Catskill Preservation Comments

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Joelle Chorny, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Joelle

Karena Louise Cronin, Nyack, NY.
Dear Federal Energy Regulatory Commission, 

I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 



Thank you for your time, 

Sincerely,
Karena Cronin

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Linda Yassky, Phoenicia, NY.
We are writing to register our strong opposition to the application filed by Premium Energy Holdings, LLC ("Premium Energy") Project No. P-15056:000, for a preliminary permit. For the reasons discussed below, as well as those cited by over 800 entities and individuals in opposition to this ill-conceived proposal, we implore The Federal Energy Commission (FERC) to deny this permit application. 
 
Notwithstanding, we are vehemently opposed to using any of the three proposed sites – Woodland Valley in Phoenicia, Stony Clove in Lanesville, or Wittenberg Road in Olive to build a new reservoir for this proposed pumped storage. The construction of a new reservoir at any of these locations would require the flooding of protected land, adversely impacting two of the Catskills' most precious and inextricably intertwined resources: our local ecology and tourism. Indeed, the Catskills are not just "our backyard," but the backyard of over 12 million annual visitors (this does not count residents) from around the world to, among other things, hike her trails, climb her mountains, swim in her pristine waters, study her plants and animals, ski her mountains and breathe her fresh air.  
 
Before we address some of the many reasons Premium Energy's plan for the Ashokan Reservoir and its environs is untenable, we want to draw FERC's attention to two glaring missteps on Premium Energy's part that we believe raise serious questions about its integrity and overall wherewithal to actually see a project of this magnitude through to fruition. 
 
First, by all accounts, it appears that Premium Energy failed to either confer with or notify critical stakeholders about this proposed project. 
Notable among these are the New York City Department of Environmental Protection, which is responsible for overseeing and protecting the Ashokan Reservoir, as well as several other affected townships, including the Town of Olive and the Town of Shandaken. Simply put, this smells of bad faith.  
 
Second, Premium Energy's permit application disingenuously characterizes its proposed development as a "closed-loop" pumped storage (a less environmentally impactful process for harnessing the power that is eligible for streamlined FERC approval). Nothing is further from the truth as both the Ashokan Reservoir and its surrounding watershed are a continuously flowing natural water source. As FERC well knows, projects where an upper reservoir is added to an existing lower reservoir – as is proposed here – does not suddenly make it a closed-loop system but rather an "add-on" to an existing "open-loop" system.  
 
While one could dismiss these two discrepancies as oversights, given the stakes here, it is more likely that these were attempts to subvert best practices and push through what Premium Energy knows is a poorly conceived plan that was likely to meet significant resistance. Indeed, while Premium Energy's website highlights proposals for at least four other pumped storage projects, it does not appear that the Company has ever developed or operated a pumped storage facility. We would expect that a prospective permit holder's "track record" is a relevant consideration to your agency when considering proposals of this magnitude and scope.  
 
We are mindful that the New York state needs to move away from our reliance on fossil fuels and that hydroelectric power offers such an opportunity. However, the Ashokan Pump Storage Plan is not the type of innovation the Department of Energy wants as the negative impacts far outweigh the minimal benefits.   
 
According to Premium Energy's permit application, the APSP would generate only 800 megawatts of hydropower. Notably, that is less energy than what would be required to pump the water uphill to the "new reservoir." The creation of 800 megawatts of power (to be sold at a higher price when the grid requires) appears to be the only thing to be gained by this project, of which Premium Energy and not the citizens of Ulster County and the Catskills, is the sole beneficiary.  
 
As you know, the APSP is located entirely within the Catskills Forest Preserve, 700,000 acres of contiguous wildlife habitat in what has become an increasingly fragmented environment. While Premium Energy's permit application and accompanying topographical maps are fuzzy/inaccurate, it is indisputable that building a massive underground power station, flooding hundreds of acres of protected land and constructing a huge multi-mile underground tunnel to carry the water between a newly-built upper reservoir and the Ashokan, would cause significant disruption to the surrounding plant and animal life.   
 
The impact of the APSP on stream ecology would be significant as pumped storage facilities are subject to rapid water fluctuations that wreak havoc on both aquatic and land habitats. Altering the sediment regime in tributaries will also alter the Esopus and thus endanger one of the Catskills' most vital trout waters and valuable trout breeding grounds. 

Additionally, the Catskill/Delaware Water Supply provides 90% of New York City's water supply at a rate 1 billion gallons a day to over 9.5 million people. Within that system, over 40% of New York City's water supply passes through the Ashokan Reservoir. There is no doubt that this pumped storage project is likely o increase the turbidity in the Ashokan, which would decrease the quality of New York City's water. 

Similarly, the impact of this proposal on Catskills' tourism would be significant. The Catskills functions as a collective "backyard" for millions of people every year. Woodland Valley is among the most popular destinations in the Catskills. The Woodland Valley campground is one of the state's oldest campgrounds with over 5400 overnight campers and 2600 day-use visitors annually. Under the proposed plan to flood Woodland Valley, access to that campground would be cut off.

Kevin Scisorek, Pitman, NJ.
FERC project number, P-15056

I write to you today in vehement opposition of the preliminary permit application by Premium Energy in their effort to build a storage hydroplant in the Woodland Valley region of the Catskill Mountain Preserve.

When New York passed their clean energy standard in 2015 with the means to produce 70% of its energy through more renewable sources I'm sure its citizens rejoiced at the thought of doing better for the environment. How devastated they would be at the means by which this would be accomplished, by the destruction of acres and acres of protected forest lands. Even calling this "clean energy" is nothing short of complete hypocrisy, and I'm sure that at the time the voting took place if it was noted that this clean energy standard would involve the destruction of protected forest lands I highly doubt that it would have passed.

Article XIV of the NYS Constitution states (in relation to protected forest lands) that the lands  “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private”. Premium Energy seems to want to gloss over over fact that the lands which they are proposing to flood out were established as the Catskill Mountain Preserve in 1885, thereby giving them full protection under Article XIV. Being that this is a State Forest Preserve, the Catskills are also considered Status 1 land under USGS “Gap Analysis Program.” Direct from the Department of Energy’s Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” This being yet another fact that Premium Energy would like to turn a blind eye to.

These lands have been protected for a reason, as they are habitats for some plant, bird, bat and snake species on NY’s “threatened”, “special concern”, or “greatest conservation need” lists. Including the bog orchid, northern long-eared bat, scarlet tanager, wood thrush, black-throated blue warbler, and three hawk species just to name a few notable species. Not to mention the significant damage it would do to trout breeding areas. This alone should be reason enough to reject the permit. It would be a tremendous oversight to allow the destruction of an area, that has been protected for almost 150 years in the interest of preserving nature, in the name of an energy standard designed to limit environmental impacts.

I adamantly oppose this project and request that the Federal Energy Regulatory Commission deny this preliminary permit.

David Kearford, Brooklyn, NY.
Secretary Kimberly Bose 
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426 

Re: Ashokan Pumped Storage Project, FERC Project No. P-15056

Dear Secretary Bose,

As a resident of Brooklyn and member of the New York City Chapter of Trout Unlimited, I am writing to express my concern with Premium Energy Holding's preliminary permit application to explore the feasibility of a pumped storage project utilizing the Ashokan Reservoir. While I am a strong advocate for renewable energy solutions, I am opposed to this specific project for a number of reasons, including the adverse impact it would have on New York City's drinking water supply and wild trout in the watershed.

The Ashokan Reservoir plays a critical role in the famously unfiltered drinking water supply for New York City and the municipalities that draw water from the Catskill Aqueduct as the water is transferred downstate. The Ashokan Reservoir is unique in its construction compared to other reservoirs in the system in that it has two basins, the western-most of which is used as a "settling basin" and contains over 100 years of settled silt deposited by the Esopus Creek and other tributaries to the reservoir. This is the same basin that Premium Energy Holding proposes to draw water from and pump water back into. Any benefit from the proposed project strikes me as marginal vis-a-vis the adverse impact on the drinking water from the disturbance of this sediment or the cost for New York City to implement filtration.

Just as the disturbance of sediment in the western basin of the Ashokan Reservoir would pose a risk to the drinking water supply, the increase in turbidity and likely changes in stratification of the water temperatures would also adversely impact the trout and other aquatic life in the reservoir. Furthermore, the proposed project necessitates construction of a new, higher-elevation, reservoir on one of three tributaries (two are tributaries of Esopus Creek, the other a tributary of the Ashokan Reservoir itself). This would result in the loss of trout habitat and by introducing a barrier to fish passage (the dam needed to create the new reservoir) would likely impact wild trout that move upstream in Spring and Fall to spawn.

This is especially problematic given that as of April 1 of this year, under the NYSDEC's new statewide Inland Trout Stream Management Plan, Esopus Creek is now designated as a "Wild Quality" trout stream, and neither Esopus Creek nor Woodland Stream will be stocked with hatchery-raised trout in recognition of the excellent wild trout habitat that they provide. This "rewilding" of the Esopus Creek sport fishery stands to be an even bigger boon to the local economy than it is today.

It is also probable that the headwaters of the proposed alternate sites for the new upper reservoir are home to wild native Brook Trout, and potentially, isolated populations of "heritage strain" Brook Trout (as documented in the 2019 genetic study on South Hollow in West Shokan conducted by the Ashokan-Pepacton Watershed Chapter of Trout Unlimited in partnership with NYSDEC Region 3 Fisheries as part of the Eastern Brook Trout Joint Venture). Not only are they the only "trout" native to the streams of Eastern North America, and New York's "official state freshwater fish" (since 1975), but the enclaves of "heritage strain" Brook Trout that remain are directly descended from those which first inhabited the region after the glaciers melted some 10,000 years ago, remarkably survived the overfishing and early industrial developments that decimated their numbers and natural range by the turn of the 20th century, and have since survived competition from non-native trout and interbreeding with their hatchery-raised cousins. While not on either the Federal, or State, Endangered or Threatened species lists, they are of utmost historical and ecological importance and are extremely susceptible to the encroachment of development.

I have many other concerns with Premium Energy Holding's proposal, all well documented in the many hundreds of other comments that have been submitted to date. In light of these, and my comments above, I respectfully urge FERC to deny the application.

Sincerely,

David Kearford

Joshua Frank, Mount Tremper, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

(your name)

Juliette Mapp, Boiceville, NY.
To Whom It May Concern, 

I live in the Catskill Watershed and would like to draw your attention to a proposal from Premium Energy: FERC project and sub-docket number: P-15056. This is regarding Premium Energy’s application for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir.

This project raises serious environmental concerns and I ask that this permit be denied for a number of reasons outlined below.

First, this is not, as Premium Energy argues, a closed-loop project. It is an add-on project, which will have a much greater environmental impact than a closed-loop project. 

Secondly, a site where the storage facilities are being proposed is designated “forever wild” under Article XIV of the New York State Constitution, which asserts that such lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” To build a project on such a site is a violation of the New York State Constitution.

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
 
Third, the sites in this project are foraging habitats for many threatened species such as the northern long-eared bat and habitat for birds which are designated under New York’s Species of Greatest Conservation Need such as the black-throated blue warbler, scarlet tanager, and wood thrush, as well as for species designated of Special Concern such as the Cooper’s Hawk, red-shouldered hawk, and the sharp-shinned hawk, and the eastern hognose snake.

In addition, the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can severely impact aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will invariably be lost.

I understand the need for clean energy and for pumped storage. However, these proposed locations are crucial to the habitat of threatened species and are on and Status 1 protected land. This is the wrong area for such a project.


Thank you for your consideration,  

Sincerely,
 
Juliette Mapp
234 Upper Boiceville Road
Boiceville, NY 12412

Monica Compton, McLean, VA.
Oppose FERC project number P-15056

As a part-time resident of Woodland Valley, I am writing to voice my strong opposition to the proposal of a pumped storage hydro plant in the Catskills. Although finding green energy alternatives should be important for New York, the Catskills and NYC watershed are not appropriate areas for a pumped storage hydro project.

The proposed locations are not at all suitable for this project. This project would detrimentally impact highly protected areas of the Catskills, including the habitats of multiple protected species. The proposed locations would harm the habitat of plant, bat and snake species that are listed as either “threatened,” “special concern,” or “greatest conservation need.” Several bird and fish species, including trout and three hawk species, would also be greatly impacted by the location of this project.

The proposed areas of development are located within a protected state preserve protected by the state constitution to “be forever kept as wild forest lands.” The land management changes to the State Forest Preserve necessary to move forward with this project would require constitutional amendment, votes in two sessions in the state legislature, and submission for public referendum. The success rate for approving amendments through this process is close to 1%. The protections placed upon the Catskill Preserve were created to prevent a project like this, and to keep companies from exploiting state forests. The public will fight to preserve the wilderness of the Catskills and will not abide by the commercial exploitation of this protected land.

Drew Stuart, Lanesville, NY.
This unlawful proposal must be rejected from further consideration, in that it is not legal at its base application.  This proposal is in direct opposition to the New York State Constitution.  The proposed land use positions the reservoirs on New York State and private lands that have been designated to be 'forever wild' in establishing the Catskills Forest Preserve. The current proposal asserts that the reservoirs would sit 'adjacent' to the Catskill Forest Preserve, a lie Premium Energy Holdings is perpetrating to begin the next step of its study. Additionally, any reservoir would be devestational from an ecological and economic standpoint to all of the surrounding towns and villages.  The proposed land is status 1 habitat and some of the most unique ecology in all of the Northeast and the Catskills.  Additionally, Route 214 is a vital artery for Hunter and areas north.  None of this destruction is worth a proposal of energy arbitrage for a net 800MW of annual power.  Energy arbitrage is not green energy.  It is unfathomably catastrophic and would be economically devastating to land that provides New York City 40% of its drinking water and represents billions of dollars of tourism for the region.  Please reject this proposal for these reasons and the many similar submissions you have, no doubt, received.

benjamin cannon, new york, NY.
Dr. Benjamin Cannon, PhD
24 Bennett Avenue, Apt. 46A
New York, NY 10033

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

I am an avid hiker and camper, and the Catskills is my favorite park in the world. And within the Catskills, there is nowhere more beautiful, or wilder, than the wilderness off of Moon Haw Road--the place that the Ashokan Pumped Storage Project is proposed. Down a long dirt road that follows the pristine Wittenberg Brook, there’s a tiny gravel lot. On either side of that lot there are the sheer sides of mountains going up to the ridges that ring the valley. Hardy hikers, snowshoers, runners know and love this spot. There’s a trail, dizzyingly steep, that climbs through oak and then pine up to the sheer rocks of the ridgeline. Its steepness and remoteness keep it wild; there are no potato chip bags or beer bottles on the trails. Just trees and chipmunks and woodpeckers and black bears and the healthy deer that venture up into the valley in droves to feed in the warmer months. 

Once you get into the forest, water is everywhere. Icy, crystalline streams, the cleanest I have ever encountered. It is a landscape shaped by and dominated by water, a massive catchment basin formed by the valley bowl that drains into Wittenberg Brook and later into the reservoirs that provide New York City’s water. These streams, fast and cold as they may be, are filled with life: crayfish hunt under rocks, minnows and tadpoles spurt through the current. Newts, northern brown snakes and northern water snakes, snapping turtles, painted turtles, and myriad other species hunt and breed along these streams. 

There is nowhere like it that I know of, certainly nowhere as near to a major city. It is a respite not only for the animals that call it home, but for humans looking for a place that is still wild, a place not carved up for human use. To destroy this place and turn it into a giant battery would be a profound violation. I understand the need for sustainable energy storage, but it cannot come at the cost of the ecological devastation of the last corners of the earth not already destroyed by humanity. It simply cannot. 


Sincerely, 

Dr. Benjamin Cannon

Steven J. Calinda, West Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Steven J. Calinda

Matthew Furlong, Phoenicia, NY.
Dear FERC,

Perhaps it made sense to Premium Energy Holdings sitting at their desks in an office park in Walnut, CA scouring the geologic maps of the country for suitable project sites... Perhaps from a desktop view, the abundant water supply of the Catskills region, which has attracted settlers, poets, industry, and the City of New York (for water resources), indeed presents an attractive opportunity to Premium Energy Holdings to court investors and deploy their radically ecologically destructive technology...

However, in the real world, to the residents of the Catskills area, the nearly 9 million residents of New York City with a 40% dependence on the Ashokan reservoir for drinking water, the scores of tourists visiting the Catskills region annually, and the countless many who fought to secure Catskills Park as a state constitutionally-protected natural habitat in 1885, the proposed Ashokan Pump Storage Project is an absolutely terribly conceived plan that poses a direct risk to the current health and safety of NYC residents and spoils one of the most naturally, geologically, and historically significant regions of the country for generations to come.

I am writing as a part-time resident of both NYC and Woodland Valley to express my total opposition to Premium Energy Holdings’ proposed Ashokan Pumped Storage Project. Please know that my property in Woodland Valley would not be impacted by the proposed Woodland Valley upland site. If anything, by the laws of real estate, the availability of less property in the Woodland Valley area, would likely raise the price of my property! So please let me be clear, that my opposition to this project is far from property- or financially-motivated.

Besides the critical strategic asset that the Ashokan Reservoir represents to the water needs of City of New York, which on its face illustrates the ridiculousness of this project, the Catskills region represents one of the most naturally, geologically, and historically significant regions of the country. The Catskills represented America’s first frontier with the untold natural beauty of the region inspiring artists and writers to celebrate the wonder of America while instilling a spirit of manifest destiny in the hearts of Americans for decades to come.

Speaking for Woodland Valley, one of the proposed secondary reservoir sites, the Woodland Valley area has immense ecological, historical, and environmental significance to the region and country - whether its the area’s use to 1) geologists researching Pantherkill Mountain, which was the site of an ancient meteorite crater, 2) tourists visiting the celebrated Roxmor Colony (founded in 1899) along with the nearby home of artist Thomas Bigelow Craig (the farm reputedly one of naturalist John Burroughs’ favorite places in the Catskills), or 3) modern adventurers and naturalists looking to stay at the historic Woodland Valley Campground and explore the natural wonders at its front door. More broadly, it should be noted that tourism to the Catskills accounts for $1.6Bn annually and supports ~20,000 jobs.

By no means do I oppose radical efforts to scale renewable energy development to help to address the catastrophic climate risks facing humanity. The risks and ecological destruction associated with THIS proposed project, however, fail terribly at addressing the climate problem it proports to help solve. And do I understand correctly that over 50% of the energy produced by the plant would have to go towards operating the plant and not each reach the grid??? How ridiculous when you think of the financial costs and massive environment destruction associated with the proposed project!!!

Perhaps it made sense from a desk in Walnut, CA... However, a simple Google search of the Catskill area’s ecological, historical, and economic importance followed by basic initial outreach to community stakeholders, would have swiftly and conclusively illustrated to Premium Energy Holdings that this proposed project DOES NOT MAKE ANY SENSE IN THE CATSKILLS!!!

I strongly hope that with the chorus of diverse voices rising in opposition to this project, that FERC will make the right decision to not advance this project whatsoever.

Thank you kindly for providing stakeholders this opportunity to share rationale for our opposition.

Wishing FERC the best of luck in all that you do to protect and regulate our country’s energy infrastructure.

Best regards,
Matthew J. Furlong
195 Muddy Brook Rd., Phoenicia, NY 12464

Kara Borbely, GLEN RIDGE, NJ.
Premium Energy entirely ignores the fact that the proposal impacts protected land within the Catskill Forest Preserve. Whether a gross oversight or a willful one, this land is protected by law within the New York State Constitution. As a lifelong resident of the Woodland Valley, I can assert that the land there is precious not only to the wild, at risk, and endangered animal and plant species that dwell within it but also to the hikers, hunters and artists who inhabit it. Those humans are well positioned and well armed with social media, historical data, and righteous conservatism to do their part to protect lands that “shall be forever kept as wild forest lands” and “shall not be sold, nor shall they be leased or taken by any person or corporation, public or private" as decreed in Article 14, Section 1 of the New York State Constitution in 1894. 

Thank you,
Kara Borbely

Cristine S Riedel, Dansville, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
Please do not allow money interests to interfere with the nature in the Catskills.  It is irreplaceable.  To allow this company to build will devastate the region.  This is not necessary.  Please decline the request.
Sincerely,
CS Riedel

Elizabeth Ryan, Brooklyn, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

ELIZABETH RYAN

Ryan Ross Smith, Fremont Center, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country's transition to renewable energy, this proposal is hasty and reckless. The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ryan Ross Smith

lester burg, Shokan, NY.
I am writing in opposition to the pending permit application.  I write as a new retiree drawn to the region and a resident one mile from the Ashokan Reservoir, for its heritage of land protection, watershed conservation and the promise of no development within its protected waters.  I am not an engineer but I have worked in the public sector for 40 years.  The proposal seems rushed, full of negative impacts to the surrounding communities, disruptive to wildlife, human life and the fresh water sources it would seek to draw energy from.  These lands are cherished for good reason and the last thing needed is a damned reservior, an underground hydro plant with transmission lines running from the town of Olive, to Ulster.  

While recent news indicates a portion of the proposal has been withdrawn, we as residents have no direct information or contact and we are the people most impacted by the massive project.

I join my neighbors and town officials in registering strenuous opposition.
Thank you,

Lester Burg

Russell Martin, Olivebridge, NY.
Russell Martin									April 12, 2021
115 Sheldon Hill Rd
Olivebridge, NY 12461

Ms. Kimberly Bose, Secretary						
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426


RE: Project P-15056 (Ashokan Pumped Storage)

Dear Secretary Bose:

I write to express my opposition to Premium Energy Holdings’ plan regarding a pumped storage facility sited in the vicinity of the Ashokan Reservoir. While the proposed filing leaves much to the imagination, the project would result in significant harm to the environment, public lands, and local communities. 

As an angler along the Esopus and Ashokan Reservoir, this project stands to reduce aquatic diversity and threatens prime brook trout habitat. While studies in the Catskills are ongoing, tributaries of the Esopus are known to hold brook trout strains that have evolved over time to be unique to their specific tributaries. The loss of these waters and trout populations would be a significant blow to the biodiversity of the Catskills and North America. With regards to the Esopus proper, the project will also likely increase turbidity, reducing angling enjoyment and harming several fish species through impacts to the food web. 

As a hiker and hunter of these mountains, the project will likely require the destruction of constitutionally protected Catskill Park lands classified as “wild forest” or “wilderness” areas. These lands, purchased or donated for the enjoyment of all, should not be inundated and removed from public use. Additionally, the New York State Department of Environmental Conservation has noted their opposition to the destruction of these land in their April 12th comments.

Finally, as a homeowner in the Town of Olive, I find it outrageous that eminent domain could be used to take land or houses to complete this project. The modest 800 megawatts of power netted from the project do not justify the damage to communities that would result from the removal of homes through negotiation or taking. In this real estate market, it is clear that families would be forced to leave the area, as housing stock remains extremely limited. 

Renewable energy is an important part of our future. Ambitious goals set for our transition to greener power sources and the limits of solar and wind power to produce electricity twenty-four hours a day require novel ideas and investment both in New York and nationwide. This pumped storage project is not novel and creates more problems than it solves. By denying this permit, you’ll spare the rivers and townspeople of Ulster County from having to navigate a study that stands no chance of coming to fruition. 

Respectfully,
Russell Martin

Erik Marschall, Highland, NY.
FERC PROJECT NUMBER P-15056:000
The purpose of this comment is to express dissatisfaction of the Premium Energy's proposed Pump Hydro Project P-15056.
Premium Energy’s proposed pump storage project in Ashokan, New York would be highly damaging to the Catskill Forest Preserve. New construction in any scale is extremely impactful on the natural fauna and flora. As a young project engineer for a mid-size commercial construction company, I have seen first-hand the destruction and pollution that occurs on the landscape over the course of an 18 - 24-month project. Silt fences are never maintained properly, and personal trash/waste materials are thrown across the site with any amount of wind. The littered trash alone of project of this size and duration would react havoc on delicate ecosystem that is the Catskill Forest Preserve and New York City Watershed. It appears that Premium Energy is unaware of the existing protections that are in place at the proposed location of their upper reservoir.

Katie Peterson, Tannersville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am a resident of the village of Tannersville (in the town of Hunter), NY. I am so incredibly concerned about this proposal regarding our neighboring lands. It is absolutely heartbreaking to think this could go forward in any way. It would be so incredibly disruptive to the land, animals, and humans who live here. It is unconscionable. 

I am writing about the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster and Greene Counties and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Please, please, please  protect our lands and our people. We believe in renewable energy, but this is not the way.

Sincerely,

Katie Peterson
Tannersville, NY

Stephen Nash-Webber, Tannersville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am a resident and homeowner in the village of Tannersville (in the town of Hunter), NY. I am very concerned about this proposal. We regularly use Rt 214 as a major thoroughfare in the mountains. Losing this would cause an incomprehensible loss and challenge for our county.

I am writing about the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster and Greene Counties and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Please, please, please  protect our lands and our people. We believe in renewable energy, but this is not the way.

Sincerely,

Stephen Nash-Webber
Tannersville, NY

Linda Yassky, Phoenicia, NY.
PART ONE OF TWO

We are writing to register our strong opposition to the application filed by Premium Energy Holdings, LLC ("Premium Energy") Project No. P-15056:000, for a preliminary permit, to conduct studies on building a pumped storage plant utilizing the Ashokan Reservoir. For the reasons discussed below, as well as those cited by the 800 plus entities and individuals to date who have filed motions to intervene and comments in opposition to this ill-conceived proposal (which we do hereby adopt as our own), we implore The Federal Energy Commission (FERC) to deny this permit application in its entirety. 
This opposition assumes FERC has a working knowledge of The Ashokan Pumped Storage Project ("APSP") as envisioned by Premium Energy in its permit application. There is no need for us to reiterate the contents of that proposal.  

We would also like to note for the record that we have resided in Woodland Valley since 1998 and that the proposed plan to create a new reservoir in this location would directly and deleteriously impact us insofar as it would block access to our home on Pantherkill Road.  

Notwithstanding, we are vehemently opposed to using any of the three proposed sites – Woodland Valley in Phoenicia, Stony Clove in Lanesville, or Wittenberg Road in Olive to build a new reservoir for this proposed pumped storage. The construction of a new reservoir at any of these locations would require the flooding of protected land, adversely impacting two of the Catskills' most precious and inextricably intertwined resources: our local ecology and tourism. Indeed, the Catskills are not just "our backyard," but the backyard of over 12 million visitors (this does not count residents) from around the world. In 2020 to, among other things, hike her trails, climb her mountains, swim in her pristine waters, study her plants and animals, ski her mountains and breathe her fresh air.  

Before we address some of the many reasons Premium Energy's plan for the Ashokan Reservoir and its environs is untenable, we want to draw FERC's attention to two glaring missteps on Premium Energy's part that we believe raise serious questions about its integrity and overall wherewithal to actually see a project of this magnitude through to fruition. 
First, by all accounts, it appears that Premium Energy failed to either confer with or notify critical stakeholders about this proposed project. 
Notable among these are the New York City Department of Environmental Protection, which is responsible for overseeing and protecting the Ashokan Reservoir, as well as several other affected townships, including the Town of Olive and the Town of Shandaken. Simply put, this wrecks of bad faith.  
Second, Premium Energy's permit application disingenuously characterizes its proposed development as a "closed-loop" pumped storage (a less environmentally impactful process for harnessing the power that is eligible for streamlined FERC approval). Nothing is further from the truth as both the Ashokan Reservoir and its surrounding watershed are a continuously flowing natural water source. As FERC well knows, projects where an upper reservoir is added to an existing lower reservoir – as is proposed here – does not suddenly make it a closed-loop system but rather an "add-on" to an existing "open-loop" system.  
 
While one could dismiss these two discrepancies as oversights, given the stakes here, it is more likely that these were attempts to subvert best practices and push through what Premium Energy knows is a poorly conceived plan that was likely to meet significant resistance. Indeed, while Premium Energy's website highlights proposals for at least four other pumped storage projects, it does not appear that the Company has ever developed or operated a pumped storage facility. We would expect that a prospective permit holder's "track record" is a relevant consideration to your agency when considering proposals of this magnitude and scope.  
 
 
See Part Two Following
Filed by Linda Yassky and Georges Nahitchevansky 324 Pantherkill Road, Phoenicia NY 12464

Linda Yassky, Phoenicia, NY.
Linda Yassky and Georges Nahitchevansky e-comment P-15056:000
PART TWO 
 
FERC SHOULD DENY PREMIUM ENERGY'S APPLICATION FOR THE ASHOKAN PUMPED STORAGE PROJECT 
 
The Negative Impacts Outweigh the Limited Benefits:
 
We are mindful that the New York state needs to move away from our reliance on fossil fuels and that hydroelectric power offers such an opportunity. However, the Ashokan Pump Storage Plan is not the type of innovation the Department of Energy wants as the negative impacts far outweigh the minimal benefits.   
 
According to Premium Energy's permit application, the APSP would generate only 800 megawatts of hydropower. Notably, that is less energy than what would be required to pump the water uphill to the "new reservoir." The creation of 800 megawatts of power (to be sold at a higher price when the grid requires) appears to be the only thing to be gained by this project, of which Premium Energy and not the citizens of Ulster County and the Catskills, is the sole beneficiary.  
 
As you know, the APSP is located entirely within the Catskills Forest Preserve, 700,000 acres of contiguous wildlife habitat in what has become an increasingly fragmented environment. While Premium Energy's permit application and accompanying topographical maps are fuzzy/inaccurate, it is indisputable that building a massive underground power station, flooding hundreds of acres of protected land and constructing a huge multi-mile underground tunnel to carry the water between a newly-built upper reservoir and the Ashokan, would cause a significant disruption to the surrounding plant and animal life.   
 
It feels like everywhere you go in the Catskills, you see a running stream along the roadside or water gushing out of the side of a mountain, all on their way to our wonderful and historic Esopus River and ultimately the Ashokan Reservoir. The impact of the APSP on stream ecology would be significant as pumped storage facilities are subject to rapid water fluctuations that wreak havoc on both aquatic and land habitats. Altering the sediment regime in these tributaries will also alter the Esopus and thus endanger one of the Catskills' most vital trout waters and valuable trout breeding grounds.  
 
Additionally, the Catskill/Delaware Water Supply provides 90% of New York City's water supply at a rate of 1 billion gallons a day to over 9.5 million people. Within that system, over 40% of New York City's water supply passes through the Ashokan Reservoir. There is no doubt that this pumped storage project is likely to increase the turbidity in the Ashokan, which would decrease the quality of New York City's water. 
Moreover, climate change (evaporation, heat events and decreasing snowpack) has created uncertainty about the Ashokan's continued ability to meet New York City's water needs. Adding a pumped storage project to the equation make little to no sense.  
 
Similarly, the impact of this proposal on Catskills' tourism would be significant. As noted earlier, the Catskills functions as a collective "backyard" for millions of people every year. Ulster County where this project would be located in the single largest Catskills destination. 
In 2020 over 6.2 million people travelled to Ulster County, up from 5 million in 2019. Tourism in a $1.6 billion dollar industry supporting roughly 20,000 jobs. The reason people come to the Catskills is to recreate and enjoy nature - not a pumped storage nightmare.  
 
Woodland Valley is among the most popular destinations in the Catskills. The Woodland Valley campground is one of the state's oldest and most visited campgrounds with over 5400 overnight campers and 2600 day-use visitors annually. Under the proposed plan to flood Woodland Valley, access to that campground would be cut off. While the plan makes no mention as to how this would be remedied, it would seem that the only solution would be to build a new road that would require extensive destruction and disruption of preserve land. Finally, Woodland Valley Creek, which runs to the Esopus and eventually the Ashokan, is an extremely popular fishing destination containing cutlips, minnow, blacknose dace, brook trout, brown trout, and rainbow trout among many others. 
 
For all of these reasons, we ask that your Commission deny Premium Energy Proposal application for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan Reservoir.  
 
Thank you for your consideration, 
 
Linda Yassky yasskylinda@gmail.com
Georges Nahitchevansky zampano1812@gmail.com

Stephen Sanchez, Shandaken, NY.
Dear Ms. Bose,

I am writing in response to the detrimental proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be highly disruptive to the local community, local businesses, and the area's biggest industry: tourism. 

Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Our facility, the Copperhood Retreat, is located in the town of Shandaken and relies on the Route 28 corridor as a lifeline to our business. We are also on the Esopus Creek which feeds into the Ashokan Reservoir and depend on our area's pristine environment to attract hikers, fisherman, and city dwellers of all types looking for a respite from their urban surroundings. The Catskill Park and its communities have already endured too much displacement and hardships as part of the NYC watershed for the benefit of others outside the region. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Stephen Sanchez
Owner
Copperhood Retreat & Spa

Josh Olsen, Catskill, NY.
I'm a resident of the Hudson Valley & active user of the beautiful Catskill Forest Preserve. The NYS Constitution clearly states these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Everything proposed falls within the limits of this State Forest Preserve. Impacting its natural beauty would be a shortsighted decision with significant negative impacts, both environmental & economic.

Tourism plays an integral role is the ongoing Catskill rebirth. It’s a billion plus dollar industry supporting tens of thousands of jobs. Limiting a major thoroughfare to popular hikes & towns would be a detriment to the local economy. Not to mention the impact on local homeowners and non-resident second homeowners, or the risk posed to a water source supplying billions of gallons a day to NYC.

I believe this “add-on” project should be rejected outright. I support alternative paths to a clean future, driven by local investment, not anonymous corporations from across the country.

Jason Kachadourian, Lanesville, NY.
April 12, 2021

Jason Kachadourian
443 Diamond Notch rd.
Lanesville, NY 12450

Comment regarding docket number P-15056-000

Dear Secretary Bose,

The Catskill Park in New York contains an enormous network of streams and creeks, many of which lead into the Ashokan Reservoir at its Southernmost point. Not only would Premium Energy’s proposed plant gut the ecosystems surrounding the pumping system but inevitably it would destroy the last of the struggling native Trout population in adjacent water bodies. The system outlined is not, in fact, a closed loop system. There are hundreds of tributaries to the Espous within each outlined potential upper reservoir site and the wild animals that live in this state protected land would suffer from wildly unnatural water levels and turbidity. 

Please consider rejecting this application on the grounds that it does not comprise a closed loop system and would have dire consequences for the surrounding ecosystems that are protected by the New York State constitution.

Sincerely,

Jason Kachadourian

Christina Pisarik, Prattsville, NY.
To whom it may concern,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

I am concerned about this project's impact on our local community and the Catskills Forest Preserve. I fear that this system will have a great negative impact on both land and aquatic habitats. 

Here in the Catskills we have a wonderful community wherein the residents respect nature and the nature provides us with resources and recreation. This project would offset that balance and destroy our community.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Christina Pisarik

Jennifer Ascosi, Olivebridge, NY.
I am a resident of Olivebridge, NY and I OPPOSE the Ashokan Pumped Storage Project. It is too costly of a project, creating upheaval to human lives (homes, jobs, overall welfare of established communities) and to the animal, plant, and geological ecosystems upon which the health of our communities rely.

Blake DeLanney, Shandaken, NY.
This project should not be allowed to move forward. This will have a negative impact on our wildlife, our local water and communities.  Please do the right thing and deny the proposal.

Fara Warner, West Shokan, NY.
Dear Ms. Bose, 

I have read with growing concern the application for a preliminary permit by Premium Energy Holdings LLC to build a large damned reservoir in the Catskills, a New York State Preserve that is protected by the New York State Constitution. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

This should be enough for FERC to deny Premium Energy Holding's preliminary proposal. But I know it will not be enough. I hope then that citizens' concern and love for the Catskills Preserve will make a difference.  

This proposal would change forever the nature of the Catskills Preserve,700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 

I live across from the Ashokan Reservoir, where no motor boating is allowed, fishing is allowed with license, dogs aren't allowed near the reservoir, we do not swim in the reservoir. We abide by these rules because we consider this pristine water to be a natural resource that while used with care also must be protected. Right now I can see eagles nesting and feeding. I watch bear and deer go to the reservoir for water. I revel in our dark nights that protect this wilderness. The Ashokan also supplies 40 percent of the drinking water to New York City. All of this would be under peril if this project were to go forward. 

I also have personal concerns that are shared by my neighbors. The proposed high voltage transmission lines would run through and over my property. It is possible that I would be displaced from my home with little recourse but to try and buy another home in a county that is suffering from a housing shortage. Even if my home wasn't taken by eminent domain, I would live with the transmission lines running across my property or nearby. Those lines would affect not just me and my health, but the health and well-being of the wildlife that we hold very dear here in the Catskills, notably the regal and majestic bald and golden eagles that have made such a comeback in this area due to the protections afforded by the Catskills Preserve. I am but one of hundreds of people who live along the southern and western edges of the Catskills. I know I am not the only who read this proposal with personal concern. 

I believe deeply in the need to shift our energy system from fossil fuels to electric systems, but not when it comes with such risk to a natural environment that serves millions of people. This proposal isn't innovative and is flawed even its conception. 

Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.


I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Thank you, 
Fara Warner

Michael Segura, Prattsville, NY.
I am posting in opposition of the Pump Storage Hydroelectric Plant (the FERC project number, P-15056) proposal.  The preservation of wildlife habitats is already in jeopardy and it remains paramount that vital lands remain protected to support and maintain their ecosystems.  Not only does a reservoir threaten to destroy land habitats, but it also threatens to destroy important and vital aquatic habitats as well.

Michael Segura.

Arden Sherman, New York, NY.
Arden Sherman
17W 121st Street APT2
New York, NY 10027

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in opposition to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

I spend my summers by the Ashokan Reservoir and have gotten to know the communities that surround this area. I have been under the impression that the these lands “shall be forever kept as wild forest lands and they shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” This is what makes the area so bucolic and unique. I am befuddled that this proposal has gotten so far. 

The damage that this proposal would cause to the natural habitat and the residents is far greater than the positive impact. The facts are on the table. The data is out there.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you very much,
Arden Sherman

Miriam Marschall, Long Valley, NJ.
Please reject the preliminary permit application from Premium Energy to construct a pumped storage hydro project in the Catskills Forest Preserve.

All three proposed locations of the upper reservoir for the project will adversely affect wildlife habitats for birds, fish, and flora; many of which are protected in New York State.

The construction of dams, tunnels, roads, buildings and transmission lines within the immediate project boundaries and surrounding areas will harm the ecology of the land and water immeasurably. Trout breeding waters, bird habitats, and the New York City water supply all will suffer. 

Premium Energy, a California company, may be unaware of the protected designation of the Catskills Forest Preserve. The Preserve is protected from development by the NY State constitution and must “be forever kept as wild forest lands” and may not be sold or leased for any development public or private.

Caleb Thomas Frank, MOUNT TREMPER, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Caleb Frank

Yuki Asada, Boiceville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Yuki Asada

Anne-Marie Johansson, WEST SHOKAN, NY.
Anne-Marie Johansson
West Shokan, NY 12494
April 12, 2021 
RE: FERC Docket # P-15056- – Ashokan Pumped Storage Project 
Dear Ms. Bose, 
I am writing to request that you deny the preliminary permit application, Docket P-15056, for the Ashokan Pumped Storage Project submitted by Premium Energy Holding, LLC.  
As a life-long resident of the Catskills and a small business owner in West Shokan for over 30 years, I will be directly impacted by the proposed project. My tourism-based Bed and Breakfast business overlooks the west basin of the Ashokan Reservoir and the proposed reservoir infrastructure developments and power lines will be visible and impact and harm my business. It will also impact the community and all visitors to the Ashokan Reservoir. It will cause fishing by boat on the Ashokan Reservoir to be curtailed or eliminated due to the dangerous conditions caused by rapid flows and fluctuations in level of the water caused by the Pump Storage Operations. Tourism around the Ashokan Reservoir has dramatically increased in the last year due to over 200,000 visitors to the new Ashokan Rail Trail (ART) which runs directly along the north eastern shore of the Ashokan Reservoir. They will understand that FERC does not normally deny a preliminary permit, but this applicant has not met a minimum standard to achieve legal and regulatory approvals, nor to deal with environmental issues their proposal will create, nor have they presented a design that is realistic nor that meets modern design best practices for a closed loop pump storage system. There will also be an impact to my property value, to my personal quality of life and experiences as well as my safety or the safety of the community. 
One of the most significant ecological and health risks in this Water Supply is turbidity. Turbidity is a product of the geology of the Catskills. The current proposal is not a closed loop system design as suggested in the application. The design will clearly interrupt existing streams and will introduce more turbidity and disrupting the natural cycles of turbidity will affect not only the environment and fisheries, but also the NYC water supply. This additional turbidity will also impact the communities below the Ashokan Reservoir, and the water supplies of communities dependent upon the Hudson River for their drinking water in the Mid-Hudson region.   
Residents of Ulster County depend upon NYC DEP to provide dam safety and flood mitigation services. The threats of terrorism have heightened the protection and security throughout the NYC watershed. This level of terrorism protection is not part of the proposal made by the applicant. The applicant must be responsible to ensure dam safety as guided by FERC. The applicant would also have to provide Security and Safety to the 9 million water supply customer against any terrorist threats to the water supply commensurate to the efforts provided by the NYC Water Supply Police and the NYC DEP.  
Therefore, for all these reasons, I urge you to reject Premium Energy Holding’s proposed preliminary application for Docket P-15056 for the Ashokan Pumped Storage Project.

Respectfully,


Anne-Marie Johansson

aaron n berger, big indian, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience.

Jessica swarbrick, Big Indian, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

John Hutchins, Wappingers Falls, NY.
To:
Kimberley D. Bose
Federal Energy Regulatory Commion
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

I would like to object to the plans for the pumped hydroelectric storage facility being
proposed by Premium Energy Holdings in the Catskill Forest Preserve.  It is ill conceived for a number of reasons.  It will require a large and permanent change to location and surrounding area where it is built.  The location for it is part of Catskill Forest Preserve in which the New York State Constitution states that the lands shall forever be kept as wild forest lands and not leased, sold or exchanged, or taken by any corporation, public or private.  The addition of the higher reservoir and transmission line directly contradict this.  The Catskill Preserve is a large,  700,000 thousand acre, continuous wildlife habitat that is home to a vast diversity of wildlife.  It is also a prime area for outdoor recreation and tourism and one of the main parts of the local economy.  Recreation and tourism support 20,000 jobs and contribute $1.6 billion to the local economy.  All of it would be degraded by building the project.  It would also be in contradiction to the DOE Hydropower Vision program which is to avoid status 1 or 2 areas according to the USGS “Gap Analysis Program. As a state forest preserve, it is considered a status 1 area.

Even though the project is being proposed as a “closed-loop pumped storage system”, it is actually an open-loop system because it connects to the existing Ashokan Reservoir which has the Esopus Creek and its tributaries running through it.  By the nature of the system, it would greatly affect the turbidity of the Ashokan Reservoir which would then have an impact on the New York City water supply.  40% of the New York City water supply runs through the Ashokan, so the impact is not minimal at all.

While solving our nation’s future energy needs is important, there are many good reasons for not approving this project.


John Hutchins
13 Stenger Ct.
Wappingers Falls, NY

Soniya Munshi, Jackson Heights, NY.
I'm writing today to express my opposition to Premium Energy's proposal to build a dam at the end of Moonhaw Road and neighboring sites. I am a New York City resident who has developed a relationship with this area of the Catskills through close friends who are year-round residents. I have a deep respect and appreciation for the Catskills Forest Preserve. The proposed plan would lead to the destruction of this wildlife habitat. This land is supposed to be protected. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private." Premium Energy should not be given permission to wreak havoc on the land, water, and wildlife of this area.

lauren elliott, JEWETT, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Lauren Elliott

Daniel Case, Walden, NY.
I am writing to comment on the preliminary permit sought by Premium Energy for its proposed pumped-storage hydroelectric project on Ashokan Reservoir near Boiceville, NY, Application P-15056:000.
FERC should stop this project right here so everyone involved in any capacity can get back as soon as possible to spending their money and time on more productive endeavors, including Premium Energy. And at least that way they can preserve the dubious achievement they already seem to have made, of submitting a major power-infrastructure project that not only fails to take into account the concerns of major stakeholders (in this case, the state’s Department of Environmental Conservation, New York City’s Department of Environmental Conservation, Trout Unlimited, Ulster County and of course the local towns and every outdoor-recreation, environmental or conservation organization within a hundred miles of this project), but seems in fact to be completely unaware that those stakeholders exist, without really tossing too much of their investors’ money down the toilet.
My interests in this project are diverse: As a hiker, I have climbed many of the surrounding mountains, not only those required for membership in the 3500 Club (on whose board I once served), more than once, parking at the trailheads (or, in the case of Moon Haw, starting point) that the project would inundate. I have waded hip deep into the portions of the Esopus Creek Premium would forever alter to cast and float flies in a vain effort to land one of the stream’s rainbows. As a volunteer Wikipedia editor, I have written, researched and taken many of the pictures in our article about the Esopus, which is likely to be primary information source for most people commenting on this proposal, and thus have come to know its history and science intimately.
And apart from that, like so many others I just love the scenic beauty that is the upper Esopus Valley specifically and the Catskills in general.
How special are the Catskills?
In 2015 I had the privilege of accompanying my father on a whitewater rafting trip down the Firth River in Canada’s Ivvavik National Park, in that country’s northwest corner far above the Arctic Circle, an area that sees fewer visitors each year than climb Mount Everest. For nearly two weeks we rafted and camped under the midnight sun, with regular hikes long and short across the tundra and through such scrubby spruce forests (the northernmost in Canada) as there were along this truly wild river’s southern portions). After my return, I knew I had to go climb Slide Mountain again, that I might see if and how I saw that experience differently. I was delighted that my long experience with the genuinely boreal had not dulled my appreciation of the montane boreal in the slightest.
So, to the instant issue … I can best begin to illustrate the issues with this by imagining the discussion that led to it:
“Hey, Frank, look here on the map, 3,000 miles away from us … This reservoir and the streams flowing into it look like they might be a nice place for us to build a pumped-storage plant.”
“OK, are there any issues?”
“Some public land that we can probably take by eminent domain if they won’t sell it to us.”
“The lower waterbody says it’s a reservoir. Does anyone drink from it?”
“Locals, I think, if any, and if we build this they’ll probably be too grateful for the jobs to care too much about their water quality. Probably just used for flood control”
“Sounds good. Draw up some plans and send them to FERC for a preliminary permit.”
“Think I should fly out there and look around first?”
“There’s a pandemic on. You’d have to quarantine for two weeks before you could do anything. And they’re not going to approve a hotel stay that long.”
“So maybe we should wait?”
“Are you kidding? If we don’t do this, someone else will beat us to it.”
Really, it seems from the many mistakes in describing local governmental units the proposal makes that Premium’s people seemed to just feel that it was OK to do things like they do in California. Well, as the late David Bowie, who lived the last years of his life in a mansion atop one of the mountains overlooking Ashokan Reservoir, once sang, “They do it over there but we don’t do it here”
There are just so many ways this proposal comes off as willfully, almost arrogantly, ignorant of the facts on the ground. Propose to use as your lower reservoir one of the most important reservoirs used by the nation’s largest city, a city very proud of the fact that it does not have to filter most of its drinking water? A reservoir that nevertheless has generated turbidity downstream that has caused considerable friction between it and the local communities in recent years? Check! 
Release water down a stream that is considered historically important in the development of American fly fishing and still a popular destination for anglers every year due to its much greater public access than other Catskill trout streams? A stream also important to boaters? A stream both interest groups fought a long and ultimately successful court and legislative battle to control the water New York City releases into it, and remain as organized and alert as they were then? Check!
Propose as one possible upper reservoir site a lake whose flooding would require relocating a state road, a public campground and a site of considerable scenic importance in local history? Propose as your others one site very popular as a hiking trailhead, and another informally used for access to the most common route up two trailless peaks required for the 3500 Club? Check!
Assume that you can just take the public land in the area that you’d need, regardless of the state protecting it via provisions of its own constitution, provisions that have been in a place for well over a century? Check!

Please, FERC, put this out of its misery. And protect the Catskills.

Susan Barnett, Franklin, NY.
This application was made with absolutely no notice to the communities involved, with no apparent understanding of the sensitive nature of the environment, nor any understanding of the political and cultural issues that would result from flooding still more of the land in those communities.

This is a foolhardy proposal, endangering the water supply to New York City, and opening the still-raw wounds resulting from the loss of many communities to create the Ashokan Reservoir.

The surreptitious way in which it has begun indicates the developers know it will never win approval. It should be denied before any taxpayer dollars are wasted.

James M Hoffman, Olivebridge, NY.
As a resident of the local area I am not in favor of this proposal. I was shocked to read of this proposal that seems to have appeared with no warning or input from the local authorities or from the DEP. It appears poorly conceived, badly thought out, and hurriedly submitted. Perhaps most important it significantly affects permanently protected land. Further, it looks as if it could have serious negative impacts on local wildlife and the environment, including nearby underground aquafiers and wells. This is absolutely the wrong type of project for this area.

Correy McGlyn, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,

I hope my letter does not find you too late. Being from Olivebridge, I am grateful to hold the Catskill ecosystem in high regard. My summers are spent swimming in the local streams, and my winters by walks in the undisrupted forests. I am indebted to the individuals who are spreading awareness of the importance of preserving the streams, wildlife, and beauty of the Catskills. 

The hydroelectric power plant proposal by Premium Energy Holdings is extremely concerning to me, and to the locals of the area. This environment is resilient, but not bulletproof. I urge you, your team, and the companies of interest to reflect on what is of the most ecologic and long-term sense. 

The Catskills are luckily preserved land – this protective legal action (Article XIV of NYS Constitution) is hopefully on the forefront of your mind. It is laws like this that help protect important wildlife habitats from the wants of short-term business incentives. While the Catskill locals appreciate the importance of renewable energy sources, it must be made clear that not all “renewable” sources are environmentally friendly. The Catskills, and New York City water supplies and livelihoods, would suffer from this proposal. There are other solutions that would be less disruptive – this is not a closed-loop project.

I truly hope FERC listens to the public and professional protests to the proposed pump storage hydroelectric plant. I’ll keep my letter on the shorter side, as I’m aware that over 1,000 individuals have reached out with strong points in opposition to Project P-15056. I stress the importance of this cause and hope by reading our letters and hearing our voices you will deny P-15056.

Sincerely,
Correy McGlyn
2311 State Route 28A
Olivebridge, NY, 12461
comcglyn@gmail.com

Christopher Parris-Lamb, Brooklyn, NY.
To Whom It May Concern: 

I am writing to voice my objection in no uncertain terms to the application by Premium Energy Holdings, LLC for the Ashokan Pumped Storage Project. That the federal government would even consider granting a private company--one with no connection to the area or to New York state--the right to build another reservoir in the Esopus watershed, given the impact to both the environment and to affected homeowners, is extremely worrisome; that it would do so for a project that would involve the construction of a massive underground hydro plant requiring miles of pipeline is inconceivable. As a homeowner in Boiceville and an avid fisherman, I can hardly begin to imagine the impact the project would have both in the short term, during the construction process, and for years to come. Hundreds of people would be evicted from their homes through eminent domain; property values within the entire watershed would be adversely affected; worst of all, from my standpoint, a world class fishery--the Esopus and its tributaries--that is quite literally part of the cradle of American fly-fishing, and whose brook, brown, and rainbow trout spawn in all three of the streams in which a proposed reservoir could be located--would be forever harmed. The Esopus was just returned to Wild status six months ago (see here: https://www.dec.ny.gov/docs/fish_marine_pdf/apcdrafttsmp.pdf), meaning that hatchery trout will no longer be stocked. Why on earth would anyone even consider a project that would undo all the progress that has been made on behalf of the Esopus so soon thereafter? Most troubling of all is what would happen to the watershed's populations of Eastern Brook Trout, which inhabit and spawn in all three streams where a reservoir has been proposed. Brook trout, which once inhabited nearly every cold-water stream from Maine to Georgia, now occupy less than 10% of their remaining habitat--and Bush Kill, Stony Clove Creek, and Woodland Valley Creek are three of the very few remaining streams in the Catskills with healthy brook trout populations. I know; I've treasured the brook trout I've caught and released in all three.

In 2021, society needs to be pursuing alternative energy sources that avoid the kind of environmental impact that would result from Premium Energy's proposed project. Wind and solar power is growing cheaper and more efficient by the month; let's invest in the future, not the old ways of doing things. Please reject this application. 

Sincerely, 

Chris Parris-Lamb
Brooklyn, NY

Madeline Wilson, Jersey City, NJ.
Stop for profit interest groups from ruining the Catskills. The impacts of your decision will have devastating impacts on ecology in the area and wipe out history of the Catskills forest.

Elaine Oswald, Olivebridge, NY.
As a resident of Olive NY, I'm strongly opposed to this proposal! Preserving the natural woodlands, streams and ecology of this region is extremely important. This land offers a habitat for wildlife, especially birds. The Audubon Society has designated this land "a distinctive sub-alpine bird community", which includes one of the largest contiguous forest tracks in New York State. The fact that this natural habitat is "contiguous" is very important, because the proposal by Premium Energy holdings would cause man-made disruptions that would render the land no longer contiguous. That would disrupt ability of wildlife to have sufficient mobility for their life cycles, including mating, foraging, nesting, and so on.

Furthermore, my understanding is that the Catskills are a State Forest Preserve, granted a "Status 1" label by the USGS Gap Analysis Program. According to the US Department of Energy, development should be avoided in these areas. 

In addition to that, I'm very concerned about the impact of this proposal to the stream ecology of this area. It's essential for the trout in this area to have uninterrupted life-cycles. The trout are necessary for a balanced ecosystem and also help with tourism in the area as well. There would be several significant disruptions from the "pumped water" system of this hydroelectric project, including altering the sediment levels in the water and causing rapid fluctuations in the water levels.

To summarize, in my viewpoint this hydroelectric proposal will do major damage to a precious and vulnerable ecosystem. As a local resident, I feel a moral duty to protect this land from the massive disruption and long-term negative consequences this project would cause.

Eric A. Goldstein, New York, NY.
           INITIAL STATEMENT OF THE NATURAL RESOURCES DEFENSE COUNCIL
        RE: PRELIMINARY PERMIT APPLICATION OF PREMIUM ENERGY HOLDINGS LLC
               BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
                FOR AN ASHOKAN PUMP STORAGE PROJECT, P-15060
	              Eric A. Goldstein, Senior Attorney
The Natural Resources Defense Council (“NRDC”) submits this initial statement in opposition to the January 29, 2021 application of Premium Energy Holdings for permission to conduct a feasibility study regarding construction of a Reservoir Pump Storage Project in Ulster County, New York, within the boundaries of the historic Catskill Forest Preserve and New York City’s Catskill Watershed, which provides unfiltered drinking water to 9 million downstate residents.   
NRDC is a national, non-profit legal and scientific organization that has worked for more than 5 decades on a wide range of environmental and natural resource protection issues.  Among other things, this has included extensive work to safeguard the Catskill Watershed (the primary source of the nation’s largest municipal drinking water supply) and to protect and enhance the Catskill Forest Preserve ( a national model for land preservation and public recreation for more than 100 years).  
While NRDC is not conceptually opposed to the use of hydropower to help meet New York State’s energy needs, the location of the proposed project in the heart of the Catskill Watershed and in or near the Forest Preserve within the Catskill Park would pose unnecessary and unreasonable risks to the downstate drinking water supply and to the area’s world-renown waterways and sensitive ecology.
One problem with this project is the danger it would pose to the Ashokan Reservoir.  The Ashokan serves as the terminal reservoir of the Catskill system and in non-drought periods provides more than 40% of the total downstate water supply.  But according to the developer’s application, the proposed project would necessitate massive construction in the Ashokan watershed --  including the building of a new upper reservoir of between 226 and 313 acres in size, a tunnel 50-feet in diameter, a powerhouse and transformer station and up to 17 miles of transmission lines, with the lower water source affecting the Ashokan Reservoir itself.  The Ashokan Reservoir already faces serious turbidity problems that represent a growing danger to this unfiltered water supply.  Filtration of the Catskill system would cost billions of dollars in construction costs and hundreds of millions more in annual operating costs.  Thus, the possible locations for the proposed Ashokan pump storage operation would all entail significant construction and land use changes in the immediate vicinity of the one of the region’s most important drinking water sources and would represent an exceptionally risky and ill-advised project on both environmental and economic grounds. 
A second danger from the proposed project is harm to the Esopus Creek.  The Upper Esopus Creek plays a major role in the New York City water supply system.  It is the primary conduit of drinking water into the Ashokan Reservoir from the Schoharie Reservoir and a waterbody that has suffered for years from serious turbidity problems.  The Esopus is also a world-famous tourism spot, known for its trout fishing and for its canoeing, kayaking and tubing opportunities -- an important economic resource in the region.  Numerous studies and reports have advocated for increased protection for the Upper Esopus.  The proposed pump station, in contrast, would bring increased construction and terrain-altering activities in the immediate vicinity of this vulnerable and essential watercourse.  
While a preliminary permit would not authorize Premium Energy Holdings LLC to operate or start construction on any such pump storage facility, it would begin what would likely be an extensive and we believe ultimately fruitless review process that could continue for years. For example, a full Environmental Impact Statement would be necessary under the National Environmental Policy Act to assess multiple adverse environmental and natural resource impacts and to guide decision-makers in reviewing alternatives to the proposed action.  So too would be compliance with federal Clean Water Act requirements, including a certification under Section 401 of the Act for discharge into navigable waters.  Reviews for consistency with numerous other State and local environmental and land use laws would also be required.  And so would demonstrations that the proposed facility would not violate any of New York City’s Watershed Rules and Regulations or the State Health Department and federal EPA-approved Safe Drinking Water Act’s 2017 Filtration Avoidance Determination. 
It is tempting to say that the project sponsor would shoulder the costs of all of these and other review processes, so the burden is simply on Premium Energy Holdings LLC.  Not so.  Participating in the multiple reviews that this permit process would trigger will end up costing state, city and local governments, as well as not-for-profit organizations, hundreds of thousands of dollars.  Why should local governments and non-profit organizations, in particular, have to bear such costs and invest thousands of person-hours to staff such permit and review processes for a project that should, on its face, be rejected due to its wholly unsuitable proposed locations?  
oFr  all these  reasons, FERC should  deny the  preliminary permite p.  aAlternativelym, tshould dirrct sthe psonsor to sprovide sufficiient fundsstso  that  local governments and  non profit groups in partticular cann participate meaninglf=lly in the tforthcoming proceediings.  hat yof

Aaron Anaya, New Windsor, NY.
As an electric power engineer that is intimately involved in the NY CLCPA goals of interconnecting renewable energy in New York State, I am adamantly opposed to this proposed pumped hydro plant. Increasing the amount of solar generation  paired with battery storage is a more technologically advanced strategy than the high-maintenance, outdated technology being proposed. This is not the type of renewable resource that is needed in New York State. While reservoirs, such as the extant Ashokan, seem like prime candidates for pumped hydro, the infrastructure that is required at the higher elevation does not exist. The construction of the required infrastructure would be damaging to the wild nature of our beloved Catskill Mountains. The Catskills are littered with ruins of ill-conceived business ventures from bygone eras - let's not add another that future generations will shamefully look upon.

Edward S Vickers, Olivebridge, NY.
I am strongly against this project due to the impact of Proposed High voltage transmission lines directly impacting the natural beauty and reason for visiting the area along Rt 28, and newly constructed Rail Trail nature immersion and views and vistas that are will negatively impact ego tourism and the ability for local residents who moved to the area within 15 miles of power lines to specifically enjoy the lack of transmission allow local open Ashokan reservoir vistas routes.   
Strongly against this project, as will destroy innate natures attraction to area and have a longer-term negative impact on local home prices as well.

Heather Hammond, Scarsdale, NY.
As an avid Catskill hiker I am concerned about this proposal

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Anna Compton, Woodstock, NY.
I am in opposition to the Ashokan Pumper Storage Project (Docket- Number P-15056) because it is not what the area needs. This will harm not only this communities air and water qualities but will further contribute to the overall threat of climate change. Do not do this.

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Laurie Winnie, Shokan, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Laurie Winnie

Harrison Molmed, West Shokan, NY.
Docket P-15056
Premium Energy Project for the Ashokan Reservoir

I am writing to express my opposition to Premium Energy’s proposal to build a hydro-electric plant at the Ashokan Reservoir and a related upper reservoir and dam.

I am a lifelong resident of the area, who is an avid snowboarder and licensed fisherman.  

This project is bad for our area on so many different levels.  It uses more energy than it produces and would disrupt the unique ecology and communities of the region.  Regardless of the reservoir option that is selected, any of these choices would hurt the recreational activities here and harm the associated businesses and employees that rely on tourism.  

This land and its waterways are supposed to be protected.  I hope that FERC rejects this proposal immediately and completely.

Thank you.

Harrison Molmed

Barbel Eggers, Stone Ridge, NY.
The Ashokan is a valuable watershed and protected area. It now attracts tourism through the use of its newly opened trails. This supports local bussinesses. We do not need a questionable project by an out of state company compromising this resource area so rich in natural beauty, low impact recreation such as hiking and fishing. We cannot get back what we destroy and we will be destroying nature and impacting people's lives.

peter himberger, Boiceville, NY.


To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
 
Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. As landowners and nextdoor residents to the Ashokan Reservoir, we take our environmental stewardship of the area very seriously for the next generations of wildlife and people to enjoy.  I am part of a large and engaged community and I urge FERC to decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 based on the following reasons:
1.)  NOT CLOSED LOOP -The application is sloppy and flawed in it’s local references and assertion of being a “closed loop system” when it is an “add on” system.
2.)  BIRDS-All proposed reservoirs are within the Audubon NY Catskill Peaks Forest Important Bird Area (IBA).  If you have ever heard the flute song of a Forrest Thrush, you would defend it’s habitat from development without question or hesitation. https://ny.audubon.org/conservation/catskill-peaks-forest
3.)  TROUT -The system’s environmental impact on the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir.
4.)  DRINKING WATER - The system’s impact on turbidity levels of the Ashokan Reservoir which supplies both local and 40% of NYC’s water, serving 1 billion gallons of water a day to 9.5 million people.  The proposal threatens this valuable asset, which holds the distinction of being the largest unfiltered water supply in the nation.
5.)  PRESERVED LAND -The three sites for the proposed reservoirs and tunnels are on highly protected land of the Catskills Forrest Preserve created in 1885 under Article XIV of the NYS Constitution “shall be forever wild… not be leased, sold or exchanged, or be taken by any corporation, public or private.”
6.)  PROTECTED LAND -The Catskill Forrest Preserve is considered Status 2 land under the USGS “Gap Analysis Program.” According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."
7.)  CONTINUOUS HABITAT - The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare) and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
8.)  COMMUNITY DISPLACEMENT, AGAIN- Premium Energy’s proposal would be devastating to local communities as it would require the seizing of homes and private property via eminent domain—a process whose scars are still felt here from when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would be unable to secure new housing, as there is currently a severe housing shortage in Ulster County.
9.)  TOURISM – The proposal would negatively impact the Catskills’ growing tourism economy, which generated 17% of employment in the region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty  and otherwise industrialize the region, negatively affecting businesses in Ulster County and beyond.
 
As a last point to make in opposition, the irony must be pointed out that the solution to fossil fuels and extractive energy methods should not be to usher in a new environmentally damaging system! Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—using innovation where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
 
Please deny Premium Energy’s proposal for a preliminary permit for the
Ashokan Pumped Storage Project P-15056.
 
Sincerely,
 
 
Peter Himberger

Johnny Simon, New York, NY.
Hello, 
I hope you are having a great day and end to your week. I am writing to inform you that I and my family oppose the development of the Pump Storage Hydroelectric Plant. The Catskills Forest & Water Preserve is an integral component that will ensure the health and prosperity of human life now and for future generations. The Catskills Preserve is also considered STATUS 1 under the USGS; which means we should avoid developing the land and do whatever it takes to protect it. Please do not move forward with the proposal for development. It will only hurt and damage the community. 

Thank you for your time
all the best
John Simon

Kelly Stefanski, Fishkill, NY.
Dear Ms. Bose, 

Sara and Kelly are writing in response to the deeply concerning proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Ms. Babyatsky holds a Master of Science degree in Applied Environmental Geoscience from Queens College and has been working as a geologist with environmental consulting firms for 8 years. Ms. Stefanski holds a Masters in Civil and Environmental Engineering from Cornell University where she studied water resource systems and has been working in the private and public water sector for 4 years. Ms. Stefanski also worked in EPA’s Region 2 Clean Water Division in NYC where she was involved with NYC’s Filtration Avoidance Determination (FAD) program. As professionals in this scientific community, we urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, due to the potential for environmental degradation and impacts on the highly preserved land and stream ecology within the watershed, and potential impacts to the quality and supply of New York City’s drinking water.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. Destroying preserved land, a protected water system, and a habitat for federally protected species would set a harmful and dangerous precedent. 

In addition, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Millions of laboratory tests in the City and the watershed show that water from these two systems continues to meet the stringent criteria set by the DOH to avoid filtration. FAD allowed NYC to avoid the construction of a $10 billion dollar filtration plant for its Catskill and Delaware supplies, with an upwards of $100 million to operate each year. The City is investing an estimated $1 billion dollars over the next decade to comply with the FAD by administering programs that protect the upstate reservoirs and the vast watershed lands that surround them. The filtration waiver emphasizes that New York City has some of the highest quality and best protected drinking water in the world. Protecting these waters at its source in the Catskill Mountains does not happen by accident. Nonprofits, government agencies and other watershed-based partners who administer the watershed protection programs continuously push toward the common goal of protecting the largest municipal water supply in the United States. This project would have devastating consequences that would disrupt the work that has been done over the last three decades to protect these waters and cost the City billions of dollars. 

Furthermore, Premium Energy states in the Application for Preliminary Permit that the “proposed Ashokan Pumped Storage Project would operate in a closed loop. Aside from evaporation and percolation losses, the project’s water would stay within the system.” The Ashokan Reservoir is an integral part of the Catskill System and a significant portion of the New York City water supply. Premium Energy’s statement that the project’s water would stay within the system is false. Premium Energy’s proposed project is not a closed-loop system—it is in fact an “add-on”, using an existing body of water as a lower reservoir, and the pumping required for this project will increase turbidity within the Ashokan Reservoir and carry significantly higher risks. Premium Energy’s project does not meet the standards of innovation sought by the Department of Energy. As stated in FERC’s Guidance for Applicants Seeking Licenses or Preliminary Permits for Closed-Loop Pumped Storage Projects at Abandoned Mine Sites (Docket No. AD19-8-000): “A closed-loop pumped storage project is generally defined as a pumped storage project that utilizes reservoirs situated at locations other than natural waterways, lakes, wetlands, and other natural surface water features, and may rely on temporary withdrawals from surface waters or groundwater for the sole purpose of initial fill or the periodic recharge needed for project operation. Types of reservoirs that lend themselves to a closed-loop project include reservoirs located in surface mine pits or underground mines.” Closed-loop pumped storage projects have less significant environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. Premium Energy’s application is falsely characterizing this project as a “closed-loop” system. The economic risk and potential for a public health crisis is too high to consider use of the Ashokan Reservoir as the location of a pumped storage project. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

We hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Sincerely, 
Sara Babyatsky and Kelly Stefanski

Sara Babyatsky, New York, NY.
Dear Ms. Bose, 

Sara and Kelly are writing in response to the deeply concerning proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Ms. Babyatsky holds a Master of Science degree in Applied Environmental Geoscience from Queens College and has been working as a geologist with environmental consulting firms for 8 years. Ms. Stefanski holds a Masters in Civil and Environmental Engineering from Cornell University where she studied water resource systems and has been working in the private and public water sector for 4 years. Ms. Stefanski also worked in EPA’s Region 2 Clean Water Division in NYC where she was involved with NYC’s Filtration Avoidance Determination (FAD) program. As professionals in this scientific community, we urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, due to the potential for environmental degradation and impacts on the highly preserved land and stream ecology within the watershed, and potential impacts to the quality and supply of New York City’s drinking water.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. Destroying preserved land, a protected water system, and a habitat for federally protected species would set a harmful and dangerous precedent. 

In addition, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Millions of laboratory tests in the City and the watershed show that water from these two systems continues to meet the stringent criteria set by the DOH to avoid filtration. FAD allowed NYC to avoid the construction of a $10 billion dollar filtration plant for its Catskill and Delaware supplies, with an upwards of $100 million to operate each year. The City is investing an estimated $1 billion dollars over the next decade to comply with the FAD by administering programs that protect the upstate reservoirs and the vast watershed lands that surround them. The filtration waiver emphasizes that New York City has some of the highest quality and best protected drinking water in the world. Protecting these waters at its source in the Catskill Mountains does not happen by accident. Nonprofits, government agencies and other watershed-based partners who administer the watershed protection programs continuously push toward the common goal of protecting the largest municipal water supply in the United States. This project would have devastating consequences that would disrupt the work that has been done over the last three decades to protect these waters and cost the City billions of dollars. 

Furthermore, Premium Energy states in the Application for Preliminary Permit that the “proposed Ashokan Pumped Storage Project would operate in a closed loop. Aside from evaporation and percolation losses, the project’s water would stay within the system.” The Ashokan Reservoir is an integral part of the Catskill System and a significant portion of the New York City water supply. Premium Energy’s statement that the project’s water would stay within the system is false. Premium Energy’s proposed project is not a closed-loop system—it is in fact an “add-on”, using an existing body of water as a lower reservoir, and the pumping required for this project will increase turbidity within the Ashokan Reservoir and carry significantly higher risks. Premium Energy’s project does not meet the standards of innovation sought by the Department of Energy. As stated in FERC’s Guidance for Applicants Seeking Licenses or Preliminary Permits for Closed-Loop Pumped Storage Projects at Abandoned Mine Sites (Docket No. AD19-8-000): “A closed-loop pumped storage project is generally defined as a pumped storage project that utilizes reservoirs situated at locations other than natural waterways, lakes, wetlands, and other natural surface water features, and may rely on temporary withdrawals from surface waters or groundwater for the sole purpose of initial fill or the periodic recharge needed for project operation. Types of reservoirs that lend themselves to a closed-loop project include reservoirs located in surface mine pits or underground mines.” Closed-loop pumped storage projects have less significant environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. Premium Energy’s application is falsely characterizing this project as a “closed-loop” system. The economic risk and potential for a public health crisis is too high to consider use of the Ashokan Reservoir as the location of a pumped storage project. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

We hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Sincerely, 

Sara Babyatsky and Kelly Stefanski

Sara Ansari, New York, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I strenuously object to the proposal by Premium Energy Holdings to build a hydro-electric power plant in New York’s Catskill Mountains. As a New York City resident and mother, I implore you to reject their permit request (Ashokan Pumped Storage Project P-15056). This project has many flaws, including devastating the local environment and economy, but I beg you to focus on what I see as the most urgent issue--compromising the drinking water supply of 9.5 million people in New York City, including 17 month old babies like mine.

The Ashokan Reservoir where Premium Energy Holdings wants to build this power plant is a reservoir that provides unfiltered drinking water for 40% of New York City. Forty percent!! The Catskill Water Supply overall, the preserve within which they wish to build, provides us with 90% of our drinking water. It is the largest unfiltered drinking water supply in the nation. To say that the people of New York City depend on the safety and stability of this water supply is a gross understatement.

I grew up in Michigan, where the drinking water of many communities has been poisoned as the result of local, state and federal failures to protect it. The Flint water crisis is the most prominent example. Who suffers the most from poisoned or contaminated drinking water? Children do, and usually children of our most vulnerable communities--our poorest residents and communities of color. Building a power plant around New York City’s primary drinking water reservoir is an unacceptable risk to take. Children drink water, absorb water and whatever is in it through their skin while bathing, they eat food cleaned or boiled in water. Clean drinking water is essential for children’s brain development and physical health. It cannot be compromised, and that is exactly what this proposed project would do. Please deny Premium Energy’s request.

We do not want to repeat the Flint water crisis in New York City. Flint is a city of around 100,000 people. New York City is almost 100 times that. Imagine the potential catastrophic damage to our city, and in turn our public health and national economy if this project moves forward.

It is also important to highlight that this proposal ignores the fact that this land has been protected by the New York State Constitution since 1885 under Article XIV, which stipulates that the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” This proposal directly violates our state constitution.

I fully understand that we as a country will need to sacrifice some public land for the greater good as we move toward more renewable energy sources, but we cannot do it at the expense of clean drinking water for 9.5 million people, at the expense of millions and millions of children and babies like mine. This project needs to find a different site where the consequences to the general public are less devastating. 

Thank you for your time and your service,
Sara Ansari
301 East 78th Street, 18c
New York, New York 10075

Jane Smiley, Carmel Valley, CA.
Please do not allow the dam project to go forward in the Catskill Forest Preserve. This is one of the most beautiful areas in the world, and according to Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” There is no reason for these beautiful lands to be destroyed by a huge dam, and no reason for the Esopus Creek, which I once lived near and loved, to be overwhelmed and also destroyed. This whole project is an example of corporate cheating. Premium is claiming that is will be “closed-loop,” but projects in which an upper reservoir is added to an existing lower reservoir are “add-on” projects, and that’s what this project is. Please do not allow this sort of corruption to destroy a cherished, precious, and prosperous region. I have been thinking of returning to the area. I would be heart-broken if it were destroyed.

Woodstock Land Conservancy N/A, Woodstock, NY.
April 9, 2021



VIA FERC ONLINE - EComment
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426

		Re: Project P-15056 Ashokan Pumped Storage

Dear Secretary Bose:

Woodstock Land Conservancy requests that FERC withhold approvals for a Preliminary Permit requested by Premium Energy Holdings, LLC. The proposed siting of the project would have a significant detrimental impact to both New York City’s drinking water supply, as well as a number of other communities whose water supply is dependent on this region, and would greatly impact the NYS Constitutionally-protected lands located in the Catskill Park, two hours north of New York City. The Catskill Park economy to a great degree is supported by its recreational offerings and the tourism that its natural beauty engenders. Among the recreational offerings are world-class trout fly-fishing with the Esopus River designated as a Wild-Quality stream by NYS’s Department of Environmental Conservation. 

The Catskill Park is one of two such parks in New York State, the other being the Adirondack Park. The State has committed enormous taxpayer resources to these parks in constitutionally protecting them and their important forests, habitats for a variety of species, some endangered, important waterways and recreational uses, and the appeal they have to the millions of annual visitors. The Catskill Park’s conserved lands account for more than half of its 700,000 acres. It is notable that the local topography in the proposed project area is a mountainous one with narrow valleys that have two-lane roadways and settlements. Any displacement of towns, residences, and infrastructure would be quite challenging as there is little valley land to accommodate these changes.

The proposed project would cause great impact on the lands, and create increased erosion into the waterways which flow to the Ashokan Reservoir, which is an unfiltered drinking water system supplying 40% of NYC’s drinking water. NYC’s Department of Environmental Protection which operates the drinking water supply system has numerous staff to control and protect these waterways. Sediment in the water is a huge issue to the water supply. And NYC is committed to a multi-billion dollar capital infrastructure project planned for the coming 10 years to continue its protection of this unfiltered water system. Adding another large-scale infrastructure project may not be possible to be coordinated with NYC’s plans, and certainly seems improbable for the local roadways to accommodate in their narrow valley corridors.

In the past year, with the challenges of COVID-19, this area has also experienced tremendous growth, with many more NYC dwellers seeking full-time housing, some of them weekenders previously, and large visitation numbers from people seeking a respite in nature. A newly-opened (October 2019) rail trail along the Ashokan Reservoir’s north shore has had more than 275,000 visitors, with a daily-total high of nearly 2,000 visitors. This trail, known as Ashokan Rail Trail, with its significant beauty is becoming known nation-wide and world-wide, and will only see an increase in these numbers in the coming years.

As the project comments roll in from a number of agencies, organizations and individuals, I imagine a clearer picture is being painted as to how the proposed project is ill-advised for this area – and reflects the challenges that would have been apparent to the applicant had they visited the area, rather than planning it from afar. In conclusion, we respectfully request a denial of this preliminary permit. If not, I am sure that there will be many court challenges, at a great expense for all, and will carry on well into the future.

With appreciation for your consideration.

Sincerely,



Maxanne Resnick
Executive Director
Woodstock Land Conservancy

JOHN b KOCH, LITTLE FALLS, NJ.
The esopus creek portal is cloudy this proposal will just increase the sediment and disperse it to parts unknown   please not here

Michael Boyer, Kingston, NY.
To Whom It May Concern:
     The proposed pump storage hydroelectric plant must NOT be allowed to be constructed in the area it's seeking to get a foot-hold in. According to the NYS Constitution this area of the state "shall be forever kept as wild forest lands", and no matter how safe or economically sound their proposal sounds, things with projects of this magnitude always seem to go awry. 
     Besides the fact that many people and communities will be forever disrupted, there is always the threat of things going wrong at a cost to the environment ---wildlife habitats will be drastically changed and/or eliminated; altering the sediment flow in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the most vital trout waters in the Catskills, doing great harm to valuable trout breeding habitats; and needless to say, tourism in this area would be greatly affected with the loss or destruction of any part of this beautiful natural environment.
     Premium Energy will try to sell what they say is best for this part of the state, but it appears that they are more interested in trying to make as much money as they can! I say NO to this entire proposal/project.

                                                                                              Sincerely, 
                                                                                              Michael J. Boyer
                                                                                              76 Beth Dr.
                                                                                              Kingston, NY 12401

Rachel Hunt, Brooklyn, NY.
I'm writing to voice my concern over the proposed hydro-electric power in the Catskill Forest Preserve by Premium Energy. While energy is an essential component of modern life, I don't think Premium Energy is going about this project the right way or in the right place. We must protect our preserves.

Elinor Stapylton, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to critique Premium Energy Holdings proposal to build a hydroelectric power plant in the Catskill Mountains. The proposal put forward by Premium Energy Holdings seems to have been made in total disregard of the Department of energy's goals, and without careful consideration of the impacts to the Catskills forever wild forests and the legal protection status of these lands. 
Premium Energy Holdings proposal is unrealistic about its own projects categorization.  

The company claims to be a closed loop system (page 11, Ashokan Pumped Storage Project P-15056). This statement is contrary to their proposed project since by definition the Ashokan would be classified as an open loop pump storage system as it is continuously connected to naturally flowing water, so that this project cannot be considered Open-loop, instead this proposed Add-on system is less energy effective and costly to maintain long term. In addition Premium Energy Holdings underestimate the amount of water level change they will cause as well as the potential devastation under increased rainfall events and under Climate Change. They also do not account for the increased turbidity rates that can be expected with their project given the turbines would disturb a centuries worth of sediment that has been accumulating in the upper Ashokan since its creation over a hundred years ago. This increased turbidity would absorb more light, resulting in increased water temperatures that reduces water quality and would be damaging for the important fish breeding habitat in the proposed areas as well as for 40% of NYC drinking water. This poorly articulated proposal does not meet its own standards that it claims to achieve, this should be enough grounds to reject Premium Energy Holdings for streamlined FERC approval for a preliminary license.  

Premium Energy Holdings proposal also disregards the protection of the Catskill forest. In Article XIV of the NYS Constitution, it is stated that the lands of the Catskills “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Additionally these lands are ranked in the top 1% of forest habitats region-wide by the New York State Forest Condition Index. In the USGS’s own language the lands of the Catskill Mountains are ranked as status 1 to conserve biodiversity and are defined as “An area having permanent protection from conversion of natural land cover and a mandated management plan in operation to maintain a natural state within which disturbance events (of natural type, frequency, intensity, and legacy) are allowed to proceed without interference or are mimicked through management.” These lands are also know for countless threatened and endangered species, such as Bicknell's Thrush, one of North America's rarest and most localized species, which was first described in the Slide Mountain Wilderness (where Premium Energy Holdings has proposed projects) and where they still reside, utilizing this land as critical protected breeding habitat.  

Premium Energy Holdings lack of critical planning and disregard for accurate language to describe their proposal demonstrates their inadequate understanding of the very project they are trying to propose and the complex system level impact it has throughout the region and into the future. I urge FERC to decline Premium Energy Holdings request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment especially under increased uncertainty of Climate Change, highly disruptive to local communities and economy, hazardous for the purity of NYC’s drinking water, as well in the case of Premium Energy Holdings proposal; lacking the insight and organization to propose a critically researched proposal to the FERC.
 
I know the FERC’s commitment to economically efficient, safe, reliable and secure energy for consumers will enable them to see the critical issues in Premium Energy Holdings request for a preliminary permit and reject their ill informed proposal on the ground that these status 1 protected lands for biodiversity conservation are essential for safeguarding the future where intact habitats will be paramount for resiliency. Of course hydroelectric and Pumped Storage Projects will be a critical component of our transition to renewable resources, but these energy solutions will only be economically efficient, safe, reliable and secure if they do not degrade the environment we depend on, such as any project that proposes the destruction of such important protected habitat for people and the environment.

Elinor Stapylton and Nicholas George

Edward Ripley-Duggan, Olivebridge, NY.
The Catskill region is an ecologically sensitive one, already under some threat from a wide spectrum of factors. Changing temperatures that impact forest health, invasive species, anthropogenic pressures, development and a host of other circumstances already impinge on this, one of New York State’s most beloved parks. That somehow the admittedly very real threat of climate change and the acknowledged need for green energy should justify a proposal that would materially effect the integrity of the region that supplies most of New York City’s drinking water, and is one of its foremost outdoor recreational resources, is staggeringly misguided.

There are, after all,  a variety of other mass energy storage mediums than pumped storage. Some are presently viable. Others will need further research before they can be considered seriously. Few of them, however, require such onerous location requirements as pumped storage hydropower. The use of this easy-fix technology would create irrevocable damage, unacceptable in a region of such critical environmental sensitivity. 

Electrical storage technologies presently technically close to full feasibility include hydrogen energy storage, utilizing fuel-cell or combustion technologies for regeneration. That same hydrogen could also be profitably sold to power  the fleets of fuel-cell powered cars that seem likely to be on the roads in a few years.  Another technology that is ready for prime time is compressed-air energy storage, which can be situated underground. There are in addition a variety of other technologies that are technologically more demanding than these, but which should be ready to bring on line over the next decade, if enough demand exists (superconducting mass energy storage and super-capacitors are both potentially feasible at large scale). Ultimately, a variety of localized energy storage methods are likely to be needed and used. From an environmental perspective, pumped hydro storage is far and away the least attractive and unquestionably the most destructive of methods of mass energy storage. 

I’m not sure that the full implications of pumped storage on the region have been appreciated. Are we prepared to see vast arrays of transmission towers in the region; power must, after all, be bought in to be stored, and lined back out. Tunnel systems that dwarf the Gilboa-Shandaken tunnel are quite customary in such projects; are we ready for that? The enormous burden and disruption to local communities created by heavy equipment passing through to these industrial construction sites in our valleys seems not to have been considered in this proposal. And the list of negatives goes on. This region sacrificed greatly a century ago for the construction of the Ashokan Reservoir and other components of the New York water supply system, and to some extent still does. Let this not happen again.

The bottom line is that pumped storage hydro is an old, and in essence, technologically lazy fix to energy needs, be it for primary electrical generation or for energy storage. Globally speaking, large dam projects have caused an immense amount of irrevocable environmental loss and human displacement. While there is a compelling need for green energy sources, for these to be created at the cost of massive environmental degradation is an unacceptable way forward.

Gail Mallimson, SAN FRANCISCO, CA.
As a former New Yorker, and frequent visitor to the Catskill area, I am horrified by the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I am requesting that the Ashokan Pumped Storage Project P-15056 be denied a permit and the project be terminated completely, as it would be destructive to the environment, create havoc for local communities, and imperil NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Gail Mallimson

Jane Levenson, New York, NY.
Regarding P-15056, I strongly disapprove of the proposed interference to the Catskill Preserve. Protected land, it should remain so for habitat, recreation enjoyment and especially for keeping the Ashokan Reservoir and watershed area safe for its drinking water. Health and safety are seriously involved

NYDEC was not consulted and all the major groups involved with the environment, land and river systems have alerted me to the details and its negative consequences. This is not only negative for me and generations now alive, but for future ones as well.

Please reject this pipeline intervention proposal 

Sincerely and concerned,

Jane Levenson
4/9/21

Suzanne Thorpe, Catskill, NY.
Docket number P-15056-000

Dear Ms. Bose,

As a Catskill, NY resident I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it will illegally disrupt the forest preserve as well as the lives of people living in the area, and poses risks to the drinking water of millions of people. 

The Catskill region is a chartered forest preserve for a reason: it is a rare continuous wildlife habitat. Our increasing awareness of the interconnectedness of ecosystems makes it even more imperative that we maintain the forest’s health. This proposal stands to significantly disrupt that balance in a destructive and devastating manner. 

In addition the region features one of the most renowned water systems and aquifers in the world, a system millions of people depend upon for clean drinking water. Threatening that system is irresponsible in a time of precarious climate events and climate instability. 

To be clear I’m supportive of alternative energy initiatives, and am aware that they often prompt a “not in my backyard” response. In this case, however, the environmental costs appear to outweigh the benefits. For these reasons and many more I encourage you to deny the permit. 

Sincerely, 
Dr. Suzanne Thorpe

Tatiana Alexa, Chichester, NY.
To:
Kimberly D. Bose 
Secretary, Federal Energy Regulatory Commission
888 First Street, NE, Room 1A, Washington, DC 20426

This letter is in opposition of the above named Application for Preliminary Permit submitted by Premium Energy Holdings, LLC.

The Catskills Forest Park is a jam, that was preserved by our predecessors for the generations to come. With its proximity to New York City, it is a beloved spot for recreational activity and weekend breaks not only by local community, but mainly by millions of New Yorkers.  Ruining it by a construction of a such scale will be a true crime, and cause a permanent damage. Premium Energy Holdings purposefully hides the fact that all three proposed locations are at the center of the Catskills Forest Preserve, established in 1885. Its status is preserved by Article XIV of the New York State Constitution. It is also very telling that none of us nor our elected representatives were notified by Premium Energy Holdings of its intentions and plans. 

What also concerns me that the request submitted by Premium Energy Holdings is highly misleading. While stating that the request is for a "closed loop", the review of the request clearly shows that it is not. 

It must be also stated, that currently there is no known machinery used for pumping, generating and/or transmitting energy, which COE would be greater than 95%. Therefore, cumulatively during energy generating cycle a MINIMUM of 10% -20% of energy will be lost in the proposed pumped power plant solution. It is at most importance to note that such lost electrical energy is originally drawn from a common grid and supplied there by non-renewable and non-green methods. 
In other words, tons of coal or oil must be burned in order to operate proposed so-called ‘renewable energy power plant’. Not mentioning here are other losses, such as hydraulic energy loss, e.g., which also contributes and increases the total energy loss in such pumped storage solutions. While using the term ‘renewable energy’ the proposed solution inefficiently uses non-renewable, ‘dirty’ energy from the grid thus directly contributing to the global warming.

