`
`FEDERAL ENERGY REGULATORY COMMISSION
`Office of Energy Projects
`Division of Dam Safety and Inspections - Atlanta Regional Office
`Gwinnett Commerce Center
`3700 Crestwood Parkway, Suite 950
`Duluth, Georgia 30096
`(678) 245-3000 Office - (678) 245-3010 Facsimile
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`April 19, 2021
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`Addressee List Enclosed
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`Subject: Annual Letter – Reminder of Responsibilities
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`Dear Licensee/Exemptee:
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`This letter is intended to remind you of your obligations and responsibilities as the
`holder of a license or exemption from the Federal Energy Regulatory Commission
`(FERC) for a hydropower facility. This letter contains new information that may impact
`your project; although we acknowledge that it also contains many of the same reminders
`each year. These reminders focus on some of the most important aspects of our dam
`safety program that require your attention. We strongly encourage you to read it carefully
`in its entirety, including the enclosures and the referenced FERC website links, in order to
`understand your dam safety, public safety, and security responsibilities.
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`This letter will be sent to you each year primarily by email. Please reply to me by
`email and copy the FERC project engineer(s) assigned to your project(s) to acknowledge
`you have received and read this letter.
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`We were unable to perform all our normal dam safety inspections in 2020 due to the
`Covid-19 Pandemic. During this time, we asked many of our licensees to respond to
`questionnaires and/or we relied upon licensees and exemptees to perform their own dam
`safety inspections. For 2021, we are evaluating which projects will be inspected by each
`Regional Office once Commission staff can resume normal travel. As of the date of this
`letter, we do not have a schedule for returning to normal operations. Please continue to
`reach out to your Regional Engineer with any questions about dam safety inspections
`and/or other dam safety matters. Below, we provide information on how to submit
`documents and filings with the Commission and with the Regional Offices during this time
`(See How to Transmit Dam Safety and Public Safety Documents to the Commission). We
`wish to thank all our licensees and exemptees for working with us during this difficult time.
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`Part 12 Regulation Update. On July 16, 2020, the Commission issued a Notice of
`Proposed Rulemaking (NOPR) proposing to amend 18 CFR Part 12 governing the safety of
`hydropower projects licensed by the Commission under the Federal Power Act. These
`regulations are intended to promote the safe operation, effective maintenance, and efficient
`repair of licensed hydropower projects and project works to ensure the protection of life,
`health, and property in surrounding communities. In general, the NOPR proposes to revise
`the regulations to: incorporate two tiers of project safety inspections by independent
`consultants, define the requirements of an independent consultant team, codify existing
`guidance requiring certain licensees to develop an Owner’s Dam Safety Program and a
`Public Safety Plan, update existing regulations related to public safety incident reporting,
`and make various minor revisions. In addition to the proposed regulation changes, the
`Commission also issued four proposed draft chapters to our Engineering Guidelines. The
`chapters include:
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`Chapter 15 – Supporting Technical Information Document
`Chapter 16 – Part 12D Program
`Chapter 17 – Potential Failure Mode Analysis
`Chapter 18 - Level 2 Risk Analysis
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`A 60-day public comment period was opened to receive comments on the proposed
`regulation changes and proposed new Engineering Guideline chapters. The public comment
`period closed in late September 2020.
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`The proposed regulation revisions are included in the NOPR as a rulemaking (RM)
`docket (RM20-9) and are available on FERC’s eLibrary system at www.ferc.gov. Each of
`the draft chapters of the Engineering Guidelines are also available on eLibrary under
`separate Advisory Docket (AD) notices (AD20-20 through AD20-23). The NOPR and four
`AD notices have also been published in the Federal Register. The proposed regulation is not
`currently in effect. A final rulemaking will need to occur before the proposed regulation can
`be finalized.
