To be or
not to be...
that is the dam question
A Playbook for Dam Decommissioning & Removal
To be or not to be.....
Contributors: Stephanie Landers, Kelly Schaeffer, Tim Oakes, Tyler Kreider, Michael Parker, Rebecca Allen, Chris Vella, Finlay Anderson, and GinaRenee Autrey.
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TA B L E O F CO N T E N TS
A Playbook for Dam Decommissioning & Removal What is Dam Decommissioning? Stage 1: Pre-Feasibility Stage 2: Project Evaluation (Feasibility) Stage 3: Developing Public Support & Final Approval Stage 4: Implementation (Design & Permitting) Stage 5: Construction Stage 6: Post-Construction / Monitoring CONCLUSION Play Exposition: Factors to be Considered
Introduction In William Shakespeare’s play - The Tragedy of Hamlet, Prince of Denmark - the main character, Hamlet, agonized over the decision ‘To be, or not to be,’ to continue and fight against obstacles and troubles or to die and no longer face those obstacles. Some dam owners may struggle with a similar thought process of rehabilitating aging infrastructure or pursuing dam decommissioning. Dams are an essential part of water management infrastructure and provide renewable energy generation, flood mitigation, aquatic and terrestrial species habitat, increased navigation, and recreation opportunities. Many dams in North America were built over a hundred years ago or are rapidly approaching that milestone. While some dams are well-maintained, others have deteriorated and require repair. Aging infrastructure can pose liability risks and may also require significant capital to improve and remain operational. In addition, dams without fish passage limit fish movement and can adversely affect aquatic species and their habitat. In light of the aging infrastructure and environmental issues, dam owners must weigh the economic, engineering, environmental, and social interests to make an informed decision on whether to keep or not to keep the asset.
Kronborg castle - known to many as Elsinore - the setting of William Shakespeare's famous tragedy Hamlet Prince of Denmark
Based on our experience with over 30 dam decommissioning projects across North America, and in keeping with the drama of Hamlet, we present the “six stages” of exploring the strategic thought and decision-making process for choosing to keep a dam and related infrastructure or decommission the asset. The six stages include: 1) 2) 3) 4) 5) 6)
Pre-feasibility; Project Evaluation (Feasibility) Developing Public Support and Final Approval Implementation (Final Design and Permitting) Construction Post-Construction Monitoring
Because our focus is dams in North America, there are references throughout this paper to dams regulated by the Federal Energy Regulatory Commission (FERC or Commission), nonFERC regulated dams (which are most likely non-powered dams), and dams in the Canadian provinces. Much of the strategic planning process is similar in the six stages; however, strategy specific to FERC, or Canada, or non-FERC regulated dams is presented separately. In addition, in the ‘Play Exposition ’ companion to this document, we provide details on some of the primary environmental and social issues typical of a decommissioning project. And now, on with the show! k l e i n s c h m i d t g ro u p. c o m
Setting the Stage What is Dam Decommissioning? Any structure that diverts or stores water can be considered a dam, but the legal definition of a dam varies according to the jurisdiction in which the dam resides. A dam decommissioning, similarly, may also vary but in general, may include abandoning in place, partial removal, or full removal of the existing dam and adjunct facilities (powerhouse, penstocks, switchyard). If the dam produces power, power production would cease, and the owner would remove or deconstruct the generating components. A dam decommissioning project includes site identification, feasibility, project planning through design, implementation, construction, and post construction monitoring.
Why consider decommissioning a dam/hydroelectric project? •
If a dam no longer serves its intended purpose, for example, it is no longer providing power for local industry, then an owner may consider dam decommissioning. An owner would also evaluate dam decommissioning if major public, safety and/or environmental concerns exist that cannot be mitigated due to lack of adequate funding or resources to maintain the dam infrastructure.
“Whether ‘tis nobler in the river facing The slings and arrows of costly regulation, Or to surrender against a lake of troubles And by removing end them. To end—to generate? That is the dam question!” k l e i n s c h m i d t g ro u p. c o m
When does dam decommissioning make sense? The most crucial factor when identifying to be or not to be is understanding that there is not a one size fits all for identifying if a dam should be remediated or decommissioned. Every project will have different site-specific engineering, environmental, and community considerations. The decision to remove or fix a dam is based on carefully evaluating a wide range of potential structural and nonstructural considerations, which could include rehabilitation or repair, dam replacement, dam removal, reservoir re-operation and even no action at all.