I'm urging the Federal Energy Regulatory Commission to deny Premium Energy Holdings, LLC request for a preliminary permit to study the feasibility of a pumped-storage hydropower facility connected to Ashokan Reservoir.

Best regards,
Tatiana Alexa
199 Stony Clove Lane
Chichester
New York
12416

Andrew Lemonier, Jersey City, NJ.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Julia Rose, phoenicia, NY.

I am writing regarding Premium Energy Holdings’ proposal to build a hydroelectric pumped storage plant in New York’s Catskill Mountains (Ashokan Pumped Storage Project P-15056). Their plan is ill conceived, poorly researched and should be denied, before wasting further time, money, and effort by FERC and all other parties involved.

I believe it is important that our nation move towards renewable green-energy sources, but this must not happen at the expense of the environment, protected wildlife, local economies, and families who will be displaced from their homes. 

It is my understanding that pumped storage facilities such as this are cost IN-effective- resulting in a near net loss of energy because the water has to be pumped back up to the upper reservoir, not to mention the astronomical costs of the infrastructure. The financial expense is only one aspect of the price of this project. Although their proposal claims to be a closed loop system, even a lay person as myself can see that this project is an open loop/add on loop system. The mere fact that they are mis-representing the facts of their proposal is a red flag about their intentions and ethics. Their utter lack of consideration for the many precluding factors that should have been investigated prior to submitting the application for preliminary study is testament to their disregard for due diligence and for the costs incurred to FERC, the government, and taxpayers. 

1.	The proposed sites for the dam are in lands protected under Article XIV of the NYS Constitution, which clearly states that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

Additionally, the US Geological Survey has designated the Catskills Park State Forest Preserve as Status 2 lands. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”


2.	The negative impact on the Ashokan watershed, its surrounding lands, and the wildlife that make their home in these protected lands would be devastating. The massive construction project and rapidly fluctuating water levels of the pumped storage system would have dire consequences for the multitude of species that live in the area, including, but not limited to the trout for which the steams of the Catskills are known nationwide, many birds, fauna and flora .

3.	Water supply to 9.5 million people in New York would be in jeopardy as the Ashokan Reservoir (which would serve as the lower reservoir in this project) supplies 40% of the city’s water (approximately 1 billion gallons a day). This project would threaten the largest unfiltered water supply in the US, and compromise billions of dollars of existing infrastructure.
4.	Eco tourism and outdoor activities (hiking, camping, fishing) are a major source of revenue for the Catskills. Much of this would be damaged and destroyed by the proposed dam. This would impact nearly 20,000 jobs and put a major dent in a $1.5 billion + industry, diminishing tax revenue for the state as well. 
Please deny Premier Energy Holdings request for a preliminary permit to build an add on loop system pump storage hydro-electric plant in the protected lands of the Catskill Preserve (Ashokan Pumped Storage Project P-15056). 

Thank you.

Sincerely,

Julia Rose

Maya Raffaele, Phoenicia, NY.

Docket number P-15056-000

My name is Maya Raffaele. I am 11 years old and live in Woodland Valley, Phoenicia, one of the locations  Premium Energy Holdings plans to build a dam. I know that your concerns are not within a personal perspective but in my opinion, the fact that it would be destroying people's homes should be at the top of the list. But it is not just peoples’ homes that will be getting demolished, countless plants and animals will be gone. There are also protected species and habitats that will be threatened:

The bog orchid, trout waters, many birds (Audubon Catskills Peaks Important Bird Area): raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk, black-throated blue warbler, scarlet tanager, and wood thrush, New york threatened northern long eared bat, to name a few.


There are also historical sights that would be destroyed, which include:

The Roxmore Inn- visited by naturalist John Burroughs

The William L. Beach house, occupied by Thomas Craig, nature painter

The Emil Brunel Studio and Sculpture garden

Living near the Woodland Valley campground, I get to see how many people come to camp, hike, and fish. What would happen to the trails and the campground?

Two ski resorts, shops, restaurants, inns will be also be in trouble if the dam is built. This means that people will lose their homes and jobs.    

I know that the words of an 11 year old might seem insignificant and silly, but I think I speak for most of the Woodland Valley residents (and of the other possible locations) when I say that our lives and the lives of countless animals would be completely turned upside down if this proposal is accepted. 


Sincerely,
Maya Raffaele

chris condon, Kingston, NY.
 To:
 Kimberly D. Bose
 Federal Energy Regulatory Commission
 888 First St. NE, Room 1A
 Washington, D.C. 20426

 Dear Ms. Bose,
   I am writing in response to the proposal of building a Hydroelectric Plant in the Catskill Forest Preserve by the company Premium Energy Holdings. This proposal has many flaws. The company has submitted an application for a "Closed Loop System" when in fact it is an "add on" to the already existing Ashokan Reservoir, which supplies 40% of the drinking water for the City of New York. The Turbidity that is caused when you pump the water back and forth will have a very negative impact on the existing Ashokan Reservoir which is the largest unfiltered water supply in our nation. Can we really afford to take this risk when over 1.7 billion dollars have already been invested in keeping this vital source of drinking water clean and pure?  The Catskill Forest Preserve has been deemed "Forever Wild" under article XIV of the NYS Constitution which states that these lands "shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or to be taken by any corporation, public or private." Each of the proposed sites would drastically alter and ultimately destroy the diverse and fragile ecosystems that make up the over 700,000 acres of wildlife habitat. This forest preserve ranks among the top 1% of forest habitats in the region. All 3 proposed sites would also be very detrimental to the communities which will be affected should this come to fruition. Any upper reservoir would result in the seizing of homes through eminent domain. One of the proposed sites would require the closure of one of only 3 main routes through the mountains. Tourism, which is a vital part of the Catskills would be affected greatly. While I wholeheartedly agree we have a strong need for renewable energy sources it should never come at the ultimate cost of environmental and community devastation. For all that is at stake I urge you to please deny proposal P-15056-000 for Premium Energy Holdings. Thank you for your consideration. 
                 Sincerely,
                            Chris Condon

Margery Schab, Woodstock, NY.
I urge you to reject Premium Energy Holdings LLC request for a preliminary permit for the proposed Ashokan Pump Storage project.  Sustainable and renewable energy is important, but this plan in the heart of the Catskill Mountains could well become an environmental and economic disaster for the region and New York City.  

Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Those who wrote the state constitution understood well the  priceless value of the Catskill Park and the New York City Watershed.  According to The Catskill Park: Inside the Blue Line, Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.  I believe the citizens of not only Ulster county but also the metro area of New York state which includes New York City, Westchester, Orange, Rockland Counties would not support such an amendment.

Moreover, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are to be avoided for development.”

A NYC Watershed is a valuable capital asset, representing billions of dollars of investment; $1.7 billion since the 1990s alone

A $1.6 billion industry in the region, supporting roughly 20,000 jobs
o Ulster County represents 43% of that market
o Second homes generate $360 million in economic activity
▪ Source: Tourism Economics, “Economic Impact of Tourism in NY, 2019”

Use of Concrete.  The proposal states that the tunnels will also be using concrete in their building materials.  Concrete disintegrates in within decades.  This will put the reservoirs at grave risk of structural damage.  

The excuse for this facility is that it will use “non fossil fuels as energy”. As a society we cannot afford to sacrifice our NYC water system for a dam in the NYC watershed.   Pursuing instead conservation, encouragement of using less and more efficient energy is better than risking the water supply for millions of people.  Since this is a limited liability corporation who will pay for the probable intermediate term the great degradation, to the NYC water supply.

For human life the most important ingredient is good clean water.  The main mission of the government is to maintain the delivery good, clean, water to all. To live in a carbon neutral environment, conservation is the most important component.  The real question is how do we cut down our energy needs and how to become more efficient. The real reality is that we live in a finite world of resources.  Let us not squander that we have unfiltered mountain water for our well being and for all the other creatures  that also depend on it for life.

Marilee Talman, Pine Plains, NY.
Hydro Project Search:

The proposal from Premium Energy of Walnut, CA concerning a pumped storage facility using water from the lower (west) basin of the Ashokan Reservoir in New York State (New York City watershed) does not even one single thing to address our biggest problem on Plant Earth or to support the biggest solution to that problem:

NOAA (National Oceanic and Atmospheric Administration) announced today (April 9, 2021) that level of carbon dioxide on Earth is highest in 3.6 million years, a time when sea level was 78 feet higher than today and temperature was 7 degrees warmer (as opposed to the 1.5 degrees or even 2 degrees that we have set as a goal for 2050).  Conditions on the surface of the earth are THE ONLY THING keeping us from the 6th mass extinction that has been predicted.  Some scientists predict the de-evolution (or devolution) of the oceans (from temperatures and/or plastic—who knew, “death by plastic”) in as little as 8-12 years, a point after which there is NO-THING we can do to avoid extinction.

The Premium Energy plan does not add energy to the grid, uses more power than it stores, is expensive financially AND is likely to be a disruptive force in the ecology of the reservoir as well as the Esopus Creek and its tributaries (due to rapid changes in water level).

This is a NO WIN.  It is NON-SENSE.  It is people trying to extract some numbers (“metrics” and “monetizing”) from a situation. It must be denied.  Send them back to the drawing board to do something useful. Thank you.

Jessica Rose, West Hurley, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jessica Rose

Adriane Hectus, Jordanville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Adriane Hectus

Stan Mashov, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed to this Enron-type, purely profit-driven project that masquerading as clean energy play. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. And it should not be taken advantage by these unscrupulous players. I hope Premium Energy will be able to see through the money-grabbing scheme of this foreign to the state player for what it is.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Stan Mashov

KELLY SINCLAIR, SHADY, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Kelly Sinclair

michael blitz, Hicksville, NY.
You're going to allow the Catskills Preserve to be destroyed???

The Coalition to Save Catskills Preserve is a newly formed network composed of a growing number of citizens and community groups dedicated to protecting The Catskill Preserve. We are united by our devotion to the environment, wildlife, recreation, and cultural heritage that’s  unique to this region, and by our mission to protect the ecology and history of Catskills State Park from misguided and inappropriate exploitation of our natural resources.

Our Immediate Goal:

Our immediate goal is the denial of a preliminary permit application by Premium Energy Holdings, LLC to study the feasibility of building a hydroelectric stored power plant on the Ashokan Reservoir and surrounding watershed. 

Premium Energy’s Ashokan Pumped Storage Project would necessitate the construction of a new reservoir, a massive concrete dam, many miles of high-voltage power lines, and the drilling of huge underground tunnels running below homes, streams, and mountains.

The flawed application should be denied for multiple reasons, including:

The project would disrupt the environment of the Catskill Forest Preserve, 700,000 acres of critical habitat in an increasingly fragmented world. Any feasible site in the Catskills would impinge on USGS-designated Status 2 land. Federal policy directs that Status 1 and 2 land areas are highly protected and must be avoided for development.
The proposed project will severely disrupt streams within the Ashokan watershed, and increase turbidity in the Ashokan Reservoir itself—which serves as a primary source of unfiltered drinking water for 9 million New York residents.
The flawed application misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design, which means it has worse environmental impacts than closed-loop hydroelectric projects.
The project raises numerous legal issues regarding States’ rights and land preservation.
The proposed site is home to protected species of wildlife and flora/fauna, as well as historical and cultural artifacts and sites.

 This project must NOT be granted a permit.

Respectfully, 
Michael Blitz, Ph.D.
Professor of Interdisciplinary Studies
John Jay College of Criminal Justice
The City University of New York
mblitz@jjay.cuny.edu

Judith Capurso, Saugerties, NY.
Closed-loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval; that’s why Premium is claiming to be “closed-loop.” 

• Projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects; that’s what this really is. YOU are lying. 

• “Initial construction impacts” for these projects are lower, but “operational impacts are still likely to be higher than for a closed-loop project because the add on project’s lower reservoir is still continuously connected to, and may affect, the natural flowing water feature that was dammed for its original construction.”

▪Source: DOE: “A Comparison of the Env. Effects of Open Loop and Closed-Loop Pumped Storage Hydropower.” April 2020

Note the DOE comments above and fulfill transparency and honesty practices. 
This is a plan about making money for the very few with catastrophic impacts for the many, the environment, and for future residents.

Judith Capurso

Alice Bierhorst, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I grew up in West Shokan, part of the beautiful Catskill Forest Preserve. My father still lives there, my mother is buried there, and my husband and I plan to take over the family home and die there ourselves. This place has deep meaning for me and my family. I am writing to urge you to reject the proposal by Premium Energy Holdings to build a hydroelectric power plant in this place I consider hallowed ground. I don't think I have to tell you how much a place can mean to a person. We all have our special places.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alice Bierhorst

Kathryn Bradley Chernis, Stone Ridge, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Heather Gierloff, Boiceville, NY.
I am a resident of one of Olive, NY in an area that is being proposed by Premium Energy Holdings in docket number P-15056-000. The large dam, reservoir, turbine, and tunnels that may be installed for storage and generation of electricity would significantly change the area. 

Preserving a portion of New York in the bounds of the Catskill Preserve is critical to maintain significant land, diversity and recreation for the future of New York for its residents and visitors. The Catskills thrive with ecotourism and altering the landscape may have a significant economic impact to the area that so many businesses and residents rely on.

Changing the paths of the water has the potential of impacting  fish species, habitat and surface water runoff. The Catskill area is centered on clean free flowing streams that have been captured in the reservoir system that was constructed 100 years ago. The reservoir system is critical in providing unfiltered drinking water to nine million people in New York City.

I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters Please do everything in your power to prevent this proposal from moving forward.

Mary Sheridan, Leeds, NY.
P-15056 Pump Storage

April 10, 2021

As a life-long resident of Greene County NY, living half a lifetime within the Town of Hunter and now in the Town of Catskill, I hold tremendous respect for those that make the "Mountain Top "their home- for generations.  
 
In short this Pumped-Storage  Hydro Plant would have a negative impact on these areas for various reasons:

-	The Ashokan  Reservoir  ( Department of Environmental Protection /DEP) provides the City of New York with approximately 40% of its water, this water is being pumped across from the the Gilboa Reservoir in Deleware /Schoharie County area.

-	The Proposal falls within the NYS Department of Environmental Conservation- (forever wild clause) - Protected and Historical Catskill Park/Catskill Forest Preserve.

-	In the event of a Catastrophic road failure of State Route 23A in the Town of Hunter from hamlet of Haines Falls to the Town of Catskill line hamlet of Palenville (which has occurred numerous times !) alternative routes such as State Route 214, the Platte Clove Road ( Greene County Route 16 a seasonal road-currently closed due to rock slides) , State Route 42 Lexington ( also having had Catastrophic  road failure numerous times  sometimes simultaneously ), along with use of State Route 296 to NY Route 23 are used for egress/ employment  for the Residents that live within the Towns of Hunter, Lexington, Windham , Prattsville and Jewett  respectively.   Also to mention those from the Ulster County side that use SR 214 to come into Greene County for employment. 
This would cause undue hardship for numerous residents.

-	These areas are dependent on Tourism.  Access to our regions ski areas, hiking trails and camping facilities both private and state run, historical areas, restaurants’ etc. are destinations for travelers and contribute to our economic and environmental growth.

-	As small communities they are Very Dependent on Volunteer  Mutual Aid  for Fire and EMS Services.


-	Electricity for the hamlet of Lanesville , Edgewood , Chichester, Stony Clove is run from the Phoneicia area and ends at the NYS Campground – Devil’s Tombstone. 

How would SR 214 be re-routed?    Roads such as Diamond Notch, Silver Hollow and  Broadstreet  Hollow are all dead ended for numerous reasons. 

As there are more reasons to list as to environmental impacts, quality of life and economic impacts, this expansive project would be devastating to the communities involved and does not belong here.



Sincerely ,
Mary Sheridan

Ricarda O'Conner, Chichester, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

To begin with, Premium Energy’s application is deficient and inaccurate.

It is deficient in that the application does not include by name two towns, Shandaken and Hunter, or a third county, Greene, that would be highly and negatively impacted by such a project. 

The application is inaccurate in that it claims that all three potential sites for the upper reservoir are situated on New York State land. That claim is only partially true. All three locations also straddle private property. In the Woodland Valley location alone over 80 homes and properties would be submerged. The Stony Clove location would completely flood the center of the hamlet of Lanesville and cut off State Route 214, a well-traveled main artery and one of only two roads that connect Rt. 28 in Ulster County to Rt. 23A in Greene County. There is nothing in Premium Energy’s application that addresses the loss of this important road, or makes provisions to reroute it.

But most of all, Premium Energy’s application is fraudulent. 

Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water, the Ashokan Reservoir, as the lower reservoir. The Ashokan is an open body of water continuously connected to naturally flowing water, the Esopus Creek. So in fact, Premium Energy’s proposal is for an “open-loop” pumped storage hydropower system, NOT for “closed-loop” as the company is falsely claiming, no doubt for the advantage of being fast-tracked for approval.

All told, The Ashokan Pumped Storage Project has been submitted under false pretenses, is antithetical to the fundamentals of “Green Energy” and would have a long-term, negative impact on the lives of local community members and the fragile, preserved Catskill Watershed lands in which they have chosen to live.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ricarda O’Conner

104 Schweitzer Road
Chichester, NY 12416
(917) 533-3748

Michael Ottavi, Chichester, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

While there’s no doubt that pumped storage and other new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of the Catskills must not be sacrificed in the process. 

The Catskills Forest Preserve was created 135 years ago. The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment. According to the New York State Forest Condition Index, the forest surrounding each of the three sites proposed by Premium Energy for an upper reservoir ranks among the top 1% of forest habitats region-wide. In addition, all the proposed reservoirs fall within what the Audubon Society has designated as the Catskill Peaks Important Bird Area.

Article XIV of the NYS Constitution states the Catskills “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” It is required by law that any change to this land provision requires an amendment to the state Constitution, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.

Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS “Gap Analysis Program.” According to the Department of Energy’s own Hydropower Vision, “areas with formal
protections designated as Status 1 or 2 under the USGS Gap Analysis Program should be avoided for development.”

Transition to renewable, green-energy sources must not come at the cost of environmental devastation. Premium Energy should select a suitable alternative location for a pumped storage project, NOT this incredibly important natural wilderness. The Catskills Forest Preserve must remain protected.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Michael Ottavi

104 Schweitzer Road
Chichester, NY 12416
(917) 533-1196

Cliff Rabuffo, Chichester, NY.
Dear Secretary Bose,

     This proposal by Premium Energy has been poorly thought out and the application is misleading; it will do far more harm to the environment and the affected communities than any potential benefit it might offer on the path towards de-carbonization. 
-This is erroneously shown as a “closed loop system” when in fact there is a river running in and out of both the proposed upper reservoir (in all three locations) and the existing “lower” reservoir

-When calculating the affect of a pump cycle on the Ashokan reservoir, Premium Energy used the surface area of the entire reservoir. They failed to take into account the fact that the Ashokan is split into two basins separated by a weir. They would be drawing from and dumping into the upper basin only. When this fact is calculated out, their assumed 2 foot rise over the whole reservoir becomes an actual 5 foot change in height in just the upper basin. This will cause a massive disruption in the homeostasis of the reservoir, and the Ashokan is part of the largest unfiltered public water supply in the world. Has Premium studied the increase in turbidity levels and how that would affect the water quality for the more than 9 million residents of New York City?

-The entire proposal is sited in the Catskill Forest Preserve. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”. Has Premium energy or FERC looked into the legality of running afoul of the New York State Constitution? 

-Since the proposal makes use of existing watersheds, it will be disruptive to the natural inhabitants of these areas, such as Brook trout and the threatened Bald Eagles that call this area home. The Ashokan as well as the streams that would be dammed by this proposal are both nesting and foraging sites for Bald Eagles.  The conservation efforts that have pulled Bald Eagle populations back to more sustainable levels are one of America’s great conservation success stories; and one of the many reasons this preserve area was set aside to begin with. Has premium looked into the affect of the of the long construction period on the these ecologically sensitive habitats?
-Has Premium energy shown the ability to actually power this facility with renewable energy? These projects are put forth as “batteries” for renewable energy, but often in practice are often run off of fossil fuels creating the worst of all worlds.

-Excavation intensive projects such as reservoirs and tunnels require a disproportionally large amount of heavy construction equipment which, even with today’s tighter emissions standards still require the burning of large amounts of diesel fuel. Has Premium Energy taken into account the environmental toll of this fossil fuel use during construction vs any perceived gain down the road? 

-These locations in particular would also require the relocation of major through roads as well as the relocation of hundreds of people and homes. This would only add to the construction costs and environmental toll. All these things taken together paint a very clear picture that these proposed locations are poorly suited for this purpose

We all know that we need to find a better way forward to preserve this planet for future generations. But we have to begin by taking the total cost of our actions into account. I urge you to deny this application by Premium Energy on the grounds of being based on false or misleading information and their failure to take the true cost of this project, in these locations, into account.  

  Thank you for your consideration,
    Cliff Rabuffo
    Chichester, NY

Luke Schwartz, Shokan, NY.
I’m incredibly concerned and vehemently opposed to this proposal. This proposal would unnecessarily tamper with national forest preserve, privately owned land, homes, jobs, local economy, and pose threats NYC water supply. This proposal breaks laws and is a threat to my 200 year old home in Shokan. This area should be protected from ever having to go through this kind of trauma again after the building of the ashokan reservoir.

Aliza, Shokan, NY.
As a resident of Olive, I am extremely concerned about this invasive project — we purchased our home and land to preserve the integrity of the natural landscape, as well as the social history of the town. Our house and barn date back 200-years (it was built by the Elmendorf family, original settlers of the area) as a homestead. This historic property and corresponding land would be directly threatened by the project, which would not only be a loss for our family, but for the entire community, as this is one of the few properties that survived the construction of the Ashokan Reservoir 100-years ago. As the land continues to heal from the devastation of the last water initiative, the proposed project would destroy that progress. This must not move forward.

Mary J Reiss, Phoenicia, NY.
To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Mary J Reiss

Melissa Kawecki, Roscoe, NY.
I am a resident of The Catskills and deeply oppose  the Ashokan Reservoir Power Plant Project proposed in The Catskills Forest Preserve.

Hendrik Uyttendaele, West Shokan, NY.
I urge you to reject Premium Energy Holdings' application to study a pumped storage facility in the Ashokan Reservoir area of the Catskills Preserve. It will fatally complicate efforts to maintain water quality both locally and for millions of New York City residents.

The Esopus Creek was dammed in 1915 to create the Ashokan Reservoir. The water of the upper Esopus Creek feeds the Western part of the Ashokan reservoir (Western basin), which then continues to flow in the Eastern part of the reservoir (Eastern basin), and the water then flows into the Catskill Aqueduct to the Kensico Reservoir in Westchester County, and then to New York City, where it provides unfiltered and clean drinking water to millions of inhabitants. 40% of the NYC water supply flows through the Ashokan reservoir.

Because of the innate geological and hydrological characteristics of the upper Esopus Creek watershed area, enormous amounts of red silt or clay are picked up by the upper Esopus Creek with each rain storm. This red silt turns the upper Esopus Creek into a river of "chocolate milk" which is then brought into the Western basin. There, the red silt settles to the bottom of the Western basin, and clear surface water is transferred at certain times to the Eastern basin, on its way to NYC. As a result, enormous amounts of red silt are currently stored at the bottom of the Western basin.

After heavy rains, the Esopus Creek can bring too much "chocolate milk" into the Western basin. At those times, the turbid water is discharged to the lower Esopus, in order to prevent the "chocolate milk" from being released into the Eastern basin. This action is referred to as "operational release" and is controlled by the NYC Department of Environmental Protection (DEP). Millions of gallons of water are sacrificed each year to preserve low turbidity in the waters of the Eastern basin.

These NYC DEP controlled discharges in the lower Esopus river have had severe impacts on the lower Esopus Creek and river bank ecology. This has resulted in ongoing litigation between the NYC DEP on the one hand, and many different parties like Ulster County, the environmental group Riverbank, many residents and the NYS Department of Environmental Conservation (DEC), on the other.

In addition, extensive efforts are currently underway to reduce the level of turbidity (also referred to as suspended sediment concentrations or SSCs) in the upper Esopus Creek. Multiple stream restoration projects of the upper Esopus Creek and its tributaries are currently being done by the NYC DEP and Ulster County Soil and Water Conservation District (UCSWCD). These restoration projects of the upper Esopus Creek watershed are done in agreement and supervised by New York State Department of Health (NYSDOH) and the United States Environmental Protection Agency (EPA). The EPA acts as the regulatory agency that oversees NYC DEP agreed upon conditions that allows NYC DEP to avoid filtering the water for millions of NYC inhabitants, as described in its Filtration Avoidance Determination (FAD) agreement.

What will happen if the proposed new upper reservoir becomes operational as part of a Pumped Hydro Energy Storage (PHES) system that uses the Western basin as its lower basin? To start, enormous amounts of sediments will become suspended in the water of the new upper basin, which is not aligned with an erosion-resistant river bed base, and huge amounts of soil sediments will be suspended in its waters with each daily fill of water. When this water with high SSC from the upper basin is released (to generate electricity), huge amounts of SSC will end up in the Western basin. The release of so much water in the Western basin will also churn up enormous amounts of sediments that are already settled at the base of the Western basin, increasing SSCs even further. To describe it simply, because of the action of the proposed PHES, the waters of the Western basin will look like "chocolate milk" all the time, not only when heavy rainfall occurs.

What can NYC DEP do with this enormous increase in daily SSC in the waters of the Western basin? It will not be able to release waters into the Eastern basin because it is too turbid, so the water supply it can provide to the Eastern basin will be drastically reduced. NYC DEP and UCSWCD's efforts reduce the turbidity of the waters of the Western basin as much as possible would be futile. The PHES system would be run by a private company trying to maximize efficiency and profit, and it will try to run this system as much as possible, to serve the interests of its investors as opposed to preserving the quantity and quality of water to millions of NYC residents.

NYC DEP could try to reduce sediments from its water supply by creating huge water treatment plants further downstream, however that would require the use of inorganic polyaluminium coagulants or synthetic organic coagulants. These treatment centers would be very expensive and the safety of these coagulants in drinking water is very controversial and their use is prohibited in many countries.

There are obviously many other issues with the above proposed PHES system, such as possible contamination of the water with soluble metals and other organic and inorganic compounds. These metals and compounds not only can affect water quality to millions of New Yorkers (which would then require filtration, which NYC has avoided under the FAD agreement) but also can affect the aquatic life in the Ashokan reservoir. Furthermore, increased turbidity will result in higher water evaporation waste (darker waters absorb more sun light) and decreased light penetration and oxygenation will result in a significant disturbance of the aquatic life that is key in keeping its water clean, as well as possible overgrowth of toxic cyanobacteria.

In conclusion, the proposal to create an "open" PHES system using the Ashokan reservoir as its lower basin is preposterous. I urge you to reject it out of hand.

Joan Hall, Phoenicia, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Joan Hall

Daniel Prousline, NEW YORK, NY.
I am appalled at this attempt to ruin the pristine beauty of the Catskill State Park 
This project will ruin the environment and affect the most important recreational area for the NYC residents. 
NO to big energy development in the Catskills! This is a disgusting big money attack on our land!

Cynthia Russak, High Falls, NY.
It's my understanding that this proposal and the building of a dam/power plant will result in destruction of the environment, therefore I object.  There has got to be a better way, with a company which will not arrogantly enter the property of others, flood homes, destroy and pollute what was a protected area, flooding homes, forcing humans and wildlife out, and probably creating many other problems we are not aware of.  I agree with all the objections stated by others who object.  Sorry I can'
t type very much due to a computer based hand injury.  Please acknowledge and accept my protest.  Thank you.

Janice Kachadourian, Lanesville, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to object to and oppose Premium Energy’s preliminary permit for the Ashokan Pumped Storage Project P-15056. The proposal contains many errors that reveal the haste with which it was contrived, as well as a lack of knowledge and research of the Catskill Preserve that seeks gain, by targeting a few energy talking points, while ignoring the political, geographic and scientific realities of the proposed site. 

The proposal targets the Catskill Preserve - 700,000 acres which are protected under Article XIV of the New York State Constitution.  Article XIV states that it “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or taken by any corporation, public or private.”  Changes to land management in the state forest preserve cannot be made lightly, they are safeguarded by extensive legal procedures – they must be passed by constitutional amendment, and voted on by two consecutive sessions of the state legislature, and submitted to public referendum.

Further, the Preserve receives the highest rating, Status 1, under the USGS Gap Analysis Program, a national program that assesses and supports the overall conservation status of wildlife. In Hydropower Vision, the US Department of Energy states that the designations of Status 1 or Status 2 are avoided for development. The prospect of an add-on pumped storage facility being built and operated entails irreparable harm to this Status 1 environment.  In addition to the loss of hundreds of acres of forest, the building project stresses or must expand existing roads, waterways and power lines, and dig miles of underground water tunnels.  

The Premium Energy Proposal also makes the false claim of being a “closed loop” system.  In fact, what they are proposing is an “add on” system; tacking on a new reservoir to the 130-year-old Ashokan reservoir in the south Catskills, fed by the Esopus Creek and numerous tributaries. Constantly recirculating water between a new, upper reservoir and the old one would alter the sediment regime of the Esopus, and raise the turbulence levels in the Ashokan, impacting the water quality for the New York City. 

Finally, this project is set to displace thousands of people who make the area home, or who vacation in the area. Second homes, alone, in the Catskills generate 360 million dollars in economic activity.
The Premium Energy Project will seriously truncate a tourist industry that, as of 2019, made up 17% of the employment in the Catskills. 

One example of the three sites proposed for the add-on storage facility is Stony Clove at Route 214.  This officially designated Scenic Byway connects Hunter Mountain Resort and the town of Phoenicia, rated the #1 tourist destination outside of New York City.  It connects the two major highways of the Catskills, Routes 28 and 23A. And it serves as access for several busy trailheads into the Preserve, including Diamond Notch, Devil’s Path and Becker’s Hollow. Flooding or eliminating this road would therefore severely impact business, residential and tourist travel in the region.

The many species of floral and fauna nurtured in the Catskill Preserve make up a unique continuity, an intricate self-sustaining environment that is open to all for appreciation, and that disseminates benefits to the surrounding region. It provides irreplaceable animal and plant habitats interfaced by man, as resident or tourist, for sustenance, research and recreation. And finally, it provides a natural filter for the water supply that serves 40% of the population of New York City.

I respectfully request that FERC deny the ill conceived and poorly presented proposal made by Premium Energy to intrude on and destroy the vital yet fragile environment of the Catskill Preserve.

Janice Kachadourian
1560 Route 214
Lanesvillle, NY, 12450

Michael Callejo, Jupiter, FL.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Michael Callejo

James Pellitteri, Jewett, NY.
Federal Energy Regulatory Commission					April 10, 2021
888 First Street, NE. Room 1-A
Washington, DC  20426

ATT: Kimberly D. Bose, Secretary to the Commission
RE: The proposed Ashokan Reservoir Pumped Storage and Hydro-electric Project
        Docket P-15056

Dear Commissioners:
 
The Mountaintop Mayors and Supervisors Association, an organization representing the nine Greene County communities that lie within the northeast Catskill Mountains, recently reviewed the application submitted by Premium Energy and discussed at its March 2021 meeting.  We submit the following comments opposing this application:
  
•         It is not practical that Premium Energy would be able to secure property rights for exploration or development, especially on lands owned by NYCDEP and the NYS constitutionally protected Catskill Park Forest Preserve, which prevents any development public or private for the greater public good.  The applicant should prove it could get the authorizations necessary to proceed before granting a preliminary permit.
•         The geology of the region is challenged by turbidity during flood events, resulting in water quality impairment from suspended clay soils which can last for days or weeks depending on the magnitude of the flood event.  The project would significantly disturb the Ashokan reservoir system on which NYCDEP relies to provide high quality drinking water to approximately 9 million residents.
•         The environmental impacts would be overwhelming to the landscape, wildlife and aquatic resources.  The applicant should prove first the workability of this project given the substantive comments submitted to the Commission. 
•         The application was poorly put together, with minimal information.  That should be an indication the applicant did not know about or care to research the challenges it would up against proposing the project in this highly sensitive, protected region of NYS. 
•         One of the proposed reservoir locations is in Lanesville, the Town of Hunter, Greene County.  We support the Town of Hunter in decrying what that would do to the hamlet of Lanesville, through which a NYS-designated scenic byway runs (State Route 214).
 
The upstate communities and NYC have had an acrimonious relationship over the years since the takings of whole communities to build their reservoir system and more often than not are on the opposite end of watershed issues.  When it comes to this, however, we fully agree with the City of New York and respectfully request FERC deny this application and save everyone considerable time, expense and heartache given the exorbitant challenges inherent with this proposal. 
 
The Mountaintop Mayors and Supervisors Association (MMSA) represents the towns of Hunter, Windham, Prattsville, Ashland. Lexington, Jewett, Halcott and the Villages of Hunter and Tannersville.

Thank you for your attention.
Yours truly,
James Pellitteri, Jewett Town Supervisor, and Secretary of the MMSA

Junice J Santa Ana, SHOKAN, NY.
I am opposed to the construction of the “Ashokan Pumped Storage Project.”  This would have a negative impact on my community and the surrounding communities in my county. 

Sincerely,
Junice Santa Ana

Ben Perowsky, West Shokan, NY.
Dear Federal Energy Regulatory Commission, 

I have been living on the banks of the Maltby Hallow Creek in the middle of the Catskill Watershed (NYC's drinking water source) on a dead end road next to miles of FOREVER WILD protected STATUS 1 land for the past 16 years.
I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. 

This project raises major environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

It is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to this community and raises our concern over Premium Energies practices. 


A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Yet, this is what is being proposed.
 

The Protected Three Birds Orchid currently live at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.” 


The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. Not to mention that it is current habitat for Black Bears, Eagles, Mink, Egrets, Owls, Bobcats, Beavers and many other wildlife species which would be greatly impacted by the plan.


In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.
Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and Status 1 protected land. 

I ask that you deny this permit based on these essential points, and that they look for some other non threatening site for their work. 

Thank you for your time,  
Sincerely,
 
Ben Perowsky
153 Moon Haw Rd.
West Shokan, N.Y. 12494

Sarah Mitchell, West Kill, NY.
This proposed project is out of scale to the area and not energy efficient and would encroach on sensitive ecosystems, including Catskill Park/New York State forever wild lands.  

We are all for renewable and sustainable energy.  But this project is not right for this area. Why in the world would you want to pump water upstream to create a massive closed loop system?  This would be highly inefficient and totally unnecessary. Exploring smaller scale projects would be smarter and more cost effective, and not infringe nearly as much on the beautiful ecosystem we have here.

The future will be in energy efficiency, but this is not efficient.  Not only is there an obviously huge waste of energy in this proposed concept, but energy is also wasted as soon as it enters the grid.  There are much better solutions to solving our energy challenges, so please think about long term effects of this project. 

We love this area and are deeply invested in taking care of it for future generations.
Let us work together for safer sustainable energy.
Sarah

Michael Rosenthal, Phoenicia, NY.
I write to protest in the strongest possible terms the interest by Premium Energy  Holding LLC in the Ashoka Pumped Storage Project. It is a truly terrible idea which no one supports. It will destroy our homes, cause needless environmental destruction, seriously affect the quality of New York City’s drinking water. And all for a minimal power gain. Maximum destruction of people’s lives, water quality, wildlife and environment for a minimal power gain makes absolutely no sense. Please do not permit this company to go ahead. It is unfair to the human beings and animals who live happily here.
Thank you, 
Michael Rosenthal

John Boston, Chichester, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

At a time where our most recent Covid-19 pandemic paralyzed so much of our country, we have recently found a long overdue interest in people wanting to move to our remote area. If this proposal is not stopped in its tracks this will quickly derail any new interest for relocation or property values.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

John C Boston

R Benaducci, Olivebridge, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Rita Benaducci

Maret Panzenbeck, Windham, NY.
I am writing this comment in response to docket P-15056. 

I am a resident of  Ashland, NY and have enjoyed the beauty of New York State's Catskill Park since my father and I hiked here when I was a boy sixty years ago.

I strongly request that FERC deny a preliminary permit to Premium Energy Holdings, LLC for the proposed Ashokan Pumped Storage Project.  

The proposed project is an “open loop system” and thus not kind of innovation the Department of Energy is looking for. The proposed system will not create new energy but rather require a net energy expenditure, i.e. more energy will be required to operate the system than the system will produce.  As an open loop system the project will interfere with New York City water supply at the Ashokan reservoir. 

The proposed project will require extensive construction and disruption to areas within the New York State Catskill Park, an area that is protected by the NYS constitution.  The proposed project will likely require an amendment to the NYS constitution. Further, the proposed sites in the Catskills are on Status 1 land.  The Department of Energy has said that Status 1 or 2 must be avoided for development.  

The three proposed areas for the “upper reservoir” are all areas used for access to hiking trailheads used by thousands of state resident and out of state tourist who come to the Catskill area yearly because of the natural beauty and challenging hiking trails.  Also, these areas have immense historical value on a national scale.

The project proposed by Premium Energy Holdings, LLC is extremely ill-conceived for the reasons stated above. In my opinion it is akin to proposing such a project in the middle of Yosemite National Park, perhaps something this California company can understand.  In my wildest dreams I have never imagined having to defend the heart of  NY's Catskill Park against a proposal of this nature.  It is unthinkable and will be widely opposed by the residents of NYS.  In my opinion the public outcry will likely be massive.  Although I understand the need for clean energy sources and fully support the goals of  FERC this project clearly is not of the type sought by the DOE.  I therefore respectfully ask that FERC deny Premium Energy Holdings this permit.

Sabina D. Tannenbaum, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Our house is likely the oldest house in Woodland Valley and has been in the family since 1945.  It will soon be in the hands of the 3rd generation.  The house already consumes little energy since we had the whole house insulated.  We are considering installing solar panels so that we would become net users.
While there’s no doubt that pumped storage and new hydroelectric projects also help offset our country’s need for fossil fuel, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing for the country by continuing to protect this irreplaceable environment and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sabina D. Tannenbaum
848 Woodland Valley Road, Phoenicia, NY 12464 (summer)
385 E Gowen Avenue, Philadelphia, PA 19119 (3 seasons)

Paul Fusco, Glenford, NY.
As a resident of Glenford and an avid fly fisherman, I oppose this project. I am a strong believer in renewable energy but after my own research this project will do more harm to the Ashokan watershed than good. I respectfully voice my disapproval and I ask you don't consider this proposal. Thanks

Jenny, Astoria, NY.
Hi,
I am a New York State resident and I care about the Catskill Forest Preserve that this proposed Dam would effect. I do not want to see this beautiful spot of nature modified or changed by any company looking to build a dam. 
It would change the area ecological systems and displace many living creatures. The plants and wildlife that is there now, would be changed forever if this dam is created. I do not agree to this.
There are other methods to create energy, why not use those alternatives rather than modifying the Catskills.

Galina Rodionov, Reston, VA.
I am against this project, it will bring a havoc on both aquatic and land habitats, it will affect water.My mother lives in NY and I have many friends who live there. Pleas stop this project.
 Galina Rodionov

Sandra Au, West Shokan, NY.
Dear Federal Energy Regulatory Commission, 


My partner and I have been living on the banks of the Maltby Hallow Creek in the middle of the Catskill Watershed (NYC's drinking water source) on a dead end road next to miles of FOREVER WILD protected STATUS 1 land for the past year.

We are part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. 


This project raises major environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. This is unspoiled land and not an appropriate site for this project. 


It is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to this community and raises our concern over Premium Energies practices. 



A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  


All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Yet, this is what is being proposed.

 

The Protected Three Birds Orchid currently live at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.” 



The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. Not to mention that it is the current habitat for Black Bears, Eagles, Mink, Egrets, Owls, Bobcats, Beavers and many other wildlife species which would be greatly impacted by the plan.



In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and Status 1 protected land. 

Please deny this permit based on these essential points, and request that they look for some other non threatening site for their work. 


Thank you for your time,  

Sincerely,

Sandra Au

Jennifer Charles, Brooklyn, NY.
I am writing to urgently press you to deny this permit for the pump plant here.
This is all protected land and wildlife. And the proposed plan would threaten and destroy many species that call this area home. There are so many other suitable barren areas where such a project could happen but please not here. As an environmental activist and amateur botanist, I am deeply disturbed that this is even being proposed here.
Thanks for your mindful consideration,
Jennifer Charles

Ina Kozel, Lanesville, NY.
		Dear Sirs.

	 I am a supporter of  renewable energy projects, however the Catskill locations proposed are untenable.  As a 25 year resident of Lanesville NY, I would like to state my strong opposition to the granting of a preliminary permit to Premium Energy Holdings.  All the local municipalities are strongly opposed to this project.  Given the environmental and economic impact and political and legal hurdles to overcome,  this project should be stopped  before further investments make it more difficult to halt.

	The proposed sites are within the Catskill Forest Preserve, which according to the NYS constitution “ shall be forever kept wild forest”. Changing that would require a constitutional amendment. The original desire to protect the catskill’s  precious land resource and should not be altered.  All the proposed sites fall within the Status 1 designation under the USGS Gap Analysis Program, which voids development according to the Department of Energy’s “Hydropower Vision”. The streams are already fragile and any further development threatens the local ecology and fauna. The proposal by Premium Energy classifies the project as a closed loop system. This is misleading at best and deceitful at worst. The project is an add- on system with a much stronger environmental impact.  The affect on the existing reservoir could be extremely detrimental. 

	The project would adversely affect the streams and waterways by increasing turbidity.  The streams are already fragile and any further development threatens the local ecology and fauna.  Recreational fishing is a prime attraction for this area and helps the local economy flourish. The project jeopardizes trout breeding grounds and falls within the  “ Audubon’s Catskill Peak Important Bird Area”. We cannot afford to threaten these resources. The turbidity also puts at risk the quality of the drinking water that serves 9 million residents of NYC

	The proposed site intersecting Route 214 in Lanesville is a designated “scenic byway” and a primary thoroughfare connecting difficult to access portions of the mountains.  Disrupting or voiding this passage would increase travel times and adversely affect the tourism and commercial economy of the region.  The ski areas of Hunter and Windham would have access cut in half.  

		This proposal will do more damage than good.  Please stop it.

		Ina Kozel

Anatoly Y Rodionov, Reston, VA.
I sincerely believe that ruin ecosystem is not what we all need, even if it is covered by sweet words.
Benefits of this project even theoretically can not pay back for the terrible losses of nature it will cause.

K.A. Risio-Smith, West Shokan, NY.
I do agree with the concept of renewable energy,  but not at the expense of the integrity of a century old dam  and the ecological upheaval of the Catskill Park Watershed. Everything about the project is too evasive for this fragile location.  Premium Energy's proposal for the West Shokan hydro-electric pump station may look good on paper, but not in reality. Thank you for considering my concern.

Sydney, Tarrytown, NY.
I urge the halt of the proposed hydroelectric facility from continuing activities. It will destroy land and resources of multiple communities in the following ways:
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville, which boost local economies.
The natural environment of the Catskills provides stability and opportunity for so many, especially during hard times such as these. It would be shameful to destroy the remaining outdoor spaces we have.

Steven Parisio, Olivebridge, NY.
FERC Docket P-15056
Ashokan Pumped Storage Project

I oppose this project based on the following concerns:

1. The project would, regardless of which alternative is selected for the upper reservoir, pose a significant threat to the nation’s largest municipal water system.  Energy is an important societal need for which trade-offs might be justified, but it is not more important or more basic than clean drinking water.  

The Ashokan reservoir and its drainage basin are a major part of the world’s largest unfiltered water supply which provides drinking water to over 9 million people.  This unique resource is one of only five unfiltered water supplies serving a major city in the U.S.  By protecting the watershed from development and contamination sources, the City avoids spending $10 billion to build a massive filtration plant and $100 million annually to operate such a plant.  The Ashokan Reservoir provides 40 percent of the City’s drinking water.

Turbidity and suspended sediment have been and continue to be the most serious threat to water quality in the Ashokan Reservoir.  This concern is described in detail in a 2016 report by the US Geological Survey.  All three of the upper reservoir alternatives involve extensive clearing of vegetation, disturbance of soils and construction activities which would take place in streams tributary to the reservoir and would cut across areas with steep slopes and soils that are highly susceptible to erosion.  The upper Esopus watershed was occupied by a pro-glacial lake during the last ice age and the silt and clay deposits originating from that glacial lake represent a significant source of turbidity which can be released by even minor disturbances within the stream channel. 

2. Two of the alternatives would violate the New York State Constitution by encroaching upon protected State lands and forests.  Article XIV of the New York State Constitution, adopted in 1894, declares that State-owned land in the Adirondack and Catskill State Parks shall remain “forever wild”.  This provision in New York’s constitution represents the strongest and most closely guarded commitment to wilderness preservation in the nation and has withstood development pressures and legal challenges for well over 100 years. Since its inception, the Forest Preserve has generated multi-generational and bipartisan support for the protection of wildlands, including a vast array of unique ecosystems, and abundant outdoor recreational opportunities. The proposal to site an energy project in a manner that encroaches on New York State Forest Preserve lands and forests flies in the face of the State Constitution and the strongly held conviction of New Yorkers that this unique natural resource and all of its societal benefits should be protected and preserved for future generations. 

3. The undeveloped and unspoiled natural beauty of the Catskills in conjunction with is proximity to New York City and other major population centers has led to the development of a $1.6 billion tourism industry supporting close to 20,000 jobs.  Disruptions caused by this project would pose direct economic threats to the regional economy.  For example, one alternative would destroy the NYSDEC’s Woodland Valley Campground which has been in operation since 1902 and is one of the State’s oldest and most popular campgrounds.  Another alternative would eliminate Route 214 which is only one of only two transportation corridors allowing vehicle traffic through the high central escarpment of the Catskills.  Blocking this route would greatly reduce access to the NYSDEC’s Devil’s Tombstone Campground as well the Hunter and Windham ski centers.  

4. The federal Department of Energy’s Office of Legacy Management defines environmental justice as “the fair treatment and meaningful involvement of all people, regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies” and defines “fair treatment” as meaning that “no population bears a disproportionate share of negative environmental consequences resulting from industrial, municipal, and commercial  operations or from the execution of federal, state, and local laws; regulations; and policies”. One of the proposed alternatives targets a community in the Town of Olive which has a history of forced sacrifice due to the condemnation of homes and businesses by New York City for the original construction of the Ashokan Reservoir. To this day, the Town lacks a physical town center and the impacts of the reservoir are still deeply felt.  To repeat this process, targeting the same community by flooding residential properties and access roads in the Valley of Maltby Hollow Brook (Moonhaw Rd and Shultis Lane) is unfair and demonstrates a lack of understanding or concern regarding the history of the community in which the project is proposed.

Francesca Esmay, Lanesville, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While I recognize that pumped storage and new hydroelectric projects will play a necessary role in the transition to renewable energy, the Catskills Forest Preserve is not the location to establish such a facility; and its pristinely protected forests, streams, and wildlife must not be compromised in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands […] and they shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (an extremely rare asset within our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. If this feasibility study is granted it will set a terrible and dangerous precedent for protected lands across the country.  

This proposed project represents clear risks to the state of preservation within the Catskills Preserve.  Moreover, there would be further environmental damage due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats given the repeated and rapid fluctuations in water levels.  In addition to causing devastating effects to wildlife habitats, this also alters sediment accumulations in connected tributaries, which has a cascading consequences.  The Ashokan Pumped Storage Project would ultimately impact sediment conditions within the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Premium Energy’s proposal is not a closed-loop system as they falsely claim—it is in fact an “add-on,” and the water fluctuations would no doubt dramatically increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices have dramatically spiked during the COVID-19 pandemic.  

Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Lastly, Premium Energy’s Ashokan Pumped Storage Project does not even meet the standards for the kind of innovation that the Department of Energy wants to see for these types of projects. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Francesca Esmay

Justin Lamarche, NEW PALTZ, NY.
I am extremely concerned that this project will not only harm the local community and economy, but do irreparable damage to the state protected forest and unique ecosystem that is the Catskill mountains. This project seems incredibly invasive and with seemingly no input from local authorities prior to the proposal, it feels like a slap in the face to all of us who call these mountains home. Please do not move forward with this application and keep the Catskills as they are. Thank you.

Thomas Smith, West Shokan, NY.
It would be shameful to remove a 17 mile long swath of wildlife habitat for construction of a transmission line. Renewable energy has it's place, but not in the Catskill Park. I object to Premium Energy Holdings conception of a hydro plant.

Barbara klippert, New York, NY.
April, 9, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to object to the proposal by Premium Energy Holdings to build a hydroelectric power plant in the New York catskill area and strongly request that FERC  decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 
Although pumped storage and new hydroelectric projects have their place in  renewable energy, a part of the  Catskill Forest Preserve should not be destroyed as a result. Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of very rare continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats in the country.
The project itself will cause environmental destruction to Ashokan watershed and its tributaries. Pumped storage is wrecks nearby stream ecology, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. It affects the sediment in connected tributaries, which has a cumulative effect. The Ashokan Pumped Storage Project would ultimately affect the sediment amounts in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s drinking water supply, serving 1 billion gallons of water a day to almost 10 million people.  
Also, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations will adversely affect the quality of water within the Ashokan and its watershed. Taking all this into account, it would be completely inappropriate to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represented over $1.7 billion of investments in the last 30 years.  Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” even though it is not, and therefore is not eligible for such approval. 
Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely yours, Barbara Klippert

Gillian Luongo, Hunter, NY.
To the Federal Energy  Regulatory Commission,

I am writing to you in opposition of the proposal by Premium Energy Holdings, to construct a massive new reservoir, dam, and underground power station in the Catskill region.

While I am a supporter of efforts to move towards renewable energy, this proposal totally disregards the deep history and importance of Catskills region to local communities and visitors alike, not to mention ignoring the protections stated in the NYS Constitution. 

The Catskills Forest Preserve was created in 1885, and the NYS Constitution explicitly states that the lands “shall be forever kept as wild forest lands, [and] shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

The forests around the proposed sites rank among the top 1% of forest habitats region-wide, and are considered Status 2 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

It would be tragic if Energy Holdings Premium, a California company, was given permission to come to NY and trample on our state Constitution and protections. 

Additionally, with the recent pandemic effecting our way of life, many New York City residents and others from surrounding areas, have newly discovered the Catskills in searching out places to enjoy safely outdoors. This new-found tourism has been a boost to local businesses, hotels, restaurants, and activity companies. This has truly been a silver lining to a sad and difficult time, and a project like this will only damage that positive revival of tourism and halt its growth in its tracks. 

Finally, the devastation a project like this poses to our fragile eco-system would be tragic. Wildlife, fish, birds, bald eagles and the very water system that New York City relies on would be impacted negatively when, again, per the Constitution, all are protected.

I urge the FERC to say NO to this proposal. Our land is protected and must stay that way.

Sincerely,

Gillian Luongo

Dawn S Peters, PHOENICIA, NY.
Dawn Peters, Chichester, NY

As a resident of both Chichester, NY in Ulster County, and Riverdale, NY in the Bronx, I am writing to voice my opposition to granting a preliminary permit to Premium Energy Holdings. 

I am unequivocally opposed to the profoundly flawed proposal by Premium Energy to build a hydroelectric power plant in New York's Catskill Forest Preserve. 

I urge FERC to decline Premium's request for a preliminary permit for the Ashokan Pumped Storage Project, P-15056. 

Premium Energy does not provide the kind of innovation sought by the Department of Energy, given that its proposal is deficient and misleading. Premium Energy's claim it will build a closed-loop system is false. A closer study indicates PREMIUM'S PROPOSAL IS AN ADD-ON PROJECT. The upper reservoir is added to an already existing lower reservoir connected to a natural water source - the upper Ashokan Reservoir. As you know, such an add-on system's operational impact on the environment and aquatic life would be significant and damaging.

The proposed Stoney Clove pumped storage upper reservoir, located in Lanesville, would be approximately 1.50 miles north of my home on Stoney Clove Creek streamside property. Built by my grandmother in 1940, this home has been in our family for eighty-one years and four generations. The CEMENT BARRIER would be about 2,600 feet in length and 212 feet high. EFFECTIVELY CHOKING the Stoney Clove Creek and subjecting its streambank to rapid fluctuations of water, altering the streambank and aquatic habitat of any plant or animal living in this vital cold water stream.

Scientists, engineers, surveyors, watershed maintainers, and other professionals in the upstate watershed are already concerned that global warming produces uncertainty for the Ashokan Reservoir's sustainability due to evaporation, heat events, and decreasing snowpack. According to NYC's Department of Environmental Protection (DEP), the city's water department, the Ashokan Reservoir, currently meets NYC's needs by providing 40% of NYC's water supply. Considering the uncertainties of climate change, NO FEASIBILITY STUDY NOR COMPUTER MODELLING can predict the consequences of a construction site and eventual dam, tunnels, high tension wires, turbines, etc., on the delicate balance of nature and the health of the Catskill Forest Preserve and NYC's drinking water. 

Forests act as a filter. This natural filter, the Catskill Forest Preserve, keeps NYC's unfiltered drinking water system clean by preventing the runoff of chemicals and soil into waterways and eventually the upper Ashokan Reservoir, which already holds 100 years of silt. The proposed pumped storage project would undoubtedly increase turbidity in the Ashokan Reservoir. Turbidity is already a big issue for NYC's DEP. Locally, constructing the upper reservoir in Lanesville would surely impact the area's water table, individual wells, MY WELL, stream turbidity, and water temperature. Altering the sediment regime in Stoney Clove Creek, a tributary of the Esopus, will transform the sediment regime in the Esopus. The Esopus, a source of life and sustenance, would inevitably be forever changed, destroying one of the Catskill's most vital trout waters and NYC water supply. 

While I support our nation's transition to renewable energy and recognize pumped storage as a critical component of our clean energy future, I believe the Catskills region is not the right location for such a project. The right project in the wrong place. This project would primarily impact state land within the Blue Line of the Catskills State Park, designated as forever wild. Pristinely preserved state forest land, streams, flora, fauna, and the New York City water supply are at risk. Much of the harm would be unlawful and in violation of the New York State Constitution. 

The company falsely states that the project will take place outside the protected Catskills Preserve boundaries. A closer study indicates that its proposed sites are located squarely within the Catskills Forest Preserve (established 1885). This area is covered under Article XIV of the New York State Constitution, which deems the lands shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any change in the management of State Forest Preserves has to be passed by constitutional amendment, which involves both state legislative approval and a public referendum. Otherwise, it is unlawful and unconstitutional. Obtaining legislation approval and a public referendum will be time-consuming and costly for Premium and New York State. 

Another significant fact to consider is that, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. According to the US Department of Energy's own Hydropower Vision report, areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.

I believe the misleading nature of Premium Energy's proposal, DoE's mandate to avoid Status 1 land, and especially the fragility and protected status of the Catskills Forest Preserve are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit. 

Respectfully submitted,
Dawn Peters

Caryn Carter, Olivebridge, NY.







Caryn Carter 
427 Upper Samsonville Rd.
Olivebridge, NY 12461


Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the ill-conceived proposal by Premium Energy Holdings, LLC to build a hydroelectric power plant in New York’s famed Catskills. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the pristinely preserved forests, streams, and wildlife of the Catskill Mountains. It would risk the purity of the water supply in the area, and subsequently, compromise New York City’s drinking water. Without question, it be highly disruptive to our local communities.

Premium Energy’s remarkably flawed Ashokan Pumped Storage Project does not even represent the kind of innovation that the Department of Energy is calling for in the “Hydropower Vision” plan. Premium falsely claims this project to be “closed-loop” rather than what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water, as in the case, for our nation’s largest city. Premium knows that closed-loop pumped storage projects are eligible for streamlined FERC approval because they have smaller environmental impacts than those that make use of existing watersheds. How can we possibly trust a company that would lie in their proposal simply for the advantage of being fast-tracked for FERC approval?

It is vital that our country transition to renewable energy, however the uniquely protected Catskill Forest Preserve, established in 1885, must not be sacrificed in the process. Under Article XIV of the New York State Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Unlike most of our increasingly fragmented environment, the Preserve currently contains 700,000 acres of continuous wildlife habitat. According to the New York State Forest Condition Index, the forest around the proposed sites ranks among the top 1% of forest habitats region-wide. The lands are considered Status 2 under USGS “Gap Analysis Program” which provides that development should be avoided. To destroy this sacred and wonderfully preserved land would set a doomed precedent for protected lands across the United States.

If the construction goes forward, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. As Premium Energy’s proposal utilizes an “add-on” system, the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. This can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir. 

In addition to affecting the wildlife, the Ashokan Reservoir supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. As the largest unfiltered water supply in the nation, it would be reckless to allow a project to proceed that would threaten such a valuable asset.

Premium Energy is a California company that has not considered how its proposal would damage local communities in New York. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands of people from their homesteads when the Ashokan was constructed 100 years ago. This century-old violation has left multigenerational scarring that still lingers fresh today. All residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing in the area, which is in limited supply and has escalated in value, particularly in the past few years as the area has become a coveted escape for NYC residents.

Beyond the problem of community displacement, there is also the proposed project’s affect on the Catskills’ growing tourism economy, which generated 17% of employment in 2019, with 43% of that represented by Ulster County where the proposed project is located. Tourism generates $1.6 billion for the region, supporting roughly 20,000 jobs that are at stake. Premium Energy’s project, which includes flooding 200 acres of land, erecting a 300 foot high dam, and stretching 230V high-tension transmission lines for nearly 13 miles, would dramatically impact the area’s natural beauty. It would create limitations to hiking, fishing, and other forms of recreation in the Catskills, like winter skiing and summer concerts at Hunter Mountain. World-renowned arts and cultural events in the towns of Olive, Woodstock, Shandaken, Hunter and Tannersville would all be adversely effected. Ultimately, Premium Energy’s financial goals would have dire consequences for businesses in Ulster County and beyond.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not threaten incredibly important natural resources, destroy protected wilderness and wildlife habitats, and displace vulnerable communities in our beloved Catskills. 

Please deny

Mickey & Mo Winograd, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Never mind that our home at an elevation of 1192 ft. would be completely submerged and destroyed. This has been our family home for 45 yrs. with a lifetime of memories for several generations. 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Mickey & Mo Winograd

Jim Sofranko, West Shokan, NY.
Dear Secretary Bose,

The Ashokan Pumped Storage application (P-15056) by Premium Energy Holdings LLC for a Preliminary Permit must be thoughtfully reconsidered by FERC. The application is fraught with misinformation and a basic lack of understanding of the very many legal obstacles the proposal presents. It is my contention the applicant must do their due diligence in providing a basic understanding and knowledge of the locations presented in their proposals before FERC to avoid unnecessary consideration. 

The lands described in the application are New York State forests legally and environmentally protected as forever wild in Article XlV of the NYS Constitution. The lands described are also all within the Catskill Forest Preserve with additional legal and environmental protections granted by New York State. The environmental protection afforded these lands is due to their uniqueness and widely documented ecological importance.

Additional lands, facilities, and water described in the application are under the control of the NYC Department of Environmental Protection. These lands, facilities and water resources are environmentally and legally protected by New York City, New York State, and the United States Environmental Protection Agency. The EPA Safe Drinking Water Act Amendments of 1986 and the 1997 Filtration Avoidance Determination and Memorandum of Understanding between NYC and the Coalition of Watershed Towns include specific environmental protections and install water protection programs necessary to maintain a safe drinking water supply for the 9 million residents of the City of New York. 

The use the Ashokan Reservoir, in what is erroneously described in the application as a "closed loop" pumped storage project, will dramatically increase water turbidity in the NYC water system. The Ashokan Reservoir was specifically designed in recognition of the natural sediment and turbidity problem in its tributaries. It is why the reservoir has an upper basin to contain sediment and turbidity. Using the upper basin of the reservoir for a pumped storage project will disturb over 100 years of sediment settled at its bottom. Increased turbidity compromises the ability of NYC to deliver safe drinking water. 

Any disturbance of the tributary streams and steep sloops of the Catskill Mountains additionally increases sediment and turbidity in the water system. The streams, steep slopes, and unstable soils have been identified and mapped by the Ashokan Watershed Stream Management Program. Ongoing erosion mitigation programs have been designed to help avoid sediment and turbidity in the streams. Sediment can transport pathogens and interfere with effectiveness of water filtration and disinfection. The problems of sediment and turbidity have been long recognized in the Catskill Watershed and any increase in turbidity will negatively affect the ability of NYC to provide clean and safe drinking water to its residents. 

This application has caused much distress to the residents of our towns. Plans have been put on hold with the future uncertain and deeply concerning all because of the deeply flawed and under-researched application before you. I respectfully request ask FERC to deny the application based on all of the above considerations.

Thank you.

Jim Sofranko
West Shokan, NY

Eileen M Gumport, New York, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the Premium Energy Holdings proposal to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The Catskill Forest Preserve is protected by New York state’s constitution to be forever kept as a wild forest and no part of it can be transferred to another entity, whether public or private. An hydroelectric plant would be devastating for the Preserve and its wildlife, the surrounding community, and for New York City’s water system which has been centuries in the making and is considered an example to others around the nation.

As a New Yorker who takes great pride in our water system and as a visitor to this area for its well-known bird-watching opportunities, I implore you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, 
Eileen Gumport

Shea Fink, Hunter, NY.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Dette Flies, Livingston Manor, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

No. No. No. Keep the Catskills wild!

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Dette Flies

Mozelle Dayan, Hicksville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Mozelle Dayan

GIANROBERT C. S. WOOTTON, PHOENICIA, NY.


To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

From an environmental and ecological perspective this proposed project would appear to be very ill conceived. The pumped storage project as envisioned would provide less energy than that expended to produce it i.e. a net deficit. Furthermore it is implied that this will alleviate demands on the grid at peak times. In the more than 20 years I have lived here we have never suffered "blackouts" or "brownouts" due to excess demands on the electrical grid. The power cuts we do have are due to downed lines from trees. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

G.Wootton

Kevin Young, Chichester, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Kevin Young

John Buckler Seiberling, Washington, DC.
                                                                
           
                                                               April 10, 2021


To:								                             
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000.

Dear Ms. Bose:

Regarding the proposal of Premium Energy Holding LLC (Premium Energy) to
build a hydroelectric power plant in Ulster County, New York, I am writing
to advocate the denial, by FERC, of Premium Energy’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

As one with family ties to the Catskill Forest Preserve region and who has enjoyed the Preserve’s natural lands in repeated visits to the area over the years, I have taken assurance in this unique area’s protected status under Article XIV of the New York State Constitution, which provides that the Preserve lands “shall be forever kept as wild forest lands” and that they “shall not be leased, sold, or exchanged or be taken by any corporation, public or private.”  It is exactly because the unviolated natural condition of these lands was and is deemed sacrosanct that to compromise it the state has required a constitutional amendment.   

The 700,000 acres of the Preserve make up a continuous wildlife habitat of a size that is becoming increasingly rare in New York State as the state’s forests become more and more fragmented.  Because of the unique support to biodiversity afforded, critically, by the scale of the unbroken forest, the lands within the preserve are ranked within the top one percent of forest habitats region-wide according to the New York State Forest Condition Index.  Native animals ranging from black bears to scarlet tanagers require such extensive unbroken forest for their species to remain viable in the area. The impinging on the perimeter of the Preserve by the construction of an upper reservoir would amount to the very erosion of the Preserve’s integrity that the Article XIV language was written to deter.

I would further emphasize that as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS “Gap Analysis Program.”  According to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

I urge that the Commission respect both the intent of the creators of the Catskill Forest Preserve and existing Federal policy and deny Premium Energy’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely yours,
John Buckler Seiberling

Robert Selkowitz, Shokan, NY.
April 10, 2021

Robert Selkowitz
3024 State Route 28
Shokan, NY 12481

Personal Comments on Docket # P-15056

I am an artist and cultural entrepreneur whose career, over more than 40 years, has focused on the natural beauty and resources of the Catskill Park and the Catskill Watershed. I feel it is a responsibility and to live in this protected area, with its special mix of public and private lands.

The proposed project would destroy one of the major tributaries of the Esopus Creek, whichever one of the three sites chosen. The Esopus Creek is the principle source for the Ashokan Reservoir, which provides 40% of the fresh water for New York City. I know this will be emphasized in many comments opposing this dangerous proposal.

Indeed, the proposal is so ignorant of the special status of this area that it is laughable for it to be considered. It has served the purpose of uniting many residents and organizations in opposition and I am astonished the people behind this scheme allowed their resources to be committed to such a doomed project.

The devastation any one of these three proposed dams and retaining ponds would wreck on the creeks, critical roads and surrounds lands is opposed to the mandate of protection in the New York State constitution protecting the Catskill Park and Watershed.

I support a rejection of this pumped storage hydro proposal. Do not inflict years of futile aggravation on our communities by letting this impractical and dangerous project linger with life. Reject it now! Thank you.

Respectfully,

Robert Selkowitz

Kathleen R Anderson, Ballston Lake, NY.
A proposed hydroelectric facility in the Catskill's Ashokan Reservoir would irreversibly damage areas of the Catskill Forest Preserve, threaten the experience of hikers and nature enthusiasts, endanger the ecological sustainability of the Forest Preserve and threaten the quality of New York City's water supply!
As a New York State resident, as a mother and grandmother, as a hiker, as someone who loves the Catskills, as a person who drinks NYC tap water, I am very concerned.

Elizabeth Gumport, Brooklyn, NY.

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in regard to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I strongly encourage FERC to reject their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. To grant it would not only violate the New York State Constitution but would cause extreme damage to the environment, disrupt local communities, and compromise the safety and purity of New York City’s drinking water.

As stated above, the proposal clearly violates the New York State Constitution. Article XIV guarantees that the Catskill Forest Preserve “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. To destroy this sacred and wonderfully preserved land would be an ethical and environmental abomination and would set a horrific precedent for protected lands across the country.

Once construction is complete, there would be additional environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. This can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Of crucial importance is the fact that Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

I urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Elizabeth Gumport

Amanda Lees, Athens, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation.I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

When we make decisions of this magnitude, even with the best intentions of improving our future, we must always ask ourselves “at what cost?”. Here, I think the cost is too great. I think it negates the intended improvements.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Amanda Lees

Marilyn Manning, Phoenicia, NY.
I'M AGAINST IT!

Peter Laciano, New Providence, NJ.
I am writing to express my strong opposition toward Docket P-15056, a proposed dam and pumped storage project. This project lies within the Catskills Forest Preserve, which is protected very explicitly in the NY State Constitution. I am a frequent user of the forest preserve, especially the area around the Ashokan Reservoir, as it lies most proximal to the NYC metro area. This proposed development would cause significant harm to hiking, biking, fishing, and sightseeing in the area. These uses have only become only more important and popular since the beginning of the pandemic, and they provide a critical source of economic opportunity to the local area. I am urging federal regulators to block this proposal as both unconstititional and excessively harmful to the 
Catskill economy, recreational experience, and ecology.

Nicole Cawley, SAUGERTIES, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Thank you,
Nicole Cawley
56 Highwoods Road
Saugerties, NY  12477

Beyl Peter, Mount Tremper, NY.
To FERC,

What is being constructed is a machine. It is extremely costly to build this machine. It will occupy large amounts of land. What does this machine do? It pumps water to a higher elevation using electricity. Is the water needed at the higher elevation? 

NO!!

The machine does produce electricity from a turbine, but it consumes all the electricity it produces and needs more to operate. Overall it is not a generator.

Why build such a machine if there is no need for water at a higher elevation? 

It seems to me that this is not about producing clean energy. It is about a company that wants to make money using land and resources located in the Catskill Mountains. It is not beneficial to local residents who will lose their homes and property. 

I will not discuss the negative environmental impact this project will have. I am sure there are plenty other letters you will receive which will do this. 

People come to the Catskills to enjoy undisturbed nature. We should try and keep it that way. Unfortunately it has become a desirable place to make money using the natural resources in the area.
 
It is a losing proposition. Wasteful time and money will be spent. It consumes more energy than it produces.

For these reasons I adamantly oppose this project.

Sincerely,
Peter Beyl
Mt. Tremper, NY

katharine s holmes, New Haven, CT.
Katharine Holmes
115 Fountain St. #1
New Haven, CT 06515
katharineholmes@gmail.com
603-851-0626

April 9, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission
88 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

With dismay -- I write in response to the proposal by Premium Energy Holdings of California to build
a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s
Catskill Mountains. This would include a reservoir of up to 300 acres at one of three sites (to be
chosen) and a tunnel to bring the water to the east shore of the upper basin of the Ashokan
Reservoir. The three sites are Chichester, Woodland Valley, and the Moonhaw valley in the hamlet of West Shokan, Town of Olive. My comments are confined to the Moonhaw and adjacent regions of
West Shokan.
Moonhaw is a settled area of some 50 homes, valued at up to $2,500,000 apiece. A 300-acre
reservoir would destroy the community -- and the tunnel leading from it would disrupt another 50
homes in the region between Moonhaw and the proposed power plant.
Furthermore the upper reaches of the Moonhaw valley are in a designated Wilderness
Area of the New York State Forest Preserve and protected from development of any kind by
the "forever wild" clause of the New York State Constitution.
Such wholesale destruction of a major portion of West Shokan cannot be allowed. I urge you to
recommend that Premium Energy's proposal be rejected.

Respectfully,
Katharine Holmes

Cathy Capozzi, Kingston, NY.
101 Oneil St 

Apt 1 

Kingston, NY 12401 

Cathy.capozzi1993@gmail.com  

docket number P-15056-000 

 

April 8, 2021 

 

Dear Sir or Madam: 

 

It has come to my attention, and the attention of many others, that Premium Energy Holdings has made a proposal to build a reservoir, dam, and underground power station to harness the Ashokan Reservoir and its watershed for hydroelectric power. This is a mistake. There are a multitude of reasons why this is the wrong course of action including, but not limited to: infringement on religious freedoms, discrimination against Asian Americans, ignoring of Constitutional rights, pollution of New York City drinking water, increased unemployment due to destruction of homes and businesses, desecration and destruction of countless trails and land used for outdoor activities, all of which is vital to the region’s world-renown tourism business and to the region’s local economy. By creating this power station, Premium Energy Holdings is destroying much, much more than they are building. 

To start it is important to make known that a Buddhist monastery sits in Mt Tremper, NY at the base of the Catskill mountains near where this power station is meant to be erected. Not only is this an important site for outsiders making their pilgrimages to a quiet place where they can practice their beliefs, it is also a place where the Buddhist Mountains and Rivers Order calls home and where this Asian practice is carried out day after day. At this monastery, followers of Buddha perform meditation exercises and other Buddhist practices in a place that is conducive to peace and the tranquility needed to perform such practices. A power plant would surely cause enough noise to disrupt these sacred practices. Also, this Order is peacefully protesting the daily discrimination against Asians along with many others during the current StopAsianHate movement. To disrupt this monastery is to disrupt social harmony and create further social unrest and distress. 

With such enormous problems as social unrest and a potentially failing economy, it can easily be seen why the beautiful Catskills Preserve, a land protected under the US Constitution, should be left intact for all to enjoy. 

 

Thank you for your time, 

Catherine Capozzi

Emily Darrow, Hurley, NY.
In reference to Premium Energy Holdings LLC Preliminary Permit application for the Ashokan Pumped Storage Project, docket P-15056,  I’d like to express my deepest concerns about the effect it will have on a very sensitive environment.

As a native to Ulster County, with one side of my family having their farm covered by the Ashokan Reservoir and the other having an engineer who worked to build it, this area is one I’ve known my whole life.

From all that I’ve read about this project it’s incredibly ill-conceived. While I truly believe in renewable energy and the need for more options — this project is not the correct one for the area.

Please hear the voices of the residents of this area and all who depend on the drinking water from the Ashokan and the Esopus.

Thank you.
Emily Darrow
845-399-2129
Em.darrow@me.com

John Draper, Brooklyn, NY.
My family and I have been a regular visitor to Woodland Valley, located in Phoenicia, NY (Town of Shandaken, Ulster County) for 22 years.  We have a number of close friends who live there, and our daughter has worked in a Day School for two summers in the past few years. We are considering buying a home in this area to live near our close friends and enjoy this community that has always felt like home. I understand that the area where we are seeking to live is surrounded by the Catskill Forest Preserve, a wilderness area protected by the NY State Constitution.

I am opposed to the granting of a preliminary permit to the California-based company Premium Energy Holdings (PEH) for its proposed project to build a pumped storage hydroelectric plant utilizing the Ashokan Reservoir (docket number P-15056). I understand that renewable forms of noncarbon energy production are essential to our country, but unfortunately the adverse effects of constructing this particular hydro-electric plant far outweigh the benefits. I hope you will consider not issuing a preliminary permit to PEH since its submitted proposal has many flaws.

After close examination of the PEH application proposal, I discovered that it includes inaccurate statements and misleading information. My opposition to the proposed project is for the following reasons:

The entire proposed project lies within (not near, as stated in its proposal) the pristine woodlands of the Catskill Forest Preserve, which has been protected by section 2.1 of the New York State Constitution since 1894.

Unlike the claim made in its proposal, PEH’s project is not a closed loop system but instead its open loop plan could cause many negative effects to the area environment and ecosystem.

New York City operates the Ashokan Reservoir (proposed to be used by PEH), the city’s drinking water supply under a Filtration Avoidance Determination (FAD) issued by the US Environmental Protection Administration. The proposed project would drastically raise the turbidity in the Ashokan Reservoir watershed, which would taint the water supply and undercut billions of dollars that NYC has invested in its water system. It is unlikely NYC would ever grant access to the Ashokan Reservoir without years of legal battles.
..
The woodlands in the Catskill Forest Preserve are home to numerous endangered species of wildlife, which would undoubtedly be adversely affected by the construction of the proposed project. Such endangered species include wild honeybees, which provide necessary pollination. The Catskill Forest Preserve is also one of the oldest fossil forests in the world and a major bird area including rare species.

Woodland Valley itself, which includes State-owned acreage of the Catskill Forest Preserve, is home to many bird and wildlife species, as well as such historical structures nestled in the forest as the Roxmor Inn (c. 1910); one of the oldest campgrounds in NYS; a private home frequented by naturalist John Burroughs; and the oldest downhill ski slope in NYS (no longer in operation but preserved with a historical marker). In addition, the Woodland and Esopus Creeks, which merge in Woodland Valley, is a prime trout breeding ground. Aspects of fly fishing were developed over the past century-plus on these creeks, which continue to attract anglers and hikers, both locally and as part of the thriving tourism in the area.

With so much private property located within close proximity of Woodland Valley Creek, and surrounded by the Catskill Forest Preserve, relocation of homes along the creek would be difficult if not impossible without amendment of the New York State Constitution.

Additionally, local and tourism traffic in the area would be severely disrupted by construction of the proposed tunnel system and dam, wreaking economic havoc on the affected hamlets, towns, and counties. Tourism provides millions of dollars and thousands of jobs to the local economy.


I urge the Federal Energy Regulatory Commission to deny Premium Energy Holdings the permit.

Dianna Brindle, PHOENICIA, NY.
Dear Secretary Bose,

As a resident of Woodland Valley, I object to Premium Energy's proposal, docket # P-15056-000, to build a pumped storage hydroelectric plant utilizing the Ashokan Reservoir as its lower reservoir. This proposal does not meet the FERC standard for granting a preliminary license. The permit application filed by Premium Energy should be rejected for its large number of mistakes, falsehoods and omissions.

Premium Energy states that this proposal is for a "closed-loop" project, making it eligible for streamlined FERC approval; however, the system Premium Energy describes is NOT a closed-loop system. It is an add-on project to the existing Ashokan reservoir, that is continuously connected to a naturally flowing water feature. The naturally flowing water feature that was originally dammed to construct the Ashokan Reservoir is Esopus Creek, which is not only an asset of high environmental value in the Catskills ecosystem, but is part of the New York City water supply, the largest unfiltered water supply in the
nation, and an infrastructure asset worth tens of billions of dollars to the city of New York. 

The New York State and New York City lands for the upper and lower reservoirs in the proposal are environmentally protected lands. Precedented legal protections have long been established for the entire watershed of NYC and NYS “Forever Wild” forests. It is unfeasible to pursue a project of this size and scale in such an environmentally fragile and legally protected area that contributes so much to the economy of our region. In addition, there are environmental legal barriers the applicant will likely face due to the project’s impact on rare and endangered species, and with the impoundment of streams containing trout habitats.

The Catskills Forest Preserve was created in 1885. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program. Areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.

The Catskills Water Supply provides 90% of NYC’s water, a water supply that provides 1 billion gallons a day to 9.5 million people. The Catskill Water Supply (40% of NYC’s water) comprises the Ashokan and Schoharie Reservoirs. The pumped storage project is likely to increase the turbidity in the Ashokan, which would decrease the quality of NYC drinking water. The quality of this water supply is governed by a regularly updated Filtration Avoidance Determination issued by the EPA.

Premium Energy’s proposed project would also hugely impact Catskills tourism, a $1.6 billion industry in the region, supporting roughly 20,000 jobs.

I respectfully request that FERC deny this preliminary license application.

Sincerely, 
Dianna Brindle

Quinn Holmes, New York city, NY.
Docket number P-15056-000

Dear Ms. Bose,
I hope this finds you well.
With dismay -- I write in response to the proposal by Premium Energy Holdings of California to build
a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s
Catskill Mountains. This would include a reservoir of up to 300 acres at one of three sites (to be
chosen) and a tunnel to bring the water to the east shore of the upper basin of the Ashokan
Reservoir. The three sites are Chichester, Woodland Valley, and the Moonhaw valley in the hamlet
of West Shokan, Town of Olive. My comments are confined to the Moonhaw and adjacent regions of
West Shokan.
Moonhaw is a settled area of some 50 homes, valued at up to $2,500,000 apiece. A 300-acre
reservoir would destroy the community -- and the tunnel leading from it would disrupt another 50
homes in the region between Moonhaw and the proposed power plant.
Furthermore the upper reaches of the Moonhaw valley are in a designated Wilderness
Area of the New York State Forest Preserve and protected from development of any kind by
the "forever wild" clause of the New York State Constitution.
Such wholesale destruction of a major portion of West Shokan cannot be allowed. I urge you to
recommend that Premium Energy's proposal be rejected.

Please strongly consider my points. Thank you.

Kindly,

Walker holmes, New york, NY.
February 21, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission 88 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000 Dear Ms. Bose,
With dismay -- I write in response to the proposal by Premium Energy Holdings of California to build a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s Catskill Mountains. This would include a reservoir of up to 300 acres at one of three sites (to be chosen) and a tunnel to bring the water to the east shore of the upper basin of the Ashokan Reservoir. The three sites are Chichester, Woodland Valley, and the Moonhaw valley in the hamlet of West Shokan, Town of Olive. My comments are confined to the Moonhaw and adjacent regions of West Shokan.
Moonhaw is a settled area of some 50 homes, valued at up to $2,500,000 apiece. A 300-acre reservoir would destroy the community -- and the tunnel leading from it would disrupt another 50 homes in the region between Moonhaw and the proposed power plant.
Furthermore the upper reaches of the Moonhaw valley are in a designated Wilderness Area of the New York State Forest Preserve and protected from development of any kind by the "forever wild" clause of the New York State Constitution.
Such wholesale destruction of a major portion of West Shokan cannot be allowed. I urge you to recommend that Premium Energy's proposal be rejected.
Respectfully,

Waked Holmes

Sally Smith-Raymond, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to comment on the proposed hydropower storage plant for preliminary permit for Premium Energy Holdings, LLC Ashokan PSP under P-15056.  My first impression of the propsal is what it lacked and how little they know about this area steeped in history, the ecological importance of the lands protected by NY State, the NY City Department of Protection, protecting the Ashokan reservoir which supplies 40% of the water to NYC, as well as private land owners and multiple conservation groups.  First and most glaringly obvious would be the forests around the proposed sites rank among the top 1% of forest habitats region-wide, and are considered Status 2 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

The fracture of the nearly 700,000 continuous acreage of the Catskill Preserve is at risk.  This Preserve is considered to be on of the most ecologically diverse in the northeast.  

Premium Energy proposes using NY State land which is currently protected as "forever wild" by the NY State constitution.   In addition, NY City lands, protecting the largest in the chain of reservoirs that supplies the City with "some of the most pristine, pure, potable water in the country" would also be obtained by Premium under eminent domain.  

I urge you to reconsider the permit application submitted by Premium Energy for the Ashokan PSP project.  

Thank you for your consideration.

Sally Smith-Raymond
West Shokan resident since 1989

MICHAEL MOSS, PRATTSVILLE, NY.
Michael A. Moss, Ph.D.
11662 Route 23A
Prattsville, NY 12468

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street NE, Rm 1A
Washington, D.C. 20426

April 10, 2021

Docket number P-15056-000

Ashokan Proposal to FERC for a Pumped Storage Add-On* Project in the Catskill State Forest Preserve


Dear Ms. Bose,
I am writing in support of a denial of a preliminary permit by Premium Energy docket number P-15056, to build a pumped storage add-on in the Catskill State Forest Preserve. I believe that we cannot allow Premium Energy to begin a process of attempting to overcome very powerful forces against it at this time and in the future. There are now major intervenors attempting to wash out the validity of this preliminary request. I am writing to ensure that these intervenors have my support.

Among the many reasons that the Premium Energy application should be denied include turbidity, water level changes in the Ashokan reservoir that will wipe out ecologically fragile systems, and destruction of trout habitat in the longest trout fishing stream in New York State. Due to destratification of the Ashokan Reservoir, it will change the temperature of the water of that stream which will affect the viability of trout to lay eggs and affect adversely the fragile ecosystem of that riparian environment. Destratification of the Ashokan Reservoir also eliminates the cold water at the bottom layer feeding into the tunnel leading to New York City, adversely affecting this unfiltered water supply to the city. The sound and the destruction of the environment by massive earth moving machines, dynamiting and drilling to 300 feet deep, digging holes to construct a generating station, and drilling of a 42 foot wide tunnel that will extend up to the upper reservoir (which is the add-on) and the 300 foot tall, half mile wide dam will destroy a valley that was constructed specifically in the Catskills to make a beautiful environment for people to live, in addition to the destruction of all of those homes in that valley. One of the three Premium Energy projected sites, Woodland Valley, is on State Land which is protected and cannot be built on without the State Legislature and the Governor signing off on such an amendment to the State Constitution. My prediction is that it will fail to achieve the granting of an amendment to the State Constitution which applies strictly to State Land.

Forty years ago a project in Prattsville, NY (see link below) almost exactly like the Premium Energy project was denied the ability to go forward by the DEP which determined that there would be turbidity in the water as a result of the pumping, and that because of destratification of the lower reservoir the temperature would not be the same after it was returned from the upper reservoir, thereby threatening the fragile ecosystem of the reservoir, in this case the Schoharie Reservoir. Since the Schoharie Reservoir feeds directly into the Esopus Creek through the Shandaken Tunnel, the two cases are exactly parallel. There is a study (see link below) going on right now studying turbidity in the Lanesville area, a third Premium Energy site, which will of course suffer from the same effect. That study is trying to determine whether runoff from a large rainfall will affect turbidity. Imagine how raising and lowering the water level of the Ashokan reservoir will affect the turbidity of the unfiltered water that goes into the water system of New York City which feeds 40% of its population. Because the effect on turbidity is equivalent to that of the rejected Prattsville project 40 years ago I submit this project should also be denied. 

Although normally, I would support green and sustainable energy initiatives, this one is ill-thought out, destructive, and damaging to the Catskills. It threatens NYC drinking water and wildlife, local businesses and revenue from tourism, people's homes, as well as the 100-year old Catskills Preserve which is constitutionally protected by NY State law.	

Deny this application.

Respectfully yours, 
Michael Moss Ph.D.

Link to River Reporter article describing Prattsville project:  https://riverreporter.com/stories/prattsville-rides-again,43064?fbclid=IwAR3_NCUhZ4yx2YHN_ueDVHhZ1i2oIFm1Jc698o5LLvQsrgiRVs6utEuZagA - .YGZnDEAQLxQ.mailto

Link to USGS survey:  https://www.usgs.gov/centers/ny-water/science/upper-esopus-creek-tributary-bedload-pilot-study?qt-science_center_objects=0 - qt-science_center_objects

Judith Moss, PRATTSVILLE, NY.
Judith Moss
11662 Route 23A
Prattsville, NY 12468

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street NE, Rm 1A
Washington, D.C. 20426

April 10, 2021

Docket number P-15056-000

Ashokan Proposal to FERC for a Pumped Storage Add-On* Project in the Catskill State Forest Preserve


Dear Ms. Bose,
I am writing in support of a denial of a preliminary application by Premium Energy docket number P-15056, to build a pumped storage add-on in the Catskill Forest Preserve. 

The fact that the application by Premium Energy is misrepresenting itself in order to be eligible for streamlined approval by labeling the pump storage project as a “closed loop” rather than an “add-on” project is in itself grounds for dismissing the application. The Premium Energy project takes water from the upper reservoir and adds on to an existing lower reservoir while the application makes a case for a “closed loop” project. Premium Energy misrepresents itself from the get -go and the application should be rejected out of hand on this basis alone.

Furthermore, the environmental and ecological impact on the surrounding area concerns me greatly. The effect of altering the sediment has profound consequences for breeding trout and the cultivation of the valuable trout habitat. Additionally, all the proposed reservoir areas are important bird areas. Altering the habitat and enduring widespread construction over an extended period of time would be highly detrimental to the birds, fish, and the wildlife in the Catskill Forest Preserve. 

Moreover, since the Ashokan Reservoir provides 40% of New York City’s water, it is inconceivable to me that New York City would fail to protect a most valuable asset. With the largest unfiltered water supply in the nation, NYC takes the protection, safety, quality, and sustainability of its water supply very seriously. The Ashokan Reservoir has extensive security in order to ensure the safety and quality of the water flowing down to New York City. I have been stopped by the police for taking a wrong path in the area around the Ashokan – protection of the water supply is a big job and a big deal. Monitoring of the premises is extensive. I cannot imagine that NYC would agree to allow a private company to come into the heavily protected Catskill Preserve and endanger the quality and safety of the water for 9.5 million New Yorkers. 

Although generally, I support green and sustainable energy initiatives, this application by Premium Energy is deceptive, destructive, and damaging to the Catskills. The proposed project threatens NYC drinking water, wildlife, local businesses and revenue from tourism, people's homes, as well as the one hundred year old Catskill Preserve which is constitutionally protected by NewYork State law.

I humbly ask you to consider all my reasons along with countless others who feel as passionately as I do and have also submitted their own reasons to protest this ill-conceived project by Premium Energy. There are very few arguments to be made in support of this project. In fact, I would like to be made aware of the rationale and reasons in support of this project and would appreciate any information on exactly why Premium Electric thinks that it is a good idea to come into protected land and water and mess it up.  In light of the overall negative impact on the Catskill area, I urge you strongly to reject the application from Premium Electric.

