Hydroelectric Plant relicensing involves dam-based facility on Shenandoah River dating to 1924

When Royal Examiner received a publication request to advertise a federal agency re-licensing request for a project titled “Warren Hydroelectric Plant” along the Shenandoah River some alarm bells went off as to exactly what was being requested to be re-licensed. – Was someone planning to construct an electrical generating facility on a river bank of the already stressed Shenandoah for a project that had been floundering since an initial permit was granted, perhaps years earlier? Would fundamental changes in the river’s usage by surrounding municipalities, available capacities, and potential threats to the river’s already at times fragile health be properly explored?

Initial inquiries to the Warren County government and its Economic Development Authority were met with the same lack of detail on exactly what was referenced in the re-licensing application of PE Hydro Generation LLC, a Limited Liability Company with a Wisconsin Avenue, Bethesda, Maryland address. So, it seemed Royal Examiner’s efforts paralleled county staff’s in seeking answers to exactly what was being proposed for re-licensing here. Our email to the listed PE Hydro contact person was replied to by another official who traced the re-licensing back, first 30 years to 1993; and then another seven decades to the 1920s.

Dam, that looks familiar. The dam at center of PE Hydro Generation LLC re-licensing application coming up for a 30-year renewal. Below, aerial perspective of the dam site, yellow lines to across river at far right, and project impact area. Photos from FERC (Federal Energy Regulatory Commission) website on project licensing

“The Project was constructed in the 1920s and the current Federal Energy Regulatory Commission (FERC) license was issued in 1993 for a 30-year term. Since the license expires December 31, 2023, PE Hydro initiated a process to re-license the Project in accordance with FERC’s regulations in 2018 (additional information on the FERC relicensing process can be found at ferc.gov/licensing).  The impacts of the Project were analyzed in the Draft and Final License Applications. Attached is a figure that shows the existing Project boundary, the existing dam and hydro station are located downstream of Front Royal, VA. PE Hydro is not proposing any new structures or changes to the existing operation of the Project,” Director of Licensing and Compliance for parent company Eagle Creek Renewable Energy, Joyce A. Foster informed us.

We first ran this reply by WC EDA Board Chairman Jeff Browne, who replied it matched the information his board had received. We then called County Administrator Ed Daley seeking additional detail on the dam’s location and function. Daley referred us to Joe Petty, now temporarily pulling double duty as the County’s new in-house EDA director along with his old job as county planning director. Petty was extremely helpful in guiding this reporter through the FERC website to the details we were seeking in a 161-page PDF, with the added advice that what we were after was on several pages within the first 20 pages, give or take, of the lengthy licensing PDF.

This is what we found on page 18:

“PE Hydro Generation LLC … is a subsidiary of Eagle Creek Renewable Energy LLC … “PROJECT FACILITIES 2.1 – Existing Project Facilities

“The existing project consists of: (1) a 15-foot-high, 483- foot-long reinforced concrete dam impounding a small reservoir with a storage capacity of 900 acre-feet; (2) an 82-foot-long by 30-foot-wide powerhouse adjacent to the north end of the dam containing 3 generating units with a total installed capacity of 750 kW; (3) transmission facilities consisting of the 2.4- kilovolt (kv) Project generator leads; a 3-phase, 2.4/34.5-kV transformer; and an 14,784-foot-long, 34.5 kV transmission line1; and other appurtenances. Power is connected to the electrical distribution grid through a substation step up 2400 V/34.5 kV transformer. Power is then sold to PJM. Since 1924 the Project has operated manually in a run-of river mode. An operator visits the station daily to check on the operation; otherwise the station is unmanned.”

County Planning Director/EDA Director Joe Petty was a helpful guide through the FERC website on the Hydroelectric relicensing for a dam-based electrical generating facility dating to 1924. Below, regional map indicating the four related dam-based hydroelectric generating facilities.

Ms. Foster of Eagle Creek Renewable Energy added some detail, telling Royal Examiner that PJM (acronym for “Pennsylvania, Jersey, Maryland”) Interconnection LLC is “a regional transmission organization (RTO), that coordinates the movement of wholesale electricity. As an RTO, PJM operates a wholesale electricity market that spans all or part of Delaware, Illinois, Kentucky, Maryland, Michigan, New Jersey, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, and the District of Columbia.”

Petty told this reporter that his understanding was that the only potential physical change was work on an “eel ladder” to facilitate the seasonal migratory habits of eels inhabiting the Shenandoah River. That observation rang a bell with this reporter, who recalls conversation about the addition of an eel ladder or bridge to the dam several years ago. Again, Ms. Foster of Eagle Creek was helpful in this regard. “The May-October upstream eel ladder is installed in the spring and removed in the fall annually. I believe there was an issue with high flows and some damage to it a few years ago, maybe 3 or 4 years ago but it was in place in 2020 and 2021. The year-round fishway has been in place for many years,” she added of environmental accommodations attached to the project.

Chart summarizing the ‘Warren Project Components and Specifications’ found on page 21 of the 161-page PDF documentation.

So, if the river’s fish and eels are happy with the project as presented, what could we humans have to worry about from an electrical generating operation in place on the Shenandoah River in Warren County since 1924, coming due for another 30-year operational licensing? Little to none, it would seem. – And we’re betting info on any refurbishing of the dam originally placed nearly a century ago is lurking in those 161 pages of the Warren Hydroelectric Project re-licensing summary, or other related documents on the FERC website. We’ll let you know when we find them – or maybe we should just bother Ms. Foster again, or not. She, like Petty, has been very helpful. And we promised her that “eel ladder” question would be our last – at least for today.