Where to start? Start with defining your objectives. This involves identifying the risk/reward of either restoring a dam or hydroelectric site versus the risk/reward of decommissioning and the cost associated with either. Project factors to identify and evaluate beyond cost include risk, public safety, fish passage and aquatic migration, river restoration, sediment exposure, economics, project funding, public benefits, owner benefits and multiple environmental impacts. Each dam decommissioning will have a schedule based on the project size and scope, and most projects take years from concept to completion. The beginning stages (Stages 1-2 below) help identify whether the project moves forward with decommissioning, and involves planning, prefeasibility, and feasibility. Once there is a decision to decommission the next stages (Stages 3 – 4 below) involve building upon public support, engineering design, filing permits and final approvals. This all comes before any shovel can enter the ground as implementation/construction begins in Stage 5. Stage 6 is the final stage of post-construction monitoring.
The 6 Stages of Dam Decommissioning Stage 1 – Pre-Feasibility Beginning the Process - Project Initiation and Screening Pre-feasibility, or Stage 1, typically involves: • Identifying the candidate dam(s) structures • Identifying issues • Assessing potential future challenges • Identifying stakeholders • Coordinating permitting and licensing responsibilities and roles • Reviewing and screening information The actual steps and sequencing will vary depending on the jurisdiction, site conditions, stakeholder objectives, and other factors specific to each dam. An experienced consultant can help develop a conceptual solution for dam restoration or removal, dam safety, sediment re-use (if present), shoreline/ stream restoration, and form an initial high-level opinion of probable costs.
Strategic planning will help determine the proper course of action and reasoning around decision-making focusing on the owners’ organizational needs, existing infrastructure, and assessing values of the asset. There are eight essential factors to research in Stage 1 Pre-Feasibility that will be fully vetted and referenced throughout the remaining stages:
Structural Integrity
Socioeconomics and Environmental Justice
So, to keep or not to keep? At the end of Stage 1, if
Public Safety
Environmental Resources
First Nation, Historic and Cultural Resources
Economics
decisions around decommissioning are still unclear, then it is time to enter Stage 2.
Recreation, Land Use and Aesthetics
Social Considerations
At the conclusion of Stage 1 (Pre-Feasibility), this initial analysis may inform the decision-maker that the best option is to restore the dam, which may include adding hydroelectric capacity, as well as mitigating structural, public safety, and/or environmental risk with well-planned refurbishment. More commonly, a dam owner may complete Stage 1 and move to Stage 2 (Feasibility), to continue data gathering and analysis to inform their final decision.
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Stage 2 – Project Evaluation (Feasibility) Stage 2 is the Project Evaluation or “feasibility study” stage. Feasibility is a deeper dive that may involve both desktop and field studies while examining conditions and the eight essential factors that influence the decision. This stage will typically involve assessing stakeholder interests, including federal, state/provincial, and local resource agencies, affected Canadian First Nation communities and U.S. Tribal communities, adjoining landowners, recreation users (fishing, boating, paddling), local communities, and non-governmental organizations. The eight factors identified in Stage 1 (Pre-feasibility) must be entirely understood and addressed to set the project owner up for success during the permitting stage. For partial or full dam removal, an owner may need to identify sediment characteristics, including a toxins evaluation, determine where and how sediment will migrate following dam removal, and calculate sediment volume. Other possible evaluations include hydrologic and hydraulic modeling, rare/threatened or endangered species surveys, wetland locations, water quality information, existing utilities including intake and outfall pipe locations, and channel substrate/bedrock presence near the dam removal site. During this stage, owners who’ve determined they want to decommission should start developing conceptual breach or removal designs, perform alternatives analysis (including risk analysis), create an opinion of probable construction costs for selected conceptual designs, and create conceptual design packages. If available, assess historic bathymetric maps of the project area to understand historic sediment characteristics compared to current levels of sedimentation, which may involve a new bathymetric study.
Permitting Requirements A critical activity in Stage 2 is identifying permitting requirements to prepare for Stage 3, including a pre-application meeting with applicable regulatory agencies to determine permitting requirements and information needs. Knowledge of data needs early in the process will help reduce project delays and costs. In the U.S., FERC-regulated hydroelectric projects follow the license surrender regulations at 18 Code of Federal Regulations (CFR) Sections 6.1 and 6.2. In Canada, non-federal dam decommissioning falls under provincial regulatory requirements, which can vary considerably.