Thank you for your time.

Best regards,

Judith Moss

Daria Skripka, Philadelphia, PA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056

Project application is misrepresented as “closed loop” design. This is a project where a new upper reservoir will be added to an existing lower reservoir. Costly and long term project that will impact wildlife on teritory of Catskill preserve, threaten quality of water that supplies NY state and negatively impact many local residents. This not the right place for the green alternative that we need

Sincerely,
Daria

Judith Coutinho, WEST SHOKAN, NY.
I am Judith Coutinho. As a private citizen, I oppose the Ashokan Pumped Storage Project, P-15056-000.  I am a long-time property owner and resident of West Shokan, Ulster County, New York. 

The need for utility-power sources is very real. The need to protect our unique ecosystems and natural resources in The Catskill Park is very real. The need to protect the Ashokan Reservoir, the largest unfiltered municipal water system in the country, is very real. There is so much to balance. There are so many points against the proposed hydro-electric project. I hope the Commission agrees this proposal should stop - now and forever. 

The Catskill Forest Preserve in Ulster County is special--a large, unfragmented area, protected since 1885. It is ecologically valuable, a rare East Coast habitat for large animals. For both resident and visitor, it is like the NY State equivalent of a National Park. It is protected by the NY State Constitution and uses like this power plant are expressly excluded. The Preserve includes endangered animals and plants. Thousands of people outside the county, state and country come here year round for recreation, rest and natural beauty. Easy accessibility from major metropolitan areas makes it a unique resource. Our local economy depends heavily on these visitors because agriculture and manufacturing have shrunk severely. 

A counter argument might be the structures for the power plant will only occupy a small portion of the Preserve. It is a poor argument because we know, from scientific research, that disturbing even a small portion of an ecosystem by constructing invasive, large structures has enormous negative ripple effects. This project will significantly degrade this habitat, which NY State Forest Condition index ranks in the top 1%.  As a State Forest Preserve, it is ranked by USGS "Gap Analysis Program" as Status 1, a category the DoE says to avoid for development.  Also, the proposed sites are all in Audubon Society's Catskill Peaks Important Bird Area.  

Those are big overviews. Looking deeper, the balance gets worse.  
Aquatic habitats will be devastated in and around any of the proposed reservoir sites, wiping out prime areas for trout and other sport fish, probably spreading ecology-damaging invasive plants (e.g. "rock snot").   

Operation of the power plant will cause sediment deposit changes, stressing the streams inhabitants (fish and their food) and t to the water in the Ashokan Reservoir. Tunnel construction and operation will produce additional sediment.  

Construction issues: Local roads and bridges are over 100 years old, built when the Ashokan Reservoir was built; this area was extremely rural, sparsely populated, relying on agriculture and forestry. The roads & bridges will not take the daily, long-term strain of large construction equipment and work crews. In addition to the abuse and destruction of our roads and bridges, the noise contamination and contamination of construction materials will pollute the streams and the land for miles around the sites, and drive off animals and tourists alike.  

Re: "closed loop" and "open loop" hydro-electric generating systems, I find a discrepancy between the proposal submitted to you and the publicly available descriptions of the systems. A "closed loop" system is independent from any free-flowing water source, and an "open loop" is continuously connected to a naturally flowing water feature. This system is an "open loop" with an add-on. The streams that feed the Ashokan are still flowing. The Esopus Creek enters the West Basin & exits the East Basin. Gravity-feed flow carries the water 92 miles to Westchester--that's FLOW, even if you can't see it because the Reservoir is so large! This was sloppy engineering or a deliberate attempt to obscure reality; either should disqualify the proposal.

I focused on the objective, observable and/or documented information that supports my opposition. I have a personal stake in opposing this flawed project: the dam for the preferred site of the upper reservoir is only hundreds of yards upstream from my home. I can never replace this home, which my husband and I helped my parents build, hammer in hand, 50 years ago.  Even if I wanted to sell this property today, no buyer would pay me what it's worth because this matter is still "open" and a threat.  

This is the human side of the damage this project is already inflicting. I feel Premier Energy treated our communities the way empires and big corporations treat third-world countries: invading with no consideration for the people already living there, and taking resources because they have the financial power and political power to do what they please…all for the sake of "profit."  Premium Energy is cashing-in on a real need, fishing for likely locations that meet geological/geographic conditions, regardless of other considerations then submitting flawed proposals. I imagine the Commission is swamped with proposals of this kind.  Reliable sources told me that not a single person from the companies putting this proposal forward has set foot in Ulster County.  Premium Energy did not even communicate their intention to the townships involved before they filed the proposal, a significant sign of their disrespect for the communities they expect to invade. The research for the proposal was long-distance and impersonal, yet the impact of their actions is very immediate, very local and very, very personal for me and hundreds of others. As you review the proposal, please take into account Premier Energy's level of ethical behavior--low-to-none. It's hard to establish a quantitative value for ethical behavior, yet I ask that it be one of the factors you consider as a predictor trust-worthiness and of future outcomes if you allow this proposal to move forward.

Respectfully, Judith Coutinho

Teresa Falkowski, PHOENICIA, NY.
Teresa Falkowski
6 Woodland Clove Rd.
Phoenicia, NY. 12464

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426
.
Docket number P-15056-000

Dear Ms. Bose,
	I have many concerns regarding the proposed project. One is the wildlife and impact on our preserved lands in the Catskills. A project of this proportion would take years to complete and a ton of construction. It would be detrimental to the wildlife, the town and the neighborhood if there are any homes left in it. Being a resident of woodland valley I can tell you first hand there are bears, deer and many more that would feel the effects of a big construction project. They are in our yards thriving on vegetation and make regular trips down to the stream to drink. This would displace many and disrupt many who hibernate and use the valley as a home. 
The town of Shandaken that thrives on tourism of nature lovers would be hit the hardest. They come here to hike, fish, camp, swim and tube the esopus and this would kill all the enjoyment these people seek and end up putting the local businesses that rely on this to stay afloat in the red and eventually close. The entire town would end up suffering severe effects of this. Considering the neighborhood of woodland valley contributes significantly to the tax roll in Shandaken and this Clean energy company that wants to take over is going to be getting tax breaks. It will put a much bigger tax burden on the businesses that will already be hurting from lack of income. 
If Shandaken and woodland valley isn't big enough for the politicians to care about, don't forget whose water supply will be used to create this energy. Are we really willing to put NYC's main water supply at risk? Just to make some energy which the plant uses a third of to operate. The water will be murky and turned up constantly from the constant pumping and heavy flows. Have you ever seen the stream after a heavy rain? It's not pretty! Also the more water is flowing in some areas the more chances of contamination and pollution. I just don't think this is worth the risk of unknown impacts to the lands, wild life, NYC water supply and the town as a whole. I respect trying to create clean energy, but these are the real costs of this project.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit
for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Teresa Falkowski

47 Hoffman st, Kingston, NY.
Dear Federal Energy Regulatory Commission, 


I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. 



This project raises major environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 



It is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to this community and raises our concern over Premium Energies practices. 




A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  


All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Yet, this is what is being proposed.

 


The Protected Three Birds Orchid currently live at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.” 

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and Status 1 protected land. 


I ask that you deny this permit based on these essential points, and that they look for some other non threatening site for their work. 



Thank you for your time,  

Sincerely,

Josh Kaufman

David E Seitz, New York, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 Frist St NE, Room 1A
Washington, D.C. 20426

Although I am not generally one to become politically involved, the proposal for a hydroelectric plant is so absurd that I just had to say something.  As you are busy I am sure, here are a few brief bullet points detailing the most egregious flaws in the proposal

1) The NYS Constitution - it is guaranteed that the Catskill Forest Preserve "shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be be taken by any corporation public or private"

2) Ecology - pumped storage destroys the ecosystem.  Sediment is altered, the water increases in turbidity, etc.  To make matters worse, almost half of NYC (about 9 million people) depend on water from the reservoir - which is part of the largest unfiltered water system in the world

3) Economics -  People come from all over the world to view the unspoiled views of the Ashokan reservoir and surrounding areas.  Development of this type would destroy the tourism industry in the Catskills - which currently generates 2 billion dollars a year and supplies 20% of the region's employment

4) We've seen this movie before from Premium Energy Holdings - they lie and fast-track their projects through subterfuge and "surprise filings"

Take a look at this:

https://sierrawave.net/premium-energy-proposes-reservoirs-where/

In summary, there is no logical reason to sacrifice one of the last remaining forest habitats close to NYC for a couple of kilowatts

Sincerely,
David Seitz MD

Rebecca Riklin, Rockville, MD.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.


Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.


As a lifelong visitor to the Catskill Forest Preserve, it is critical to me that the area not be destroyed. Its beauty and peacefulness are unique. I have delighted as other have recently rediscovered the joys of the Catskills. The area deserves to be preserved for generations to come. 

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Rebecca Riklin

Claudine brenner, Stone Ridge, NY.
As so well said by Executive Director of Catskill Central, "the project proposed by Premium Energy Holdings is ill-conceived and does not take into account the barriers to its implementation including the impacts to critical habitat, New York City water supply, Catskill Park Forest Preserve Lands, and the presence of communities within areas where upper basins are proposed. This project does not belong in the Catskill Park and should not move forward."

Andrey Zhukov-Khovanskiy, Chichester, NY.
To: Kimberly D. Bose 
Secretary, Federal Energy Regulatory Commission
888 First Street, NE, Room 1A, Washington, DC 20426

Dear Secretary Bose, I am a resident of Chichester, NY (Ulster County), and I am writing this to strongly oppose the Application for Preliminary Permit submitted by Premium Energy Holdings, LLC (docket # P-15056-000). The reason of my objection count on both the deficient and misleading of the proposal and dramatically negative effect on wildlife of the proposed location.

The proposal make believe the project will take place not into heart of Catskills Forest Preserve (established 1885) but some Catskill Mountains. The Catskills Forest Preserve has long time been identified as an area with a greater need for environmental protection and has the constitutional protections of the NYS lands. Despite on this all three of proposed sites for upper reservoir and main power plant facility are actually located squarely within the boundaries of the protected Catskills Preserve.
 
The proposal states the proposed Ashokan Pumped Storage Project would operate in a “closed loop” and   the existing Ashokan Reservoir’s water storage would not be used for project operation. The review of the request clearly shows that it is false statement. In fact the proposal is actually an “open loop”, an add-on project where an upper reservoir would be added to already existing lower reservoir connected to a natural water source. Ashokan Reservoir is a source of 40% of the drinking water of New York City. The impact of such an open loop system to Ashokan Reservoir would be significant and damaging. Construction of such scale will result in higher loads of sediment transport in the named streams, something that the NYC Department of Environmental Protection and NYS Department of Environmental Conservation have been studying and trying to prevent by investing in restoration projects in the watershed in our area.

As citizen who cares deeply about environment a wildlife protection, I’d like to draw your attention to the devastation that this construction will bring to federally listed species with the “critical habitat” in Catskills Forest Preserve. Namely, federally endangered Indiana bat (Myotis sodalis), federally threatened northern long-eared bat (Myotis septentrionalis), federally threatened Northern wild monkshood (Aconitum noveboracense) and the bald eagle (Haliaeetus leucocephalus), that remains on the New York State list as a state-listed threatened species. The Catskills Forest Preserve is a rare protected land that was preserved by our predecessors for the generations to come specifically to leave it intact, and protect its wildlife. 

I strongly urge the Federal Energy Regulatory Commission to deny Premium Energy Holdings, LLC request for a preliminary permit to study the feasibility of a pumped-storage hydropower facility connected to Ashokan Reservoir.

Best regards,
Andrey Zhukov-Khovanskiy
199 Stony Clove Lane
Chichester NY, 12416

Vivian Welton, Phoenicia, NY.
To:  Federal Energy Regulatory Agency
From:  Vivian Welton, 313 Old Rt. 28, Phoenicia, N.Y. 12464
Re:  P-15056-000 Premium Energy Pumped Storage Facility Proposal

I am requesting that you deny Premium Energy’s application for a permit to conduct feasibility studies for a proposed pumped storage facility on the Ashokan Reservoir.  There is no chance that this project could pass scrutiny and prove to be feasible.

This project would be disastrous for the ecology, economy, and survival of the Upstate New York Catskill Park area. It is clear that Premium Energy did not research the area before they created this plan.  Their plan description has flaws that make it plain that their engineers were unfamiliar with the proper design of a closed-loop hydroelectric plant (which it claims to be, but is not). Conducting an excavation of immense size next to the only drinking water source (unfiltered!) for millions of people apparently did not seem a potential problem.  The fact that the lands in question could not, and would not be conveyed, leased, or given access to for such a use did not seem to register on their radar, even after they had been informed of that fact by New York City.  

Many valuable and endangered species of wildlife would be at risk by the project, regardless of where in the Catskill Park and surrounding area it is located.  The Esopus Creek, which conveys the water into the Ashokan Reservoir, is a fragile ecosystem, prone to flooding and drought, with unstable banks.  It is home to Bald Eagles, endangered Eastern Timber Rattlesnakes, and is a world-famous trout fishing stream.  The economy of the area depends on tourism, which centers on the pristine stream, and the unspoiled beauty of the mountains, which remain “forever wild” by provision of the New York State Constitution.

Premium Energy may claim that their proposed hydroelectric project could be fine-tuned to be feasible, energy-efficient, or a net positive for the environment.  Please do not subscribe to such foolishness.  I say this with respect for your leadership as the Federal Energy Regulatory Agency, charged with protecting our precious natural resources and acting for the benefit of all.

Yours truly,
Vivian Welton, Phoenicia, NY

Elziabeth Earle, Olivebridge, NY.
I am writing in regards to Premium Energy’s proposal for a hydropower plant. While it is necessary to remove our dependence on fossil fuels, a dam in these locations would likely cause ecological issues.

Having worked several years in agroforesty in many local counties, I can attest to how important stream and land ecology is to maintain wildlife species found in the Catskills. Prior to conservation efforts many important plants and animals in the Catskills were either endangered or ceased to exist altogether. By allowing wild lands to stay undisturbed we gives struggling species a chance to regenerate and thrive. The suggested areas of this proposal are ranked in the top 1% of forest habitats according to the New York State Forest Condition Index. “Differences in microclimate, predation levels, invasive species, and other disturbance at forest edges produces effects that can extend 100 meters or more into forest patches” (https://www.nynhp.org/documents/98/forest_condition_index_hshjI31.pdf).

Diverting water can cause a rapid decline in forest health, which in turn greatly affects local flora and fauna. In the Woodland Valley area, trout breeding areas would be disturbed and the impact of such a large-scale project would likely impact their spawning conditions (https://onlinelibrary.wiley.com/doi/10.1111/eff.12210).

Clearing trees for power lines and tunnels to move water will greatly affect local bird populations. The Bicknell’s Thrush is listed with a S2S3B rank and is of special concern to NYS conservation due to the breeding habitat according the New York Natural Heritage Program (https://www.nynhp.org/documents/1/rare_animals_2017.pdf). This species was only recently determined to be a new species and has a “has a limited summer range in the northeast” for breeding (https://www.audubon.org/field-guide/bird/bicknells-thrush).

There are numerous species of at-risk birds that populate and breed in these areas, such as the American Black Duck, Olive-sided Flycatcher, and the Cerulean Warbler (https://www.audubon.org/important-bird-areas/catskills-peaks-area). There has not been enough research conducted into these species in order to fully understand the impact of building this project around these ecosystems.

Pumped hydro storage creates situations where water rapidly adjusts reservoir water levels to produce electricity. This would place an incredible strain on terrestrial and freshwater ecosystems. Local wildlife cannot react to those immediate shifts in water levels. These habitats would become uninhabitable and inhospitable to many species (https://e360.yale.edu/features/for_storing_electricity_utilities_are_turning_to_pumped_hydro).

Allowing Premium Energy to build in the Catskill Preserve sets a dangerous precedent for the sake of cleaner energy at the cost of wildlife and habitat loss. There are likely better options available that should be researched and considered in order to gain the benefits of hydroelectricity while maintaining ecological diversity.

Alison Maltby-Duggan, Olivebridge, NY.
Alison Maltby-Duggan
Olivebridge, NY

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I ask that FERC decline their request for a preliminary permit for the Ashokan Pumped Storage Project (P-15056).

I am a firm believer in renewable energy sources, but I find the proposal to be deeply flawed. Their calling of the project as a “closed-loop” instead of an “add-on” is particularly disturbing to me since their use of the Upper Basin of the Ashokan Reservoir, as proposed, could threaten the drinking water of the more than 8.5 million residents of New York City.

I am also deeply concerned about the effects this project would have on the wildlife of the area. All the proposed reservoirs appear to fall within Audubon’s Catskill Peaks Important Bird Area. The Upper Esopus Creek, which feeds into the Upper Basin of the Reservoir, is a trout breeding site and could be affected by changes in turbidity caused by the proposed project. The US Geological Survey has designated the Catskills Park State Forest Preserve as Status 2 lands. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” The Esopus Creek has been listed by the U.S. Fish and Wildlife’s National Rivers Inventory as “Outstandingly Remarkable Value: Fish, Recreational, Scenic”. The forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to New York State’s Hudson Valley Forest Condition Index. 
In addition to its potentially negative effects on the environment and water supply, Premium Energy’s proposal would be deeply harmful to the fabric of local communities. Residents displaced by the project would likely have a hard time securing new housing, as there is a housing shortage in Ulster County, and for homes that are available, prices are high. In addition to this, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry which supports 20,000 jobs. The project would limit access to hiking, fishing, and other forms of recreation in the Catskills. The proposed Stony Clove Reservoir site would cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville. The proposed Woodland Valley Reservoir site looks like it would cut off access to Woodland Valley Campground and the trails around it.

I hope that Premium Energy is able to find a different spot for their project where they will not have to disturb a wilderness that is in the New York Constitution (Article XIV) as lands that “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Renewable energy should happen, but not at the expense of protected wilderness, vulnerable communities, and incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project (P-15056).

Thank You,
Alison Maltby-Duggan

Janine Connell, High falls, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Janine Connell

Janine Connell, High falls, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Janine Connell

Michael pezzolla, Lanesville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline this permit. Of course alternative energy sources are important for our future, but to consider placing this type of open loop system in a Status 1 area as this is designated by the USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.

Please decline this application

Sincerely,

Michael Pezzolla

Ralph Schimmenti, Kerkonkson, NY.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ralph Schimmenti

Alexandria Rabuffo, Shandaken, NY.
To the good people of the FERC,

I strongly object to the proposal on docket P-15056, Premium Energy Holdings LLC Proposed Ashokan Pumped Storage project. The ecosystem of the Shandaken and Catskill Mountains Areas depends on the waterways and lands included in the Lanesville proposal all the way down to the Ashokan Reservoir. While this proposal failed to recognize and notify them, there are many townships less than 5,000 along the proposed pathway through a precious forest preserve that would be impacted as well as the vast majority of the New York City Watershed. Additionally, this forest preserve represents a piece of the less than 1% of old growth forest remaining in the deciduous regions of eastern North America and is a precious limited habitat for biodiversity.

The waterways proposed for modification are already fragile and would cannot withstand the proposed added turbidity this project would cause. Beyond damage from hurricanes, these waterways are already prone to seasonal flooding and have undergone major infrastructure projects to decrease turbidity which this proposal would undo. Increasing turbulence will only cause more drastic erosion and raise flood levels to new heights, making not only the proposed dam location but all areas downstream uninhabitable. This will wreak havoc on the residential, business and infrastructure zones that adjoin these waterways. These waterways are a large part of the local economy as well as serving as a primary water source for New York City. In addition to the being the drinking water for the 8.7 Million people in New York City, this proposal would affect the depth needed for all existing local well based water sources and would increase particulates and sediment in the drinking water. This project proves a huge safety risk to the potable water of New York City and the communities this project passes through, which stretch almost half way across Ulster County.

Furthermore, this proposal will impede migration patterns for many species and be catastrophic to their populations. Destruction of these lands and waterways affects habitats for rare and endangered plants and animals, as well as impacting habitats and migration patterns which put other species at higher risk. Included; among many species in this area; are the endangered American chestnut (virtually/functionally extinct), the rare Bicknell’s thrush (who breeds in these mountains), the White Mountain Tiger beetle (a globally rare beetle whose home lies in the banks of the Esopus creek), the rare Lepidotera species, and the American bald eagle (a raptor under federal protection). These are only a few of the endangered flora, regionally rare raptors, regionally rare reptiles and amphibians, and large mammals that rely on the forest and its pristine waters for survival and reproduction.

The United Nations has already warned of the risks of biodiversity collapse, yet this project would propose to route through one of our country’s most biodiverse areas. This is not a way to save the environment, only one that would destroy the resources green energy is supposed to protect. Please deny this project any ability to move forward, this region is a precious and limited natural resources that would be devastated by this work and needs the wisdom of good people and the FERC to protect it.

Sincerely,
Alexandria Rabuffo

Lindsay Stanislau, Brooklyn, NY.
I’m writing to express opposition to the proposed hydroelectric dam in Catskill State Preserve. The Ashokan Reservoir is a key water supply for New York City and could be put in jeopardy by such a hastily designed project. The impact on the ecology and potential flood risks  of the surrounding areas has also not been fully assessed. I urge that you please do not move forward with this proposal.

Jennifer Christie, Chichester, NY.
Project Docket:  P-15056
Jennifer Christie
Chichester, NY 

I am opposed to the project.

As a retired business owner of a second-home building company over 35 years in the town of Phoenicia, I know first-hand how this would affect the tourist industry and tourist appeal of our Catskills.  A project of this magnitude, spanning many years, would destroy our tourist economy. The Catskill Park is 2 hours from NYC. We are an area to decompress from the stress of our modern world. The importance of a pristine escape can never be overstated.

1.	 Large electric towers will ruin our pristine mountain views.
2.	These high power electric lines give off an electrical field which effects all living things.
3.	Our sensitive environment would be threatened, nesting sites destroyed, animal breeding grounds and migratory paths disrupted.
4.	Increased noise levels will affect all life.
5.	The project would increase our carbon footprint.
6.	Large trucks, hauling dirt supplies, concrete will ruin our roads.
7.	Our world renowned trout streams will be destroyed.
8.	The park supplies drinking water for New York City.   The increased movement of water will expand turbidity.
For this and many other reasons, please reject this proposal.

Arthur Christie, Chichester, AL.
Project Docket:  P-15056
Arthur Christie
Chichester, NY 

I am opposed to the project.

As a retired business owner of a second-home building company over 35 years in the town of Phoenicia, I know first-hand how this would affect the tourist industry and tourist appeal of our Catskills.  A project of this magnitude, spanning many years, would destroy our tourist economy. The Catskill Park is 2 hours from NYC. We are an area to decompress from the stress of our modern world. The importance of a pristine escape can never be overstated.

1.	 Large electric towers will ruin our pristine mountain views.
2.	These high power electric lines give off an electrical field which effects all living things.
3.	Our sensitive environment would be threatened, nesting sites destroyed, animal breeding grounds and migratory paths disrupted.
4.	Increased noise levels will affect all life.
5.	The project would increase our carbon footprint.
6.	Large trucks, hauling dirt supplies, concrete will ruin our roads.
7.	Our world renowned trout streams will be destroyed.
8.	The park supplies drinking water for New York City.   The increased movement of water will expand turbidity.
For this and many other reasons, please reject this proposal.

Megan Brenn-White, Kerhonkson, NY.
Hello,

As a current resident of Ulster County (about 20 minutes away from the site of the proposed plant) and former resident of NYC, I’d like to register my strong opposition to this poorly thought out proposal. The loss of preserved wilderness, risk to NYC water supply, and loss of homes in no way would be worth the benefit that would accrue only to a for-profit company.

As a realtor in the area and head of the largest real estate team, I can also say that the very proposal has already thrown doubt into the minds of future homebuyers in the area and would and is already lowering the value of properties around the proposed site.

I hope that this will be swiftly shut down.

Thank you,
Megan Brenn-White

Robert Howe, Wesr Shokan, NY.
April 11,2021
RE: MOTION TO INTERVENE Docket # P-15056 – Ashokan Pumped Storage Project 
Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314(a)(3)), I am a resident of the Town of Olive and I have a vital interest in the Preliminary Permit application submitted to the Commission by Premium Energy Holdings for the Ashokan Pumped Storage Project (P-15056).
My home for the past 21 years, 200 yards from the edge of Route 28a and the Ashokan Reservoir, is in direct proximity with the proposed. 
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 
•	The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 
•	Wildlife in our pristine, residential, rural Catskill community is rich; inclusive of a full natural order, which, daily, visit and pass through our small estate.  The damage to habitats resulting from the proposed project is callous and harrowing to consider.
•	We, my wife and I, are in our late 80’s.  We retired in 2019.  Our decision to remain in this home was based on our love of what we enjoy as part of this remarkable community.  The time it would take to complete this project, with the interference from the construction activity nearby our home, noise and traffic on our roads, is overwhelming and against every reason we have for staying here.  Considering what it might be like after the massive project is alarming.
•	I want to emphasize that where we live is a residential area, as is most of the broad area that the project can impact.  The diverse makeup of the population includes many retirees like ourselves, longtime residents, professionals and blue collar.  
Please do everything in your power to prevent this proposal from moving forward.

Sincerely,
Robert Howe
914-388-0330
Organic13@earthlink.net

Robert Brown, New York, NY.
Secretary Bose
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426 
re: P-15056


Dear Secretary Bose,

I would like to express my opposition to docket # P-15056, Premium Energy's proposal to build a pumped storage hydroelectric plant that would use the Ashokan Reservoir as its lower reservoir and construct an upper reservoir in one of three proposed locations. While I am cognizant of the pressing need for and value of new hydroelectric plants for energy storage, I believe the Catskill Mountains are not the correct site for these plants to be built. I am a landowner in the Catskill Mountains, and unlike Premium Energy, am aware of the unique qualities of this highly preserved area.

The Catskill Forest Preserve was created in 1885 centered in Ulster County, with its protection as "forever wild" written into New York's state constitution. It has grown significantly since then, increasing the area of land that is highly protected and managed for biodiversity. The Forest Preserve's 700,000 acres of unfragmented wilderness provides increasingly valuable habitat in our fast-developing world. The area provides critical habitat to many species of birds, including NY-Species of Greatest Conservation Need black-throated blue warblers, scarlet tanagers, and wood thrushes, as well as NY-Special Concern raptors Cooper's hawk, red-shouldered hawk, and sharp-shinned hawk. It also provides some of the last good habitat for the NY-Special Concern eastern hognose snake and the NY-threatened timber rattlesnake. The Catkills provide summer foraging habitat for the NY-threatened northern long-eared bat. For these and other reasons, the entire area has been designated the Catskills Peaks Important Bird Area by the Audubon Society.

If these environmental considerations are not sufficient to render this proposal infeasible, the legal ramifications should be. The construction of any possible reservoir inside the "Blue Line" of the Catskill Forest Preserve would inevitably require the condemning of land in the State Forest Preserve, either for inundation or to reroute essential roads. But this is an act specifically prohibited in the state constitution. This would put New York State and FERC on a collision course to a lawsuit unlikely to be resolved before reaching the Supreme Court. In fact, a case currently before the Supreme Court, PennEast Pipeline v. NJ, hangs on the question of whether FERC can force the state of NJ to condemn state land via eminent domain in order to let a private company build a pipeline. And New Jersey state land is not even as highly protected as New York's. Yet Premium Energy seems to be basing their entire application on the unlikely passing of this future amendment to New York's constitution.

It is my understanding the Department of Energy specifically designates areas of high preservation, i.e. those accorded Status 1 or 2 in the USGS Gap Analysis Program, as to be avoided for new stream reach hydroelectric development. All state lands in the Catskill Forest Preserve are considered Status 2 according to the USGS.

I request that FERC uphold the DoE's own standards and reject Premium Energy's proposal for a preliminary license before this California company wastes any more money investigating it.

Sincerely yours,


Robert Brown

71 Warren Street #4
New York, NY 10007

Laura Tofte, Saugerties, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Laura Tofte

Cynthia Thomas, West Shokan, NY.
April 11,2021
RE: MOTION TO INTERVENE Docket # P-15056 - Ashokan Pumped Storage Project 
Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314(a)(3)), I am a resident of the Town of Olive and I have a vital interest in the Preliminary Permit application submitted to the Commission by Premium Energy Holdings for the Ashokan Pumped Storage Project (P-15056).
My home for the past 21 years, 200 yards from the edge of Route 28a and the Ashokan Reservoir, is in direct proximity with the proposed 
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding's application for a preliminary permit. 
"	The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 
"	Wildlife in our pristine, residential, rural Catskill community is rich; inclusive of a full natural order, which, daily, visit and pass through our small estate.  The damage to habitats resulting from the proposed project is callous and harrowing to consider.
"	We, my spouse and I, are in our late 80's.  We retired in 2019.  Our decision to remain in this home was based on our love of what we enjoy as part of this remarkable community.  The time it would take to complete this project, with the interference from the construction activity nearby our home, noise and traffic on our roads, is overwhelming and against every reason we have for staying here.  Considering what it might be like after the massive project is alarming.
"	I want to emphasize that where we live is a residential area, as is most of the broad area that the project can impact.  The diverse makeup of the population includes many retirees like ourselves, longtime residents, professionals and blue collar.  
Please do everything in your power to prevent this proposal from moving forward.

Sincerely,
Cynthia Thomas
914-388-0426
edgreenc@earthlink.net

Catherine Yoon, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings (“Premium Energy”) to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that we, as a country, need to transition to renewable energy resources, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve (the “Preserve”) must not be sacrificed in the process. Under Article XIV of the New York State Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. Premium Energy’s Ashokan pumped storage project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation and represents over $1.7 billion of investments since the 1990s alone.
As a last point to make in opposition to Premium Energy’s Ashokan pumped storage project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds and are thus eligible for streamlined FERC approval. This is why Premium Energy is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
It is imperative that our country begin to take steps to transition to renewable, green-energy sources. However, such transition must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Catherine Yoon

Mark Mann, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to register my opposition to the Premium Energy Holdings application to build a hydroelectric power plant in the Catskills region. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities and risky to NYC’s drinking water.

It is evident that under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  This is an essential provision to uphold and insure that we protect the watershed system and avoid negative impact to Esopus Creek and the wildlife that depend on it. In addition, the Ashokan Reservoir supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Premium Energy’s proposal is not a closed-loop system—but is an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. 

I am personally opposed to the use of  eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing. As Town of Olive Supervisor Jim SoFranco so clearly stated “Once is Enough!” 

Please reject Premium Energy’s plan for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Mark Mann
Shokan, NY

Morgan Miller, Hensonville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. My husband and I moved to the Catskill Mountains to contribute to the local economy, local infrastructure, and the local wildlife. It was an integral part of our move here and the longer we have lived here, the longer we have realized that the wildlife, tourism, and agriculture that is key to the region is the cornerstone and foundation of the Catskills. To displace the community, disrupt and decimate the wildlife population, and destroy a key element of tourism would be a travesty and injustice to the community and beyond.

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Morgan Miller

Simon Mortimer, Hensonville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. My wife and I moved to the Catskill Mountains to contribute to the local economy, local infrastructure, and the local wildlife. It was an integral part of our move here and the longer we have lived here, the longer we have realized that the wildlife, tourism, and agriculture that is key to the region is the cornerstone and foundation of the Catskills. To displace the community, disrupt and decimate the wildlife population, and destroy a key element of tourism would be a travesty and injustice to the community and beyond.

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Simon

Bonnie Valentines, Philadelphia, PA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Bonnie

Joel I Shapiro, Olivebridge, NY.
  Please do not grant a development permit to Premium Energy.

   The following statements of New York City’s Department of Environmental Protection in regard to Premium Energy’s “fatal flaws” makes an undeniably strong case against the project.
1.  The land that Premium wants to use near the Ashokan Reservoir is "part of the Catskill Forest Preserve, for which sale, lease and development are prohibited under the New York Constitution.”
2.  “Under Section 21 of the FPA (Federal Power Act), the federal right of eminent domain would be unavailable to Premium Energy even in the remote possibility that the commission ever grants it a license. Accordingly, Premium Energy will never be able to gain control of those lands.”
3.  “Put simply," the DEP filing said, "this is a poorly conceived, inappropriate project that should be stopped before it can cause any damage to the water supply system or the environment, or the imposition of billions of dollars of incremental costs on New York [City] consumers for ... [a] filtration system” that could become necessary if the turbidity becomes unmanageable.

   I will add that the construction of the Ashokan Reservoir in the early 20th Century was, for this area, a traumatic event that destroyed more than a dozen towns and required hundreds of people to leave their land, their farms, their homes.  The effects of this dislocation are still being felt.  As a result, this is not an area where a development project such as the one proposed will be welcomed in any way.  You should expect all legal avenues to be explored. 
So, a sloppily thought out project in an area that is environmental sensitive and with a population that will be in full opposition seems a very bad idea.

Tina DiVello, Brooklyn, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Tina DiVello
917-208-6327

Dashall Vazquez, Walden, NY.
The project would flood over 200 acres to construct a new reservoir, with a dam as high as 300 feet. It would be connected to the Ashokan Reservoir by a tunnel up to 50 feet wide and many miles long, drilled under both public and private lands. It would threaten endangered species, damage water supply for wells, impact the NYC water supply, block tourism, and cut revenue for our area -to name just a few of the negative impacts.

Stop premium energy's proposal! We do not want this restricting land and blocking it off from the people that live here. Again! Stop premium energy's proposal!

katherine mcmillan, High Falls, NY.
ADAMANTLY OPPOSED TO THE WALNUT ENERGY PROPOSAL. PLEASE DO NOT LET THIS HAPPEN.

Douglas Gillespie, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
As a property owner in Woodland Valley, I am writing to strongly condemn the proposal by Premium Energy Holdings to build a pumped storage system in the Catskill Mountains (Ashokan Pumped Storage Project P-15056.
The number of reasons to oppose are almost too numerous to count. While I am strongly in support of moving out of fossil fuels as an energy source, this project will create many and devastating problems should it be allowed to move forward.
As someone who learned to appreciate the amazing diversity of the trees, plants, fish and wildlife habitat in the Catskills from my earliest days, I will list a few:
• Severe negative impacts to plant, wildlife and trees, some of which are endangered or rare.
• Severe negative impacts to the Woodland Creek and the Esopus Creek, popular recreational fisheries.
• Severe negative economic impacts to the community, both during and after construction.
• Risk of negative impact ti\o the quality of water in the Ashokan Resevoir which supplies up to 40% of water to New York City. It is currently unfiltered and the cost of a filtration plant would be in the billions of dollars.
While I am not a scientist, I have read many more detailed articles relating to the items I mention above. And yes, my concerns are also personal with a view towards future generations and the impact this would have, while ultimately not helping mitigate the effects of  global warming in a significant way. The damage outweighs the benefit.
The project also looks to run roughshod over many environmental laws and protections currently  in place, both nationally and in the State of New York laws.
Lastly, the preliminary proposal  from Premium Energy Holdings is poorly written and shows little understanding of the area they propose to use for this project.  I question whether they even have the ability to follow through with the project, much less the capital.
I urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Douglas Gillespie
624 Woodland Valley Road,
Phoenicia, NY 12464

Ty Stallard, Philadelphia, PA.
To: Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I like add my true comment first before using this copy and paste comment for support.

It would be a huge mistake messing with NYC water supply. Once you give a corporation access to this fresh water under the disguise of "energy", they'll come for NYC fresh water next. I'm a Michigan native, and corporations are pillaging the great lakes fresh water there. The next step would be to start syphoning this water next and shipping it west for sale then traded on wall street.

I'm also writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,

Ty Stallard
627 N. 13th Street
Philadelphia PA

Lynn Luong, Brooklyn, NY.
As a frequent visitor to the Catskills and someone who consumes the filtered water supply daily in my Brooklyn apartment, I object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

After reviewing the plan and seeing how it would affect not only the people who frequently visit such as myself, but the land's ecology itself. This will create wreak havoc on the ecologically rich areas where terrestrial and freshwater ecosystems that overlap.

The State forest preserved land, states that the Catskills are considered Status 1 land under the USGS "Gap Analysis Program" And under the DOE's Hydropower Vision, Status land 1 should be avoided for development. 

Furthermore, This would plan is not sufficient to meet the DOE standards of a closed loop as the plan would affect the upper reservoir which will affect the it's natural flowing original structure. 

This is not the risk to take that could affect the economy, millions of people and their homes and lastly the ecology of our natural lands. This proposal by Premium Energy will damage more than what we've has already been done.

Walter Alexander, West Shokan, NY.
I am opposed to all aspects of this project. The proposed reservoir location (let’s be honest, the one seriously targeted is the Wittenberg location). That would destroy the grandeur, natural beauty and overall healthy environment permanently. Plus endanger the NYC water supply. This is a pricelessly preserved area, a vital resource, enjoyed by local people and many, many thousands of visitors a year. No to all meddling with this!

Thank you. Please feel free to contact me for further comment.

Barbara Blumenthal, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Barbara and George Blumenthal

Maria muller, Roscoe, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

You must deny this proposal and set the precedent that reckless and potentially disastrous plans have no place in the State protected Catskills Forest Preserve. Companies like premium energy holdings ignorantly and arrogantly choose the Catskills for projects without considering the environmental impact of their choices. 
This must be stopped. 
 
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Maria

Amie Green, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats because, within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As the last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. 

Our country’s transition to renewable, green energy sources must not come at the cost of environmental and community devastation. I believe in renewable energy projects that will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Amie Green

Alexandra Schmidbauer, Lanesville, NY.
To whom it may concern,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alexandra Schmidbauer

Brian Powers, Chichester, NY.
Kimberly D Bose
FERC
888 First ST,NE,Rm 1A
Washington, DC 20406

Dear Ms. Bose;

New York City’s Catskill Watershed is one of the great engineering feats of our modern world.  As the largest unfiltered water supply anywhere, it serves 9 million New Yorkers although with Long Island’s aquifer rapidly degrading and no alternative source available, the watershed will, within a few years, be serving 12-14 million of us.  So the effective operation of the this watershed is genuinely critical to most of the people of New York State. And while there are other ways and places to create and to buy the electricity we will need, there is only this single 5-county watershed where the economic center of these United States can get its drinking water.  40% of this water, sometimes up to 50%, moves through the Ashokan Reservoir. 

As the former publisher of the largest circulation newspapers in this watershed, The Phoenicia Times and The Olive Press, I have a long history of assessing the benefits and drawbacks of major developments proposed for our region.  In the 30-some years I’ve been analyzing such proposals, I have never seen a project so poorly conceived as Premium Energy’s Ashokan Pumped Storage Project. This proposal in my view, evidences a basic lack of comprehension of how the Catskill watershed and the Ashokan reservoir actually work, and of how such a project if actually built would impact both.  It also evidences a lack of understanding of how civic governance works in New York State, including the responsibilities of the US EPA in protecting this drinking water supply. 
 
The baseline issue that Premium’s proposal fails to account for is that the greatest problem the watershed faces and the largest impediment to maintaining water quality is the control of naturally-occurring sediment from the region’s red-clay soils.  Every time water moves in volume in this watershed, it moves with it an equally enormous volume of suspended solids. And the whole operational concept of Premium’s proposal is to move, both by pumping and by gravity- a total of 10 billion gallons a day into and out of the Ashokan reservoir.  That liquid would be the kind of slurry one would create by placing a handful of clay into a blender full of water, and then pouring the mixture back into the tub from which you’ve filled the blender. 

If such an impact were accomplished by an adversary against the most critical infrastructure of our nation’s largest metropolitan area, that would be generally viewed as an act of war; a terrorist act at the very least.  Given what we know about the public health impacts, the premise itself makes no sense.  And the capital cost alone just to build a filtration infrastructure required to mediate those impacts would be $12-20 billion.  So any notion that the public might benefit from this through nominally reduced electrical costs is clearly not true.  The capital and operating costs to mitigate the problem created would exceed any financial benefit from electrical generation by a factor of dozens or hundreds of times. 
    
But even contemplating such a project is a purely theoretical undertaking. Because even if FERC were to ultimately determine that ramping up the contamination of the State’s water supply would somehow serve the public interest, there are practical realities that would render such a decision moot.
   
The first of these is that absolutely no property rights required for the project are in any way obtainable.  The applicant has no legal right or ability to use the Ashokan reservoir or any City-owned lands for its stated or for any other purposes.  The second intrusion of reality is that by exacerbating turbidity problems and reducing water quality, the project would take the City of New York out of its compliance with its Filtration Avoidance Waiver, and compel it to bond and construct a mitigation project it cannot reasonably afford.  The City would never agree to this, and no court in the land would ever compel such a thing.  And so even if ultimately permitted by FERC, the project could never move forward to actual construction.  Third, the project as outlined requires extensive use of public landholdings, held by the State of New York.  The lands are held as a public trust under Article XIV of the State’s constitution, to be “forever kept as wild forest lands. They shall not be leased, sold or exchanged, or taken by any corporation, public or private.”  These lands of the Catskill Park have been so protected since 1885, and no one in State government has no intention of permitting their seizure by any authority for this or any other project.  That is why we have state and local governments and courts, and institutions entrusted with protecting the public interest. As for the potentially impacted lands and communities, the residents of this region are already speaking with a single voice in opposition to this project.  None of us are leaving our homes and lands to make this nightmare possible. 
  
In summary, I believe the applicant has demonstrated no likelihood and no ability whatsoever to receive the authorizations required to even prepare a license application for this project. Because the project cannot actually be constructed in any iteration of the real and shared world in which we live, I ask and urge you to deny the application for a preliminary permit. 
Thank you for the opportunity to comment.
Sincerely,

Brian Powers
30 Park Road, PO Box 52
Chichester, NY 12416

Carol Monteleoni, Olivebridge, NY.
As a resident of Olivebridge, New York, a rural community close to the Ashokan Reservoir, I am writing to express my opposition to the hydroelectric plant proposed by Premium Energy Holdings.  The proposed project with its upper basin and use of the Ashokan Reservoir, construction of dams and tunnels will have a significant negative impact on the local wildlife, natural resources, the homes and communities, and public lands which make our area so beautiful and peaceful.  I urge you to reject this proposal to retain valuable and fragile environment surrounding the Ashokan Reservoir.

Sincerely yours,
Carol Monteleoni

Marlene Castro, High Falls, NY.
I am against this project because it will negatively impact the quality of the water we drink. Also, it will dismantle the local communities and interfere in the wild life of the Catskills area.

Jess Bird, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jess

Val Zlatev, Phoenicia, NY.
Dear FERC staff,
Please deny the Premium Energy Holdings hydro project in the Catskills.  The Catskills are protected by the NYS constitution and this project is in direct violation of the NYS constitution. I regularly fish in the Esopus creek and this fishery will be very negatively affected by the proposed project.  We have a home in Woodland Valley and we cherish the moments we spend with our 2 kids there.  The last thing we want is for a private California company to seize our home and put it 100 feet under water.  We also have a place in NY City and the Ashokan reservoir provides 40% of our water.  This project will negatively affect our main source of drinking water.

Lemuel, Westborough, MA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
The United States of America’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Lemuel Amaral

Nancy N Parisio, Olivebridge, NY.
FERC Project Docket: P-15056

New York recognizes the need to take action towards a sustainable climate pathway by becoming 70% dependent on renewable energy by 2030.  However, the Ashokan Pumped Storage Project proposed by Premium Energy Holdings LLC is not a suitable part of that action.  The Ashokan Pumped Storage Project will cause irreparable damage to water resources in the Catskills.

As a whole, the Catskill/Delaware Water Supply meets 90% of the drinking water needs for 9.5 million people of New York City – one billion gallons per day of unfiltered water.  New York City is one of five major cities that has a surface water system that doesn’t require filtration.  The proposed high elevation reservoirs of the Ashokan Pumped Storage Project will almost certainly increase turbidity in the Ashokan Reservoir, through which 40% of New York City’s water supply passes, due to rapid fluctuations of water levels in the Esopus Creek tributaries.   Costs to create an upstate filtration system are estimated to be approximately $12 billion.

Now is the time for FERC to make the correct decision to deny Premium Energy Holdings’ application for a preliminary permit to conduct feasibility studies for the Ashokan Pumped Storage Project. 

Nancy N Parisio
241 Sheldon Hill Road
Olivebridge, NY 12461

Dorothy Solomon, Olivebridge, NY.
To:
Kimberly D. Bose

Federal Energy Regulatory Commission 

888 First St. NE, Room 1A

Washington, D.C. 20426

RE:  Docket number P-15056-000

Dear Ms. Bose,

I respectfully submit my response to the unsound and inaccurate proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would 

     have a devastating impact on the local environment 

     be highly disruptive to local communities and 

     create an unnecessary,and potentially hazardous effect on the purity of a  
     water supply that provides 1 billion gallons a day equaling 40% of New York
     City's drinking water. 

Even though pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the 700,000 acres of continuous wildlife habitat containing pristine, protected forests, streams, and wildlife of the Catskill Forest Preserve must not be sacrificed in the process. 

Under Article XIV of the New York State Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be an abhorrent act to destroy this sacred and wonderfully preserved land, and would set a catastrophic precedent for protected lands across the country.

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir. 

Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

Another key point in opposition to Premium Energy’s Ashokan Pumped Storage Project, is that their proposal does not represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and thus, are eligible for streamlined FERC approval. This is why Premium is falsely claiming this project to be “closed-loop” rather than what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would make false claims in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, threaten incredibly important natural resources, threaten the local ecosystem and displace vulnerable communities.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.  Thank you.

Sincerely,

Dorothy Solomon
Olivebridge, NY 12461

Leslie Cagan, Elmhurst, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am adding my voice to the many others urging FERC to reject the Premium Energy Holdings application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. Granting this permit could lead to the building of a hydroelectric power plant in the Catskill Mountains in New York which would be terrible for the environment, might make NYC’s drinking water less pure and be greatly disruptive to the local communities in the areas being considered.

Article XIV of the NY State Constitution clear states that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Catskill Forest Preserve has 700,000 acres of continuous wildlife habitat, and the forest ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Years of construction would negatively impact both the natural life of the Preserve and the lives and livelihoods of many families in the area. And once the construction is over there could be ongoing environmental problems related to the ways the Ashokan watershed and its tributaries are connected.
In addition, as I understand it, Premium Energy’s proposal is not really a closed-loop system but rather it is an “add-on,” and the water fluctuations could certainly increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

While I and many others are concerned about the effects on the environment and water supply, we are also very worried about the negative impact Premium Energy’s proposal would have on local communities. Any of the possible upper reservoir sites in the Catskill Forest Preserve would mean homes and private property will be seized by via eminent domain. People who lose their homes because of the Ashokan Pumped Storage Project would face the daunting challenging of trying to find new housing since there is a housing shortage in Ulster County, and homes that are on the market are very costly. 

Premium Energy’s project would certainly limit access to hiking, fishing, and other activities in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and generally reduce tourism in the region. The tourism industry accounted for 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 

Finally, the Premium Energy’s Ashokan Pumped Storage Project  proposal does not represent the type of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. 

I urge you and FERC to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.

Thank you.
Sincerely,
Leslie Cagan

Jeffrey Potent, Highmount, NY.
I am strongly opposed to the pumpstorage project proposed for the Catskill Mountain region of New York State. This project will have a deleterious impact on water quality that serves 9 million people by increasing turbidity and associated pollutants. It will also disrupt communities and destroy the natural habitat of the wilderness area that is part of the Catskill Mountain Park, one the first public parks established for the preservation of wildlife and wilderness in the United States.

John H Moore, Shokan, NY.
I'm writing in opposition to the proposed Ashokan Pumped Storage Project  (FERC Project No. 15056-000 ). The project as proposed has no clear benefit to the residents and businesses of the area in which it is proposed, describes an incomplete and flawed process, and will have a significant negative impact to the local environment.

The complete lack of input from and consideration of the impact on the local population is breathtaking. The listing of the twelve components of the project contains only one about mitigating "environmental and cultural impact" and no mention of benefit to the local populace [1]. This speaks to the fact that the proposers have no local connections, and in fact have not engaged any of the local stakeholders including residents, business owners, municipalities, New York State or the City of New York. This approach is wholly inadequate. The Biden administration is moving towards an infrastructure plan that integrates environmental justice into a restructuring of the energy sector and this proposal - by not coordinating with the local populace who will be impacted by the many externalities of this project - is totally out of sync. The only beneficiaries of this project are the company - Premium Energy Holdings - and their investors. 

Pumped Storage Hydropower (PSH) is an unproven technology and of questionable value to a well designed renewable energy portfolio. According to Power Magazine - an energy industry news source - 

"The industry notes, however, that the value of hydro and pumped storage hydro’s flexibility and reliability attributes are not fully understood. Like hydropower, the flexibility of pumped storage hydro has been historically constrained by the interaction of the turbines, the dam, the water flow, and the institutional agreements—and this has become increasingly critical as markets evolve to embrace more, potentially cheaper, wind and solar power.  “This results in sub-optimal designs and equipment, attrition of existing hydro resources, and stalled investments in new pumped storage hydro,” the DOE says." [2,3].

Power Magazine further goes on to describe how the US Department of Energy (DOE) is "looking to save hydropower" and that it is involved in "an effort to help the flailing industry counter stiff competition from wind and solar"[2].

Research into PSH is ongoing and standards and guidelines are just beginning to be established [4,5]. This proposal is vague about the ultimate customers of the energy storage resource, citing Independent System Operators in the northeast US [6]. In fact the value of PSH for black start operations is dubious at best [7]. Here again, a proposal such as this should not warrant serious consideration unless accompanied by collaboration and consent of local stakeholders.

Lastly, Premium Energy Holdings - a California corporation - is proposing a massively destructive build in an area wholly within New York State wilderness or wild forests. The proposed pumping stations would destroy the recreational value of these beautiful natural areas, most notably of the Ashokan Rail Trail [8] newly created and managed by Ulster County. The construction of the tunnels and upper reservoir would cause untold damage to the local ecosystem and provide an ongoing disturbance while operational.

I urge you to make certain that the above issues are addressed, and that any further feasibility study not proceed unless coordination with and consent of the many local stakeholders is obtained.


[1] Application For Preliminary Permit For The Ashokan Pumped Storage Project - FERC Project No. 15056-000, Exhibit 2, subpart 1.
[2] https://www.powermag.com/four-projects-picked-to-speed-up-pumped-storage-hydro-construction/
[3] https://www.wecc.org/Administrative/HydroWIRES-overview.pdf
[4] https://www.energy.gov/sites/default/files/2021/01/f82/hydropower-value-study-v2.pdf
[5] https://publications.anl.gov/anlpubs/2021/03/166807.pdf
[6] Application For Preliminary Permit For The Ashokan Pumped Storage Project - FERC Project No. 15056-000, Exhibit 1, subpart 1.
[7] https://www.energy.gov/sites/prod/files/2019/05/f62/Hydro-Black-Start_May2019.pdf
[8] http://ashokanrailtrail.com/

Sid Davidowitz, Upper Saddle River, NJ.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Daniel W Morgan, West Shokan, NY.
I'm writing in regard to the Application for Preliminary Permit P-15056 by Premium Energy Holdings, LLC. 

This preliminary permit should be denied for these reasons: 

• The land on which this project is proposed was designated Status 2 land by the USGS and not recommended for development. Each proposed dam site is listed in the inventory of USGS' PAD-US 2.1. 
• The application contains falsehoods that seek to expedite its approval: 
	• Falsehood 1: The project calls itself 'closed loop' when it is in fact 'open loop' and requires the disruption of a continuously flowing, high-value drinking water reservoir. The DOE has promoted closed rather than open loop projects; this dishonesty is careless. 
	• Falsehood 2: The proposal, wherever land ownership is mentioned, fails to mention that any land which would be flooded, disrupted, taken for high-transmission line construction, or required for the completion of the project is privately owned. Only 'New York State' or 'New York City's' lands are mentioned. Similarly, no mention is made of New York City's highly protected watershed, or the Delaware River Basin Compact, U.S. Public Law 87-328 of which Shandaken, NY is a member. 
	• Falsehood 3: The proposal presumes certain future occurrences which cannot be guaranteed, namely that the New York State Constitution will be amended to allow this project to be built and that the project will be greenlit for filtration avoidance by the US EPA. 18 CFR § 4.32(j) states that “Any application, the effectiveness of which is conditioned upon the future occurrence of any event or circumstance, will be rejected.” 
	• Falsehood 4: The proposal also claims that it would be used to store excess renewable energy in section 4: “The project would store excess renewable energy, helping to integrate renewables into the grid, and to supply firm peaking power generation with primary load following capability.” This region (powered by less than 6% renewable energy) does not produce an excess of renewable energy during peak generation times, nor do local power companies seek projects like this as they can provide reliable energy via transmission upgrades, not storage upgrades: https://www.cenhud.com//my-energy/our-energy-future/capacity-zone/. Energy storage would be primarily non-renewable sources, and represent an arbitrage opportunity for Premium Energy LLC. 

The proposal's many errors, blurry and incomprehensible maps with inaccurate GPS readings, incorrect town names, (Shokan City & West Hurley city do not exist), and dishonest omissions are a signal that Premium Energy LLC does not have the capacity to embark on a project of this magnitude. FERC should not trust them with The Catskill Forest Preserve or New York City's drinking water and I respectfully request that their application be denied. 

Sincerely,
Daniel Morgan

Nick Frattaroli, Boiceville, NY.
Hi, as a local resident I am not comfortable with the effects that this hydro project will have on our animals, forest and drinking water.  This also will negatively impact our area in terms of our home values.  Please do not do this.

Noah Kagan, New York, NY.
Docket number P-15056-000

Hello,
I am someone who grew up hiking and camping on the protected lands near the Ashokan Reservoir and Slide Mountain wilderness, and the lands of New York State that are now being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. I was truly dismayed to hear about this project, particularly the lack of transparency and community input that Premium Energy Holdings has engaged in. As such, I am vigorously opposed to the proposal and I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. The NYCDEP has come out objecting to the proposal, as have many local elected officials in NY State. Premium Energy Holdings did not engage with NYC, NYS, or localities before announcing this project. Any projects such as this one that begin without input from the local community, are in my opinion, doomed to fail from the start. The social, environmental, and economic impacts of these projects are enormous; we as a nation cannot afford to get these sorts of projects wrong, and this project is not right for NY. Please do everything in your power to prevent this proposal from moving forward.
Thank you,
Noah Kagan

corey adams, Boiceville, NY.
April 11, 2021

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000
 
Dear Ms. Bose,
 
I am writing to you, and everyone at FERC, about the Ashokan Pumped Storage Project P-15056.  I ask that this permit NOT be approved.  This project will adversely affect the place my family has chosen to settle, grow, raise our child, and retire. The proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains will destroy our ecosystem, endanger a reservoir that supplies drinking water for NYC, and greatly impact the local communities.  The benefits of this proposal do not outweigh the long term costs to our residents and our land. 
 
Weakness in the plan is evident:
 
·        Catskill Forest Preserve, wildlife and ecosystem are at risk. The Preserve contains 700,000 acres of continuous wildlife habitat protected by Article XIV of the NYS Constitution. It states, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  To move forward with the Pumped Storage Project would provide a precedent endangering all preserved land and the wildlife it supports.
·        NYC’s water supply serves a billion gallons of water daily to 9.5 million people. The Ashokan Pumped Storage Project will affect the sediment regime in one of the key creeks feeding into the Ashokan Reservoir, the Esopus Creek. 
·        Pumped storage damages stream ecology and on both aquatic and land habitats. Our home is part of the Ashokan watershed and we know how delicate the ecosystem is. Without a doubt, altering the water flow will adversely affect the communion between the Ashokan watershed and its tributaries.
·        Premium Energy’s proposal will be deeply damaging to local communities, which I am a part of. This project requires the use of eminent domain to take homes and property—a process that displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are not affordable for those that are displaced. 
·        The proposed project will definitely affect the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 
The connectedness of Rt. 214 between Ulster and Green counties will be damaged, impacting skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
 
There are plenty of reasons to argue against the Ashokan Pumped Storage Project.  The fact is that this project will directly harm our environment, our community, and our livelihood on both personal and county levels. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.
 
Sincerely,

Corey M Adams

PATRICK DIMILIA, West Shokan, NY.
    My family has owned a home in West Shokan, NY since 1950.The proposed dam for this project will be 2 miles up stream from the Bushkill creek whish   passes near our house. My family's is 100% against this project because of damage to the natural forest and water resources that will be caused by this hydro project. The land and water in the area of this project is part of the NY state forest preserve which protected to be forever wild by NY state constitution. This land where the project will occur is also part of the Catskill's watershed which flows into the Ashokan,brings unfiltered drinking water to millions in NY city. The this project will have negative effect on the quality of this unfiltered drinking water supply. I would like the FERC  to  reject this proposed project outright for the reasons mentioned above and numerous others. Thank out. Patrick DiMilia  



























































  



















5

Michael Rosenman, PLEASANTVILLE, NY.


Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Michael K. Rosenman
Pleasantville NY

Sondra Wolferman, Albrightsville, PA.
The Ashokan Reservoir Pumped Storage Proposal calls for the construction of three additional dams in an area of ecologically valuable land in the Indian Head Wilderness and Wittenberg Wild Forest areas, north and west of the existing Ashokan Reservoir in the Catskill Forest Preserve. 

Dams and reservoirs fragment aquatic ecosystems in the same way that roads and utility lines fragment forest ecosystems, often with disastrous results for the native flora and fauna in and around these facilities. Dams, reservoirs, and the operation of hydroelectric generators can change natural water temperatures, water chemistry, river flow characteristics, and silt loads, and obstruct fish passage. 

Surveys of the hydropower industry and its regulators have  found that the two biggest environmental issues facing hydropower plants in the U.S. are obstruction of fish passage and water quality degradation. Hydroelectric power plants can interfere with the movements of riverine fish in three general ways: (1) water velocities within the reservoir or flows released from the dam may be too low to allow migration; (2) the dam may create a barrier to upstream movements; and (3) resident or downstream-migrating fish may be drawn into the intake flows (entrainment) and suffer injury or mortality on passing through the turbine. The reduction in fish populations caused in part by migration barriers has caused some fish stocks to be declared in danger of extinction. (U.S. Energy Information Administration. Hydropower and the environment - U.S. Energy Information Administration (EIA) 

The Catskill Preserve is a world-class hiking, fishing, and outdoor recreation destination known globally for its extraordinary natural beauty, biological diversity, and historical features. Visitors come here from all over the world to experience one of the last unspoiled wilderness areas in the heavily industrialized eastern United States. 

While hydropower does not directly emit air pollutants, the manufacture of concrete and steel hydropower dams requires equipment that runs on fossil fuels, thereby adding to the release of greenhouse gases into the atmosphere. In addition, greenhouse gases such as carbon dioxide and methane form in natural aquatic systems and in human-made water storage reservoirs as a result of the aerobic and anaerobic decomposition of biomass in the water. 

When these emissions are factored into the equation, along with the damage to aquatic ecosystems, it seems highly unlikely that the public benefit of a pumped storage facility in the Catskill Preserve outweighs the negative impacts to the environment and to local economies that rely on good water quality for survival.

Anne E Glausen, Kingston, NY.
As a resident of New York with a home in the Ashokan Reservoir Territory and a supporter of the conservation of our fragile ecosystems, I oppose the Ashokan Pumped Reservoir Project in its entirety. This project will not only destroy neighborhoods and communities, it will also decimate our valuable ecosystems and the industries that rely on them, all while violating the constitution. The Ashokan Pumped Reservoir Project can not become a reality because it will end the reality and prosperity of the animals and people in the territory and the surrounding region.
The project is proposed within the Catskills Forest Preserve, with impacts on formally protected and ecologically valuable land. The U.S. Department of Energy itself has recognized that development on such lands should be avoided. The movement of water in pumped storage can affect the sediment regime and stream ecology, pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. This is of heightened concern, since excessive sediment is already a major issue affecting the Ashokan Reservoir and the quality of NYC’s unfiltered drinking water. The project would likely affect the 9.5 million residents of New York City and many Hudson Valley communities that rely on its drinking water. It also has significant implications on the health of the Esopus Creek and the communities on its banks, and to the communities that draw drinking water from the Hudson River. The region's trout industry would face extinction because the Esopus Creek is one of the Catskills’ most vital trout waters. Not only are the waters effected, but bird sanctuaries will be decimated and Preserved State Forest lands will be demolished. As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
This proposed project will destroy many communities such as the Town of Hunter, communities that have worked their entire lives to leave to the many future generations to thrive off of. This project will literally drown our neighbors' homes and businesses that have managed to grow without destroying what is left of the local lands and ecosystems. The proposal not only goes against our laws set forth to protect our land, but it goes against what the effected communities are willing to allow. This proposal can not be approved as it will kill more than it can create, it will destroy parts of this region and the surrounding area that can never be restored to as they are now.

Michael Wong, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Michael Wong

Todd Green, West Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
This proposal by Premium Energy appears to be in contradiction with the company’s stated mission which in part reads “… Premium incorporates community interests, aesthetic value, financial accountability, safety, and environmental stewardship [with a desire to develop long term and lasting relationships and a model for future projects]”.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,

Todd Green

Lynnette, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Lynnette Hernden

Steve Cunningham, Olivebridge, NY.
I am writing today in response - and in opposition - to the error-filled proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Forest Preserve. (Docket: P-15056-000)

I moved to this beautiful area in 2016, FROM California, home of Premium Energy. One of the reasons I moved here was the landscape. As I have made my home here, I have come to learn its history, and the price this area has already paid for “the Good of New York City.”

This proposal would not only be devastating to our area, but also would threaten the drinking water of New York City, those they purport to help.

In addition: Under Article XIV of the New York State Constitution, the lands of the Catskills Forest Preserve “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” So, in effect, Premium Energy has no standing to even PROPOSE this project. 

And, in addition, as the New York City Department of Environmental Protection put it: “Based on publicly-available information, it does not appear that Premium Energy has ever developed or operated any hydropower projects, and it is unclear whether it has the financial resources to address any problems it creates.” Does FERC really want to grant a permit to a company who has no idea what it's getting into, and put our entire community – and New York City’s drinking water - in peril?

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000. It would be devastating to the environment, our local communities, and put the purity of New York City’s drinking water at great risk.

Thank you,
Steve Cunningham, Olivebridge NY

Jeannette Estruth, Hudson, NY.
Dr. Jeannette Estruth
Hudson, NY 

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.


Docket number P-15056-000


Dear Ms. Bose,


I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.


While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.


Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.


In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.


As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 


Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.


Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,

Dr. Jeannette Estruth

Robert Munk, Chichester, NY.
To Whom it May Concern,

I am a resident of Chichester, NY in Ulster County, and I am writing to strongly oppose the granting of a preliminary permit to Premium Energy Holdings. I do support our nation’s transition to renewable energy, however, this is not the right way to to go about it.The Catskills will be irrevocably sullied, and the water supply of New York City shouldn’t be trifled with.  The harm that would be done is unlawful and in violation of the New York State Constitution. Further, Premium Energy does not provide the kind of innovation sought by the Department of Energy as its proposal is deficient and misleading. Premium Energy’s claim that it will build a closed loop-system is false. Their proposal is actually an open loop system, an add-on project where an upper reservoir would be added to an already existing lower reservoir connected to a natural water source.  As you know, the environmental and aquatic impact of such an open loop system would be significant and damaging. 
 
The company also falsely states that the project will take place outside the boundaries of the protected Catskills Preserve. Closer study indicates that its proposed sites are actually located squarely within the Catskills Forest Preserve (established 1885). This area is protected under Article XIV of the New York State Constitution, which deems the lands shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any changes in the management of State Forest Preserves have to be passed by constitutional amendment, which involves both state legislative approval and a public referendum. Otherwise, it is unlawful and unconstitutional. Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. According to the US Department of Energy’s own Hydropower Vision report, areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development. This is not preservation. This is profiteering. 

I believe the protected status of the Catskills Forest Preserve; the misleading nature of Premium Energy’s proposal; and DoE’s mandate to avoid Status 1 land are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.

Thanks for reading,

Robert Munk

Jacqueline Lyons, Thousand Oaks, CA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline Premium Energy Holdings’ request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be unconscionable to destroy this sacred and preserved land, and would set a damning precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to negatively impacting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Dr. Jacqueline Lyons
Thousand Oaks, CA

Jonathan Basker, Livingston Manor, NY.
I am fully against the proposed hydro dam project on the Ashokan. I don’t agree with how this proposal has been put forward without DEP involvement or oversight and lack of community input. I think this is a bad choice for NY and too damaging to our natural environment and an important part of our wild fisheries. Not only will that negatively impact our environment but also local businesses that depend on fishing and fishing tourism for revenue. Please don’t do this!!


Respectfully,
Jonathan Basker

Wendy Wolfenson, West Shokan, NY.
Docket P-15056
Premium Energy’s application for a Permit for the Ashokan Reservoir 

Numerous factual errors and omissions, in both the original and amended applications, all point to the conclusion that FERC should deny the application for Premium Energy’s Ashokan Pumped Storage project, P-15056.  There is no justifiable reason to allow this company, with its sloppy and incompetent application, to proceed with a potentially life-threatening and definitely community-altering project.

A few of the many shortcomings in Premium Energy’s application are:

1)	Some of the roads in the area are absolutely unable to sustain the level of heavy-duty construction required to build the project.  Specifically, Moonhaw Road, where the Wittenberg Dam would be built, has a weight limit of 20 tons on a bridge that would be traveled by construction vehicles hundreds of thousands of times.  Since the weight of a single concrete truck is 33 tons (13 for the truck and 20 for the cement alone), the project cannot be completed without upgrading and widening the access road.  This would involve taking additional residential property, on either side of that road, to create a road that can sustain the upper reservoir construction.  Premium fails to acknowledge this issue at all or to address who will be forced to pay for the road upgrade.  They neglect to address that many more separate residential properties will be diminished or taken entirely, simply for the project construction.

2)	Premium incorrectly lists “Ridgeline Timber Services” as a political subdivision and as only 1 of 2 local municipalities with an interest in the project.  First, Ridgeline is a company, not a municipality.  Of equal significance, Ridgeline has not had any contact with Premium Energy, Ridgeline’s name was used without permission and the owner is personally opposed to the project.  This speaks to an incredibly sloppy application process by Premium that should not be rewarded with a permit to proceed, least of all in an expedited manner.

3)	The Work Plan in Premium’s application (p. 19) states “Therefore, assessing the project site’s suitability for construction of the new dams.”  This is not even a sentence and makes absolutely no sense.

4)	Premium’s plan for the hydro-plant under the Ashokan Reservoir in West Shokan would place that plant roughly 500 feet from the only Public Library in the Town of Olive.  In addition to the traditional library functions, this particular Library serves as a public meeting site, assists with tax preparation, houses classes in music and art for children, teens and adults, presents movies, hosts art exhibits and is the repository of the Town’s historical artifacts.  Even though the 2-acre hydro plant will be located 300 feet underground, the disruption caused by the construction of such a huge facility will undoubtedly make access to the library difficult, if not impossible, for a period of years.  The nearest Public Libraries are 10 and 14 miles away and do not support functions specifically related to the Town of Olive.  Moreover, given the distance of these other libraries, it is extremely likely that seniors, many of whom have difficulty driving on unfamiliar roads and who benefit greatly from community activities, would suffer an especially acute loss.

5)	During the construction phase of the project, it is evident that NY State Route 28A (a 2-lane road) would need to be closed for long periods of time.  This road is the only direct means of travel from various points within the town.  Such a closure would necessitate drivers traveling around the Ashokan Reservoir.  This would turn an 8-minute drive for the nearest groceries and all schools into a 25-minute drive.  It would also negatively impact the ability for emergency services (fire, ambulance and police) to reach town residents and could create fatal consequences. 

6)	Premium continues to use maps that are fuzzy and vague in its amended submission, despite FERC’s request for clearer maps. The visual presentation obscures important facts of the application, specifically the relationship of reservoirs, dams and tunnels to local towns and private property.  The maps Premium submits incorrectly suggest that this is a proposal in an uninhabited area.  They fail to include existing roads, towns or other relevant facts that would enable residents to understand the proximity of the project to their homes, the potential to render their homes completely inaccessible or the likelihood that their homes would be taken by Eminent Domain.  It is evident from Premium’s website that they have access to excellent graphic artists.  The only conclusion one can draw is that Premium is being deliberately vague and confusing and/or is indifferent to the communities it proposes to harm.


7)	There is no mention that mitigation will be required for potential seismic activity.  Although Premium Energy acknowledges that it will perform Seismological Studies as part of the next phase, there is no indication that it will prepare a mitigation plan as well.  As recently as March 11, 2020, there was a 3.1 tremor in Glens Falls and on June 23, 2020, there was a tremor that was felt in nearby Kingston that “rattles building” (geo.mtu.edu).  In 1885, which is a tiny blip in geological time, there was a 3.4 quake in the area (ideo.columbia.edu).  Given the size and volume of the proposed upper reservoirs, a seismic event could be catastrophic to the downstream residents.  Premium needs to address this factor and prepare a detailed seismic mitigation plan before proceeding.

We cannot trust a company that is so inept and careless, at best, and deceptive and mercenary at worst.  The permit application of Premium Energy should be denied outright.  At a bare minimum, Premium should be compelled to resubmit their application, correcting any and all of the deficiencies. Premium Energy should not, under any circumstances, be allowed to proceed.

Wendy Wolfenson
April 11, 2021

Irene Jessica Upson, Forest Hills, NY.
Dear Ms. Bose,
I strongly urge FERC to decline the request from Premium Energy Holdings for a preliminary permit (Ashokan Pumped Storage Project P-15056) to build a hydroelectric power plant in New York's Catskill Mountains. This project is based on a deficient proposal with negative and lasting impacts on an inter-connected watershed, affecting natural habitats and communities miles and miles away. Further, the project is not accurately described; it is not a 'closed-loop' project, but really a project with an 'add-on' with an upper reservoir added to the loop. We are being lied to. 

The Catskills are an invaluable and incomparable source of beauty for New York. Every year thousands of visitors carve out time from their schedules for vacation, family gatherings, alone-time, and team-building activities in the Catskills because of it's beauty, serenity, proximity to NYC, and unique vibe. It would be an absolute shame if this incredible aspect of New York was ruined by a rushed and false proposal. New York deserves a truly innovative and sustainable alternative to the proposed project from Premium Energy Holdings. I urge you to take the time and get it right. 

Approving this proposal would set a doomed precedent for protected lands across the country.Please decline the request by Premium Energy Holdings' request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Thank you,
Irene Jessica Upson

Betsy Cowden, Gilboa, NY.
The proposed hydroelectric project will have a huge impact on the Catskills.  This area provides recreational opportunities including hiking, camping and sight seeing to not only NY residents but to adjacent states as well. The results of the devastation to this area will have a great economic impact on the Catskill region which depends on tourism for its success.  The project will displace homes, trails and camps along with the local flora and fauna.  

While the use of hydroelectric power is certainly a better option than burning of coal etc there are cheaper methods of obtaining the same results.   Wind and solar power are just as efficient and much less costly.

It is my hope that this plan will be dropped and the Catskill region can maintain its beauty for decades to come.

Thank you.

Nicholas Arbatsky, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,

As a resident and long-term property owner in Woodland Valley in the Town of Shandaken, I strongly object to Premium Energy Holding’s proposal and request that the Federal Energy Regulatory Commission deny their application for a preliminary permit. My family’s home valley is under proposed consideration as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and the generation of electricity.  The proposed project is an unprecedented large-scale disruption to the Catskill Forest Preserve, and if constructed, likely to damage local lands, wildlife, and streams causing increased turbidity to the waters that provide an unfiltered drinking water source for over nine million people in the New York City area. Over the last 27 years my family has adhered to the development restrictions that protect New York City’s drinking water and I question how the magnitude of Premium Energy Holding’s proposed project can safely address the mandates set forth by New York’s Department of Conservation to protect the water quality in our area.  My family owns three properties in Woodland Valley that will be flooded by Premium Energy Holding’s dam proposal and I’m concerned that the Town of Shanadken will be rendered uninhabitable to the majority of middle class families due to the loss of tax revenue generated from all the properties that will be destroyed in Woodland Valley.  

Our country’s transition to renewable, green-energy sources cannot come at the cost of environmental and community devastation.  I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project where the construction and operation do not destroy protected wilderness, displace thriving communities, and threaten the Catskill’s unique natural resources.  Please do everything in your power to prevent the Ashokan Pumped Storage Project proposal, docket number P-15056-000 from moving forward.

Laura Giles, BROOKLYN, NY.
Dear Ms Bose,

Our drinking water and health, as well as the natural integrity of our beautiful state, should never be for sale. As someone raising a young child in NY, I can’t help but feel betrayed by the public officials considering this proposal. I implore you to reject Premium Energy’s request to pursue a preliminary permit for the Ashokan Pumped Storage Project P-15056. It’s simply not worth the risk and the inevitable impact it would have on the nature that makes the Catskills so majestic and our lives here in NY healthy and safe. 

Sincerely,
Laura Giles

Leanne Avery, Olivebridge, NY.
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose:

In their 4/8/2021 comments submitted to FERC, the DEP comprehensively captured the magnitude of damage that would come from approving P-15056 where no precautionary principle was considered. In extraordinary detail, the DEP clearly described this poorly-conceived, inappropriate and dangerous project that puts 9 million people at risk by contaminating their drinking water (e.g., increased turbidity, toxic cyanobacterial blooms (Monger, 2021)). Moreover, P-15056 is inconsistent with our state constitution that forever protects the Catskill Preserve (Article XIV), does not adhere to FERC guidelines, is fundamentally flawed by the authors’ lack of understanding of close-looped systems, and is morally and ethically vacant.

Since the DEP has already demonstrated that P-15056 is highly problematic, I use my 6000 characters to shed light on the Complex Connectivity of Place and the toxic impacts that result from disrupting ecosystems, people, and place.

Context: My family has inhabited the Catskills since the 1700s. The Moonhaw site contains ruins of my family homestead. 

Background: I am a Professor of Rural STEM Education whose research entails documenting local rural knowledge connected to people, ecosystems and place.  I am a first generation college graduate of Cornell University whose land-grant mission is rooted in agriculture, history and place. As a former co-editor of a community development journal and NSF proposal reviewer, I evaluate proposals scientifically, realistically, critically and pay particular attention to how authors adhere to guidelines. Thus, I evaluate the Ashokan Pumped Storage project through a “whole-cost” lens. My familiarity with processes by which corporations make proposals that wrongfully place the burden of proof on communities impacted (CDER, 2021), also informs my perspective. 

Complex Connectivity of Place: Connection between people and place is extremely complex and well-documented in Indigenous and non-Indigenous literatures (Basso, 1996; Fikret & Berkes, 2008; Kassam, 2009:2020; Joppa, et al, 2016; Smith, 2013; Ruelle et al, 2019) and neuroscience and environmental psychology alike (Hebgeb & Kistemann, 2012; Rollero & DePiccoli, 2010; Williams & Seward, 1998). “Socio-cultural and ecological systems are linked through relationships between people and their environment, which includes both relations between humans and relations between humans and other animals, plants and their habitats [Wohlleben, 2016]...thus illuminating the complex connectivity of human ecological relations" (Kassam, 2010, p. 2). These connections begin at an early age as evidenced by photodocumentation interviews with 100 NYS rural children (Avery & Kassam, 2011), and include social, emotional and behavioral components. Research also shows that the cognitive relevance of Indigenous and rural knowledge is critical to survival (Kassam, Avery & Ruelle, 2017). Knowledge, memory, stories, identity, and community is intertwined with, and attached to, place (Avery & Hains, 2017).  Significant interactions between people and the natural environment have been recognized as cultural landscapes (UNESCO, 2021). Simply put, place is more than a zip code.

Context matters: This region was taken by eminent domain in the early 1900s to build the Ashokan Reservoir. The towns of Olive and Hurley including villages/hamlets of West Hurley, Glenford, Ashton, Olive Branch, Brown's Station, Olivebridge, Olive City, Brodhead's Bridge, Shokan, West Shokan and Boiceville, were taken or relocated. These rural communities' sense of place, identity, and their alternative ways of knowing and being that are in relationship with the ecosystems - were disrupted or forever lost in the flooding. We were then colonized for water, and now energy (Beisaw, 2016; Thomas, 2015). P-15056 involves a for-profit corporation from California inaccurately using a map program to situate a project that will again disrupt communities, ecosystems and place. This project aims to again colonize the same rural communities and repeats the intergenerational trauma caused by the first takings (Avery, 2019). Disruption from place is an evisceration, not a change of address. 

Renewable energy production/storage is an important infrastructure to consider and how/when/where it is done, is equally important. The research and arguments herein suggests that multiple ways of knowing drawn from diverse sociocultural and ecological contexts contributes to conservation values that must inform effective sustainability practices (Kassam & Avery, 2013). P-15056 is devoid of these epistemological and ontological understandings.

Lastly, as a Commission whose charge is to protect people from harm, FERC must realize that this comment process disenfranchises community members who do not have access to technology, high speed internet or deliberative public spaces. Our elderly (intergenerational trauma survivors from the first taking) need to engage in face-to-face public discourse to make key decisions. This comment process does not allow all voices to be heard. 

Summary: P-15056 is an ill-conceived morally and ethically vacant proposal. Our community has spent 1000’s of hours researching this, seemingly more than Premium Energy spent writing multiple submissions. I find this offensive. 

For the reasons set forth herein, I respectfully request FERC reject this proposal once and for all, and put an end to this incompetent endeavor before it damages the NYC Water Supply System, environment, people, and place. FERC has the power to prevent these harms, and an ethical responsibility to do so.


Sincerely,

Dr. Leanne M. Avery, Olivebridge, NY 12461

References cited are available upon request.

Anne, Chichester, NY.
To whom this may concern:

As a New York City resident and second home owner in Chichester, NY in Ulster County, I am writing to oppose the granting of a preliminary permit to Premium Energy Holdings. Although I do support clean, renewable energy and the push to move away from fossil fuels, I do no think the plan by Premium Energy Holdings is the right way to enact this change and should not be approved by the Department of Energy.

The areas they have chosen in the Catskills are not only state protected forest lands, but also connect to the Ashokan Reservoir which supplies 93% of the usable water in New York City to its residents. Any tampering with this land and the streams that run into the Ashokan Reservoir could greatly impact the largest city in the United States. 

After Hurricane Irene, millions of dollars were spent in order to stabilize the land from erosion and turbidity in the areas that Premium Energy Holdings wants to disturb. This will not only affect local residents and New York City residents, but will greatly impact the wild life in these areas that is also protected by the state. 

It is my understanding that under the New York State Constitution that this proposal is in direction violation of using state protected lands for public or private gain.

Every year the Catskills brings in more and more tourists from around the state and the country for its natural beauty and also for the charming towns that exist in the area. Phoenicia is one of the most popular destinations in the Catskills along with its two ski resorts at Belleayre and Hunter. Any proposal to block off sections of these areas via construction on roads such as 214 would drastically inhibit the amount of travel in these areas which would be a huge strain on the local economy.

I ask that you take into consideration all of these reasons to oppose the preliminary permit for Premium Energy Holdings.

Sincerely,
Anne Kohlhagen

Catherine White, Roxbury, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Dear Secretary Bose,

I am writing as a homeowner in the Catskill Mountains and a part-time resident of NYC to urge FERC to decline Premium Energy Holding’s request for a preliminary permit for the Ashokan Pumped Storage (Project P-15056). As someone who is currently studying climate science, I recognize the urgent need for renewable energy storage at scale, and understand that our communities will need to make sacrifices for our clean energy future. However, flooding the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve—which protects biodiversity and acts as an important natural carbon sink—is not the answer. The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

As a NYC resident I am also concerned about potential impacts to the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. New York City Department of Environmental Conservation invests heavily in purchasing land in this area in order to protect the water supply for the longterm. Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

My understanding of the proposal is that it is not “closed-loop” as it claims, but an add-on to an existing reservoir. This makes me question Premium Energy’s transparency and methodologies. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Catherine White

Angel Molina, Pine Hill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to DECLINE their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Therefore, incorrectly stated that this by the applicant that this is a closed loop system, when in fact the Ashokan Reservoir is connected to many tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. 

Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities and their economies. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. 

How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and DENY Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Angel Molina

Catherine White, Roxbury, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Dear Secretary Bose,

I am writing as a homeowner in the Catskill Mountains and a part-time resident of NYC to urge FERC to decline Premium Energy Holding’s request for a preliminary permit for the Ashokan Pumped Storage (Project P-15056). As someone who is currently studying climate science, I recognize the urgent need for renewable energy storage at scale, and understand that our communities will need to make sacrifices for our clean energy future. However, flooding the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve—which protects biodiversity and acts as an important natural carbon sink—is not the answer. The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

As a NYC resident I am also concerned about potential impacts to the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. New York City Department of Environmental Conservation invests heavily in purchasing land in this area in order to protect the water supply for the longterm. Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

My understanding of the proposal is that it is not “closed-loop” as it claims, but an add-on to an existing reservoir. This makes me question Premium Energy’s transparency and methodologies. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Catherine White

Daniel Melnick, Saugerties, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you - 
Danny Melnick
Saugerties, NY

Adrienne Larys, Troy, NY.
I write to oppose the Ashokan Reservoir Pumped Storage Energy project proposed by Premium Energy Holdings, LLC of California. Project Docket # P=15056.

The application to FERC is poorly conceived and appears to show complete ignorance of the purposes of the Ashokan Reservoir and the constitutionally protected Catskill Park. While it is important for this county to prepare for a future that is less reliant on fossil fuels, the installation of such an energy generation plant in the middle of the Catskills and Catskill Park is not environmentally sound. 

The Ashokan reservoir is a significant source of fresh, clean drinking water for 9 million people in the New York Metropolitan area. The New York Department of Environmental Protection has invested billions of dollars in preserving the purity of the famed Catskill water. A pump storage hydro-electric plant situated to draw water from an upper reservoir and drain it into the Ashokan to generate electricity will increase turbidity — something that will affect the quality of the water for the downstate residents and the ecology of important protected trout fisheries and other plant and animal habitats, let alone destroy the natural and historically significant landscape for which the Catskills have been enjoyed and celebrated since the early 19th century. The Catskills relatively speaking do not encompass a very large area. What may seem like small incursion will be grossly magnified and have a wide impact.

Any of the three proposed upper reservoirs will have even greater impact both upstream and downstream from the dams, destroying the very environment the NYS Legislature sought to preserve when it created the Catskill Park in 1904. 

Water is vital to all life on earth. The Catskills have been shaped over the eons by the forces of climate and geology to create a place that is undeniably extremely rich in this vital natural resource. It must look tempting to a company from California where water is not an abundant natural resource.

Worldwide, dams themselves are altering the very way our entire planet functions. According to a PBS documentary series on water: “H2O, The Molecule that Made Us”, the sheer number of dams that have been constructed world wide, with China and the United States in the lead, has had a measurable effect on the planet. There are nearly 24,000 large dams in China, and a total of 84,000 dams in the United States. This impounding of large volumes of water is a major concern for the planet and for the world wide management of this precious resource. It has been determined that the sheer weight of the water behind all these dams is altering the shape of the planet and changing its rotation.

I am not a scientist or engineer, but I love the Catskill Mountains and the Catskill Park. I have hiked its peaks and explored its valleys. I am the president of a small historical society in the Catskills. We work to preserve the heritage and legacy of the people and the environment of the Catskills. Building the proposed Ashokan Pumped Storage project and damming up one of three protected valleys will irreparably damage the beauty and health of the Catskill Park, including the forests, fields and pristine streams that run down its valleys and mountain sides. 

Pump storage hydroelectric projects may be inevitable and necessary but planning them carefully and avoiding at all costs a deleterious impact on the people, their neighborhoods, and the environment is imperative. Please reject the Premium Energy Holding, LLC proposal to build the Ashokan Pumped Storage Project. Thank you.

Pamela Moulton, New York, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, but this in an inappropriate project for this area.  It will affect the pristine & protected forests, streams, and wildlife of Catskill Forest Preserve. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. I have seen the negative effects in the Housatonic River in NW CT, where a pumped storage system is in place.  This can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Our drinking water in NYC already suffers when water levels fluctuate and there has been a lot of runoff.  Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Pamela Moulton

Hiroko Sakurazawa, Bearsville, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Jeffrey C Schwartz, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply 
flawed proposal by Premium Energy Holdings
to build a hydroelectric power plant in 
New York’s Catskill Mountains. 
I urge FERC to decline their request for 
Aza preliminary permit for the Ashokan 
Pumped Storage Project P-15056, as it 
would be devastatingly harmful to the 
residents and the area.

I am sure you have received many comments 
indicating the following

Application is flawed and inaccurate in 
describing the project (not a closed loop 
system)

Bad for the area
Bad for the current residents
It is proposed to be built on protected land.
Increased turbidity and Will effect New York
City drinking water.

AN ITEM THAT YOU MUST BE CONCERNED WITH IS

THE POSSIBLE FAILURE OF THE PROPOSED DAM.

Just look in the recent news of failed man made dams.

Look at videos of the water volume during 
and post hurricanes in this area.

Normal spring thaw brings a large volume 
of water through the area.

The 100 and 500 year floods are more common.

Act wisely and deny this application now.
You do not want to regret your decision later.

Thank you for your time.
Aileen and Jeff Schwartz

Judith Hannon, Rochester, NY.
I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Peggy E Reynolds, Lanesville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Additionally, as a homeowner in Lanesville, one whose property would be completely inundated were the Stony Clove site to be approved for a pump-storage reservoir, I have a personal interest in FERC’s decision on this matter. 

Other letter writers have already pointed out the many reasons why Premium’s filing should be rejected: deficiencies in its composition e.g., mischaracterization of the project as a “closed-loop” system, inaccurate sketches of affected areas; the threat it poses to the unique character and protected status of the Catskill Park wilderness area; the havoc that would be wreaked on local economies and on the drinking water of 9 million New Yorkers; the historical abuse suffered by local communities as a result of projects of this nature. 
 
These and related arguments are sound and informative and do not need to be rehearsed again here.  I only wish to add that Premium Energy Holdings has not earned the right, in my opinion, to be given exclusive rights to the installation of hydropower projects in this area.  Even before any feasibility study has begun, they have already lost the trust of local communities by: seemingly putting a minimum of effort into the composition of their filing; appearing to have willfully mischaracterized the nature of the project; and by failing to do any outreach to stakeholders including, but not limited to, the DEC, DEP, local communities and individuals likely to be directly affected  by the project.  Indeed, recognizing the opprobrium that has been directed towards Premium as a result of this behavior, it’s CEO has announced his intention to withdraw their proposal; however, as of this writing, he has yet to do so.  Trust is a necessary ingredient in any project of this size and scope and Premium has already squandered any opportunity they might have had to gain it.

For all the above reasons, I urge you in the strongest terms to reject this filing.