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`Security Branch. The Security Branch will continue to evaluate physical and cyber
`security at FERC licensed and exempted projects, in remote and on-site capacities. While
`the Security Branch has several team members, the Branch utilizes
`D2SISecurityBranch@ferc.gov for the majority of its correspondence. The Security Branch
`asks that all inbound and outbound correspondence is encrypted and/or attachments are
`password protected (with the password provided via telephone call, separate email, or
`alternate communication) with the subject line referencing the project number(s). As a
`reminder, security documents must not be submitted to eLibrary – those documents
`required as part of FERC’s Security Program for Hydropower Projects, will be reviewed in
`the field or in an agreed-upon remote capacity. While not an exception to this filing rule,
`the Annual Security Compliance Certification (required for Security Group 1s & 2s and due
`December 31st each year) should be emailed to the Security Branch with the appropriate
`Regional Engineer copied on the email. When submitting dam safety and other
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`licensing/compliance correspondence to the Commission, do not mix security related
`information including, but not limited to, security features (e.g., cameras), security
`procedures (e.g., guards and response), cyber network connectivity, and law enforcement
`response times.
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`Annual Emergency Action Plan (EAP) Requirements. There are several annual
`requirements for EAPs discussed in Enclosure 1 of this letter. Several of these items have
`historically been handled in face-to-face meetings (i.e., annual seminars, training sessions
`for drills, and distributing updates/EAP reprints). If face-to-face meetings are not possible
`due to the pandemic, these items should be handled through virtual meetings to the extent
`possible.
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`There may be issues with providing hard copies of documents (e.g., updates,
`reprints) to certain parties during the pandemic. For EAP submissions to the Commission,
`see the How to Transmit Dam Safety and Public Safety Documents to the Commission
`section below. At a minimum, documents provided to plan holders should be provided as
`searchable PDF files and hard copies should be distributed when possible. You should
`ensure the PDF files are of such quality that the documents are legible, especially the
`inundation maps. You may also want to confirm the preference for all parties to receive
`hard copies in addition to the electronic versions. We highlight that hard copies still serve a
`purpose during emergencies when there is a loss of power.
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`We note that some licensees use automated notification systems in their EAPs.
`These systems are also being used to perform the call-down tests during annual drills. The
`use of these systems during drills should include a procedure for all parties to acknowledge
`receipt of the message to determine the system’s effectiveness. We also recommend that all
`EAPs, that rely on automated notification systems, include a procedure to ensure responders
`can confirm the message is accurate; can receive more detailed information if needed; and
`can ask for additional information soon after receiving the initial notification. This can be
`done by holding a virtual meeting or phone conference with all parties soon after the initial
`notifications go out. You should consider testing this procedure during the annual drill.
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`Employees and Incident Reporting. This is a reminder that Part 12.10(b) requires you to
`report, for your employees and contractors under your employ, any serious injuries and
`deaths in the same manner those injuries/deaths are reported for the general public. Most
`such employee incidents, that happen at the project, would be considered project-related
`and would require a written report describing the cause, location, and any remedial actions
`taken or proposed to avoid or reduce the chance of similar accidents pursuant to
`12.10(b)(1)-(4). This requirement is separate from any reporting obligations to the
`Occupational Safety and Health Administration.
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`Change of Ownership. This is a reminder that the new owner of a FERC-regulated
`hydropower project (or of a Corporation that owns a project) assumes all dam safety
`responsibilities and liabilities and all non-compliance liabilities from the previous owner.
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`Before acquiring a project and/or seeking a license or exemption transfer, we advise the
`prospective buyer to perform all needed due diligence to identify any outstanding dam
`safety and compliance issues from the current owner. In general, scheduled and required
`dam safety work must be completed on time with few exceptions made due to a change in
`ownership. Should you decide to sell and/or transfer one of your projects, please inform the
`prospective buyer of the above information.