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FERC processes applications to surrender a project license or exemption to ensure that safety and environmental concerns are addressed before authorizing the project to be removed from federal jurisdiction. As a part of the process and application to surrender, licensees must submit an Environmental Analysis and a Dam Decommissioning Plan. All licensees filing a surrender application with the Commission must address issues such as: • Dam and public safety • Environmental resources
The licensee must identify all project features: • Dam and reservoir • Power plant • Transmission lines • Recreation features, etc. • How they will be disposed
By the end of Stage 2 (Project Evaluation), dam owners should have adequate information to decide BEFORE entering Stage 3. Stages 3 – 6 in dam decommissioning entail a significant amount of permitting, dedication, time, cost, and resources and should only be undertaken if the decision has been made to decommission. Making the final decision of to be or not to be at this point ensures any costs moving forward are those associated with the chosen path. It is now time to make the decision. If the proponent is still on the fence, then more information should be collected in order to make that decision.
When we can decide it is over and remove Before it falls with age? Why should freshets bear, To resize and anchor to meet changing guides, Unless the power is valued. But to walk away Is not an option, and studies and costs which will Never show a return, puzzles the will, And makes us rather bear those ills we have
Than fly to others that we know not of? Thus the process doth confuse us all, And so the notice of intent Is wrestled over when deadlines approach, And focus of study effort is unclear to determine. With green power lost but restoring currents turned dry To be or not be is not an easy answer.
Stage 3 – Developing Public Support & Final Approval Now that the owner has decided to decommission the dam, it is time to build upon Stages 1 and 2, develop public support and complete the applicable federal and state/provincial processes. Following literature reviews and applicable studies, the owner would develop a schedule that incorporates other federal, state/provincial and local processes. Discussing the decommissioning process and applicable permitting requirements can help the owner determine the scope of the effort, costs, and schedule. Using the stakeholders identified in Stages 1-2, the proponent can now investigate fundraising, move forward with requesting letters of support, identifying and contacting possible funding sources through government, private, nonprofits (for example - watershed groups, sportsman’s associations), and grants. In Stage 3, the project is announced and the owner works with stakeholders to address additional resource or process questions. Conducting public meetings and meetings with permitting agencies, special interest groups, dam owners, and local municipalities are essential steps in this process. Stakeholder support during these Stages (1-3) will facilitate a smooth transition to Stages 4-6. The environmental assessment review includes formal notices, public, and agency consultation to review the dam decommissioning project and evaluate the decision around the notification of the license to surrender.
Many stakeholders will have an interest in a dam decommissioning process.
Hydroelectric projects under the Commission’s jurisdiction cannot be abandoned; the Commission must approve surrenders in order to ensure public safety and applicable environmental protection needed. The complexity of the surrender process is determined by the site-specific conditions and the implications of ending Commission jurisdiction. Any surrender application must include a decommissioning plan describing the planned disposition of project facilities; an environmental report that describes the existing environment in the project area, environmental effects that are expected to occur upon surrender, and any measures that would be taken to mitigate those effects; as well as a schedule for implementing any proposed measures, and copies of consultation with relevant federal and state agencies. The application must include plans to restore any federal lands occupied by the project to a condition acceptable to the applicable land management agency. Upon receipt of an application for surrender, FERC’s Division of Hydropower Administration & Compliance (DHAC) staff will review the application. FERC may request additional information from the applicant necessary to complete their review and then issue a 30-day public notice soliciting motions to intervene, comments, and protests. DHAC staff generally issues an Environmental Assessment (EA) pursuant to NEPA that analyzes the environmental effects of the proposed surrender. The public has the opportunity to provide comments on FERC’s environmental document. Finally, the Commission will issue an order on the surrender application, which considers stakeholder comments filed in the proceeding, and the analysis performed in the EA. The surrender order will address the disposition of the hydro facilities and may contain specific environmental conditions based on analysis and protection of the public interest. The conditions in the order must be complete before the surrender becomes effective and Commission jurisdiction over the project ends (See 18 CFR 6.2).
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An experienced consultant can assist dam owners with license surrender regulatory processes in the U.S. and Canada including: • • • • • •
• • • •
License surrender applications Dam decommissioning and stabilization plans H&H modeling and water quality studies Developing materials for public and agency meetings. Designing new channel and rock ramp structures Evaluating the breach size under numerous river flow conditions, based on operation of the upstream dams and hydro facilities Certificate of approval for temporary sediment settling ponds Archaeological assessment clearance, plans and specifications Interference with wetlands and alterations to shorelines Watercourse’s regulations, issued by the responsible conservation authority
In Ontario, the issuance of an approval by the Ministry of Northern Development, Mines, Natural Resources and Forestry (NDMNRF) may constitute a disposition of rights to Crown Resources and trigger the need for the applicant to either conduct an Environmental Assessment, according to NDMNRF’s Class EA process or, if applicable conduct a different Environmental Assessment (e.g., Municipal Class EA or Conservation Ontario Class EA). If a dam is located on Crown land, the NDMNRF’s Class EA for Resource Stewardship and Facility Development Projects applies to dam decommissioning or retirement. implementing dam decommissioning for a Canadian project may require that several different government approvals be obtained before the onset of construction. Policies that will be heavily involved in the project and need to be paid attention to in the U.S. are the Federal Power Act and Clean Water Act. FERC has discretionary authority, but other agencies may have mandatory conditions around certain aspects. Beyond mandatory requirements, agencies can comment to FERC on other things to consider.