Peggy Reynolds, PhD

Josh A Massicot, Rochester, NY.
We are avid hikers and naturalists in the Catskills and members of the Catskill 3500 club. While we support a move toward green energy, this alarming proposal is not the way forward.

1. All of the proposed locations are within the Catskill Forest Preserve, which is protected as “forever kept as wild forest lands” that should not “be leased, sold or exchanged, or be taken by any corporation, public or private” by the NYS Constitution. The forest around the proposed sites is among the top 1 percent of forest habitats region-wide according to the New York State Forest Condition Index.

2. This proposal has substantial ecological trade-offs. In addition to claiming protect land, rapid fluctuations in water can wreak havoc on the ecologically rich areas where terrestrial and freshwater ecosystems overlap. Reservoirs produce methane: Hydropower Vision acknowledges that more research is needed on this issue. Additionally, pump storage is a net consumer of energy - pumping water up takes more power than it can make going back down.  

3. The proposal from Premium Energy Holdings contains inadequate information. There are vagaries in the proposal as to the type of pumped storage system being used (closed-loop vs open-loop). They seem to have done little preliminary research about the areas they’re proposing to develop, many of which are crucial homes to wildlife and are designated a Status 1 area by the USGS Gap Analysis Project.

There is a right way to do this. This is not that way. I am confident that a company earnestly working towards clean, renewable energy would be interested in partnering with community stakeholders toward a better, more sustainable, more efficient, and more responsible solution.

Elizabeth Ristow, Rochester, NY.
My husband and I are avid hikers and naturalists in the Catskills and members of the Catskill 3500 club. While we support a move toward green energy, this alarming proposal is not the way forward.

1. All of the proposed locations are within the Catskill Forest Preserve, which is protected as “forever kept as wild forest lands” that should not “be leased, sold or exchanged, or be taken by any corporation, public or private” by the NYS Constitution. The forest around the proposed sites is among the top 1 percent of forest habitats region-wide according to the New York State Forest Condition Index.

2. This proposal has substantial ecological trade-offs. In addition to claiming protect land, rapid fluctuations in water can wreak havoc on the ecologically rich areas where terrestrial and freshwater ecosystems overlap. Reservoirs produce methane: Hydropower Vision acknowledges that more research is needed on this issue. Additionally, pump storage is a net consumer of energy - pumping water up takes more power than it can make going back down.  

3. The proposal from Premium Energy Holdings contains inadequate information. There are vagaries in the proposal as to the type of pumped storage system being used (closed-loop vs open-loop). They seem to have done little preliminary research about the areas they’re proposing to develop, many of which are crucial homes to wildlife and are designated a Status 1 area by the USGS Gap Analysis Project.

There is a right way to do this. This is not that way. I am confident that a company earnestly working towards clean, renewable energy would be interested in partnering with community stakeholders toward a better, more sustainable, more efficient, and more responsible solution.

Sam S Spata, Shandaken, NY.
This project will negatively impact NYC drinking water and the quality of life throughout the town of Shandaken, for which I am a member of Planning Board.

The process of assessing project feasibility will place all home values and project developments in limbo for yours, stifling recovery of our tourist economy just when threat of COVID 19 appears to be lessening.

The Catskills are a State Preserve protected by the NY State Constitution as forever 'wild'. Most land in Shandaken is owned by NY State and the City of New York. This project will destroy long-standing communities.

It would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water.

It would be detrimental to our local community by disrupting our economy and displacing residents.

Alexander Miller, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alexander Miller

Thomas Parker, OLIVEBRIDGE, NY.
Kimberly D. Bose
FERC
888 First St.
Washington, D.C.  20426                                                                                                    April 10, 2021

Docket #P-15056-000

Dear Ms. Bose:

I am writing to voice my strong opposition to Premium Energy Holding's proposal to build a hydroelectric power plant int New York's Catskill Mountains.

The application is inaccurate many times over. Referring to the project as a “closed loop design” is ludicrous. The Esopus Creek runs into the Ashokan Reservoir. The Ashokan Reservoir would be looped into the proposed new reservoir. It is an “add-on” design with worse negative environmental impact.

The proposed site is located in the Catskill Forest Preserve. Article XIV of the NYS Constitution precludes implementation of this proposal. Premium Energy would have to succeed in passing a NYS constitutional amendment, requiring passage in both legislative houses and a sigh-off by the Governor. There would be no public support for this.

I am all for transitioning to green-energy sources. This is not the way to do it.

Thank you,
Thomas Parker
50 Weber Lane, Olivebridge, NY 12461

Ellen Helman, Martinsville, NJ.
Proposed Woodland Reservoir  P-15056

In 1973 my family discovered Phoenicia, NY. My father Robert Marschall, built a vacation home on Fawn Hill Road. At that time, we were a family of 7; 2 parents and 5 teenage kids. We spend a lot of time in the area, taking advantage of all Ulster County has to offer: Belleayre Mountain Ski Area, Belleayre Lake, North Lake, hikes to Kaaterskill Falls, Fishing and Hunting, etc. We took advantage of great restaurants in Phoenicia such as Sweet Sues, The Sportsman and Al’s. We contributed to the local economy at that time and we continue to contribute. Our family has now grown to 4 generations and over 30 people. The house is still there and it is used more than ever. During the pandemic almost everyone spent time there enjoying the wide-open spaces and again frequenting the newer establishments: The Phoenicia Diner, The Woodstock Brewing Company, Bread Alone Bakery, as well as the old established companies.
Knowing that Ulster County and specifically Phoenicia have shown incredible growth in tourism I would think this would not make it an ideal area to put the proposed Reservoir.
Through the 48 years that we have owned the house we have seen the economy of the area ebb and flow. Stores and Restaurants have open and then closed but in this past few year it has been up and remained up. Ulster County contributes a large portion to the tourism revenue and vacation home owners contribute millions of dollars to this percentage. 
Flooding an area of the Woodland Valley would not only have a Financial effect but also an Environmental effect on the area. This would have truly a negative effect on the Esopus Stream and the Fly-Fishing industry. 
There are countless negatives to this proposal that should put this area out of the running. 
Sincerely,
Ellen Helman
Fawn Hill Road Phoenicia, NY

Donad Sandor, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Bald Eagles have taken up residence in the proposed Woodland Valley creek area.  They have been sighted and photographed multiple times. The Code of Federal Regulation Title 50 Chapter 1 Subchapter B Part 22.12 prohibits anyone  from "taking" bald or golden eagles, including their parts*, nests, or eggs.  By definition in Part 22.3 of the same document, “Take” includes pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb. "Disturb" means: “to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, 1) injury to an eagle, 2) a decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior."
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Donald Sandor

Elizabeth Sandor, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
Bald Eagles have taken up residence in the proposed Woodland Valley creek area.  They have been sighted and photographed multiple times. The Code of Federal Regulation Title 50 Chapter 1 Subchapter B Part 22.12 prohibits anyone  from "taking" bald or golden eagles, including their parts*, nests, or eggs.  By definition in Part 22.3 of the same document, “Take” includes pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb. "Disturb" means: “to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best scientific information available, 1) injury to an eagle, 2) a decrease in its productivity, by substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior."
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Elizabeth Sandor

Barbara Becker, West Shokan, NY.
27 Dry Brook Road
West Shokan, NY 12494

24 Monroe Place, #1D
Brooklyn, NY 11201

April 11, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426

Re: Docket # P-15056-000

Dear Ms. Bose: 

As a homeowner in both West Shokan, Ulster County, New York and Brooklyn Heights, Kings County, New York, I am writing to oppose the proposal by Premium Energy Holdings, LLC, of Walnut, California, as submitted in Docket #P-15056-000 for an Ashokan Pumped Storage Project, to build a reservoir, dam, pumping station and high-voltage electricity lines in Ulster County. I appeal to the FERC to seriously consider all the reasons why this proposal should be rejected, and then to reject it. 

As others, including individuals, Ulster County and the New York City Department of Environmental Conservation have outlined in great detail, there are numerous reasons why this proposal should not be granted. While all are greatly important to me, I cite below in brief a few that are of gravest concern.

* The proposal itself is, in its essence, deeply flawed. It endeavors to categorize the project a “closed-loop” one, when in fact it most obviously is not, but rather is clearly an “add-on” to the existing Ashokan Reservoir. That gross misrepresentation alone should be grounds for rejection.

* If conducted, a project of this magnitude would have devastating environmental impact. It would impinge on protected Catskill Forest Preserve land and waters, severely and permanently damaging land and aquatic species. 

* If conducted, this project, from the outset of construction, would threaten the quality of the 1 billion gallons of drinking water provided every day to 9.5 million residents of New York City. The Ashokan Reservoir is the largest unfiltered water supply in the nation. Tampering with its quality and that of the many clear-running feeder creeks that supply the extensive watershed would be senseless.

* If conducted, this project would once again have a horrific impact on the local community. You are no doubt familiar with what happened about 100 years ago when the Ashokan Reservoir was built — land seized, entire communities, including cemeteries, flooded, farms and livelihoods lost; our local area is still feeling the difficult after-effects of that devastation. If the Ashokan Pumped Storage Project were to proceed, history would repeat itself, but in much greater magnitude. My own 200+ year-old home, which survived that first seizure, lies perilously close to the proposed site in West Shokan, and would likely not survive this round of eminent domain. And I am only one of many homeowners who would suffer this way.

For all the reasons above, and many others of which you are no doubt aware, I respectfully request that Premium Energy’s proposal — and similar proposals from other companies that you may receive in the future — be summarily dismissed.


Sincerely,

Barbara E. Becker

27 Dry Brook Road, West Shokan, NY 12494
24 Monroe Place, #1D, Brooklyn, NY 11201

Philip Monteleoni, Olivebridge, NY.
As a long time Ulster County resident and former Board Member of the Rondout-Esopus Land Conservancy, I want to voice my strong objection to the proposed Premium Energy project to build a reservoir in the Catskill mountains adjacent to the Ashokan Reservoir.

This project proposes to expropriate people's dwellings, excavate trenches across private properties and disrupt a very peaceful, esthetic and deeply rural mountain community by shoehorning into it an industrial scale project.

Even the massive equipment's noises when operational will be a major intrusion into the environment, noxious alike to humans and animal life.

An additional negative feature of this proposed project is to tamper with water that is intended to be used as drinking water, unfiltered by permit, for the entire New York City metropolitan area. How many people will welcome drinking from water that has been used to spin turbines? Yuk!

Ruth Rich, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Ruth Rich

Sabrina B Taylor, West Shokan, NY.
4/11/2021
Sabrina Taylor
23 Waldorf Ct 
Brooklyn NY, 11230
thenightowlbaker@hotmail.com
718 233 7574

Kimberly Bose
Federal Energy Regulatory Commission
888 First St NE, Room 1A
Washington, D.C. 20426

Docket Number P-15056-000

Dear Ms. Bose,

How shocking and upsetting it is to have to respond to the proposal made by Premium Energy Holding. It is shocking that they would want to build a hydro electric power plant in the highly protected Catskill Preserve. It’s upsetting that the many people, agencies and local governments in this region were uninformed and ignored by the Premium Energy Holdings Ashokan Pumped Storage Project.

I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage project P-15056, as it would be devastating to the environment, highly disruptive to local communities and their economies, and risky for the purity of NYC’s drinking water.

I understand that for now pumped storage and hydroelectric projects will be a component in our countries transition to renewable energy. In my opinion more research and innovation must be done to provide for better more effective systems for renewable energy. It is so important that our countries transition to renewable energy not come at the expense of the valuable resources we currently hold dear. Environmental and community devastation for an expensive net consumer of energy and methane gas producing project does not seem like a smart trade off.

Ashokan Pumped Storage Project by Premium Energy is not a closed loop system, as they claim in their proposal. It is in fact an Add-on. This is a system not recommended in the DOE’s own guidelines. This system would interconnect with the Ashokan watershed and it’s tributaries. Pumped storage is notorious for wreaking havoc with nearby stream ecology on both land and aquatic habitats. The Ashokan Pumped storage project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills most vital trout breeding waters and a key creek feeding the Ashokan Reservoir. It would also obliterate the Wittenberg Creek a wild trout breeding area. The Ashokan Reservoir supplies 40% of the water supply for NYC. It is the largest unfiltered water supply in the nation and is NYC most valuable capitol asset. It would be reckless to allow a project to proceed that would threaten such a valuable commodity that represents 1.7 Billion dollars in investments since the 1990’s
We must speak for the trees and in the Catskills we have. The Catskill forest Preserve created in 1885 is status 1 protected land. 700,000 acres protected under article X1V of the New York State constitution. It is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold ,or exchanged, or be taken by any corporation, public or private.”

The forest in and around the proposed sites ranks among the 1% of forest habitats region wide. The US government and the NYS and City government  have spent millions of dollars to maintain and preserve these highly precious lands. We are in a struggle to save our planet from environmental catastrophe and the remaining forests are a lifeline in this effort. It is illogical for FERC to even consider projects of this order of magnitude without careful review of the pros and cons of such a venture.  

In addition to the negative effects on the water supply and environment, 33 towns and Native lands were already sacrificed to build the Ashokan Reservoir. Once again homes and private property would be seized by eminent domain. New housing would be hard to come by as there is a housing shortage in Ulster county, and due to the Covid 19 crisis there has been a buying frenzy leaving even less inventory available. The negative effect on the Catskills growing tourism economy would be enormous. 17% of employment come from this sector and Ulster County represents 43%. This is a 1.6 billion dollar industry supporting roughly 20,000 jobs. Premiums Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills and decrease the areas natural beauty. Trucks on the roadways, construction and chaos will dampen tourism throughout the region, negatively affecting businesses in Ulster county and beyond.

My hope is that Premium Energy will be able to find a more suitable alternative location for a pumped storage project, and that FERC will continue to innovate green energy alternatives. Projects where the construction and operation will not destroy protected wilderness, displace vulnerable communities and threaten incredibly important resources for our planet.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for Ashokan Pumped Storage Project P1-15056.

Sincerely,


Sabrina Taylor

Linda Werner, OLIVEBRIDGE, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street
Washington, D.C.  20426                                                                                                    April 10, 2021

Docket #P-15056-000

Dear Ms. Bose:

I object to Premium Energy Holding's proposal to build a hydroelectric power plant in New York's Catskill Mountains.

The application itself is deficient and misleading. 

Premium Energy states that the project is a “closed loop” design. It is an “add-on” design with increased negative environmental impacts. Note position of Esopus Creek in relation to Ashokan Reservoir. Note position of Ashokan Reservoir to proposed new reservoir.

Towns referred to are non-existent. There is no Shokan City, West Hurley City or West Shokan Town. Ridgeline Forest Services is a private business, not a political subdivision.

The proposed site is located in the New York State Catskill Forest Preserve. Article XIV of the NYS Constitution states the land “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Project implementation would require a NYS constitutional amendment. That requires passage of both legislative houses and a sign-off by the Governor, none of which would garner public support.

The Catskills are designated Status 1 under the USGS “Gap Analysis Program” which, according to the US Department of Energy's own Hydropower Vision, is to be ”...avoided for development.”

The increased turbidity would negatively impact the drinking water of 9 million New York City residents.

Premium Energy states the project would involve public lands,while their GPS co-ordinates reveal private properties as well, which brings up eminent domain issues.

The Ashokan Reservoir was created over 100 years ago by completely uprooting and/or removing existing towns, homes, businesses, cemeteries, and people. I believe this fact contributes to the Town of Olive's daunting activism as verified not only by voter turnout but its resident participation in all issues presented, including years of court battles with New York City. Let's not add insult to injury.

I do understand the need for transition to green-energy sources. This proposal does not land in the solution for this transition. Quite the opposite. I urge you to reject the Premium Energy Proposal for a preliminary permit for Ashokan Pumped Storage Project P-15056.

Respectfully submitted,
Linda L. Werner
50 Weber Lane, Olivebridge, NY 12461, (845)657-6467

Brian Sandor, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Brian Sandor

Jeffrey Martin, Chichester, NY.
Dear Ms. Bose,
I am writing as a property owner in Chichester, New York, to voice my strong opposition to any of the alternative proposals for a hydroelectric power plant and reservoir located within the Catskills Forest Preserve. My property is located near, adjacent, or at the proposed Alternate 1 Stony Clove reservoir. I urge FERC to decline the request for a preliminary permit by Premium Energy Holdings for the Ashokan Pumped Storage Project P-15056. I believe that this project would be devastating to the environment, highly disruptive to my local community, and a risk to the purity of NYC’s drinking water.  
As a professional landscape architect, I am acutely aware and proactively supportive of our country's transition to renewable energy. I have fought against proposals by energy suppliers in New York City to build new fossil fuel peaker plants that would only delay our needed transition to renewables and instead support proposals, such as Renewable Rikers, that conceive of a clean energy future. This to say, I believe that it is important to consider all options to move our country to a renewable energy future but the pristine protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. The Stony Clove Notch has gone undisturbed since the 1894 publication The Catskill Mountains: The Most Picturesque Mountain Region on the Globe said that “surely no visitor to the Catskills will care to miss a trip through the Stony Clove”. That rings as true today as it did in 1894, mostly because the Notch and Creek have avoided development and have maintained a pristine and natural setting. Any time of the year, you will find local residents, vacationing New Yorkers, and tourists from afar, mingling on our hiking trails, skiing on our mountains, and fishing in our creeks. All three alternatives would negatively impact our environment, our lifestyle, and has the potential to destroy our most pristine resource, the drinking water to 9 million residents of New York City. 
Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. It would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. 
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Jeffrey Martin
364 NY 214
Chichester, NY 12416

Natira Silva, Gardiner, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Natira Silva

Gayle Panzenbeck, Windham, NY.
I am writing this comment in response to docket P-15056. 

Please deny the permit to Premium Energy Holdings,LLC.

The proposal for the hydroelectric plant in the Catskill Forest Preserve is not wanted here on this pristine mountaintop.  It is protected under the NYS Constitution.

It will uproot people from their homes which is a terrible thing to do to people, and families. You can't possibly imagine what that is like unless it happens to you.

It will effect stream ecology, plant and animal species, and trout fishing.  The Catskill Park is an important bird area as noted by the Audubon Society.

In the early 1800's people came by train from NYC to look at nature as a revitalizing escape from crowded, unhealthy, conditions. Before cars they boarded horse and buggies to climb up to the top of these mountains. We that live here now know why they came: beauty, exercise, and fresh air.   As of late there are more people coming here for the serenity and to escape the crowded city bombarded by the covid epidemic.  Very similar to the need to leave in the 1800's.  

It is a majestic place to just BE.  

People that live, visit, and have 2nd homes here cherish it for the exact same reasons. They come from states all around and southern states as well.  They come to fish, hike, ski, relax, hunt, play golf. Tourism brings revenue to our smaller population on the mountaintop.  It generated 17% of jobs in 2019.  We need income up here for growing families.

This area  is of historical significance.  The Tanning industry thrived here.  The famous Romantic painters, Thomas Cole and Frederic Church made their homes here to paint our most breathtaking views. Some accessible by trails. We are concerned about the loss of access to these magnificent trails.

John Burroughs the American Naturalist was born in Roxbury, N.Y. and wrote about his love of nature.  He was friends with Teddy Roosevelt, Henry Ford, Harvey Firestone, Thomas Edison, John Muir, and Walt Whitman.

They all shared the love of  nature, as we do, living here.

Teddy went on to conserve lands.  He created the United States Forest Service, 51 bird reserves and so much more.  He did it to protect the land and animals and make it available for generations to come.

That is what we want for The Catskills.  If we keep finding ways to destroy natural beauty and land, it is destroyed forever.  The next generation will not share in this splendor. With it goes wildlife specific to this area.

There are a wide variety of animals in the Catskills.   A pocket of golden eagles are here and the size and extent of the population is being explored.  Bald eagles travel here. We see them in residential as well as remote areas.  There are 84,541 eagles in just the Atlantic Flyway alone and the population has risen four-fold since 2009 in the United States. Flyway means a seasonal route they follow as they migrate between nesting and wintering areas.

We have coyotes, fox, fisher cats, deer, turkeys, bears, trout, and a wide array of plant species. There are an estimated 6-8,000 bears in New York State with 30-35% in the Catskill region.  That is approximately 2,400 bears.  They are seen off and on foraging for food.  I have see them along Route 214, the Stony Clove Notch Area.

To put the reservoir in that area would be destroying habitat not just for bears but other animals as well.

Disrupting a main road from Hunter to the town of Phoenicia will make it inconvenient to travel and put more traffic on the other roads.

It is inconceivable that anyone can entertain the thought of tearing up so much land, moving people, altering habitats, possibly effecting the water supply for 9.5 million people in New York City,  use more energy to operate the system than the system will produce, for a extremely high cost, without first evaluating the use of other forms of green energy, wind, solar.....

We are nearing the end of a pandemic.  The economy has suffered and states have lost a good deal of their money. It has been unlike any year we have ever had. Our lives have been turned upside down.  We lost friends and family.  Please do not make us lose anymore of what we hold dear to us. 

We so love it here.

During the worst times in the pandemic we went out into nature where we found solace and peace to  carry us through this. We must preserve the park for all, for all that it gives us.  We all want peace and time to heal.  Not more turmoil.

Do the right thing, please deny this permit!

Laura Endres, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Laura Endres

Sierra Flach, Kingston, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sierra Flach

Maddy Culpepper, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Maddy Culpepper

Esther Normann-Rios, Boiceville,, NY.
cid:EB4EB21C-ED00-4041-AAB7-7D6B49FBC377 

cid:EB4EB21C-ED00-4041-AAB7-7D6B49FBC377
The above sould be a link to my comments that I hopefully copied and pasted.

I stand in objection to the proposed  project.  This is the CATSKILL PRESERVE.  Preserve means to keep and not alter as stated when the preserve was created.  Any site of the 3 proposed would be devastating to the people who live there, and to our community.  The creation of this project would also create turbidity in our Ashokan Reservoir.  The Ashokan Reservoir created the demise of a huge amount of property and many businesses when built.  This community has already given.  Each of these sites chosen are pristine works of nature.  This project would be a ruination.
I stand firmly against this California based potential project/ruination.
Esther Normann-RIos

Michelle Tuorto-Collins, Bloomfield, NJ.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. We cannot renege on preservation designations because it is convenient to a corporation who also stands to make a lot of money from the conservation rollback.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.  My husband is a member of the Catskills 3500 Club (both regular and winter memberships), and we both enjoy recreating there, which includes patronizing local businesses.  Haven't small, local businesses taken enough of a hit with COVID?  How could they survive this?

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Michael Taffet, OAKLAND, CA.
Dear Federal Energy Regulatory Commission (FERC) and Interested Parties-

I am writing this letter to express my strong opposition to Premium Energy Holdings LLC’s Preliminary Permit Application for the Ashokan Pumped Storage Project. Growing up in Brooklyn, I spent many of my summers in the Catskills and harbor a rich appreciation of its unique natural beauty. I continue to regularly visit the Catskills. As a hydrogeologist with over 35 years of experience in groundwater and surface water hydrology, and an environmental scientist, I have an understanding of the significant negative impacts this project could have on the surrounding and downstream ecosystem and surface waters, including the Ashokan Reservoir and Esopus Creek. Admittedly, at this current conceptual design stage, any analysis is preliminary, and the actual specific plans would be necessary to do a proper evaluation. However, the current “conceptual design” as presented provides information for making some points that would likely apply regardless of the specifics of an engineered design. Many of the points I make have already been communicated by others, and in my opinion, they are correct and relevant.
This is not a “closed-loop system” as claimed by the applicant. The construction and ongoing operation of the proposed upper reservoir and tunnel would likely increase sediment transport and turbidity within the waters of the Ashokan Reservoir. It could also increase sediment transport and erosion in the Esopus Creek and tributaries.  Even if these impacts could somehow be minimized during upper reservoir, tunnel, and overhead power line construction, they would be difficult to impossible to mitigate during normal operations. The increased turbidity within the Ashokan Reservoir would degrade the water quality to the point where filtration would likely be necessary before the water could be used as a potable source. The rising and falling surface water levels would likely adversely affect stream and adjacent terrestrial ecology in the Ashokan Reservoir, Esopus Creek, and tributaries. Erosion and sedimentation regimes would likely change and could negatively impact the drainages. Trout and other aquatic organisms could be seriously threatened, and valuable breeding habitat could be eliminated.
The Catskills Forest Preserve is a relatively pristine and special natural resource within New York State. As is well-known, it is protected under the State constitution and is designated as Status 1 land under the U.S. Geological Survey’s (USGS’s) Gap Analysis Program. This status precludes its development for hydropower under the U.S. Department of Energy’s (DOE’s) Hydropower Vision. Any changes to surface water and associated land management within the Catskill Preserve would require a constitutional amendment, passed by the State legislature, followed by a public referendum.  
As is common knowledge, the Catskill Preserve is especially important as it consists of over 700,000 continuous acres of wildlife habitat in a region that is being increasingly developed. The three specific areas being considered for the project are home to species that are designated as protected, and the project would likely impact threatened species as well. Additionally, the Reserve as a whole is designated as an important bird area by the Audubon Society. 
I recognize that the federal and State agencies, and New York City (NYC) are all in agreement that the burning of carbon fuels needs to be reduced, but the proposed project is not a sensible net-positive way to do that. Beyond the obvious inefficiencies these pumped storage projects entail in their construction and use of cheap night-time energy to “cleanly” generate more expensive and high-demand daytime energy, there are likely deleterious impacts on the water-supply of NYC; on surface water, avian, and terrestrial ecology and fisheries; and on sedimentation and erosion within and adjacent to streams. I recommend that FERC deny this permit application.

Sincerely, 

Michael J. Taffet, PhD, PG

Martha M Porter, Rochester, NY.
To Kimberly D Bose 
Federal Energy  Regulatory Commission
888 First St NE Room 1A
Washington DC 20426

Dear Ms Bose,  

I am writing in response to the very troubling proposal  by Premioum Energy Holdings to build a hydroelectric plant in NYS Catskill Mountings.  I urge FERS to decline their request for a preliminary permit for the Ashoka Pump Storage Project.  P15056 as it would be devastating to the environment, highly disruptive to local communities and risky to the quality of NYC water..

Sincerely, 
Martha M Porter

Devon Kasarjian, NEW YORK, NY.
I believe this proposal to be detrimental to the community and surrounding land, both of which I enjoy weekly. I humbly propose a re-think to where the plant should be built, as its intention is well received but the execution of the project leaves behind a wake of avoidable consequences.

Jenna Pethybridge, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jenna Pethybridge

Jordan Tsao, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jordan Tsao

David I Reiner, Demarest, NJ.
I do not approve of this project. It seems unnecessary to destroy a NYC escape for a for profit company.Please reconsider this.

Zelma Livingston, Rochester, NY.
This project would be devastating to the environment , highly disruptive to local communities, and risky to the purity of NYC’s drinking water.  I oppose this project.
Sincerely, 
Zelma T. Livingston

Jim Rich, West Shokan, NY.
To whom it may concern,

I urge you to decline the request for a preliminary permit for the Ashokan Pumped Storage project. It is not that there is inherently a problem with hydroelectric plants as an alternative power source — to the contrary, we should be building more of them to help wean ourselves off fossil fuel-based power. BUT, the notion of building such a plant in such an environmentally sensitive and critical area like the Catskills Preserve is figuratively and literally (Article XIV in the NYS Constitution clearly protects the preserve from such decimation) criminal.

In addition, the affect on NYC’s water supply in the form of increased turbidity as a result of this proposed project is too much to risk.

Let’s find places where the environmental gains clearly outweigh the potential damage done by the construction of these plants, and then move forward with great speed, as our future depends on it. Unfortunately, the proposed Ashokan Pumped Storage project does NOT meet that  critical criteria and would be a monumental disaster. 

It is with this in mind that I believe it is your duty to decline the requested permit.

Thank you for your time and I hope you and your agency make the prudent decision here.

Sincerely,

Jim Rich

Ruth Ann Gyure, Larchmont, NY.
I oppose this project for several reasons. As a professional ecologist, it is clear to me (and there are many references available) that fragmented habitats are not suitable for sustaining the wildlife and plant life desirable in our state, especially our precious protected lands.  The Catskills Preserve is an invaluable 700,000 acres of continuous land whose benefits cannot be fully measured. It is among the top 1% of forest habitats region wide (NY State Forest Condition Index). If we continue to break it up, and use it for commercial purposes, the original intent of establishing it as preserved land is increasingly lost in a way that does not equate to the value estimated by developers who will mostly benefit from the outcome. This protected land is preserved for all of us, not the few who seek to exploit it. 
Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
As an avid birder, I also point out that all proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: see www.audubon.org/important-bird-areas/catskills-peaks-area .  Bird populations are particularly depended on large tracts of reliable and continuous habitat for the maintenance of healthy numbers and activity.  It is also clear that changing the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the NYC water supply 
As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protecIons designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” So why is it being targeted for development?   
Clean unfiltered water is also a hugely important resource for the citizens of New York State. Our drinking water supply is here for us because of billions of dollars worth of investment to keep watersheds as pristine as possible. The Catskills play a vital role in supplying this system, and clearly, our valuable water resource will be even more important in an uncertain climate future. 

I urge decision makers to take all thes points into consideration, and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Amanda Insall, West Shokan, NY.
Dear Ms. Bose;

We are responding to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

We urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, because as we argue below this entire project would be destructive to the environment, to local communities, and would possibly put the purity of NYC’s drinking water at risk.

A century ago the land in the Catskills Forest Preserve was protected. In that hundred years many more lands have been added to the preserve as ‘forever wild’ status 1 protected lands. This is the highest level of protection. I don’t know if the company has studied the site enough to have reviewed the NY State constitution in reference to the Catskills Forest preserve, and the long and involved legal process of removing protected lands from the preserve for use by a for-profit company. These lands are protected for a reason and 100 years of conservation efforts show the importance of the Catskill Forest Preserve as an asset to our area and New York State in general. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The lands are protected to ensure the purity and clarity of the Ashokan reservoir as an unfiltered water source for New York City. The city presently receives 40% of its water from the unfiltered water source of the Ashokan reservoir. The high-level protection of this area also serves to maintain the system and ecology of the general area which is veined with streams and tributaries. The town of West Shokan is involved in commissioning stream studies and has already invested a lot of research and and a big engineering project to preserve the ecology and wildlife of the area and to prevent extreme flooding in Boiceville and the West Shokan town hall area that we have experienced during recent hurricane events. Our citizens are highly invested in the environmental preservation of our area. I have talked to a number of neighbors who are firmly opposed to a project which would seem to wreak havoc on our efforts to preserve the integrity of our forest lands and the purity of the Ashokan reservoir water source.

I am skeptical that a for-profit company from California which does not seem to have sufficiently studied the site and the level of protection it currently enjoys will be able to make environmentally sensitive decisions to preserve the assets of the Catskill Forest preserve and the Ashokan reservoir.

Even after construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. 

Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

Lastly, such a project would be bad for the community as a whole.  Not only would it lead to seizure of community homes and private property in the immediate area by the process of eminent domain. But this is what happened in this local area 100 years ago when the Ashokan Reservoir was built—and has traumatized this region ever since.  Combined with a current Ulster County housing shortage and an inflated real estate market, what will happen to those who lose their homes and property because of this? 

Please deny Premium Energy’s permit for a feasibility study for their proposed project, Ashokan Pumped Storage Project P-15056. Our neighbors and our elected officials and their active voices have already judged this project to be unfeasible for the protected area of the Catskill Forest Preserve.

Sincerely,
Amanda Insall
West Shokan, NY

Augusta Gillespie, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
 
I am writing to urge FERC to decline Premium Energy Holdings’ proposal to build a hydroelectric power plan in New York’s Catskill Mountains.
 
I recognize the valuable and important role that hydroelectric power will play in our effort to mitigate climate change and reach the important climate goals set forth by both Governor Cuomo and the Biden Administration. That said, the Ashokan Pumped Storage Project would destroy over 700,000 acres of pristine wildlife preserve, and would require significant energy to build. The US Energy Information Administration clearly states the trade-offs of hydroelectric plants, including the likelihood of increased carbon emissions in the construction phase. While the long life-cycle of Hydroelectric plants can sometimes offset the initial Greenhouse Gas (GHG) emissions, this project is likely to net significant GHG emissions between now and 2050, and is not necessary to meet the demand response needs of New York State. Dedicated efforts to building retrofits, high efficiency heating and cooling upgrades, enrollment in remote demand response programs, and the adoption of local solar, will produce immediate reductions in both GHG emissions and peak energy use.
 
Clean energy sources are only one part of the climate solution. It is imperative that our efforts to ensure a clean energy future do not favor renewable energy proposals at the expense of biodiversity. The Catskill Forest Preserve, ranks among the top 1% of forest habitats region-wide and is clearly protected under Article XIV of the NYS Constitution which states that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Additionally, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Allowing a preliminary permit for this project sets a dangerous precedent that protected lands can be converted in the name of “clean energy” with no consideration to holistic environmental impacts.
 
In addition to its negative effects on biodiversity and short-term GHG emissions, Premium Energy’s proposal would be deeply damaging to local communities. This proposal would require the relocation of thousands of residents through eminent domain. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
 
But it’s not only local communities that would be impacted by the Ashokan Pumped Storage Project. The project could jeopardize the health of the Ashokan reservoir, which supplies 40% of New York City’s water supply.
 
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
 
Our country’s transition to renewable, clean energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
 
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
 
Sincerely,
 
Augusta Gillespie

Jason Campe, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jason Campe

Natalie Parker, Olivebridge, NY.
I am writing to express my concerns with the proposed Ashokan Pumped Storage Project.  It appears that this company, Premium Energy, is not particularly familiar with this area and does not have the best interest of our citizens or our wild spaces in mind.  This company is California-based, and in doing a little bit of research, I found a number of similar proposals (nearly identical in fact) of theirs to the FERC in CA proposing dams to be built in the Eastern Sierra region, one of them even potentially within the John Muir Wilderness.  Fortunately, these permits were deemed ‘deficient,’ and I hope to see the same outcome in this instance.  I wonder if there isn’t a trend here: this company seems to seek out wild areas bordering on some existing infrastructure (a dam/reservoir), and proposes a massive project that involves building new reservoirs, dams, pipelines and powerhouses often on protected land.  They provide a conveniently vague proposal with an outline for upcoming surveying and studies to determine whether or not the proposal is actually feasible, taking place over the course of 24 months and costing approx. 3 – 5 million dollars.  Why are they now targeting our beautiful Catskill region in New York?  Were they rejected one too many times back in California, and have since decided to exploit wild areas further afield?  

I am all for renewable energy, but I would like to see it done in a practical, well thought out way, taking the land and the communities that it will be impacting into consideration.  The proposal for the Ashokan Pumped Storage Project does not do this.  It negatively impacts land and water resources that tens of thousands of people, both local residents and tourists from all over, enjoy.  I have spent my whole life hiking in the Catskill preserve, and I am intimately familiar with all three areas that this company has elected as potential sites of its upper reservoir.   These are ecologically important areas.  The streams that would be dammed harbor trout stocks, provide habitat for many other species, and attract numerous visitors.  

I would hope that even if Premium Energy were allowed to conduct their proposed survey and assessment of this project, they would soon realize that this plan is simply not feasible in this area.  However, since I do not know how they operate and what their finances/methods truly are, I am hoping that this can all be shut down before it even has a chance to get underway.  Please reject this proposal!

Karl Steinbrenner, West Shokan, NY.
As a resident of West Shokan, NY and Brooklyn, NY, I wholeheartedly agree with Ulster County Executive Pat Ryan in the county’s opposition to the proposal for the Ashokan Pumped Storage Project.  It provides us no benefit whatsoever to West Shokan, Ulster County or New York City. I also endorse NYC’s opposition to the proposed project on the basis of its danger to the clarity of the drinking water in New York City.  In addition, the Catskills are protected land, and therefore no projects such as this one proposed by Premium Energy Holdings should be approved. The disruption to neighborhoods and the environment would be profound. To invoke eminent domain would be catastrophic, tantamount to stealing land for profit. This project must not go forward. 

Karl Steinbrenner 
27 Dry Brook Road, West Shokan, NY 12494
24 Monroe Place, 1D, Brooklyn, NY 11201

Constance Kieltyka, Olivebridge, NY.
I believe the preliminary permit application for the ashokan pumped storage project should be denied.
"I go the woods to lose my mind and find my soul."
this project makes no sense financially, environmentally or ethically.
It would effect millions of people's drinking water 
Please do not entertain the thought of building this project!
Constance Kieltyka
532 Beaverkill Rd
Olivebridge NY 12461

Michelle Friedel, West Shokan, NY.
Michelle Friedel, West Shokan, NY

Kimberly D. Bose, Secretary 
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A, 
Washington, DC 20426

Re:  Docket P-15056 Ashokan Pumped Storage

To whom it may concern,

This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. 

Permitting this proposal to move any further through the FERC, to the feasibility study, would be detrimental to the lives of all who live in the proposed feasibility study areas. It would be directly harmful to our community by disrupting our local and regional economy and would directly displace long term residents and decimate wildlife in the area if it were to move forward. 

In particular, the proposed Wittenburg Reservoir site, which would be located on Moonhaw Road according to the project’s application, is incredibly rich with geological history noted by the famous geologist Arnold Guyor who identified this area to have significant glacial features. There have been numerous works published documenting the history of the Catskill Forest and the geological treasures of this area.

From our research, it appears that Premium Energy puts out a great deal of proposals regarding these types of projects, with the hopes one of them might stick and go through. In reviewing the proposal and all their other filings for a pumped storage power plant, there is a major consensus that their preparation and planning is simply a copy and paste job. The contents within the application exhibit a lack of expertise and knowledge of the lands they propose to use by obtaining permission or by means of eminent domain.

Our small but mighty Town of Olive is vital to the economy of Ulster County, and the Catskills Region as a whole. We are a recreational destination for local folks and visitors alike. As previously mentioned this project will directly negatively impact the Catskills tourism economy. According to the New York State Department of Labor, tourism is most important to the Catskills since it generates 15% of total employment for the area. Tourism Economics is an Oxford Economics company, which states that the Catskills region has one of the strongest gains in traveler spending in particular when it comes to recreation, lodging and restaurants. Premium Energy has put its project proposal in direct alignment to adversely affect the economy in all three proposed sites. This again highlights the impact of sanctioning this proposal’s dangerous forward momentum. 

On a more personal level, the Friedel family has lived on and owned our land for over 20 years. I myself have lived in the Town of Olive for 20 years, raising my two sons, and building our home by hand, on our land. The idea that Premium Energy’s proposal threatens multiple municipalities and hundreds of home-owners by seizing property by eminent domain is incredibly traumatizing to imagine. The stress and anxiety that this proposal has brought to the various communities and individuals is real. The Ashokan Reservoir was built between 1907 and 1915, and during this time thousands of residents lost their homes, businesses, and communities. I can’t help but reflect on the events that occurred in 1907 and wonder if history is repeating itself in 2021. The Ashokan Reservoir has prohibited various activities around the area (swimming, motorboating, diving etc.) in order to protect the quality of the water, yet Premium Energy’s proposal threatens this preservation work. The 53 private property owners of Moonhaw Road and those surrounding the project site are at great risk for permanent displacement, loss of income, and generational trauma if this proposal were to move forward. 

I myself have many questions; Who are the investors of Premium Energy? Which power purchasing entities are making a profit off this project? Who economically benefits from  this project? Most importantly, who will hold this California based company, Premium Energy, accountable for their ethics, standards, and workmanship? The application submitted is a poor example of Premium Energy’s knowledge of the area, and the plethora of errors that have been highlighted from the various comments that have been filed regarding docket number P-15056 are startling.

Thank you for your consideration of this matter and I trust that the Commission will reject the proposal due to the egregious nature of its contents and the aforementioned grounds.  

Sincerely,


Michelle Friedel

Roger & Judith Morris, West Shokan, NY.
We wish to register a strong protest against the proposed “PSH” hydro-electric project by Premium Energy Holdings for this area.  Such a project would hugely disrupt and damage the protected forest, water, flora and animal species in this area, as well as add electrical pollution in the form of high voltage transmission towers planned to run through our very backyard.  High voltage towers have been proven to cause leukemia and other negative health effects on humans and animals. The extensive digging and tunneling required will also do immense damage to the reservoir water quality, our towns, and these parklands meant to be forever wild.  We moved to West Shokan in 1982 confident that the Catskill Park was an area legally protected from development and pollution by the NYS Constitution.

Sita Anderson, Boiceville, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.  It would be devastating to the environment, highly disruptive to local communities (some of which have suffered eminent domain previously to make the Ashokan Reservoir), and pose a risk to NYC’s drinking water. 

While there’s no doubt that pumped storage and new hydroelectric projects are important in our country’s transition to renewable energy, the Catskill Forest Preserve (700,000 acres of continuous wildlife habitat) must not be sacrificed in the process.  Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation-one where the construction and operation will destroy protected wilderness, displace communities and threaten important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sita Anderson

Curtis Troeger, Darien, CT.
For three generations, my family has made a home in Woodland Valley during the summer months. In particular, my parents bought a family cabin in 1968; they passed it on to me and my siblings, and I hope to pass it on to my children, and that they will be able to pass it on to their own children in years to come. 

Additionally, since 1968, my family and I have paid taxes, supported local businesses, helped safeguard the ecology, and enjoyed being productive, participatory members of the Woodland Valley area. Since 1968, My family has stocked the Woodland Valley stream, brought extended friends and family to the region to spend money, and create beautiful traditions that are essential to the our family’s happiness.

Not only will this proposed Project destroy entire ecological systems and my family’s summer traditions, but the ripple effects of this project will certainly harm local businesses when thousands of residents – both summer and year-round – are displaced.

In fact, the transfer of reserve land to a private party must be done by a constitutional amendment. So, the plan appears that this project is both I’ll-advised and illegal.

For these reasons, I object in the strongest possible terms to this project and the devastating effect it will have on the local community, it’s business ecology, and recreation.

Gary, Phoenicia, NY.
The effects of dams have a long history of harming the environment. While dams do provide renewable energy, this does not outweigh the direct effects of dams on the environment surrounding them. This will be putting people’s property underwater and contaminate habitats of animals in the area. This dam should not be built, please consider how this is affecting the community.

Sara Muskulus, Glendale, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in the Catskill Mountains in New York. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

I have been a part-time resident of the Catskills, specifically Prattsville and Roxbury, for over seven years. I have seen first hand the devastation the hurricanes, such as Irene, have brought to the neighboring towns. I have witnessed the displacement, the impact on the economy, and the havoc it brought to the environment. Hurricanes, however, are acts of nature and mostly unpredictable.

What this project is proposing to do would be equally disastrous. Pumped storage upper reservoirs are subject to rapid fluctuations of water which are destructive to both aquaIc and land habitats. This could potentially flood the town, yet again. Not to mention, altering the sediment regime in tributaries to the Esopus, one of the Catskills’ most vital trout waters and part of the NYC water supply. It will also interfere with the breeding territory of the trout.

The lack of concern for displacing the families in the town is also disconcerting. These towns are already suffering economically. Residents displaced by the Ashokan Pumped Storage Project would have a difficult time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain and otherwise lessen tourism in the region, negatively impacting businesses in Ulster County and beyond.

I agree that we must find greener, more sustainable ways of souring energy, but it should not come at the cost of displacing families, destroying the environment, and tampering with the water supply. 

I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Sara

John F Krenek, HURLEY, NY.
I write this letter strongly opposing the Ashokan Pumped Storage Project being submitted by Premium Energy Holdings LLC. There are numerous reasons why this proposed project should not be considered and be dropped immediately. I'll point out a few that stand out to me most. #1 The Catskills are a State Preserve protected by the NY State Constitution. Hundreds of precious acres would be effected by this ridiculous project. Imagine what it would do the wildlife and fauna that rely on this region? #2 This project would be detrimental to our local communities by disrupting our economy and displacing residents. I personally own several businesses in the area and can tell you from first hand experience that COVID was brutal to small businesses. In fact, I was forced to close one of them. Let's not have Premium Energy Holdings,LLC create another economic fiasco for our region. #3 Lastly, the power lines for this project are proposed to cut right through my property which is a historic 1720 homestead built by dutch settlers. I don't think the founders would have ever imagined huge electric lines cutting right through their property and over their house. I also don't think that any owner of Premium Energy Holdings, LLC would allow this to ever happen on their gorgeous historic property. I can tell you that I sure the hell don't want this to ever happen on mine. This ridiculous proposal must be stopped now and not go any further!!!

Nicole Mihatov, Nanuet, NY.
This project must be rejected. It will bring too much harm to the Catskills

Robert Marschall, Long Valley, NJ.
I’m voicing my opposition to build a pumped storage hydro plant in the Catskills.

The proposed project impacts some highly protected areas of the Catskills and affects wildlife habitats of multiple protected species in all three potential development areas. All three areas impact highly preserved lands and stream ecologies. All three are trout breeding waters. All three are within Audubon’s Catskills Peaks Important Bird Areas. All are habitats for some plant, bird, bat and snake species on NY’s “threatened”, “special concern”, or “greatest conservation need” lists including the bog orchid, northern long-eared bat, scarlet tanager, wood thrush, black-throated blue warbler, and three hawk species.

Although NY State needs to consider green energy alternatives, this project is not the kind of innovation the state seeks. The Catskills and the NYC watershed are not the areas for a pumped storage hydro project.

Premium Energy appears to be completely unaware of the protected areas in which it proposes its upper reservoir for the project. 

The city of New York will never tolerate any muddling with its watershed that could adversely affect the quality of drinking water for 9 million residents. The City will tie ribbons of red tape around the project and will suffer years of legal challenges before it concedes to this development.

New York City is only half the battle. 

The proposed areas of development are an extremely protected state preserve, a Status 1 area according to USGS. The Catskills Forest Preserve are protected by the state constitution and “shall be forever kept as wild forest lands.” Any changes to land management in the State Forest Preserve must be passed by constitutional amendment and then voted on by two consecutive sessions in the state legislature, and THEN submitted for public referendum. 

Does Premium Energy have the mettle to endure the wrath of the City, the State, and the public? If by miracle the project survived the onslaught of legal challenges by the City and State, every NYC resident and every fisher, hunter, hiker, and bird watcher will shout this down in every form of media available.

Michael L Rusilas, WAPPINGERS FALLS, NY.
Please deny this application for a permit.  We must keep our natural resources pristine.  A for-profit company should not have this opportunity.  They will not properly preserve nature.

Bethany Saltman, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I have lived in Woodland Valley for twenty years.

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Bethany Saltman

Kimberly Standerwick, Carmel, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

In regards to this proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 
This project also would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
With all due respect, 
The Premium Energy project would cause permanent and irreparable harm, to these necessary inhabitants and must be rejected.

Sincerely 

Kimberly Standerwick

Doreen Arnesen, Cottekill, NY.

  To: Federal Energy Regulatory Commission
RE: Docket #: P-15056-000

     After much reading and sharing on the topic of a hydro plant being built near the Ashokan Reservoir I find that I CANNOT accept this project.  I understand the issues at hand, and realize that it is important for New York state to have high renewable energy goals, but the Catskills are deemed Status 1 land and the Department of Energy states that Satus 1 & 2 lands should not be developed.  This project would create havoc and destroy the beauty of this awe-inspiring region.
     Also, in my reading it stated that water would have to be pumped uphill in order for it to then flow downhill; very sisyphean. It just does not make sense to ruin land, change the landscape, and build new tunnels in an area so protected.
     I object to the proposal of a hydro plant at the Ashokan Reservoir and request that the Federal Energy Regulatory Commission DENY Premium Energy Holdings application for a preliminary permit.
      Very truly yours,  Doreen Arnesen

Rebecca A Anwar, Philadelphia, PA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely yours,

Rebecca A. Anwar Ph.D.

Holli Silver, Scarsdale, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

In regards to this proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 
This project also would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
With all due respect, 
The Premium Energy project would cause permanent and irreparable harm, to these necessary inhabitants and must be rejected.

Sincerely 
Holli Silver

James Borbely, Washington, DC.
I am writing in opposition to building a pumped storage hydro plant in the Catskills. The proposed project impacts some highly protected areas of the Catskills and affects wildlife habitats of multiple protected species in all three potential development areas. All three areas impact highly preserved lands and stream ecologies. All three are trout breeding waters. All three are within Audubon’s Catskills Peaks Important Bird Areas. All are habitats for some plant, bird, bat and snake species on NY’s “threatened”, “special concern”, or “greatest conservation need” lists including the bog orchid, northern long-eared bat, scarlet tanager, wood thrush, black-throated blue warbler, and three hawk species.
Although NY State needs to consider green energy alternatives, this project is not the kind of innovation the state seeks. The Catskills and the NYC watershed are not the areas for a pumped storage hydro project. 

There has to be a better use of NY tax payer dollars than rerouting streams and roads, and disrupting the delicate ecosystem in the Catskills. Not to mention the damage this project would do to the local community drinking water.

Please consider other options and do not move forward with this project.

Damian Amitin, Chichester, NY.

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

I feel the letter below written by my community members and neighbors summarizes our families and community's firm stance on the matter:

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Damian Amitin

Susan Hereth, Kingston, NY.
For the following reasons, I am 100% OPPOSED to the proposed Ashokan Pumped Storage  Project proposal , Docket #  P-15056-000 and appeal to FERC to deny any further permitting of this application: 
Premium Energy provided false information on their application. The proposal is being made for vast areas of land WITHIN the Catskill Forest Preserve, a New York State designated state park and protected forests. The forest within Premium Energy's proposal is ranked among the top 1% in the NYS Forest Condition Index. 
The Catskill Forest Preserve, which the Premium Energy Proposal falls within, is considered Status 1 land through USGS analysis, which is identified as to be "avoided for development." Any changes to land management with the Catskill Forest Preserve require a constitutional amendment in the State of New York. 
Premium Energy's proposal for the Ashokan Reservoir Pumped Hydro Storage would destroy highly preserved ecosystems, both aquatic and terrestrial. The proposal to  build a reservoir, tunnels, and transmission lines would destroy intact forests, riparian zones, wetlands, and other habitats that would have detrimental impacts on multitudes of species such as protected and important fish, amphibians, reptiles, mammals, birds, and plants.
The path of the proposed 800mw (the Premium Energy website also mentions 230kw lines) transmission lines crosses NYS protected wetlands. There is at least one NYS-regulated Freshwater wetland AS-10 (Class 2) that the transmission lines are shown crossing according to Premium Energy's proposal. The wetland located at Stone Church Road is an important wetland for migratory waterfowl and other birds, species such as Bald Eagles, Green Heron, and Great Blue Heron, and Kingfishers, as well as home to beaver, otter, turtles, frogs, and more. 
The path of the proposed transmission lines would destroy intact forests and open up an invasive species corridor that would be the death knell of the State protected lands and species of concern (ex: raptors, song birds, bats, and orchids)
The path of the transmission lines crosses farmland in Hurley that is currently producing food that is feeding 1000s of New Yorkers experiencing food insecurity and supporting the food system during the pandemic.
The Ashokan Pumped Storage proposal would negatively impact the economic viability of the County by damaging the tourism sector. Pre-COVID pandemic numbers indicate the tourism industry of Ulster County creates 20,000 jobs, an approximate annual industry of $684 million (in 2019). 
The open-loop, add-on system proposed by Premium Energy is not a proposal that the Federal Government should want to support because of the damage that will be done to the lower reservoir which serves as a drinking water source for over 9 million people. The Premium Energy proposal would negatively impact the drinking water of over 9,000,000 New Yorkers. The turbidity and water fluctuations created by this proposal would also negatively impact important trout habitats and breeding grounds.
Turbidity impacts from discharge into the lower Esopus Creek would negatively impact aquatic and terrestrial ecosystems for over an additional 20 miles. The lower Esopus Creek flows out of the Ashokan Reservoir and travels through the Towns of Marbletown, Hurley, Kingston, Ulster, Saugerties, and the City of Kingston. The Esopus Creek discharges into the Hudson River in the Town of Saugerties, an important East Coast estuary, that provides habitat to threatened species for 150 miles of its tidal estuary. 
Premium Energy's Ashokan proposal for pumped storage has negative impacts on more towns and entities than listed in its application. The Ashokan Pumped Storage Proposal would negatively impact the following towns: Hunter, Olive, Shandaken, Marbletown, and Hurley. The land and aquatic ecosystems that would be impacted are under jurisdiction of the above mentioned towns as well as NYS DEC as well as NYC DEP. None of the listed towns or entities were, or have been, contacted prior to Premium Energy's application. 
Culturally and historically as a region, the lands within Premium Energy's Ashokan Pumped Storage facility and transmission lines, were home to indigenous peoples since the last Ice Age retreated 12,000 years ago as well as enslaved Africans during the 1700s and 1800s. Premium Energy's project would destroy cultural and historically important sacred sites.
As a region, the lands that Premium Energy has proposed for their project have a 12,000 year history Indigenous peoples' living across, and stewarding, the entirety of the landscape - from the shores of the Hudson River, across the floodplains, valleys, hills, and lowlands, into the peaks of the Catskill Mountains.  The Ashokan Pumped Storage project and transmission lines would destroy extensive Indigenous sacred sites, shelters, traditional migratory pathways, and encampments. 
With a deep history of enslaved Africans working and living (1700s-1800s) on the agricultural lands that fall within Premium Energy's Ashokan proposal for transmission lines, any work done within the agricultural land and surrounds would destroy sacred burial grounds holding the remains of enslaved Africans. 

Lastly, there should be no foreign investors or investment in United States domestic energy grid projects. I have read that Premium Energy has had foreign investors in previous projects. As a matter of National security, all domestic energy projects should be domestically owned and financed. 
Premium Energy's application's deficiencies are tremendous and can not be corrected. Given the above stated detrimental impacts to an intact forested State preserve, aquatic and terrestrial ecosystems, economic industry, and cultural and historic aspects, the Premium Energy Ashokan Pumped Storage Proposal Docket #  P-15056-000 should be denied any future permitting or applications. The Ashokan Pumped Storage proposal # P-15056-000 should NOT proceed.

John Lamberty, Oconomowoc, WI.
After an in-depth review of the application submitted by Premium Energy Holdings, LLC, requesting a preliminary permit for the Ashokan Pumped Storage Project, Docket No. P-15056-000, I recommend the Federal Energy Regulatory Commission FERC decline the request. This recommendation is based the inconsistencies and irrelevant statements placed throughout the application, in what I view as an attempt to dissuade the reviewer. 
Specific examples: 
On page 12 it is stated, "... produce a maximum of 2700 GWh of annual energy production.", yet this is an application for a storage system, not a production system.  
Dividing 2700 GWh by 365 days per year, yields a storage system capacity cycle of 7400 MWh/day. On page 11 it is stated, "... operation at 800 MW would be possible for 12 hours of continuous output.", why state a 9600 MWh/day capacity cycle? 
Furthermore, a simple calculation of the required average hydraulic head to produce 9600MWh from 15800 acre-ft of water would be 594 feet, using 3.76616e-7 kWh/ft-lb energy conversion, 62.4 lbs/cubic foot water density, and 43560 cubic feet per acre-ft volume conversion. On page 11, 594 feet is the stated maximum, not average hydraulic head of the proposed Wittenberg Reservoir, which obviously would not work. 
In addition, throughout the application an absolute maximum potential hydraulic head of 914 feet is stated, instead of the required average, I believe in an attempt to elude the reviewer with regard to the actual volume of water required for daily cycling.  
Lastly the first sentence of the second paragraph on page 9, "The proposed Ashokan Pumped Storage Project would operate in a closed loop.".  What exactly is the intent of this statement?  I believe it is an attempt to elude the reviewer into the belief that the proposed project is for a closed loop Pumped-storage Hydropower (PSH) system.  Using the U.S. Department of Energy’s definition, "PSH capabilities can be characterized as open loop—where there is an ongoing hydrologic connection to a natural body of water—or closed loop, where the reservoirs are not connected to an outside body of water.", the proposal clearly is not closed-loop.  The existing Ashokan reservoir is currently connected to naturally flowing water features and the proposed upper reservoirs would be created by placing dams into naturally flowing water features. Excess water flow in the region surrounding both reservoirs would continue to rely on existing water features as well as suffer from daily flow modulation as a result of PSH operation. 
With this level and appearance of elusive statement inclusion, intended to elude the reviewer, I highly question the transparency and actual intent of the application.  Again I would like to repeat my recommendation for denial of the application.  
Sincerely, John

Kari E. Hoyt, Hurley, NY.
As a former long-time resident of the Town of Olive (having grown up in and around Olive, having only recently moved to Hurley) and being someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Megan Offner, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing out of concern for the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Clearly new hydroelectric projects will play a key role in our country’s transition to renewable energy, however the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Pumped storage is also notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would likely increase turbidity within the Ashokan and its watershed. It would be reckless to allow a project to proceed that would threaten the Ashokan Reservoir, the largest unfiltered water supply in the nation that represents over $1.7 billion of investments since the 1990s alone.

Premium Energy’s proposal would also be deeply damaging to local communities as any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. 

Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Premium Energy’s Ashokan Pumped Storage Project proposal lacks the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Megan Offner

Jen Brueckner, West Shokan, NY.
April 11, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission,
888 First St. NE Room 1A
Washington, D.C. 20426
The FERC project and sub-docket number: P-15056:000

Dear Ms.  Bose,

    Please consider denying the proposal by Premium Energy Holdings of California to build a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s Catskill Mountains. We know hydroelectric storage pump plants will happen now and in the future to help meet green initiative goals for developing and maintaining our growing needs for energy utilizing renewable resources.  Adding hydro storage pump systems does make a lot of sense for NY to meet our goals. We are about 100 miles north of New York City and the current reservoir is part of the New York City water supply system which serves over 9 million people.  The NYC Department of Environmental Protection has expanded its precinct, officers and worked hard to protect it’s watershed by a land acquisition program.  It looks practical from a map perspective of the reservoir to use the existing water to turn the turbines with a building of a reservoir from one of the mountain sites proposed, but the mountainous areas have been protected by the state and the city for over 100 years.
     We are all aware of the new green energy and the federal funding used to promote hydroelectric.  It is supposed to have less of an impact on the environment, but when land is flooded to create a reservoir, a necessary step in building some hydroelectric facilities, naturally occurring mercury is released into the water column, where it is taken up by bacteria and transformed into methylmercury, a neurotoxin that can accumulate in the food chain and, in extreme cases, can cause serious damage to the neurological and nervous system of humans (Hongoltz-Hetling, M 2020).  According to a study among scientists in Hong Kong hydropower does the most damage, the scientists found. "Hydropower has degraded some of the most biologically rich habitats on our planet," said Professor William Laurance from James Cook University in Australia  (Gibson, Wilman, Laurance 2017).
       According to Kate Hudson Hydropower is Not Clean Energy:  Dams and Rivers are Major Drivers of Climate Change  She states that on November 8, 2017, the House of Representatives approved a bill, H.R. 3043, that defines hydropower as a renewable energy source and fast-tracks the licensing of large, taxpayer-funded hydro-projects, claiming that the concentration of licensing power in the hands of one federal agency—the Federal Energy Regulatory Commission (FERC)—will boost a clean source of energy.  She states that research released has confirmed that dams and reservoirs are a major source of greenhouse gas emissions driving climate change. Until recently, it was believed that about 20 percent of all man-made methane emissions came from the surface of reservoirs.  Reservoirs are a classic example of how major human alterations to the Earth’s landscape can have unexpected effects.
      The impact on nearby streams will impact turbidity in the Ashokan Resevoir. 
Portions of the mountainside slopes leading down to the Maltby Hollow Creek are steep with unstable soils. Any construction on the mountainside will increase streambank erosion and even possible hillslope failure. This will result in an increase in the turbidity of the water in the Maltby Hollow Creek, and therefore into the Ashokan Reservoir.  This turbidity could also reduce the fish population in the reservoir which would drive away the bald eagles who nest near the reservoir and feed there. 
      Risk to the trout population in the Maltby Hollow Creek and Wittenberg Brook lie directly downhill from the proposed reservoir site. They are classified both as trout waters and trout spawning waters. Soil runoff from the reservoir construction and storm overflow will run directly into these two streams. This will both increase the turbidity of the streams and affect the water temperature, likely having a negative impact on trout spawning and survival. 
     Impact on rare and endangered species in the area. The core interior forest area supports a unique array of plants and animals that are easily disturbed by human activity generally associated with more open habitats (e.g., roads and developed areas). The core forest is especially important for sensitive wildlife including many forest songbirds, which avoid nesting near areas with human disturbance. Although the value of individual forest patches for wildlife depends on landscape context. 
     Additionally, both sides of the upper Dry Brook are the premier locations, in all of NY State, for the Three Birds Orchid (Triphora trianthophora).  This is very definitely a rare species.  The end of the Maltby Hollow Creek is another location for the Three Birds Orchid.  These sites are registered in the Biological and Conservation Database for North America, and in the database maintained by the New York Natural Heritage Program, jointly funded by The Nature Conservancy and NYDEC.
     The proposal does not even represent the kind of novel proposal that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city of 9 million people.
     
Sincerely,
Jen Brueckner
  
Citations:
Bierhorst, J. The Ashokan Catskills: A Natural History. Purple Mountain Press, Fleischmanns, 1995, pg 52.
Conley, A. K., E. Cheadle, and T. G. Howard. Updating Forest Patches and a Patch Assessment

Lauren Jordan-Amitin, Chichester, NY.

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

I feel the letter below written by my community members and neighbors summarizes our families and community's firm stance on the matter:

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Damian Amitin

Rachel Silver, Scarsdale, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

In regards to this proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 
This project also would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
With all due respect, 
The Premium Energy project would cause permanent and irreparable harm, to these necessary inhabitants and must be rejected.

Sincerely 

Rachel Silver

Kenneth Lipnickey, Chester, NJ.
I’m writing in reference to docket P=15056.
The Catskills are a great area. Some of the views remain spectacular and visiting remains a humbling experience. Although development and continued encroachment are likely inevitable, where we can, we should try to limit growth and destructive development. The proposal to build a dam, a reservoir, powerhouse, pipeline and powerlines falls into this category. This development would remove access to popular hiking destinations and limit already stressed resources available for recreation. Vistas will be destroyed and ecosystems irreparably damaged. The outdoor industry is a multi-billion dollar industry and this area of New York would see a reduction in tourist dollars and business revenue. We need to do the right thing which is limit development, don’t allow development of a new hydroelectric facility and preserve land for future generations.
Thanks,
Ken Lipnickey

Lorraine DellaPenna, Phoenicia, NY.
/Users/lorrainedellapenna/Documents/P15056titled.pdf/Users/lorrainedellapenna/Documents//Users/lorrainedellapenna/Documents/P15056titled.pdf

MELISSA GAGNIER, Bristol, CT.
Please don't build this damn and destroy the beautiful surrounding environment and animals. Flooding by this damn would have great consequence to it's beauty

Thank you,
Melissa Gagnier

Rosalind Dickinson, Woodstock, NY.
I live in Ulster County and I walk, ski and bike regularly on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. 
This area is part of the Catskill Park and Forest Preserve and is constitutionally protected (much of it as Forever Wild lands) by New York State. The Ashokan Reservoir is part of the largest unfiltered drinking water system in the world, with gravity-fed water provided to New York City. This area and its scenic beauty are economically important to many people here - tourists come from all over the world to see the beauty of the Catskills and tourism is a major part of our local economy. 
I object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 
In addition, the project will affect both local and tourist enjoyment of these protected lands, damaging our local economy. Two major walking and biking paths are on either side of the Ashokan Reservoir, used by many thousands of visitors in every season. Damage to this area would have a pronounced negative effect on local businesses of all types.
Please do everything in your power to prevent this proposal from moving forward.
Thank you for your attention -
Rosalind Dickinson
Woodstock, NY

Mary Ann Shepard, West Shokan, NY.
As a resident of Olive, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for millions. Please do everything in your power to prevent this proposal from moving forward.
The project is proposed within the Catskills Forest Preserve, with impacts on formally protected and ecologically valuable land. The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.The U.S. Department of Energy itself has recognized that development on such lands should be avoided.
The proposal call for the movement of water into the Ashokan Reservoir. This reservoir is a primary source of drinking water for New York City. The movement of water in pumped storage can affect the sediment regime and stream ecology. This is of heightened concern, since excessive sediment is already a major issue affecting the Ashokan Reservoir and the quality of NYC’s unfiltered drinking water. The project would likely affect the 9.5 million residents of New York City.  It also has significant implications on the health of the Esopus Creek and the communities on its banks, and to the communities that draw drinking water from the Hudson River where the Esopus flows into.

Due to the devastating effects this proposal will have on our area, I urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Mary Ann Shepard
West Shokan, NY

Tiffany Joy Butler, Walden, NY.
Dear Ms. Bose,

With dismay -- I write in response to the proposal by Premium Energy Holdings of California to build a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s Catskill Mountains. This would include a reservoir of up to 300 acres at one of three sites (to be chosen) and a tunnel to bring the water to the east shore of the upper basin of the Ashokan
Reservoir. The three sites are Chichester, Woodland Valley, and the Moonhaw valley in the hamlet of West Shokan, Town of Olive. My comments are confined to the Moonhaw and adjacent regions of West Shokan. Moonhaw is a settled area of some 50 homes, valued at up to $2,500,000 apiece. A 300-acre reservoir would destroy the community -- and the tunnel leading from it would disrupt another 50
homes in the region between Moonhaw and the proposed power plant.
Furthermore the upper reaches of the Moonhaw valley are in a designated Wilderness
Area of the New York State Forest Preserve and protected from development of any kind by the "forever wild" clause of the New York State Constitution.
Such wholesale destruction of a major portion of West Shokan cannot be allowed. I urge you to recommend that Premium Energy's proposal be rejected.

Sincerely,
Tiffany Joy Butler

Sally Plass, New York, NY.
RE:  Ashokan Pump Storage Facility in The Catskills

I would like to VOTE NO ON THIS PROJECT.

Reasons:

Premium is lying on the type of method they are using ('closed loop') and plan a method more destructive.

Premium has a bad record on projects they have worked on in California.

Existing park lands, and forest will be destroyed for this project.

The water source into New York City (40% Ashoken, 90% total reservoir complex) may become turbid and     undrinkable by the residents of New York City.

Alternative solutions for energy resources for the area have not been researched - especially in wind and solar power.

The project itself was announced in February without adequate time to do this research.

The rush to do this project, which would destroy so much, affect so many millions of people, possibly forever, by an incompetent company must be halted.

Sally Plass. (a resident of both Manhattan and Greene County)

Cynthia Purchase, Marietta, GA.
Please accept these comments regarding docket P-15056.
The proposed 800-megawatt hydroelectric project would draw water from a lower reservoir, the existing Ashokan Reservoir. The upper reservoir would be built at one of three sites: West Shokan, Shandaken, or Hunter. Between 13 and 17 miles of transmission lines would be required to connect to the grid.

I strongly oppose this pumped storage project. 
1. The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and powerlines will permanently damage the viewshed and recreational experiences on multiple hiking trails. Reduced tourist dollars and business revenue would directly hurt area communities.

Undisturbed wild lands and waterways where native flora and fauna thrive would be irreversibly damaged by constructing new dams and reservoirs and associated infrastructure. Noise, light and dust pollution, and increased sedimentation of waterways will degrade trail users’ experiences.

Powerline right-of-ways will disrupt ecosystems and fragment habitat. Sensitive native vegetation will be destroyed. Invasive species will spread into the State Preserve 

2. NYC drinking water comes in part from the Ashokan Reservoir. This project would increase turbidity and negatively impact NYC’s drinking water. 

The US Environmental Protection Agency allows New York City to operate an unfiltered water supply. New York City’s Filtration Avoidance Determination is worth at least $10 billion; the estimated cost to build and maintain a plant large enough to filter drinking water for 9 million City residents.

3. Pumped hydroelectric is a clean solution to the problem of energy storage. However, pumped hydroelectric is a net consumer of energy. Pumping water uphill uses more power than the power generated by letting it run downhill to spin the turbines.

Please deny the preliminary application for Premium Energy Holdings, LLC.
Thank you

Jolie Parker, Olivebridge, NY.
I am writing in regards to the proposed Ashokan Pumped Storage project.  This proposal seems vague at best and in researching I can’t find any information on how it will benefit our community.  We are all very concerned about the negative impact such a 3-5 year undertaking will have on our environment, our wildlife and our beautiful Catskill Mountains not to mention tourism which accounts for a large part of the area business income.

In other words there are many negatives to this plan, and to date not one obvious positive.

To sum up, I and everyone I have spoken to regarding this endeavor, are 100% against it.

William Melvin, West Shokan, NY.



Docket number P-15056-000
Hello,
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. AS a resident of West Shokan, New York, I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While pumped storage and new hydroelectric projects is important the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a negative effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies NYC’s water.  
Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation. 
In addition to its negative effects on the environment and water supply.
The country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
William Melvin

Eleanor Waligurski, BROOKLYN, NY.
To  
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Re: P-15056-000
Dear Ms. Bose,
I am writing to express my opposition to the Premium Energy Hydropower plant proposal.  I do not understand why a preserved natural habitat is the place for such a project.  
The Catskills Forest Preserve contains a wonderful 700,000 acres of continuous wildlife habitat, and the surrounding environment rates in the top 1% of forest habitats in the region.  With human construction projects creeping ever further into what is left of our natural Earth habitat we need to take action now to preserve these wonderful examples of nature on Earth.  A hydropower plant in the middle of one of the most pristine preserves is moving in the opposite direction and runs counter to article XIV of NY’s own constitution which states the lands, “shall be forever be kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
The Catskills are also designated a Status 1 state forest preserve under the USGS Gap Analysis Program.  The  Dept. of Energy’s own hydropower vision declares that: 
“areas with formal protection designated Status 1 or 2 under the USGs Gap Analysis program, are avoided for development.” 
Please deny this proposed project.  I am not against hydropower, and am glad for  a focus on green energy, but this is not the place for such a project.
Secondly, I am not an expert on hydroelectric plants but have read that pumped storage is not an efficient model, and so would recommend taking a closer look at whether this type of hydropower plant even makes sense.
There are other concerns as well, such as effects on sediments in downstream waters such as the Esopus Creek, which would in turn affect aquatic life and further, water quality in NYC.
This particular proposal runs counter to the US mandates and New York’s own Constitution, and makes no sense from an environmental or even practical perspective.  More would be lost than gained. What a sadly misguided irony to destroy a pristine natural habitat in the name of green energy.
I ask that you please consider these concerns in your decision and deny Premium Energy’s proposal for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Eleanor Waligurski

Alexander Borbely, Washington, DC.
As an active member in the Hunter Valley Community I have grave concerns about the proposed hydroelectric power plant. There is absolutely no benefit to the Catskills mountains nor the people who reside there. In fact, there are only costly detriments to the protected wildlife in the region and forced evictions for the thousands of residents in the proposed flood plane. It’s my understanding that this proposal would require rerouting Rt 214. Absurd, impossible and frankly irresponsible. Route 214 is the main access road to the mountain areas where millions of dollars a year are spent on tourism, skiing and lodging, and wildlife activities. The cost of changing the location of route 214 should be an immediate deterrent. The flood plane effectively cuts off thousands of residents from the southern New York State. The damage to the water table will take decades to recover. The environment impact of dams is scientifically proven to disproportionately harm the ecosystem. The energy produced from this plant is not even close to outweighing the negative impact it will have on the freshwater table nor the list of protected wildlife that lives in the area. 

I will be extremely vocal on social media informing the public on how terrible this proposal truly is.

Jen Brueckner, West Shokan, NY.
March 12, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission,
888 First St. NE Room 1A
Washington, D.C. 20426
The FERC project and sub-docket number: P-15056:000

Dear Ms.  Bose,

    Please consider the following points in your decision for the proposal by Premium Energy Holdings of California to build a hydroelectric power plant at the Ashokan Reservoir, Town of Olive, Ulster County, in New York’s Catskill Mountains. 
    We know hydroelectric storage pump plants will happen now and in the future to help meet green initiative goals for developing and maintaining our growing needs for energy utilizing renewable resources.  Adding hydro storage pump systems does make a lot of sense for NY to meet our goals.  We are about 100 miles north of New York City and the current reservoir is part of the New York City water supply system which serves over 9 million people.  The NYC Department of Environmental Protection has expanded its precinct, officers and worked hard to protect it’s watershed by a land acquisition program.  It looks practical from a map perspective of the reservoir to use the existing water to turn the turbines with a building of a reservoir from one of the mountain sites proposed, but the mountainous areas have been protected by the state and the city for over 100 years.
    The City’s drinking water would be threatened by high turbidity from this project and interfere with the Environmental Protection Agency’s Grant of consent for the New York City’s Filtration Avoidance Program (FAD) Filtration Avoidance Determination - DEP which was just revised and granted again in December of 2017 which clearly protects our ecosystems.  This is one of the few sources of natural, unfiltered water in the United States.  Through this waiver it protects one of the largest water systems in the country.  All of the protected forests, soils help maintain adequate levels of carbon for the natural filtration process to happen.  An estimated 8 to 10 billion dollar filtration plant would really be costly to NYC to build and maintain.  
After reviewing the Application of the Ashokan Reservoir Power Plant Proposal/Electric, it came to my attention that it has several misrepresentations:
    One major one is that the configuration is proposed as a closed loop system.  The reservoir to be built from one of the three proposed sites is clearly added on to the open system.  The Ashokan reservoir has the Esopus Creek running into it which is clearly not a closed loop system. Ulster County should not be the only county to be identified (notified)for this proposal.  The proposed Stony Clove Reservoir falls within Greene County as well.  Green County was not notified.
     Many people would be surprised to learn that New York has one of the largest percentages of both state land and state-managed conservation easements in the United States. The Department of Environmental Conservation (DEC) is the state agency which manages 90% of the state land and 4.6 million acres.  
The three proposed sites for the hydro plants are all connected to New York’s Forest Preserve Catskill Park (state land).  The Catskill Park was created along with the Adirondack Park as a way to preserve ALL forested lands both public and private.  Protected as "forever wild" by Article XIV of the New York State Constitution.  This protection of the streams and animal habitats has been in effect for over 100 years.
    The Maltby Brook MoonHaw project proposal site has parts which are protected as forever wild land.  At the end of MoonHaw there is a widely used trailhead to access the Friday Mountain and Balsam Cap from the end of MoonHaw Road and is a 5.6 mile heavily trafficked out and back trail located.  All of the mountains in these proposals bring tourists who enjoy camping and hiking.  
    The placement of high tension/voltage electric lines required would also fall within these protected lands.  These protected lands are home to many protected animals and plants by the DEC:  The protected Three Birds Orchid (Triphora trianthophora), is present at the end of Maltby Hollow Creek and both sides of the upper Dry Brook; these sites are registered in the Biological and Conservation Database for North America.
    Summer foraging habitat for NY-threatened northern long-eared bat  Protection of Northern Long-eared Bats - NYS Dept. of Environmental Conservation
Audubon Catskill Peaks Important Bird Area.  Habitat for NY-Species of Greatest Conservation Need, such as black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk.Habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake.Maltby Hollow Creek and Wittenberg Brook are both trout waters and trout spawning habitat.
    In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. 
     Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace communities, and threaten important natural resources.  
     Please deny the Premium Energy Proposal for the preliminary permit for the Ashokan Pumped Storage Project P15056.

Sincerely,

Jennifer Brueckner

David Rainbird, Margaretville, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

David Rainbird

Jennifer Kabat, margaretville, NY.
I am not sure where to start, the lack of community input or comment before a company in California announced they would build a hydroelectric plant requiring a holding pond. Or that this holding pond (Pond should be in quotes obviously as this is no pond) will destroy countless homes. We are already a community who has been decimated by these projects in the past, and while I don't oppose NYC DEP, we do not/ cannot have more homes taken in such a fashion. 

I could list more reasons, but the most important reason of all is to say that I a citizen of Delaware County in the Catskills am angered and upset by this and opposed to it.

NYC already operated hydroelectric projects on its water supply dams and I applaud this. Premium Energy is applying to build a disruptive system that will destroy towns and communities. We as a region have already sacrificed lands to serve others, to serve the NYC watershed and asking for more sacrifices is criminal.

Richard W Brown, Barnet, VT.
Dear Kimberly D. Bose/FERC

I  was recently shocked to learn of the preliminary efforts of Premium Energy Holdings to build a pumped storage hydro project at the top of Moon Haw Road in West Shokan. Or, to put it more accurately, to obliterate this wonderful area by drowning it under several hundred feet of water. I have been a  professional photographer for the last fifty years and have been a regular contributor to such publications as Audubon, and National Wildlife as well as the author of over a dozen books of my photographs, with a special interest in the interaction of man and the landscape. Sometimes the interaction is benign, but much more often, as in this case, it is irreparably harmful. 

I do not live in the Catskills, but I have photographed there over the years. I know MoonHaw Road and the beauty of the surrounding mountains and forests well, especially along the Wittenberg Brook, where my step-daughter and son-in-law live. Because this spot is not one of the must-see tourist destinations of the region like Kaaterskill Falls, it has escaped the overuse of too many hikers (not to mention the careless selfie fanatic occasionally plunging to their demise.) It remains an unspoiled and beautiful gem, and should be protected, not destroyed!

If the surrounding mountains and the forests along the banks of Wittenberg Brook are designated by law as: "forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private." I don't understand how this is even under consideration. Obviously, this developer's motivation is not altruism or a passion for green energy, but money. I strongly urge you and your committee to put an end to this proposal at the outset and not allow this preliminary permit to go forward.

Thank you,

Richard W. Brown

derek stukuls, Olivebridge, NY.
I am against the proposal to build a Pump Storage Hydroelectric Plant within the Catskill Park. The Catskill Preserve is one of the great public lands in the United States. Preserved in the Constitution of the State of New York to be forever wild. Building this plant could destroy what makes the Park so beautiful to all New Yorkers. I believe that changes to ant land management would have to be done through a New York State constitutional amendment and no other way.

Melanie Kier, MOUNT TREMPER, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the erroneous proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.

Although pumped storage and new hydroelectric projects will be vital to the transition to renewable energy, the pristinely protected forests, streams and wildlife of Catskill Forest Preserve must not be sacrificed in the process.

The Preserve currently contains 700,000 acres of continuous wildlife habitat and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. Destroying this sacred and preserved land for this project is a travesty, and would set a doomed precedent for protected lands across the country. Alternative and more appropriate sites must be instead considered.

In addition, The Catskills are a State Preserve protected by the NY State Constitution. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

The proposed plan would be devastating to the environment. Therefore FERC must decline Premium Energy’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Melanie Kier

James Armstrong, Olivebridge, NY.
To Whom It May Concern,

I am deeply troubled by the proposal of a hydroelectric pumped storage facility (docket number P-15056-000) in the Ashokan Reservoir area. As someone with significant environmental education and an eye toward the future, I well understand the need for alternate power sources. Solar, wind, and water are certainly necessary power sources that will help us all transition away from fossil fuels and will help our Earth survive well past when we are all gone. However, the cost of the Ashokan Reservoir proposed hydroelectric facility is far too great, both environmentally and monetarily.

Throughout my life I’ve enjoyed this area and these mountains more than most. I’ve hiked all the highest peaks in the Catskills time after time. I know beautiful, hidden places that hold a lot of value to me, and that will surely be discovered by adventurous folks in the future. I’ve fished the Ashokan Reservoir and enjoy the views driving over the dividing weir on a daily basis.

To allow a private company to come in and effectively steal “forever wild” land sets an extremely dangerous precedent. The Catskill Mountains are one of New York’s greatest treasures – a resource that is intended to be available for generation after generation. If this private company can “steal” this resource, then what is next? Vail Resorts purchased the Hunter Mountain ski area several years ago. Vail Resorts is a massive corporation, with tremendous capital to invest. What if they decide that Slide Mountain, the tallest mountain in the Catskills, would make a great ski resort? Could they similarly “steal” this Forever Wild land from generations to come, just as it is proposed that Premium Energy Holdings can do for their hydroelectric project?

The environmental impacts of the hydroelectric project cannot be understated, and I’m sure have been addressed by others who are better informed than I. Similarly, the local areas, the tourism industry, and local homeowners will be adversely impacted by a truly massive project. Our local communities may not have the monetary assets that Premium Energy Holdings does but we have a tremendous and rich sense of community, up here in these mountains that are our homes.

Please, do not let this land that I and others value so greatly be turned to simply monetary value for a corporation. We are better than that.

James Armstrong
188 Grassy Ridge Rd.
Olivebridge, NY 12461

docket number P-15056-000

Greg Clarke, Brooklyn, NY.
Hi, there,

I'm writing to urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project. The impact on the environment of the Constitutionally protected Catskills land would be brutal, as would the impact on the people who live there, whose homes would be seized via eminent domain. The land is considered status 1 land according to USGS Gap Analysis and should be protected from development. I'm sure people more articulate than me have made these points in greater depth, but I wanted to take a moment to add my voice. Thanks!

Mark Loete, Chichester, NY.

Ms. Kimberly Bose                                                                            Secretary Federal Energy Regulatory Commission                                             888 First Street NE                                                                    Washington, DC 20426 
RE: Docket #P-15056 Ashokan pumped storage hydroelectric proposal 
Dear Ms Bose, 
I’m writing to express my opposition to the pumped storage hydroelectric generation project proposed by Premium Energy Holdings LLC for the Catskill Mountain region of upstate New York. (FERC Docket #P-15056). 
While recognizing the role pumped storage hydro electricity generation has in our future of a clean, renewable energy economy, the Catskill Mountains and Catskill State Park are the absolutely worst possible choice of location for the project proposed by Premier Energy. The reasons are numerous. Where to begin? 
1) Article XIV of the New York State Constitution (amended to the NYS Constitution in 1904) explicitly designates the Catskill State Forest lands as “Forever Wild”. A rare thing in today’s America. “Forever Wild” still means forever wild. This project would require an amendment of the NYS Constitution to move forward. 
2) Any one of the three proposed upper storage reservoir locations would require the seizure and inundation of numerous privately owned parcels. The proposed site for the Woodland Valley upper storage reservoir, by example, would displace and disenfranchise an estimated 75 to 100 homeowners. 
3) While the latest scattershot proposals from Premium Energy would seem to indicate land to be inundated by the upper reservoir proposed locations would be primarily privately owned land that would be seized by eminent domain, the disruption of natural wildlife habitat, riverine drainage systems, pristine forest growth patterns, etc, would be felt throughout the contiguous forest ecosystem.
4) All three of the current proposals for the upper storage reservoir location would subsume critical wild trout habitat. The Catskill Mountains are world famous for our wild trout angling opportunities. In a “Forever Wild” economic environment, our wilderness resources are our most valuable economic resource. Compromising our free flowing trout streams is compromising the life-blood of our economy.
5) The Catskill Mountain water resources are the drinking water source for nine million (and counting) New York City residents. The Esopus Creek drainage, where the project is sited, is the source of 40-45% of that water, delivered to NYC taps UNFILTERED. The Catskill-sourced, New York City water system is the largest ground water sourced municipal water delivery system on the planet. 
Urban planning officials come to the Catskills from all over the world to study it. New York City is one of only five municipalities nationwide that are allowed to deliver tap water unfiltered. This by fiat of a “Filtration Avoidance Determination” issued by the Environmental Protection Agency. The disruption of free-flowing drainage systems and the resulting disruption of natural bed load transport and increased turbidity threatens New York City’s Filtration Avoidance Determination, at a potential cost of billions of $ annually to construct and maintain a municipal filtration system. 
Many more objections could be raised, and they have been elsewhere. The detriments of P-15056 so far outweigh the benefits, one wonders if the applicant, Premium Energy Holdings, has ever even visited the proposed sites. Likely not. I’m asking, as a private citizen residing in the Catskill Mountains, and as the president of our local Ashokan-Pepacton Watershed Chapter of Trout Unlimited conservation group, to deny the permit to study this proposal. 
Thank you for your consideration, 
Mark Loete 
President Ashokan-Pepacton Watershed Chapter – Trout Unlimited

Elise Lark, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Re: Docket number P-15056-000

Dear Ms. Bose,

I am writing to oppose the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains, due to its expected deleterious impact on the pristine Catskill Forest Preserve, consisting of 700,000 acres of increasingly rare continuous wildlife habitat, and on the Ashokan Reservoir, which provides the largest unfiltered water supply in the nation. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Firstly, the proposal would be in violation of the NYS Constitution (Article XIV), which guarantees that government protected lands, such as the Catskill Forest Preserve, “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” While pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, we need to proceed conscientiously, applying an ethos of DO NO HARM (to the greatest degree possible). We cannot afford to rob Peter to pay Paul (harm the environment in the interest of preserving/protecting our environment) by irresponsibly and illegally wreaking havoc on a rare, protected habitat, with devastating consequences. For FERC to allow the proposed project to proceed would be condoning a crime as well as establishing a doomed precedent for legally protected lands across the country.

Furthermore, the destructive consequences of pumped storage would be expected to continue well after construction, due to the interconnectedness of the Ashokan watershed and its tributaries, propelling a damaging cascading effect on the nearby stream ecology, both water and land habitats, and its wildlife. Premium Energy’s proposal falsely claims it is a closed-loop system; rather it is an “add-on,” and the resulting water fluctuations would undoubtedly increase turbidity within the Ashokan and its watershed. Eventually, the Pumped Storage Project could be expected to disrupt the sediment regime of the Esopus Creek, thus having both wildlife and human impact, compromising trout-breeding and NYC’s source of clean drinking water.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to the residents of local communities, resulting in a resurgence of displacement that began with the construction of the Ashokan Reservoir a century  ago. This would result in enormous hardship due to the current housing climate in Ulster County; a shortage of housing has causing prices to skyrocket. 

Premium Energy’s proposed project would also negatively affect the Catskills’ growing tourism economy, and thus employment, by limiting access to recreation, and diminishing the area’s natural beauty, that which makes it a desirable destination. It would also impact tourism beyond Ulster County, by cutting off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville. Loss of jobs and housing could result in people leaving the region, especially those with less socioeconomic resources and opportunities.

Lastly, while green innovation is a necessity for our planet, its habitats and inhabitants, and for our children’s and grandchildren’s future, Premium Energy’s Ashokan Pumped Storage Project, fails to represent the kind of innovation encouraged by the Department of Energy and communities (i.e., closed-loop pumped storage projects, which have a smaller environmental impact than those making use of existing watersheds). Premium’s false claim that its project is “closed-loop” only breeds distrust and despondency. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Elise Lark

Divyan Mistry, Denver, NY.
This project will not be good for the catskills watershed. As a resident I urge ferc to block this

Henrietta Wise, Olivebridge, NY.
From:                                                                            April 10, 2021
Henrietta Wise
208 Krumville Road
Olivebridge, New York 12461


To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.


Docket number P-15056-000


Dear Ms. Bose,


I am writing for myself and my family to list some good reasons why FERC must deny a dangerously faulty preliminary permit application by Premium Energy Holdings LLC, to study the feasibility of building a hydroelectric stored power plant on the Ashokan Reservoir and surrounding watershed: Ashokan Pumped Storage Project P-15056.