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`Prior Commission Authorization. Modifications and changes to your projects require
`prior coordination with the Regional Engineer. Any activities that require engineering
`analyses, modifications to existing structures, or ground-disturbing activities of any kind
`(e.g., clearing, grubbing, excavation, or repeated off-road travel) are subject to review for
`potential dam safety and environmental impacts. Therefore, you are required to coordinate
`these activities with us prior to performing the work. This does not include replacement in-
`kind of motors, pumps, or similar items that are considered routine operation and
`maintenance, unless you are removing or altering potentially historic or culturally
`significant items. We require a minimum of 60 days to review final plans and specifications
`for the proposed work, although initial communication with this office will provide a better
`understanding of what’s involved for us to perform our review. See additional information
`in items No. 11 and 12 in Enclosure 1.
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`Natural Disasters. Floods, fires, major storm events, and earthquakes often impact
`projects. If one of your projects is damaged by a natural disaster, we ask you to notify the
`Regional Engineer immediately, similar to any significant dam safety incident covered
`under item No. 5 in Enclosure 1.
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`How to Transmit Dam Safety and Public Safety Documents to the Commission
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`Electronic Submittal of Documents. All dam safety and public safety documents you
`submit to the Commission should be filed electronically using the Commission’s eFiling
`system at http://www.ferc.gov/docs-filing/efiling.asp. The one exception is Security related
`documents which are addressed in the Security Branch section of this letter. Documents
`should be in a searchable format with a linked Table of Contents to enable navigation to
`each section of the document. The cover letter or first page of the filing should indicate
`“Electronically Filed.” When eFiling dam safety and public safety documents, including
`items addressed to the Director of Dam Safety in Washington, DC, always choose Hydro:
`Regional Office and the regional office that corresponds to your project from the eFiling
`menu. See No. 15 of Enclosure 1 for additional information regarding document labeling
`and uploading documents under the correct security classification tab during eFiling. Please
`refer to our Hydropower Filing Guide for additional information on filing hydropower
`documents. For assistance with any of our online systems please contact FERC Online
`Support at FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659
`(TTY).
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`There are some cases where your submission cannot be eFiled because the file types
`are not accepted by eFiling, the files cannot be divided into 50 mb or less, or the data
`package is too large. In these cases, anything that can be eFiled must be eFiled and the
`remaining parts of the submission can be transmitted using one of four methods: 1) email,
`2) file transfer site provided by you, 3) file transfer site (using SharePoint) provided by
`FERC, or 4) mailing a CD, DVD, or external drive to the Office of Energy Projects in
`Washington DC. Any transmittal of files that does not occur through eFiling must be
`coordinated with the project engineer.
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`What if I cannot Submit Documents Electronically? If you cannot submit documents
`electronically because you do not have access to the internet, you must notify the project
`engineer of your submission and send one copy of all dam safety and public safety
`documents to the Secretary of the Commission’s Office to be posted to eLibrary at the
`appropriate address. NOTE: Address blocks on the letters to the appropriate Commission
`staff may remain as is.
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`Packages sent via the U.S. Postal Service must be addressed to:
`Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission,
`888 First Street NE, Room 1A, Washington, DC 20426.
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`Packages sent via any other carrier must be addressed to:
`Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission,
`12225 Wilkins Avenue, Rockville, Maryland 20852.
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`Hard Copies Are Not Required During 100% Telework. The Commission remains on
`100% telework status due to the ongoing Covid-19 Pandemic. Requirements for sending
`hard copies are suspended during this time.
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`This guidance for submitting documents to the Commission is valid until FERC
`reconstitutes and staff returns to offices. We do not have a timeline for when that will
`occur. When the Commission reconstitutes, we will issue further guidance regarding: 1) any
`need for hard copies of documents submitted during 100% telework and; 2) any need for
`hard copies going forward after reconstitution.
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`Reminder of Responsibilities
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`In addition to the above, to assist you in ensuring compliance with FERC dam
`safety regulations, Enclosure 1 includes a summary of common requirements, primarily
`from Title 18, Parts 8 and 12 of the Code of Federal Regulations, as well as a number of
`administrative requirements that are often overlooked. Please review Enclosure 1 along
`with your license or exemption to ensure that your operations comply with all
`requirements.