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Potential approvals at the federal level in Canada could include but are not limited to the Fisheries Act authorization for the harmful alteration, disruption, or destruction (HADD) of fish habitat issued by the Department of Fisheries and Oceans (DFO), formal approval under the Navigable Waters Protection Act issued by Transport Canada, and Environmental Assessment Screening pursuant to the Canadian Impact Assessment Act (IAA).
Stage 4 – Implementation (Design & Permitting) It is now time to put the not to be plan into effect and execute the dam decommissioning project. The dam owner now creates Request for Proposals (RFP) specific to drawings, technical specifications, and construction requirements to allow contractors to bid on the project. Conceptual level drawings that may have been adequate for environmental analysis now need to be turned into final constructible designs. These designs need to be approved by a registered professional engineer. In Stage 4, a consultant can prepare final drawings & specifications for construction and incorporate design considerations from the Army Corps of Engineers and other federal, state/provincial agencies. This also includes updating opinion of probable construction costs, conducting site surveys that incorporate topographic and bathymetric metrics, performing calculations around design removal, and finalizing and submitting permit applications. Permit applications and approvals are a significant focus in Stage 4 because obtaining the permits are vital to the construction schedule. As the project moves into deconstruction (Stage 5), there will be more specific local permitting. For example, the county conservation authority may need to approve erosion control plans or permits for road/bridge access may need to be issued by local municipalities. Other items to consider are if the project is on a federal reservation (reserve in Canada – and note a different process), wildlife refuge, or other land managed by national forest. Regional regulatory requirements around maintaining the water supply, fisheries, and river views, which vary in North America and are often factored into licensing. For example, if a decommissioning project is located on federal lands, the land managing agency will play a significant role. FERC notes that “where project works have been constructed on lands of the U.S., the existing licensee would be required to restore the lands to a condition satisfactory to the federal agency having supervision over such lands”. National forests may have processes around invasive weed control and aquatic invasive species. If a decommissioning project is on a federal reservation, a land manager will play a significant role.
How has it borne the droughts and scours of time, The license process, the compliance record, The pings of rusted steel, and concrete decay, The incentives limited, and costs high.
We recommend these Best Practices in dam decommissioning: 1) Open communication with stakeholders 2) Clear understanding of the project including visual representations is helpful to the agencies and public 3) Qualitative and Quantitative information that will support the environmental review
Portion Removed Portion Lowered
There are other requirements to consider in the U.S., such as state water quality certification (under Section 401 of the Clean Water Act) and Section 404 dredge and fill permits from the U.S. Army Corps of Engineers. Once these permits are filed with the appropriate agency, there may be some additional information requests before approval. Depending on the agencies involved, this can be a time-consuming process. Once the owner has all permit approvals, the dam removal may proceed. (Stage 5). Stage 4 may feel frustrating, and even duplicative, but an experienced consultant can help consolidate and navigate the permitting process. To summarize the stage in the words of Polonius from Hamlet “Though this be madness, yet there is method in‘t.”
Once the formal application is submitted, parties can challenge the application. Stakeholders can comment individually or through associations and coalitions. Stakeholders may oppose decommissioning, particularly when it threatens real estate values or historical uses of areas.
Stage 5 – Construction Congratulations to those who reach Stage 5 as the project finally enters the construction stage. Stage 5 is the culmination of research, studies, analysis, engaging stakeholders and working with federal, state and local or provincial entities. The dam is not to be, and it is now time to remove the structure and officially make it so. In Stage 4, FERC issued an order approving the surrender, and the owner can proceed with construction; however, the timing depends on other permitting requirements. FERC regulates non-Federal jurisdictional hydropower, but they do not oversee non-powered, and non-FERC jurisdictional dams. These dams are generally covered by the individual state. If Stages 1-4 are successful, these agencies have already been consulted and permits filed. At this point, design has been determined, a path forward is in place, and a construction contractor for deconstruction selected to perform the dam removal. Thanks to the rigorous research and identification of erosion and sediment controls in prior stages, sediment management has been determined and will be performed either through excavation, natural erosion, or stabilization in place. In Stage 5 a construction contractor has been selected to perform the dam removal. Construction will involve lowering the reservoir and stabilizing exposed sediments and banks, as necessary. The dam will be strategically breached, and the required infrastructure will be removed, and riverbed grading will be initiated to restore the stream and channel (if required). A re-vegetation plan may include planting live plants, tree stakes, and seeds to restore formerly inundated areas. When the site is stabilized, erosion and sediment control measures are removed. Once construction is complete, it is time to move onto Stage 6, which may include finalizing permitting requirements, remediation on site, communicating the project completion to stakeholders, and completing any final permit reporting to applicable federal agencies.
