A Bay Journal article (2017-12-05) reported that the Chesapeake Bay Foundation (CBF) and The Nature Conservancy released a study on the role Exelon should play in addressing the water pollution issued caused by the Conowingo Dam. The study, conducted by Energy+Environmental Economics and the Water and Power Law Group, found that the dam generates between $27 million and $44 million annually in additional revenue (beyond industry standards). Based on those results, CBF and The Nature Conservancy argued that Exelon can play a role in mitigating the pollution caused by the dam’s reservoir while still remaining profitable. The article contained comments from both environmental groups and Exelon:
An Exelon spokeswoman responded with a statement disputing the study’s estimates of the dam’s future revenues and profitability, saying they are based on “flawed assumptions and theories.” Deena O’Brien, the spokeswoman, said that the company is committed to being a good neighbor, but shouldn’t be held accountable for pollution passing through the dam.
“It’s important to note that Conowingo’s operations do not generate sediment,” O’Brien said. “Most of the sediment that impacts the Bay comes from upstream sources. As such, the regional sources of sediment across the basin should take joint responsibility for the issue, not a single company or entity.” …
“We are not looking to have Exelon be responsible for everything that is no longer being trapped because of the reservoir being full,” Alison Prost, Maryland director of the Bay Foundation, said in a conference call with reporters.
Rather, said Mark Bryer, the conservancy’s Chesapeake Bay director, the groups want Exelon to mitigate the dam’s impact in two different ways — by funding some pollution reduction measures elsewhere that would offset what’s now being passed downriver, and by altering the flows of water through the dam.
The article also noted that the public has until January 15 to submit written comments on Exelon’s Conwingo Dam relicensing application with the Maryland Department of the Environment (MDE). MDE’s approval is the final permission Exelon needs to complete the federal/state relicensing process. The public should send comment to Elder Ghigiarelli, Jr., Deputy Administrator, Wetlands and Waterways Program, Water and Science Administration, Maryland Department of the Environment, 1800 Washington Boulevard, Suite 430, Baltimore, MD 21230, or email them to email@example.com.
A CBF press release (2017-12-05) provided greater detail on the the environmental groups’ point of view :
A new study commissioned by [CBF] and The Nature Conservancy (TNC) shows Exelon Generation Company can mitigate a substantial portion of environmental impacts caused by its Conowingo Dam operation, while continuing to make a healthy profit.
“The good news that comes with this report is that Conowingo’s environmental performance can be brought into the 21st century with effective mitigation measures while the dam continues to provide low carbon energy and Exelon receives a reasonable return on its investment,” said Mark Bryer, TNC’s Chesapeake Program Director. …
“More pollution will come through the Conowingo Dam and into the Bay than scientists previously calculated,” said CBF President Will Baker. “Exelon has the responsibility and revenue to pay for its share of the solution.” …
Recent studies affirmed that while most of the sediment and phosphorus in the dam reservoir originates upstream, the dam itself also worsens downstream water quality because it alters the form of the sediments and phosphorus and the timing of their discharge. Other studies have shown that Conowingo discharges water in a way that is more harmful to fish and habitat than average dams elsewhere.
Exelon has filed an application with the Federal Energy Regulatory Commission (FERC) for a new operating license for the Conowingo Dam. Under federal law and FERC’s relicensing process, Exelon is required to obtain a Clean Water Act Water Quality Certification from MDE. Exelon must demonstrate that the dam’s operation meets Maryland’s water quality standards. MDE will hold a public hearing on the certification today, December 5, 2017. The public has until January 15, 2018 to submit written comments.
CBF and TNC both are scheduled to testify at the public hearing. They will urge that MDE require Exelon to: 1) mitigate the harm the dam causes to downstream water quality, including a financial contribution to mitigate sediment and nutrient pollution; 2) make operational changes to restore safe and effective habitat for migratory fish like American shad and striped bass–and for keystone species like freshwater mussels and aquatic vegetation; and 3) make structural investments to restore fish passage connectivity to upstream spawning habitats.