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`Throughout the year, we host workshops and training courses that may be of
`interest to you. A schedule and description of upcoming workshops and courses can be
`accessed at the following website:
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`https://www.ferc.gov/industries-data/hydropower/dam-safety-and-
`inspections/meetings-workshop-and-conferences
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`Thank you for your attention to this letter. Please call me at (678) 245-3075 or
`email me at Wayne.King@ferc.gov if you have any questions about the enclosed
`information or about your projects in general.
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`Sincerely,
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`Wayne B. King, P.E.
`Regional Engineer
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`Enclosures:
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`1. Reminder of Responsibilities
`2. Addressee List
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`Enclosure 1
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`REMINDER OF RESPONSIBILITIES
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`ANNUAL REQUIREMENTS
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`Spillway Gate Operation. See 18 CFR §§ 12.44(b) and (c), and 12.13 for
`1.
`periodic requirements and verification. If any of your projects include spillway gates,
`please ensure that you are correctly measuring and documenting the current and voltage
`for each electric motor during load testing and provide a time plot of the yearly readings.
`You must submit a notarized “Annual Spillway Gate Operation Certificate” by December
`31 of each year or as arranged with the Regional Engineer. Please ensure that you are
`using our latest form, which may be downloaded from the following website:
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`Annual Spillway Gate Operation Certificate (Word)
`Annual Spillway Gate Operation Certificate (PDF)
`Testing and Reporting on Spillway Gate Operations
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`Please note that we will not provide a formal response to future annual spillway
`gate operation certificates unless we have comments or find that the submittal does not
`satisfy the requirements of 18 CFR Section 12.44.
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`Emergency Action Plans (EAPs). There are a number of annual requirements
`2.
`regarding EAPs, including performing exercises. Please note our comments in the main
`body of this letter regarding the use of automatic dialers during your annual exercise. By
`December 31 of each year, you must submit an EAP Status Report regarding these
`requirements for each of your projects that require an EAP. Chapter 6 of our
`Engineering Guidelines explains what should be included in the Status Report. Please
`note that the Chief Dam Safety Engineer or Chief Dam Safety Coordinator must always
`be included in the sequence on the notification flow chart. For your convenience, the
`items to be included in the EAP Status Report are listed below:
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` The dates you performed an annual comprehensive review of the EAP.
` The dates annual updates to the EAP, and if applicable, the Radiological
`Emergency Response Plan, were sent to plan holders. You may submit any
`updates to your EAP along with the EAP Status Report. Updates must
`include documentation of consultation between your staff and the
`Emergency Management Agencies (EMAs) which occurred during the year.
` A list of EAP recipients. Please note that a list along with your EAP Status
`Report is sufficient. Updated acknowledgement forms from each EMA do not
`need to be submitted.
` The date of the last full reprint of the EAP for all plan holders.
` The dates of your last annual seminar and a brief description of what was
`discussed.
` The dates of your last drill/training/call-down test, including any lessons
`learned.
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`Enclosure 1
`Page 2 of 9
` A brief description of the project’s emergency equipment and the dates
`tested.
` The date and results of the most current Sudden Failure Assessment. This
`must include an explanation of any response time enhancements implemented
`or changes in downstream population that would affect the Sudden Failure
`Assessment results.
` The dates and descriptions of any public education outreach provided during
`the year and who received this outreach. This includes public education that
`was provided by local EMAs.
` A table indicating all parties who: (1) received EAP revisions and/or annual
`updates, (2) participated in the annual seminar, and (3) participated in the
`annual drill and/or were contacted during the call-down test.
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`If the EMAs involved with your project have Geographical Information System
`(GIS) capabilities, your EAP inundation maps should be based on GIS data. Guidance on
`GIS inundation map files can be obtained at:
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`https://www.ferc.gov/tips-developing-and-submitting-gis-inundation-map-files
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`Training for EAP exercises is available from FERC each year. Please contact the
`regional office to find the date and location of the next training session.