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Stage 6 – Post-Construction / Monitoring The dam decommissioning project is nearing completion. Stage 6 involves post approvals, monitoring, data collection, and for some projects, adaptive management. Monitoring may require performing site visits as needed to assess environmental conditions and to comply with the federal, state or provincial monitoring requirements. Post-construction requirements are site-specific and dictated by regulatory requirements. In some cases, there may be limited monitoring, while in others, it could be years of monitoring after post dam removal. An owner can develop a strategy for appropriate monitoring, based on consultation that has occurred in previous stages. FERC regional offices determine whether the dam owner has met the obligations pursuant to the decommissioning order. At that point, the dam owner is no longer under FERC jurisdiction. State or provincial agencies may require post-monitoring as well. Post-construction also involves closing out of grants, contracts and publicizing project results. Sometimes it may even involve a celebration of completion with project partners such as regulators, stakeholders, and individuals who supported the project.
CONCLUSION - The Final Curtain Dam decommissioning projects are long and intensive, like Shakespeare’s most extended play Hamlet (with 29,551 words). As a proponent who has now navigated through the decision-making process of to be or not to be and the 6 Stages, it may comparably feel like tens of thousands of words have gone back and forth between government, stakeholders, consultants, and the public to come to this conclusion. Hamlet is considered one of the most powerful and influential works of world literature. Similarly, is the influence of a dam on a river and ecosystem. Perhaps being the owner of a dam that is no longer in existence comes with some relief in knowing that, unlike Hamlet, dam decommissioning is not a tragedy. As of 2016, American Rivers reported that nearly 1,400 dams had been removed in the United States. Dam removal is expected to continue with changing environmental values, aging infrastructure, climate change, and continued reservoir sedimentation challenges.
For more information on the factors that go into making the decision for dam decommissioning and removal, please see our Play Exposition: Factors to be Considered in the next section of this document.
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About Kleinschmidt
Kleinschmidt has performed dam removal studies, designs, and construction monitoring of the removals for more than 30 projects across North America for both owners and public and private organizations. We have the engineers, biologists, ecologists, and regulatory permitting experts to cover all aspects of the dam decommissioning and removal process. Whether the decommissioning of your dam is primarily to restore fish passage or remove a structure that is no longer necessary, our team of experts has the passion and experience to work with you to make your project a success. For more information or to schedule a consultation with one of our dam decommissioning experts, please email us at solutions@kleinschmidtgroup.com Note: The purpose of this document is to provide general information in layman’s terms. It is not intended as legal advice, nor is it meant to be exhaustive of dam decommissioning or removal regulations or requirements. This document is property of Kleinschmidt Associates. No replication of its content is permitted without express permission from Kleinschmidt.
Play Exposition
Factors to be Considered
Each project will have different site-specific engineering, environmental, and community considerations in the ‘to be or not to be’ decision. In the following pages we will provide a brief overview of some of the most common factors to be evaluated and considered including:
Environmental Impacts and Benefits Structural Integrity and Public Safety Recreation Cultural and Historical Significance Hydrology and Hydraulics Extreme Weather Events Fish and Fish Passage Economics Licensing and Permitting Cost Benefit Analysis Project Funding Sediment Exposure
Factors to be Considered in the Decision To Be or Not to Be Environmental Impacts and Benefits
Structural Integrity & Public Safety
When considering the potential impacts of dam decommissioning, the term environment is used in a broad sense to include the natural environment and social and cultural values. Economics and cost are crucial factors in the decision-making process (discussed further on). Still, not all decisions are costdriven, as some sites may have environmental and social benefits that come from a dam remaining in place or being decommissioned.
Public safety is a significant consideration when identifying if a dam location is fit for rehabilitation or removal. A dam inspection is a good starting point for identifying risks at dams.