The Ashokan Reservoir is known by scientists throughout the world for the millions of lives it supplies with fresh water without fear of the contamination so many other reservoirs throughout our and many other countries suffer (including the toxic chemistries usually applied to kill pathogens)  because untold millions of people's watersheds have been breached by greedy industries and poor oversight.


The Ashokan Reservoir's watershed covers 255 square miles of the rainwater and snowmelt accumulating through the waters of eleven Towns in Ulster, Greene and Delaware Counties. Those waters are tended by protected ecologies - many legally protected.


Premium Energy's proposed new 216-acre reservoir with it's Open Loop system - Not "Closed Loop" as the company has falsely claimed in its application - would introduce destructive fluctuations into the Ashokan Reservoir's waters e.g., lowering and raising them via a foreign, imposed system. The resulting increase in raparian damage and turbidity alone would no doubt cost the DEP it's hard-won Filtration Avoidance Determination from the EPA triggering the necessity for filtration at the present amount of $10 billion. 

 Accordingly, this ill-conceived project presents a clear and alarming legal precident and physical danger to the waters and carefully time-proven monitoring of them for their safety for not only 9 million lives in New York City; 70 communities North of the City; the protected ecologies and waters of the Ashokan Reservoir Watershed territories in all eleven towns of three counties in the Catskills but, equally alarmingly to the three protected Catskill Forest Preserve territories around which and directly into which the Premium Energy Holdings reservoirs are proposed to be built: Stony Clove in Lanesville; Woodland Valley Road in Phoenicia and Maltby Hollow Brook in the Town of Olive.

 The Catskill Forest Preserve is protected as "Forever Wild" (Article XIV NYS Constitution).  The Preserve protects and serves as Catskills' finest scenic recreational and ecological destinations for International fishermen and a fast-growing multitude of tourists.  Its protected beauty is international.  To breach State Constitutional law to allow egress to a private corporation sets a forbidden legal precedent in our system.

Audubon has designated the Preserve as an "Important Bird Area."  The Preserve contains multitudes of birds and Protected Species.  In this unprecedented time of the death of one-third of all the birds in America, All must be made to understand that the Catskill Forest Preserve Must be Carefully Guarded.

The Catskill Forest Preserve has been designated by the United States Geological Service as "Status 2 Lands." The Department of Energy's own Hydropower Vision says "Areas with Formal protections designated as Status 1 or 2 under USGS's Gap Analysis Program, are avoided for development."  For example: Whittenberg Dam area is USGS designated as "Status 2."

I do not know the heads of Premium Energy Holdings, but judging from the glaring mistakes found by the DEP and other reliable sources in their preliminary permit, I believe they must not be allowed to endanger our very precious water systems anywhere at all.

Thank you for keeping our lives, kid's lives and the integrity of our States' waters and ecology highest in your decision.

Sincerely,

Henrietta Wise

Frank M Parslow, West Shokan, NY.
4/11/2021
Kimberly D. Bose				
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Frank Parslow

Benjamin Hellman, High Falls, NY.
Dear Friends,

I just heard about the organization, Save the Catskill Preserve from my father. Their call to action is to stop “Premium Energy” from building unnecessary dams and flooding hundreds of acres of wilderness protected by the New York State Constitution in perpetuity.  As an avid hiker, fisherman, camper, and rock climber of the Catskills and a long-standing resident of Ulster County, I believe this is a very important cause. I believe it would be a travesty to flood these ancient forests and deprive my children and their children’s children the ability to enjoy these sacred lands. Please lend your voice to help protect such a huge part of Ulster County’s Legacy. 

Best Regards,

Benjamin Fredrick Franklin Hellman

Madeline Mallon, Phoenicia, NY.
Dear Ms. Bose,
As an avid birdwatcher and nature enthusiast I am aware of the potential damage the project being considered can do to bird populations as well as fish populations.  The Catskill area is known for it trout fishing, dark night skies with less light pollution than the surrounding areas, poetic vistas for artists, and wild life hiking trails open to all to explore.  

Herons, eagles, osprey, and many other birds, depend on healthy river systems for food and shelter. They make their nests in and along the  banks of Esopus.  It's taken decades for the Eagles to return to our area, it's been mainly in the last 10-15 years they have increased in numbers.  The hydroelectric dam and storage area will prevent the natural highs and lows of the stream, changing the patterns of migration for trout, that are a huge draw for tourists in our area.  This project can also reduce the breeding ground of migratory fish—a key food source for eagles, osprey—and cloud the waters, making it harder for these birds to spot their prey.  
I strongly request you seek to protect the wild life of our esteemed area.                                            Respectively,                                                               Madeline Mallon RN.







The cure for anything is salt water : sweat, tears, or the sea. Isak Dinesen

Mark Bernard, Kingston, NY.
Dear Ms. Bose,

As Hudson Valley native, I am concerned about the proposal submitted by Premium Energy Holdings in their quest to construct a pumped storage system based on the Esopus Creek and Ashokan Reservoir.  I ask FERC to reject Premium's request for a preliminary permit of their project P-15056.

While I do appreciate the usefulness of energy storage for our grid, the location chosen is terribly irresponsible with respect to risks to NYC's drinking water, and the area's rare, forever-wild contiguous wildlife habitat.

The first red flag that caught my eye was Premium's unabashedly false contention that their proposal is for a closed-loop system. It's obviously an open-loop system; as it involves the Esopus Creek, Ashokan Reservoir, and Ashokan Watershed. Just on the merits of Premium Energy Holdings having lied in order to meet NYS' preference for closed-loop storage solutions, I think they've demonstrated either incompetence, or a breach of good faith.

The second red flag is that they would even attempt a site with such a sensitive ecology, which further influences the public health of New York City.  Management of turbidity and sediment is already a challenge for the NYC Bureau of Water Supply.  In order to keep the drinking supply clean; the upper Ashokan reservoir is used to buffer turbid waters from entering the lower reservoir after heavy storms.  This allows sediment dumped from the Esopus to settle before being released in the lower reservoir.  Creating a new source of turbidity, operating on a never-ending 24 cycle, would certainly cause insurmountable problems for water delivery from the reservoir; since it takes more than 24 hours of buffering to allow suspended particles to settle.

I'm not as much of an environmentalist as others, but I would be remiss if I didn't mention that the State Constitution explicitly declares this area "shall be forever kept as wild forest lands," and not "be leased, sold or exchanged, or be taken by any corporation, public or private."  Shouldn't that be enough of a reason on its own?

Please reject Premium Energy's proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Yours,

Mark Bernard
49 Fischer Ave
Kingston, NY 12401
845-658-8555

Traci A Parks, Chichester, NY.
April 11, 2021

Ms. Kimberly Bose, 
Secretary Federal Energy Regulatory Commission 
888 First Street NE 
Washington DC 20426 

Re: Ashokan Pumped Storage Project Docket Number P-15056-000

Dear Secretary Bose:

I, Traci Parks, file this Motion to Intervene in this proceeding. 

I will be directly impacted by the project’s effect on the Stony Creek, New York State Route 214, the Esopus Creek, and the Ashokan Reservoir in Ulster County, which provides 40% of the unfiltered drinking water for New York City. I respectfully request that the Commission grant my Motion to Intervene as a party with full rights to participate in all further proceedings. 

Respectfully submitted on 04/11/2021 

Traci Parks 
96 Stony Clove Lane 
Chichester, Ulster County, NY 12416

Sorrel Brae Ahlfeld, Lanesville, NY.
Kimberly D. Bose

Federal Energy Regulatory Commission

888 First St. NE, Room 1A

Washington, D.C. 20426.

Docket number P-15056-000

Sorrel Brae Ahlfeld
1245 Route 214
Lanesville, NY
12450

April 11, 2021


Dear Ms. Bose,

I am writing in reference to Premium Energy Holdings’ proposed hydro-electric project in New York’s Catskills State Park currently seeking approval from your Commission.

I am a resident of Lanesville, NY, one of three potential communities to be flooded should the project go through. But it is not as a resident concerned with my own property that I write to you today.

Instead I am deeply concerned that one of New York State’s oldest wilderness areas, protected from development by law in the State Constitution, may be irreversibly compromised by the extreme intrusions outlined in this proposal.

Alternative methods for generating energy are sorely needed in this country and I am a vocal supporter of moving to green energy solutions wherever possible. But this project is not what it seems. 

First, it is not a “closed loop” system as Premium Energy Holdings has claimed. It is what they call an “add on”. The years of necessary development they propose would wreak havoc on the local ecology, creating substantial destruction of existing natural and protected habitats.

Second, once operational, pumped storage raises and lowers water levels frequently and rapidly, creating turbidity up and down local streams and creeks that rank among the nations best trout fishing destinations. In addition, this turbidity pushes sediment downstream, eventually bringing it into the Ashokan Reservoir which, as you know, is a main component of New York City’s drinking water system, serving 9 million residents.

Finally, pumped storage itself is merely a stop-gap in the hunt for better sources of energy. Instead of creating a truly renewable resource that moves the country off of carbon-based fuels, pumped storage simply plays an economic shell game, pumping water when the rates are cheap in order to generate electricity from that water when the rates are more expensive.

I have no doubt this makes fiscal sense to a private company looking for short-term profit but, as a nation, we need to be thinking long-term, investing in the kinds of renewable projects that will bring us fully into a new, green economy. This project does not meet that standard.

I strongly encourage FERC to decline this request for a preliminary permit for the Ashokan Pumped Storage Project. Not only would it negatively impact long-protected wilderness, imperil the clean and unfiltered drinking water of New York City, and disrupt hundreds of mountain communities along the way, but it is a cynical solution to a truly pressing problem.

Our nation deserves better.

Thank you for your time,

Sorrel Brae Ahlfeld

Dr. Wayne Ouderkirk, Lake Luzerne, NY.
I am writing in opposition to this project. It will encroach on NY State Constitutionally protected lands in the Catskill Park. 

Those lands are revered by New Yorkers and by many others from around  the USA and around the world. 

Also, this project will inundate hundreds or thousands of acres in an ecologically sensitive region. Habitat destruction, interference with wildlife, and destruction of human communities and businesses will all result from this ill-conceived proposal should it come to fruition. 

In addition, the creation of additional electricity supply is a wrong-headed response to the need to reduce fossil fuel usage. Alternative efforts such as increased conservation and efficiency would be better solutions.

FInally, the net gain in supply will not be as great as many believe, since the creation of the power from the project requires the use of electrical power in order to accomplish its aim. The chief gain would be for the owners of the project, rather than to the residents of the affected communities.

For these reasons and more, this project should be rejected before it gets under way.

Yours truly,
Dr. Wayne Ouderkirk
Lake Luzerne, NY

David Wargula, Slingerlands, NY.
I am writing to object to the hydro-electric dam building project, docket P-15056.  I have been visiting the Woodland Valley Campground and hiking area for over 6 years.  I love this area.  This land should continue to be preserved as per article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  If we don't honor this article it will only lead to other businesses doing the same.  The article should not be broken for any reason.
I travel to this area several times a year for hiking, camping, and fishing.  Then, I stay at the town of Phoenicia where me and my friends often stop at the Phoenicia Diner.  Without this land and the draw of the preserved wilderness, I would search out other places that offer a unique combination of food, culture, and outdoors.

Thank you.

David Wargula

Anne Devine, Bearsville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am a Catskills area resident writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.
 
I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Premium Energy's project in any of the proposed area/s would displace wildlife.
The region is a crucial homeland to countless birds and wildlife. Around the Ashokan Reservoir and nearby forests, there are nesting Bald Eagles (Haliaeetus leucocephalus) and numerous other protected birds. 

As a local resident, walking artist and avid outdoor enthusiast, I have walked throughout the area and hiked many of the trails of the Catskill Preserve. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. ANY conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing (rental or purchase), as there is currently an extreme housing shortage in Ulster County.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Anne Devine

Joseph Felter, Pine Island, NY.
I am AGAINST this project. 

The project would increase turbidity and pollution in the protected Ashokan Reservoir, which supplies 40% of NYC’s drinking water.

Justin Michel, West Shokan, NY.
Justin Michel
218 Moonhaw Rd.
West Shokan, NY 12494

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

April 11th 2021
Docket number P-15056-000
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

I live on Moonhaw Rd, site of the Wittenberg Storage project.  I am tied to the land and its inhabitants in a spiritual and financial way.  While I will be extinct at some point, the animals and plants in our area need not be.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,

Justin Michel

Delia K. Adams, West Shokan, NY.
	I join the myriad number of people who say NO to the application.

	The surreptitiously (acting in a stealthy way) presented, insidious (intended to enrage or beguile) application has already caused great harm to many people who are seriously suffering from the Covid 19 pandemic and its effects, and questioning every aspect of their future.

	This added burden is unacceptable!

	We live our lives in the Catskills as conservators of precious resources —- from the purest water for a city with millions of people to an unmatched environment of natural beauty for renewal of sprit and health.

	Please do the right thing and reject this entire application that is before you!

Adam Kaufman, SEATTLE, WA.
OMMENT SUBMITTED:

Dear Federal Energy Regulatory Commission, 

I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. 

This project raises major environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

It is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to this community and raises our concern over Premium Energies practices. 

A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Yet, this is what is being proposed.

The Protected Three Birds Orchid currently live at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.” 

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. Not to mention that it is the current habitat for Black Bears, Eagles, Mink, Egrets, Owls, Bobcats, Beavers and many other wildlife species which would be greatly impacted by the plan.

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and Status 1 protected land. 

I ask that you deny this permit based on these essential points, and that they look for some other non threatening site for their work. 

Thank you for your time,  

Sincerely, 
Adam Kaufman

Seattle, WA (formerly of Brooklyn - having spent many days hiking in the beloved and forever wild catskills region)

James R Devens, West Shokan, NY.
I, James Devens, Own property as well as a physical residence in one of the proposed building site locations which is included in the premium Energy holdings, LLC Project No. 15056-000. I am seeking a motion to intervene because of the massive damage it would create

The proposed building site, Alternative 3, Wittenberg Reservoir, is located where my entire property and residence exists.  This would totally render my property and residence useless and would completely destroy the entire area.

My Address is:
James Devens
298 Moon Haw Road
West Shokan NY 12494

There is important damaging information and perspectives to be brought to this process, which will serve the publics interest.I JAMES DEVENS requests the commission to grant my Motion to intervene as a party with full rights to participate in all and any future proceedings

Respectfully

James Devens
298 Moon Haw Road
West Shokan NY 12494

Cheyenne Mallo, Olivebridge, NY.
I am writing in opposition to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric plant in New York’s Catskill Mountains.  

The proposal to situate this hydroelectric plant in the Catskill Mountains shows a disrespect and lack of basic understanding of this area's history, and its environmental and tourism history and future.  

The Catskills Forest Preserve was created in 1885 in Ulster County, and consists of a continuous wildlife habitat of around 700,000 acres.  This pristine forest ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index.   As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”  According to Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

Not only is this land protected, it provides essential tourism through access to wilderness hiking and fishing, among other activities. The Catskills have seen an exponential growth of users in recent years, and offer the only regional opportunity for this type of recreation on continuous land.  By taking away area to build the proposed hydroelectric plant, more users will be forced onto already crowded trails, increasing the negative environmental impact on this pristine wilderness.  

I strongly urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Cheyenne Mallo

Tom Luciano, Phoenicia, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

 Tom Luciano

Melody Troeger Sweet, Tully, NY.
FERC docket # P-15056-000
To the committee that determines the future of the Catskill Forest Preserve,

April 11, 2021

	I was greatly distressed when I heard about the plan to build a hydro-electric plant in the West Shokan and the Woodland Valley, in particular.  My family and I have been summer residents of Roxmor Colony in Woodland Valley since 1965.  I am VEHEMENTLY against the proposal put forth by Premium Energy Holdings to build a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity in the West Shokan area.   
	I understand that one of the proposed sites for a damned reservoir is Woodland Valley and it would affect historical structures, including the William L. Beach House and Roxmor Inn.  Built in 1914, the Roxmor community has applied to have this structure listed on the National Register of Historic places.  
	In the 1980’s Roxmor Colony was told that they would no longer be able to construct a temporary summer damn on the Woodland valley stream, which ran through their property and, eventually, into the Esopus Creek.  This small wooden damn was build every July, for the children.  It created a 5 foot (maximum) deep pool, about 20 x 60 feet, and water flowed freely over the top.  It was deconstructed annually, right after Labor Day.  They were told that, even though fish nibbled at the swimmers toes, this small temporary damn would have too great an impact on the regional stream ecology.  So, they respected the DEC policy and the stream was never altered again.  
	And NOW there is a proposal to permanently dam the stream in Woodland Valley.  I can’t believe it.  How could this happen?  Where is the DEC now?  This proposed project would have an extreme impact a highly preserved region of the Catskill Forest Preserve, considered Status 1 by the Department of Energy.  How could this project even be considered when Status 1 regions are to be “ avoided for development?”  
	And I am surprised that NYC, which receives 40% of their water from this watershed, is in favor of this proposed project location. 
	“The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams” and affect NYC’s drinking water.  Please DO NOT continue to consider this hydro-electric plant proposed by Premium Energy Holdings.

							Sincerely,

							Melody Troeger Sweet

Henry Malarkey IV, MD, Jamestown, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Henry Malarkey IV, MD

Nathan Lehmann-Ziebarth, Willow, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Nathan

Philip Pardi, Phoenicia, NY.
10 April, 2021 								
Phoenicia, NY

re. the FERC project # P-15056

Dear Members of the FERC,

I’m writing to express my strong opposition to the plans to build a hydro-electric dam in the Catskills. Although my own house will likely not be directly affected, I am horrified that such a plan has even been articulated. It’s the kind of idea I’m tempted to laugh off, but the prospect is just too disheartening to ignore. I could write pages, but for now, I’ll say just this.

The proposal to build a dam in Woodland Valley (which is just down the road from where my wife and I have lived full-time for twenty-five years) would destroy one of the most cherished parts of the Catskills. If you haven’t been here, please come—I’d love to show you around. Woodland Valley attracts countless walkers, runners, bikers, birdwatchers, campers, hikers, hunters, fishers, to say nothing of the many folks who actually own homes there. The impact is far and away greater than any benefit I’ve seen listed. 

Furthermore, to remove all those homes and eliminate the woods that attract so many visitors would essentially destroy the town of Phoenicia. Like so many upstate towns, it relies on a mixture of year-round residents, weekend/summer residents, and tourists. I have lived here for over two decades and seen many businesses come and go. It’s tough. Friends who own local B&B’s and antique stores are often on the brink—a string of rainy weekends in July and August is about as much as they can withstand. Take away the thousands of residents and visitors—to say nothing of the tax base that supports the town more generally—and the results will be painful to many, many people. 

In addition, as far as I can tell, such a project is illegal. These lands are supposedly “forever wild.” A quick Google search yields this from the New York State Constitution: the Catskills “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” My understanding is that the only way to revise this clause would be via an amendment to the Constitution. 

A century ago, a dam and reservoir were built in nearby Ashokan, and in the process, a handful of towns were dismantled and/or moved. All these many years later, that loss—and the loss of tax payers—continues to poison local politics. (It flared up not long ago in the local school board elections, and it will doubtless return.) Decisions like the one before you now have an outsized effect on residents today and those of the future. I hope that fact will give you pause. Certainly, for those of us who live here, have raised families here (our son went to Onteora schools K through 12), and plan to retire here, that history is not one we will allow to be repeated. 

I teach across the river, and each day, driving home, I cross the Rhinecliffe-Kingston Bridge. I’d like to show you that view, too: the entire Catskills are spread before you, including Overlook Mountain in the foreground, Indian Head and others off to the north, and what I like to call the Shandaken mountains in the distance to the south. Often, depending on the season, the sun is sinking or setting. If I work late or if it is winter, I might catch a stunning sunset. I’ve been driving across that bridge for eighteen years, and I never tire of the view, never tire of feeling a thrill as I return to these mountains. They are worth cherishing and protecting. I hope you will join us in turning aside this proposal.

Sincerely,

Philip Pardi
131 Muddy Brook Road
(845) 688-2824

Kristopher Seto, Prattsville, NY.
Hi there,

I'm a Catskills region resident who is adamantly against this proposal for so many reasons:

-The detrimental effects on our region.
-The potential harm to our drinking water.
-The ways that a non-local organization is proposing to invade our region for their own private profit. 
-The people it would displace.

This is a protected area. Could a citizen propose such an absurd development? 

There are lots of ways to harness green energy in this region that do not involve such a massive, destructive undertaking.

Who does this proposal really benefit?

Not us.  

Do not allow or consider this proposal.

Roberta Ziemba, Kingston, NY.
URGENT re: Ashokan Reservoir

APRIL 10 2021
Online submission - Motion to Intervene: Ashokan Pump Storage Project 
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission 888 First Street NE
Washington DC 20426

RE: MOTION TO INTERVENE Docket # P-15056 – Ashokan Pumped Storage Projecti
Dear Secretary Bose:
Please hear my plea to not allow this plan which I strongly feel would distrupt the animals that live in the Catskill region. I moved to this area 20 years ago and I want to advocate to preserve the land the fragile ecosystems. 

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314), Catskill Mountainkeeper, a non-profit organization with its primary office in Livingston Manor in Sullivan County New York and a satellite office in Woodstock in Ulster County New York, hereby petitions the Federal Energy Regulatory Commission to grant it full party status in the above captioned proceeding. 

The persons to whom communications should be addressed and to whom service should be made are as follows:

Kathy Nolan, Senior Research Director PO Box 1081
Woodstock NY 12498 kathy@catskillmountainkeeper.org

Ramsay Adams, Executive Director PO Box 1000
Livingston Manor NY 12758 ramsay@catskillmountainkeeper.org

As grounds for this Motion, Catskill Mountainkeeper states as follows:
Catskill Mountainkeeper, a 501(3)(3) non-profit organization has a vital interest in the Preliminary Permit application submitted to the Commission by Premium Energy Holdings for the Ashokan Pumped Storage Project (P-15056). 

Catskill Mountainkeeper is a nationally recognized advocate for the Catskill region and works with a network of more than 40,000 concerned citizens and strategic partners to protect and promote our region’s extraordinary natural heritage, while promoting smart development that supports local communities. 

Catskill Mountainkeeper seeks to become a party to this proceeding to ensure the public interests of residents of Shandaken, Olive, communities near the Ashokan Reservoir, and residents of New York City are adequately represented. 

Our members stand at risk of serious harms from the construction and operation of the project, as well as from additional infrastructure necessary to service it, such as the Ashokan Switchyard, powerhouse, and transmission lines. 

Accordingly, Catskill Mountainkeeper has a substantial interest in this matter. No other party represents Catskill Mountainkeeper’s interests, and no other party reasonably could do so. 

Neither disruption to the proceedings nor any additional burden to any party will result from the granting of this Motion. In light of the foregoing, Catskill Mountainkeeper respectfully petitions for intervention. 

Ramsey Adams
Executive Director 
Catskill Mountainkeeper
and Roberta Ziemba

Carsten Warnes, West Shokan, NY.
  My name is Carsten Warnes.  I reside at 4265 Route 28A, West Shokan, NY 12494.  I am writing in opposition to the Premium Energy Proposal P-15056:000. The Catskill Forest Preserve is supposed to be "forever wild". It was created for that exact purpose in 1885 in Ulster County.  The language in Article XIV of the New York State Constitution states that the land shall not be leased, sold, or exchanged, or be taken by any corporation, public or private.  The idea was to guard and conserve the land in world that is increasingly fragmented.  The Preserve consists of 700,000 acres of contiuous wildlife habitat.  The habitat contains both birds and fish that will be endangered by the project.  All three reservoirs fall within the Audubon's Catskill Peaks Important Bird Area.  The Catskill Forest Preserve are considered Status 1 lands under USGS "GAP Analysis Program".  The Department of Energy has stated that lands with this designation cannot be considered for projects.
   Premier Energy says their project is a closed loop.  It is not, but rather is an add-on project which is not what the Department of Energy is looking for in the way of innovation.

Zeke, Acton, MA.
Hi. I’m Zeke, an 11-year-old from Acton, Massachusetts. Before I can remember, I’ve always had a summer home, where I went with all my family, in Chichester, NY. It is a place that brings joy to me, and a place where so many memories were made. Since the world shut down because of COVID-19, I have been thinking about Chichester a lot. Thinking back on everything that happened and thinking about what we’ll do in there once the world is out of quarantine. When I heard the news that your company was going to use the land that our house in Chichester, as well as so many others, as building grounds for a hydroelectric plant, I was upset. So I’m saying this, on behalf of everybody living and working on the ground where you’re going to build the plant, please, don’t. That place is a lifeline for me, so please don’t cut it.

Sincerely,
Zeke

Janet A Steen, West Shokan, NY.
I am writing regarding the proposal by Premium Energy of California (Docket #P-15056) to create a pumped storage hydro plant in the Moonhaw Valley of West Shokan, NY, a hamlet in the town of Olive in Ulster County. The proposal seeks to use the water of New York City's Ashokan Reservoir in combination with a new reservoir of some 250-300 acres that would sit above the Watson Hollow community, now the center of West Shokan.   
 

My neighbors and I understand the need for various kinds of renewable energy. However, the Premium Energy proposal is not the kind of hydropower that the Department of Energy wants. While claiming to be an environmentally sound "closed loop" project, it clearly is not – it is an “add on,” and likely to be much more environmentally destructive. So Premium is either being purposefully dishonest in its application or it doesn't know what a closed loop project is. Either way, an application with such a glaring "mistake" is not worthy of approval for further study.
 

The nonstop churning of Ashokan Reservoir water that would be caused by the proposed project would threaten and very likely reduce the quality of drinking water for 9.5 million residents downstate. Does anyone really believe that the pristine, unfiltered water that city residents now enjoy would be unchanged by such an ongoing assault on one of its principal water sources, with the enormous increase in turbidity and continual disturbance of the sediment at the bottom of the reservoir?
 

Also, as I understand, the plan as proposed will most likely use more energy than it produces. I know that part of the point is energy storage for peak times -- during which we've almost never had an issue here, partly because many see no need for air conditioning in the summer. But the enormity of the destruction to be caused by this proposal does not seem justified when there is unlikely to be a net increase in energy produced.
 

This is also an area where residents' options for making a living are already severely limited by the restrictions posed by being in the New York City watershed. Tourism is a major industry here, and to destroy a massive amount of the most beautiful land in the area, in addition to running high-tension wires for many miles -- from West Shokan to Kingston -- will not only change the character of the area but will surely reduce the incomes of many who depend on year-round visitors to survive financially. What will replace this income? Is there a plan for that? If there is, I haven't heard one.  

 
In addition, this is an area that is home to numerous species designated by New York to be of greatest need of conservation, including the red-shouldered hawk, the black-throated blue warbler, the scarlet tanager, the wood thrush, the timber rattlesnake, even the three birds orchid (which would be entirely destroyed by Premium Energy’s project)...the list goes on and on.

 
The area also includes lands that, according to the New York State Constitution, “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

 
West Shokan has already been destroyed once, during the building of the Ashokan Reservoir early in the 20th century. But the people here are close enough to their recent ancestors that the grief remains from that first displacement. Will they be forced to endure a second destruction of West Shokan?
  

Obviously, this is where I live, I love where I live, and I don't want it to be destroyed. It would be silly to pretend otherwise. But the flaws in Premium Energy's plan are so significant and clear that this issue goes far beyond the not-in-my-backyard scenario. With such a great need for beneficial projects that wisely achieve what they set out to do, time and money and energy should be spent on a better proposal than Premium Energy's.
 

Thank you for your consideration.

Janet Steen

Ian Faden, Brooklyn, NY.
Ian Faden
20 Ditmars St, Apt 3
Brooklyn NY, 11221


To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Ms. Bose,

I am taking the time to write because I care deeply about how the proposed hydroelectric power plant would affect the Catskill region and its environment. As a frequent visitor to the specific area that would be sacrificed, I vociferously oppose development in a pristine forested area. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ian Faden

Muriel Rush Gillespie, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

(your name)

Simon Berring, Phoenicia, NY.
Docket number P-15056-000

Dear Ms. Bose or other interested party,

I am writing to strongly object to proposed Project P-15056 in the Catskill Mountains of NY.

I live in an area which would be dramatically impacted by this project, particularly if the "Woodland" proposed site is adopted. As far as I can tell, the project will have substantial negative impacts on the local environment and New York City's water supply infrastructure. However, I most wanted to emphasize that it would be devastating to my century-old nearby community. It's hard to tell from the maps, but the project would almost certainly involve the destruction of critical roads, the displacement of houses, and the despoiling of much of the well-loved surrounding natural beauty.

Please reject Premium Energy's request for a preliminary permit. (!)

Sincerely,
Simon Berring

Deborah Franke Ogg, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing you to urge you to reject current and all future proposals from Premium Energy Holdings, LLC. concerning the Ashokan Pumped Storage Project.  They obviously did not do their homework, and I doubt they ever will.

 I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, for the reasons listed below.

• Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

• There would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

• In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County.

• Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

• As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

• The Wittenberg Brook site is also a local habitat for the rare Three Birds Orchid (Triphora trianthophora) which would be wiped if this site were approved. In all three proposed sites the Timber Rattlesnake which is already on the endangered species list would be deeply effected.

Respectfully Yours

Deborah Franke Ogg MSW, LCSW

Michelle beck, Germantown, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Michelle beck

Iris Brown, Kerhonkson, NY.
DOCKET# P-15056-000

I am writing to voice my strong opposition to the Premium Energy Holdings proposal for the Ashokan Pumped Storage Project. DOCKET# P-15056. 

The company in question is not being honest about its intentions in order to ram through this shoddy project.
Premium is claiming to be “closed-loop.” project. Closed loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval. Contrarily, projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects; that’s what this really is. They are lying.  

This project will be devastating, not only to The Catskill Preserve, but also to its wildlife, the surrounding water systems, all the residents of the area, the thousands upon thousands of tourists who visit this pristine and beautiful area every year (which is an economic boon to the area) and the many millions of New York City residents, whose drinking water will be adversely effected. 

According to the DEP. The Ashokan Reservoir and watershed, provides 40% of NYC’s water, a water supply that provides 1 billion gallons a day to 9.5 million people. This valuable capital asset, represents $1.7 billion since the 1990s alone. This is another reason that this economically unsound project should be denied.

‘The Environmental Species Act’ protects much of the wildlife on this preserve. This is yet another reason to deny Premium Energy Holdings.

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Under Article XIV of the NY State Constitution, the Catskill Preserve lands “shall be forever kept as wild forest 
lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
FERC cannot selectively choose if they will abide by the NY State Constitution.

It is for all these reasons (stated above) that I vehemently oppose this proposal. It must be struck down. I Vote NO!

Best,

Iris A. Brown
20 Tilly Rd
Kerhonkson NY 12446

A. Gaudioso, West Hurley, NY.
Dear Commissioner,				RE: Docket number  P-15056-000

I am a 20-year homeowner and Ulster County resident and taxpayer. I’m also someone who recreates on New York State’s Constitution-protected lands surrounding the Ashokan Reservoir and our magnificent Catskills Forest Preserve as a hiker, birder, and environmental advocate. However and whenever I am able, I personally promote “leave no trace” principles. If it's not already clear, I LOVE the amazing Catskills, where it is I call home! 

As you know, it is this same protected land that is being proposed by Premium Energy Holdings (PEH) as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. I am writing today to vigorously object to this project in its preliminary stages for all of three proposed locations in Olive, Shandaken, and Phoenicia’s Woodland Valley. 

While I certainly welcome viable alternative solutions to fossil fuel-sourced or nuclear energy, this hydroelectric plan by Premium Energy is not among them: It attempts to put forth an inefficient and ill-conceived project that this “Status 1” area of the Catskills (to be avoided for development), will not be able to sustain without serious and lasting detriment. 

The proposed project is massive, intrusive, and if constructed, likely to highly impact local lands, roads, and stream ecology, and to cause increased turbidity in waters—adversely affecting fish and wildlife habitat and protected species. Furthermore, it is reportedly not the kind of innovation the NYS Department of Energy states that it wants: this proposal is being promoted as a “closed-loop” project, which it emphatically is not. (Unfortunately, transparency has not been at the forefront of PEH’s ambitious undertaking.) If it moves forward, it will also impact on the Catskills’ tourist economy and the precious historical and cultural artifacts in our valley. Likewise, it can do irreparable damage to the unfiltered drinking water source for millions of residents in New York City. 

For all these reasons, I respectfully request that the Federal Energy Regulatory Commission denies Premium Energy’s application for a preliminary permit. 

I appreciate your time and attention to a matter that is of significant importance to folks not merely who live in these three proposed sites. As stated, so many more of us who live and work and recreate in this area are convinced that the Premium Energy project, if given an early pass, will have a negative impact for generations on our entire region and well beyond the so-named towns and terrain.

I ask that the Commission does everything in its considerable power to prevent this misguided endeavor from advancing in any way.

Thanking  you for your time, and the time you have permitted me to express my sincere concerns.

Respectfully submitted.

Charlotte Rose, Boiceville, NY.
As a resident and voting citizen of Olive NY I hereby register my strong protest to the proposed project: Ashokan Pumped Storage Project. The unforeseen environmental and economic impact on both current residents and tourists is too big to risk.

Our local area is protected and beautiful land, and of course a tourist attraction. This project could have a potentially devastating impact on the natural ecosystem and thus could have a negative economic impact on our tourist industry. This project is to be avoided at all costs. There are other sources of renewable energy now available that must be urgently considered like solar and wind energy. 

As residents, we vow to organize community locally, at state and federal level if we need to in order to block this proposal. Thank you for your consideration, we look forward to thanking you for your denial of this project.

Emily Salatino, Carmel, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Emily Salatino

Paul Ohan, West Shokan, NY.
Motion to Intervene of David Traub for the Premium Energy Holdings, LLC, Project No. 15056-000

All communications, pleadings, and orders with respect to this proceeding should be sent to the following individual:
Paul Ohan
1162 1st Avenue, 5N
New York, NY 10065

I, Paul Ohan, own property, including land and physical residence, within one of the proposed building sites included in the Premium Energy Holdings, LLC Project No. 15056-000. As such, I am seeking a Motion to Intervene.

The proposed building site, Alternative 3, Wittenberg Reservoir, is located where my residence and my entire property exists. I would no longer be able to use any part of my property or residence if this project were approved at the proposed building site, Alternative 3, Wittenberg Reservoir. The address of my property located within the proposed building site is:

298 Moonhaw Rd.
West Shokan, NY 12494

I respectfully requests that the Commission to grant my Motion to
Intervene as a party with full rights to participate in all further proceedings as I would like to learn what can be done to best serve the public in a rantional manner.

Thank you,
Paul Ohan
298 Moon Haw Road
West Shokan, NY 12494

Grace Himberger, Boiceville, NY.
Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I am currently a student at USC in Los Angeles, but I grew up next to the Ashokan Reservoir and am part of a large and engaged community.  I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 based on the following reasons:
1.)  NOT CLOSED LOOP -The application is sloppy and flawed in it’s local references and assertion of being a “closed loop system” when it is an “add on” system.
2.)  BIRDS-All proposed reservoirs are within the Audubon NY Catskill Peaks Forest Important Bird Area (IBA).  If you have ever heard the flute song of a Forrest Thrush, you would defend it’s habitat from development at any cost. https://ny.audubon.org/conservation/catskill-peaks-forest
3.)  TROUT -The system’s environmental impact on the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir.
4.)  DRINKING WATER - The system’s impact on turbidity levels of the Ashokan Reservoir which supplies both local and 40% of NYC’s water, serving 1 billion gallons of water a day to 9.5 million people.  The proposal threatens this valuable asset, which holds the distinction of being the largest unfiltered water supply in the nation.
5.)  PRESERVED LAND -The three sites for the proposed reservoirs and tunnels are on highly protected land of the Catskills Forrest Preserve created in 1885 under Article XIV of the NYS Constitution “shall be forever wild… not be leased, sold or exchanged, or be taken by any corporation, public or private.”
6.)  PROTECTED LAND -The Catskill Forrest Preserve is considered Status 2 land under the USGS “Gap Analysis Program.” According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."
7.)  CONTINUOUS HABITAT - The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare) and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
8.)  COMMUNITY DISPLACEMENT, AGAIN- Premium Energy’s proposal would be devastating to local communities as it would require the seizing of homes and private property via eminent domain—a process whose scars are still felt here from when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would be unable to secure new housing, as there is currently a severe housing shortage in Ulster County.
9.)  TOURISM – The proposal would negatively impact the Catskills’ growing tourism economy, which generated 17% of employment in the region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty  and otherwise industrialize the region, negatively affecting businesses in Ulster County and beyond.
 
As a last point to make in opposition, the irony must be pointed out that the solution to fossil fuels and extractive energy methods should not be to usher in a new environmentally damaging system! Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—using innovation where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
 
Please deny Premium Energy’s proposal for a preliminary permit for the
Ashokan Pumped Storage Project P-15056.
 
Sincerely,
 
 
Grace Himberger

Michael Drillinger, Woodstock, NY.
I am a resident of Ulster County, NY. I am also a New York State Outdoor Guide and I regularly guide visitors on the protected land around the Ashokan Reservoir, including lands near the dam, reservoir, turbine, and tunnels proposed by Premium Energy Holdings for use in pumped storage and generation of electricity.  I do recognize the value and importance of pumped storage facilities, but this proposal is the wrong project for the given locations.

The Boiceville location would flood a major access point to two popular wilderness mountains. The Stony Clove location impacts access to the Phoenicia and Mount Tobias Wilderness Area. The Woodland Valley site similarly encroaches on Catskill Park Forever Wild areas. Tourism and recreation are major industries in the Catskills where agriculture has always been marginal and there are few other industries.

The current proposed sites would impinge upon lands of the Catskill Wild Forest which are lands protected under the New York State Constitution. In addition, the construction work would be in the watershed of the New York City water supply, an unfiltered supply of fresh water that supports 11 million people. There is a danger that a construction accident could lead to toxic or dangerous materials finding their way into the reservoir. At the very least, there is a danger that runoff from the construction of the upper reservoirs would cause turbidity that will impact local streams as well as the Ashokan Reservoir.

The finished operation proposes to outflow into the Ashokan Reservoir which will create turbidity and change the water temperature which affects the water’s chemistry. How can this project be allowed to go forward when it impacts constitutionally protected lands, and more importantly, the water supply of New York City?

The Stony Clove site would certainly impact the Stony Clove Creek, which is a major tributary of the Esopus Creek. As described above, there is danger during the construction process as well as in the proposed operation. There is recreational tubing, kayaking, and fishing on the Esopus that all support the local economy. Any degradation or alteration in the flow of the Esopus will impact businesses that depend on these recreational activities, but also, the Esopus is the major water supply of the Ashokan Reservoir. Increased turbidity due to the functions of the proposed reservoir in the Stony Clove will have a negative effect on the New York City water supply.

The issue of turbidity and possible toxic runoff from the construction site as well as on going issues of turbidity will have a direct impact on the local environment and stream ecology. Catskill streams are blessed with a wide variety and a healthy population of macro invertebrates. These form the base of a food web that supports fish, birds, and larger predators. Any threat to stream ecology due to dangerous runoff or turbidity has wider ripples that affect the general health of the local environment.

As a licensed guide I know that the Catskills are a destination for visitors from around the world for hiking, fly fishing, cycling, and other recreational activities. These underlie the tourism industry which is the life blood of the communities in the Catskills.  A 2016 report “The Economic Impact of Tourism in New York” states that tourism is responsible for 16% of the total employment in the Catskills and tourist spending continues to grow year over year. The Premium Energy Holdings proposed pump storage project for the Ashokan Reservoir will have a direct negative impact on my guiding business as well as tourism in general and the local environment.

Robert Lamberty, Olivebridge, NY.
Dear Ms. Bose,

I am writing in response to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, risky for the purity of NYC’s drinking water, and a relatively costly alternative that is likely not worth the investment.

I purchased by home in Olivebridge in 2016. Why Olivebridge, you might ask? Because it is on the boarder of Catskill Park; a small, majestic area of New York that I fell in love with after my elder sister toured Bard college located just across the Hudson. The Catskills offer an extraordinary connection with nature with its hundreds of thousands of protected acres of land, gorgeous mountains, seemingly endless supply of recreational trails, and abundance of wildlife. This area, only two hours away from NYC, has managed to remain rural and free of most environmentally devastating projects, albeit we have power lines, hardly enough cell towers (I hope it stays this way), and the existing network of reservoirs that supply water to NYC. The proposed pump storage project with its additional reservoir, water connection line, and high-tension wires, however, should not be added to this exception list. The construction and operation of such a project here is both more harmful to the preserved environment and costlier to the operators, making it a project  that should not be granted approval to move forward.

I understand that the shift towards renewables require battery like systems so that power can be delivered during peak demand and during times that energy generation sources are not available. Are pumped storage hydroelectric projects really the best solution to that problem? If they are, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

The completed project would greatly harm the environment due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

Connecting to the water supply of NYC would undoubtedlymake this project have higher construction and running costs than alternative locations. The Ashokan reservoir is currently fully secured by NYC police with constant surveillance. Any connected reservoir would need the same level of security. This project is a net user of energy and relies on only the differential of energy prices between peak and non-peak power rates to make any revenue stream. Does it really make sense to attempt this type of project connected to the NYC water supply where it would be much more expensive relative to alternative construction sites?

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Rob Lamberty

Hide Harashima, Olivebridge, NY.
I am a home owner in the area adjacent to the proposed underground hydroelectric plant adjacent to the Ashokan Reservoir. I am 100% for clean renewable energy. However, this project proposal does not benefit the town and more importantly the ecology and environmental benefits. Therefore i strongly oppose this proposed project from Premium Energy Holdings.

This project involves digging into valleys in the towns of Olive or Shandaken and damming streams to create reservoirs as part of “pumped storage” for electricity to be generated using associated water transport tunnels. Tapping into any energy generated would require a massive new high power electric transmission network. New York needs clean energy, but this is not the way to go.

This construction adjacent to the drinking water reservoir not only affects the immediate community but also may disrupt a critical drinking water supply for nine million people.

Douglas R. Helman, Phoenicia, NY.
COMMENT IN OPPOSITION TO FERC PROJECT NO. P-15056:000.

As a life-long inhabitant of Phoenicia, NY, I write to oppose Premium Energy’s preliminary permit application for a pumped storage plant near the Ashokan Reservoir (FERC Project No. P-15056). Condemnation of this specially designated land by a private entity, or even by the federal government, would constitute a violation of both the New York and U.S. Constitutions, entailing years of costly litigation. The project must be abandoned.

In its cursory request for a preliminary permit application, Premium Energy ignores that the land it wishes to seize is entirely contained within the Catskill Forest Preserve. This preserve, along with the Adirondack Forest Preserve, represents the largest region of protected wilderness east of the Mississippi river, and in fact, is the “only such area specifically protected by a state constitution.” The Forest Preserve, A Chronology, The Conservationist (May-June 1985).  The Catskill Forest Preserve was created by New York State law on May 15, 1885, but more importantly, was enshrined in Article 14, Section 1 of the New York State Constitution in 1894. The Constitution explicitly provides that lands of the Catskills “shall be forever kept as wild forest lands” and “shall not be sold, nor shall they be leased or taken by any person or corporation, public or private.” (This is not to be confused with the entirely separate state-law designation of “Catskill Park,” which also encompasses much of the land Premium Energy seeks to commandeer. Condemnation of park land would require a cumbersome but entirely separate state process via the  NYS Department of Conservation, see NY CLS ECL § 9-0101(2) (definition of “Catskill Park”)) 

The Catskill Forest Preserve thus enjoys the highest degree of legal protection of wild lands in any state in the country. And this protection was enacted specifically to end projects like the one proposed by Premium Energy. “Historically, the forest preserve was given constitutional protection to bring a halt to the commercial exploitation [of State forests]. . . and presumably, to protect them for use by all the people of the State.” Helms v. Reid, 394 N.Y.S.2d 987, 994 (Sup. Ct. 1977). New Yorkers have successfully sued to prevent projects as minimally invasive as bobsled trails, see Protect the Adirondacks! Inc. v. N.Y. State Dep't of Envtl. Conservation, 106 N.Y.S.3d 178, 182 (App. Div. 2019). (Further note that Section 2 of Article 14, which allows Forest Preserve land to be used as a reservoir “for the municipal water supply” says nothing about generating electricity). And it is far from clear that Premium Energy has the legal authority to condemn these state-protected lands without the consent of state officials. At least one federal Circuit Court of Appeals has ruled that private parties may not condemn state-owned lands through eminent domain without explicit consent from the state. This issue is currently pending before the Supreme Court. See PennEast Pipeline Co. v. New Jersey, Supreme Court Docket No. 19-1039 (2021). The Court is likely to rule that condemnation of state lands in contravention of the state’s wishes by a private party violates the powers reserved in the Eleventh Amendment. 

But there is a far more onerous legal hurdle to this project. As New York Courts recognize, “the purpose of the ‘forever wild’ clause” in our state constitution was to specifically reserve to the people of New York the right to dictate how the Preserve land is used, and to “prevent the commercial exploitation of the forest preserve which had previously been sanctioned” even by “the Legislature.” Helms, 395 N.Y.S.2d at 994. Accordingly, it is not even up to the New York State Legislature, nor any other state or federal entity, to determine whether Premium Energy may use the land for its own purposes. The people of New York must specifically grant their consent, via an amendment to Article 14. Amending New York’s constitution is a deliberately cumbersome process that requires the approval of both houses of the Legislature in consecutive sessions, and then critically, requires public approval via plebiscite at the next general election. In the past two decades, over 2,000 amendments have been introduced in the Legislature; only 29 have made it on the ballot, and only 20 have passed. That is a success rate of approximately 1%.

As noted, no other land in America retains the degree of legal protection bestowed upon the Catskill State Forest Preserve. While this project would be legally dubious on the state lands of any other state in the country, in New York’s Forest Preserve, it is dead in the water. Not even the federal government can override the sovereignty retained by the State of New York and its people, as expressed in New York’s constitution, since the time of the founding. At the very best, New Yorkers will fight tooth and nail to end this project, and Premium Energy’s right to condemn the land would be an issue of first impression for the federal courts, tying up this project in extensive litigation for the foreseeable future. 

As the Catskill Park State Land Master Plan reminds us, “[t]he People of the State have New York have demonstrated a deep and abiding concern for the Catskill region for over a century.” See Catskill Park Master Plan (amended 2014). That abiding concern endures, and the people of New York do not and will not ever consent to this endeavor. It must be abandoned. 


Douglas R. Helman, esq.

Chris Rose, Boiceville, NY.
As a resident and voter in Olive, NY I strongly protest this plan. The potential ecological devastation is unacceptable, and we residents will do everything in our power to prevent this plan from moving forward, at every possible opportunity.

Bruce Katz, West Shokan, NY.
I am writing to oppose the granting of the permit for a preliminary study by Premium Energy Holdings, LLC.  I oppose this application for a number of reasons: 

1.  This study is planned in the Catskill preserve, which is a state-protected "forever wild" area of half a million acres of land.  This project would completely disrupt the sensitive wetlands, wildlife, and ecological balance here. It would clearly destroy habitat for numerous species, some of which are protected and endangered. 

2.  This California-based company seems to know nothing about our actual town (The Town of Olive, NY), referring to it as "Shokan City" and implying that no one lives here.  In reality, the location of their possible above- and underground project is home to many people who would be displaced.  As an added note, a large section of this town was already displaced to construct the Ashokan Reservoir. 

3.  The Ashokan Reservoir provides water to New York City, which carefully maintains the lands around the reservoir to keep the water pollution-free and as undisturbed as possible.  It seems obvious that this plan would increase turbidity and upset the delicate balance maintained by the City of New York. 

4.  This seems a worthy project but this is the wrong location.  It should be sited where it does not endanger humans, wildlife, forests, and thedrinking water of 10 million people.  

Thank you, 
Bruce Katz

Daniel Greenbaum, Maplewood, NJ.
Dear Ms. Bose,
I am writing to urge FERC to not grant a preliminary permit to Premium Energy's proposal for the Ashokan Pumped Storage Project, FERC Project No. 15056-000.
I am a homeowner in Chichester, NY in Ulster County for over 25 years and have been coming to this part of the Catskills for over 60 years.
The project will be located within New York State's Catskill State Park and will encroach on New York State Forest Preserve within that Park. The Preserve is protected by the New York State Constitution. The State Constitution declares that Forest Preserve lands will be kept "forever wild," and that they can only be developed by an amendment to the State Constitution followed by a public referendum.
Many endangered species of plants and animal, designated as such by New York State but some also recognized by the Federal Government, will be impacted if not destroyed by allowing this project to proceed in any of its proposed locations within the Forest Preserve. 
Because the proposal places this project on State Forest Preserve land, allowing the proposal to proceed would be contrary to the Department of Energy's "Hydropower Vision" that acknowledges avoiding such projects where development could destroy publicly protected wilderness and endangered species. 
The construction of the project itself will negatively impact residents not only of Ulster and Greene Counties, but also residents of New York City who rely for their water supply on the streams like Stony Clove Creek or Woodland Valley Creek that flow into the Ashokan Reservoir. 
Finally, I am given to understand that the proposal claims to be for a "closed-loop" pumped storage project but is in fact an "add-on" that uses an existing body of water as a reservoir. The latter type of project has far greater environmental impact than the former and is not the type of project that the Department of Energy is encouraging.
FERC should deny the requested preliminary permit for Project No. 15056-000. 
Thank you,
Daniel Greenbaum

Kate Murphy, Cornwall, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Lillian Slezak, West Hurley, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Lillian Slezak

Julia Armstrong, Olivebridge, NY.
This response is in regards to docket number P-15056-000. The proposed Ashokan Pumped Storage project in the Town of Olive should be rejected due to the inherent disruption to the local ecosystem and because it necessitates the displacement of local residents. 

As a solar energy developer, I fully believe renewable energy projects should be embraced, but not at the expense of local communities. Less invasive projects should be explored that do not pose a threat to lifelong residents and their way of life. Preserving the Town of Olive and the greater Catskill Park in which it resides should be of utmost priority. 

And so I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit.

Julia Armstrong
188 Grassy Ridge Rd
Olivebridge, NY 12461
P-15056:000

Joanne Flynn Black, Phoenicia, NY.
Re: Premium Energy for the Ashokan Pumped Storage Project (P-15056:000)

We are the Woodland Community Association which covers over 200 homes in the hamlet of Woodland Valley, in the town of Shandaken, Ulster County, New York.

We’ve held several meetings with our Association to review and discuss the Premium Energy for the Ashokan Pumped Storage Project (P-15056:000) There is an overwhelming opposition to this project.

We have read your proposal and strongly believe that this should not be completed because of the following reasons:

Provides 90% of NYC’s water 

Water supply provides 1 billion gallons a day to 9.5 million people.

The largest unfiltered water supply in the nation, built at the cost of displacing 25 communities.

Will the “ public good” be served when the public harm of this project is weighed against the so-called benefit in terms of providing possible, but not certain, cheaper energy. 

Specifically, the projected limited energy benefit does not justify taking and rendering inaccessible the amount of property that will need to be taken and the impact on the use of State recreational land. 

Eminent domain may not be used to take the property of the landowners in Woodland Valley, so that a private, for profit corporation, can build and profit from this pumping storage project. 


Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild
forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

The historic Woodland Valley campground, built by the Civilian Conservation Corps in the early 1930s, is one of the state’s oldest campgrounds; the caretaker’s cabin is listed in Ulster County NY: The Architectural History and Guide.

According to the DEC’s most recent Use Management Plan (1994), the campground has 70 campsites and is used by over 5400 campers and at least 2600 day use visitors annually.

Serves as the trailhead for two of the area’s most popular trails, the Slide-Wittenberg trail and the Woodland Valley-Denning trail.

Woodland Valley Creek is a popular fishing destination, containing cutlips minnow, blacknose dace, longnose dace, sculpin, brook trout, brown trout, rainbow trout, and white sucker 

Woodland Valley Creek is a trout breeding ground 

Two historic structures listed in “Ulster County NY Architectural History and Guide” are in the proposed inundation area 

William L. Beach House, built 1852, occupied by landscape painter Thomas Craig (1849-1925) 

The Roxmor Inn, built 1914-15, visited by John Burroughs 


We want to understand whether this Federal Agency is authorized under the Federal Constitution and Federal law to overrule the NYS Constitution and the protection of State property declared forever wild. 

Thanks for considering our comments

George Tsontakis, Shokan, NY.
I write in reference to docket number P-15056-000.

Living in Olive for the past 35 years, with a near panoramic view of the magnificent Ashokan Reservoir, I find the proposal by the Premium Energy Holdings company uniquely disturbing. What I have always cherished most about our area is the relationship between nature, the environment and the need to service the essentials of the local population; all existing in a fine balance. This proposal seems outrageously out off whack and self serving and I believe it would alter the nature of this Catskill area irremediably. I can't but see, in my mind's eye, the figure of Smokey the Bear with that tear in his eye. It seems as though a multitude of concerned people are raising their voices as Smokey did, with “Only YOU can prevent this travesty”. We do hope you will reject such an ill conceived plan.

Yochanan Kushnir, Shokan, NY.
My name is Yochanan Kushnir. I am a resident of the Town of Olive. My address is 161 Black Road, in Shokan. I am writing to express my objection to the FERC project and sub-docket number P-15056:000: the Ashokan Pumped Storage Project.

I am a climate scientist, a professor at the Lamont-Doherty Earth Observatory, Columbia Univeristy. I am extremely concerned about the impact of climate change and wholly support the transition to renewable, clean energy. I was delighted that the State of New York adopted its Clean Energy Standard plan in 2015. However, I was extremely concerned when I found out about this Pumped Storage project. Cutting down forest and clearing out land to dig a reservoir will have huge negative environmental consequences in the highly preserved, New York State Catskill Forest, its precious streams and rare wildlife. Forest fragmentation is an often neglected issue that affects availability of clean water and air as well as effective, natural Carbon Dioxide sequestration. It affects wildlife mobility and survival on land and in the streams. And this particular project seems to me as threatening the safe functioning of the Ashokan Reservoir by increasing likelihood for high turbidity events. I resided in the past in New York City and appreciated the quality of water coming down from the Catskills. The proposed project will damage this quality.

I understand that Pumped Storage plants have been put to successful use in the US and that they are a clean backup option to wind and solar power plants. I also understand however, that building a Pumped Storage plant is a costly endeavor and is not an efficient solution (it consumes more energy than it delivers). In this case the project has particularly negative, site-specific, environmental and ecological impacts. I therefore register my objection to this project.

Eldeva M Tofte, Kingston, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Eldeva Tofte

E Hamilton Appelson, Mount Tremper, NY.
I became a resident of Mt. Tremper nearly 30 years ago, and these mountains have become home to my family, my business, and all that is dear to me.  After years of coming to know this place, I now spend my days as a guide, introducing visitors to the Ashokan watershed region. I take this role seriously, believing it’s critical for people from urban areas to clearly understand the remarkable environmental treasure that the Catskill Mountains represents.  I learned of this proposal with alarm, just 3 short weeks before the period for comments is closes, and though my time is short, I feel a responsibility to make my position known. 

This region’s development has long been strictly curtailed by both the regulations of the Catskill Forest Preserve, the NYS Department of Environmental Conservation, and the NYC Department of Environmental Protection.  The message I aim to send home in all of my encounters with visitors is that while the region’s residents have historically paid a high price (economically and socially) for the multiple layers of environmental protection in force here, we have the great satisfaction and security of knowing that we live in a place that will remain clean and safe for flora and fauna (AND WATER) in perpetuity.   

The Catskill Forest Preserve is written into the New York State Constitution, and cannot be altered except by constitutional amendment.  It would be an outrageous overstepping of boundaries for FERC to approve this proposal, as it would effectively over-rule the New York State Constitution, New York Regional Department of Environmental Conservation regulations, Ulster County regulations, Town of Shandaken regulations, Town of Olive regulations, Hamlet of Olivebridge regulations, Hamlet of Chichester regulations, Hamlet of Lanesville regulations, Hamlet of Phoenicia regulations, and the New York City Department of Environmental Protection laws and regulations.

Running roughshod over the law of the land in order to permit a private company that hasn’t done its homework and has presented a shoddy application would be bad public policy.  Allowing this project to actually get built would fly in the face of every level of governmental oversight of our environment.   Overruling environmental protections in the name of supposed clean energy is a race to the bottom.  Let's stop this in its tracks and build smarter.

Please say no to docket number P-15056.


--
Liz Appelson
123 Miller Road #3
Mt. Tremper, NY 12457

Vanessa Esparza, Pine Bush, NY.
Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline this  request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require seizing homes and private property via eminent domain. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and the homes that are available are priced significantly higher than even just a few years ago. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I urge Premium Energy to find another suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Vanessa

Timofey Zhukov-Khovanskiy, Deep River, CT.
I oppose this project, because this area houses a vibrant community with many people’s homes and local businesses. The lives of people and wildlife depend on this area, it would be a shame to have it damaged by a project like this. Not to mention the effect of the construction process and the dams and pumps on the NYC drinking water.

David Kukle, Tannersville, NY.
David T Kukle 
As an Induvial but also serve as:
Councilman Town of Hunter
President Mountain Cloves Scenic Byway
Board Member Catskill Center for Conservation and Development 




Kimberly D. Bose, Secretary 					April 11, 2021
Federal Energy Reserve Commission 
888 First Street, NE 
Washington, DC 20426 


Re: Premium Energy Holdings’ First Amendment for Preliminary Permit for the Ashokan Pumped Storage Project, FERC Project No. P-15056

 Subj: Comments on Behalf of David Kukle

 Dear Secretary Bose:
I am writing to lend my voice to the growing chorus in opposition to the proposed pump storage system in the Catskill Park, and particularly the Town of Hunter, Greene County New York. This proposal is just becoming known to the Public, after having quietly arriving in our communities. This is about to unleash incredible push back from the millions of New City Residents that are also now just learning about this project. All three of these particular sites have becomes the City dwellers new Central Park. This is where they now come to experience the last vestige of a wilderness experience area within proximity to their home. I sure if the comment period was extended for a short time to allow for the recipients of NYC’s unfiltered water to weigh in, you might need your own Post Office to hand the comments.
The proposed site of this project is spectacularly inappropriate and unsuitable. In exchange for a de minimis and dubious environmental benefit, this project will severely and permanently damage the Catskill Park and its Forest Preserve, one of the most highly valued, protected & preserved sites in all of New York State. Drowning an entire community in Lanesville, damaging state protected lands, adversely affecting drinking water supplies and surface water quality, damaging the economy of Hunter and other Catskill towns, and threatening a host of other adverse environmental impacts is too high a price to pay for whatever tiny benefit this project may bring.
 For anyone who lives in the Catskill Park, or who knows and enjoys the Park, this is obvious. Besides threatening environmental harm, this project also threatens the economic life blood of Hunter and the Catskills communities, communities who have relied upon tourism as their economic engines literally for hundreds of years. In the Catskills, environmental protection and economic health are symbiotic. The health of the environment is directly connected to the health of economies. This project strikes serious blows to both, And the impact of the obliteration and erasure of the entire hamlet of Lanesville in Hunter cannot be overstated. The callousness of proposing this in a mountaintop community, where the memories of the destruction of Ashokan are still vivid and continue to be remembered, written about, and sung about, is shocking.
 Besides all these negatives, there are legal obstacles as well. The lands which the Applicant seeks to use for this project are unattainable due to immovable protections of state law that are exempt from federal eminent domain authority. Granting this permit and forcing all the stakeholders to continue to expend blood and treasure to participate in this review process will perpetrate a tremendous injustice. A continued review of this project will also spawn a long string of dispute resolution and litigation. The opposition to this project isn’t NIMBY-ism. Instead, the project is so ill-conceived that it has drawn vigorous opposition from just about every imaginable quarter. This project is opposed by the Towns of Hunter, Woodstock and Olive, by The Counties of Greene, Ulster and by New York City. Not failing to mention a myriad environmental organization and concerned citizens. The good sense of the collective judgment of this broad coalition should be respected.
 This project is proposed on a site which may easily be the worst possible site for a project of this kind. It is the wrong place for this. It will do more harm than good.
  The time to stop this insanity is now.
 The permit application should be denied. 
Sustaining information in found in the Correspondence from Attorneys Grant and Lyon submitted on behalf of the Town of Hunter 
The decimation of Lanesville and the displacement of its residents.
Route 214 is a vital lifeline to the Town of Hunter and its tourism.
Route 214, and the access it provides, may be lost forever.
Loss of Access to Devils Tombstone Campground.
Destruction of a designated scenic by-way.
This Project is antithetical to Hunter’s Town Comprehensive Plan.
Lack of Notice to Hunter.
The Adverse Impacts this Project will bring to the Catskill Park
Practical impossibility of this project warrants permit denial.
New York State Forever Wild Protection of Forest Preserve Lands.
Lack of federal eminent domain power in this case.
 Impossibility of using New York City lands
The General Adverse Impacts this Project.
 This project will exacerbate existing turbidity problems in the Esopus Creek.
Conclusion. Permit denial is warranted
The permit sought by the Applicant should be denied based on the practical impossibility of acquiring the lands necessary to build this project. While possession of the necessary property rights are not a requirement of the permit, it should be a basis for denial in this case. To grant this permit, and to place the local stakeholders in the position of having to continue to expend time and money to engage and participate in this impossible project would perpetrate a tremendous injustice. The resources of local governments, and individuals are stretched thin already without this pointless additional burden. The same can be said for the myriad environmental organizations which have mobilized to oppose this thoughtless application.

I appreciate your consideration on this matter 
Respectfully

David Kukle
PO Box 164
Tannersville, NY
12485

Matthew Every, West Shokan, NY.
Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose, 

My name is Matthew Every. I am a resident of West Shokan, New York and the senior editor of Field & Stream magazine. I grew up hunting and fishing around the Ashokan Reservoir and my family has lived in West Shokan for generations. I am commenting on behalf of myself, as someone who would be impacted by this project, and as a lifelong conservationist, hunter, and fisherman. 

The Ashokan Reservoir meets the needs of roughly 40 percent of New York City’s water supply. Out of the six reservoirs that serve NYC, it is the second largest. It is constructed with two separate basins, an upper and lower, the upper serving as a settling basin for periodic turbid flows to settle out. It was built in 1915 and over 100 years of sediment has settled there. 

Because of this settling basin, the drinking water coming from the Ashokan does not need to be filtered. It hasn’t been since the reservoir was constructed. If Premium Energy Holdings was to discharge water from a pumped storage facility into the upper basin of the Ashokan, I believe that it could increase turbidity in the entire system, posing a risk to the quality of the drinking water for millions of people. To quote another comment to this proposal from the local chapter of Trout Unlimited: 

“In a similar request before FERC for a license to construct a pumped storage project on NYC’s Schoharie Reservoir at Prattsville, Project # 2729, New York City retained Lamont-Doherty Earth Observatory as a consultant. On page 12 of a report produced by NYC’s consultant, it  noted that the operation of such could “create an unacceptable human health risk.”

On top of this health risk, increased turbidity in the Ashokan would affect the surrounding stream ecology in an adverse way. The Ashokan is fed by the Esopus creek. The Esopus creek and the Ashokan Reservoir have a unique and recognized relationship. The Reservoir is home to a robust population of brown and rainbow trout. Anglers fish for trout in the reservoir, and these trout run up the Esopus to spawn every year keeping the creek stocked with wild fish. 

With climate change, dams, and an increased demand for clean water, wild trout are under constant threat. A proposal like the one before you would further imperil this important species. It would constantly increase turbidity in the water thus negatively impacting zooplankton—a large part of a rainbow trout’s diet. Because the trout in the Ashokan are an integral part of the Esopus creek’s ecosystem, any change to their ability to feed would diminish the quality of this important trout fishery. 

The Esopus is one of the Catskill drainages that comprise the “Cradle of American Fly Fishing,” and it is irreplaceable. Trout fisheries of the Esopus’ quality are becoming rarer in the United States. The NYS Department of Environmental Conservation has recently reclassified the Esopus Creek as a wild-quality stream, under their newly approved Trout Management Plan. Anglers already flock to the Esopus every spring and summer. But this reclassification will likely draw even more people to the area from around the Northeast and across the country. 

These anglers book hotel rooms, eat at local restaurants, and hire local fishing guides. Any negative change to the Esopus creek would stifle the local economy at a time when it is on the rise. Our economy relies heavily upon recreation and tourism. Trout have real value in this area, both financially and culturally. 

Through the years, the City of New York has purchased land around the Ashokan reservoir to curb development and keep the watershed clean. A positive side effect of this has been the habitat they’ve created for local wildlife. As a result, the Ashokan Reservoir, and the land that surrounds it, are classified as an Important Bird Area by the Audubon Society. It is a stopover and home to many migratory birds including the American black duck. 

Black ducks were once at dangerously low numbers, and they have been slowly coming back through the years. For waterfowl hunters and bird watchers, they are an important species. They make up a significant portion of an eastern waterfowl hunter’s daily bag limit. 

Historically the eastern mallard made up the bulk of a waterfowl hunter’s limit in the eastern flyway. But a recent study has shown that the mallards are declining due to habitat loss and the introduction of farm-raised mallards to the landscape. This resulted in the bag limit for mallards in the eastern flyway being cut in half in recent years. I have interviewed two biologists who study eastern mallards. From these interviews, I have gathered that eastern mallard populations are likely to continue to decline. 

As a result, waterfowl hunters may rely more and more on healthy populations of black ducks in the future. The Ashokan Reservoir and its surrounding wetlands represent the kind of habitat that takes years to replace or construct for these kinds of species. Digging the large tunnels this project requires and clearing tracts of land to erect high-tension power lines could pressure important wild areas for these ducks and other migratory birds.

If Premium Energy Holdings got approval and constructed a pumped storage facility at any of the proposed sites, the habitat, wildlife, recreation-based economy, and the quality of New York City’s drinking water would be adversely affected. This project would also negatively impact the local cultural heritage of trout fishing and be in conflict with New York State constitutionally-protected Forest Preserve lands. While I understand the need to transition to more sustainable sources of energy, the detrimental effects of a project like the one being proposed would outweigh the benefits. Because of this, I respectfully request FERC to deny Premium Energy Holdings the approval for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Sincerely, 
Matthew Every

Caleb Slovensky, Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. The project also has a high probability of displacing residents from their homes in a county that is already lacking in affordable housing. Please do everything in your power to prevent this proposal from moving forward.

Ric Burns, Phoenicia, NY.
April 11, 2021

Federal Regulatory Energy Commission

RE: Proposed Hydroelectric Dam in Ulster County NY
Reference docket P-150156

Dear Sir/Madam,

As a longtime resident of both New York City (since 1975) and the Catskills Reserve (2008), I am writing to register the strongest possible objection to the proposed Ashokan Pumped Storage Project put forward by the Premier Energy electric company.  

It is shocking that such a proposal has even been submitted, given the myriad stunningly obvious negative consequences it will have, any one of which would be sufficient to make such a project unthinkable.  

The area in which the proposed dam and pumped storage project would be constructed is at the very heart of one of the most historic, beloved, visited, skied, fished, hiked, lived in, traveled through and ecologically critical areas in New York State – every one of which activities and/or aspects would be catastrophically damaged by the proposed project.  Where to begin?  New York City’s drinking water – long lauded as among the cleanest and most potable in the nation – would be rendered measurably, indeed visibly, more turbid as a result – to say nothing of the negative impact on the water supply for wells throughout much of Ulster County.  The gateway to the area’s four great skiing facilities would be changed ineradicably for the worse, reducing access to the ski resort and summer concert venue at Hunter Mountain, and at the very least rendering access to the Hunter, Wyndham, Plattekill and Belleayre ski districts more difficult, and time-consuming, particularly from the south and east – which is to say from the largest cosmopolitan region in the United States. World class trout fishing streams would be devastated.  One of the premier scenic routs through the Catskills, Route 214, would be re-routed and disrupted.   Fishing sights and swimming holes, hiking paths and boatways used by hundreds of thousands of people a year would be eliminated or severely curtailed.  The impact on the ecology of the Catskills Forest Preserve would be disastrous – an extraordinary resource and amenity that has already come back once in history from the devastation in the 19th century caused by the rampant deforestation of hemlock and other trees due to the tanning industry.   As a result of that catastrophe, the entire Catskills were explicitly brought under the protection of New York State, whose constitution clearly and unequivocally prohibits exactly the kind of wholesale environmental molestation this would involve.  No matter how you consider this staggeringly ill-considered proposal it couldn’t be clearer that its impact – environmental, recreational, economic, on public health – would be resoundingly negative.   I very much hope this woefully ill-considered proposal gets turned down and shut down.  

Yours sincerely,

Ric Burns
917 750-8983 rburns@steeplechasefilms.com

Jonathan and Madelaine Piel, Phoenicia, NY.
April 11, 2021


Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, D.C. 20426

Re: P-15056:000


Dear Secretary Bose:

  We respectfully request that FERC denies the application from Premium Energy Holdings, LLC (Premium) for a Preliminary License to build a hydroelectric generating facility associated with New York City’s Ashokan Reservoir, located in New York State’s Ulster County.
   The building of this facility would violate both the New York State Constitution and New York State law.  Premium proposes to build the facility in the Catskill State Forest and on land owned by New York City. The Catskill State Forest Preserve that the State’s Constitution designates as “…forever wild…”  The area is also a Status 2 region and is therefore protected from building or development.
    In addition to its impact on the Catskill region the construction and operation of the Premium facility would threaten the quality of New York City’s water supply. Specifically, the pumping of water from and into the Ashokan’s west basin would create substantial turbidity, forcing New York City to invest hundreds of millions of dollars to develop, build and maintain a filtration system.
    The Premium proposal also suffers from numerous technical flaws. For example, Premium identifies the project as a “closed-loop” system.  In fact, it is an add-on system: the Ashokan Reservoir is fed by the Esopus Creek, which also exits from it into the Hudson River.
    The three proposed Catskill sites for this facility share these prohibitive flaws, as you will undoubtedly hear from the affected communities of both Ulster and Greene counties. 
    Thank you for your attention and—we hope—an affirmative response to this request to deny Premium’s application for a Preliminary License.

Sincerely,

Jonathan and Madelaine Piel

118 Muddy Brook Road
Phoenicia, New York 12464

Oscar Ogg, Kingston, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone. It should also be noted that often by mid summer till late winter the water level of the Upper Basin of the Ashokan is extremely low and any additional water removed could be a problem, not to mention the increased turbidity.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? They have also failed to notify several parties (Greene County, Town of Hunter) that fall directly within the scope of this project. It would appear that Premium Energy Holdings was hoping to quietly ram thru this preliminary study before anyone knew what was happening.
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Oscar Ogg

Joe Smith, Chichester, NY.
Pls stop this project.

Dina Kushnir, Shokan, NY.
My name is Dina Kushnir, I live I the town of Olive and my address is 161 Black Rd Shokan. 
I am writing about NY FERC project and sub-docket numbered: P-15056:000. 
I am a nature lover and hiker and enjoy the many hiking trails in the Catskill Mountains. I moved to this area for the beauty and tranquility. This land is a NY State Park and preserved for its mountains, forest and wild life. My most concern with this project is the impact and harm to the wild life, forests and animals. The environmental destructions of forests and mountains will destroy their species habitats. It either pushes them towards human habitats, like the bears who roam this area and become dangerous to human, or destroys countless smaller animals’ life spaces and even brings some species to the brink of extinction. Ecosystems are the result of thousands and of years of development and homeostasis. Nature works to maintain balance with endless correcting and balancing timeless acts. When a major destruction like this project is forced on the environment in few months’ time, more or less, the environmental impact is far reaching and can take decades to repair. This is only one negative aspect of the intended project and the impact is far reaching to human too. This is why I register my objection to this project. 

Cordially, Dina

Isaac sorensen, Saugerties, NY.
As a local and resident having grown up in the Catskills and Hudson valley and now as a landowner and full time resident of the area, I find the plans for the dam and power generation plant a massive oversight of what we residents will value and support. I do not support the plans and believe the proposal should be struck down. I own property in both Saugerties and New Paltz and frequently enjoy the Catskill Park and all it has to offer. The plans for the dam diminish value and negatively impact an area I care deeply about and have invested my life in. Please stop the dam from being built.

Jamie Pabst, West Kill, NY.
To whom it may concern,

I'm writing to express my concern and opposition against the Premium Energy Holdings, LLC’s proposed Ashokan Pumped Storage Project. 

I feel the project is wildly inappropriate and irresponsible given all the negative and harmful impacts it will have on drinking water, watershed, and the displacement of residents and wildlife inhabitants. The Catskills are a State Preserve protected by the NY State Constitution, and it would be a disaster to harm this land and its inhabitants.  I urge you to not allow this project to advance.

Regards,
Jamie

Katherine Freston, Carmel, NY.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Katherine Freston

Janet Robinson, Phoenicia, NY.
Dear Ms. Bose,

I’m writing as a deeply concerned citizen and property owner in the Catskills region regarding the Premium Energy Holdings proposal to build a hydroelectric power plant. I believe it is important to consider transitional solutions to renewable energy but this is a terribly executed proposal, and would cause great harm to one of the most pristine and ‘protected’ environments ¬– streams, the Catskill forest preserve, its wildlife – in the country. Article XIV of the New York State constitution guarantees these lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
It would have a negative impact on New York City’s drinking water by the increased turbidity in the Ashokan Watershed, displace the residents and their livelihood; the disruption to the economy as tourism is a major part of the state’s economy and particularly so in this region.

Tourism generated 17% of employment in the Catskill region in 2019, a $1.6 billion industry in the region, supporting roughly 20,000 jobs, Ulster County represents 43% of that market, and second homes generate $360 million in economic activity. 

This is not a project the community, adjacent communities, or New York State wants in this region.  We urge you to reject approval for the preliminary permit Premium Energy Holdings is seeking – the Ashokan Pumped Storage Project P-15056.

Sincerely,
Janet Robinson
48 Muddy Brook Rd.
Phoenicia, NY. 12464

Chris Aston, Olivebridge, NY.
To the FERC team - 

As a resident of Olivebridge, NY, I am writing to oppose Premium Energy Holdings, LLC’s proposed Ashokan Pumped Storage Project (FERC project number, P-15056). I am writing in the hopes that the initial permit application by Premium Energy Holdings will be denied, rather than allowing any further progress to the project. 

It is my understanding that New York City Dept of Environmental Protection, a city agency that I have worked with in the past and whose work I hold in high scientific regard, is not supporting this project. Their research into the project calls into attention serious issues with gaps and quality of the application, viability for the project's realization, and issues with the environmental impacts of the project. I stand behind this analysis and respectfully request that the project permit be denied. 

Other environmental groups have also raised series and significant issues with the application by Premium Energy Holdings. Among others, these include the likely impacts on highly preserved land: 
- under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
- The Preserve is 700,000 acres of contiguous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. 
- Of serious note: as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
According to The Catskill Park: Inside the Blue Line-Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum 
- Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats ▪ Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the NYC water supply

While I am strongly in favor of renewable energy projects, and have supported many other projects around NY State, this is one project I cannot support. I strongly urge you to heed the analysis and requests of NYC DEP to stop the project from continuing. There must be other, less impactful possible locations for renewable energy projects.  

Thank you,
Chris Aston

Andrea Garritano, Graniteville, VT.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Andrea Garritano

Michelle Hinchey, Kingston, NY.
April 11, 2021

Michelle Hinchey 
New York State Senator, 46th Senate District

TO: Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission 888 First Street NE
Washington DC 20426 

RE: Docket Number P-15056-000	

Dear Secretary Bose, 

As the State Senator representing New York’s 46th Senate District, I am writing to express my strong opposition to the preliminary permit application submitted by Premium Energy Holdings LLC to study the feasibility of building an underground hydroelectric power plant at the Ashokan Reservoir. This proposal threatens irreparable damage to the quality of our drinking water in the Hudson Valley and in New York City; the constitutionally protected lands of the Catskill Forest Preserve; the precious ecological biodiversity of our region; the communities within areas where upper basins are proposed, and our Catskills tourism economy. 

While I fully support New York’s transition to renewable, green energy sources, and recognize that all energy production involves certain trade-offs, we cannot take on projects that would destroy our highly preserved lands and water resources. This sited project is too high a price to pay. 

Premium Energy, a California-based company, has put forth a proposal that demonstrates a complete lack of knowledge of our local terrain or regard for the well-being of people living in the region of this proposed endeavor. If Premium Energy had chosen to consult local governments or New York City’s Department of Environmental Protection (DEP) prior to submitting their application, they would have learned that portions of the upper reservoirs they seek to construct fall within New York State Forest Preserve lands, which would be a direct violation of the New York State Constitution. Article XIV of our State Constitution reads that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve, which is home to endangered and rare animal and plant species, contains 700,000 acres of wildlife habitat, and according to the New York State Forest Condition Index, the forest around the proposed sites rank among the top 1% of forest habitats region-wide. We protect these fragile lands for good reason, and Premium Energy’s project would absolutely devastate the significant natural resources that make up our treasured Catskill Forest Preserve. 

Of particular concern to me and my constituents is the unacceptable water quality impacts that this project would have for our Hudson Valley communities and over 9.5 million residents of New York City that rely on the Ashokan Reservoir for drinking water. Turbidity in the Ashokan is already a grave environmental and economic challenge for our downstream communities, and the continual pumping and releasing of millions of gallons of water--as proposed by this project--would exacerbate the issue even further. Degrading our water supply would also have a major impact on our agriculture-based businesses, which is a significant concern for me as Chair of the Senate Agriculture Committee. Our local craft beverage industry, for example, depends on freshwater sources to produce their high-quality products. At a time of great economic uncertainty, our small, farm-based businesses need to know that the natural resources they rely on will remain unharmed. 

Premium Energy’s project would also pose substantial harm to the use and enjoyment of our recreational resources and would cut off key areas of growth for our Catskills tourism economy--a $1.6 billion industry that supports approximately 20,000 jobs. This project would wipe out some of the world’s best fishing streams, access to hiking trails and skiing opportunities, and negatively affect our business community, which relies on the millions of dollars in local spending that visitors bring in from across the region.   

On Thursday, April 8, 2021, my office organized a press conference attended by a diverse coalition of environmental stewards, municipal leaders, and area residents to voice our vehement opposition to this proposal, which can be viewed here. Premium Energy’s proposal came as a shock to all of us, and within a few weeks of learning about the project, an organized alliance of over 200 citizens and environmental groups formed the Coalition to Save Catskills Preserve, which has grown to include local elected representatives and community leaders. This coalition is a clear testimony of the strong opposition to this project and together, we are united in our goal to protect the ecological integrity of our region’s irreplaceable lands and waters. 

As we make the important and absolutely necessary transition to renewables, we must give careful consideration to where we are siting these projects in a way that best protects our natural and cultural resources and ensures minimal impacts on the surrounding land and communities. As it stands, Premium Energy’s proposal would destroy the purity of our drinking water, devastate our protected wilderness, and displace communities, which is why the Ashokan Reservoir and the Catskill Park are not the right place for a pumped storage project. It is our hope that Premium Energy will recognize these unacceptable impacts and withdraw its application immediately. 

I stand in firm opposition to the Ashokan Pumped Storage Project, and I strongly urge the Federal Energy Regulatory Commission to decline Premium Energy’s request for a preliminary permit to further develop this dangerous and ill-conceived plan. 

Sincerely, 

Michelle Hinchey
New York State Senator, 46th District

Thomas  Pfeffer, Kingston, NY.
The maps Premium Energy have provided showing the transmission lines go directly across a NYS DEC protected wetland and across/over our home. The wetland located is an important wetland for migratory waterfowl and other birds.

We abided by stringent environmental guidelines to have our home on this property. The Premium Energy proposal is an unfathomable attack on both the environment and NYS laws. 

Premium Energy failed to accurately portray the location of the proposed project. It is IN the NY State Catskill Forest Preserve. The Preserve is an intact, valuable ecosystem  
The Catskill Forest Preserve, which the Premium Energy Proposal falls within, is considered Status 1 land through USGS analysis, which is identified as to be "avoided for development." 

A pumped storage project that uses more energy than it produces is, at a basic level, absolutely foolish.

The path of the proposed transmission lines would destroy intact forests and open up an invasive species corridor that would be the death knell of the State protected lands and species of concern (ex: raptors, song birds, bats, and orchids.

The open-loop, add-on system proposed by Premium Energy is not a proposal that the Federal Government should want to support because of the damage that will be done to the lower reservoir which serves as a drinking water source for over 9 million people. The Premium Energy proposal would negatively impact the drinking water of over 9,000,000 New Yorkers. The turbidity and water fluctuations created by this proposal would also negatively impact important trout habitats and breeding grounds.

Any changes to land management with the Catskill Forest Preserve require a constitutional amendment in the State of New York. 

There should be no foreign investors or investment in United States domestic energy grid projects. I have read that Premium Energy has had foreign investors in previous projects. As a matter of National security, all domestic energy projects should be domestically owned and financed. 

Given the above stated detrimental impacts to an intact forested State preserve, aquatic and terrestrial ecosystems, economic industry, and cultural and historic aspects, the Premium Energy Ashokan Pumped Storage Proposal Docket #  P-15056-000 should be denied any future permitting or applications to proceed.

Jennifer Ogg, Olivebridge, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone. It should also be noted that often by mid summer till late winter the water level of the Upper Basin of the Ashokan is extremely low and any additional water removed could be a problem, not to mention the increased turbidity.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. 

This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? They have also failed to notify several parties (Greene County, Town of Hunter) that fall directly within the scope of this project. It would appear that Premium Energy Holdings was hoping to quietly ram thru this preliminary study before anyone knew what was happening.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jennifer Ogg

Thomas  Pfeffer, Kingston, NY.
The maps Premium Energy have provided showing the transmission lines go directly across a NYS DEC protected wetland and across/over our home. The wetland located is an important wetland for migratory waterfowl and other birds.

We abided by stringent environmental guidelines to have our home on this property. The Premium Energy proposal is an unfathomable attack on both the environment and NYS laws. 

Premium Energy failed to accurately portray the location of the proposed project. It is IN the NY State Catskill Forest Preserve. The Preserve is an intact, valuable ecosystem  
The Catskill Forest Preserve, which the Premium Energy Proposal falls within, is considered Status 1 land through USGS analysis, which is identified as to be "avoided for development." 

A pumped storage project that uses more energy than it produces is, at a basic level, absolutely foolish.

The path of the proposed transmission lines would destroy intact forests and open up an invasive species corridor that would be the death knell of the State protected lands and species of concern (ex: raptors, song birds, bats, and orchids.

The open-loop, add-on system proposed by Premium Energy is not a proposal that the Federal Government should want to support because of the damage that will be done to the lower reservoir which serves as a drinking water source for over 9 million people. The Premium Energy proposal would negatively impact the drinking water of over 9,000,000 New Yorkers. The turbidity and water fluctuations created by this proposal would also negatively impact important trout habitats and breeding grounds.

Any changes to land management with the Catskill Forest Preserve require a constitutional amendment in the State of New York. 

There should be no foreign investors or investment in United States domestic energy grid projects. I have read that Premium Energy has had foreign investors in previous projects. As a matter of National security, all domestic energy projects should be domestically owned and financed. 

Given the above stated detrimental impacts to an intact forested State preserve, aquatic and terrestrial ecosystems, economic industry, and cultural and historic aspects, the Premium Energy Ashokan Pumped Storage Proposal Docket #  P-15056-000 should be denied any future permitting or applications to proceed.

Mark Marschall, Newark, DE.
FERC Project Number, P-15056
Comment in OPPOSITION to Proposed Project

My name is Mark, a senior mechanical engineering student at the University of Delaware with a minor in sustainable energy technology. As a frequent resident to the Catskills of New York and a student of sustainable energy this project caught my attention.  Sustainable energy is great, but one of the key limitations is location.  For a project to go through the location must be adequate, both in terms of the technological advantages as well as the political/social impact.  In my studies at University, I held an internship position at a solar energy company.  My primary responsibility was to evaluate project sites both for the advantages to solar as well as things such as endangered/protected species or land. This was a preliminary screening for a project site. If it interfered with any protected habitats, endangered species or historical sites, the site was out of the question.  The three proposed projects for the pumped storage hydro plant all interfere with New York States Forest Preserve, in which the goal for this Preserve is to keep the lands “forever wild.” Building a pumped storage within these lands will directly affect the biodiversity of the area by displacing various animals and plants.  All in all, I support the state of New York for looking into renewable energy sources. However, the proposed locations for the hydro plant directly violate the goals and values put forth by the Forest Preserve. I will not consent or abide to this proposal by Premium Energy.

Sincerely,
Mark Marschall

Katie Hood Morgan, Dover Plains, NY.

Katie Hood Morgan
84 McCourt Road
Dover Plains, NY
12522

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,

Katie Hood Morgan

Tavon Bolourchi, Dover Plains, NY.

Tavon Bolourchi
84 McCourt Road
Dover Plains, NY
12522

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,

Tavon Bolourchi

Kate McGloughlin, Olivebridge, NY.
Dear Ms Bose,

I’m writing to oppose the plan for a hydroelectric plant proposed by Premium Energy Holdings LLC, your docket number P-15056.

By now you’ve heard from my neighbors who are engineers, conservationists, sports enthusiasts, environmentalists and community activists the myriad reasons that this application should be denied. Though I comprehend the protestations from these professionals, I can’t speak with authority on any of those subjects. Their voices are informed and clear—the facts based on science and engineering—this project shouldn’t be placed in this location.

I can only speak with authority from my own experience and work about the magnitude and lasting effects this sort of disruption can have on a community, and the legacy of generational trauma it can engender for its descendants. For the last five years, the focus of my work has been to name, express, publicize and help the community heal from the impact the last significant act of eminent domain has had on our community.
( https://www.katemcgloughlin.com/video).

Those of us whose families were dislocated from what is now the Ashokan basin, still wrestle with reconciliation; there exists, still, a mistrust between some of us and agencies and commissions that enact life-altering undertakings for ‘the greater good’. Once again, our rural way of life is undervalued. Once again, our lifestyle and livelihoods are pitted against a good idea—who could possibly be against renewable energy?—perhaps someone whose homeland and neighborhood will be destroyed by the creation of another reservoir.

I openly and publicly resent the process by which a non-local, for-profit company can apply to a non-local commission to make an application to begin an operation that would be so deleterious to another person’s homeland. I’m a twelfth generation Ulster County resident and I take this matter very personally.

It will be a great day when renewable energy is delivered through a not-for-profit coalition that actually has an understanding of holistic progress, not by a process that undercuts the obvious way of the future (renewable energy) by devastating the delicate ecology of humanity and wilderness that is the hallmark of the Catskill Mountains.