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`For a project previously exempted by this office from filing an EAP, you are
`still required to:
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` perform a field reconnaissance to determine if there have been any changes to
`upstream or downstream conditions affecting the determination that no
`reasonably foreseeable project emergency would endanger life, health, or
`property;
` develop, maintain, post, and annually verify a contact list of people and
`organizations such as local EMAs and upstream and downstream dam owners
`who would be called during flood events, if the dam is in danger of failing, or
`has failed; and
` submit an annual report documenting your field reconnaissance along
`with a request to continue your EAP exemption.
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`Your emergency contact list and a statement that you have verified the accuracy of
`the information on the list should be submitted with your annual report.
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`Please note that we will not respond to future annual EAP exemption
`certifications unless we have comments or find that your submittal does not satisfy the
`requirements of 18 CFR Section 12.21(c).
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`Enclosure 1
`Page 3 of 9
`Dam Safety Surveillance and Monitoring Plan (DSSMP) and annual Dam
`3.
`Safety Surveillance and Monitoring Report (DSSMR). Reference 18 CFR § 12.41
`and Chapters 9 and 14 of our Engineering Guidelines. Please see this website:
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`https://www.ferc.gov/industries-data/hydropower/dam-safety-and-inspections/eng-
`guidelines
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`DSSMPs must include all instrumentation and monitoring activities for features
`located within the FERC project boundary of each project. This includes conveyance
`structures such as flumes, penstocks, canals, and any other conveyance features. For
`some projects, visual observation may be the only monitoring possible, which may be
`appropriate and sufficient for the project.
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`The DSSMR, together with any update to the DSSMP, should be submitted
`annually on a schedule previously arranged with the Regional Engineer. If possible,
`data tables and plots should be accompanied by a searchable electronic version using
`Microsoft Excel.
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`As a reminder, a table must be included in your annual DSSMR submittals
`relating all instrumentation to applicable Potential Failure Modes. Review Appendices J
`and K of Chapter 14 of our Engineering Guidelines for more information. These
`documents are located at:
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`https://www.ferc.gov/sites/default/files/2020-04/chap14.pdf
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`Note: Your DSSMR submittals must include a statement from your Chief Dam
`Safety Engineer or Chief Dam Safety Coordinator stating that your dams are safe for
`continued operation. If the Chief Dam Safety Engineer or Coordinator cannot make a
`clear statement that the dam is safe for continued operation, then a Justification for
`Continued Operation plan and schedule is required. This plan should include interim
`measures to reduce risk until remediation is complete and the dam is judged to be safe
`for continued operation.
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`Hydropower Security Program. All licensees/exemptees with developments
`4.
`designated as a Security Group 1 or 2 must file an Annual Security Compliance
`Certification (ASCC) with the Security Branch and include a courtesy copy to the
`appropriate Regional Engineer. Guidance on content of the ASCC and its filing, as
`well as templates, were presented in a November 4, 2020 Webinar and are available
`here:
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`https://www.ferc.gov/media/2020-annual-security-compliance-certification-new-
`template-and-cyber-asset-designation
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`Enclosure 1
`Page 4 of 9
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`REPORTING REQUIREMENTS
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`Project Safety and Public Safety Related Incidents. See 18 CFR
`5.
`§§ 12.10(a), 12.10(b), and 12.3(b)(4). When a project safety condition or public safety
`incident is discovered, you must:
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` Call the Regional Engineer as soon as practicable;
` Follow up with a summary email to the Regional Engineer; and
` Submit a written report within 10 days of the incident or as directed by
`the Regional Engineer.