Dams and hydroelectric facilities are operated to balance multiple social, environmental, and economic objectives. Prior to decommissioning a dam, a rigorous environmental assessment and permitting is required through which local and sitespecific values, including those associated with hydrology, hydraulics, sediment, fish, and fish passage, are all heavily considered.
If a dam has significant structural issues and is in danger of failing, decommissioning is often recommended. In other cases, a dam may be in good condition, but it doesn’t meet newer, more strict dam safety requirements. Understanding what needs to be repaired at the site, and knowing the time, permitting requirements, and cost to bring the dam into compliance with required standards is an important consideration when assessing whether to decommission. Some items to consider when it comes to refurbishment will be if the structure needs a new spillway or new foundation anchoring.
An engineer can look at the concrete structure and integrity of the infrastructure, earth embankment, risk of failure (dam breach), and/or unanticipated release, which can happen slowly or all at once.
Often the larger dams are of concern to dam owners or the public, but low head dams also need to be assessed and can also be a safety risk. Aging infrastructure is of particular concern, as many dams reach several decades or even centuries of existence, there is more risk of failure. Another consideration is if dams are removed improperly, then there can also be safety risks.
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“There is nothing either good or bad but thinking makes it so.” (Hamlet, Act 2 Scene 2)
Recreation Dams are often located on river systems that are heavily used by the public for multiple recreation activities. These activities can range from boating, paddling, fishing, swimming, resource-based tourism, and first nations cultural activities such as fur/baitfish/ wild rice harvesting, etc. When considering decommissioning and associated permitting, public input needs to be considered as it can be more complicated in areas that affect local communities. It is important to identify potentially interested parties early on in order to take the initial steps to unite and optimally support a proposed project. Regardless of the decision to be or not to be, all stakeholders must be thoroughly engaged from the beginning to ensure transparency and that local considerations and eventual community support (also known as social license) are met by those who will be most affected. While Stage 2 is identification and initial outreach, Stage 3 will focus on public support initiatives, environmental impacts and benefits, and the associated permitting and approvals that go along with these assessments.
There may be an assumption that water resource users would prefer not to have an existing dam in place due to environmental benefits of removal, but this may not be true in some cases. Remember, each project is unique. Consider those individuals who have been using the water and land or using the dam infrastructure and existing water levels for recreation activities such as fishing, boating, or swimming; or those who may feel that the removal of the dam means a loss of aesthetic values. Property values can be affected due to changes in water levels, and ‘waterfront’ property may no longer be close to the water once the dam is removed. Boating on the reservoir above the dam may be drastically changed. Not in my backyard issues (NIMBY ) do occur often, and adapting to change takes time. The sooner a dam owner can engage, consult, and communicate to stakeholders on the project goals and timeline to get community buy-in, the better.
Cultural and Historical Significance Since dam decommissioning often aligns with aging infrastructure, many projects have historical and cultural significance to a particular group or location. Heritage studies and historical relevance of the dam or the impacted area surrounding the dam is something to consider in literature reviews and moving into stakeholder engagement. Consultation with State Historic Preservation Offices an federally recognized Tribes in the U.S. is required on all FERC licensed projects. Potential impacts to archaeological sites or historic features need to be identified and potentially mitigated. Identification of these resources can help mitigate potential challenges related to maintaining and respecting cultural and historical significance. Additionally, as part of a complete cultural analysis in North America, indigenous engagement is included to varying degrees, depending on project location. In Canada, consulting with indigenous communities and ideally incorporating First Nations Traditional Ecological Knowledge (TEK) through local indigenous communities helps identify historical and cultural factors which may not be considered otherwise. TEK represents experience acquired over thousands of years of direct human contact with the environment. Cultural and heritage resources surveys, engagement, and consultations with First Nations can help to foster support for the project.
Hydrology and Hydraulics Most impacts associated with dam decommissioning arise from changes that the original development and/or operations made to the river’s flow regime. One of the keys to dam removal is detecting any flood storage behind the dam currently and if it will be an issue with altering the floodway. The U.S. Federal Emergency Management Agency (FEMA) conducts flood studies and hydraulic analysis that can be used as a basis to see if the dam removal will create additional flooding or rise in flood levels. This may be an easy conclusion in a typical dam removal, but larger dams can be harder to identify due to the larger management of flood water and deregulated water. In Canada, local governments, provincial emergency measures organizations, and provincial water resources organizations bear most of the planning and relief operations responsibility.
Under the National Flood Damage Reduction Program, the federal, provincial, and territorial governments cooperate to map and designate flood risk areas across Canada. Flow regime is a concept that covers many parts of a river’s behavior, including magnitude, frequency, duration, timing, and rate of change. Flow regime is a defining characteristic of river systems and is important to its environmental health and integrity, and the interests of other users of the resource. Flow magnitude refers to the volume of water moving past a fixed point over a period of time. Dams can modify flow magnitude in rivers by holding water back in reservoirs and controlling water discharge below the dam.