Sincerely,
Kate McGloughlin
Olivebridge, NY
(Descendant of Asa Bishop of Olive City, Lemuel Boice of Boiceville, Lemuel Winchell of Olive, and Kit Davis of Tongore)

Brian Kaley, Pleasant Valley, NY.
As a lifelong NYS resident born and raised in Ulster County, the proposed site of the Ashokan Pumped Storage Project, I want to register my great concern over the concept and scope of this project and its potential dramatic impact on this Catskill Mountain region and its communities.  Based upon my review of the project as currently proposed, there appears to be a high risk for negative consequences on this fragile and beautiful ecosystem which includes the Esopus Creek fishery and its tributaries as well as vast areas of protected wilderness.  Certainly, less impactful options need to be considered before this proposal receives even preliminary consideration given the potential impact.  Thank you for the opportunity to comment on this proposal.

George Holz, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of  NYC’s drinking water.
We have lived in Woodland Valley, one of the proposed, for the last 35 years. We live just above the where the upper section of the dam would be. Has Premium Energy given any thought to how the remaining residents in  Woodland Valley would get in and out of the valley during the construction and after the dam is there?  We have done excavation here to build a small pond, and other building projects, The ground up here is riddled with clay layers, and we’ve had major slumping with just minor excavation. It slides on itself—very unstable.  The clay layer is so prevalent, that even the littlest rain, can make the streams run brown for weeks. The area is intertwined with Forever Wild NYS DEC State Land, and also is a major trout spawning habitat.  It is rich in history, where everyone from writer John Burroughs to Roosevelt would come to escape into nature. There is NYS DEC campsite plus trailhead to the high peaks at the end our our dead end road. What is going to happen to that? Besides living here, we also operate the Holz farm, on the site of historic Larkin Farm—dating back to the days of John Burroughs. This would devastate our businesses and livelihoods, but also wreck our bucolic existence with nature.

While there’s no doubt that pumped storage and new hydroelectric projects may possibly play a role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” You are not even allowed to even cut a twig on state land. The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof due to many people moving up the area during the pandemic. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, hunting, fishing, and other forms of recreation in the Catskills.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, 
George Holz

Margo Pomelova, Chichester, NY.
My parents live and own property directly in the area that will be affected by this project. I am very concerned with the impact of this plan, both on the area and on the drinking water in NYC. Environmental impact: the Catskills are a State Preserve protected by the NYS constitution. Economic impact: $300 million, or more, of spending by tourists in the Catskills would be impacted, if not destroyed. The drinking water of people who live in Queens, Bronx, Brooklyn, Manhattan or Staten Island, would be negatively impacted by the project. Premium Energy’s application has mistakes and inaccuracies. Key players weren’t contacted (Ulster, Greene Counties, Shandaken, Olive and Hunter towns, NYC, DEP, etc.)

Patty Wu, Lanesville, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you for you consideration.

Sincerely, Patty Wu

David Schneider, Lanesville, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to you as a resident of Lanesville whose historic house sits right in the middle of one of the proposed sites and a  local business owner in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,

David Schneider

Kathleen Marschall, Hillsborough, NJ.
FERC project number, P-15056

As a part time resident of Woodland Valley since 1973, I am writing to oppose the preliminary permit application by Premium Energy to build a pumped storage hydro plant in the Catskill Forest Preserve in New York.

I understand that New York’s Clean Energy Standard passed in 2015 means NY aims to achieve 70% renewable power by 2030. This objective is driving the need for innovative methods of energy storage, however, the Catskill Forest Preserve is not the appropriate site for pumped storage hydro-electricity generation.

The Catskills Forest Preserve was created in 1885 and is protected under Article XIV of the NYS Constitution:  the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” It appears that Premium Energy is unaware of this status.

While hydropower reduces greenhouse gases from fossil fuels, reservoirs themselves produce methane, a particularly harmful greenhouse gas, which begs the question: Does pumped hydro storage benefit the environment, the ultimate goal of the Clean Energy Standard? The Premium Energy proposal is not the kind of innovation the Department of Energy is seeking. 

In all of the three areas proposed for the reservoir construction, the ecological impacts would be severe. Valuable trout breeding habitat would be lost. All three are within Audubon’s Catskills Peaks Important Bird Areas. All are habitats for some plant, bird, bat and snake species on NY’s “threatened”, “special concern”, or “greatest conservation need” lists including the bog orchid, northern long-eared bat, scarlet tanager, wood thrush, black-throated blue warbler, and three hawk species. It creates rapid fluctuations of water in the upper reservoir which wreak havoc on both aquatic and land habitats. These lands are protected for these very reasons!

I adamantly object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy’s application for a preliminary permit.


Kathleen M. Marschall

Adam Cherrington, Athens, NY.
I oppose the hydroelectric proposal due to the damage it will do to the Catskills park and water quality for NYC

Paul Misko, Phoenicia, NY.
This project is ill-conceived and will ruin a beautiful and historic valley, the value of which far outweighs the possible benefit of a dubious plan. Therefore I am opposed to this project.

Stacy Quinn, Rhinebeck, NY.
I am writing regarding docket # P-15056 and the proposed pumped-storage hydroelectric facility.  

I am very strongly opposed to the new Catskills-based pumped-storage hydroelectric facility proposed by Premium Energy Holdings of Southern California.

I am sure that this project has an economic upside for the shareholders of Premium Energy Holdings.  There is no upside for current or future residents of the area, however, and there are many, many downsides. 
 
The Catskills are protected by NY State as a State Preserve for good reason.  They contain valuable geological and natural environments that are unique and, if damaged, irreplaceable.  Our current generations have been fortunate to inherit them in relatively undamaged condition and we have a responsibility to future generations to hand them off in equally good condition. 

The Catskills region is also a vital recreational area.  Area residents and tourists alike rely on it for mental and physical health.  On a personal note, it has been a critical resource for me and my friends as we navigate the covid pandemic.  And the soaring traffic/usage numbers over the past year demonstrate how similarly vital it has been for many, many others.  In addition to its physical and mental health benefits, it is an economic lifeline for the region.  Tourism is the backbone of the local economy and we cannot afford to jeopardize the regional financial ecosystem.  

Finally, this proposed project has potential to interfere with the quality and increase the cost of drinking water for NY City residents.  This project has been introduced with minimal public oversight or discussion and the time period for public comment is very brief.  If NY City residents were aware of this proposal, though, and had an opportunity to provide input, I expect it would be VERY strongly opposed.  

I have heard that the supposed justification for this proposed project is that it increases the availability of ‘clean’ energy.  Granted, this pumped-storage facility would provide an alternative to carbon-based energy.  That does not automatically make it a worthwhile or beneficial project, however.  NY is already benefiting from a growing solar energy supply and we do NOT need to implement a detrimental project like this in order to decrease our dependence on carbon-based energy.  

In summary, for all of the reasons stated above – I STRONGLY oppose this proposal as it would harm NY residents in myriad ways without any corresponding benefits and the only people who would benefit from our misfortune would be a small group of outside investors.  Please support American democracy and make a decision that protects the residents of this state instead of selling us out to outside interests, as in a third world authoritarian regime.

Jennifer Holz, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of the DEP New York City’s drinking water supply.
We have lived in Woodland Valley, one of the proposed, for the last 35 years. We live just above the where the upper section of the dam would be. Has Premium Energy given any thought to how the remaining residents in  Woodland Valley would get in and out of the valley during the construction and after the dam is there?  We have done excavation here to build a small pond, and other building projects, The ground up here is riddled with clay layers, and we’ve had major slumping with just minor excavation. It slides on itself—very unstable.  The clay layer is so prevalent, that even the littlest rain, can make the streams run brown for weeks. The area is intertwined with Forever Wild NYS DEC State Land, and also is a major trout spawning habitat.  It is rich in history, where everyone from writer John Burroughs to Roosevelt would come to escape into nature. Besides living here, we also operate the  small Holz Farm, on the site of historic Larkin Farm—dating back to the days of John Burroughs. Besides agriculture, we also do photo shoots and workshops here. This would not only devastate our business and livelihood, but also wreck our bucolic existence with nature.

While there’s no doubt that pumped storage and new hydroelectric projects may possibly play a role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” You are not even allowed to even cut a twig on state land. The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. There is NYS DEC campsite plus trailhead to the high peaks at the end our our dead end road. This is enjoyed by thousands of people each summer. The legendary trailheads are open all year. What’s going to happen to those?

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof due to many people moving up the area during the pandemic. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, hunting, fishing, and other forms of recreation in the Catskills.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Best, 
Jennifer Holz

Ellen Rosenshein, MARLBORO, NY.
I stand with the Catskill Mountain Club in opposing this proposal. It is obvious that the applicants have no knowledge or understanding of the meaning of the Catskill Park, America's First Wilderness. The Catskill Park deserves to be preserved, as do the lives and livelihoods of those who reside there. This project honors neither. 
  The Premium Energy project would cause permanent and irreparable harm, and, therefore, it must be rejected.

Jeffrey Roberts, OLIVEBRIDGE, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to make my voice heard about the poorly conceived and executed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.  I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, due to: the problems presented by the legal ramifications; the lack of congruence with DoE objectives; and the impact on a delicate ecosystem which has been preserved “forever wild.”  

We must not sacrifice the idyllic and protected Catskill Forest Preserve in the process of securing new energy sources.  Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve has large swathes of continuous wildlife habitat, as well as fragile ecosystems. We must protect our “forever wild” land, for its own sake, and to set precedent for future projects.  A pumped storage system such as this will increase turbidity in the Esopus Creek, and threaten the un-filtered water supply for NYC.  Our community is fueled by eco-tourism.  In the fallout of the pandemic, the Catsklils became a refuge of beauty and space from the crowded cities.  We need to preserve the environmental beauty in order to preserve our local tourist economy.

The legal ramifications of building a new reservoir in the Catskills are staggering.  Landowners would be forced to allow the building of the reservoirs, most likely by eminent domain.  How will Premium Energy address the herculean task of the NYS legislature creating an amendment to the state constitution to allow a project like this on protected land?

Premium Energy claims this project is a “closed-loop” system when in fact it is an “add-on,” using an existing body of water as a lower reservoir.  This is not the kind of innovation that the Department of Energy wants to see, and Premium Energy has not been honest in the proposal.  We can assume that their deceit was intended to secure a fast-track approval, but the citizens and lawmakers of NYS are not fool, and we expect that proposals be honest and transparent.

I am aware that the transition to renewable, green-energy sources will not be easy, but I am passionate that it will not come at the expense of environmental protection. Premium Energy has every right to find a suitable location for a pumped storage project—but this is not it.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jeffrey Roberts

Max Fortgang, bearsville, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Max Fortgang

Philip Mouquinho, West Shokan, NY.
P-15056-000

Philip Mouquinho
74 Butternut Knolls
West Shokan NY 12494
845 657 3337 home
917 439 2383 cell

Dear Sir/Madam,

I am writing this comment in regard to the Ashokan Pumped Storage Project. I find no more ridiculous idea than to place this inefficient and criminally negligent idea in the heart of a most bucolic and peaceful wildlife setting in the Catskills. To begin with they plan to generate 2.8 Kw of power and use 2.0 Kw (71%) of the production to run the pumps and the facilities in the support buildings with the remaining 20% going to Ulster Township. Where is the fairness in this when those of us who live in West Shokan and the other towns and hamlets around the reservoir have to bare the burden and put up with the new congestion, vibration, dust, noise and impacts on our immediate environment.  I ran away from Lower Manhattan 25 years ago and have been living right next door to the reservoir and now the insanity of constructing this hair brained project has followed me up here.
As it stands now route 28 A is one of the most neglected road surfaces in the area and with this new construction, we will be inundated with a parade of heavy construction vehicles and traffic from workers and material deliveries not to mention the rumbling noise and deterioration of the peace and tranquility that makes this area so special.
I served on Community Board 2 in Manhattan and Chaired the Zoning Committee as well as other committees such as sidewalks and public accesses, Traffic and know when there is something afoul with an idea such as this. The fix is in and we must stop it before it gains momentum. The Politicians will say there is plenty of time for alternatives and nothing Is set in concrete and create committees and stall until one day we wake up and the area is cleared and the excavators and cement trucks start arriving and then they say “well we tried and put up a good fight but we can’t stop progress” ! I have seen this too many times in my day.
Sincerely,

Philip Mouquinho

Kevin Noble, Brooklyn, NY.
									Kevin Noble
									6702 Ridge Blvd apt  6G
									Brooklyn, NY 11220


Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426							April 11, 2021

Re: Project P-15056.  Ashokan Pumped Storage

Dear Secretary Bose,

   I am writing to respectively request that you deny the preliminary permit to Premium Energy for the Ashokan Pumped Energy Project P-15056.

   Given that the NYC DEP has commented that they are totally opposed to this project and will  not even allow any testing of soils on NYC DEP land for studies means that granting this permit to Premium Energy will ultimately be a waste of time. 

   I live in Brooklyn, NY and I depend on the Ashokan Reservoir for about 40% of my drinking water. I am very concerned that the drilling of a tunnel into the bottom of the Ashokan Reservoir will disturb the sediment that has been collecting there for the past 100 years. The Esopus Creek regularly flows turbid with sediment after heavy rainstorms . The NYC DEP engineers have  developed methods over many years to allow the sediment to settle out in the western basin of the reservoir before sending the water into the eastern basin. From there clean clear flows though tunnels on its way to the faucets of the residents of NYC. The Premium Energy Project would likely upset this crucial process of clearing the water of sediment.

   Besides the disturbance to the bottom layers of sediment from the construction of the dam and tunnel there would also be the ongoing disturbances by the daily releases from the dam and the pumping of water back up to the upper reservoir.

  This release from the upper reservoir and pumping back up would also likely cause problems with the water temperature stratification especially in the summer months when the rainbow and brown trout in the reservoir depend on the cold water at the bottom layers.

   I am a member of the New York City chapter of Trout Unlimited. Along with other members of our chapter I have spent considerable time as a volunteer working to improve the habitat for trout in the streams and rivers in the Catskills.  Wild trout populations have seriously declined over the years due to the building of dams and reservoirs which prevent trout from reaching their spawning grounds in the upper reaches of the tributaries.

   The Esopus Creek and and its tributaries are widely known as a wild rainbow trout fishery. Anglers travel from around the country to fish the Esopus. Hundreds of anglers from New York City fish the Esopus every year.The NYS Department of Environmental Conservation this year upgraded the classification of the Esopus Creek to a “Wild Quality Stream” in their new Trout Management Plan. This means that the NYS DEP recognizes that the Esopus and the tributaries have the proper habitat for trout spawning.

Sincerely,
Kevin Noble

Don Kinsella, West Shokan, NY.
Dear Federal Energy Regulatory Commission (FERC)

I am writing to express my opposition to the permit for the Ashokan Pumped Storage project being proposed by Premium Energy Holding LLC of California. As a resident of the Catskills I have firsthand knowledge of the areas under consideration for this project, the delicate ecosystems that would be impacted and the potential economic destruction a project of this size in this area would entail.
The Catskill Forest Preserve is classified as Status 1 land under the U.S. Geological Survey’s Gap Analysis Program. Because of this status it means that there can be no development for hydropower under the U.S. Department of Energy’s (DOE’s) Hydropower Vision. Any changes to this status within the Catskill Preserve would require a constitutional amendment, passed by the State legislature, followed by a public referendum.  
This is not a “closed-loop system” as claimed by Premium Energy Holding LLC. If this project were to happen there will be increased turbidity within the Ashokan Reservoir degrading the water quality to the point where filtration would likely be necessary before the water could be used as a potable source. The rising and falling surface water levels would likely adversely affect stream and adjacent terrestrial ecology in the Ashokan Reservoir, Esopus Creek, and tributaries. Erosion and sedimentation regimes would likely change and could negatively impact the drainages. 
There are numerous rare plants and animals that grow and breed in the Catskills whose habitats would be threatened if such a project were to go forward. The Esopus Creek is one of the most popular trout fishing streams in the Catskills with Brook, Brown and Rainbow Trout all calling its waters home which would be seriously threatened, and their breeding habitat may be eliminated. Trout fishing is a large source of tourism and vital to the local economy as well. There are many rare plants and in fact it is illegal to harvest or remove plants from the Catskills. 
It is clear to me that based on the fact that the Catskills are designated as Status 1 Land, that there are numerous negative impacts to protected plant and animal habitats and that this system will degrade the water in the Ashokan Reservoir which serves over 9 million residents of New York City that this project application permit should be denied. 

Thank you, 

Don Kinsella

Jason Howell, Brooklyn, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am greatly concerned with the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Forest Preserve. FERC should refuse their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. Having a pumped storage project link to the Ashokan reservoir would be cause irreparable harm to the environment, disrupt small local communities, and even risk the purity of NYC’s drinking water.
The Catskills forest preserve is not to be disturbed per NYS Constitution and even if it were the proposal is flawed as it jeopardizes the drinking water of NYC. Per the NYS constitution, the lands  “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The existence of this contiguous forest is essential for the well being of our forests and wildlife habitat. Not to mention a great source of recreation for people from the surrounding communities and positive economic impact. If this is allowed it would be a sad day cause what’s next on the chopping block. 
Not only will the construction be disruptive and destroying and flooding an area for an upper pond in the middle of a Forest Preserve be absurd, the effect on the surrounding community due to ground water diversion and unknown effects of holding so much water and releasing it repeatedly into a vast  reservoir that supplies unfiltered water to NYC with close to 40% of its drinking water needs. The effect on streams and trout streams which is a vital part of the tourism in the Catskills would be affected with increased turbidity too. What would the cost be in loosing something that could not be put back. 
The impact on outdoor recreation would be devastating to the community and also the long time and new residents who would face eminent domain seizures. Hiking, hunting, skiing, snowshoeing, camping, fishing, and other activities would be disrupted and potentially cut off for good. 
The idea that this is a closed loop system as Premium Energy’s Ashokan Pumped Storage Project claims is not true. Tying into an existing system that feeds the drinking water of a major metropolitan city should be enough put a stop to this and it is heart wrenching to imagine it has even gotten to a point were citizens must standup in mass to oppose it.  
If Premium Energy want’s to make pump storage project they should find place that is not a forest preserve and has such a history of already displacing people. While they may be a future for these types of pumped storage facilities they should not be at the expense of common sense and preserved forest preserves and local communities. I would hope they were actually green and not a net loss system too. The system takes advantage of commercial energy rates at the expense of the rest of us. 

I urge you to deny the proposal for Premium Energy’s preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Jason Howell
Brookly, NY 
(Long time outdoor enthusiast of the Catskills Mountains Forest Preserve)

Sarah, Saugerties, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Sarah Vogwill

Sylvia Grieser, Kerhonkson, NY.
To whom it may concern 

As a resident of the catskills and only 10 minutes drive from the proposed project location I would like to express my serious concerns.
The area has a beautifully functioning eco system, that holds a balance in nature. 
There are very few manmade constructs that aren’t disruptive to nature and this particular one would have a huge negative impact on everything living in its vicinity with a questionable attempt towards renewable energy. The impact is just not worth the outcome. This project seems to only have the economical gain of the investors in mind and not of the local community.
I strongly hope that we will make a wise decision in favor of keeping the catskills safe from such invasive projects and companies and will vote against this dam project

Sincerely 
Sylvia
Grieser

Sylvia Grieser, Kerhonkson, NY.
To whom it may concern 

As a resident of the catskills and only 10 minutes drive from the proposed project location I would like to express my serious concerns.
The area has a beautifully functioning eco system, that holds a balance in nature. 
There are very few manmade constructs that aren’t disruptive to nature and this particular one would have a huge negative impact on everything living in its vicinity with a questionable attempt towards renewable energy. The impact is just not worth the outcome. This project seems to only have the economical gain of the investors in mind and not of the local community.
I strongly hope that we will make a wise decision in favor of keeping the catskills safe from such invasive projects and companies and will vote against this dam project

Sincerely 
Sylvia
Grieser

Bennet Ratcliff, Bearsville, NY.
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426
Docket P-15056-000

Dear Secretary Bose,

The permit application for a feasibility study, P-15056, should be rejected outright by the Federal Energy Regulatory Commission because the applicant fails to recognize the specific jurisdiction and authority granted by Public Law 87-328 to the Delaware River Basin Commission of which the municipality of Shandaken, New York is covered.

In its amended application for a preliminary permit, the applicant, Premium Energy Holdings, LLC, fails to list the Delaware River Basin Commission (DRBC) and the Town of Shandaken, in Ulster County, New York.  These omissions are quite large, and significant.  

The DRBC was created by a compact which was signed into law in 1961 by President John F. Kennedy, and signed into state laws by the Governors of Delaware, New Jersey, New York, and Pennsylvania. 

Article 2, Section 2.7 of the Public Law 87-328 states the jurisdiction of the Delaware River Basin Commission: "The commission shall have, exercise and discharge its functions, powers and duties withing the limit of the basin, except that it may in its discretion act outside the basin whenever such action may be necessary or convenient to effectuate its powers or duties within the basin, or to sell or dispose of water, hydroelectric power or other water resources within or without the basin.  The commission shall exercise such powers outside the basin only upon the consent of the state in which it proposes to act."

The DRBC lists the municipality of Shandaken, NY as one of the 63 municipalities in New York state that fall within the Delaware River Basin.  
https://www.state.nj.us/drbc/basin/municipalities.html

The applicant's amended locations appear to be outside the basin, but within the municipality of Shandaken. This municipality is clearly under the authority of the DRBC.  Article 2, Section 2.7 of Public Law 87-328 specifically states the DRBC "may in its discretion act outside of the basin."  One situation listed is "to sell or dispose of water, hydroelectric power or other water resources win or without the basin."

The applicant's proposal clearly ignores the DRBC's jurisdiction as outlined in Public Law 87-328.  The applicant's proposal clearly ignores the DRBC's authority concerning hydroelectric power "within or without the basin."

This is not simply about the applicant's failure to list the Delaware River Basin Commission and the Town of Shandaken, NY. While this is a glaring deficiency in the application, another deficiency is more significant.

The applicant is proposing that FERC grant a permit for a feasibility study for hydropower in a municipality under the authority and jurisdiction of the Delaware River Basin Commission as outlined in Public Law 87-328.

FERC should not approve such a request because the DRBC has authority and jurisdiction that this applicant ignores.

In consideration of the above and cited information, I request that you reject this application from Premium Energy Holdings, LLC, for a preliminary permit.

Respectfully,

Bennet Ratcliff
Bearsville, NY

Erika Karl, Brooklyn, NY.
Hello,

This is in reference to docket P-15056. I would like to voice my concerns and dismay with the proposed West Shokan hydro-electric pump storage pump. First, let me start by describing myself as someone who both lives in New York City, and am also familiar with the friends and family of people who live in Olive and on Moonhaw Road in particular. 

I find it appalling that a company based in California could come out to a New York Forest Reserve and create a project that would disrupt and destroy parts of a nature reserve and a community they have nothing to do with, other than to make money for themselves.This plan is obviously not well thought out. 

First, the concept alone is faulty. Using more energy to pump water up a mountain in order to create less energy is not a good idea. Granted, it is cheaper to pump while the price of energy is lower, but there has to be a better way. Technically, this way of generating energy still uses more energy than it creates. Also, when it comes to touting pumped water as a “green” energy source, I don’t think it really is. When an energy project destroys or disrupts the surrounding ecosystem, can we please say that this is no longer a “green” energy source? Faulty!

Second, the project is going to use the Ashokan Reservoir, a main water supply for New York City. Why mess around with this reservoir at all? If anything… anything at all goes wrong, the water supply for NYC, which is New York State’s main cash-cow of a city, could be in jeopardy. Heck, NYC is a major money-generator for the rest of the nation, don’t mess with it! 

Third, and most importantly, did this company from California take any time to read into the history of how the Ashokan Reservoir came to be? There still is bad juju because of  how they removed whole towns and communities, steeped in historic importance, in order to provide a water supply for New York City. How tone-deaf can this project be? How thoughtless to rip up once again, the re-located and in some cases, destroyed historic towns of the Catskills for this project? This may in fact put in jeopardy the Ashokan Reservoir itself! What was the point of building this massive reservoir if some greedy company sneaks in and ruins it for this ridiculous way to generate power?!

I whole heartedly oppose and am dismayed by this project. I stated 3 points of why I am opposed, but there are also so many more reasons that I can’t even touch the surface of describing… like the impact on the nature reserve that is so precious to maintain and once gone, it can’t be put back.  Please put an end to this faulty and thoughtless project. 

Sincerely,
Erika Karl

Tracy Walsh, West Shokan, NY.
April 11, 2021

I’m writing to protest Premium Energy’s Proposed Pump Storage Hydroelectric Plant (FERC project number, P-15056). The truth is, sustainable and renewable energy are incredibly important, and good projects need to be supported. But this particular plan is a non-starter—for multiple reasons. Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation.

As a resident of Moonhaw Road—one of the 3 sites being looked at for this project—I am painfully aware that over 100 years ago, our valley was previously flooded, our town destroyed, and the livelihoods of local residents taken away. This cannot be allowed to happen again. Not here. Not ever. 

First off—this project would destroy highly preserved land. The Catskills Forest Preserve was created under Article XIV of the NYS Constitution, with the understanding that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” These 700,000 acres of continuous wildlife habitat ranks among the top 1% of forest habitats region-wide, and are considered Status 1 land under the USGS “Gap Analysis Program.” According to the Department of Energy’s Hydropower Vision, “areas with formal protections designated Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Of equal importance, this project would forever alter the Esopus, one of the Catskills’ most vital trout waters and a major contributor to the water supply for New York City—bringing 1 billion gallons a day to 9.5 million people.  This is in effect the largest unfiltered water supply in the nation. This particular project would increase the turbidity of the water in the Ashokan Reservoir, and wreak havoc on the NYC water supply.

An additional point that should be made is that Premium Energy’s Ashokan Pumped Storage Project proposal does not represent the kind of innovation that the Department of Energy is looking for. “Closed-loop” pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. And while Premium Energy describes this project as a “closed-loop” system, it is in fact a project with significantly higher risks and detrimental effects. Why should we (and why should FERC) trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

I trust that Premium Energy will be able to find an alternative location for a project such as this one—but which will not destroy protected land, devastate communities, and threaten wildlife and other natural resources.

The bottom line is that it would be foolhardy for FERC to allow this project to proceed beyond the preliminary permit stage. Project P-15056 should be rejected now, and Premium Energy’s focus should be directed toward a more effective and less costly solution to the ongoing problem of energy storage. And perhaps next time they should tell the whole truth.

Sincerely,
Tracy A. Walsh


Lindsay G Black, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
 
Docket number P-15056-000
 
Dear Ms. Bose,

My name is Lindsay Black. I recently purchased my first home in Olivebridge in May of last year, and am deeply troubled at the prospect of the Ashokan Pumped Storage Project P-15056. Our natural environments are important - sacred even, these days. Though the notion of hydroelectric power in and of itself creates a pathway toward the reduction of our dependency on fossil fuels, the cost to our constitutionally protected natural habitat is grossly antithetical to the preservation of our environment. We are in the midst of a pandemic still, and the continued loss of natural habitat, further upsets precious ecosystems, whose inherent  diversity is key to our planet’s ability to regulate itself. And we, the people who live and work here, do so in symbiosis with the natural environment, as local economies are built upon visitor traffic who come to hike, boat, eat, fish, ski, vacation, and marry here. Potential relocation of families from their homes via eminent domain would tear apart communities, and add to the housing crisis that already exists in Ulster County, a crisis that has worsened with the pandemic as the cost of real estate has surged upward. 

I am in deep disagreement that this is a way forward regarding our country’s transition to green, renewable energy. The scale of ecological disruption, of community disruption, is disturbing. I am further distrubed by Premium Energy’s verbiage of this project being closed loop. I cannot imagine how that is possible given the vital tributaries that interconnect with the Ashokan, which would have rippling effects on the Esopus. None of this is for the benefit of those who will bear the brunt of this dam’s effects. Its creation is to provide a type of energy insurance for consumers, which ultimately only benefits the pockets of  Premium Energy. True green and renewable energy wouldn’t seek to harm protected environments. It would seek to reimagine our energy consumption and how that energy is produced, not just create a backup for the way we currently consume it. 

With conviction and heart, I sincerely plead with you to deny the preliminary permit proposal for the Ashokan Pumped Storage Project P-15056.

Sincerely, 
Lindsay G Black

Heather Tannenbaum, Berwyn, PA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Heather Tannenbaum

Scott Fernjack, Lanesville, NY.
I am writing in response to the preposterous proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands." 

Premium Energy’s proposal would be deeply damaging to the environment, our local economy and our thriving community. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Robert Graffeo, Lanesville, NY.
So called Engineers..   In regard to the preliminary expedition for Hydro project in Catskill Mountain area.  As much as the desire is to evaluate and attempt to develope a hydro project...Please note some realistic concerns.
     Rerouting a roadway to develope a Dam, would obstruct:
     
     1. traffic to and from outdoor recreation, local restaurants, and residents.  This roadway is also a state road that has scenic protected land which is routinely traveled.  Infrastructure is already neglected unfortunately and your anticipated project may on paper seem beneficial to private enterprise but would serve no value to current residents or frequent and new visitors to the landscape , historic scenery.
    
      2. Construction and destruction of Protected land would effect the overall environment.  Natural preserves serve as an environment for many species protected and non- protected.

      3. The ecological effect of re-routiing the water flow would destroy the waters ecological system.  Honestly, you putting pen to paper may seem wonderful on paper , however the destruction of natural protected state land would only leave to a failure of quality of water in N.Y.C.  Many years ago the water in NYC was considered the best in the state and country.  Unfortunately, the neglect of the city and poor execution of private vendors like yourself would only be interested in the economic gain for corporate companies and the narrow minded politicians that you have in your pocket.

     4. As engineers, challenge yourself with projects that re-build or utilize distressed properties. Utilize the many distressed properties along the Hudson.  consider the old IBM building in Kingston. Spend time and money re building the existing infrastructure.  The overall cost would be less and the profit margin would also exist , power the destruction of protected areas would not occur.

As engineers, revise the mess created at the Gilboa Dam.  NYC is responsible for the managing of dams and reservoirs.  The responsibility includes upholding dam regulations to lesson any environmental impacts .  NYC not surprisingly  has been identified as having high hazard levels according to the National Inventory of Dams.

SIMPLY... Your company will make it work on paper, however hydrological or structural faults that make them susceptible to a failure either triggered by storms, and progressive deterioration, SIMPLY INADEQUATE MAINTENANCE!!

Elliot Avi Gitler, West Shokan, NY.
To whom it may concern, 
Like so many others, I was astounded to hear of FERC's consideration of Premium Energy Holdings hydroelectric power plant proposal in New York’s Catskill Mountains. 

This should not even be granted a feasibility study given that: 
1) This is State Forest Preserve, and under ArIcle XIV of the NYS ConsItuIon, the lands “shall be forever kept as wild forest lands.

2) These lands are home to a diverse and rich habitat, which supports myriad species of fish, birds mammals, etc.,,,, one which is beloved by all, AS IS.

3) Aside from potential local issues, this project could potentially harm NYC's drinking supply, which is one of the city's greatest assets. That particular part, of playing games with the reservoir which dependably supplies NYC with [I believe] 40% of it's daily drinking water is particularly surprising to me.

I hope FERC will make the right decision, and reject this feasibility study outright.
I thank you for your consideration.
-Avi Gitler

Kristal Kinder-Bartlett, Shokan, NY.
Hello,

As residents of Shokan, NY, we vigorously object to the proposal by Premium Energy Holdings to place a hydro-electric plant near the Ashokan Reservoir. We request that the Federal Energy Regulatory Commission to deny the application for a preliminary permit. This project is NOT a closed-loop project so should not be considered. Also, the Catskill Forest Preserve is a State Forest Preserve, protected by the NY constitution, and is considered Status 1 land under USGS Gap Analysis Program. According to the Dept of Energy’s own Hydropower Vision, “Areas with form protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

This project will most definitely be detrimental to the area wildlife and to valuable drinking water for NYC and NY state. This project should not be considered and should not move forward in any shape or form.

Thank you,
Kristal Kinder-Bartlett & James Bartlett

Brian McDonald, Mount Tremper, NY.
As residents and home/property owners in Mount Tremper and NYC me and my family have a very intimate relationship with the Catskill Mountains and the NYC watershed. More specifically the Esopus creek and Ashokan reservoir. Our property in Mount Tremper is adjacent to NYC watershed property our condo in NYC utilizes this same water. Nearly all residents and visitors alike are drawn to the Catskills for the natural splendor the area provides and our family relishes in the natural recreational opportunities in the area. We are avid hikers and I am devout fly fisherman on the Espous. As much as we enjoy and treasure the natural beauty found in the Catskills we also appreciate the importance of the city and its challenges in handling over 8 millions inhabitants. I am acutely inspired by the ingenuity and the sacrifices it took to develop the reservoir watershed to provide clean and safe drinking water for the inhabitants of NYC. Catskill residents and resources ware severely impacted in creating the reservoirs; ultimately they have been successful and since those initial impacts the City and DEC have been working with the state and local municipalities to mitigate further impacts and when possible improve the surrounding areas.
With the knowledge of this history and personal relationship with the area me and my family vehemently oppose Premium Energy Holding’s application for permit for the proposed hydro electric project. I consider my family environmentalists and we strongly support alternative energy sources/programs but all presented and available information on this project represent significant negative impacts to the local environment not to mention the water source for nearly 9 million people. This project will have a negative impact on nearly every outdoor recreational activity that the Catskill park was preserved for: hiking, hunting, fishing, etc. 
The Catskills represent a historically significant touchstone of American naturalism that was memorialized in the work of great American artists such as Thomas Cole and Washington Irving. Please do everything in your power to acknowledge and preserve our natural resources and our history and deny the permit application of Premium Energy Holdings.

Capt. Lindsay R. Hoyt, Jr., Boiceville, NY.
Capt. Lindsay R. Hoyt, Jr.
95 Piney point Rd.
Boiceville, NY  12412

April 11, 2021

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC  20426

RE: Docket # P-15056 Ashokan Pumped Storage Hydroelectric Proposal
 
Dear Secretary Bose:

I am writing to express my opposition to the pumped storage hydroelectric generation project proposed by Premium Energy Holdings for the Catskill Park region of  New York. (FERC Docket #P-15056).
 
The whole proposal is erroneously described as a “closed loop system,” when in fact it is anything but a closed loop. It should at best be described as an “add on” system.
 
Building any one of the proposed upper reservoirs would displace hundreds of local residents, destroy wild trout spawning tributaries and, according to experts, destabilize the streams that are dammed. This  destabilization would cause more turbid waters to be delivered to the Ashokan Reservoir, which is also acting as the lower reservoir for the Power Project. Moving water back and forth between the upper reservoir and the Ashokan would also likely create more turbidity.

The final nail in this coffin should be the fact that the Ashokan Reservoir provides unfiltered drinking water to over 9 million people in New York City and other communities along the way! Risking this much pure drinking water over some half-baked pumped storage power plan.

Premium Energy Holdings should be denied any permits to do any further studies on this proposal.

Sincerely,

Lindsay Hoyt
Treasurer
Ashokan-Pepacton Watershed Chapter of Trout Unlimited

Brooke Parslow, West Shokan, NY.
Dear Kimberly D. Bose and all,

I am writing to express my opposition to Premium Energy Holding’s proposed Ashokan Pumped Storage Project, Docket number P-15056-000.

As we move forward into a more sustainable energy future, FERC will play a large, vital role in what that looks like. It’s clear that all energy projects will require some degree of sacrifice and upset, whether it’s shifts in the job market or people losing homes via eminent domain. However, it’s FERC’s responsibility to be principled in this process by following its own mission (like that set forth in Hydropower Vision) and holding prospective developers to high standards. It’s abundantly clear to me that this proposal falls short on both of these fronts; allowing it to continue forward would be a dangerous precedent, possibly undermining the public’s faith in our institutions and making people wary of sustainable energy projects as a whole.

The creation of an upper reservoir in the Catskill Forest Preserve and the ensuing rapid fluctuations of water in both reservoirs would devastate our surrounding wildlife habitats. Habitats like these cannot be fully recovered once they’re destroyed and are vital to our ecological future. The Department of Energy clearly understands this, as areas with “formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development,” according to Hydropower Vision. The forests around any conceivable sites in the Catskill Forest Preserve rank among the top 1 percent of forest habitats region-wide, and are considered Status 2 land under USGS “Gap Analysis Program.” These areas have been protected as forever wild by the New York State Constitution for over 100 years.

The proposal incorrectly states on page 11 that the “proposed Ashokan Pumped Storage Project would operate in a closed loop.” The Ashokan Reservoir, the proposed lower reservoir, is part of a flowing water system fed from above by the Schoharie Reservoir, Esopus Creek, and smaller tributaries, and flowing downstream into the Esopus Creek and the water-supply system of New York City. It is actually an add-on project for open-loop pumped-storage hydropower because the Ashokan Reservoir is still continuously connected to the naturally flowing water feature that was dammed to construct the Ashokan Reservoir. 

Premium’s misrepresentation of this seems self-serving (since the Department of Energy supports closed-loop projects) and calls into question their ability to operate with integrity when profit is at stake. 

The proposal omits Greene County, incorrectly names multiple townships, and omits numerous major streams. Its descriptions of the proposed sites (with blurry maps and contradictory locations) are so poor that many community members cannot even tell if they’ll be directly impacted. The proposal feels rushed and careless, which is truly an insult to the ecosystems and communities that would be sacrificing so much for a project like this.

I respectfully request that FERC deny this preliminary license application.

Thank you,
Brookelyn Parslow
241 Moonhaw Rd
West Shokan, NY 12494

Maya Muratov, New York, NY.
Dear Ms. Bose,

I am tremendously concerned about the proposed Ashokan Pumped Storage Project, that proposes to flood over 200 acres of private land and protected state forests to construct a new reservoir. 

We should not forget that the Catskills are a State Preserve protected by the NY State Constitution. The wildlife in the area will be endangered. 

This project would also be detrimental to the local community by disrupting the economy, thriving tourism, and displacing residents. 

Moreover, it would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water (as it serves as a primary source of unfiltered drinking water for over 9 million New York residents). 

Another concern is that it will severely disrupt existing regional wells and septic systems which in turn will negatively affect the quality of water regionally and in New York City.  

We clearly recognize the need for our nation and world to transition to green-energy sources. However, this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, contaminate local wells and septic systems, and negatively impact the drinking water of over 9 million New Yorkers.

Julie, Mew York, NY.
To whom it may concern:
This is an OUTRAGEOUSLY MISLEADING proposal:

With a great concern I must state that the information presented in the Proposal is vague and misleading and does not allow respective approving Government Officials consider any meaningful quantitative parameters to evaluate the following decision-making points:
• Feasibility
• Costs
• Efficiency
• Avoidable Environmental impact
of the proposed solution to flatten peak energy usage.  
Further,
the Proposal does not specify gigantic implied construction and environmental costs;
 
Further,
the Proposal does not provide any comparable contemporary existing methods and/or solutions successfully implemented for similar causes.

-  Proposed solution is NOT a ‘renewable energy’ or ‘green’ solution. It is outdated and widely debunked ‘energy storage’ solution.
 
While using a hot contemporary ‘renewable energy’ term, the solution of a power plant powered by water pumps is an old, archaic and well-known ‘energy storage’ solution. By no means could this be called a ‘renewable energy’ or ‘green’ solution.
 
Pumped storage power plants existed for over a half of a century. Their main disadvantage is that they always operate at a significant energy loss.
In order to raise the water up the dam and, by doing so, to ‘store’ energy, a use of an additional 5-10% of grid energy is needed just to cover the energy losses while operating heavy machinery (pumps) to raise water in the first place. This means that a minimum of 5-10% of the grid energy is lost in order to ‘store energy’.

It must be stated that currently there is no known machinery used for pumping, generating and/or transmitting energy, which COE would be greater than 95%.
 
Therefore, cumulatively during energy generating cycle a MINIMUM of 10% -20% of energy will be lost in the proposed pumped power plant solution.
 
It is at most importance to note that such lost electrical energy is originally drawn from a common grid and supplied there by non-renewable and non-green methods.
 
In other words, tons of coal or oil must be burned in order to operate proposed so-called ‘renewable energy power plant’!!!

— Proposed solution comes at enormous monetary and environmental cost
 
The Proposal outlines constructing dams, water reservoirs, tunnels, power lines, underground facilities, electrical grid, and so on. Powerful turbines, generators, motors, transformers, etc. have to be purchased and installed.
 
It is obvious that implied related costs would be enormous, most likely in billions, yet the Proposal does not provide one single figure to outline costs. Nor does it offer costs vs. efficiency calculations.
 
Furthermore,
the proposed power plant is to be built in the State Park areas. Hundreds of acres of ancient forests are to be sunk and destroyed. Natural habitat of thousands of flora and fauna species, some of which are endangered, is to be destroyed, too.
 
Furthermore,
the plant is proposed to be built in direct proximity to water reservoirs supplying the US largest city, New York City, with approximately 40% of its drinkable water. It is unknown how proposed construction and disturbance of water supplies will affect the New York City water quality. 

So, why doing all of this when there are existing proven, contemporary and efficient energy storage solutions?
 
Why NONE of them are presented in the Proposal for the consideration of the approving Government agencies??

—  There are contemporary energy storage solutions currently existing on the market at a fraction of implied cost of the proposed pumped power plant.
 
Existing new energy storage solutions are cheap and effective.  

Currently, there are existing energy storage solutions with power storage of 60 MW.
 
They are cheap, compact and can be installed on existing electro-station and/or sub-stations.  There is no need to build enormous capital structures, disrupt water supplies or sink natural habitat of various species!!

Cost of such storage batteries is well-known to the contrary of the unknown cost and impact of the proposed water plant solution.
 
Further,
The Proposal’s completion date is years in the future.
Given the speed of developments in the field of contemporary energy storage systems, by the time of supposed pumped power plant completion the capacity of such systems will undoubtedly increase while their cost will be reduced even further.
 
THE PROPOSAL  BY PREMIUM ENERGY IS DANGEROUSLY MISLEADING AND CAN CAUSE ENORMOUS DISTRACTION FOR NO CAUSE WHATSOEVER.
STOP IT!!!!

Bennett D. Krasner, Hunter, NY.

THE LAW OFFICES OF
BENNETT DAVID KRASNER
P.O. Box 778
Hunter, New York 12442
(516) 551-9864   Fax (516) 432-7016

Of Counsel
Bonnie Ellen Krasner

April 11, 2021


Kimberly D. Bose, Secretary
Nathaniel J. Davis, Sr., Deputy Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

		Re:	Project No. 15056-000
			Premium Energy Holdings, LLC

Dear Commissions:

	This preliminary permit should be denied. The land that the preliminary permit appears to be utilizing is “The lands enclosed within the proposed project boundary are New York State Lands”. (See Application Section 5 at page 13). This land while owned by New York State is shown as wilderness or forest. (See Application Exhibit 3). This land, as I understand, is designated by New York State as “Forever Wild”. Such designation is given by the New York State Constitution and it cannot be utilized for the purposes of a Hydroelectric Power. As I and many others understand, this land cannot be sold or leased or licensed for use and cannot be built on in any form and must be left as forest and wilderness. It would literally take the President of the United States and an act of Congress to condemn by eminent domain this land. 

	With the above being said, your standard of denying an application is stated succinctly in  footnote 2 in opinion 170 FERC ¶ 61,231, UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION application of Premium Energy Holdings, LLC Project No. 14991-001 when you state as follows:

§ 1133(c), (d)(4) (prohibiting the Commission from licensing projects within designated wilderness areas, except where authorized by the President); see also Hudson River-Black River Regulation Dist., 33 FERC ¶ 61,122, at 61,261 (1985) (“We deny applications for a preliminary permit where licensing of the project to be studied is clearly statutorily precluded, because no purpose would be served by issuing a permit for a proposed development that could not be licensed.”); Woods Creek, Inc., 19 FERC  ¶ 61,181, at 61,348–49 (1982) (denying a permit for a project proposed in a designated wilderness area).

	Based upon the forgoing, the permit application demonstrates that it should be denied as it clearly statutorily precluded. No purpose would be served by issuing a permit for a proposed development that cannot be licensed.


Very truly yours,
Bennett D. Krasner

Hartley Walker Money, Poughkeepsie, NY.
While renewable energy is incredibly valuable in the fight against climate change, the impact of renewable energy, such as hydropower, must be assessed critically. Acknowledging the tradeoffs of ‘clean’ energy is important in moving forward towards decarbonizing our energy sector and the world at large. Large-scale energy projects have the potential to displace people, wildlife and reshape the hydrological and natural systems of the region.  

Premium Energy’s project proposal is not fit for FERC approval due to Premium Energy Holding’s preliminary permit application/proposal not meeting the Department of Energy’s expectations of closed-loop pumped storage hydropower expansion. Additionally, Premium’s proposal and is lacking in a comprehensive understanding of the potential impacts of pumped storage hydropower in the Ashokan watershed and surrounding Catskill region.  

Premium Energy claims in their project proposal that the PSH system at Ashokan Reservoir would be a closed-loop system, which is incorrect and misleading. Because of Esopus Creel feeding and draining Ashokan Reservoir, any hydro project within this watershed would be considered open-loop. Open–loop pumped storage will threaten the Esopus Creek and its cherished wild rainbow trout population of which has been recently recognized by the NYS DEC. The recent designation of Esopus Creek as a “Wild” fishery is a testament to the quality of this ecosystem. The Esopus Creek is fed by the surrounding watershed located in the Catskills which have been protected for over a century and helps support a tourism-based economy in the region. Tampering with this watershed means tampering with an already sensitive economy.  

The Catskills are some of the most pristine forests in the northeast and deserve considerable attention and care. Article XIV of the NYS Constitution, states that lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private” which suggests that Premium Energy and their proposed PSH has no place in the Catskills. 

The creation of an upper reservoir as a holding tank for pumped storage would inevitably displace people, reroute road infrastructure and disturb the ecosystems of the Ashokan Watershed. Rapid fluctuations of water levels in both upper and lower reservoirs due to power production during peak demand has implications on the water quality for downstate residents in New York City. 40% of NYC’s water supply is sourced from the Ashokan and Schoharie Reservoirs, which means that any dramatic landscape changes in development could put NYC’s water supply at risk. 

Renewable energy is essential in an efficient energy transition away from fossil fuels, but the implications of hydropower are worth critical consideration. Pumped storage hydropower has a place in our energy sector, but it has no home in the Catskills.  

In conclusion, I write to you to comment in my opposition to Premium Energy Holding’s pumped storage hydropower proposal for Ashokan Reservoir. It would be a shame to see the people of the Catskills have to spend years fighting Premium Energy. This project needs to be halted in its tracks before traction is made.  Allowing Premium Energy to conduct feasibility studies on PSH would be inviting the infringement and degradation of highly preserved lands with deep historical ties to conservation and management. This project has immense potential to disrupt the ecosystems and communities of the Ashokan Watershed which would leave deep lasting scars on the Catskill region.

tyler schwerzler, olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Tyler Schwerzler

Steve London, CHICHESTER, NY.
I am writing in opposition to the Premium Energy Holdings’ application for a permit to develop a “closed loop” pump storage reservoir system.  I believe Premium’s proposal to be deficient and should be denied.

I live in Chichester, NY, on Stony Clove Creek about two miles from the proposed Alternative #1 Lanesville dam site. In 2005, The Stony Clove Stream Management Plan was published.  The Greene County Soil & Water Conservation District staff and the New York City Department of Environmental Protection completed an assessment of the Stony Clove Creek and its corridor.  The Ashokan Watershed Stream Management website says of this Plan, “This plan provides a comprehensive review of stream characteristics, data, maps, and recommended management strategies.” 

Even a cursory reading of this extensive Plan makes it clear that damming Stony Clove Creek at Lanesville will cause major damage to Stony Clove Creek south of the dam and major damage to the Ashokan Reservoir, and thus to New York City’s drinking water.

The Plan comments that Stony Clove is a major contributor to the turbidity of the Ashokan Reservoir, because of the suspended sediment carried by Stony Clove Creek.  In part, this is due to the “underlying clay-rich glacial geology.”  The Plan comments that glacial clay was observed in a 1996 survey on the banks of Stoney Clove Creek in the parcel of the Creek slated as the site of the dam.  Damming Stony Clove Creek at Lanesville and striping the entire reservoir area of vegetation will create two major problems: 1) The constant change in water level associated the rise and fall of the “upper” reservoir will cause significant erosion, turbidity, and injection of sediment directly into the Ashokan reservoir.  2) The dam will continuously trap the known Stony Clove suspended sediment, thus injecting this sediment directly into the Ashokan Reservoir or causing significant silting of the dam; thereby limiting the dam’s usefulness, life-expectancy, or causing expensive maintenance.

The dam will adversely affect the water quality and flow of Stony Clove Creek south of the dam causing changes in the chemical composition of water and damage to the flora and fauna adjacent to the steam.  Furthermore, the reduction of water flow caused by the Lanesville dam interrupting the water flow of the stream will cause extensive damage to the trout spawning in Stony Clove Creek. 

Also, in the Alternative #1 “Concept” plan, Premium does not indicate exactly where they plan to drill the .27 miles shaft to connect with 10-mile underground tunnel to the Ashokan Reservoir.  That said, from the schematics presented, it appears that shaft will be drilled in land adjacent to Warner Creek, a significant tributary of Stony Clove Creek.  There is no assessment of the realistic impact this would have on water quality. Contrary to Premium’s assertions, I will note that this is not near any existing road and appears to be about .5 miles beyond the end of Silver Hollow Road.

It should be clear to all that the Premium plan is not a “closed-loop” system.  It should be obvious that the Premium Energy Holdings proposal anticipates using Stony Clove water trapped by the Lanesville dam to supplement water presumably they intend to pump up from the Ashokan Reservoir.  I don’t know if they factored Stony Clove Creek water flow into their cost-analysis, but given all the studies done on Stony Clove Creek, they should have been able to provide this information in their application.

Premium Energy Holdings failure to correctly identify the true nature of their plan should be a prima facia case for finding their application deficient.  The fact that they failed to report on the most elemental research nor to contact stake holders not only adds to the deficiencies of their application, but raises concerns about their application as a good faith effort.

I urge the Commission to reject this application and send a message to Premium Energy Holdings that such deficient applications undermine good policy, cause ill-will, waste a lot of peoples’ time and energy, and do nothing to advance the common goal of shifting from a carbon-based energy system.

Sincerely,
Steve London
90 Stoney Clove Ln
Chichester, NY 12416

Lee S Wecker, Phoenicia, NY.
April 10, 2021


Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose,

I am a tax paying home owner with properties in the hamlets of Chichester, Allaben and Phoenicia in the town of Shandaken. I am wholly against the Ashokan Pumped Storage Project being proposed to the Federal Energy Regulatory Commission (FERC) by Premium Energy Holdings (PEH) , docket number P-15056.

While I support the production of energy that is not based on fossil fuels, this project is not appropriate for the proposed locations for numerous reasons stated by so many others.

•	This project is not compatible with New York State’s desire to protect and preserve forests and wildlife. All proposed reservoirs are within the Audubon NY Catskill Peaks Forest Important Bird Area (IBA).

•	The system’s impact on turbidity levels of the Ashokan Reservoir which supplies both local and 40% of New York City’s water, serving 1 billion gallons of water a day to 9.5 million people. The proposal threatens this valuable asset, which holds the distinction of being the largest unfiltered water supply in the nation.

•	The potential benefits of the project are minimal to the “public good” compared to the value of these lands for conservation of biodiversity as well as the ecological services provided to the People of the Unites States by such lands.

•	The project is not closed loop as proposed due to the fact that the Esopus Creek runs into and out of the Ashokan Reservoir. 

•	Siting a project such as this within the Catskill Forest Preserve would be unforgivable from a biodiversity conservation prospective. The Catskill Forrest Preserve is considered Status 2 land under the USGS Gap Analysis Program.  According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."

•	The Filtration Avoidance Determination (FAD) as it relates to the NYC watershed and water supply would need to be renegotiated with the USEPA before preliminary work on this project could proceed.

I respectfully request that FERC deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Lee Wecker

John BOudreau, Yonkers, NY.
April 10, 2021


Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose,

As a person who recreates, swims, hikes, skis, and shops in the Catskill Preserve and a person who regularly drinks New York City water, I will be directly impacted by the proposed Ashoken Pumped Storage Project being submitted by Premium Energy Holdings, docket number P-15056. 

This project is not appropriate for the proposed locations for numerous reasons. I agree with comments written by so many others, that I summarize here:

•	This project is not compatible with New York State’s desire to protect and preserve forests and wildlife. All proposed reservoirs are within the Audubon NY Catskill Peaks Forest Important Bird Area (IBA).

•	The system’s impact on turbidity levels of the Ashokan Reservoir which supplies both local and 40% of New York City’s water, serving 1 billion gallons of water a day to 9.5 million people. The proposal threatens this valuable asset, which holds the distinction of being the largest unfiltered water supply in the nation.

•	The potential benefits of the project are minimal to the “public good” compared to the value of these lands for conservation of biodiversity as well as the ecological services provided to the People of the Unites States by such lands.

•	The project is not closed loop as proposed due to the fact that the Esopus Creek runs into and out of the Ashokan Reservoir. 

•	Siting a project such as this within the Catskill Forest Preserve would be unforgivable from a biodiversity conservation prospective. The Catskill Forrest Preserve is considered Status 2 land under the USGS Gap Analysis Program.  According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."

•	The Filtration Avoidance Determination (FAD) as it relates to the NYC watershed and water supply would need to be renegotiated with the USEPA before preliminary work on this project could proceed.

I respectfully request that FERC deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
John Boudreau

Alexander Sandor, Aurora, CO.
Good evening,
My name is Alexander Sandor and I write as a member of the Roxmor community off Woodland Valley rd. I am a 3rd generation resident of Roxmor Colony.

 I am currently travelling and learning which is my address is not more localized. However this does not mean I don't long for a pie from Brio's or to lounge on tubes down the Esopus Creek with friends and family alike. Stopping in for some ice cream and buying nicknacks from the nest egg.

     I am confident you've read a share of emails dedicated to the environmental impacts, economic implications, for phoenicians and NY state itself as well as its environment would be assuredly irreversibility impacted. I understand I was advised to highlight these tangible and understandable values to be calculated against one another. However I seek to voice my opposition on the basis of the place itself. The community as a whole. The people, customs, passions, cultures that may be simply lost to a private company's ambition. 

      Assigning a value to a company, experience or life has always been a struggle to the state. Balancing gains and losses based on progress and what part of ourselves as a body or people's get left behind. A business can be valued. As can a property or an opportunity in gross terms. However the experience, culture, the things learned are something that can never be taken away. 

     There is one thing that is always said when you graduate college. "You have something no one person or entity can not take from you, your knowledge, understanding, and experience". This company will not simply take lands away but experiences, culture and tradition. 

    Square dances and pig roasts and traditions extended further. Including but not limited to council fires wherein knowledge is passed down generation by generation. Songs remembered skills learned and taught by parents and grandparents. Gaining a respect for nature and leaning while stocking the stream with trout or finding small swimming holes. Another generation is growing and it pains me to think a corporation would rob my children and a 4th generation of learning about, respecting and enjoying the traditions of a place that cannot be replaced. If we take away what makes us special nothing is left but a calculated anger and anxiety. I hope you and your coworkers not only understand but feel the gravity of the loss of a historical and cultural place in NY.

~Alexander W. Sandor

Valerie Linet, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to express my serious concerns and dismay about the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.  I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, due to: the problems presented by a flawed proposal which will negatively impact the health of the Esopus Creek, as well as the quality of drinking water drawn from the Hudson River and Ashokan Reservoir. In addition, there would be negative impact on the people who live on, vacation in, and drink water from impacted lands and bodies of water. The proposed plan would also have a damaging impact on a delicate ecosystem which has been preserved “forever wild.” Finally, it is an expensive and wasteful energy “solution” that uses more power than it stores. 

The movement of water in pumped storage can impact the sediment regime and ecology of the tributaries to the Esopus Creek as well as to the Esopus, itself, which is a valuable trout breeding habitat. The Esopus which feeds the Ashokan Reservoir, is an essential part of New York City’s drinking water, is already highly affected by excessive sediment, and thus there is a concern for the unfiltered water relied upon by the city’s 9.5 million residents as well as Hudson Valley community members.

We must not sacrifice the ecologically precious and formally protected Catskill Forest Preserve in the process of securing new energy sources. The U.S. Department of Energy has itself recognized that development of such lands should not occur.   Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” We must protect our “forever wild” land, for its own sake, and to set precedent for future projects. 

The legal and social ramifications of building a new reservoir in populated areas of the Catskills are significant. Landowners would be forced to allow the building of the reservoirs, most likely by eminent domain. Community displacement and seizing of private property, as well as flooding over 200 acres, much of which are preserved forests on protected state land, would be destructive to the human communities  and ecology.  How will Premium Energy address the enormous issue of getting the NYS legislature to create an amendment to the state constitution to allow a project like this on protected land?

Lastly, pumping water to the proposed upper reservoir could require more power than what’s generated as the water flows back down, and is therefore a process that could burn through cheap power in order to make costly power. 

I am aware that the transition to renewable, green-energy sources is necessary and  challenging, though it must not come at the expense of environmental protection and community health. Premium Energy has chosen an incredibly unsuitable location for this proposed pumped storage project.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Valerie Linet

Barbara Hirth Strauss, Shokan, NY.
/Users/barbarahirth-strauss/Desktop/Untitled.pages

Project Docket.  P-15056



Problems with Premium Energy’s proposed pumped storage hydro facility:

Premium Energy has still not formally informed Greene County officials (Lanesville site), as per the application directive.

Premium Energy is applying for a closed loop system project of which the Ashokan Reservoir is not.  It has ingress and egress of the Esopus Creek and others.

The land In question in the application is protected in the NYS Constitution as the Catskill Forest Preserve and the Catskill State Park under Article XIV.  It is forever wild and not to be sold or taken by any corporation.  

The land is also Status 1 under the USGS.  The Department of Energy states that Status 1 lands are to be avoided in the DOE’s hydro vision projects.

Other detrimental impacts include loss of habitat for endangered species, wildlife, and fish.  Damage to the environment would impact fish spanning, ecosystems, infrastructure and tourism.

Although pumped hydro storage is important, this is not an excepted environment for this project based on legitimacy, correct information in the application, and lack of transparency on the part of Premium Energy.

I believe they have not yet completed one of these projects.  This fragile system is not the place to start.

Joel Riklin, Bethesda, MD.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426

Docket P-15056-000

Dear Ms. Bose

I am Joel Riklin. I currently live in Bethesda, MD, where I have lived for almost 20 years.  Prior to living in Bethesda, I lived for about 25 years in Hartford, CT area.  I began my life in the New York City area, primarily Yonkers, NY.  

I am writing to you to urge you to reject the deeply flawed proposal submitted by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains.

This proposal by Premium Energy offers three possible locations for the pump storage all within the Catskill Forest Preserve.  This is a valuable recreation area that I like many residents of the New York City metropolitan have enjoyed for many years.  I have particularly enjoyed camping and hiking for many years in the Woodland Creek Valley, one of three sites proposed for the pump storage reservoir.  I have also hiked in the Stony Clove area, another possible location for the pump storage reservoir.  I continued to visit the area to hike and enjoy the natural environment while a resident of the Hartford, CT area and, although I currently live much further away I still vacation in the area.  

The destruction of such a valuable forest and recreation land should be sufficient reason to deny this proposal for a preliminary permit.  Moreover, The proposed sites are on designated Status 1 land, and federal policy (the Department of Energy) explicitly directs that Status 1 and 2 land areas are highly protected and must be avoided for development.  Furthermore, the Catskill Forest Preserve is protected by the New York State constitution.  Under Article XIV of the constitution it is guaranteed that these lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanges, or be taken by any corporation, public or private.”  Thus, this proposal would require a Constitutional Amendment passed by the NYS Legislature and signed by the Governor. The inconsistency with Federal policy and significant NYS legal hurdle are clear reasons to stop the proposal now.

In addition the destruction of valuable forest and recreational resources, the proposed project will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for 9 million New York residents.

I recognize the need for our nation and world to transition to green-energy sources. However, this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, and negatively impact the drinking water of 9 million New Yorkers.

I urge you, as a responsible public official, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.    

Joel Riklin

James Friedlich, Shokan, NY.
Dear Madame or Sir:

I am writing to urge that all public officials oppose this Permit from Premium Energy Holdings. The proposal is a clear and present danger to the immediate environment, to the Ashokan Reservoir, and ultimately to the precious drinking water of New York City. 

Thank you, 
James Friedlich
Shokan, NY

Alison Gerson, Woodstock, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alison Gerson

Jodi La Marco, OLIVEBRIDGE, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in opposition to the ill-conceived proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Preserve. While I understand and support green energy initiatives in New York State, the cost of this proposed project far outweighs its benefits. 

I’m a member of the Catskill 3500 Club, a hiking group that grants membership to those who have climbed the 35 highest peaks in the Catskills. I hike in the Catskills regularly and have seen the popularity of the Catskills Forest Preserve grow wildly during the pandemic. Our area has been attracting a record number of both locals and visitors from nearby New York City. In the most recent issue of The Canister (the 3500 Club newsletter), it was announced that on January 13th, 2021, two of the 35 peaks required for club entry—Doubletop and Graham—were permanently closed to the public. “We all have seen how the number of hikers in the Catskills has increased in the past few years and COVID-19 has just been a part of that – this was happening pre-COVID-19 as well. With more people pursuing the 35…the traffic on these mountains (and everywhere) is expanding. The impact on the natural resources is evident and the landowners have taken this step to enhance the health of the ecosystem and protect the flora and fauna. Consequently, the family has decided that the mountains they love need to make the return back to their original wilderness state.”

In a press release dated November 20, 2020, the Catskill Center also reported an increase in visitors to the park, stating, “the number of visitors to the Catskill Park and our open spaces are growing, just ask the Stewards of the Catskill Center’s Catskill Stewards Program, who saw a 27% increase in the number of visitors they greeted in the Catskill Park during the 2020 season.” 

While the Covid-19 crisis has encouraged more people to recreate outside, the park’s increase in popularity will not end with the pandemic. Many of these visitor have become so enamored with the Catskill area, that they have caused a housing boom (please see this June 17th, 2020 article from the New York Times entitled “A run on the Catskills”: https://www.nytimes.com/2020/06/17/realestate/a-run-on-the-catskills.html.) 

The placement of any of the proposed new reservoirs would add to the problem caused by the recent influx of visitor and new residents by putting increased strain on remaining hiking access points. The ill-conceived placement of these reservoirs would also make travel difficult.

Indeed, the New York New Jersey Trail Conference (NYNJTC) has stated, “The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.” 

The Wittenberg reservoir would submerge the end of Moonhaw Road, which serves as an access point to Friday, Balsam Cap, Lone, and Rocky mountains. The Woodland Valley reservoir would flood Woodland Valley Road, which provides access to Wittenberg and Cornell Mountains, and to Woodland Valley Campground. The Stony Clove reservoir would arguably create the most dramatic problems for motorist journeying northward from Route 28. Just north of the proposed reservoir is the Devil’s Tombstone Campground, as well as trailheads providing access to Plateau and Hunter Mountains, two popular mountains along the famed “Devil’s Path” hiking trail. All of the mountains listed above are popular with hikers, as each is a 3500 Club-required hike. 

The most troubling road interference is the proposed interruption of Route 214. Due to the fact that the road passes between Plateau and Hunter Mountains, it would be impossible to reroute this road. Travel from Lanesville to Tannersville via Route 214 currently takes 13 minutes according to Google Maps. The same trip would take an hour via Route 212 and Platte Clove Road to the east, or 50 minutes via Route 42 to the west. These would be the most direct routes available should access on Route 214 be interrupted.

Simply put, the quaint little towns of upstate New York are no longer quaint little towns. The population and usage of our area has swelled drastically during the past year, and the increase in permanent residents indicates that the popularity of our area is unlikely to lessen once the Covid-19 pandemic has come to an end. More people are visiting the Catskill Forest Preserve than ever before, resulting in more stress on the park. At this critical time, we need more environmental protections for this state-designated “forever wild” zone, not additional conservation challenges.

It is clear that Premium Energy Holdings is woefully unfamiliar with our area. I respectfully request that this company be denied the right to conduct a preliminary study for this poorly thought out project. 

Thank you,

Jodi La Marco

Abbey Dedola, Seal Beach, CA.
To Whom It May Concern,

I am a homeowner in the Chichester area and stand with the Chichester Property Owners Association in opposition to the granting of a preliminary permit to Premium Energy Holdings (PEH) for the project to build a pumped storage hydroelectric plant utilizing the Ashokan Reservoir (docket number P-15056).

The proposal as submitted contains much erroneous and misleading information, and I  believe that the FERC should study the following facts, and deny this application.

1. The entire proposed project lies within the Catskill Forest Preserve, which has been protected in section 2.1 of the New York State Constitution since 1894.

2. Key players were not notified beforehand, as legally required, including:

* New York City
* The hamlets of Lanesville, Chichester, Phoenicia, Mt. Tremper
* Towns of Shandaken, Olive and Hunter
* Ulster and Greene counties
* Hunter Mountain Ski Resort, and its parent company Vail Resorts

3. Local and vacationer traffic on New York State Route 214, connecting Hunter Mountain, and the hamlets of Tannersville and Hunter to all points south, would be severely disrupted, wreaking economic havoc on the affected hamlets, towns, and counties.

4. Replacing New York State Route 214 will prove impractical, if not impossible, given the topography of the land.

5. New York City’s Department of Environmental Protection operates the city’s drinking water supply under a Filtration Avoidance Determination (FAD) issued by the US Environmental Protection Administration. The proposed project would drastically raise the turbidity in the Ashokan Reservoir watershed

6. As proposed, PEH’s project is not a closed loop system. With so much private property located within close proximity to the Stony Clove creek, and surrounded by the Catskill Forest Preserve, relocation of homes and businesses along the creek is impossible without amendment of the New York State Constitution.

We urge the Federal Energy Regulatory Commission to deny Premium Energy Holdings the permit.

If you have any questions about this letter, please contact me at the provided phone number. Thank you.

Sincerely,
Abbey Dedola

Clare Herzog, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket Number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains.  I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Clare Herzog

Elizabeth Kostro, RIDGEWOOD, NJ.
Open spaces and the small towns or hamlets interconnecting the public open spaces need to be preserved and not sacrificed for energy production.

The Catskill preserve provides a haven and respite into nature for some of the most populous areas of the nation. The Catskills are drivable for a day trip from many of the commuting communities of New York City.

In a time of pandemic and an awareness of the need for open, shared, public, wilderness spaces, the Catskills should continue to be preserved.

Climate change is real. Preserve the existing open spaces. Premium Energy Holdings of Southern California should develop in its own backyard in Southern California as oppose to here in on the east coast. 

Lastly, pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314), the Catskill Mountainkeeper, a non-profit organization with its primary office in Livingston Manor in Sullivan County New York and a satellite office in Woodstock in Ulster County New York, should be granted full party status in the Docket # P-15056 – Ashokan Pumped Storage Project proceeding by the Federal Energy Regulatory Commission.

Christina Roe, BROOKLYN, NY.
I am writing to urge FERC to decline the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 would be devastating to the environment, highly disruptive to local communities, and risk the safety of NYC’s drinking water.

While pumped storage and new hydroelectric projects will play a key role in our transition to renewable energy, to sacrifice the protected forests, streams, and wildlife of Catskill Forest Preserve in the process would do more harm than good. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. To destroy this sacred and wonderfully preserved land would set a doomed precedent for protected lands across the country.

Even after construction is complete, environmental devastation would continue due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Premium Energy’s proposal is not a closed-loop system as they claim — it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being transparent about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would engage in such trickery in their proposal simply for the advantage of being fast-tracked for approval?

Our transition to renewable, green-energy sources must not come at the ironic cost of environmental and community devastation. I trust Premium Energy will be able to find a suitable alternative location for a pumped storage project — one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Christina Roe

Stephanie Siehr, Grass Valley, CA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

Hydropower that destroys a watershed, drinking water supply, and an ecological preserve is NOT 'clean' or 'green'. I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power and pumped storage plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The clean energy transition has the purpose of protecting ecosystems and human societies, by reducing disruption of Earth's climate system. Hydropower that destroys a watershed, drinking water supply, and an ecological preserve is NOT 'clean' or 'green'. Even thought pumped storage is one component in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Stephanie Siehr, PhD

Mary Lou Ganio, Roseboom, NY.
I’m writing to oppose the plan for a hydroelectric plant proposed by Premium Energy Holdings LLC, your docket number P-15056.

I lived within just a few miles of the Ashokan for a number of years though now am only a visitor. (I still vested as a landowner in Ulster County.) The  pain afflicted on the people whose families lived there for generations by the creation of the reservoir a hundred years ago is still felt. The raw scars to the land are healed, but the scars to their hearts remain and is shared by those of us who come more lately to the land. 

I can only speak from my heart, not with the authority of professionals as to why this project should be denied. I know that those people have given you clear reasons the project should not be allowed here, but let my voice be joined with them in saying no, no no, this project shouldn’t be placed in this location.

Please listen to the voices of local citizens like Kate McGloughlin whose families were dislocated from what is now the Ashokan basin, who still wrestle with reconciliation, listen to the voices of those who have come more recently to the land of the Catskills they call the Ashokan.  We are against renewable energy, who could be against that, but do not undervalue once  again, a rural way of life, our lifestyle and livelihoods. 

Using Kate McGloughlin’s words directly, “I openly and publicly resent the process by which a non-local, for-profit company can apply to a non-local commission to make an application to begin an operation that would be so deleterious to another person’s homeland.
It will be a great day when renewable energy is delivered through a not-for-profit coalition that actually has an understanding of holistic progress, not by a process that undercuts the obvious way of the future (renewable energy) by devastating the delicate ecology of humanity and wilderness that is the hallmark of the Catskill Mountains.”

Sincerely,
Mary Lou Ganio

Nina Shengold, Stone Ridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE
Washington DC 20426

Docket # P-15056-000

Dear Ms. Bose,

As an environmentalist, I'm excited by the possibilities of hydroelectric power as a greener alternative to fossil fuels.  But Premium Energy Holdings's plan to build a pumped-storage hydroelectric facility using the Ashokan Reservoir as a lower basin and excavating a new upper reservoir in the surrounding mountains is a classic example of the right idea in the wrong place. 

My home is five miles from the Ashokan Reservoir, and it's no exaggeration to say I walk there every day.  My book Reservoir Year: A Walker's Book of Days (Syracuse University Press, 2020) details the reservoir's natural history, human and animal communities, and the history of its construction.  I've also hiked, biked and driven through all three of the proposed upper reservoir sites.  I know this watershed inside out, and it's amply clear that Premium Energy does not.

The proposal is misleading, describing the three proposed upper basin sites as "near" the Catskill Park, when all three overlap the park's boundaries, including wild lands protected in perpetuity by New York State law.  The town of Lanesville is identified as being in Ulster County, not Greene.  

Most crucially, this is billed as a "closed-loop" system.  It is not.  The Ashokan Reservoir is an active water supply for the City of New York.  Its waters enter from the upper Esopus Creek, gather in the reservoir's basin, and are released through gravity-feed tunnels to NYC's holding reservoirs and into the lower Esopus Creek to the Hudson River.  The Esopus is plagued with ongoing turbidity issues that affect water quality, fish mortality, algae bloom, erosion and silt buildup, flood damage to nearby properties, and loss of revenue from tourism and recreational activities such as fishing, swimming, and kayaking.  The release channels and lower creek are opaque brown and frothy, churning around submerged tree trunks.  At the creek mouth near the Saugerties lighthouse, muddy water fans into the Hudson.

Compounding these problems by pumping huge quantities of water to and from an upper reservoir on a daily basis is a disastrous idea.  The proposed sites are upstream of an unfiltered gravity-feed water system that provides 40% of the drinking water for 9 million people.   I understand that in recent days Premium has agreed to look for alternate locations for the upper reservoir, but given the need for a high elevation and a dammable creek, there really are no good alternatives.  

The problem is not which part of the Catskill Park watershed to seize, grub, and dam to build a new upper reservoir above the Ashokan.  The problem is the Ashokan itself.  It is simply the wrong place to locate this pumped-storage plant.  Water quality and turbidity issues are only the tip of the iceberg.  Premium's hydroelectric project would uproot local residents, negatively impact wildlife and fish habitat, lower property values, curtail tourism and recreation, and destroy a carefully preserved, forever-wild part of New York state's cultural heritage.

As you know from the hundreds of letters you've received, I'm not alone in these objections.  During the last three decades, I've been involved in many local environmental and development issues, and I have never seen such unanimity of opinion.  The city of New York, the DEP and DEC, politicians in both parties, local business owners, town boards, local and national environmental organizations, green energy boosters, fishermen, hunters, hikers, second-homers and longtime local residents: no one supports this plant.  I have not heard a single voice saying, "But it's good for the local economy.  We need the jobs."  Not one.

What I am hearing, loud, clear, and everywhere, is NO.  Please listen and turn down Premium Energy's request for a feasibility study.  This ambitious and well-meaning project belongs in another location.

Respectfully submitted,

Nina Shengold
201 Woodland Road
Stone Ridge, NY 12484
Ulster County

Stephen Molmed, West Shokan, NY.
Stephen Molmed, P.E., West Shokan, New York

It is evident that Premium Energy did not put much effort into studying the areas they are proposing to construct the Ashokan Pumped Storage project. The entire application has the feel of “let’s quickly throw it together and see what happens. If the preliminary permit is approved, great, if not, we didn’t spend much time, money or effort.”  A common theme throughout the Preliminary Permit Application is the lack of doing the most basic research to gather the most readily available public information about the proposed locations for the upper reservoirs and power plant locations.

Some people believe that any problems associated with construction can be mitigated through proper engineering and design. However, some projects, such as this one, are so fundamentally flawed that no amount of engineering can resolve their inherent problems. I offer this opinion as a Licensed Professional Engineer. 

Following are descriptions of a number of the deficiencies and inaccuracies in the preliminary application.

Missing Studies

In their preliminary permit application, Premium Energy lists some studies they propose to carry out, their list neglects to include several extremely important studies as listed below. The list is not meant to be all inclusive. 

•	Effects of construction, and operation, of the Wittenberg Reservoir and Dam on the Ashokan Reservoir with special emphasis on siltation and its impact on New York City’s ability to meet their obligations with the USEPA. 

•	Effect of Wittenberg Reservoir impounding the Maltby Hollow Brook on trout as well as other aquatic and terrestrial animals and plants, effects on local wells in shall alluvial gravel deposits. 

•	Flood impact study evaluating effects of a failure of Wittenberg Dam failure on downstream residential properties.

•	Emergency response study proposing measures to be taken to mitigate effects of a dam failure.

•	Impact of the construction of the necessary transmission line right-of-way, including, but not limited to effects of pesticides and herbicides used to maintain the corridor on the Ashokan Reservoir, and on potable water wells and people living near right-of-way.

•	Study and evaluation of the “probable fall zone/engineered fall distance” for the proposed transmission line towers. Based on the route shown in the application, it is probable that many residences would be located with the fall distance of the towers

•	Impact of proposed construction on traffic flow, with special attention to delays in emergency response time for fire, police and ambulance services.

Temporary Roads

Page 18 of the application Premium Energy claims that temporary access roads will not be needed to reach project sites to perform initial studies. This is inaccurate, particularly for the proposed Wittenberg Reservoir site that is located near Moonhaw Road in West Shokan.
Temporary roads will be required to allow machinery to gain access to the areas needed collect the necessary soil and subsurface geotechnical information. Numerous bore holes will be required, to get to all of the locations, multiple temporary roads will need to be constructed, requiring much, much clearing and grading. 

Public Roads

Construction of the pump house/power plant will require that sections of 28A are closed off for a significant period of time. The need for diverting traffic due to the construction of the pump house/power plant is not mentioned. Route 28A is a, relatively, high traffic volume road used by local residents, emergency services, law enforcement, school buses and tourists. Due to the rural character of the area, there are few opportunities to easily divert traffic around the construction. Additionally, no mention is included in the application about the need to permanently realign Route 28A around the power plant. A bypass road or diverting traffic flow will result in significant negative impacts on the daily lives of many residents.

Route 28A is a New York State road, located on land controlled by New York City, and would require permission from agencies such as New York State Department of Transportation, New York State DEC, New York City DEP, among others. 

Plant Capacity

FERC’s deficiency letter requests that the Applicant clarify and update the application with the correct rated capacity of the proposed power generation plant. 

In their response, Premium Energy states that information about the rated capacity of the power generation plant is included in Exhibit 1 of the amended application.

This does not satisfactorily clarify the proposed capacity of the power generation plant. While Exhibit 1 of the amended application states that the proposed power generation capacity is 800 mw, with 1,000 mw required for pump up. Premium Energy’s website, as well as other information published by Premium Energy, states that the project capacity could be 2,000 mw with 2,800 mw required for pump up. This is almost 3 times the capacity stated in the application and, if correct, will, potentially, have significant impact on the volume of the proposed upper reservoir, its level change and flow rate of water needed to be pumped and discharged between the reservoirs. 

If Premium Energy is considering the potential of increasing capacity of the power plan to 2,800 megawatts, all of the effects of this substantial increase need to be addressed as part of the Preliminary Application, and, certainly, must be thoroughly studied in any license application.

New York City DEP Position

NYCDEP has stated that is categorically opposed to the project and will not permit tests to be performed or construction to occur on its property. Further NYCDEP states that their land in not subject to taking by eminent domain. Therefore, it would serve no purpose to grant a preliminary permit for a project proposed to be constructed on lands that the project cannot be constructed.

Sara Amrani, Margaretville, NY.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sara Amrani

Ayla, Saugerties, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ayla Rector

Molly Riddle, Kingston NY, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely
Molly Riddle

Gabriella DiGiovanni, Palenville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Gabriella DiGiovanni

Ariel Helman, Tillson, NY.
To whom it may concern,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ariel Helman

Ann Roberti, ANDES, NY.
This proposal is unacceptable. The project would necessitate construction in a very fragile area of the Catskills, which our Constitution necessitates stay forever wild. The turbidity the project would introduce into the Ashokan Reservoir would be damaging to the New York City water supply as well as the downstream ecology. This permit should not be granted

Submission Description: (doc-less) Motion to Intervene of Terri Basilone under P-15056-000.

Submission Date:        4/9/2021 5:29:21 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               tbasilone1017@yahoo.com                                                          

Basis for Intervening:
motion to intervene
As a home owner at 70 Brodhead Rd West Shokan NY. My property would directly impacted by the proposed project due to the proposed high tension lines by my home.
p-15056
I request intervention

Terri Basilone
Amit Shamir
70 Brodhead Road 
West Shokan NY
12494
917 640 6295
tbasilone1017@yahoo.com

Inka Rector, Saugerties, NY.
I strongly oppose docket P-15056, proposal for generating hydroelectric near the Ashoka preserve fir the following reasons:

-The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

-The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

-The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

-The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

-This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Submission Description: (doc-less) Motion to Intervene of Nicholas Arbatsky under P-15056-000.

Submission Date:        4/10/2021 8:32:01 AM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               nyarbatsky@gmail.com                                                             

Basis for Intervening:
04-10-2021

Kimeberly D. Bose Secretary
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A,
Washington, DC 20426

Re: Docket P-15056-000
MOTION TO INTERVENE of Nicholas Arbatsky for the Premium Energy Holdings, LLC, Project No. 15056

Dear Secretary Bose,
This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. 

Nicholas Arbatsky is filing a motion to be an intervener and meets the requirements of 18 CFR385.214 of the Commission’s regulations to be granted full party status.
The basis for intervening is due to the proposed location of the project in Woodland Valley, New York which would mean that I would lose my home and access to 3 other  properties owned by my family.  I'm concerned that three of these properties would be underwater and I would lose access to the fourth. 
Therefore, I have substantial interest in the matter. I reside on 462 Woodland Valley Rd, Phoenicia NY.
I, Nicholas Arbatsky respectfully requests that the Federal Energy Regulatory Commission grant this motion to intervene.

Respectfully,
Nicholas Arbatsky
PO Box 448
462 Woodland Valley Rd
Phoenicia, NY
12464

Julia Lowrie Henderson, Fremont Center, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,I

 am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country's transition to renewable energy, this proposal is hasty and reckless. The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Julia Lowrie Henderson

Lize Mogel, Brooklyn, NY.
To the Commission:

I am a resident of New York City and I also develop education programs in the Catskills about New York City’s drinking water supply. There are several important reasons why the Premier Energy filing should not move forward:

First, it will impact a major part of the water supply of the City of New York. The Ashokan Reservoir is a terminal reservoir. More than 40% of the City’s water supply is stored here before it moves through the Catskills Aqueduct down to the City. The water supply is one of the best-protected and managed in the United States, and interference with it will negatively affect water quality and the City’s ability to control its management.

Second, the project will impact parts of the Catskills State Preserve, which is constitutionally-protected land. It provides crucial wildlife habitat and corridors, accessible and unique recreational opportunities in the region, and is the foremost economic driver for the region as well. The project will impact people’s ability to access this land, as well as impact wildlife and forests. 

Third, any of the project’s proposed reservoir sites will displace long-time communities, in a region where eminent domain used to create the NYC water system still has generational impacts. 

There is already a carefully developed, delicate balance in the Catskills between the needs of key stakeholders, including 9.5 million water consumers in New York City, Catskills residents and business owners, more than half a million visitors to the region each year, wildlife and forests, the City of New York, and the State of New York. Premier Energy’s proposal would radically disrupt this balance, for a project that is clearly speculative, and has, at this point, no market for the energy produced, no investors, and no support whatsoever from any local stakeholders. 

I would also like to comment on the FERC filing process itself. Through this process, Premier Energy is able to lay claim to a critical part of a region that the company’s principals have most likely never visited, and that they clearly have not done even basic research on. The potential negative impacts as described above are extreme.

While we desperately need to find solutions to our dependence on fossil fuels, these should not come at the cost of important physical and natural infrastructure, as well as people’s lives and livelihoods. Sustainable energy solutions should be developed in collaboration with communities from the start, not forced upon them with little recourse except lengthy legal battles. The FERC process as it stands, to allow exploratory projects without any requirement of basic community support, opens the door to predatory practices, as is evidenced by the Premier Energy filing. 

Thank you for your consideration.

Submission Description: Motion to Intervene of Edward Ripley-Duggan under P-15056-000.

Submission Date:        4/10/2021 2:49:59 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               Erd@wilsey.net                                                                   

Basis for Intervening:
Motion to Intervene of Edward Ripley-Duggan for the Premium Energy Holdings, LLC, Project No. P-15056

As a resident of Olivebridge, an impacted community and as a taxpayer in that community, which is part of the town of Olive in Ulster County, the State of New York, the proposed Ashokan Pumped Storage Project will significantly impact the immediate environment and further, will be deleterious to constitutionally protected public land that I have a stakeholder interest in as a contributing taxpayer.

The proposed Wittenberg dam is about four miles from my home; the alternative proposed Woodland Valley and Stony Clove locations impact major trailheads in the Catskill Park system, and as a one-time officer of the Catskill 3500 Club and a keen outdoorsman this is of deep concern to me. Additionally, there will be major impacts at all of the proposed sites on endangered and threatened species, and it appears that Premium Energy, the applicant for this permit, has insufficiently researched these environmental impacts.  The deleterious effect on the Ashokan Reservoir and New York City’s drinking water is of major concern, as is the impact on the Forever Wild status of protected Catskill lands, and the detrimental character of this development the Catskill Forest Preserve as a whole. 

I, Edward Ripley-Duggan, respectfully request that the Commission grant my Motion to Intervene as a party with full rights to participate in all further proceedings.

Submission Description: (doc-less) Motion to Intervene of Brooke Parslow under P-15056-000.

Submission Date:        4/11/2021 9:56:59 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               broookelyn@gmail.com                                                             

Basis for Intervening:
April 11, 2021
Kimberly D. Bose, Secretary 
Federal Energy Regulatory Commission 
888 First Street, NE, Room 1A, 
Washington, DC 20426 

Re: Docket P-15056-000 
MOTION TO INTERVENE of Brookelyn Parslow for the Premium Energy Holdings, LLC, Project No. 15056 

Dear Secretary Bose, 
This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. Brookelyn Parslow is filing a motion to be an intervener and meets the requirements of 18 CFR 385.214 of the Commission’s regulations to be granted full party status. 

My basis for intervening is that the construction of the proposed project would mean that I would lose my lifelong home and access to my parent's property. Therefore, I have a substantial interest in the matter. I reside on 241 Moonhaw Rd, West Shokan NY 12494.
Brookelyn Parslow respectfully requests that the Federal Energy Regulatory Commission grant this motion to intervene. 

Respectfully, 
Brookelyn Parslow
241 Moonhaw Rd
West Shokan, NY 12494

Submission Description: (doc-less) Motion to Intervene of John Boudreau under P-15056-000.

Submission Date:        4/11/2021 11:33:12 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               john@boudreaudesign.com                                                          

Basis for Intervening:
As a person who recreates, swims, hikes, skis, and shops in the Catskill Preserve and a person who regularly drinks New York City water, I will be directly impacted by the proposed Ashoken Pumped Storage Project being submitted by Premium Energy Holdings, docket number P-15056. I request intervener status.

Submission Description: (doc-less) Motion to Intervene of Thomas Parker under P-15056-000.

Submission Date:        4/10/2021 4:16:46 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               nopremium50@gmail.com                                                            

Basis for Intervening:
I am a resident of the Town of Olive. I live in Catskill Park, which enjoys a protected status. I am concerned about the inevitable effects on our fish, wildlife and plant life. I also have grave concerns about what will happen not only to our drinking water but to the water in the Ashokan Reservoir that comes out of the taps of 9 million New York City residents.

For these and a multitude of other reasons, I am requesting intervenor status.

Thank you,
Tom Parker
50 Weber Lane, Olivebridge, NY 12461

Submission Description: (doc-less) Motion to Intervene of Maxine Davidowitz under P-15056-000.

Submission Date:        4/11/2021 11:54:55 AM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               maxine.davidowitz@gmail.com                                                      

Basis for Intervening:
Motion to intervene in Premium Energy Holdings, LLC proposal for the Ashokan pumped storage hydroelectric project. 
I live in West Shokan (32 McMillan Road) very close to the area that has been proposed for high power electric lines, and am concerned that they would be run across my property or very near it. As well, I avail myself of the extraordinary forest preserve in my immediate area and would be devastated to see it destroyed. I have been horrified by the inaccurate, poorly-planned proposal that gave no thought to the particulars of this region; its tourist economy, its pristine streams, its history of trauma from the huge eminent domain destruction of many towns, etc. etc. This company shows no ability to treat the environment I treasure with any sensitivity or smarts. To have a dam so close to my home that would be privately owned, so that if flooding or other issues came up the local government would have no recourse to respond, is just one of the many many nightmare scenarios this proposal has brought up. 
I request a motion to intervene to be part of the process of seeing and affecting this proposal's status.