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`It is imperative that you notify the Regional Engineer immediately of any
`condition, event, or action at a project that compromises the safety, stability, or integrity
`of any project works or that otherwise affects life, health, property, or public safety. This
`includes, for example, any damage to the project as a result of fires, floods, or
`earthquakes including any damage that requires action to prevent additional damage
`and/or that requires action to restore the project to an operational status. In addition to
`significant events such as the above, you should report any other abnormal incidents that
`could impact the safety of the project if left unaddressed, for example, gate mis-
`operation, mechanical failures that impact water releases or retention, abnormal trends in
`instrumentation, and any other event that requires your action to prevent a deteriorating
`condition that could impact your project. Your Chief Dam Safety Engineer or Chief Dam
`Safety Coordinator should be proactive in instrumentation review and evaluation. If you
`are uncertain whether an emerging, ongoing, or completed event constitutes a reportable
`incident, you should contact the Regional Engineer.
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`Any deaths or serious injuries within your FERC project boundary should also be
`reported immediately to the Regional Engineer, who will work with you regarding the
`specific reporting requirements based upon the occurrence. This applies to the general
`public as well as your staff and contractors hired to perform work on your project.
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`Any activation of the EAP, including activation of the Non-Failure or High
`Flow Conditions, is considered a safety-related incident (see Chapter 6 of our
`Engineering Guidelines) and requires filing a 12.10(a) report. Your incident report or
`subsequent correspondence should include your analysis of the incident and your specific
`plans for any necessary project improvements or additional prevention measures.
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`Project Conditions. Aberrant conditions, including those mentioned above,
`6.
`encountered during new construction, project modifications, or geotechnical work
`should be reported immediately after discovery or while attempting to control the
`situation in accordance with 18 CFR § 12.10(a).
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`Emergency Modifications. See 18 CFR, § 12.11(b)(1). You must report any
`7.
`project modifications taken to respond to emergency conditions as soon as practicable.
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`OTHER RESPONSIBILITIES
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`Enclosure 1
`Page 5 of 9
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`Instrument Readings during unusual or extreme loading events. Acquiring
`8.
`instrumentation readings during unusual loading events, like a flood or post-earthquake,
`is important to help evaluate the performance of your dams. However, personnel safety
`should not be compromised and should always be considered when surveilling and
`monitoring structures and instrumentations during and after these events. These readings
`should be immediately reported to this office if they are found to be reaching or
`exceeding threshold and/or action levels.
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`Excavations and Investigations. Your plans for any proposed ground-disturbing
`9.
`activities within your FERC project boundary must be submitted for our review at least
`60 days prior to commencement. Ground-disturbing activities include anything that
`could have dam safety implications and/or that could impact any cultural, biological, or
`historic features. This could include clearing and grubbing, excavations, or repeated off-
`road travel.
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`10. Drilling Guidelines. Our drilling guidelines entitled, Guidelines for Drilling in
`and Near Embankment Dams and their Foundations, provide guidance for drilling in or
`near any dam as well as for trenching, test pits, and similar activities. The guidelines
`should be referenced when performing any type of exploration activities near any
`FERC-licensed project. These guidelines are available on our website at:
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`https://www.ferc.gov/sites/default/files/2020-04/guidelines.pdf
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`If you have any questions about whether a proposed activity requires our review
`and authorization, please contact the FERC staff engineer assigned to your project.
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`11. Drawdowns and Dewatering. See 18 CFR § 12.4(b). All non-emergency
`drawdowns of a reservoir, canal, or forebay that would be inconsistent with the
`operational requirements and/or terms and conditions in your license or exemption
`require prior authorization. Documentation of consultation with appropriate federal,
`state, and local resource agencies must be included in your drawdown request. The
`request for an extended drawdown (exceeding four weeks) should be made through the
`Commission’s Division of Hydropower Administration and Compliance (DHAC) with
`a courtesy copy emailed to the Regional Engineer. Emergency drawdowns to protect
`life or property must be reported to our office in accordance with 18 CFR § 12.10(a).