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This can be beneficial by reducing flooding as well as supplementing flow during low flow periods. Flow frequency refers to how often a flow of a certain magnitude takes place over a specific period of time. Dams, hydropower operations, and other control structures can change the recurring pattern of flows on long and short-term scales. Flow duration is the interval of time, or how long or short a flow occurs and can be affected more by dams with storage reservoirs, which manage water discharge to maintain flows for longer or shorter periods than what would naturally occur in the river. For example, the timing of flows in a hydropower facility relates to the release of water through the turbines, to generate electricity during certain seasonal periods or times throughout the day. The timing of flow events created by operations of a dam often differs from that of an undeveloped river. Dam decommissioning will therefore alter the flow regime. This is the fundamental challenge and opportunity – to achieve a balanced sharing, a sustainable use, of this resource through understanding, respect, compromise, and cooperation.
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Extreme Weather Events To protect against flooding, conservation authorities, governments, and private industries have constructed and maintained protective infrastructure such as dams. Flood risk information and safety plans help government planners reduce development in areas at high risk of flooding and reduce potential for residential harm. Dam and hydro facilities can only protect high-risk flood areas and zones as much as their infrastructure enables it. Extreme weather events and community location to water bodies is often out of the dams or operators’ control, but some dams can help to reduce the impacts of major flood events. When a dam is removed and the area is restored to a natural system, this could considerably alter flood zones and there is no longer any control of river flow. A dam may need to be kept in place to ensure flooding does not happen to communities further downstream from the site.
Climate change has already proven, depending on the location, to increase the potential for flooding or drought occurrence. Water velocity and water depth can drastically change with the onset of ‘100-year floods’ breaking precipitation records on a more regular basis. Conducting max storm flood analysis can help with the decision to remove a dam because the results may not pass Probable Maximum Flood (PMF) requirements. PMF is designed to identify flood level points where the dam is at risk of overtopping at which point there will be a likely dam failure, driving motivation to remove the dam. On the other side of extreme weather events, historically dry areas with drought conditions lead to a lack of water, contributing to the decision-making process if the water flow is no longer high enough to justify power or is no longer supporting other water resources need. In these cases, the dam may be preventing other uses from accessing important water resources.
Fish and Fish Passage Most projects involve potential effects related to fish, fish passage, and fish habitat. Aquatic ecology may be impacted by changes in water levels and temperature. Dams can also affect nutrient enrichment, access to aquatic habitats, and connections between the river channel and the floodplain. When looking at dam decommissioning, both the downstream ecosystems can be affected by erosion or low/ high flows, while the upstream ecosystem and/or reservoirs can affect flooding and sedimentation. All of which can impact the aquatic ecology, the fish, and terrestrial wildlife. Ecological connectivity is usually expected to improve with the removal of a dam. However, some brand-new dam removals may be a barrier to fish passage due to increased water velocities or other factors. Pre-removal studies and testing will help identify if postmitigation efforts may be needed. A presence or absence study may be done through electrofishing or other means to see where the fish are pre and post-dam removal to see if fish can swim back and forth through the newly opened river channel.
Water temperature and dissolved oxygen levels may also change with the removal of a dam. Whether this is positive or negative to fish species depends on how the water was released at the original infrastructure. For example, if a dam is releasing water from the bottom of a reservoir, summertime releases will often be colder and contain less oxygen than natural river flows. Provided the oxygen levels recover quickly, this can be beneficial to some cold-water fish species, and dam removal may change the species composition in the river. If water is spilling over a dam, oxygen is likely being added to the water and this benefit may be lost when the dam is removed. Fish species can be affected by changes in water temperatures and oxygen levels, as will macro invertebrate communities where there is usually a shift in species composition pre and postremoval.
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Other considerations with fish passage are new opportunities for invasive fish species to move up or down the river system once the dam has been removed. Identifying potential risk around invasive species and management may also be assessed and potentially addressed. There is a cost associated with infrastructure to meet modern dam fish passage and species habitat requirements. Some facility owners may find the cost of the addition of fish passage or mitigation for species at risk too much to justify dam remediation, making the decision of not to be an easier one – particularly when resource agencies typically support dam removal as the preferred option for fish passage.