Submission Description: (doc-less) Motion to Intervene of Janice A Kachadourian, homeowner on Route 214 in Lanesville, NY, under P-15056-000.

Submission Date:        4/11/2021 2:37:54 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               sunnyfield818@gmail.com                                                          

Basis for Intervening:
April 11, 2021

Online submission - Motion to Intervene: Ashokan Pump Storage Project

Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

RE: MOTION TO INTERVENE Docket # P-15056 – Ashokan Pumped Storage Project

Dear Secretary Bose:

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314), Janice and Gary Kachadourian, owners of the property at 1560 Route 214, Lanesville, NY, 12450, hereby petition the Federal Energy Regulatory Commission to grant full party status in the above captioned proceeding. The persons to whom communications should be addressed and to whom service should be made are as follows:

Janice and Gary Kachadourian
1560 Route 214
Lanesville, NY 12450
845-688-3231
sunnyfield818@gmail.com

As grounds for this Motion, we state that we are full-time residents at the above address, and it is our only residence.  Our residence is in the immediate path of one of the proposed project sites, Stony Clove in Lanesville, and thus we are in danger of losing our home.  We also stand at risk of serious harm from the construction and operation of the project, as well as from additional infrastructure necessary to service it, such as the Ashokan Switchyard, powerhouse, and transmission lines. In light of the foregoing, we respectfully petitions for intervention.

Sincerely,

Janice and Gary Kachadourian
1560 Route 214
Lanesville, NY 12450
845-688-3231

Submission Description: (doc-less) Motion to Intervene of elizabeth iwinski under P-15056-000.

Submission Date:        4/11/2021 2:48:27 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               spaadict@gmail.com                                                               

Basis for Intervening:
I am a long time business owner in Shandaken so I feel I have enough acumen to have pragmatic view on the proposed project from the perspective of return on investment. I look at it from both sides: the residents and business owners vs project investing company. All seems to me as loose/loose preposition:
Impact on forest preserve ecology, impact on tourism business, possible impact on property values 
on one side vs costs of amending the state constitution for permitting the project on the state forest preserve lands, enormous legal fees to justify playing with local and NY City water supply and review processes costs necessary to obtain green light for the project.

Bruce Littlefield, Kingston, NY.
I'm a resident of Marbletown.  My 15 acres borders the Esopus Creek, which spills off the Ashokan Reservoir.  I VEHEMENTLY OPPOSE the use of the protected lands near the reservoir for another dam, turbine & tunnels as proposed by Premium Energy Holdings.  I encourage the Federal Energy Regulatory Commission to deny the application.  The proposed project will cause great damage to our beloved, protected and historic area.  The proposed project must not be allowed to be constructed as it will damage local lands, roads, streams, historic properties and cause turbidity in waters serving as the drinking water for the 9 million people of New York City.  Please do everything in your power to PREVENT THIS DISASTROUS PROPOSAL FROM MOVING FORWARD.
Thank you,
Bruce Littlefield & Scott Stewart
Marbletown

Submission Description: (doc-less) Motion to Intervene of Leanne Avery under P-15056-000.

Submission Date:        4/11/2021 4:47:47 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               leanne.avery@oneonta.edu                                                         

Basis for Intervening:
Dear Commission,

My family has inhabited the Catskills since the 1700s. The Moonhaw site contains ruins of my family homestead. This is where Premium Energy seeks to put another reservoir.

I am a Professor of Rural STEM Education whose career research entails documenting local rural knowledge connected to people, ecosystems and place.  I am also a first generation college graduate of Cornell University whose land-grant mission is rooted in agriculture, history and place. My family history and career work is deeply connected to, and rooted in,  place. I want Premium Energy and FERC to learn about the Complex Connectivity of Place so that the full impacts of P-15056 are understood beyond those shared previously by the DEP (comments submitted 4/8/21). 

Connection between people and place is extremely complex and well-documented in Indigenous and non-Indigenous literatures (Basso, 1996; Fikret & Berkes, 2008; Kassam, 2009:2020; Joppa, et al, 2016; Smith, 2013; Ruelle et al, 2019) and neuroscience and environmental psychology alike (Hebgeb & Kistemann, 2012; Rollero & DePiccoli, 2010; Williams & Seward, 1998). “Socio-cultural and ecological systems are linked through relationships between people and their environment, which includes both relations between humans and relations between humans and other animals, plants and their habitats [Wohlleben, 2016]...thus illuminating the complex connectivity of human ecological relations" (Kassam, 2010, p. 2). These connections begin at an early age as evidenced by photodocumentation interviews with 100 NYS rural children (Avery & Kassam, 2011), and include social, emotional and behavioral components. Research also shows that the cognitive relevance of Indigenous and rural knowledge is critical to survival (Kassam, Avery & Ruelle, 2017). Knowledge, memory, stories, identity, and community is intertwined with, and attached to, place (Avery & Hains, 2017).  Significant interactions between people and the natural environment have been recognized as cultural landscapes (UNESCO, 2021). Simply put, place is more than a zip code.

This region was taken by eminent domain in the early 1900s to build the Ashokan Reservoir. The towns of Olive and Hurley including villages/hamlets of West Hurley, Glenford, Ashton, Olive Branch, Brown's Station, Olivebridge, Olive City, Brodhead's Bridge, Shokan, West Shokan and Boiceville, were taken or relocated. These rural communities' sense of place, identity, and their alternative ways of knowing and being that are in relationship with the ecosystems - were disrupted or forever lost in the flooding. As evidenced in the many documents of the takings hearings (which I have read for my research), these families were dismissed, disrespected and diminished, and the majority, were never compensated for their losses. We were then colonized for water, and now energy (Beisaw, 2016; Thomas, 2015), and the intergenerational trauma persists. 

P-15056 involves a for-profit corporation from California using a map program to situate a project that will again disrupt communities, ecosystems and place. This project aims to again colonize (following the very same 5-step colonization playbook used for generations across national and international contexts - see below) the same rural communities and repeats the intergenerational trauma caused by the first takings (Avery, 2019). Disruption from place is an evisceration, not a change of address. 

[Ironically, Premium Energy seeks to do the very same to the City of NY by colonizing and disrupting what is now their ecosystem and Water Supply System, and in so doing, puts the lives of 9 million people at risk by contaminating NYC’s drinking water.]


Here we are now in phase #5 “Decolonization” that entails the individual’s rejection of the colonizer and their victimization, and the rebirth of resistance and resurgence, particularly by descendants (5th- 6th generation => me) who want their families’ and communities’ stories told. As Tom Petty’s song goes…“Don’t back down.” Thus, I apply to be an intervenor this time around because I want Premium Energy to look me in the eye as they plan to eviscerate my family and place once again. 


Phases of colonization (adapted from Fanon, 1963) 
1.	Colonizer's forced entry into territory to exploit natural resources and inhabitants
2.	Colonizer imposes its culture, disintegrates the Indigenous or non-Indigenous culture
3.	Colonizer is portrayed as more civilized, the colonized as wild, savage, and uncivilized and its the colonizer's responsibility to monitor, tame and civilize
4.	Establishment of a society where the political, social and economic institutions are designed to benefit and maintain the superiority of the colonizer while continuing to subjugate the colonized
5.	Decolonization: rejection of the colonizer and their victimization, and the rebirth of resistance and resurgence, particular by descendants (5th- 6th generation) who want their families’ and communities’ stories told


References cited are available upon request.


This is deeply personal, and I thank you for considering.

Leanne Avery
Olivebridge, NY

Submission Description: (doc-less) Motion to Intervene of Michael B Cooper under P-15056-000.

Submission Date:        4/11/2021 5:17:49 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               mbcooper66@yahoo.com                                                             

Basis for Intervening:
This is to request Intervener status on the hydro-electric power station and
dam project proposed by Premium Energy, FERC Docket id P-15056-000.
My property at 99 Dry Brook Road in West Shokan will be directly impacted by the Wittenberg Reservoir since part of that project will be on my land, and more generally my property will be impacted by the installation of power lines, tunnels and dams in the area.

Michael Cooper
FERC ID #F650311

Submission Description: (doc-less) Motion to Intervene of Linda L Werner under P-15056-000.

Submission Date:        4/10/2021 3:26:00 PM

Filed Date:             4/12/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               nohydro50@gmail.com                                                              

Basis for Intervening:
Please allow this to serve as my request for Intervenor status. I am a land owner in the Catskill Park. These are highly protected lands. My concerns should this project go forward, in addition to the legalities of it being on state park land, revolve around the adverse effects on my well water, on our rare and endangered species, and on our trout waters. 

I have no confidence in Premier Energy's ability to construct a dam when they are unable to even see to the detail of getting the name of our town right in their proposal for a preliminary permit. I fear for our safety.

Thank you,
Linda L. Werner
50 Weber Lane
Olivebridge, NY 12461
(856)657-6467

Severin Winter, Woodstock, NY.
I object to the development of a hydroelectric facility in the Ashokan reservoir area in the Catskills. 
There is no need for antiquated technology to provide energy. There are enough green options that do not necessitate  the destruction of the natural environment and force the displacement of residents. 
It is paramount that we preserve the natural resources and environment in this region. 
There are enough social and environmental emergencies driving an influx of displaced people in the area. We need to think of low impact environmental solutions that are sustainable over the long term. 
I do not support the project proposed by Premium Energy Holdings and request that local and regional authorities tasked with the preservation and protection of our parks and reserves refute the science behind this attempt at commercialization of our beautiful and pristine region and stop this development.

Severin

Michael Birnbaum, Bearsville, NY.
I am opposed to this proposal.
DO NOT DISTURB our lands. 
Taxpayer in Woodstock and Saugerties NY.

Rachel Arnold, Pleasantville, NY.
I am strongly against the proposed dam. The Catskills are a State Preserve protected by the NY State Constitution. The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails. The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.  The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Christa Perfit, Woodstock, NY.
As a local resident I am very concerned about this proposed project and do not want to see it go forward. The environmental impact will be devastating. Please do not approve!

Christopher Ernst, Boiceville, NY.
The construction process & harmful alterations thereafter made to the local environment by this proposed Project will forever have a negative impact on these natural mountains that the Ernst family has loved throughout generations past, current, and certainly of the future.  This proposal for the Ashokan Pumped Storage Project must not proceed.

RICHARD ALAN RADEL, GANSEVOORT, NY.
To Whom it  May Concern, 

This letter is written as response to the preliminary applicated entitled the Ashokan Pumped Storage Project.  I Grew up In the Town of Olive, ( Ashokan ) and have enjoyed the State Forest Preserve for recreational pursuits, Hunting, Hiking , Mountain Biking , Back packing, and fishing.  I Have experienced the expansive growth of the Town of Olive and surrounding communities. We have had unprecedented weather extremes over the past 2 decades which has affected the flora and Fauna. We have seen floods, and fluctuations in the water level in the fabled Esopus Creek. I am vehemently against this proposal as it will adversely affect the local community and the aesthetic beauty of the Catskills. The native brook trout, Rainbow trout and Brown trout will be affected with the fluctuation of water levels and water temperature. Conversely, the upper or west basin would also be affected, and the topography changed. The local infrastructure cannot support the heavy equipment that is needed for construction. Let us not let history repeat itself. Let us review the New York Public Library digital collections articles regarding the Catskill Aqueduct . In 1905, the New York State Legislature established the Board of Water Supply (BWS) and imbued the Board with significant power to dictate land use, seize land through eminent domain, and realize a massive expansion of the New York City water supply.  This will happen again for the greater good of New York City , not the residents. Let us not forget The  Constitution of the State of New York, 
ARTICLE XIV CONSERVATION
Section 1. The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold, or exchanged, or be taken by any corporation, public or private, nor shall the timber thereon be sold, removed, or destroyed.

This proposal is an effort to circumvent the New York State Constitution as a Living constitution to be manipulated and interpreted by lawyers and politicians who stand to benefit from its construction. This project needs to halt at its inception . 

Respectfully, 

Richard A.Radel
91 Spier Falls Road
Gansevoort, N.Y. 12831

LESLIE A SNOW, Shokan, NY.
It was with horror that I read of the proposed hydroelectric project! This project as would impair our quality of life here beyond repair.

This project would require years of pollution-producing construction, destroying our natural environment. The habitat for our cherished wildlife: our bears, coyotes, deer, and bald eagles, the entire web, would be destroyed. Huge power lines would denigrate irreparably our beautiful mountain and reservoir views. Our ability to hike the wilderness freely would be blocked. This is Catskill Park!

In short, all the reasons that we live here would be destroyed and altered beyond recognition. We have other, safer, less destructive, more decentralized ways to generate more electricity, such as rooftop solar panels.

I am committed to fighting this proposal tooth and nail, and encourage my neighbors to fight it also. We will be united against this.

Thank you.

Melanie Hall, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I have been deeply concerned about the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Melanie Hall

Lisa Hubbard, West Shokan, NY.
I urge you to decline Premium Energy Holdings application for an add-on hydroelectric plant (FERC project and sub- docket number: P-15056:000). This proposal is hastily thrown together by a small business interest that seems to be throwing out as many hydro plant proposals as possible, with little or no preparation or research into the lands affected.

Premium Energy Holdings has misrepresented this project as a closed-loop system, presumably in an effort to qualify for streamlined FERC approval. In reality, this proposal includes the construction of a new dammed reservoir and tunnels, making it an add-on system. Closed-loop projects are considered by FERC to have a lower environmental impact. This misrepresentation downplays the environmental impact of the project. 

This project would be constructed within the Catskills Forest Preserve. The preserve was created in 1885 in Ulster County through Article XIV of the NYS Constitution. The state constitution requires that this land "be forever kept as wild forest lands”. Such lands shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any hydroelectric plant built on these lands would require a change to the NYS Constitution, voted on by two consecutive sessions in the state legislature, and submitted to the public in a referendum. Such amendments rarely pass, and, as this is in highly preserved land, this may be fiercely opposed by the public. 

Additionally, lands in the State Forest Preserve in the Catskills are considered Status 1 under USGS “Gap Analysis Program”. According to the Dept. of Energy's Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development”.

All three areas proposed here are within Audubon Society's Catskill Peaks Important Bird Area. Additionally, rapid fluctuations in water and changes in stream sediment would destroy important trout habitat. 
 
At least one town, West Shokan, would have to be relocated for the second time in its history, the first being during the building of the Ashokan Reservoir in 1907-1915. This may be an impressive force in galvanizing public opinion against the project.

Premium Energy seems to have thrown this together with no awareness of the specific area and little or no research.

Ann T Tortorelli, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
 
Dear Ms. Bose,
 
As a resident and long-term property owner in Woodland Valley in the Town of Shandaken, I strongly object to Premium Energy Holding’s proposal and request that the Federal Energy Regulatory Commission deny their application for a preliminary permit. 
 
My family’s home valley is under proposed consideration as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and the generation of electricity.  
 
The proposed project is an unprecedented large-scale disruption to the Catskill Forest Preserve, will undermine the tax base to the area and will effect the public drinking water system to the New York City metropolitan area. How can a project of this  magnitude safely address the mandates set forth by New York’s Department of Conservation to protect the water quality in our area? 
 
Our country’s transition to renewable, green-energy sources cannot come at the cost of environmental and community devastation.  I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project where the construction and operation do not destroy protected wilderness, displace thriving communities, and threaten the Catskill’s unique natural resources.  Please do everything in your power to prevent the Ashokan Pumped Storage Project proposal, docket number P-15056-000 from moving forward. 

Sincerely,
Ann Tortorelli

Alison Goudreault, Phoenicia, NY.
The role of renewable energy must be to supply the needs of a modern civilization while supporting the natural systems of the earth that sustains us. This requires equally also, a stewardship of land that holds some of the last pristine natural resources that are critical to organized life on our planet. Water, Forest, and Habitat CANNOT be lost at the expense of building renewable energy infrastructure, it would be completely counter to the initiative as a whole. I live on a stream in the Catskills, it serves an integral purpose from the moment it rushes out of the ground on the side of Panther Mountain, it is sometimes a raging torrent, sometimes a trickle. It cannot be held by man-made earthworks without a devastating outcome. Mergansers and Herons nest and rear their young, trout spawn and travel down to the Esopus. Over the years we have participated in NYS programs for restoring and protecting our riparian area with plantings of native trees, and we tend carefully and consciously to our space along it. We also maintain a vacation rental cabin on our property, so we understand the ecosystem of people as well as the mountain around here – all of the Catskills serves as a nature retreat for the city of New York in a long standing relationship – providing clean water and a much needed connection to nature, while supporting the communities and businesses that live here year round. Hydroelectric power, although a critical component to a future that moves us from the terminal outlook of fossil fuel dependency, DOES NOT belong in this important Protected  Nature Preserve. 
Thank you for your time.

tt, amsterdam, NY.
o A Highly Preserved Land
▪ The Catskills Forest Preserve created in 1885 in Ulster County 
▪ Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild 
forest lands. They shall not be leased, sold or exchanged, or be taken by any 
corporation, public or private.” 
▪ The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly 
fragmented environment; the forest around the proposed sites ranks among the 
top 1% of forest habitats region-wide according to the New York State Forest 
Condition Index. 
▪ All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: 
see https:// www.audubon.org/important-bird-areas/catskills-peaks-area 
▪ KEY POINT: As a State Forest Preserve, the Catskills are considered Status 1 land 
under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own 
Hydropower Vision, “areas with formal protections designated as Status 1 or 2 
under the USGS Gap Analysis Program are avoided for development.”
▪ According to The Catskill Park: Inside the Blue Line-Changes to land management 
in the State Forest Preserves must be passed by constitutional amendment, 
voted on by two consecutive sessions in the state legislature, then submitted to 
the public in a referendum 
• Impacts on Stream Ecology
▪ Pumped storage upper reservoirs are subject to rapid fluctuations of water 
which wreak havoc on both aquatic and land habitats ▪ Altering the sediment regime in tributaries to the Esopus will alter the sediment 
regime in the Esopus, one of the Catskills’ most vital trout waters and part of the 
NYC water supply 
▪ Valuable trout breeding habitat would be lost
• Impacts to NYC water supply 
o According to the DEP-Provides 40% of NYC’s water, a water supply that provides 1 billion 
gallons a day to 9.5 million people 
o The largest unfiltered water supply in the nation, built at the cost of displacing 25 
communities 
o A NYC valuable capital asset, representing billions of dollars of investment; $1.7 billion 
since the 1990s alone 
o Meets current NYC needs, but climate change produces uncertainty about its future 
ability to do so: evaporation, heat events, and decreasing snowpack. 
• Impacts on Catskills tourism economy 
o Tourism is an integral part of the NYS economy and continues to grow 
o Tourism generated 17% of employment in the Catskill region in 2019 
o A $1.6 billion industry in the region, supporting roughly 20,000 jobs 
o Ulster County represents 43% of that market 
o Second homes generate $360 million in economic activity 
▪ Source: Tourism Economics, “Economic Impact of Tourism in NY, 2019”
• This is not the innovation that Department of Energy would want
o Closed-loop projects are considered to have smaller environmental impact and are thus 
eligible for streamlined FERC approval; that’s why Premium is claiming to be “closedloop.” 
o • Projects where an upper reservoir is added to an existing lower reservoir are known as 
“add-on” projects; that’s what this really is. They are lying. 
o • “Initial construction impacts” for these projects are lower, but “operational impacts are 
still likely to be higher than for a closed-loop project because the addon project’s lower 
reservoir is still continuously connected to, and may affect, the natural flowing water 
feature that was dammed for its original construction.”
▪ Source: DoE: “A Comparison of the Env. Effects of Open Loop and Closed-Loop 
Pumped Storage Hydropower.” April 2020

amy farges, Chichester, NY.
Please register our strong opposition to the proposed Ashokan Pumped Storage Project.

Rachel Wolff, Minneapolis, MN.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Rachel Wolff

Genie Tillisch, Haines Falls, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. It would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs.

Premium Energy is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, especially since the lower reservoir is a vital source of drinking water for our nation’s largest city.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Genie Tillisch

Matthew Raue, Elizaville, NY.
The proposed hydropower project in the Catskills can not move forward. It is hard to list the number of ways in which the costs do not justify the potential rewards. Catskill ravines, mountains, waterways and ecosystems are not renewable, in fact they are extremely finite. 

Clean energy storage is important but especially in the Catskills all efforts must be taken to preserve the far more valuable resource of the natural landscape and ecosystem itself. This stands over and above the obvious benefit that the Catskill region receives from stewarding and lightly exploiting this magnificent landscape. All this beside the risks to the NYC water supply, which is easily one of the most precious water supply systems in the world, and which we are so lucky to have. 

Sincerely,
Matt Raue

Ken M, NY, NY.
Hello,

I’m writing as a visitor to this amazing area, and a student who recently completed a water governance course taught at Columbia University. The studies remain inconclusive about the positive contributions of hydroelectic dams (across the globe), let alone when you factor in the harm done to neighboring communities displaced as a result of their build.

What remains true (and our Professor studied at NASA) is that power and democracy must be fairly introduced when it comes to ensuring due process plays out in accordance with current governance requirements. The relationship between society and water is complex, and its critical to our enjoyment and livelihoods.

Integrated water resource management requires deep understanding, and as an avid hiker and visitor to this particular area, I’m appalled that you believe your corporation is better equipped to steward the lands than 1) the original stewardship laws put in place 2) the stakeholders who reside in and around this area.

Please reconsider your decision and the irreparable harm it stands to have. In your rush for business objectives, think beyond the short term and understand that nature knows best. Not your private (less than transparent about process ) pockets.

Do what is right for future generations. Leave Ashokan alone.

Garry Kvistad, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

mary redlich, boiceville, NY.
We are responding to the information regarding the Ashokan Pump Storage Project-  We are strongly opposed to initiating a system that would put high tension lines from Olive to Hurley-  this area is known for its peacefulness and beauty and to rip a corridor thru the woods for a non needed purpose makes no sense.   We have lived here for MANY years and have never felt that we were short electricity  - we have never even had an outage that had lasted for any concern able amount of time.  If people cant go without power for short periods of time - maybe they should move to a more populated area .   This proposal also can affect what limited resources we have in this area-  people come to drive, hike and bike throughout the region-  imagine driving up 28 and turn to look at the mountains and see a trail of metal monsters instead - if you want continue to destroy California-  you are more than welcome to go back there.

James Pellitteri, Jewett, NY.


Federal Energy Regulatory Commission					April 12, 2021
888 First Street, NE. Room 1-A
Washington, DC  20426

ATT: Kimberly D. Bose, Secretary to the Commission
RE: The proposed Ashokan Reservoir Pumped Storage and Hydro-electric Project
        Docket P-15056

Dear Commissioners:
 
The Town of Jewett, NY strongly objects to the project to possibly create a dam in Stony Clove Notch on Route 214 in Greene and Ulster County for the following reasons.

•	It is not practical that Premium Energy would be able to secure property rights for exploration or development, especially on lands owned by NYCDEP and the NYS constitutionally protected Catskill Park Forest Preserve, which prevents any development public or private for the greater public good.  The applicant should prove it could get the authorizations necessary to proceed before granting a preliminary permit.
•	The geology of the region is challenged by turbidity during flood events, resulting in water quality impairment from suspended clay soils which can last for days or weeks depending on the magnitude of the flood event.  The project would significantly disturb the Ashokan reservoir system on which NYCDEP relies to provide high quality drinking water to approximately 9 million residents.
•	The environmental impacts would be overwhelming to the landscape, wildlife and aquatic resources.  The applicant should prove first the workability of this project given the substantive comments submitted to the Commission. 
•	The application was poorly put together, with minimal information.  That should be an indication the applicant did not know about or care to research the challenges it would be up against proposing the project in this highly sensitive, protected region of NYS. 
•	One of the proposed reservoir locations is in Lanesville, the Town of Hunter, Greene County.  We support the Town of Hunter in decrying what that would do to the hamlet of Lanesville, through which a NYS-designated scenic byway runs (State Route 214).
•	The Mountaintop which consists of the towns of Hunter, Jewett, Lexington, Prattsville is almost entirely a tourist economy.  The only roads used to reach us from downstate New York and New Jersey are Route 214 and Route 23A.  Route 23A is a winding mountain road with little space for the road between a steep hill and a steep drop to Kaaterskill Creek. It’s not unusual for the 23A to be closed for weeks at a time for repairs. 

 
Thank you for your attention.
Yours truly,
James Pellitteri, Jewett Town Supervisor 
518-263-4646 Ext 2 
3547 Route 23C 
PO Box 132 
Jewett, NY 1244

Richard Hall, Olivebridge, NY.
April 12, 2021

To:
Ms. Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains - a state preserve protected by the NY State Constitution.
I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Richard Hall

248 Weber Lane
Olivebridge, NY 12461
tel 917-821-5811
richard@richardhall.com

Tonia Waterbury, Accord, NY.
We all understand the need for electrical power infrastructure, and most of us see the imperative to replace fossil fuels, but must ask At what cost?  The Catskills Park is a critical watershed, a recreation area, and a protected ecological and scenic reserve. Because the proposed pumped storage project will adversely affect this essential watershed and forest preserve, I submit that the cost is too high. Please deny this request by Premium Energy for a preliminary permit. 

In considering this project, FERC is being asked to bargain with dangerous trade-offs – electricity vs. water safety and security; electricity vs. a vitally important tourism economy. 

Concerns about Water - 
The Ashokan Reservoir System is fed into by the Schoharie Reservoir and Esopus Creek. It is the largest unfiltered water supply in the nation. The Ashokan supplies 40% of New York City water to some 19 million people. With this proposed pumped storage project:
-	The turbidity of the Reservoir is likely to increase, impacting the quality of the water
-	Sediment changes in tributaries to the Esopus will alter sediment in the Esopus proper as well as the Ashokan Reservoir because they are all connected; *this is not a closed-loop project 

Economic Concern -
Catskill Tourism is integral to the New York State economy.
-      Tourism is a $1.6 billion industry supporting ca 20,000 jobs
-      Tourism generated 17% of employment in the Catskill region in 2019 (and is
                     growing)
 Earth-moving blastings/construction trucks and noise, will be destructive to habitats, jarring to the peace and beauty of the natural environment, thereby eating away at what makes the Catskills desirable and therefore a place people want to visit, live and work.

As residents -- whether new, multi-generational, or part-time with second homes outside of New York City, of all ages, incomes, political persuasions, etc. – we are joining together with our elected officials and civic/environmental organizations to prevent this harmful project. We understand that any changes in our State Forest Preserve must be passed by constitutional amendment voted on by two consecutive sessions of the NY State Legislature, and submitted to the public in a referendum. We stand committed to see this battle through, as long as the legal, legislative and lobbying actions may take, but we hope and pray that FERC will join us now in rejecting project P-15056 at an early stage, before years of great cost, litigation and angst. 

Thank you for your careful consideration of this urgent matter.

Sincerely,
Tonia Waterbury

Malcolm Grant, Olivebridge, NY.
FERC should deny this permit for the Premium Energy Holdings, LLC Ashokan PSP.  

This project would flood NYS constitutionally protected forest preserve land.  This land has very high conservation value due to the large intact forest tracts in the area, and would require a change to the New York State constitution to allow this project.  

This project is not a closed loop system as Premium Energy claims incorrectly in their application.  This is not the type of project that DOE is looking for.
This project would also require a renegotiation of the EPA's Filtration avoidance determination that the New York City drinking water supply is currently operating under. 

Michael Kauffman, pine hill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Michael Kauffman

Karla Kretschmannova, Westwood, NJ.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
This is a text I can wholeheartedly sign. Speaking for myself: ?!?! A company from CA, that is facing similar strenuous opposition for their ill-thought projects in other states (NV, CA) wants to build similar ill-thought project in protected/preserved land in NY?! Asking for a permit behind the backs of people whose property, their homes and land, would be seized by eminent domain and flooded?! Threatening supply of drinking water for almost 10 million people in NYC?! Ruining the ecology of the Ashokan watershed?! And what for? So, some already rich investors can get richer out of that!!!

Camille Alma, BAYSIDE HILLS, NY.
April 12, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to request that the Federal Energy Regulatory Commission (FERC) completely reject the application for a preliminary permit by Premium Energy for their Ashokan Pumped Storage Project P-15056.  

The Catskills are a State Preserve protected by Article XIV, Section 1, of the New York State Constitution, “…shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private...”.

In addition, the Catskills Park State Forest Preserve has been designated by the US Geological Survey as Status 1 land. Section 3.3.4 of the Hydropower Environmental Considerations of the US Department of Energy’s Hydropower Vision Report explicitly states that protected lands - areas with formal protections designated as Status 1 or 2 under the U.S. Geological Survey’s Gap Analysis Program 10 - are avoided for development. 

Lastly, the project is identified as being a closed-loop project. However, the project is adding an upper reservoir to an existing lower reservoir, which is in fact an open-loop or “add-on” project. Outflow from the proposed 216-acre reservoir would raise and lower an open system of protected water that nine million New Yorkers depend on for their water. The Department of Energy’s April 2020 report, A Comparison of the Environmental Effects of Open-Loop and Closed-Loop Pumped Storage Hydropower, compared the potential environmental effects of constructing and operating open loop and closed-loop pumped storage hydropower projects and concluded that  “…the impacts of project operations would still likely be higher than for closed-loop because the add-on project’s lower reservoir is still continuously connected to and affects a naturally flowing water feature.”  

Based on the above, I strongly request that FERC deny Premium Energy’s Pumped Storage Project application for the Ashokan Reservoir.  

Respectfully,
Camille Alma

Chloe Metz, Phoenicia, NY.
I am writing to express concern over the application by Premium Energy to construct a hydroelectric dam on the Ashokan reservoir. This is an extremely sensitive area from an ecological standpoint - home to trout and bald eagles. The Ashokan reservoir is also one of the primary sources of drinking water for New York City. Construction of this project would lead to changes in habitat and an increase turbidity that would have an extremely negative impact on the animals and humans who rely on these pristine waters.

Additionally, the proposed location on the Stony Clove Creek would disrupt commerce and tourism which is critical to the area's economic health. Route 214 connects the towns of Phoenicia and Hunter/Tannersville. It provides access to ski resorts, hiking trails, grocery and hardware stores, gas stations, etc. It is one of the few roads in this area and is well traveled. It is also a scenic byway and goes through some of the most sensitive and protected land in the state. Rerouting, closure, changes to the scenery would all have negative impacts on the beauty, ecology and the economy of the area.

I ask that you please reject the application for this permit. Thank you, Chloe Metz

Maureen Hirschfield, West Shokan, NY.
 I am writing in response to the permit that Premium energy has requested for a study on a proposed pumped storage hydro plant.

Building the kind of plant that Premium has proposed continues the methodology of the past- build a huge monolith that displaces people and wildlife- some endangered- from their homes.

We have learned form the past that intruding on wildlife areas has caused endangerment of the species that inhabit those areas; the American Eagle, already endangered, inhabits the areas that Premium is targeting
  
The building of the Ashokan Reservoir at the turn of the century in order to provide water to New York City inhabitants, displaced residents from generational homes. Why we we consider a project that would do this again?


I am in full support of the development of clean alternative renewable energy sources.

Why not encourage the development of energy on a smaller, non invasive platform? New technologies and methods would have to be developed- but isn't that we Americans do best? Innovate?

Please fell free to contact me directly with any questions or comments.

Thank you,
Maureen d. Hirschfield

Rosemary Young, Olivebridge, NY.
April 12, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Projects such as these should seek out towns/counties that would be eager to have this type of proposal in their communities instead of trying to find affordable venues to turn a profit for their investors.
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Rosemary Young

Rudy Hunter, Olivebridge, NY.
I'm a 28 year resident and taxpayer in Olive and object wholeheartedly to the proposed Ashokan Pumped Storage Project.  It will drastically diminish water quality, raise temperature in our water to kill fish, add horrible and health-diminishing high voltage transmission lines and a flurry of other things which will RUIN the beauty and water safety in the Hudson Valley where I live, play and enjoy my life...and where I pay taxes.  I object strongly to the entire project.
Rudy Hunter

Jenny Lynn McNutt, Brooklyn, NY.
To Whom It May Concern:

Sharing my concerns and Objections to the proposed project of the Ashokan Pumped Storage Project in the Catskill Mountains.

Sustainable energy is important more than ever but so is preservation of NYC and regions drinking water.
The preservation of many endangered species, recreational use of waterways and livelihoods of residents in the Catskills
are also at stake with this extraordinarily disruptive project.

In the strongest way I object to this project and the harm that it would cause so many in the region and beyond. 

Sincerely,
Jenny Lynn McNutt

Roman Pietrs, PHOENICIA, NY.
I am writing to oppose the Premium Energy project in the Catskills.  

My family lives in Woodland Valley right in the center of one of the proposed damns which makes my objection to this project slightly more personal.  We love the beauty and the peace of this area.  My daughter would just soon look for eagles than look at her ipad.  The water in the Catskills is one of its greatest resources and not to be tampered with.  Most of us rely on well water as our drinking water and spend countless hours on the many waterways here enjoying nature in all its splendor.  Catskills Park has always been a refuge for those seeking a break from their busy city lives - never more so than this last year during the pandemic.  It would be so sad to see this protected area be exploited for profit and set a scary precedence for  other protected areas like it.  Thank you.

Lyle Lange, Annandale, NJ.

April 12, 2021

RE: docket P-15056


As my family owns land in the Catskills and enjoys using and supporting the Catskill region’s Outdoor activities and its communities,

We oppose the “Premium Energy Holdings” of Southern California for a large and poorly designed “pumped storage” project that would effect existing Ashokan Reservoir and its surroundings.

* The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

* The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

* The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

* The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

* This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.

* The loss of tourist dollars and business revenue would directly hurt our communities.

* The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.


Sincerely,


Lyle and Luanne Lange
107 Sidney Road
Annandale, NJ 08801

Katie Bull, Kingston, NY.
(Docket # P-15056)


Ms. Kimberly Bose, Secretary 
Federal Energy Regulatory Commission 
888 First Street 
NE Washington DC 20426 

RE: MOTION TO INTERVENE: Docket # P-15056 - Ashokan Pumped Storage Project Dear 

Secretary Bose: 

I would like to comment on Docket # P-15056 . The person to whom communication should be addressed is Katie Bull, 891 Ashokan Rd, Kingston, NY 12401, katiebullvox@gmail.com, 917-754-2990.

 I live on a mountain in Lomontville within 15 miles of the Ashokan Reservoir and within 15 miles of the proposed alternative sites for the Ashokan Pumped Storage Project’s Upper Reservoir and other towns and cities served by the Ashokan Reservoir as a source of drinking water. And while I recognize that hydro storage can be environmentally useful, the question is *where is as pumped storage project least ecologically damaging?* The proximity of this proposed project to small towns, recreation and wildlife, is harmful.

Please allow citizen comments and the dialogue with organizations filing motions to intervene, to continue. 

Many Thanks,
Katie Bull

Jeffrey Colgan, Brooklyn, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jeffrey Colgan

Caroline C Emerson, BROOKLYN, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Caroline Emerson

Valeria Gheorghiu, Kerhonkson, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing as a resident within the Ashokan Reservoir neighborhood in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. As an AirBnB host I regularly benefit from good reviews by sending my guests to enjoy the Ashokan Reservoir rail trails and even fishing in the Woodland Valley stream, both of which will be impacted negatively by this project. 

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Valeria A. Gheorghiu, Esq.

Max Owen-Dunow, Brooklyn, NY.
To Whom it May Concern:

I am writing to express my opposition, in the strongest possible terms, to Premium Energy Holding’s request for a preliminary permit for their Ashokan Pumped Storage Project P-15056 proposal. I urge FERC to consider the proposal’s harmful environmental impact, disruption of existing communities, and degradation of highly preserved land in a manner that poses economic threat to the Catskills alongside the obvious environmental challenges of such an “add-on” project.

Premium Energy Holding’s proposed use of land within the Catskills Forest Preserve stands in direct contradiction to the terms under which the land is protected in the New York State Constitution. The proposal simply does not meet the requirement that the lands “be forever kept as wild forest lands,” nor does the limited benefit of this add-on project merit the disruption of one of the state’s most important habits for wildlife. The project’s anticipated negative impact on local stream ecology – not to mention the possibility of risks posed to the vital water supply of the Ashokan Reservoir – give further reason for pause.
  
I grew up in the neighboring community of Rhinebeck, NY, and have both fond personal memories of times spent in the area in question, and many family and friends who would be directly impacted by this project, were it to be approved. Premium Energy Holding’s bad-faith representations in their proposal – including the preposterous idea that their proposed construction of an upper reservoir be somehow considered a “closed-loop” project, when it is clearly an “add-on” project – only underscore the threat of turning over these vitally important lands to an unscrupulous outside developer who has already shown willingness to blatantly misrepresent their project in order to ease its acceptance.

I thank you for your time, and for your consideration of this comment, and hope you will heed the numerous community members who stand opposed to this misuse of our beloved forests.

Max Owen-Dunow

marcy t. meiller, phoenicia, NY.
04/12/21
Good morning to you, whom it may concern,

Having served as past Treasurer of the Woodland Community Association for apx.10 years, ending in the year 2013, I have made it a point to educate myself on the Rules and Regulations that govern the Zoning Code of the Town of Shandaken. During my tenure as Treasurer we successfully litigated to halt a proposal to “harvest” water from a spring at the far end of Woodland Valley situated in an R5 designated residential area. So I am familiar with research on water sources, tables, turbidity, etc. In short the drastic effects that can come to pass by the act of moving water from it’s natural course of flow to places where it was never meant to be. In general these effects tend to be disastrous to the environment, as well as the surrounding communities. 
    I could write in great detail of why I believe that the preliminary application proposal sent to FERC by Premium Energy is beyond ABSURD !!!, however I am trusting that FERC will see the deficiencies even in the initial preliminary application proposal and send Premium not only back to the drawing board, but AWAY altogether(wish them into the corn field, for you Twilight Zone aficionados).
I also question whether this application from Premium Energy is valid in any way, since they supposedly have “rescinded” their choices for the three sites that they had initially put forth. Does this not make the application moot at this point? Are they saying “We would like to do something, somewhere, at  some point, and we would like FERC to permit us to study that something, somewhere, but we don’t know what it is that it will be? Again ABSURD !!!
The lack of information and transparency leads me to question what the actual motives hiding behind any of this nonsense really is.
   Should any of this move forward in any way we will muster our ranks and proceed with what-so-ever we must do to protect our beloved Valley and precious water.
I for one (or perhaps one amongst many) am so grateful to the DEP for their very strong stance of condemnation, and the power to back that up.
It is my sincere hope that FERC will heed the words of all who object.
May you live long and prosper, and never want for clean water.
Be Well
Sincerely
Marcy T. Meiller
Past Treasurer- Woodland Community Association
Woodland Valley 
Phoenicia, NY

Matthew A Yanchuk, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,
I am writing this letter in opposition to granting a preliminary permit to Premium Energy Holdings LLC for their proposed project hydroelectric project for the Shokan reservoir in the Catskills forest preserve. There are many reasons for this preliminary permit to be granted but for me the most glaring is the disruption of the watershed of the Ashokan and how their plans would be a detriment to the ecology of the area. It is also a poorly conceived plan for the three proposed dammed reservoir and pumping station which are described as closed loop storage but are actually add on storage facilities. All three proposed sites would impede on water flow to the watershed of the Ashokan reservoir which would greatly affect the water resource of New York City. I hope that you will deny this preliminary permit for this project. 
Thank you 
Matthew A Yanchuk

Gardner Gillespie, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
We are writing in opposition to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. We are part owners of an historic farm at 624 Woodland Valley Road, Phoenicia, NY, which would be covered up and destroyed by Premium Energy’s proposal. We urge FERC to decline its request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
Whatever the value of renewable energy, it makes no sense to sacrifice the Catskill Forest Preserve to achieve results that could be achieved my much less disruptive and efficient means.  Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites rank among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be absurd public policy to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction was complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. 
Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Respectfully submitted,
/s/
Gardner and Antonia Gillespie
624 Woodland Valley Road,
Phoenicia, NY.  12464

Melinda, Saugerties, NY.

To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Melinda Woolsey

Shannon Perrotta, Shokan, NY.
April 12, 2021

To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1AWashington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

This letter is in regards to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Because of detriment to the environment, community and New York City’s drinking water, I hope FERC will decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

I understand and support the benefits of renewable energy; however, the lasting and devastating effects to the surrounding land and wildlife of the Catskills needs to be a priority. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The pumped storage is known to damage wildlife, stream ecology and the surrounding lands.  Local communities are also at risk with Premium Energy’s proposal. The upper reservoirs proposed would lead to people losing their homes. Due to the current housing shortage, community members displaced by the project would have a difficult time finding new homes.

Renewable energy shouldn’t be at the cost of local communities and the their economy environment. I hope Premium Energy will be able to find a better-suited location. The current plan will destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Shannon Perrotta 

Patrick Tarleton, Shokan, NY.
I’d like to voice my opposition to the proposed Ashokan Pumped Storage Project using Hydro Power. The location in which the proposed project is being considered is a beautiful, largely unspoiled area in The Catskill Mountains, within lands supposedly protected by New York’s designation of them as Catskill State Park. We who live here value the natural beauty, the lack of overdevelopment, the clean air, and the flora and fauna. Much of our area’s economy is based on the same things - they are much of the reason tourists from NYC and beyond come here. A project such as this could only harm all of that. Something else to keep in mind is that another project here over a hundred years ago drastically changed the landscape for the worse and negatively affected several towns and displaced thousands of residents - The Ashokan Reservoir. Although in the century since then, people have come to accept and embrace it, pushing another similar (although on a smaller scale) project through here would be a huge mistake, and would be extremely inconsiderate to the residents and others who love this place. Furthermore, the area is a part of the watershed for New York City’s drinking water, and any industrial construction or related traffic could possibly negatively affect the city’s water quality.

Matt McDonagh, Mt. Tremper, NY.
Hi - 
I am writing in firm opposition to Hydropower Station currently being proposed in the 3 locations above the Ashokan Resovoir.  Our friends live on these roads, we hike and use these roads and areas every single day.   

Sincerely,
matt mcdonagh

susan kukle, tannersville, NY.
FERC: Federal Energy Regulatory Commission 
Save Catskill Preserve

Our region of the Catskills is most poignant because THE WORLD learned about us through a fine artist named Thomas Cole. The Hudson River School of Artists followed in his footsteps continuing to illustrate the picturesque clean inspirational landscape.

We must honor and uphold their vision FOREVER as a guide for humans to navigate in the political cultural scene.  I join the comments made by the other organizations and individuals in reference to environmental issues, commercial enterprises and life for the locals, etc.

Our Catskill Park provides a haven and resource of such high value. The scientists and engineers must come up with an alternative energy plan.

I am in opposition to the proposed hydroelectric power generator in the Stony Clove, NY, Catskill Mountains.

Susan Kukle, life long resident
PO Box 473
Tannersville, NY  12485
susankukle@gmail.com

March Gallagher, kingston, NY.
April 12, 2021
Kimberly D. Bose
Secretary Federal Energy Regulatory Commission 
888 First St., NE 
Washington, DC 20426 

RE: COMMENTS on the Application for Preliminary Permit Ashokan Pumped Storage Hydroelectric Project, FERC No. P-15056-000 Esopus Creek, Bush Kill Creek, Ulster County, New York

Dear Ms. Bose:

As the elected fiscal and programmatic watchdog for Ulster County, and on behalf of the 177,000 people of Ulster County, I am writing to request you reject the Application for Preliminary Permit filed with the Federal Energy Regulatory Commission by Premium Energy Holdings, LLC, for the proposed Ashokan Pumped Storage Hydroelectric Project located on Esopus Creek, Bush Kill Creek, and the Ashokan Reservoir in Ulster County, New York.  I urge you to deny the application for the following reasons: 

1)	Federal energy policy should not preempt state conservation goals. The project, proposed for lands conserved for water quality and ecologically sensitive habitat goals, would require taking state and city owned and protected lands.  By its very nature the proposed application pits these public priorities against renewable energy generation goals and sets deleterious precedent that sacrifices invaluable public resources necessary for the planetary and human health. In the Catskills region, the conservation water quality and ecological protection goals are constitutionally protected and should not be preempted by federal energy policy. 

2)	The project would jeopardize the water quality for nine million residents of the metropolitan New York City region (including residents of Ulster County both on the aqueduct and drawing from surface waters downstream from the Ashokan). The Ashokan Reservoir, part of the Catskill water supply system has been providing water since 1915 and is part of the largest unfiltered fresh water supply system in the country. The fundamental monetary value of this irreplaceable water supply infrastructure to the City of New York, the State of New York or the United States of America cannot be quantified. The project would severely impact water quality by increasing the turbidity of the water not only during construction but through ongoing operations which will continue to create new sediment load and resuspend existing sediment in the system on a continuous basis.

3)	Significant ecological resources should be protected. The Catskill Park and the Catskill Forest Preserve, a combination of public and private protected lands, serves as irreplicable, contiguous ecological habitat and unfragmented forest lands. Not only does the region provide critical habitat, carbon sequestration, and natural water supply filtration, the Catskill Park also serves as proximate recreational and environmental resource for the greater New York City metropolitan region. 

For all the reasons briefly described here, I respectfully urge the Federal Energy Regulatory Commission to deny the application of Premium Energy Holdings. Thank you for the opportunity to comment.
Sincerely,
 
March S. Gallagher, Esq.
Ulster County Comptroller

Henry F Ayres, Tannersville, NY.
Mr. Bruce Johnson, President, & Dr. Caryl Clark, Director of Heritage
The Onteora Club
5 Minwawa Road
PO Box 546
Tannersville, NY 12485

To: FERC representatives:	

Re: FERC project and sub-docket number: P-15056-000 

We are writing on behalf of the Board of Directors of the Onteora Club to register our opposition to the proposed Premium Energy Ashokan Pumped Storage Plan. We have carefully reviewed the Plan to create a pumped storage hydroelectric plant on the Ashokan Reservoir. We have concluded that it is flawed and ill-conceived, and that it contains much misinformation. 

Premium Energy state they’re proposing a closed-loop system. What they propose, however, is an add-on system. The proposal is very misleading on this point, which suggests other inaccuracies. The Ashokan Reservoir, which is divided into an upper and lower reservoir as part of its filtration system for New York City’s water, is fed by the Schoharie Reservoir and the Esopus Creek. Far from being a closed system, this interconnected water system functions efficiently as a flow-through system to supply nearly half of the City’s water supply. The potential for this development to interfere with New York City’s filtration system and famously clean water supply is very high. The reservoir and surrounding area also support important fish and wildlife habitats, which are important to our entire membership as well as the surrounding communities. To interrupt this delicate balance would wreak havoc on the habitats of many protected species. 

The Catskills Forest Preserve, within which the historic Onteora Club resides, was created in 1885 to support and maintain the pristine forest growth and wildlife habitat of the region. As Status 1 lands under the United States Geological Survey, the Catskills Forest Preserve are protected and meant to be defended to the fullest extent possible from significant development. An upper reservoir on any one of the three proposed sites would have a devasting ecological impact, destroying trout streams and spawning areas, and causing considerable and unnecessary damage to one of the most important natural environments in the state. It would also compromise the environmentally-minded tourism industry that provides a vital source of local employment in a part of the state with few other options. 

Although we support the objective to create more renewable power, we urge you to decline this particular application, and explore other less vulnerable sites. Premium Energy’s plan should not be allowed to advance further. 

Thank you for your consideration.						 

Bruce Johnson						Caryl Clark

Brigid Walsh, Saugerties, NY.
To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
 
Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.   As landowners downstream from the Ashokan Reservoir, and as a member of community already suffering from the turbid waters released through our water ways, we take our environmental stewardship of the area very seriously for the next generations of wildlife and people to enjoy.  I am part of a large and engaged community and I urge FERC to decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 based on the following reasons:
1.)  NOT CLOSED LOOP -The application is sloppy and flawed in it’s local references and assertion of being a “closed loop system” when it is an “add on” system.
2.)  BIRDS-All proposed reservoirs are within the Audubon NY Catskill Peaks Forest Important Bird Area (IBA).  If you have ever heard the flute song of a Forrest Thrush, you would defend it’s habitat from development without question or hesitation. https://ny.audubon.org/conservation/catskill-peaks-forest
3.)  TROUT -The system’s environmental impact on the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir.
4.)  DRINKING WATER - The system’s impact on turbidity levels of the Ashokan Reservoir which supplies both local and 40% of NYC’s water, serving 1 billion gallons of water a day to 9.5 million people.  The proposal threatens this valuable asset, which holds the distinction of being the largest unfiltered water supply in the nation.
5.)  PRESERVED LAND -The three sites for the proposed reservoirs and tunnels are on highly protected land of the Catskills Forrest Preserve created in 1885 under Article XIV of the NYS Constitution “shall be forever wild… not be leased, sold or exchanged, or be taken by any corporation, public or private.”
6.)  PROTECTED LAND -The Catskill Forrest Preserve is considered Status 2 land under the USGS “Gap Analysis Program.” According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."
7.)  CONTINUOUS HABITAT - The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare) and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
8.)  COMMUNITY DISPLACEMENT, AGAIN- Premium Energy’s proposal would be devastating to local communities as it would require the seizing of homes and private property via eminent domain—a process whose scars are still felt here from when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would be unable to secure new housing, as there is currently a severe housing shortage in Ulster County. 
9.)  TOURISM – The proposal would negatively impact the Catskills’ growing tourism economy, which generated 17% of employment in the region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty  and otherwise industrialize the region, negatively affecting businesses in Ulster County and beyond.
 
As a last point to make in opposition, the irony must be pointed out that the solution to fossil fuels and extractive energy methods should not be to usher in a new environmentally damaging system! Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—using innovation where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
 
Please deny Premium Energy’s proposal for a preliminary permit for the 
Ashokan Pumped Storage Project P-15056.
 
Sincerely,


Brigid Walsh
& Ed Gerrard Himberger

Jerry Gallo, Shandaken, NY.
April 12, 2021

To:  FERC
Re:  Docket #P-15056 – 000 / Premium Energy Holdings, LLC Proposal for the Ashokan Pumped Storage Project

I am writing to voice my opposition to the Premium Energy Holdings, LLC Proposal for the Ashokan Pumped Storage Project (docket #P-15056-000.
This project would likely affect the 9.5 million residents of NY City as well as many Hudson Valley communities that rely on its drinking water.  Also, the project has significant implications on the health of the Esopus Creek and the communities on its banks. It will compromise the Catskills, running roughshod over our forests and wildlife.
Per my comments above this project seems ill conceived and must be stopped – now.
I appreciate your consideration and understanding regards my concern and opposition to this project.

Sincerely,
Jerry
Jerry Gallo
196 Route 42
Shandaken NY 12480
jerrydgallo@gmail.com

Nick Alba, Boulder, CO.
This is an ill-conceived proposal that is prohibited under the New York State Constitution and federal law.  Its implementation would be quite obviously destructive to thousands of acres of natural habitat, rob families from their homes, and very likely be detrimental to the public infrastructure and drinking water quality for the City of New York.  The benefits of this proposed hydroelectric project are infinitesimal when compared to the clear risks of irreversible damage to pristine lands that are called home by people and wildlife alike.  It should be given no further consideration as it is not at all feasible or beneficial to any party other than the applicant itself.

Monica Savits, North Miami, FL.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Monica Savits

Susan Ploch, SOMERSET, NJ.
As a frequent visitor to the Woodland Valley NY area for the past 48 years I would like to let you know that I oppose the application by Premium Energy Holdings to build a pumped-storage hydropower facility in this area.
 
This proposed project would destroy state land and have disastrous effects on the ecology of the Esopus.  The Catskills Forest Preserve was created in 1885 in Ulster County, and according to the NYS Constitution the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Premium’s permit is requesting access to these lands.
 
I vehemently object to Premium Energy Holding’s proposal and ask that you, the Federal Energy Regulatory Commission reject their preliminary permit.
 
Thank you.

Ailsa Wong, New York, NY.
April 12, 2021

Secretary Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE Room 1A
Washington, D.C. 20426

Re: FERC project number P-15056-000

Dear Secretary Bose:

I am writing regarding the proposal by Premium Energy Holdings, LLC to build a hydro-powered pumped energy storage facility using the Ashokan Reservoir as the lower reservoir, with one of three potential sites in the surrounding area to be used as the upper reservoir.

While Premium Energy's written proposal holds a number of flaws and incorrect information that warrant a rejection of their request for a preliminary permit, the most egregious is the claim that this project is intended to be a CLOSED-LOOP system (preferred by the DOE, according to DOE's own website) when in fact it is an ADD-ON system, which is far more environmentally destructive. Using the Ashokan Reservoir for this project could work only as an ADD-ON system, not CLOSED-LOOP.

The Ashokan reservoir receives water from local creeks and streams, which then gets distributed as drinking water, supplying 40% of the needs of New York City's 9.5 million residents. The city diligently manages and maintains the Ashokan Reservoir to prevent the kicking up of sediment due to turbulence. If this hydro-pumped energy storage facility is allowed to happen, it would be devastating to the local ecology and the quality of New York City's unfiltered drinking water. 

While I am not against using this kind of system (specifically closed-loop) for energy storage, the Ashokan Reservoir is not the place for it. I am urging the Commission to deny Premium Energy a preliminary permit for this project.

Respectfully,

Ailsa Wong

Margaret Neu, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing to oppose the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.  I’ve been a resident of Woodland Valley for 26 years so know first-hand how devastating it would be to destroy our pristine environment with abundant wildlife, a clean beautiful stream, which is an important habitat for trout, and a thriving community.  
The Catskills Forest Preserve is a unique resource because it’s been declared “forever wild” by the NYS Constitution, which states that the land “shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  This ensures clean, untreated drinking water for NYC and 700,000 acres of preserved land that is a treasure for the state of NY.  It would be a crime to destroy this land.
Premium Energy’s proposal demonstrates a complete lack of understanding of the communities and natural resources that would be sacrificed by their project.  While I applaud moving towards more sustainable energy sources, it must be led by companies who are willing to work with and understand the needs of communities.  Premium Energy submitted this proposal without any consultation with local stakeholders and communities, which should disqualify them from any similar pursuit in the NYS or elsewhere.
I respectfully ask that FERC deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Margaret Neu

Jo Panke, Brooklyn, NY.
I am writing in reference to docket number P-15056-000. I urge you to deny Premium Energy's proposal seeking a feasibility study on building a dam in the Catskills, which are a State Preserve and are protected by the New York State Constitution.
As a native of the Catskill Mountains and a current resident of New York City, this proposed project concerns me greatly. The effects that it could have on the drinking water of both the Catskill region and New York City could be devastating, and negatively affect millions of people. 
Furthermore, the impact it could have on the natural ecosystem could be disastrous. The Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s ownHydropower Vision, “areas with formal protections designated as Status 1 or 2under the USGS Gap Analysis Program are avoided for development.” 
The residents of the Catskills and anyone who could be affected by this should, and legally speaking must, have a say in whether a project like this goes forward.
Thank you.

Linda Champanier, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to oppose the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The Catskill Mountains must remain as pristinely protected forests, streams, and wildlife, which must not be sacrificed under any circumstances. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

The project’s proximity to the Ashokan Center in Olivebridge is unacceptable and could have devastating impact. Ashokan’s 385 acres provide a site where over 5,000 school children visit each year for day or residential programs where they experience nature firsthand, and learn about the interconnectedness of life. As a National Historic District, the Ashokan Center property must not be disturbed by projects like this. About 15,000 visitors come to the Ashokan Center each year because they value time in nature. These Ashokan Center visitors contribute to Ulster County’s economic wellbeing by the business they bring to local hotels and restaurants. Tourism generated 17% of employment in the Catskills in 2019, and is a $1.6 billion industry in the region, supporting roughly 20,000 jobs. Ulster County (where the proposed project would be located) represents 43% of that market.

Pumped storage facilities are subject to rapid fluctuations of water and are notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. It would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and the few homes that are available are being sold for exorbitant prices. 
Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

I urge you to do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Linda Champanier

Paula McGinnis, Shandaken, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Paula McGinnis

Adrienne Bolten, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

As a local resident, tax payer, avid hiker, cyclist and lover of all the flora and fauna that is to be found in the Catskills, I oppose this project and ask that you do the same.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Adrienne Bolten MS, RD, LDN

William Smith, Shokan, NY.
Hello.

I am responding/commenting on the proposed Ashokan Pumped Storage Project.  After reading through the entire proposal, a few thoughts came to mind.   First is the obvious environmental impact that, from my talks with people is the obvious reason to oppose the project.  Yet; I like to go further into the topic then just be very generic with a coverall opposition of " the project will impact nature".  

First; nowhere in the proposal did I see the full electrical coverage of the proposed project.  I wonder if the megawatt production is just for current needs, an anticipated need or for supplemental electrical coverage.  I therefore question the validity of the massive impact to the surrounding communities and nature. 
Secondly.; after looking at the three dam proposals; I honestly do not see the reason to create Stony Clove or the Woodland Dam.  If the project DOES goes forward, with the distance to Ashokan Reservoir being so much closer to the proposed Wittenberg Dam, that seems to make the most sense.  Add to the fact of having to create a horizontal tunnel only 2.71 miles long, that is vastly shorter than the other two.  It would also have the least environmental impact I presume.  Also at only 673 acre-ft. less capacity than the Woodland Reservoir and vastly more than Stony Clove; that just adds to the reasons for Wittenberg Dam.  Yet; please note that I am not advocating for the project. 

Lastly; although I have only been a resident of Shokan for 3 and a half years, I have fallen in love with the beauty that the area possesses. People live here to be closer to nature, not next to massive construction, continued destruction and altering of the land and more and more intrusion onto what nature has to offer.  Although Ashokan reservoir was created before anyone here was alive; the irreparable damage, destruction and erasing of entire communities was an act of permanence that can never be undone.  This on top of the permanent alteration of natures landscape.  Add that injury to the insult of all that being done for a city over 120 miles away.  New York City gobbled up even more land.  Yet that is another story.

  My point however poses a very important set of questions/thoughts.  The building of the reservoir in 1915 has had lasting effects for over 105 years.   Most of us just see a beautiful body of water and the nature around it; yet there was a pretty dark past to its inception.  So, I will end with this....

WHAT WILL BE THE LASTING, GENERATIONAL EFFECTS OF THIS PROJECT?  WHO WILL THIS PROJECT BEST SERVE? WILL THE LOCAL COMMUNITIES BE THE ABSOLUTE BENEFACTORS? THEY SHOULD IF IT IS THEIR COMMUNITIES BEING AFFECTED......

Respectfully Submitted,

William Smith

Bridget Leicester, New York, NY.
Please deny the preliminary permit requested by Premium Energy Holdings for the Ashokan Pumped Storage Project in NY's Catskills Mountains.  The project will be damaging to the environment and local communities and risk spoiling the purity of NYC's drinking water.   Thank you.

amit shamir, West Shokan, NY.
I am opposed to the Premium Energys proposed Ashokan pumped storage project.
As a West Shokan home owner local business owner and working musician I would like the Catskill Preserve to remain an attractive destination for people who visit from around the world.
As stated Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

Clearly Premium Energy is not aware that the drinking water of nine million people is at stake!

I urge FERC to not grant this permit. p-15056

Thank you Amit

Jay B. Killin, Phoenicia, NY.
J. Blake Killin
P. O. Box 248 296 Route 214 Phoenicia, NY 12466
Kimberly D. Bose
Federal Energy Regulatory Commission 888 First St. NE
Room 1A
Washington, DC 20426
Docket No. P-15056-000 Dear Ms. Bose,
I am writing to voice my opposition to the proposed Premium Energy Holdings plan to flood our communities to build a hydroelectric power plant. Much of the land that will be flooded is part of the New York State Forest Preserve and is designated as “Forever Wild” per the state Constitution. Per state law, an amendment to the state Constitution requires a vote by those involved and if passed, it will require approval from the State Legislature by two successive votes. That will take at least two, maybe three years so this project cannot be fast-tracked, by law.
This land cannot be taken via eminent domain per the Watershed Memorandum of Agreement of January 21, 1997 with New York City which established land acquisition requirements which set more stringent regulations to those of New York State. Under those requirements, land can only be purchased from willing sellers at fee simple and cannot be acquired by eminent domain. If New York City is obligated to follow these regulations, Premium Energy cannot seize property with the stoke of a pen.
Under the New York State Environmental Quality Review Act, projects such as proposed by Premium Energy must undergo stringent public review. First of all, a “lead agency” must be named to oversee these proceedings. To my knowledge, Premium Energy has not applied for a permit under NYSEQRA, but only through FERC. Some entity like the state Department of Environmental Conservation would have to be appointed as Lead Agency to oversee these required hearings.
Premium Energy will have to prove its project will not have a negative impact on water quality, such as turbidity, siltation and pollution as it will have to dig up this land which contains numerous cesspools and septic systems. Transporting all this demolition debris will have to be done via roads through deep mountain valleys. The applicant will have to prove its actions will not have a negative impact on water quality.
Then there is the issue of destroying some of the nation’s premium trout habitats that attracts hundreds of anglers per year. Flooding these valley’s will destroy wild trout
spawning grounds and have a negative impact on the economic livelihood of the remaining residents of the Catskill Watershed.
Premium Energy has not proven it has explored alternatives to its proposal for the Catskill Watershed such as land in the Adirondack Mountains that is unpopulated or less populated as is required by NYSEQRA. Sure, it would cost Premium Energy more money to use unpopulated land in the Adirondacks but what is the cost to the communities in the Catskill Watershed?
So I ask FEFC to deny a permit to Premium Energy and follow the procedures that are required of everyone in New York State.
J. Blake Killin

Diane Munro, Roxbury, NY.
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Re:  The Ashokan Pumped Storage Project

The Premium Energy Holdings proposal to initiate a hydroelectric project involving the environs of the Ashokan Reservoir is vacant of any consideration of the economic and cultural circumstances of the Western Catskills, let alone the role of the Catskills in supplying abundant, high quality, safe drinking water for residents of New York City. 

My husband and I were born and raised in the region and returned as permanent residents following our retirement. We cherish the natural beauty of the Catskills and are active in hiking, skiing, kayaking, biking, fishing, and hunting pursuits.  Further, the region benefits significantly from the increasing numbers of tourists and second homeowners coming to the Catskills to live and recreate.     

The region faces uncertainty now given increased traffic, the threats of climate change, and a severe housing shortage at times blocking young families from settling here.  Communities are joining together to learn about and plan to mitigate these challenges going forward.  The Premium Energy Holdings proposal appears to stand everything currently underway on its' head! It is not only ill-conceived but demonstrates little recognition of the complex regulatory entities that must be consulted in taking on such initiatives in the Catskills.

While organizations more deeply steeped in technical details of the issues involved are weighing in, I believe it is important that individual citizens speak up when threats necessitate. We respectfully ask that the Federal Energy Regulatory Commission stop this this project in its tracks now.

Thank you for your consideration,
Bill and Diane Munro

Cory Schermerhorn, Troy, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Cory R. Schermerhorn

PS, while the above comment is part of a template being used by many, I just want to say in my own words, that this area has been ravaged enough, after being promised as "forever wild".  First, with the impoundment of rivers for NYC drinking water, then by hurricanes Irene and Sandy.  Please don't allow man to do further damage in the name of "green energy".  There are better ways.  Thank you!

Molly Farrell, Troy, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Molly Farrell

Jennifer Cucchiarella, Tarrytown, NY.
I am absolutely against the Premium Energy Holdings of Southern California's proposed pumped-storage hydroelectric facility within the Catskill Forest Preserve. This proposal is within the boundaries of the Forever Wild lands of the Catskill Forest Preserve and directly threatens the ecological sustainability of the Preserve.  Among many other negative impacts, it would threaten trout breeding grounds, the quality of the NYC water supply, the experience of trail users in the preserve.  This impacts the local landscape, wildlife, plants, and people.  I stand with dozens of nonprofit and environmental groups opposing this project.

Thank you,

Kelsa Trom, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.


From: Kelsa Trom
514 Grand Street
Brooklyn, NY 11211

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the problematic and upsetting proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. The Catskills are extremely special to me as an NY transplant from nature-adjacent San Francisco. My ability to explore nature, take long hikes among Catskill peaks, and travel to a pristine wilderness has a marked effect on my mental health and my ability to live in New York City.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 

Besides, once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Kelsa Trom

Casey Helman, Upper Marlboro, MD.
Comment in Opposition to FERC Docket No. P-15056-000


Regarding Premium Energy’s preliminary permit application affecting my family’s property in Phoenicia, NY, I write in opposition.  Premium Energy (PE) has applied for a pumped storage plant near the Ashokan Reservoir in direct violation of New York State Constitution and the Constitution of the United States regarding protected land of the Catskill Forest Preserve. 

While I understand the need to devise green energy solutions, I do not believe that flooding large portions of multiple protected nature preserves and displacing countless species of great ecological importance is a responsible method.

The Catskill Forest Preserve is part of the largest region of protected wilderness this side of the Mississippi River and the rights of the preserve, enshrined in New York State Constitution Article 14, Section 1 in 1894, prohibit being sold or leased by a public or private corporation.  Additionally, PE also proposes to use land in the Catskill Park area which, though separate from the Catskill Forest Preserve, is protected by state law.  These areas represent habitats for plant and animal species on New York’s “threatened”, “special concern”, or “greatest conservation need” designations, such as the bog orchid and three different hawk species. 

PE faces a costly and uphill legal battle to the construction of this plant that proposes to destroy the ecosystem around it.  The public referendum campaign waged by opposition to this project will undoubtedly point out the potential that the project will meddle with public drinking water in the NY watershed, could cause multiple species of wildlife to become extinct, and would displace thousands of residents in the area.   The legal protective status of this area and the requirements for encroaching on the public land (consecutive legislative sessions and voter referendum) should clearly demonstrate that this is not an acceptable location for this initiative.

Augusta Ogden, Bearsville, NY.
I write in objection to the proposed hydro-electric dam to be built in the Catskill Preserve. As a long-time resident of this area, I think this project would be fatally damaging to our tourism industry, which depends on the natural beauty of our environment. Wildlife would be negatively impacted, with loss of habitat. The disruption of this major construction would be devastating to residents and tourists alike. Not to mention the private homes which would be destroyed in the process – where are these people supposed to go? Please vote to DENY this proposal, which is of no benefit to the people who actually live here and will destroy our way of life.

camilla calhoun, Tarrytown, NY.
To whom it may concern,
I am writing to oppose Premium Energy Holding’s Hydro-Electric Project in The Catskill Preserve. 
I know Olivebridge and the Ashokan Reservoir well, as my mother’s family has been in the area since the 1700s. My grandmother’s home and general store were the first condemned for the building of the Ashokan Reservoir. The residents of the area still recall the pain and sacrifices made by many families being displaced in that fertile valley in the early 1900s.   

Although supportive of renewable energy as the future, the location of this project would subject, yet again, the residents of this valley to yet another painful upheaval caused by eminent domain. The project will increase the turbidity of the unfiltered Ashokan water that millions of residents rely on in New York City.  It will upend the Catskill Preserve’s “forever wild” clause which is designated by our new York state constitution.  

I urge FERC to consider the injustice of this particular location, and that Premium Energy Holding finds another location for their project.
Thank you,
Camilla Calhoun
914 844 6296
111 Grove Street
Tarrytown, NY 10591
Author, A Town Called Olive. 
NYC Watershed Retrospective: A Town Called Olive, by ...
http://www.catskillarchive.com › watershed › olive

Eric Keeling, New Paltz, NY.
Please abandon this proposal. The proposed locations for a new reservoir are in the heart of the Catskills Park, very near or even adjacent to designated wilderness. There are people who live in these valleys, and wildlife that pass through them. There are also water quality concerns for many people who rely on the Ashokan for drinking water.  

I understand the value of pumped storage and its connection to meeting goals for sustainable energy.  But this location is inappropriate. I would much rather see the people of our area take a hard look at reducing their energy demand, than to have the natural and wild areas in our back-country compromised by a another large dam and reservoir.

Sincerely,
Eric Keeling

Anthony Wright, Olivebridge, NY.
As a resident of the town of Olive and a member of the Operating Engineers local 825, I support this project.

Erik Gaull, Cabin John, MD.
Premium Energy’s proposed Ashokan Hydroelectric Pumped Storage project is wholly inappropriate for the Catskills. This project was dreamed up by a small, for-profit energy holding company in California. It was not requested by New York State or New York City – the purported beneficiaries of the project. In fact, both OPPOSE this project.

This project would wreak havoc on the environment (protected public lands in the Catskill Forest Preserve). It would harm wildlife and endangered species in the area, inundate hundreds of homes and lands of great cultural and historical significance, and damage a fragile regional economy that depends on tourism and recreation. The project will require the construction of high-tension power lines that would be a huge visual scar (extending for miles) on the scenic beauty of the area. Additionally, it would jeopardize a major drinking water supply for New York City, necessitating that the City construct a filtration system for its water costing billions of dollars. Finally, because it relies on eminent domain for the taking of hundreds of parcels of private property, the project would transfer the land acquisition costs from Premium Energy to the taxpayers of New York. Considering that neither New York State nor New York City desires this project, this last fact adds insult to injury.

The project purports to produce 800 MW of power, but my understanding is that it will require about 400 MW of power to pump water up to the proposed upper reservoir – meaning that the project will only net about 400 MW of power.

Given all the adverse impacts of this proposed project, coupled with the relatively meager increase in power generation, I urge you to deny the application of Premium Energy Holdings at this early juncture.

Caroline Sinders, New Orleans, LA.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Lastly, as a fan of Ashokan, having lived in New York, it’s a beautiful place that should be preserved. I’ve loved visiting it and friends there and am saddened to hear this area could be flooded and totally disappear. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Caroline Sinders

Thomas Rhindress, High Falls, NY.
Dear Ms. Bose

The premise of Premium Energy Holdings (PEH) proposed pumped storage facility in New York’s Catskill Mountains is to create a sustainable "green" energy storage facility.   Project P-15056 couldn't be further from sustainable.  Habitat destruction in the name of "green" energy is anything but sustainable.  I ask that FERC reject this proposal and not issue a permit for its construction, now or in the future.

In the early 1900s, New York State's Catskill Park Preserve was established by a New York State constitutional decree  All three of PEH's alternate reservoir sites are situated within the Catskill Park's boundaries. Their construction would destroy and inundate 100s of acres of valuable habitat, plus that irreparably altered in constructing the needed electrical lines to move the generated electricity to existing transmission lines.    More than a century ago, the New York State legislature recognized the value of protecting and conserving land and habitat for future generations.  Today scientists in the fields of ecosystem management and climate change know that preserving natural ecosystems is the most efficient protection against further atmospheric warming.  Healthy, unaltered ecosystems store carbon, preventing it from entering the atmosphere, while destroying intact natural areas releases carbon and reduces the absorption capacity.  Severely altering an already legally protected natural area in the name of "sustainable energy" demonstrates Premium Energy Holdings' utter lack of understanding in how to best address our changing energy needs and preventing further climate change.  Protecting lots of nature is the best, easiest, cheapest climate strategy we have.

There are additional problems with Proposal P-15056.  The land and waterways within this area were already seized once by eminent domain in order to build the Ashokan Reservoir .   Approximately 2000 people had their land, homes, and businesses taken and flooded; entire towns were abandoned to the depths of the new reservoir.  Those emotional scars have not healed a century later.  If the pumped storage facility is allowed, more families will be permanently displaced by Premium Energy Holdings.   Should we allow history to repeat itself?   However, now that the Ashokan Reservoir is built, it provides an invaluable service: clean, unfiltered drinking water to 9.5 million people, most of whom live in New York City.  This is made possible by the thousands of acres of preserved forests in the Catskills.  They create a natural filtration system for the precipitation that falls on the slopes of the Catskills before entering the Ashokan Reservoir.   Again, the PEH proposed pumped storage facility puts this drinking water source at high risk with the potential to move unpredictable amounts of water and suspended sediments from the proposed storage reservoir into the Ashokan.  Climate change has already increased the unpredictability and strength of storms that track northward into the Hudson Valley and Catskill region; creating flooding events which require unplanned water releases from reservoirs and bringing increased turbidity to the waters downstream (the Ashokan's drinking water supply). 

Lastly, this past year  - The Year of COVID-19  - has brought The Catskill region back into the spotlight.  People have sought refuge and solace in the outdoors.  Tourism in the region has soared, pumping much needed tourist spending into the local economy.  The region has been rediscovered.   Yet, a company located 3000 miles away, with no connection to the region, want to put this in jeopardy, first scarring the land, then flooding it, destroying vital habitat to unique plants, important bird breeding habitat, and vital spawning grounds for threatened brook trout - a victim of the warming climate PEH claims to be helping.  The Catskills are a gem, to be preserved as "Forever Wild" for all of humanity just like the NY State legislators realized a century ago.  

Please reject the permit application for P-15056-0000. 
Thank you for your time and consideration.
Sincerely, Thomas A. Rhindress

Mateo Belen, KINGSTON, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Mateo Belen

Sean Mack, Albany, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Sean Mack

Andy Laster, Chichester, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I urge you to deny Premium Energy Holdings a preliminary permit to conduct further study on its proposed hydroelectric power plant in the Catskill Mountains.

The Catskill Forest Preserve is not the right site for this project. Under Article XIV of the New York State Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Under the United States Geological Survey’s “Gap Analysis Program,” the Catskills are considered Status 1 land. According to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Furthermore, all three of the sites being considered for construction of an upper reservoir in Premium Energy’s proposal fall within Audubon’s Catskill Peaks Important Bird Areas.  

Pumped storage upper reservoirs are subject to rapid fluctuations of water, which threaten both aquatic and land habitats. Altering the sediment regime in tributaries to the Esopus, such as the Stony Clove, will alter the sediment regime in the Esopus, one of the Catskills most vital trout waters and part of New York City's water supply. 

This project will damage local communities through displacement and negatively impact the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. It will significantly reduce the very small number of swimming sites in the Catskills, which are along the Esopus and Stony Clove.

A broad coalition of concerned citizens and organizations will fight this project tooth and nail, but knocking it out from the start will allow experts to work toward genuine solutions to our energy needs.

Sincerely,

Andy Laster

Elizabeth Fullerton-Dummit, Boiceville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000


Dear Ms. Bose,

I am writing in response to the proposed hydroelectric power plant that the California based company Premium Energy Holdings would like to build in the Catskill Mountains of New York. As a resident of the area, I am urging FERC to unequivocally deny Premium Energy Holdings Company’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The Catskills are a status 1 area with formal protections to prevent such a project as this. Our state preserve contains 700,000 acres of wildlife habitat that is protected by the NY state constitution, and under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The potential environmental threat this project makes to birds, aquatic habitats and the land should be enough to stop this before it starts. And if it is not enough, then please consider the displacement in our community such a project would cause. This area is having an unprecedented interest since the pandemic, so displacing long-time residents would make an already tough housing shortage even worse. Water is sacred, water is life— this is a chant being echoed across this country. There is only one water, and moving forward on a project that could negatively impact the drinking water for more than 18 million residents of New York City can never be considered renewable.  

Our country and state are looking for creative solutions to transition to more renewable energy sources, however the pristine forests, streams, and wildlife of the Catskill Forest Preserve should not be sacrificed in the process. I hope you will encourage Premium Energy to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Elizabeth Fullerton-Dummit

Ilse Pfeifer, New York, NY.
To Secretary Bose -- 

I would like to comment on the MOTION TO INTERVENE Docket # P-15056 

Both my partner and I come to the Ashokan Reservoir to visit that area for recreational purposes. We have close friends that we call family living within 15 miles of the Ashokan Reservoir and so within 15 miles of the proposed alternative sites for the Ashokan Pumped Storage Project's Upper Reservoir and other towns and cities served by the Ashokan Reservoir as a source of drinking water. 

We are concerned. While we recognize that hydro storage can be environmentally useful, the question is where is as pumped storage project least ecologically damaging?. 
The proximity of this proposed project to small towns, their neighbors, the recreation and wildlife is harmful. 

We ask, please to allow citizen comments and the dialogue with organizations filing motions to intervene, to continue. 

Thank you! 
Ilse Pfeifer

Walt Daniels, Mohegan Lake, NY.
The Catskills are a State Preserve protected by the NY State Constitution.

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would increase turbidity and negatively impact NYC’s drinking water.

It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.

The loss of tourist dollars and business revenue would directly hurt our communities.

The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Michael B Cooper, New York, NY.
99 Dry Brook Road
West Shokan, New York 12494

April 11, 2021

Secretary Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE Room 1A
Washington, D.C. 20426

Re: FERC project number P-15056-000

Dear Secretary Bose:

I am writing to express my extreme concern over and opposition to the proposal by Premium Energy Holdings, LLC of California to build a pumped storage and hydroelectric facility at the Ashokan Reservoir, and surrounding areas, in New York's Catskill Mountains.  While I am supportive of efforts to decarbonize our energy supply, the benefits of the particular proposed project will be marginal at best and do not outweigh the very high costs the project will impose on the region in terms of environmental and economic impact.  Most importantly for this stage of permitting, the application suffers from basic flaws and inaccuracies and does not merit approval.

1.	The project would necessitate the acquisition of property that is not subject to the eminent domain power granted by the Federal Power Act.  Specifically, all of the options for the upper reservoir contained in the proposal would involve property that is currently owned by New York State and New York City that meets the description contained in section 21 of the Federal Power Act (16 U.S.C. s. 814) of "lands or other property that, prior to October 24, 1992, were owned by a State or political subdivision thereof and were part of or included within any public park, recreation area or wildlife refuge established under State or local law." Such property is ineligible to be taken by a licensee under eminent domain.  In addition, a voluntary transfer of such property by the State would require a constitutional amendment, a very difficult, slow, and rarely successful process.

2.	The application notes that if the preliminary permit is granted, Premium Energy will spend up to $5 million on subsurface investigations, including soil and rock borings and seismic surveys and testing in the delicate and diligently protected reservoir watershed, which also composes part of the land protected as described in the prior paragraph.  While I believe this alone merits denial of the application, if the permit is granted, Premium Energy should be required to file environmental impact statements with state and local authorities that address the impact of these preliminary testing activities.

3.	The project is described as a "closed loop" but it is actually an add-on to an existing reservoir, as the Esopus Creek runs into and out of the Ashokan Reservoir.

4.	The application contains the following errors and omissions:
-  Portions of the project are in Greene County, which is not listed
-  "Shokan City" does not exist
-  "West Hurley City" does not exist
-  West Shokan is a hamlet, not a town
-  The project would be situated partly in each of the Town of Olive, Town of Shandaken, Town of Hunter, and the Town of Hurley; none of which are listed
-  Olivebridge is a hamlet, not a town
-  The City of Kingston, New York, is not listed as a local political subdivision that is within 15 miles of the project and has a population over 5,000
-  The Town of Rosendale, New York, is not listed as a local political subdivision that is within 15 miles of the project and has a population over 5,000
-  Maltby Hollow Brook is not listed as a stream in the impacted area
-  Dry Brook is not listed as a stream in the impacted area
-  Woodland Creek is not listed as a stream in the impacted area
-  Stony Clove Creek is not listed as a stream in the impacted area

5.	The application lacks precision and uses very low-resolution and possibly out-of-date and incorrect topographical information, including geographic coordinates that do not correspond to the locations shown on the maps.

6.	By requiring the reservation of up to 15,800 acre feet out of the Ashokan Reservoir's total capacity of 382,300 acre feet, the project would permanently reduce the capacity of the Ashokan Reservoir to supply drinking water to New York City by over 4%--the equivalent of drinking water for 360,000 people.

7.	The project is highly inefficient.  By the sponsor's own presumably best-case analysis, the plant would consume 1000 MW of power and only generate 800 MW in each cycle of pumping and release.  This consumes net 200 MW per cycle, which represents 80% efficiency.  By contrast, battery technology is more than 90% efficient today and, given the amount of investment in battery technology research, is likely to be much better and far more scalable when this hydro storage plant would go on-line, approximately fifteen years from now at the earliest.

8.	By requiring the reservation of up to 15,800 acre feet out of the Ashokan Reservoir's total capacity of 382,300 acre feet, the project would permanently reduce the capacity of the Ashokan Reservoir to supply drinking water to New York City by over 4%--the equivalent of drinking water for 360,000 people.

It is not in the public interest to grant a preliminary permit to a project that is inefficient, legally non-viable, and not a true closed-loop system, the application for which lacks important detail and is rife with errors and omissions.  There is no reason to allow the applicant to continue to expend its own resources, those of the communities, organizations and governments opposed to the project, and those of FERC itself on such an ill-conceived and fatally flawed project.

Respectfully submitted,

Michael B. Cooper
FERC ID #F650311

Maria Juur, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Maria Juur

Paul Champanier, Olivebridge, NY.
The plan of Premium Energy Holdings to build a hydroelectric power plant in the Catskill Mountains is an incredibly poor idea. Their request for a preliminary permit for the Ashokan Pumped Storage Project should be denied.
This project would be devastating to the environment, disruptive to local communities, and create a serious risk for the purity of NYC’s drinking water.

This plan would damage the protected forests, streams, and wildlife of the Catskill Forest Preserve. The NYS Constitution, Article XIV , guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

Even after construction there will continue to be environmental devastation as pumped storage has a history of damage to the environment on stream ecology, and aquatic and land habitats.
Plus, the New York State Forest Condition ranks the proposed sites ranks among the top 1% of forest habitats region-wide. 

The plan is a short sighted attempt to solve one problem and create what could be hundreds of others as it impacts the community, the environment, wildlife, and tourism.

Michele Pellar, New York, NY.
I am writing in opposition to the proposal by Premium Energy Holdings to build a hydroelectric power energy plant in New York's Catskill Mountains.  I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 as it would be devastating to the environment, extremely disruptive to local communities and would risk the purity of New York City's drinking water.

I agree with and fully support our country's transition to green energy renewable sources.  However, the transition must not come at the cost of environmental and community destruction and devastation.

Please deny Premium Energy's proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you for you consideration in this matter.

Marvin H Seligman, jewett, NY.
I am strongly opposed to the “Ashokan” Hydro Project particularly in the Stony Clove Valley.

Hydro Power can have benefits, if it is in the right place. This is not the right place.

It is in the center of the NYC watershed. The NYC water system is one of America’s greatest engineering accomplishments. Clean water is a precious resource. Billions have been spent and continue to be spent to preserve and deliver clean water to NYC. This is a protected area. There’s only one efficient place to get water for NYC… right here in the watershed. There are many sources for alternative energy. The project is not compatible with the need for clean water for NYC. 

It is in the heart of a NY state protected forest and the center for outdoor activity and tourism. Historically It is the first tourist area in the USA.

The area has a growing vibrant economy and community. 

There are better and more cost efficient ways to an alternate fuel future.  


Sincerely, 
Marvin Seligman

Charlotte Jaeger, Lexington, NY.
TOWN OF LEXINGTON
3542 State Route 42
P.O. BOX 28
LEXINGTON, NY 12452

JoEllen Schermerhorn, Supervisor
Michael Barcone, Councilman				        Bradley Jenkins, Councilman
William Pushman, Councilman				        Bennett Wine, Councilman
				    Charlotte Jaeger, Town Clerk


April 12, 2021


Kimberly D. Bose 
Federal Energy Regulatory Commission
888 First St. NE Room 1A 
Washington, D.C. 20426

Re: PROJECT P-15056 ASHOKAN PUMPED STORAGE PROJECT
Dear Ms. Bose,
On behalf of the Town of Lexington, we respectfully request the FERC deny the preliminary permit Premium Energy filed (# P-15056) given the number of serious, unanswered issues with its proposed project, namely the impact on state constitutionally protected land, the impact and disruption to the NYC water supply, which is required to meet state and federal surface water standards, and the impacts to the environment especially fish populations and water resources.  
The application is weak in understanding the geologic, legal and environmental ramifications of proposing this project in the Catskill Park and NYC Watershed.  The costs to develop the project in this protected, sensitive area would be astronomical. There should be assurance the company knows what it is getting into.
Thank you for your time and attention to this matter.
Sincerely,

JoEllen Schermerhorn
                                                  		 Telephone: (518)989.6476
       Fax: (518)989.6618

Sarah Galbraith, High Falls, NY, NY.
The premise of Premium Energy Holdings (PEH) proposed pumped storage facility in New York’s Catskill Mountains is to create a sustainable "green" energy storage facility.   Project P-15056 couldn't be further from sustainable.  Habitat destruction in the name of "green" energy is anything but sustainable.  I ask that FERC reject this proposal and not issue a permit for its construction, now or in the future.
In the early 1900s, New York State's Catskill Park Preserve was established by a New York State constitutional decree.  All three of PEH's alternate reservoir sites are situated within the Catskill Park's boundaries. Their construction would destroy and inundate hundreds of acres of valuable habitat, and irreparably altered more in constructing the needed electrical lines to move the generated electricity to existing transmission lines.    More than a century ago, the New York State legislature recognized the value of protecting and conserving land and habitat for future generations.  Today scientists in the fields of ecosystem management and climate change know that preserving natural ecosystems is the most efficient protection against further atmospheric warming.  Healthy, unaltered ecosystems store carbon, preventing it from entering the atmosphere, while destroying intact natural areas releases carbon and reduces the absorption capacity.  Severely damaging a legally protected natural area in the name of "sustainable energy" demonstrates Premium Energy Holdings' utter lack of understanding of how best to address our changing energy needs and preventing further climate change.  Protecting nature is the best, easiest, cheapest climate strategy we have.
There are additional problems with Proposal P-15056.  The land and waterways within this area were already seized once by eminent domain in order to build the Ashokan Reservoir.   Approximately 2000 people had their land, homes, and businesses taken and flooded; entire towns were abandoned to the depths of the new reservoir.  Those emotional scars have not healed a century later.  If the pumped storage facility is allowed, more families will be permanently displaced by Premium Energy Holdings.   Should we allow history to repeat itself?   
The Ashokan Reservoir provides clean, unfiltered drinking water to 9.5 million people, most of whom live in New York City.  This is made possible by the thousands of acres of preserved forests in the Catskills.  They create a natural filtration system for the precipitation that falls on the slopes of the Catskills before entering the Ashokan Reservoir.  The PEH proposed pumped storage facility puts this drinking water source at high risk with the potential to move unpredictable amounts of water and suspended sediments from the proposed storage reservoir into the Ashokan.  
Lastly, this past year has brought The Catskill region back into the spotlight.  People have sought refuge and solace in the outdoors.  Tourism in the region has soared, pumping much needed tourist spending into the local economy.  The region has been rediscovered.   Yet, a company located 3000 miles away, with no connection to the region, want to put this in jeopardy, first scarring the land, then flooding it, destroying vital habitat to unique plants, important bird breeding habitat, and vital spawning grounds for threatened brook trout - a victim of the warming climate PEH claims to be helping.  The Catskills are a gem, to be preserved as "Forever Wild" for all of humanity just like the NY State legislators realized a century ago.  
Please reject the permit application for P-15056-0000. 
Thank you for your time and consideration.
Sincerely,
Sarah Galbraith

David Vassar, New York, NY.
To whom it may concern at FERC:

I have deep concerns which I share with many fellow Empire Staters about the Ashokan Proposal to FERC for a Pumped Storage Add-On Project in the Catskill State Forest Preserve:
1.	Literally millions of New Yorkers including me and my family depend on water sourced from the Ashokan Reservoir System, and this water would likely be harmfully contaminated by the project’s operations.
2.	Quality of life for residents in the region would be adversely affected by the operation’s loud, jarring noise, with much area wildlife habitat damaged or destroyed in the process.  Air quality would also be greatly compromised, and the peace and natural beauty of the impacted area would be ruined for all.
3.	The region’s robust tourism industry, traditionally a win-win for both the Catskill’s communities and their legions of visitors, would take a huge hit, entailing not only much loss of gainful employment but also a permanently degraded environment—which I believe we all agree is absolutely priceless.

