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`January 12, 2021
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`Indian Pond Project (FERC No. 2142)
`Brunswick Project (FERC No. 2284)
`Bear Swamp Project (FERC No. 2669)
`Gulf Island- Deer Rips Project (FERC No. 2283)
`Wyman Project (FERC No. 2329)
`North Gorham Project (FERC No. 2519)
`Cataract Project (FERC No. 2528)
`Skelton Project (FERC No. 2527)
`Bonny Eagle Project (FERC No. 2529)
`Weston Project (FERC No. 2325)
`Moosehead Project (FERC No. 2671)
`Flagstaff Project (FERC No. 2612)
`Penobscot Mills Project (FERC No. 2458)
`Ripogenus Project (FERC No. 2572)
`Williams Project (FERC No. 2335)
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`Kimberly D. Bose, Secretary
`Federal Energy Regulatory Commission
`888 First Street, NE
`Washington, DC 20426
`
`Via eFiling
`
`Subject: Notification of Recreation Facility Closures and Request for Extension of Time
`to Conduct Recreation Monitoring Due to Continued Covid-19 Outbreak
`
`Dear Secretary Bose,
`
`Due to the recommendations of the CDC (Centers for Disease Control and Prevention) amidst
`the current ongoing Covid-19 outbreak and escalating cases in the New England states in which
`we operate, Brookfield Renewable (Brookfield), on behalf of the licensees listed below, will be
`making the following changes to the normal operation schedule for the recreation facilities listed
`below at the Indian Pond (FERC No. 2142), Brunswick (FERC No. 2284); Bear Swamp (FERC
`No. 2669); and Wyman (FERC No. 2329) Projects:
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`• Brookfield White Pine Hydro LLC (BWPH), Indian Pond Project – Indian Pond Campground
`– BWPH operates a campground that features 27 campsites, restroom and bath house
`facilities, and an office/camp store. The normal operating start date for Indian Pond
`Campground is May 1. In order to limit contact of Brookfield staff with the general public,
`while still capturing the peak of the recreation season, BWPH proposes to delay the
`opening of the Indian Pond Campground until at least May 24, 2021 (actual opening date is
`tentatively targeted for Memorial Day weekend, but may be postponed pending current
`CDC, state and federal guidelines). This is consistent with a similar delay in the opening of
`the campground in 2020. Any future delays in the opening of the Indian Pond
`Campground, should CDC, state/federal or corporate guidelines for Covid-19 still exist, will
`be communicated to the Commission as soon as practicable.
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`150 Main Street
`Lewiston, ME 04240
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`www.brookfieldrenewable.com
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`Tell: 207.755.5600
`Fax: 207.755.5655
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`• BWPH, Brunswick Project, Brunswick Fishway Viewing Window - BWPH voluntarily
`maintains a viewing window at its Brunswick Project for public outreach and information
`from May 1 to mid-July. The fishway viewing window is open to the public on Wednesdays
`to Sundays from 12:00 pm to 5:00 pm, and it is staffed. As this is a voluntary undertaking
`and to limit the interaction of the public with one another and with BWPH seasonal staff
`within the confined space of the fishway viewing window, BWPH did not open this site for
`the 2020 season and intends to keep the site closed for the 2021 season.
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`• Bear Swamp Power Company, LLC (BSPC), Bear Swamp Project, Bear Swamp Visitor
`Center – BSPC operates a visitor center for public outreach and information from April 1 to
`mid-October. The visitor center is open to the public Friday to Sunday and on Monday
`holidays from 9:00 am to 4:00 pm, and it is staffed. To limit the interaction of the public with
`one another and with BSPC seasonal staff within the confined space of the visitor center,
`BSPC closed this site in 2020 and this site will remain closed for the 2021 season.
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`• BSPC, Bear Swamp Project, Zoar Picnic Area - BSPC maintains a recreation site that
`provides a hand carry boat launch, portable toilets, and picnic facilities. Because Brookfield
`staff would be unnecessarily exposed to frequent interactions with the general public
`through the normal routine maintenance activities at this site, BSPC will open the
`recreation site and install portable toilets as was done in 2020, but close its picnic facilities.
`BSPC has also provided Covid-19 information signage regarding these amenity closures.
`Until state and federal Covid-19 guidelines are lifted and the appropriate facilities can be
`properly prepared and put in place, these amenities will remain unavailable, though the
`pathway to the Deerfield River and the hand-carry boat launch will remain open for river
`and boating access.
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`• BWPH, Wyman Project, Pleasant Ridge Swimming Area – BWPH maintains a recreation
`site adjacent to a Maine Department of Transportation (MDOT) boat launch site that
`provides a beach area, vault toilets and picnic facilities, the layout of this site and proximity
`to the MDOT boat launch make closure of this facility impractical. As such, BWPH will
`open the recreation site, but will close its restroom facilities and provide Covid19
`information signage regarding the amenity closures. This is consistent with our operation
`of the site in 2020.
`Brookfield would like to take this time to emphasize that, as was done in 2020, it is currently our
`intention to open and maintain our other 200+ recreation facilities in the Northeast Region,
`including our boat launches, angling access sites, canoe portages, and remote camping areas.
`Many of these sites are located in remote or highly rural areas that allow the continued
`implementation of social distancing and/or are otherwise amenity-free, and thus they present low
`risk to the general public. To the extent that Brookfield can continue to support local businesses
`that may operate during the 2021 season to provide outdoor recreation opportunities, such as
`commercial whitewater rafting companies and guide services, we will do so to the extent allowed
`and/or recommended by the CDC, state and/or federal government agencies, or corporate
`policies. Should additional sites be selected for delayed opening or closure due to increased or
`newly discovered risks, Brookfield will inform the Commission as appropriate.