Economics All the aforenoted factors must be integrated into the actual cost of dam decommissioning. In conducting a realistic cost-benefit analysis, owners should understand that decommissioning a project will, in most cases, be more expensive than one might expect. Depending on the project, dam decommissioning may prove to be a lower cost option in terms of immediate capital investment and provide bigger picture benefits from reduced owner liability and the environmental benefits of remediating a location to the original natural river system. If the intention is to walk away and cut the power, but leave the dam in place, this is different than completely removing the dam.
Licensing & Permitting Although refurbishing a hydroelectric facility is an attractive alternative with long-term economic benefits in energy/grid cost recovery, and contributing to a low-carbon renewable energy economy, there can be unforeseen costs around regulatory compliance, particularly when bringing aging infrastructure up to new dam safety regulations, environmental studies and mitigation required through re-licensing. The cost and time-specific to adhering to regulatory requirements in North America are significant, and obtaining a new license from the Federal Energy Regulatory Commission (FERC) in the U.S., for example, can be prohibitive, especially for small-scale projects. Project owners are therefore increasingly considering decommissioning their projects as an alternative to relicensing and continued operation. Dam removal in North America works through state/provincial/federal government permitting requirements linked to the degree to which the dam is owned publicly vs. privately.
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“To notch, perchance to restore —ay, there’s the rub: For what is restore when the world keeps changing?”
Cost Benefit Analysis Bringing in professional consultants to do a cost-benefit analysis can aid in identifying project challenges and costs that could save a significant amount of time and money. There are costs associated with conceptual designs, repairs, permitting, assessments through final design to construction, and issues or barriers that may not be predicable right away. There could be additional studies identified to satisfy stakeholders opposing the project. Determining what is feasible will help with estimating costs. Alternative options do exist and need to be considered. A proponent must look at all options and ask questions - Can the asset be sold? Is it a partial or full dam removal? Is there a way to enhance the existing infrastructure or environmental habitat? Will the public or special interest groups support or oppose the project?
Owners should look at the pros and cons on both sides of the decision-making process. It is not a ‘one size fits all’ and, in some cases, a hybrid approach could be identified. For example, some larger projects have multiple dams in a cascade river system; in this case the owner may decide to upgrade a hydropower site to increase MW capacity, while decommissioning other dams along the same system. Each project is unique. Decisions should be based on what is best for the client with all factors considered, including dam location, structural integrity, public safety, permitting, environmental impacts, public uses, culture relevance and recreation.
Project Funding Evaluating funding options is an important part of cost analysis. There are owner-funded, grant-funded, or a combination of both funding options available, depending on the dam(s) location. Often the review and feedback from stakeholder engagement can help to pursue fundraising opportunities from project supporters. There is funding available for various aspects of the projects and from different organizations. There are fisheries and ecological minded state/provincial or federal level grants and funding options in some jurisdictions.
In some cases, funds are set aside for restoration projects, or in other cases, opportunities around recreation, aquatic flora, and fauna and fish passage may be available. For example, the U.S. National Fish and Wildlife Foundation provides funding on a competitive basis to projects that sustain, restore and enhance the nation’s fish, wildlife and plants, and their habitats. There are currently efforts in the U.S. to pass legislation that would provide tax credits for investments in dam removals.
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Sediment Exposure Geomorphology is a significant factor to consider when looking at dam removal. Researching how the dam was developed, the amount of sediment in the upper reservoir or below the dam, identifying where the sediment will end up with the removal, and if there are any contaminants in the soil. If sediment must be removed, then the banks may be different than when the dam was in place. Erosion risk after post dam removal can be a concern due to minimal vegetation, but vegetation usually comes back organically, and if not, mitigation efforts using vegetation (staking/tree planting) will be part of Stage 6 post-construction requirements.
Figure 4: Reduced sediment – Note: the water is deeper, but water levels are lower - considerations with environmental and recreational changes post decommissioning
About Kleinschmidt
Kleinschmidt has performed dam removal studies, designs, and/or construction monitoring of the removals for more than 30 projects across North America for both owners as well as public and private organizations. We have the engineers, biologists, ecologists, and regulatory permitting experts, to cover all aspects of the dam decommissioning and removal process. Whether the decommissioning of your dam is primarily to restore fish passage or remove a structure that is no longer necessary, our team of experts has the passion and experience to work with you to make your project a success. For more information or to schedule a consultation with one of our dam decommissioning experts, please email us at solutions@kleinschmidtgroup.com Note: The purpose of this document is to provide general information in layman’s terms. It is not intended as legal advice, nor is it meant to be exhaustive of dam decommissioning or removal regulations or requirements. This document is property of Kleinschmidt Associates. No replication of its content is permitted without express permission from Kleinschmidt.
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