Eagle Creek Renewable Energy, LLC
`7315 Wisconsin Avenue, Suite 1100W
`Bethesda, Maryland 20814
`240.482.2700
`
`VIA Electronic Filing
`
`December 27, 2023
`
`Re:
`
`Affiliates of Eagle Creek Renewable Energy
` Owners Dam Safety Program Annual Update – December 2023
`
`1.
`
`Kevin Griebenow, Regional Engineer
`Federal Energy Regulatory Commission
`Office of Energy Projects
`Division of Dam Safety and Inspections
`Chicago Regional Office
`230 South Dearborn Street, Room 3130
`Chicago, IL 60604
`Dear Mr. Griebenow,
`On behalf of its affiliates, Eagle Creek Renewable Energy (ECRE) is hereby submitting an annual
`update of our Owners Dam Safety Program. Several updates have been made to the ODSP as detailed
`in the revision history including updates to address the Commission’s comments from the review of
`the ODSP update filed on February 24, 2023. The Commission’s comments from the May 10, 2023
`review letter along with our responses are as follows:
`Include a signed and dated copy of the Dam & Public Safety Policy statement issued annually
`by the President and CEO. This can be included in Section 3.1 or added as an Appendix. If added
`as an appendix, include a reference in Section 3.1
`2. Add a discussion in Section X Audits on the timeframe for completing an internal and external
`audit.
`3. Add discussion in Section X Audits on the process of the CDSE reporting the results of the
`internal and external audits to upper management. For example, our Outline with Discussion –
`Documentation of an Owners Dam Safety Program states, “The chief dam safety engineer should
`review the audit report and prepare a summary report for presentation to the senior
`management of the organization. A copy of the summary and audit reports should be
`submitted to the FERC.”
`
`Response: The latest Dam & Public Safety Policy Statement for 2023 has been included in
`Appendix 1.C and is referenced under Section 3.1 as directed. These statements are issued in
`January of each year so the 2024 statement has not been sent out yet.
`
`Response: Additional details on the timing of audits has been added to Section X.
`
`Response: As stated in the ODSP the internal audit process is used to inform goals and objectives
`for the year and identify improvements to the ODSP. Goals and objectives are shared with the
`Executive Leadership Team (ELT) which the CDSE is part of but not formally reported.
`
`

`

`Re: Updated ODSP
`
`2
`
`December 27, 2023
`
`Enhancements made to the ODSP are signed off on by the President and CEO, CDSE, and SVP of
`Operations. We don’t believe additional reporting of internal audit results is warranted.
`
`Additional details have been added in Section X on the reporting of external audit results to the
`ELT and FERC.
`
`Response: The Kanaka Project has been added to the ODSP list of Projects in Appendix 1.A.
`
`4. We note that the Kanaka Project, P-7242 is not included in the ODSP. We understand that you
`are in the process of surrendering the project; however it should remain as part of your
`inventory and in the ODSP until a surrender is granted.
`If you have any questions regarding this submittal, please contact me at 601-624-1427 or by e-mail
`at Dusty.Myers@eaglecreekre.com.
`Sincerely,
`Dusty Myers, P.E.
`VP Engineering & Project Management
`Chief Dam Safety Engineer
`
`Enclosure: ODSP – Rev. 12 (December 2023)
`
`

`

`
`
` cc:
`
`Mr. David Capka, P.E., Director
`Division of Dam Safety and Inspections (D2SI)
`Federal Energy Regulatory Commission
`Office of Energy Projects (OEP)
`888 First Street, N.E., Room 6N-01
`Washington, DC 20426
` ARO William Brown, Regional Engineer
`Federal Energy Regulatory Commission
`Office of Energy Projects
`Division of Dam Safety and Inspections
`Atlanta Regional Office
`3700 Crestwood Parkway NW, Suite 950
`Duluth, GA 30096
` NYRO
`John Spain, Regional Engineer
`Federal Energy Regulatory Commission
`Office of Energy Projects
`Division of Dam Safety and Inspections
`New York Regional Office
`19 W 34th Street, Suite 400
`New York, NY 10001-3006
` PRO Douglas Johnson, Regional Engineer
`Federal Energy Regulatory Commission
`Office of Energy Projects
`Division of Dam Safety and Inspections
`Portland Regional Office
`1201 NE Lloyd Blvd, Suite 750
`Portland, OR 97232
` SFRO
`Frank Blackett, Regional Engineer
`Federal Energy Regulatory Commission
`Office of Energy Projects
`Division of Dam Safety and Inspections
`San Francisco Regional Office
`100 First Street, Suite 2300
`San Francisco, CA 94105
`
`
`
`
`