`The following Projects have recreation monitoring and reporting requirements that are
`independent of, though historically concurrent with, the former FERC Form 80 process:
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`150 Main Street
`Lewiston, ME 04240
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`www.brookfieldrenewable.com
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`Tell: 207.755.5600
`Fax: 207.755.5655
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`• North Gorham Project, owned and operated by BWPH – Article 407 as amended,
`requires a recreation monitoring report, in consultation with agencies and the Town of
`Gorham, to be filed every 6 years to include annual use figures, an evaluation of the
`fisheries program and status on theft, vandalism and loitering, a discussion of recreation
`facility adequacy, plans to control visitation, and documentation of agency consultation.
`• Cataract Project, owned and operated by BWPH – Article 407 as amended, requires a
`recreation monitoring report, in consultation with agencies, to be filed every 6 years to
`include annual use figures, a discussion of recreation facility adequacy and need, plans
`for improvements, and documentation of agency consultation.
`• Skelton Project, owned and operated by BWPH - Article 413 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement, and documentation of agency
`consultation.
`• Bonny Eagle Project, owned and operated by BWPH - Article 412 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy including the Limington
`Rips recreation area (maintained by MDOT), a description of monitoring methodology,
`plans for improvement, and documentation of agency consultation.
`• Weston Project, owned and operated by BWPH - Article 406 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement (including safety measures), and
`documentation of agency consultation.
`• Gulf Island - Deer Rips Project, owned and operated by BWPH - Article 411 and the
`FERC Order Approving the Recreation Plan (dated March 25, 2010) require a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement, and documentation of agency
`consultation. The report also is required to include a discussion of the need for
`sanitation facilities and a boat launch, status of water access campsites and signage,
`and the adequacy of parking.
`• Wyman Project, owned and operated by BWPH - Article 411 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement, and documentation of agency
`consultation.
`• Moosehead Project, owned and operated by Kennebec Water Power Co (KWPC) -
`Article 412 requires a recreation monitoring report, in consultation with agencies, to be
`filed every 6 years to include annual use figures, a discussion of recreation facility
`adequacy, a description of monitoring methodology, plans for improvement, and
`
`
`
`150 Main Street
`Lewiston, ME 04240
`
`www.brookfieldrenewable.com
`
`Tell: 207.755.5600
`Fax: 207.755.5655
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`documentation of agency consultation.
`• Flagstaff Project, owned and operated by BWPH - Article 410 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement, and documentation of agency
`consultation.
`• Penobscot Mills Project, owned and operated by Great Lakes Hydro America, LLC
`(GLHA) - Article 415 requires a recreation monitoring report, in consultation with
`agencies, to be filed every 6 years to include annual use figures, a discussion of
`recreation facility adequacy, a description of monitoring methodology, plans for
`improvement, and documentation of agency consultation.
`• Ripogenus Project, owned and operated by GLHA - Article 411 requires a recreation
`monitoring report, in consultation with agencies, to be filed every 6 years to include
`annual use figures, a discussion of recreation facility adequacy, a description of
`monitoring methodology, plans for improvement, and documentation of agency
`consultation.
`• Williams Project, owned and operated by BWPH – Article 406 and the FERC Order
`Approving the Recreation Plan (dated April 16, 2019) require a recreation report
`describing the use and capacity of the four existing recreation sites and the tailrace area
`of the dam, and the availability of boating access from the commercial launch at
`Evergreens Campground.
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`Covid-19 infections and associated deaths continue to increase, and the roll out of vaccines
`has been limited in the state of Maine. Given the current state of affairs, it is not anticipated
`that 2021 will reflect typical recreation conditions or use at any of Brookfield Renewable’s
`recreation facilities. Like observed in 2020, some FERC-approved recreation sites could see a
`significant increase in use as individuals look for ways in which to exercise and recreate while
`maintaining social distancing recommendations, while other recreation sites could see a
`significant decrease in use from closures, whether in response to potential contamination or
`public safety concerns, or from individuals choosing to shelter in place and not participate in
`their normal recreation activities.
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`In either case, Brookfield does not believe that recreation monitoring conducted during the 2021
`recreation season will again reflect an accurate depiction of recreation facility use and
`adequacy, nor would it be particularly informative regarding capacity and the potential need for
`improvements. Additionally, dispatching Brookfield staff or consultants to recreation sites to
`gather information from recreational users potentially exposes both them and the public to the
`Covid-19 virus. As such, Brookfield, on behalf of the licensees for the above-listed Projects,
`respectfully requests an extension of time of one year to file the recreation reports required by
`the license articles referenced above. Brookfield is hopeful for a return to normalcy in the 2022
`recreation season and would therefore anticipate conducting recreation monitoring during the
`2022 recreation season and providing the required recreation monitoring reports to the
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`
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`150 Main Street
`Lewiston, ME 04240
`
`www.brookfieldrenewable.com
`
`Tell: 207.755.5600
`Fax: 207.755.5655
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`Commission no later than April 1, 2023.
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`We appreciate the inconvenience that our requests may cause to some stakeholders, but wish
`to be as protective of the public and our staff as possible. Please contact Allison Frechette at
`(207) 320-1440 or at Allison.Frechette@brookfieldrenewable.com with any questions.
`
`Sincerely,
`
`Kelly Maloney,
`Manager, Compliance – Northeast
`
`N. Stevens, J. Seyfried, S. Michaud, J. Rancourt, E. Deluca, A. Frechette, M.
`Cc:
`Kessel, L. Anderson, K. Bernier, M. Leblanc, J. Cole, S. Farrington
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`Brookfield File: HSSE 4a/0000
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`
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`150 Main Street
`Lewiston, ME 04240
`
`www.brookfieldrenewable.com
`
`Tell: 207.755.5600
`Fax: 207.755.5655
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