`Conveyance Feature Draining/Dewatering. Requests to dewater tunnels,
`conduits, or penstocks as part of normal operation and maintenance activities must also
`be submitted for review and comment at least 60 days prior to initiation. If
`emergency conditions exist (e.g., mechanical failures, storm damage, etc.) that result in
`the immediate need to drain a conveyance feature, you must notify this office in
`accordance with 18 CFR § 12.10(a).
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`Enclosure 1
`Page 6 of 9
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`Plan Review. See 18 CFR, § 12.11(b)(2). Your plans for any proposed
`12.
`modifications to, or major maintenance of, any of your projects must be submitted for
`review and acceptance at least 60 days prior to initiation. Larger and more complex
`projects can require substantially more than 60 days for us to review and provide
`comments. Therefore, you are encouraged to contact this office as soon as possible to
`discuss upcoming projects to minimize any delays. You are also responsible for
`obtaining all necessary permits from other federal, state, and local agencies to perform
`proposed work, as well as consulting with DHAC, as needed.
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`13. Review and Submittal of Consultant Reports. Each cover letter transmitting a
`consultant’s report must include a statement that the report has been reviewed by you,
`your Chief Dam Safety Engineer or Chief Dam Safety Coordinator, and/or your staff. The
`cover letter must also provide either your concurrence or disagreement with the
`consultant’s findings and/or recommendations. When you agree that urgent actions are
`necessary, you must include your proposed plan and schedule for these actions in the
`cover letter. Any dissenting opinion should be fully justified. All reports submitted on
`behalf of your consultants should be signed by the individuals who performed the work
`discussed in the reports.
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`14. Extension of Time Requests. If you are unable to meet a due date, you must
`submit a written request for an extension of time that includes an explanation of why the
`due date could not be met and your plan and schedule for completing the required
`action. Your extension of time request should be submitted sufficiently far in advance
`of the due date (typically 30 days) for us to review and decide on your request.
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`15. Critical Energy Infrastructure and Privileged Information. Documents
`containing Critical Energy/Electric Infrastructure Information (CEII), per 18 CFR
`§ 388.113 and https://www.ferc.gov/legal/ceii-foia/ceii.asp, should include the label
`CUI//CEII centered in the top header of each page of the document. Documents
`containing information that 18 CFR § 388.112 recognizes as privileged should include
`CUI//PRIV centered in the top header of each page of the document. Documents
`containing both CEII and privileged information should contain CUI//CEII/PRIV
`centered in the top header of each page of the document. Any document containing
`CUI must be uploaded under the corresponding security tabs during eFiling. If a
`document contains both CUI and PRIV material, it should be uploaded under the
`Privileged tab.
`
`In accordance with the Commission’s Information Governance Policy, please
`designate all security documentation as CUI//CEII/PRIV centered in the top header and
`Security Sensitive Material Do Not Release centered in the footer of each page of the
`document. Security documents must not be submitted to eLibrary – those documents
`required as part of FERC’s Security Program for Hydropower Projects, will be reviewed
`in the field or in an agreed-upon remote capacity. While not an exception to this filing
`rule, the Annual Security Compliance Certification (required for Security Group 1s & 2s
`and due December 31st each year) should be emailed to the Security Branch with the
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`Enclosure 1
`Page 7 of 9
`appropriate Regional Engineer copied on the email. When submitting dam safety and
`other licensing/compliance correspondence to the Commission, do not mix security
`related information including, but not limited to, security features (e.g., cameras),
`security procedures (e.g., guards and response), cyber network connectivity, and law
`enforcement response times.
`
`16. Contact Information. Any changes to your dam safety point of contact (e.g.,
`Chief Dam Safety Engineer or Chief Dam Safety Coordinator), including contact
`names, addresses, phone numbers, and/or email addresses should be promptly reported
`to our office so that we can contact your staff in the event of an emergency. If the
`primary contact for your organization changes, you must also file a change of contact
`form located at the following web address:
`
`https://www.ferc.gov/how-submit-andor-update-contact-information
`17. Owner’s Dam Safety Program (ODSP) and Chief Dam Safety Engineer