pf the payback period a relatively
small principal payment is all that can be made, making the total
interest cost over the life of the bond issue larger. The $3.5M
plant begins to show a profit in year 14 .at 32 cfs and in year 18
at 5.0 cfs. The $4 . OM plant shows a profit in. year 19 at 32 cfs and
in year 28 at 50 cfs.
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Draft David Zwiebel April 6, 1982
Economic consequence to city of Ithaca- from hydropower
plant development at Ithaca Falls
I . Cornell University owns and operates plant
1 . University exempt from taxes - no tax gain
2. In lieu of taxes, as a aood neighbor, university makes
some contribution to city.-
3. University improves and maintains recreational facility -
Youth park, senic area, parkina lot, paths, fishing areas.
NET : A. Smallest economic. gain for city
B.- most limited ability to -influence design and .construction
criteria.
Problems: University in strongest bargining position all
other factors beinq equal.
II .Synergics or other pri-ate developer owns and operate(s/ plant.
1 . Developer pays significant taxes. �� ^"
2. Huge tax advantage for investors allows developer margin a��d
to improve and maintain recreational area.
3. With chance in tax .benefits for investors after seven years,
developer has great interest in selling the facility to the
city at a good price in direct exchange for city bonds
(no marketing fee)
4. developer needs city support in challenge to Cornell application.
NET : A. Largest economic gain for city
B. Strong position to influence design, construction,
and operation criteria.. -
-C. City. ends up with plant at lowest possible cost.
Problems : Developer fails to complete contract or is sig-
nificantly delayed by extended litigation with Cornell .
ITI .City owns and operates plant
1 . City receives all revenues after costs - small short term _
gain - substantial long term gain.
2. City in complete control of balance between economic
incentives and environmental impacts.
NET : A. Si.anificant more gain than by Cornell development -
sliahtly less gain than by private development.
b. Greatest ability by a large margin to influence design,
construction. and operation criteria.
Problems : Land ownership litigation with Cornell
QSSump{wn a� "Si` by C'�y