So I strongly urge all of you at FERC unhesitatingly to reject this project, P-15056, irrevocably. In doing so you’ll help preserve the well-being of entire NY communities as well as the health of the region’s precious natural heritage. You’ll also prevent possibly many costly years of litigation and distress for all involved.

Thank you for your serious consideration of my appeal.
David Vassar

Laura C. Sitler, Bridgewater Township, NJ.
I'm writing to let you know I oppose this project to build a hydro-electric plant above the Ashokan. I visit several friends in this area and value the wonderful beauty of this region. The project site is inside of Catskill Forest Preserve, and would destroy these highly preserved forests, wildlife, and stream ecology. It could also have negative effects to the Ashokan Reservoir, which supplies 40% of NYC’s drinking water. It's a protected water source and this could  ​increase turbidity and pollution and affect people throughout the state. Finally, private property may need to be taken to build this. My friends have lived in the area for decades and have set up businesses and are actively contributing to the economic and cultural growth of this region. To have them potentially lose their land and all that they have worked for so that an out-of-state company can build something that may damage this protected land is heartbreaking. Please protect this natural environment and do not move forward with this project.

Thank you,
Laura Sitler

Chris Abramides, West Hurley, NY.
I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Kathleen Nolan, Mount Tremper, NY.
As a resident of Shandaken, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Richard B. Boyd, Vienna, VA.
Ms. Kimberly D. Bose                                                                                                                            Federal Energy Regulatory Commission (FERC)                                                                                      888 First St. NE Room 1A
Washington, D.C.  20426. 

REGARDING: FERC Project Number P-15056:000

Dear FERC Reviewers,

I am opposed to approval of the request for a preliminary permit by Premium Energy (FERC Project Number P-15056-000) to conduct studies on building a pumped storage hydropower project utilizing the Ashokan reservoir.

I am a co-owner, with my sister Ruth Boyd Kletzander, of a summer cabin located at lot 28, Roxmor Colony, 724 Woodland Valley Road, Phoenicia, New York 12464.  We have a strong interest in the appropriate development of renewable energy infrastructure in the United States, and my review of the current request by Premium Energy referenced above prompts me to voice my strong opposition to this proposal for pumped storage hydropower.

There are two primary areas that I believe should be considered in the assessment of the request.  These demonstrate why this proposal is not a good choice for sustainable energy development in the United States, and serve as a basis for denial of the request.  They are:

1)	Premium Energy’s proposal would involve development of land in the Catskill State Forest Preserve that is designated as “Status 2” under the United States Geological Survey “Gap Analysis Program.”  I reference and agree with the 2016 United States Department of Energy (DoE) "Hydropower Vision" publication which indicates in section 3.3.4 (5) under Protected Lands that “Areas with formal protections designated as Status 1 or 2 under the U.S. Geological Survey’s Gap Analysis Program are avoided for development.”

and

2)	The Premium Energy proposal does not provide clear information regarding the basic nature of the project.  The proposal states that “The proposed Ashokan Pumped Storage Project would operate in a closed loop;” however, this statement is not supported by the proposal’s use of the open Ashokan Reservoir as the lower reservoir.  Based on the information presented in the proposal, the project is an “Open-Loop add-on” pumped storage hydropower project, since the project’s lower reservoir (the existing Ashokan Reservoir) would still be continuously connected to the natural flowing water feature (i.e., the Esopus Creek) that was dammed for the original construction of the Ashokan Reservoir.  Due to this basic inconsistency, the proposal is inadequate and should be rejected.  Further, because the project is an Open-Loop add-on, it would not have some of the likely environmental benefits associated with a traditional Closed-Loop pumped storage hydropower project.  As proposed, it appears the project would impact the water of the Ashokan Reservoir which is relied upon by myriad users for drinking water and serves as an ecological habitat for fish and wildlife.  I refer to, and agree with, the April 2020 DoE HydroWires publication: "A Comparison of the Environmental Effects of Open-Loop and Closed-Loop Pumped Storage Hydropower" which notes that, regarding certain Open-Loop add-on projects (similar to the Premium Energy proposal), “…the impacts of project operations would still likely be higher than for closed-loop because the add-on project’s lower reservoir is still continuously connected to and affects a naturally flowing water feature.”  I also note that as an Open-Loop add-on project, the Premium Energy proposal does not meet the criteria for expedited processing by FERC.

In addition, I have strong concerns regarding: the potential environmental impact the proposal could have on the fish and wildlife habitats and vegetation in the affected streams/waterways and related areas; the potential adverse impact on places of historical significance; and economic impacts to the area which relies on a substantial amount of tourism. 

Based on the above concerns, Premium Energy's proposal (FERC Project number P-15056-000) is not a good choice for sustainable energy development in the Ashokan reservoir region, and it does not align with the FERC's vision of responsible environmental stewardship in the development of hydropower in the United States.

I strongly urge FERC to deny Premium Energy’s request for a preliminary permit (FERC Project Number P-15056-000).

Thank you for the opportunity to provide comments. 

Sincerely,

Richard B. Boyd
217 Moore Avenue, SE
Vienna, Virginia  22180

maraleen manos-jones, shokan, NY.
As a long time resident of the town of Olive, N.Y., I am dismayed that a private electric company could invade, destroy, and usurp our land for their profit. 

This project would negatively impact the environment in far too may ways. It would impact the Esopus Creek, one of the premier trout fishing streams, with muddy turbidity also affecting the Ashokan Reservoir, a source of drinking water for  millions of people in NYC.  It would devastate local tourism for which this area is famous and dependent.

The Catskills are a State Preserve, protected by the state constitution.  Does this mean nothing in the face of money to be made?  How dare this company invade and destroy our environment?  Who are the politicians shilling for this company? I have worked for decades to protect pollinators in our area. The Scenic Byway, 52 miles of Route 28, has encouraged the towns along the By-way to protect pollinators and all wildlife.

This disruptive electric power and dam project is not how to move forward toward an equitable future mindful of climate change.  This project destroys and disrupts and should definitely not be approved.

Thank you.
Maraleen Manos-Jones
www.spiritofbutterflies.com

Scott Ambrose Reilly, Phoenicia, NY.
I am a homeowner for 15 years on State Route 214 in the town of Phoenicia, NY.

Building green energy infrastructure is a necessary step for New York State but the proposed hydropower facility proposed in Project Docket:  P-15056 would harm water quality at Ashokan Reservoir which provides fresh clean water to approximately 3,600,000 people and add variables to, while potential disrupting, New York City’s longstanding efforts to operate and protect the water supply. 

Not only could the hydroelectric plant contaminate the water quality, but building the infrastructure to service the energy production would put a strain on the protected wilderness of the Catskill region. The Catskill Forest Preserve is home to hiking, camping, fishing, skiing, and all other types of outdoor recreation that could be disrupted by large-scale energy projects.  It would disrupt recreation areas that were established more than a century ago and are now home to many species of threatened animals.

Thanks to the unfragmented forests we are able to be an area that's more resilient to climate change and also host a number of rare and endangered species.

I am sure there must be multiple locations with the same upside yet not having all the downsides.

Lissa Kiernan, West Hurley, NY.
Lissa Kiernan
1693 State Route 28A
West Hurley, NY 12491

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the seriously troubling proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, risky for the purity of NYC’s drinking water, and potentially to human health.

Premium Energy’s proposal to construct a new reservoir, dam, and underground power station to harness the Ashokan Reservoir and its watershed for hydroelectric power would directly impact my home and business. I live in West Hurley, 0.4 miles from the Ashokan Reservoir Spillway. I moved here six years ago from New York City.I now live adjacent to the watershed that supplied the majority of the drinking water for the city I lived in for 30 years. I was shocked to learn that West Hurley and ten other towns were seized to create the reservoir. I have neighbors who can attest to the devastating effect of this act of eminent domain on their lives firsthand. Similarly, the Ashokan Pumped Storage Project P-15056 threatens to devastate my community by disrupting our economy and displacing its residents.

While there is no question that the Ashokan Reservoir project was a crushing hit to this area, at least it fixed a problem: getting much-needed water to the growing population of New York City. Conversely, it is unclear to me what problem the proposed Ashokan Pumped Storage Project P-15056 would solve. While no doubt pumped storage and new hydroelectric projects will play a role in the transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

I am a small business owner, and my business is home-based. I chose this location, in part, for its proximity to these protected lands, an Audubon Important Bird area and top 1% of forest habitats region-wide. I offer writing workshops, readings, and retreats through my LLC, The Poetry Barn. The barn also serves as a private library holding over 3,000 volumes, and serving the community as a free poetry resource. My business relies heavily on the Catskill tourism industry, seeing the majority of its visitors during the high seasons of spring, summer, and fall. My organization's workshops and events are typically attended by a mix of locals and visitors. The Catskills’ growing tourism economy generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Ulster County represents 43% of that market. Premium Energy’s project would dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

My business is writing, not energy. However, I did write a book—"Glass Needles & Goose Quills" (Haley's, 2014), that examined lessons learned from Yankee Rowe Atomic, which operated as a prototype nuclear power plant.In 1997, The Massachusetts Department of Public Health conducted a study (“Assessment of Cancer Incidence and Down Syndrome Prevalence in the Deerfield River Valley, Massachusetts”) of the area downwind from that plant and found statistically significant elevations in breast cancer, Down Syndrome, and non-Hodgkin lymphoma, the type of cancer from which my father died, manifesting as a brain tumor type known as Primary Central Nervous System Lymphoma.

The Ashokan Pumped Storage Project would place 12.9 miles of 230kV high-tension transmission lines, including some adjacent to my home and business. The potential health risks of living near overhead high voltage transmission power lines are still controversial particularly as regards long-term health effects like cancer. The literature does suggest, however, that ELF-EMF exposure could be involved in the occurrence of brain tumors. According to a study conducted to investigate the association between residential proximity to power lines and brain tumors among adults in France,“a death certificate-based case-control study found an association between adult brain tumor mortality and living less than 50m from a power line and a recent case-control study found an association between adult brain tumors and particularly meningioma and living less than 100m from a power line (“Residential proximity to power lines and risk of brain tumor in the general population.") 

The project would certainly harm the health of animals and plants. While it’s proposers are proclaiming it a closed-loop project it is in reality an “add-on” project. This kind of project carries with it significantly higher environmental risks. Even when complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats because the upper reservoir is subject to rapid fluctuations as water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.

For these reasons, I urge you to do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, 
Lissa Kiernan

Delia Kulukundis, Phoenicia, NY.
I am writing to oppose the Ashokan Hydroelectric pumped storage facility that Premium Energy Holdings has proposed in the Catskill region of New York (P-15056-000), and to urge FERC to fully account for the greenhouse gas emissions that would result from the flooding of forests within the Catskill Preserve. In addition to the negative impacts on species that depend on our forests, inundating these forests would cause methane to be released as vegetation decomposes. We must not inadvertently create more greenhouse gas emissions by building new hydropower facilities - and any accounting of their greenhouse gas emissions must include the lost carbon sequestration potential of the areas inundated. Forests are perhaps the best-known “nature-based solution” to climate change. We need to increase the area of forested land in our state, not decrease it. Before we resort to destroying vital natural areas like the forests and streams within the Catskill Preserve to create pumped hydropower energy storage, we should explore alternatives that reduce greenhouse gas emissions, like electric water heaters that can be turned on and off in response to the needs of the grid. Please reject this shortsighted proposal by Premium Energy Holdings, and prioritize real greenhouse gas emission reductions.

Patricia Matus, Olivebridge, NY.
Hello

I'm opposed to the underground hydroelectric power station being proposed by Premium Energy Holdings, LLC.

One of the reasons my husband and I purchased our home in Olivebridge, NY is because we were interested in being near protected land.

The Catskill Forest Preserve has existed for 135 years and is highly significant to the ecosystem that it protects.  This project would be destroying highly persevered land and would be against the Dept. of Energy’s own Hydropower Vision. As a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. That designation, in and of itself, is reason enough not to allow this proposal to go through. Land designated as status 1 or 2 are not supposed to be developed in any way,

This proposal also goes against what the DoE says it wants - it wants to support closed-loop projects -  this is not.  

It’s an upper reservoir being added on to a lower reservoir - an "add-on” project.  They are not truthful in what they are proposing so don’t deserve FERC approval. 

Source: DoE: “A Comparison of the Env. Effects of Open-Loop and Closed-Loop Storage Hydropower. April 2020

Thank you for your consideration.

Patricia Matus

Brian P Hehir, OLIVEBRIDGE, NY.
Dear Sir or Madam

I write to object to docket P-15056-00 - Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056 filed by Premium Energy Holdings, LLC of California who are applying for an initial permit for an open-loop pumped-storage hydropower plant to be built within the NY State Catskills Forest Preserve.

As a resident of The Catskills and keen supporter of renewable sustainable energy, clean water and the environment, I find this application to file for a permit to begin the process of creating an open-loop pumped-storage hydropower plant within the Catskills Forest Preserve highly speculative, legally troubling and fraught with both litigative and technical problems. 

It is a difficult position to be in to support sustainable power but object to a potentially 'clean' power plant but this plan is thoroughly unconscionable and rather than simply file a 'not in my backyard' objection I found that this application has issues under at least three critical criteria even before one considers the environmental impact on the protected wildlife and the natural beauty of the area or the disruption and destruction this project could have on the economy of the area and the revenue it generates for the local community, county and state. 

The Catskills Forest Preserve was created in 1885 under article XIV of the New York state constitution to be "forever kept as wild forest lands.. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private." As the watershed source for New York City's water supply, and an area of outstanding natural beauty The Catskills Forest Preserve is enshrined within the NY State constitution and I am sure that Federal eminent domain was never intended to over reach into such an area of land that is protected by a state within its own constitution. Such an action would trigger litigation more vociferous, highly charged and financially supported throughout the union than even PennEast Pipeline vs New Jersey. The resulting litigation that would result from allowing this plan to move forward would run for many, many years leaving our need for sustainable power unmet, while bringing all involved open to contributing litigation that could only possibly be resolved by appeal to the highest court in the land at significant financial cost for all involved. See https://www.supremecourt.gov/DocketPDF/19/19-1039/175183/20210407141230704_19-1039_Brief.pdf

In addition to the very questionable and troubling legal grounds on which the permit might be granted this plan falls short of and contradicts the Department of Energy's own Hydropower Vision. The Catskills Forest Preserve location is designated as a status 1 location by the Department of Energy's Hydropower Vision "Gap Analysis Program", accordingly “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

This open loop project application has issue on its technical foundation as pertains to the Department of Energy's own guidelines. For such a permit to be granted, FERC would need to ignore the Department of Energy's guidelines which clearly preclude such a project moving forward, in addition the technical nature of the project itself does not appear to meet the preferred method for pumped hydro as a closed loop system where this is clearly an open-loop pumped-storage hydropower plant, despite the application rather deceptively attempting to portray it otherwise. 

If this application was to be allowed to move forward it would be the first project that would extend Federal eminent domain in to a State's constitution while simultaneously contradicting Department of Energy guidelines for both plant location due to the Catskills Forest Preserve designation as a Status 1 protected environment and technical implementation preference for closed loop over open loop.

On legal, location and technical grounds alone this project should not be allowed to move forward.

Thank you for your time and I hope you reach the right decision in this case.

Fred Perry, Olivebridge, NY.
I am commenting on the proposed Ashokan Pumped Storage Project. I looked at the proposal on the website, and it is very difficult, from the online documents, if one is not an engineer, to determine whether this would be good, or necessary, and how much it would impact the local resident’s quality of life, the wildlife, or the ecological systems we all depend on. Therefore, I can not make a definitive comment either way regarding whether I would support or oppose this project. I can say this, though. The ecological balance is very delicate in this area of New York. The residents live here because of the natural beauty of the area. Any new engineering project should be considered and reconsidered extremely carefully to insure there would be minimal negative effects to the natural beauty of the area or the ecological balance. The quality of life is another factor to be considered. Should this project inconvenience or upset the daily routine of residents, that would be another reason to consider and reconsider this project. The residents of this area are largely poor or lower middle class, (although there is a fairly large group of wealthy people as well), and traffic jams, rerouting of travel, and other inconveniences of this type would present an economic disadvantage to many local residents. Thank you for reading and registering my comments.

Laraine Mai, New Paltz, NY.
We have choices for alternative energy resources often they require a balance between the need for protection of environments with seeking new energy development.   This project seems to be so ill conceived, so inappropriate to the setting, so damaging to the quality of the water supply (locally and for NYC), and so disruptive to local human communities that have historically suffered the loss of homes6 and villages to create the reservoir.  Premium Energy has questionable capacity to manage such a project and has no local connection - nor has it reached out to the relevant local officials or organizations for comment or advice to its plans.

Please deny this permit.  We’re at such a transformational time and the choices we make now will shape the realities of the next generations.

Thank you.

Adeline Basil, Lexington, NY.
Docket Number P-15056-000
Dr. Adeline Basil
Lexington, New York 12452

Kimberly D. Bose
Federal Energy Regulatory Commission
8The Premium Energy Holding of Walnut, California has applied for a permit to conduct studies regarding building a “Pumped Storage Plant” utilizing the Ashokan Reservoir. I wish to register my objections and concerns for this initiative in the strongest possible terms.
I am a resident of this area for over 50 years, and my love for these lands and the way of life provided is significant. My children and my grandchildren feel the same way, passionately! 
To be clear the Premium Energy people have announced that they will NOT proceed without the support of the local officials and communities. Therefore, if we are to take them at their word, all plans must be immediately halted and dismissed, since NO such support exists. They do NOT have local approval.

My objections are listed followed by elaborations. 

There has been inadequate notice regarding this to the officials, the communities, and the local agencies holding interests.
The FERC and Premium Energy have been ignoring the Constitutionality of these proposals. 
The tragic impact of these plans on the Catskill Park, with its Forever Wild protected status.
The environmental harm these proposals would accomplish.
The economic devastation on many of the towns and villages in the counties which stand to be affected.
The sacrifice to the quality of life for the citizens who call these areas HOME.
The unconscionable destruction of the habitat vital to the wildlife in these areas.
The Science and supporting documentation of the planned procedures are weak, indefensible, and illogical.

There has been inadequate notice regarding this to the officials, the communities, and the local agencies holding interests. The Supervisors of the affected towns were not given any reasonable notice, and only learned within mere days. Town Supervisors, Mayors, Councilmen, and Legislators were left without the necessary amount of time to examine these plans, and prepare responses. The DEC (Department of Environmental Conservation) was given no notice, and so reasonable, responsible discussions and considerations were missing! 

The FERC and Premium Energy have been ignoring the Constitutionality of these proposals. Such plans require Amendments to the New York State Constitution. FERC and Premium Energy have taken no steps to plan for or consider any legal amendment process. The Department of Energy reminds us that Sites 1 and Sites 2 must be avoided for projects such as this, according to our New York State Constitution.

The tragic impact of these plans on the Catskill Park, with its Forever Wild protected status, is unconscionably evil. Destruction of the entire way of life for so many areas and so many acres is not at all justified by any advantage they seek to accomplish regarding renewable water. Such goals, accomplishing renewable water sources, must not sacrifice the Catskills. In the hearts of anyone with a conscious, such endeavors would produce a sickening regret.

The environmental harm these proposals would accomplish is substantial. Our stunning landscapes must not be wiped out. The trees providing magnificent hills and mountains are sacred to us all. The many hiking trails in these areas provide such vital parts of our lives. The rivers, which provide home to our fish and many forms of recreation to our citizens are precious to us all. Fly fishing, swimming, canoeing, rafting, and boating are to be preserved at all costs. The ecology is a God-Given Gift, which must never be sacrificed!

The economic devastation on many of the towns and villages in the counties which stand to be affected is enormous. This area is a vibrant, thriving economic way of life to all our citizens. Tourism is a major industry providing jobs for all in every aspects of life. Every age group in the areas depends on, and enjoys, the many jobs and business opportunities Tourism offers. Parents raise their children through this industry, young people work hard to accumulate funds to pay tuition for college educations, and senior citizens are able to support themselves as they struggle to meet the challenges of retirement. Further, the TOURISTS themselves create many, many wonderful family memories. The Route known as 214, as a major travel route from Ulster County to Hunter. This provides travel access to and from the tourists’ destinations. Also, the ability of the towns and villages to sustain government would have a ridiculously painful effect as properties are removed from the Tax Base! We truly cannot abandon the economic realities.

The sacrifice to the quality of life for the citizens who call these areas HOME is IMPOSSIBLE to defend. The leisure time and recreational time our citizens enjoy is vital to the well-being and happiness. These communities are populated by hard-working, sincere people who need our environment for the emotional and spiritual benefits our land offers. Serenity and peace cannot be considered luxuries; rather they are necessities, insuring mental health and subsequent physical health. We need the hiking trails for exercise and awe in nature, the streams for our swimming, fishing, and boating experiences, and benefits of the prolific fresh produce available.

The unconscionable destruction of the habitat vital to the wildlife in these areas is absolutely out of the question! Protecting our wildlife is our sacred duty that, as human beings, we owe to the planet. Our deer population is wonderful, our many small animals that enjoy our fields and forests are delightful, and our birds provide visual wonder and lovely, soothing song. Our fish provide not only food, but a significant part of the legacy of the Catskills. We must protect the habitat!

The Science and supporting details of the planned procedures are weak, poorly designed and reckless.

I vehemently oppose these plans! Dismiss this matter now!
Dr. Adeline Basil

Erica Breckels, Kingston, NY.
People over profits. Land over profits. Environmental protection of our land and water over profits. Say no to a building a dam in the Catskills. Not now, not ever. Say no to Premium Energy and their Ashokan Pumped Storage Project. 

Erica Breckels
Ulster County Resident

Mary Helen Crump, Lindenhurst, NY.
FEDERAL REGULATORY ENERGY COMMISSION
COMMENTS ON ASHOKAN RESERVOIR PROPOSED PUMPED STORAGE
HYDROELECTRIC FACILITY   P – 15056
April 12, 2021

I OPPOSE ASHOKAN RESERVOIR PUMP STORAGE PROPOSAL

As a resident of NYS, I have hiked and backpacked the region for over 50 years in these Catskill Forest Preserve wilderness and wild lands.  

I have supported the organizations that have taught us all respectful and safe use, and maintained and improved habitat protection and recreational access.  NYNJ Trail Conference, Adirondack Mountain Club, Catskill 3500 Club, and NYS DEC have done commendable work to protect this valuable resource in its wild state.

The value of these lands has only increased with more demand by the public.
  
The critical need to protect this NYC water source’s fine quality is essential.

ISSUE:  The pumped-storage proposal directly threatens the disruption and future degradation of quality of these lands for habitat, recreational and water quality maintenance. 
 
There are no safeguards to this project that could possibly satisfy the higher purposes of these lands. Forever wild.

THEREFORE, I URGE YOU TO REJECT THE PREMIER ENERGY HOLDINGS OF SOUTHERN CALLIFORNIA ASKOKAN APPLICATION.

Sincerely,
Mary Helen Crump
326 South 4th Street
Lindenhurst, NY 11757
mpcrump@hotmail.com

Matthew Lange, Shokan, NY.
Dear Secretary Bose, et al.;

I am writing to voice my strong objection to the proposed "Ashokan Pumped Storage Project."

This project is nothing more than an abuse of government works programs, designed solely for the profit of an exploitative corporation. 

It should be clear from the previous endeavors and pursuits of Premium Energy Holdings, LLC that there is no tangible benefit from this project to the community or the interests of any community members. It should also be painfully clear that this company has no interest whatsoever in sustainably improving the infrastructure of any community. They are simply fishing for projects from which they might profit. 

The idea that this corporation should be allowed to disrupt not only the ecosystem of this region, but the supply of fresh drinking water for over 8 million people, for the sake of a handful of California-based entrepreneurs should be appalling to any of the area's citizens. The management team at Premium Energy Holdings knows very well that they are not adding value to this community, or to New York's green energy initiatives. 

While I am aware that Premium Energy Holdings has indicated that they will seek new sites or revise their plan, I still feel an urgent need to voice my opposition to this company and its practices. New York State, like every other state, is in desperate need of newer, greener infrastructure. The projects that comprise this infrastructure will need to be efficient, effective, and exacting. Hydroelectric plants that do little more than power themselves are a complete waste of tax payer's money, and of the precious little time that we have to curb carbon emissions. 

Please stop Premium Energy Holdings from building any projects anywhere in Ulster County or anywhere in New York State. New Yorkers can do it better, and we can do it in a way that benefits all New Yorkers.

Thank you for your consideration.

Sincerely,
Matthew Lange

Deanna Schwarz, West Shokan, NY.
I am writing to express my significant concerns with regards to the proposal to obtain a preliminary permit for the construction of the Ashokan Pumped Storage Project.  I am a homeowner in West Shokan near the Ashokan reservoir and I believe the project as proposed could have significant effects on the surrounding community that far outweigh the benefits of the energy it would generate for times of high demand.  This type of construction can take years (and, based on my own preliminary research) often runs over budget due to unforeseen hurdles once excavation begins.  The project is in the heart of New York’s Catskill Park where so many come to enjoy the beauty and the recreation opportunities afforded by the wilderness.  The area around Ashokan Reservoir, in particular, is quite popular with tourists all year round as a place to come to hike, climb, fish, hunt, and ski.  A project like this could disrupt these activities for years and potentially impact the economic health that depends on this activity.

While I am only beginning to understand the specifics of the proposal made by Premium Energy Holdings, I do have significant concerns specifically related to the potential for ecological disruption due to the construction of the upper pool and the tunnels that would be needed for the closed loop system.  All three of the alternative upper reservoir locations are proposed at substantial distances (from ~3 to 10 miles) from the Ashokan Reservoir, the proposed lower pool.  Similar (albeit open-loop) pumped storage projects (e.g., the Blenheim-Gilboa HPS in Schoharie County) have upper reservoirs often located less than half a mile from the lower reservoir).  In addition to concerns about ecological disruption due to such extended tunneling, pumping water uphill for that extended distance (even if done at night/when costs are low) seems inefficient and could offset the benefits of the pumped storage system.  Finally, even if Premium Energy determines that the proposed Woodland Reservoir, the closest of the three proposed upper pool locations, is feasible, the area they are proposing appears to be situated near many residential properties along Moon Haw Rd in West Shokan and the tunneling could impact other areas of the hamlet.  Consideration for the impact on these property owners and the hamlet overall must be taken into account.

I, as many home owners in this area, are committed to finding more opportunities to transition to renewable energy sources.  I ask FERC to carefully consider whether this project is the right one for the region.  Thank you.

Isabel A D Bengtson, Olivebridge, NY.
My objection to the proposed application is based on:
the fact that as a State Forest Preserve, the Catskills are considered  
Status 1 land under USGS "Gap Analysis Program".  According to the Dept. of Energy's own Hydropower Vision, "areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development."  
The Catskill area provides 90% of NYC's water, a water supply that provides 1 billion gallons a day to 9.5 million people.  The largest unfiltered water supply in the nation, built at the cost of displacing 25 communities.  40% of NYC's water passes through the Ashokan reservoir.  The pumped storage project is likely to increase the turbidity which would decrease the quality of NYC water.  
Then Route is one of only two roads that connect the Catskills' two major highways, Route 28 and Route 23A.  Any disruption to that road would inflict a heavy blow to the tourist economies of Hunter Mountain Resort and the town of Phoenicia, rated the #1 tourist destination outside of NYC.  Route 214 is designated a scenic byway and is part of the Mountain Clove Scenic Byway.  NYC DEP, Ulster County, and Greene County have all invested significant sums of money to reinforcing and improving Stony Clove Creek to improve stream ecology, reduction of flooding, reducing turbidity in the Ashokan reservoir, and maintaining the roads around the reservoirs.  
The investment in this project seems as though it will not garner the rewards that would justify the disruption to our ecology, economy, and personal lives to justify going forward.  
Thank you for your time and attention.  Sincerely, Isabel A D Bengtson

David Lydick, Pine Hill, NY.
To Whom it may concern,

Thank you for the opportunity to voice my definite opposition to this project.

As a lifetime resident of New York, and a homeowner here in the Catskill park itself, it is incredibly evident and conclusive that this proposal is absurd when held under the looking glass of our state's legislation, pride in conservation, and legacy of preserving the wilds of the Catskills for future generations to come.

When something by definition causes more harm to an area it is proposing to help, it is already deemed a failure.

So is, in the opinion of this New York State Outdoor Guide, Eagle Scout and resident, any idea of exploiting the natural resources of this area for any purpose.

The Catskills does not need, nor can it bear, any future failures in terms of conservation.It's success environmentally depends on a fragile balance which is voiced by it's constituents and legislature which protects the park.

In this case, the silent voice of nature has also been vocalized by our representatives, scientists, and respected biologists.

And the mountains say "NO".

David Lydick
NYS Guide #8615

Cara Cruickshank, Big Indian, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, outdoor tourism, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

What is the good of naming this region a protected state park, unless we protect it? Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 
Sincerely,

Cara Cruickshank

Stephanie Blackman, Chichester, NY, NY.
April 12, 2021

Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

RE: Docket #P-15056

Dear Ms. Bose,

I am writing to voice my opposition to the pumped storage hydroelectric generation project recently proposed by Premier Energy Holdings LLC for the Catskill Mountain region of New York. (FERC Docket #P-15056)

This project is ill conceived in too many ways to innumerate in this letter. Here are just a few of the many issues and negative impacts:

1. The project’s proposed reservoirs and tunnels would be located in the Catskill State Forest — land designated as “Forever Wild” by means of an amendment to the New York State constitution in 1904. Another amendment to the state constitution would be necessary to reverse this designation and build these reservoirs and tunnels. 

2. Building any of the proposed reservoirs and tunnels would require the seizure and inundation of many privately-owned homes and properties, presumably by eminent domain. In addition, the single road that provides the sole access to each of these valleys would be destroyed, effectively cutting off access to numerous homes. In the case of the proposed Chichester/Lanesville reservoir, Route 214 (a state highway) would be inundated, eliminating the only road connection between the towns of Shandaken and Hunter and between state highways 28 and 23A.

3. The idea of pumping water in and out of the Ashokan Reservoir, which provides approximately 40% of New York City’s water seems inconceivable. (My understanding is that the NYC Department of Environmental Protection, which manages the reservoir system, was not consulted.) First, pumping activities would disturb 100 years worth of sediment now resting on the bottom, ensuring continual turbidity in the water delivered to New York City. NYC would surely no longer be able to qualify for the EPA’s Filtration Avoidance Determination and would be forced to build filtration facilities at a staggering cost. Second, how would the Ashokan Reservoir, completed in 1915, stand up to the constant in-and-out movement of water?

4. Any of the proposed reservoirs would destroy valuable recreational lands and critical wild trout habitat. Catskill Mountain streams are renowned for their wild trout angling opportunities, and the area draws anglers, hikers and other visitors from all over the world. These are important economic resources for the region, as well.

5. And what about maintenance? Who maintains the reservoir and miles of tunnels, which will exist long after Premier Energy Holdings is gone, perhaps purchased and carved up by a hedge fund, or just no longer in business, say, 50 years from now. This brings to mind the issue of uncapped or improperly capped wells and toxic wastewater ponds left behind when fracking companies have left or gone bust. The cost will be left to New York taxpayers, no doubt.

In addition to the above, numerous other objections to this proposal will be raised by others. I urge you to refuse the permit to study this proposed project.

Sincerely,

Stephanie Blackman
Chichester, NY resident

Jean Duffy, Olivebridge, NY.
  My comments are in opposition to premium energy holdings LLC permit to do a feasibility study in the Catskill Park. I surely hope this office will see the flaws in this permit application.  Everything from the Ashokan reservior as a major source of NY city drinking water to the fact the Catskill Forrest Preserve has been designated wild forever.  I have been from a local farming family for 100 years.  Being a lifelong resident of this farming family I have witnessed our growing season becoming very unpredictable, especially in the last 10-15 years due to climate change.  I have watched the wildest fluxuations in our water cycles from no snow pack in the winter to serious flooding.  This is an open hydro system plan, extremes of these conditions are a threat to these plans, not to mention the threat to NYC water supply which obtains 40% of their drinking from the ashokan reservior.  This proposal will compound the problems our area already faces.  The town of Olive already has a shortage of housing.  Displaced local people will not be able to find local housing.  The catskill park has been designated wild forever, it is home to threatened species such as the box turtle to the wild three bird orchid. I personally have documented and registered a colony of over 600 three bird orchids on my land on Moonhaw road. this is one of only 6 in NYS. I hope FERC will seriously consider the impact of this proposal on this fragile and protected environment.  I believe there will be many new breakthroughs in energy production in the near future. Sincerely Jean Duffy

Submission Description: (doc-less) Motion to Intervene of Center for Biological Diversity under P-15056-000.

Submission Date:        4/12/2021 3:53:37 PM

Filed Date:             4/12/2021 3:53:37 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Center for Biological Diversity          lbelenky@biologicaldiversity.org                                                 

Basis for Intervening:
The Center for Biological Diversity is a national, nonprofit conservation organization with more than 1.7 million members and online activists dedicated to the protection of endangered species and wild places including water resources needed to sustain natural ecosystems. The Center supports the development of clean and renewable energy and needed energy storage to support such development, which is a critical component of efforts to reduce greenhouse gas emissions, avoid the worst consequences of climate change, and assist the nation in meeting critical emission reduction goals.  However, like any energy project, proposed energy storage projects must be thoughtfully planned to minimize impacts to the environment and, in particular, avoid harming sensitive species, habitats and other critical resources including water resources.  The Center is concerned that the proposed Ashokan Project is poorly sited in an area with highly sensitive environmental resources and would adversely impact critical water resources.

Harriet menocal, Bedford, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Dafne DeJesus, West Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant at the Ashokan Reservoir in New York’s Catskill Mountains. The 1906-1915 creation of the  Reservoir demolished homes and businesses, rerouted roads, railroads, and waterways. Like the reservoir water we don't have access to, now we are being threatened again with upheaval, for energy we also won't have access to. You may not be aware that the relocated community of Boiceville is currently undergoing many parcels being leveled in the economic center of the Town of Olive as floodwaters entering the Reservoir often back up into Boiceville, submerging the fire-station and threatening the only grocery store. Construction of a power plant and secondary reservoir will add yet another source of hardship to our communities that have already sacrificed so much in the name of NYC water. Allowing the proposed hydroelectric plant to be built will destroy what is left of our mountain towns, and the environmental impacts will again continue for decades, if not centuries. 

The residential center of West Shokan, where I live, is near Moonhaw Road, which is mentioned as a potential power plant and reservoir site. Trout run in the pristine Bush Kill Stream across the street from me, and approximately 120 avian species, including American Bald Eagles, Blue Herons, Mergansers, and dozens of other water and migratory songbirds use West Shokan as breeding grounds and as a year round habitat. Nearby Maltby Hollow Brook and Dry Brook waterways also feed down to the Esopus. West Shokan is a lush natural paradise that is home to everything from Black Bears, Bobcat, and Red and Grey Foxes, to Great Horned Owls, Grouse, Woodcocks, and the rare Bicknell's Thrush; regionally rare and protected species such as Timber Rattlesnakes, spotted and wood turtles, and spotted salamanders also live here. Lastly, these mountains and valleys are home to rare native plant species such as Three Birds Orchid, several varieties of Lady Slipper Orchids, and American Ginseng. 

Also in this area, at the end of Moonhaw Road, are New York State trailheads for Balsam Cap and Friday Mountains; Nearby are trailheads for Peekamoose and Table Mountains, as well as Ashokan High Point and the Kanape Brook trails. The proposed project would completely cut off accessibility to these vital trails used by locals and tourists alike. There are dozens of homes in and around the our Valley and other adjacent areas of West Shokan that will be lost, and due to the current housing crisis in Ulster County, much less in Olive - there is nowhere for us to relocate, even if affordable homes were available - there is a lack of housing, and the prices of homes have skyrocketed since the pandemic to a well over 46% increase. Because of the nature of the terrain, and that we live within the Catskill Forest on Federally deemed Forever Wild Lands, we cannot even build new homes, even if that were somehow an affordable option; proximity to the tributaries that run through West Shokan to the Ashokan Reservoir is also a hindrance in many cases in that nothing can be built or installed septic wise lest it taint the water that supplies the reservoir. Lastly, West Shokan, Chichester, and Woodland Valley all sit within the Onteora School District. This rural school district that has seen a steady decline since the loss of IBM in nearby Kingston in the 90s, which provided steady income for many people in the community. We are already on the verge of having to make severe budgetary decisions about keeping as many of the 5 schools that operate in this district from Kindergarten through 12th grade. It is a massive district that encompasses approximately 300 square miles, serving 45,000 residents in the townships of Shandaken, Olive, Woodstock, and West Hurley. Any major upheaval like this proposal in this community would mean not only loss of homes for our families, but would be a huge slash to our taxpayer base. Onteora would have to be re structured, schools closed, and hundreds of students left in the balances. It is an impractical, inequitable, and financially and social-emotionally unsound way to provide for our children's futures.

In closing, there is nothing natural about the existing Ashokan Reservoir nor the proposed hydroelectric plant and supplemental reservoir. Our mountain hamlets and in many cases, 7 generations of families, already have born and continue to bear the brunt and hurt of generational trauma over the construction of the Ashokan Reservoir, and now that is being triggered again by the possibility of it happening all over again for a project that in no way benefits our close knit community or pristine environment. The creation of the Catskill Forest Preserve is protected in the New York State Constitution which states that such lands shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Please, do not allow a new round of destruction and upheaval in the name of progress and green energy-displacing hundreds of families and countless species of federally protected, endangered, and rare species of flora and fauna is not the way to push forward. Please consider the vast consequences from this poorly thought out proposal along with its lack of transparency to the communities who will be directly impacted.

Thank you in advance for your consideration, 

Dafne DeJesus, resident of West Shokan, Town of Olive, NY

Lindsay Shands, Glenford, NY.
I am 100% opposed to the proposed Ashokan Pumped Storage Project for the following reasons:
1. This project proposal called within the Catskill Forest Preserve, a NYS designated State Park and protected forests. The forest are ranked among the top 1% in the NYS Forest Condition Index.
2. The Catskill Forest Preserve is ranked as Status 1 land through the USGS analysis. Which indicates the land should be “avoided for development.”
3. The region proposed in this project has a long and deep history. The Catskill Forest Preserve was home to indigenous people since the last Ice Age over 12,000 years ago. Because of this, extensive surveys should be conducted by NYS experts and should be hired and paid for by Premium Energy Holdings. This will ensure the historical importance of these cultures are not destroyed.
4. The path of the 800mw transmission lines will cross over and destroy several protected wetlands. There is at least one NYS regulated freshwater wetland AS-10. This is home to migratory birds, including but not limited to Bald Eagles, green heron, great blue heron, kingfishers. This wetland is also home to beaver, otter, turtles, frogs and much more.
5. This pathway will also destroy protected forests and open up the possibility of invasive species to invade those protected lands. Destroying the habitats of raptors, birds, bats, wild flowers.
6. The pathway for the 800mw lines will also cross farmland used to produce food for 1000s of New Yorkers and small businesses who buy the produce for their grocery stores and/or restaurants. These farms were also vital in feeding those experiencing food insecurities during the global pandemic in our area. 
7. Ulster County is a thriving tourist industry creating 20,000 jobs and an approximate annual industry of $1.6 billion. The Ashokan Pumped Storage project would negatively impact the economic viability of Ulster County.
8. The open-loop add-on system is not a proposal the Federal Government should want to support because is will damage the lower reservoir which is a drinking source to NYC. The turbidity and fluctuations created by this system will also negatively impact important trout habitats and breeding grounds.
9. There should be no foreign investors or investment in US domestic energy grid projects. I read that Premium Energy has foreign investors in previous projects. As a matter of national security all domestic energy projects should be domestically owned and financed.

Given all this the proposed P-15056-000 project should be denied in whole.

Miranda Haydn, Glenford, NY.
To Whom It May Concern:

I am writing to oppose the application for a preliminary permit for the Ashokan Pumped Storage Project.  There are many reasons to oppose.  Here are just a couple.  First, we have other viable and less invasive energy sources available to us in 2021.  Solar and wind.  Second, the biggest concern is how much it would damage the environment immeasurably.  The Catskill Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest. Third, according to The Catskill Park: Inside the Blue Line-Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.  

We need to be able to have a vote on such a big proposal that would affect all of our lives.

Thank you.

james tadic, chichester, NY.
Hello,
The plan submitted by premium energy will negatively impact the environmet permanently. The Catskills is already designated a forest preserve to right the wrong done by the tanning industry at the beginning of the 20th century. The forest is still coming back as second growth trees do we need to stress the plant life, animal life and the waters again?
As a home owner I have invested in this land and community. I vehemently object to a corporation from across the country with no vested interest in the land and the people setting up a for profit corporation under the guise of sustainable energy.

Best,
James

Hannah Cohen, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Hannah Cohen
fulltime resident of West Shokan, NY

robert e wilder, Phoenicia, NY.
I own a home in the Woodland Valley area of Phoenicia, NY, one of the three alternative sites in Premium Energy’s application for a permit. If the proposed hydro-electric power station is built at this site, the location of the dam would make it impossible to gain access to my property.  While I obviously have a personal stake in opposing this project, this is not simply an example of “not in my backyard.” Rather, the construction and operation of a power station at the proposed sites would result in the destruction of protected public forests and streams, and threaten the integrity of New York City’s drinking water. 

The Woodland Valley site, and the other alternative sites, are all within the Catskill Forest Preserve, a unique national treasure, created in 1885, which was a blueprint for our national parks. It is protected by the New York State Constitution which mandates that it be kept “forever kept as wild forest lands.” The project, if permitted, would inexorably destroy protected forests, streams and wildlife within the preserve.  

The proposed sites are also inappropriate because they all contemplate that the newly-constructed reservoir would drain into the Ashokan reservoir, which provides 40 per cent of New York City’s drinking water. Particularly because the drinking water flowing from the Ashokan is unfiltered, the proposed project would present an intolerable threat to New York City’s water supply. 
    
For all of these reasons, I respectfully submit that the application should be summarily denied.

Eliott Peacock, Olivebridge, NY.
I am writing to express my emphatic opposition to Premium Energy's proposal, and to urge FERC to deny the proposal.

ILLEGAL. New York State’s constitution (Article 14, section 1) expressly prohibits any development of the Catskill State Park land. Furthermore, the Catskill Preserve is exempt from eminent domain actions by the Federal Government. Therefore, Premium Energy’s proposal is a non-starter.

NOT CLOSED-LOOP. Premium Energy claims its project would be a “closed loop” system. This is not true. It is an “Add-on”. This company is being flagrantly dishonest in its proposal. Because this is not a closed loop project, Section 3004 of the America’s Water Infrastructure Act of 2018 is not applicable here. Premium Energy is therefore disqualified from receiving expedited treatment in its application process; conversely, FERC has no basis to expedite Premium Energy’s application. Oddly, Premium Energy’s proposed timeline suggests it is expecting FERC to expedite it’s application process.

THREAT TO PUBLIC HEALTH. The Ashokan Reservoir provides unfiltered drinking water to New York City. Premium Energy’s pumped energy storage project would escalate turbidity in the Ashokan to such an extent that disinfectants could seize to be effective and filtration would then be required. What would Premium Energy do if its operation tainted New York City’s unfiltered drinking water? What would the residents of New York City do?

It is as though Premium Energy is telling FERC it intends to break the law and it wants FERC to give it permission to proceed. Does FERC have authority to approve projects that it knows would be breaking the law?

I urge FERC to deny Premium Energy's proposal on these grounds. I have many additional concerns but will refrain at this point in time.

Thank you,

Eliott Peacock

Stephen A Cooper, Boiceville, NY.
741 Bostock Road
Boiceville, NY 12412


April 12, 2021

Secretary Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE Room 1A
Washington, D.C. 20426

Re: FERC project number P-15056-000

Dear Secretary Bose:

I am writing to express my concern over and opposition to the proposal by Premium Energy Holdings, LLC of California to build a pumped storage and hydroelectric facility using the City of New York’s primary source for drinking water, the Ashokan Reservoir, and surrounding preserved areas, in New York’s Catskill Mountains.  While I support efforts to decarbonize our energy supply, the benefits of this proposed project, and the proposed seismic study, will be marginal at best and do not outweigh the very high costs and risks the project will impose on New York City and the Catskill Mountain region in terms of environmental and economic impact.  Most importantly for this stage of permitting, the application suffers from basic flaws and inaccuracies and does not merit approval.
1.	The preliminary permit, if granted, would put the nation’s largest unfiltered drinking water supply, worth several billion dollars to the City of New York and local communities, at risk, as the applicant intends to spend up to $5 million on subsurface investigations, including soil and rock borings and seismic surveys and testing in the delicate and diligently protected reservoir watershed.  This alone merits denial of the application. It has not been demonstrated by the applicant, limited liability company with proposed budget of $5 million for the proposed study, how the proposal provides adequate protections against substantial impact that the proposed study and project might cause to this critical water supply.
2.	The applicant made numerous errors, omissions and misstatements in the permit application. Most critically, this applicant describes this project as a closed loop but it is actually an open loop: the proposed project is an add-on to an existing reservoir containing New York City’s drinking water, as the Esopus Creek runs into and out of the Ashokan Reservoir. The applicant made several other errors, omissions and misstatements:
•	Portions of the project are in Greene County, which is not listed
•	Maltby Hollow Brook, Dry Brook, Woodland Creek, and Stony Clove Creek are not listed as streams in the impacted area 
•	The project would be situated partly in each of the Town of Olive, Town of Shandaken, Town of Hunter, and the Town of Hurley; none of which are listed
•	The City of Kingston, New York and the Town of Rosendale, New York, are not listed as local political subdivisions within 15 miles of the project and having population over 5,000
•	Several towns were listed in the application that do not exist
2.	The application uses out-of-date and incorrect topographical information, including geographic coordinates that do not correspond to the locations shown on the maps.
3.	The seismic study, and the ensuing project were it to proceed, would impact property that is not subject to the eminent domain power granted by the Federal Power Act.  Specifically, all of the options for the upper reservoir contained in the proposal would involve property that is currently owned by New York State and New York City that meets the description contained in section 21 of the Federal Power Act (16 U.S.C. s. 814): of lands or other property that, prior to October 24, 1992, were owned by a State or political subdivision thereof and were part of or included within any public park, recreation area or wildlife refuge established under State or local law. Such property is ineligible to be taken by a licensee under eminent domain.  In addition, a voluntary transfer of such property by the State would require a constitutional amendment, a very difficult, slow, and rarely successful process. The City of New York has already indicated that it will not allow the study or project to proceed on any City-owned land.
4.	By requiring the reservation of up to 15,800 acre feet out of the Ashokan Reservoir’s total capacity of 382,300 acre feet, the project would permanently reduce the capacity of the Ashokan Reservoir to supply drinking water to New York City by over 4%--the equivalent of drinking water for 360,000 people. This will exacerbate current and future stress on the reservoir’s capacity as a result of climate change and resulting reduction in snow pack.
5.	Based on current industry trends, the proposed project is expected to be highly inefficient compared to lithium-ion battery storage in every dimension including even risk-adjusted cost to the highly sensitive ecosystem:  By the sponsor’s own presumably best-case analysis, the plant would consume 1000 MW of power and only generate 800 MW in each cycle of pumping and release.  This consumes net 200 MW per cycle, which represents 80% efficiency.  By contrast, battery technology is more than 90% efficient today, has a far lower impact on the local ecology, and is already being deployed around the world including in Australia and California.
It is not in the public interest to grant a preliminary permit to a project that is based on inaccurate statements and critical omissions, for a project that would at best be inefficient, legally non-viable, and in fact an open-loop as opposed to a closed-loop system.  There is no reason to allow the applicant to continue to expend its own resources, those of the communities, organizations and governments opposed to the project, and those of FERC itself on such an ill-conceived and fatally flawed project. There is no reason to subject one of the nation’s most critical and protected ecological wildness areas containing the nation’s largest source of unfiltered drinking water to a pointless and impactful study. 

Respectfully submitted,

Stephen A. Cooper
FERC ID #F650311

Sarah Loertscher, Olivebridge, NY.
FERC should deny this application on the basis that Premium Energy's proposed project would violate New York State's constitution (Article 14, section 1).

Furthermore, the America’s Water Infrastructure Act of 2018 does not give priority to projects such as these unless it is "Closed-Loop". Premium Energy's project would NOT be a "Closed-Loop" system, and FERC should treat its application accordingly.

This project poses high risks to environment, public health, ecology, and community. I urge FERC to deny Premium Energy's application. I would also like to request that FERC flag any proposals in the future where applicants intend to use lands that are protected by our state constitution. This would save everyone a lot of grief.

Thank you for considering these comments.


Sarah Loertscher

Bradley Sacks, Phoenicia, NY.
Please accept this comment in opposition to the proposed hydropower dam project. I have been a resident of Woodland Valley, NY for over 30 years and have hiked, backpacked and enjoyed the rivers, streams and trails of the Catskill State Forest Preserve for more than 50 years.  It is my understanding that these lands have been granted special legal protection both as part of the preserve and as the watershed for the New York City drinking water. The forest ecology should not be tampered with for energy infrastructure or generation facilities. The unique habitat accessible via the trailheads within Woodland valley should not be endangered by a project of questionable ecological and economic viability.  It is generally understood that a hydro project, as proposed, is actually a net user of energy and will unavoidably cause ecological degradation.  Pumping water uphill uses more electricity than it generates running downhill. The unique habitat in this section of the Forest Preserve, includes virgin timber stands and other flora, as well as habitat for diverse animals including raptors and bats. I am also a resident of New York City and object to this project because of the probability it will degrade the source of New York City’s unfiltered and world-renowned  drinking water.  The COVID pandemic has again revealed the importance of the Forest Preserve’s wilderness, providing recreational activities in a quiet, safe and clean environment.  The project will permanently de-grade and reduce access to the State Forest trail system and world-renowned fishing streams for short term energy production goals.    This is a time to reinforce not eliminate, the forever wild designation to allow access to this ecological gem for all of us now and in the future.

ILENE Marder Hinchey, Saugerties, NY.
To: Federal Energy Regulatory Commission
      Washington, D.C.

From: Ilene Marder, 31 Old Powder Mill Rd., 
          31 Old Powder Mill Rd.Saugerties NY, 12477; 
          845 399-9034


RE:  Premium Energy Holdings proposedPumped Storage Project at the Ashokan Reservoir, Ulster County NY. Docket # P-15056-000


Commissioners:

I join the thousands of people who have already written in opposition to this poorly reasoned and researched plan to build this project in the Constitutionally protected Catskill Park. 

While I strongly support green energy projects, it cannot be to the extreme detriment of the welfare of people and communities in the region. 
This project is wrong for the surrounding environment and watershed, bad for the economy and tourism, detrimental to the livelihood of thousands of residents, and 
unconscionable in terms of the loss of resident’s homes and businesses. 
To add insult to injury, Premium Energy did not notify local and state officials, the City of New York which controls the reservoir, or local residents and businesses which are devastatingly affected by this “plan” (which barely deserves to be called a plan considering the many errors and complete lack of knowledge of this region contained herein).  

The Catskill Park was granted Constitutional protection for a reason. Please do not abdicate your responsibility to protect the people affected, our natural resources and water supplies, our economies, and this historically important area.

This foolhardy, poorly conceived project appears to represent a fast grab by Premier Energy to get in on the spending surge of renewable energy projects. They didn’t do their homework, they have no apparent expertise, and have been wrong on facts— including placing communities in the wrong counties. 
However, even if their plan was perfect, The Ashokan Reservoir and protected Catskill Park is no place for this project.

Thankyou for your time and consideration.

Sincerely,

Ilene Marder Hinchey
Saugerties, New York, Ulster County
12477

Adam Doan, Highland, NY.
As the organizations who deliver a stream management program in the
Ashokan Reservoir watershed, Cornell Cooperative Extension of Ulster
County and the Ulster County Soil and Water Conservation District are
offering these comments on the Ashokan Pumped Storage Project (P-15056)
proposed by Premium Energy and submitted for a Preliminary Permit
application to the Federal Energy Regulatory Commission.

Our organizations see the following potential concerns related to the project
based in our understanding of stream science:
- The alternative sites for an upper reservoir will dam streams that carry
high loads of coarse sediment (bed load) through steep mountain
valleys. As proposed, the upper reservoir dam will interrupt 100% of
the coarse sediment supply.
- Bed load is needed to re-form stream riffles and other channel
stabilizing features downstream of the reservoir dam. Stream riffles
and other natural channel features armor stream beds against erosion.
Streams located downstream of newly constructed dams are highly
likely to become unstable and erode downward and laterally following
dam construction during a period of adjustment.
- This adjustment period or channel evolution is critical to the stream
returning to an equilibrium state following the disruption to hydrology
and sediment supply caused by dam construction and would likely
occur over a period of decades.
- In addition to downward adjustment of channels, a reduction in stream
flow downstream of a dam can lead to sediment accumulation in the
channel bed triggering stream bank erosion. In accordance with
modern understandings of stream physics confirmed through scientific
study, it can be expected that streams below a newly constructed dam
will undergo erosion and adjustment before a new channel
configuration achieves hydraulic stability (Williams and Wolman, 1984;
Church, 1995; Grant, 2003).
- The Ashokan Watershed’s geology is such that coarse bed load
transported by streams is frequently deposited over relatively deep
deposits of clay sediments that historically formed under glacial lakes.
Channels starved of bed load below a dam would likely erode into
glacial lake clays and substantially increase fine sediment loading to
downstream water bodies, including the Esopus Creek and Ashokan
Reservoir.
- Adjustments to the channel bed and stream bank erosion raise the
following concerns:
1. Banks in this watershed include large hillslopes that are layered
with the glacial lake clays that threaten water quality.
2. Extensive bank erosion could undermine existing public culverts
and bridges located on affected streams.
3. Public roads by necessity are located near or adjacent to streams
in steep mountain valleys and could be undermined.
4. In this heavily forested watershed, bank erosion would likely
increase the supply of large wood to channels, further
contributing to channel instability and threatening public
infrastructure.
5. Private septic systems, buildings, and stream crossings could
similarly be undermined.
- The Upper Esopus Creek and minor tributaries between the Ashokan
Reservoir and Allaben are included on the NYS Section 303(d) List of
Impaired Waters. Water supply and recreational uses are impaired by
silt/sediment. Streambank erosion is the primary source of
silt/sediment, along with a diversion from the Schoharie Reservoir. The
confluences of Woodland Creek and Stony Clove are located within the
portion of Upper Esopus Creek impaired by high levels of turbidity.
Streambank and bed erosion below any upland reservoir could further
contribute to water quality impairment of the Upper Esopus Creek.
- The primary drinking water supply impaired by Upper Esopus Creek
turbidity is the Ashokan Reservoir, which provides approximately 40%
of the drinking water supply to about 9 million New York state
residents.
- Based on observations of similar pumped storage projects in the
region and nationally, the rapid filling and drawdown of the upland
reservoir could result in almost complete loss of native riparian plant
and animal communities bordering the upland reservoir and along
streams for some distance upstream of the reservoir.
- Riparian plant communities that resist bank erosion and provide
unique and valuable wildlife habitat, could be threatened downstream
of the reservoir by extreme changes in the hydrologic regime and
erosion processes as described above.
- The installation of transmission lines could further degrade riparian
areas throughout the watershed.

Since the early 2000s, we have co-delivered the Ashokan Watershed Stream
Management Program (AWSMP) in the 255-square mile Ashokan Reservoir
watershed. The AWSMP has assessed streams and published stream
management plans for the Esopus Creek and most of its major tributaries.
We have assessed conditions in all of the streams proposed for upland
reservoirs by Premium Energy. We are monitoring bank erosion in all
streams affected by this proposal.

Our program focus is on managing and restoring geomorphic channel
stability, sediment transport, riparian cover, aquatic habitat, and floodplain
access. The AWSMP works to restore ecological function to streams by
implementing restoration projects and riparian plantings. We provide
education, funding, and technical support to local communities for applying
stream best management practices to their projects.

Since 2001, the AWSMP has fully assessed over 15 tributaries to the Esopus
Creek and Bush Kill streams and restored geomorphic function to over 2
miles of stream and stabilized over 1.5 acres of hillslope. We have
completed over $2.1 million in projects to restore Woodland Creek and over
$6.1 million to restore the Stony Clove Creek. These projects stabilized large
sections of eroding stream banks and channels, hydrologically reconnected
floodplains, and revegetated riparian areas with Catskill native species. 

For more information please reach out to Adam Doan, UCSWCD and Leslie Zucker, Cornell Cooperative Ext. Ulster Co.

Jane Burd, Elka Park, NY.
To whom it may concern

My family and I are outright against the proposed pumped hydro storage project in Greene and Ulster counties. 
I have lived in the Catskill Park in the Town of Hunter, for over 15 years and see the impact that increased visitors have on the trails and infrastructure of local towns. Creating fake landscapes is diluting and damaging to the identity of a world renowned Park. 
Many not for profit organizations for the Catskill Park diligently offer an educational experience for visitors and assist in strengthening and protecting our First American Park for the good of all.  We are the stewards of the land and protection of our fragile environment is paramount to curb unfavorable development here. As it stands today the Esopus runs brown with turbid waters from the out flow from the Ashokan reservoir having grave effects on spawning grounds of the trout. Now proposing upstream burying land and its natural identity by flooding, makes a false vista and environmental damages that no Hudson River painter ever would want to paint! Fix the existing abuse don’t do more. 
This is a vibrant park with bald eagle, bear, wood turtles and humans that love it and stand to protect its natural beauty. With ever intrusive urban sprawl and the unfathomable pressures for destruction of people’s lives in this delicate sense of place, I say no to this proposal. 
Yours sincerely 
Jane Burd

Gloria Coelho, Big Indian, NY.
I’d like to see this proposal denied!

Laurie Osmond, WILLOW, NY.
The proposed Ashokan Pump Station project is pure insanity.  

This naked, corporate land grab would decimate a large swath of our forever wild Catskills, destroy neighborhoods, blight the environment, harm wildlife, force people from their homes, drive down property values.  

One of America’s most unspoiled and beautiful regions would be exploited and ruined for private profit.

Additionally, New York City’s drinking water supply would be threatened. 

The fact that a proposal like this was allowed to get this far by the Federal government, without the awareness of the towns and entities that it would be endangering, is a travesty and should be investigated.

This project must not be allowed to go forward.

Brett Keyser, Highland Lake, NY.
Kimberly D. Bose

Federal Energy Regulatory Commission 

888 First St. NE, Room 1A

Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing to address the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that the lands under consideration “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index.

Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Premium Energy’s proposal is not a closed-loop system as they claim—-it is in fact an “add-on,” and the water fluctuations would increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are beyond the reach of most.

There is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Brett Keyser

Michael J Flaherty, New Paltz, NY.
Dear FERC:
  I have recently retired from my position with the New York State Department of Environmental Conservation’s Bureau of Fisheries, where I held the position as Region 3 Fisheries Manager since 2006.  Prior to being the Region 3 Fisheries Manager, I was a Senior Aquatic Biologist within the same fisheries unit since 1990.  Since 1990, one of my primary responsibilities for NYS DEC has been the fisheries management and protection of the fisheries resources in the Ashokan Reservoir Watershed.
  I am generally very supportive of the idea of renewable and “clean” energy, but I also am aware that there can still be environmental and societal tradeoffs which render certain projects just not worth the risk.  Some projects are so obviously not worth the money and time involved in studying them, primarily  because the outcomes of these studies are clear enough from the onset.  I believe that proposed Project # 15056 (Ashokan Pump Storage), is one of those projects that should be denied at this point, prior to wasting millions of dollars in agency review and private investments in studies. 
  The Ashokan Reservoir watershed is blessed with an abundance of free-flowing mountain streams.  Nearly all of these streams contain self-sustaining wild trout populations.  In order to continue to sustain themselves, these cool water ecosystems must have a continual source of cool and clean water all year.  Trout and other fish also need to have access to suitable areas to spawn.  Within this watershed there is only one dam that I am aware of.  This is on the Little Beaver Kill and it forms a small lake in Kenneth Wilson State Park.   The other impassable man-made obstruction to trout movement on a main tributary is on Birch Creek, and it has a successful fish ladder installed on it.   If a new dam is created on one of the streams within the watershed, it will undoubtedly result in the loss of trout habitat, including the section of stream above it that has been used for trout spawning.  Water within the new reservoir will also likely be warm in the summer and, even if a minimum release of this water is required to the stream below, would likely change the temperature regime downstream, making it uninhabitable for trout while it is warm.  The quality of this water also would likely be changed based on whatever the water quality of the Ashokan Reservoir happens to be at that time.  It is not uncommon for the water in Ashokan Reservoir to be very turbid. Even if a new reservoir was somehow built to be self-contained and not built by damming a tributary, the footprint of this new waterbody could potentially change the local drainage to the stream by intercepting natural water flow, removing natural vegetation, and increasing erosion. 
  Within Ashokan Reservoir itself, the ecological impacts could be quite profound.  The west basin of Ashokan Reservoir is an important resource for both its function as a human water supply as well as the connected stream ecosystems upstream and downstream.  For water supply purposes, the west basin was designed to slow and contain the water as it comes in, before it enters the larger east basin portion of the reservoir.  This allows for settling of sediment brought in by the upper watershed.  After storm events the turbidity of this water can be extreme and can take months to settle.  If large power generating volumes of water are flushed into the reservoir on a daily basis, this may cause resuspension of sediment and could also disrupt and slow the rate that particles in the water settle.  This could change the usability of the water for water supply purposes and create more turbid releases downstream.  Not only do trout need clean water, but so do other organisms in the reservoir.  The base of the aquatic food chain in the reservoir is phytoplankton.  Turbid water does not allow as much sunlight to penetrate into the water and decreases the biomass of phytoplankton.  Decreased phytoplankton can have a cascading negative effect through the food chain.  Additionally, the zooplankton that feed on phytoplankton are in turn fed on by fish.  These planktivorous fish, including trout, and the fish that trout feed on, use their sight to feed on the zooplankton.  Higher turbidity levels create a more challenging environment for fish to find and feed on zooplankton.  Therefore, increased turbidity in the reservoir affects both the availability of food for fish and decreases their ability to feed on it.  This will slow the growth of fish and can affect their survival.
  Thermal stratification of the reservoir is very important for the survival of trout.  In the late spring, the reservoir will thermally stratify.  This occurs as the surface water is heated by the sun and becomes separated by a thermocline from the cool water below.  The upper heated layer of water can be 20 to 40 feet deep and is called the epilimnion.  The epilimnion is too warm for trout to survive through the summer, so the trout live the summer months below the thermocline in the cooler water.  Depending on the volume and location of where the power generating water is being released in the reservoir, I worry that this could disrupt the thermal stratification of the reservoir and thus threaten some of the cold water habitat available for fish that need it.
  Depending on how the water intake is designed, some fish residing in Ashokan Reservoir could be entrained when the water is pumped up to the storage reservoir.  These fish would likely not make the round trip back to their reservoir of origin alive after experiencing the pressure changes and physical gauntlet of the pumps and turbines.  
  I also am concerned about many other points that have already been made in other comments.
  I sincerely believe this project in the proposed location is a bad idea, and the process of further study and applications should be stopped before any more time and money wasted on this project.
 Sincerely,
 Michael J. Flaherty

Sam Owens, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to express concern in Premium Energy’s flawed proposal to build a hydroelectric power plant/ pump storage facility in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

I understand the need to pursue and develop new hydroelectric projects as our country transitions to a renewable energy infrastructure, but using the protected forests of the Catskills as a staging ground for such projects would be counterproductive, and would undo years of preservation and environmental activism.

Throughout the 19th century, the Catskills were logged for Hemlock to feed the ever growing demand for Tannins from Tanneries in the Northeast. What remains is a forest and ecosystem that has only started to recover from the shortsightedness of man and his thirst for overconsumption. This forest is home to many endangered or rare species that are protected by the state. 

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sam Owens

Kristin Ritter, Lanesville, NY.
I would like to take this opportunity to point out that Premium Energy appears to be completely unware that they are proposing a project in and around an extremely protected state preserve, a Status 1, according to the USGS Gap Analysis. According to the Dept. of Energy's own "Hydropower Vision", "areas with formal protections designated as Status 1 or 2 are avoided for development". As a resident of Lanesville, where one of the resevoirs is proposed, I understand that a portion of the resevoire is on private land, but to that effect, the forest, which includes the rare wildlife that lives within these areas, cannot distinguish between what is state, and what is private land. The impacts of these resevoirs will wreak havoc on stream ecology and the habitats of both land and water wildlife. Please do not allow this study to proceed. We need to keep the Catskills Wild.

Christine Manaker, Hoboken, NJ.
To:
Kimberly D. Bose, Secretary
Office of the Secretary
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426
Docket number P-15056-000



Dear Ms. Bose,
I am writing to urge FERC to decline Premium Energy Holdings’ request for a preliminary permit to build a hydroelectric power plant in New York’s Catskill Mountains. The company’s proposed plan for Ashokan Pumped Storage Project P-15056 would devastate a pristine and protected environment, disrupt and displace local communities, negatively impact the region’s tourism economy, and put at risk a major source of New York City’s drinking water—the Ashokan Reservoir, which provides 40% of the city’s water and is the largest unfiltered water supply in the United States. 

The Catskills Forest Preserve in Ulster County—700,000 acres of continuous wildlife habitat protected under Article XIV of the New York State Constitution—is guaranteed to be “forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Under the USGS Gap Analysis Program, the Catskills Forest Preserve is considered Status 1 land, and according to the Department of Energy’s Hydropower Vision, “areas with formal protections designated as Status 1 or 2 … are avoided for development.” Furthermore, any changes in State Forest Preserves must be passed by constitutional amendment and voted on by two consecutive state-legislature sessions before proceeding to the public in a referendum.

In addition, Premium Energy’s proposal would severely damage (if not destroy) local communities, requiring the seizing of homes and private property via eminent domain—a scenario already experienced by local communities a century ago, when construction of the Ashokan displaced 25 communities and thousands of residents. I grew up in Ulster County, where my family still lives, and spend at least 7 weeks each year just a few miles from the Ashokan. Because the county has a serious housing shortage, with an accompanying jump in real estate prices, residents displaced by the proposed pumped-storage project would have difficulty finding new housing locally. Prices have skyrocketed as a result of surging demand from urbanites seeking vacation homes during the coronavirus pandemic and attracted by the region’s natural beauty and recreational opportunities. 

One must factor in the proposed project’s negative effects on the Catskills region’s growing tourism economy, a $1.6 billion industry that supports some 20,000 jobs (or 17% of employment in the region; as of 2019). Ulster County accounts for 43% of this market. The project would cause severe traffic disruptions to main thoroughfares, including, most likely, to Route 214, a scenic byway and one of only two roads connecting the Catskills’ two main highways (routes 28 and 23A). The town of Phoenicia and the Hunter Mountain resort would be among the communities experiencing these negative effects.  

The proposed project also would limit access to fishing, hiking, and other forms of recreation in the Catskills—major tourism draws—and forever alter the Ashokan’s beautiful landscape, itself the setting for biking, skating, boating, and sunset-watching. My 84-year-old mother regularly and frequently walks at the reservoir, along with other locals and visitors from all over the country and the world.  

Although Premium Energy is attempting to bill this as a closed-loop project, which would be considered for streamlined FERC approval, its proposal to add an upper reservoir to an existing lower one is in actuality an “add-on” project. The proposal’s misrepresentation is certainly a red flag. Such projects tend to result in greater operational impacts than closed-loop projects; pumped-storage upper reservoirs are subject to rapid water fluctuations, which significantly disrupt both land and water habitats. Premium Energy’s project would increase the Ashokan watershed’s turbidity and negatively affect New York City’s drinking water. Altering the sediment regime in Esopus Creek tributaries, the project would result in an altered sediment regime in the Esopus itself—one of the best-known and most vital trout waters in the Catskills (and beyond) and part of New York City’s water supply. 

As we eye more renewable energy sources, the tradeoff must not be environmental and community devastation. We cannot sacrifice vulnerable communities, protected wilderness, and drinking water and other natural resources. The costs are too high. Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Christine Manaker

Other formats

Kathryn M. Carey
  88 Burgher Road
  West Shokan, NY 12494

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy
Holdings to build a hydroelectric power plant in New York’s Catskill
Mountains. I urge the FERC to decline their request for a preliminary
permit for the Ashokan Pumped Storage Project P-15056. This project
would be devastating to the environment, highly disruptive to local
communities, and have a negative impact the purity of New York City’s
drinking water.

I understand that pumped storage and other hydroelectric projects may
play a role in our country’s transition to renewable energy. However,
the pristinely protected forests, streams, and wildlife of Catskill
Forest Preserve must not be sacrificed in the process. Under Article XIV
of the NYS Constitution, it is clearly guaranteed that these lands
“shall be forever kept as wild forest lands. They shall not be leased,
sold or exchanged, or be taken by any corporation, public or private.”
The Preserve unique in that it currently contains 700,000 acres of
continuous wildlife habitat which we should keep intact. The forest
around the proposed sites ranks among the top 1% of forest habitats
region-wide, according to the New York State Forest Condition Index.
There are rare plants and animals throughout the Catskill Forest
Preserve. The Whittenberg Brook site is a location for the rare Three
Birds Orchid (Triphora trianthophora) which is registered in the
Biological and Conservation Database for North America by the New York
Natural Heritage Program, an agency funded by the NYS Department of
Environmental Conservation and The Nature Conservancy. The Orchids as
well as their habitat will be obliterated should this project be
approved. It would be unconscionable to destroy this sacred and
wonderfully preserved land. Such action would set a terrible precedent
for protected lands across the country.

This project would cause environmental devastation due to the
interconnectedness of the Ashokan watershed and its tributaries. Pumped
storage is notorious for wreaking havoc on nearby stream ecology, on
aquatic and land habitats because of rapid fluctuation in water levels.
These rapid fluctuations will alter the sediment regime in connected
tributaries, which has a cascading effect. The Ashokan Pumped Storage
Project would ultimately affect the sediment regime in the Esopus Creek,
one of the Catskills’ most vital trout breeding waters, and one of the
key creeks feeding into the Ashokan Reservoir. The Ashokan Reservoir
supplies 40% of NYC’s water supply, serving 1 billion gallons of water a
day to 9.5 million people. Premium Energy’s proposal is not a
closed-loop system as they claim—it is in fact an “add-on”. As such, the
water fluctuations would no doubt increase turbidity within the Ashokan
and its watershed. The Ashokan Reservoir is the largest unfiltered water
supply in the nation and represents over $1.7 billion of investments
since the 1990s alone. It would be reckless to allow this project to
proceed.

In addition to its negative effects on the environment and water supply,
Premium Energy’s proposal would be deeply damaging to local communities.
Any conceivable upper reservoir site in the Catskill Forest Preserve
would require the seizing of homes and private property via eminent
domain. This process displaced thousands of residents when the Ashokan
was constructed 100 years ago, and this has not been forgotten. There is
currently a housing shortage in Ulster County, and for affordable homes.
Residents displaced by the Ashokan Pumped Storage Project would have
difficulty securing new housing. Beyond the problem of community
displacement, there is also the proposed project’s effect on the
Catskills’ growing tourism economy, which generated 17% of employment in
the Catskill region in 2019, and is a $1.6 billion industry, supporting
roughly 20,000 jobs. Premium Energy’s project would limit access to
hiking, fishing, and other forms of recreation in the Catskills,
decrease the area’s natural beauty, cut off access to skiing and
concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise
dampen tourism in the region, negatively affecting businesses in Ulster
County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped
Storage Project, it must be pointed out that their proposal does not
represent the kind of innovation that the Department of Energy wants to
see. Closed-loop pumped storage projects have smaller environmental
impacts than those that make use of existing watersheds making them
eligible for streamlined FERC approval. In an unethical attempt to get
FERC approval, Premium Energy is falsely claiming this project is a
“closed-loop” system. Premium needs to be honest about what this project
is. It is an “add-on” system, using an existing body of water as a lower
reservoir. This kind of project carries with it significantly higher
risks, especially in this instance, when the lower reservoir is not a
vital source of drinking water for our nation’s largest city. How can we
trust a company that would lie in their proposal simply for the
advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy resources must not
come at the cost of environmental and community devastation. It my
opinion that the Catskill Forest Preserve and communities within the
Blue Line should be off limits to such development. I hope Premium
Energy will be able to find a suitable alternative location for a pumped
storage project—one where the construction and operation will not
destroy protected wilderness, displace vulnerable communities, and
threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a
preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Kathryn M. Carey-Ackermann

Stephen B. Ackermann
  88 Burgher Road
  West Shokan, NY 12494

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy
Holdings to build a hydroelectric power plant in NYS Catskill Mountains.
I urge the FERC to decline their request for a preliminary permit for
the Ashokan Pumped Storage Project P-15056. This project would be
devastating to the environment, highly disruptive to local communities,
and have a negative impact the purity of New York City’s drinking water.

Pumped storage and other hydroelectric projects may play a role in our
country’s transition to renewable energy. However, the pristinely and
protected forests, streams, and wildlife of Catskill Forest Preserve
must not be sacrificed. Under Article XIV of the NYS Constitution, it is
clearly guaranteed that these lands “shall be forever kept as wild
forest lands. They shall not be leased, sold or exchanged, or be taken
by any corporation, public or private.” The Preserve is unique in that
it currently contains 700,000 acres of continuous wildlife habitat which
we should keep intact. The forest around the proposed sites ranks among
the top 1% of forest habitats region-wide, according to the New York
State Forest Condition Index. There are rare plants and animals
throughout the Catskill Forest Preserve. The Whittenberg Brook site is
habitat for the rare Three Birds Orchid (Triphora trianthophora) which
is registered in the Biological and Conservation Database for North
America by the NY Natural Heritage Program, an agency funded by the NYS
Dept. of Environmental Conservation and The Nature Conservancy. The
Orchids as well as their habitat will be obliterated should this project
be approved. It would be unconscionable to destroy this sacred and
wonderfully preserved land. Such action would set a terrible precedent
for protected lands across the country.

This project would cause environmental devastation due to the
interconnectedness of the Ashokan watershed and its tributaries. Pumped
storage is notorious for wreaking havoc on nearby stream ecology, on
aquatic and land habitats because of rapid fluctuation in water levels.
These rapid fluctuations will alter the sediment regime in connected
tributaries, which has a cascading effect. The Ashokan Pumped Storage
Project would ultimately affect the sediment regime in the Esopus Creek,
one of the Catskills’ most vital trout breeding waters, and one of the
key creeks feeding into the Ashokan Reservoir. The Ashokan Reservoir
supplies 40% of NYC’s water supply, serving 1 billion gallons of water a
day to 9.5 million people. Premium Energy’s proposal is not a
closed-loop system as they claim, it is in fact an “add-on”. As such,
water fluctuations would increase turbidity within the Ashokan Reservoir
and watershed. The Ashokan is the largest unfiltered water supply in the
nation. It represents over $1.7 billion of investments since the 1990s.
It would be reckless to allow this project to proceed.

In addition, Premium Energy’s proposal would be deeply damaging to local
communities. Any conceivable upper reservoir site in the Catskill Forest
Preserve would require the seizing of homes and private property via
eminent domain. This process displaced thousands of residents when the
Ashokan was constructed 100 years ago, and this has not been forgotten.
There is currently a housing shortage in Ulster County, and for
affordable homes. Residents displaced by the Ashokan Pumped Storage
Project would have difficulty securing new housing. Beyond the problem
of community displacement, there is also the proposed project’s effect
on the Catskills’ growing tourism economy, which generated 17% of
employment in the Catskill region in 2019, and is a $1.6 billion
industry, supporting roughly 20,000 jobs. Premium Energy’s project would
limit access to hiking, fishing, and other forms of recreation in the
Catskills, decrease the area’s natural beauty, cut off access to skiing
and seasonal programming at Hunter Mountain Ski Center, towns of Hunter
and Tannersville, and otherwise dampen tourism in the region, negatively
affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped
Storage Project, it must be pointed out that their proposal does not
represent the kind of innovation that the Department of Energy wants to
see. Closed-loop pumped storage projects have smaller environmental
impacts than those that make use of existing watersheds making them
eligible for streamlined FERC approval. In an unethical attempt to get
FERC approval, Premium Energy is falsely claiming this project is a
“closed-loop” system. Premium needs to be honest about what this project
is. It is an “add-on” system, using an existing body of water as a lower
reservoir. This kind of project carries with it significantly higher
risks, especially in this instance, when the lower reservoir is not a
vital source of drinking water for our nation’s largest city. How can we
trust a company that would lie in their proposal simply for the
advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy resources must not
come at the cost of environmental and community devastation. It my
opinion that the Catskill Forest Preserve and communities within the
Blue Line should be off limits to such development. I hope Premium
Energy will be able to find a suitable alternative location for a pumped
storage project—one where the construction and operation will not
destroy protected wilderness, displace vulnerable communities, and
threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a
preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Stephen B. Ackermann

FERC COMMENT TEMPLATE

Use the comment template below or parts of it to help in your
submissions. Use these instructions to submit a comment.

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy
Holdings to build a hydroelectric power plant in New York’s Catskill
Mountains. I urge FERC to decline their request for a preliminary permit
for the Ashokan Pumped Storage Project P-15056, as it would be
devastating to the environment, highly disruptive to local communities,
and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric
projects will play a key role in our country’s transition to renewable
energy, the pristinely protected forests, streams, and wildlife of
Catskill Forest Preserve must not be sacrificed in the process. Under
Article XIV of the NYS Constitution, it is clearly guaranteed that these
lands “shall be forever kept as wild forest lands. They shall not be
leased, sold or exchanged, or be taken by any corporation, public or
private.” The Preserve currently contains 700,000 acres of continuous
wildlife habitat (very rare in our increasingly fragmented environment),
and the forest around the proposed sites ranks among the top 1% of
forest habitats region-wide, according to the New York State Forest
Condition Index. It would be a true crime to destroy this sacred and
wonderfully preserved land, and would set a doomed precedent for
protected lands across the country.

Even once construction is complete, there would be further environmental
devastation due to the interconnectedness of the Ashokan watershed and
its tributaries. Pumped storage is notorious for wreaking havoc on
nearby stream ecology and on both aquatic and land habitats, because
within a pumped storage system, the upper reservoir is subject to rapid
fluctuations as the water is pumped up and down. In addition to
affecting wildlife, this can alter the sediment regime in connected
tributaries, which has a cascading effect. The Ashokan Pumped Storage
Project would ultimately affect the sediment regime in the Esopus Creek,
which is one of the Catskills’ most vital trout breeding waters, and one
of the key creeks feeding into the Ashokan Reservoir, which supplies 40%
of NYC’s water supply, serving 1 billion gallons of water a day to 9.5
million people. Plus, Premium Energy’s proposal is not a closed-loop
system as they claim—it is in fact an “add-on,” and the water
fluctuations would no doubt increase turbidity within the Ashokan and
its watershed. Taking all this into account, it would be reckless to
allow a project to proceed that would threaten such a valuable asset as
the Ashokan Reservoir, which is the largest unfiltered water supply in
the nation, and represents over $1.7 billion of investments since the
1990s alone.

In addition to its negative effects on the environment and water supply,
Premium Energy’s proposal would be deeply damaging to local communities.
Any conceivable upper reservoir site in the Catskill Forest Preserve
would require the seizing of homes and private property via eminent
domain—a process that already displaced thousands when the Ashokan was
constructed 100 years ago. Residents displaced by the Ashokan Pumped
Storage Project would likely have a hard time securing new housing, as
there is currently a housing shortage in Ulster County, and for homes
that are available, prices are through the roof. Beyond the problem of
community displacement, there is also the proposed project’s effect on
the Catskills’ growing tourism economy, which generated 17% of
employment in the Catskill region in 2019, and is a $1.6 billion
industry, supporting roughly 20,000 jobs. Premium Energy’s project would
limit access to hiking, fishing, and other forms of recreation in the
Catskills, decrease the area’s natural beauty, cut off access to skiing
and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise
dampen tourism in the region, negatively affecting businesses in Ulster
County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped
Storage Project, it must be pointed out that their proposal does not
even represent the kind of innovation that the Department of Energy
wants to see. Closed-loop pumped storage projects have smaller
environmental impacts than those that make use of existing watersheds,
and are thus eligible for streamlined FERC approval. This is why Premium
is claiming this project to be “closed-loop” rather than being honest
about what their project actually is: an “add-on,” using an existing
body of water as a lower reservoir. This kind of project carries with it
significantly higher risks, even when the lower reservoir is not a vital
source of drinking water for our nation’s largest city. How can we trust
a company that would lie in their proposal simply for the advantage of
being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not
come at the cost of environmental and community devastation. I hope
Premium Energy will be able to find a suitable alternative location for
a pumped storage project—one where the construction and operation will
not destroy protected wilderness, displace vulnerable communities, and
threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a
preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely

Carrie Garfinkel

4/10/2021

  Kimberly D. Bose, Secretary 

  Federal Energy Regulatory Commission 

  888 First Street, NE, Room 1A, 

  Washington, DC 20426 

  Re: DOCKET P-15056-000 

  MOTION TO INTERVENE of Jennifer Christie for the Premium Energy
  Holdings, LLC, Project No. 15056

  Dear Secretary Bose, 

This correspondence is in direct response to the Federal Energy
Regulatory Commission (FERC) proposed PROJECT NO. 15056-000, Ashokan
Pumped Storage Project, submitted by Premium Energy Holdings LLC,
Walnut, CA. Jennifer Christie is filing a motion to be an intervener and
meets the requirements of 18 CFR 385.214 of the Commission’s regulations
to be granted full party status. 

The basis for intervening is due to the proposed location of the project
Project No. 15056-000 the proposed project path of the tunnel would
directly go under our property endangering our access to clean water for
our family and substantially affect the property value of our home and
investment properties that support our retirement. Therefore, I have
substantial interest in the matter. I reside on 18 Silver Hollow,
Chichester, NY.  

Jennifer Christie respectfully requests that the Federal Energy
Regulatory Commission grant this motion to intervene. 

  Respectfully, 

  Jennifer Christie

  18 Silver Hollow, Chichester, NY 12416

4/10/2021

  Kimberly D. Bose, Secretary 

  Federal Energy Regulatory Commission 

  888 First Street, NE, Room 1A, 

  Washington, DC 20426 

  Re: DOCKET P-15056-000 

  MOTION TO INTERVENE of Melissa Rabuffo for the Premium Energy
  Holdings, LLC, Project No. 15056

  Dear Secretary Bose, 

This correspondence is in direct response to the Federal Energy
Regulatory Commission (FERC) proposed PROJECT NO. 15056-000, Ashokan
Pumped Storage Project, submitted by Premium Energy Holdings LLC,
Walnut, CA. Jennifer Christie is filing a motion to be an intervener and
meets the requirements of 18 CFR 385.214 of the Commission’s regulations
to be granted full party status. 

The basis for intervening is due to the proposed location of the project
Project No. 15056-000 the proposed project path of the tunnel would
directly go under our property endangering our access to clean water for
our family and substantially affect the property value of our home and
investment properties that support our retirement. Therefore, I have
substantial interest in the matter. I reside on 18 Silver Hollow,
Chichester, NY.  

Melissa Rabuffo respectfully requests that the Federal Energy Regulatory
Commission grant this motion to intervene. 

  Respectfully, 

  Jennifer Christie

  18 Silver Hollow, Chichester, NY 12416

Chester Karwatowski

111 High Point Mountain Road

West Shokan, NY 12494

April 8, 2021

RE: FERC Docket # P-15056 – Ashokan Pumped Storage Project

Dear Ms. Bose,

I am writing to voice strong opposition to Docket P-15056, the Ashokan
Pumped Storage Project submitted by Premium Energy Holding, LLC. I
request that you deny this preliminary permit application immediately.

As a resident and small business owner in West Shokan for over 30 years,
I will be directly impacted by the proposed project throughout the
proposal and development phases as well as during ongoing operations.
Our B&B, Ashokan Dreams, overlooks the west basin of the Ashokan
Reservoir. We start and end each day looking out over the entire length
of the upper basin of this reservoir from the Esopus Creek to the
dividing weir. Our B&B is housed in a barn built by the Eckert Brothers
in 1820. The Eckerts built 2 barns, this one survived, the other one was
destroyed for the building of the Ashokan Reservoir. We have a fishing
boat on the Ashokan Reservoir in West Shokan as do hundreds of other
residents who frequently and safely use the Reservoir for fishing. The
proposed infrastructure development and power lines will be visible and
impact and harm not only our business and community, but all visitors to
the new Ashokan Rail Trail (ART) which runs directly along the north
eastern shore of the Ashokan Reservoir. There were over 200,000 visitors
to the ART in 2020.

I understand that FERC does not normally deny a preliminary permit, but
this applicant has not met a minimum standard to achieve legal and
regulatory approvals, nor to deal with environmental issues their
proposal will create, nor have they presented a design that is realistic
nor that meets modern design best practices for a closed loop pump
storage system. I also understand that the impact to my property value,
to my personal quality of life and experiences or my safety or the
safety of the community, as well as the disruptions to my business,
visitors and the community that has been disrupted for over 100 years by
the building and operations of the current Ashokan Reservoir, does not
warrant stopping this proposal at this phase but I appreciate your
consideration of these issues.
In addition to being a resident of this community for over 40 years, I
am also a board member of the Ashokan-Pepacton Watershed Chapter of
Trout Unlimited, an Intervenor in this process along with the NY State
Council of Trout Unlimited (TU). TU is committed to conserving,
protecting, and restoring cold water fisheries and their ecosystems. I
am also an Executive Committee member of the Ashokan Watershed Stream
Management Plan (AWSMP) Stakeholder Council. This organization delivers
stream management programs in the Ashokan Reservoir watershed in
accordance with the Watershed Memorandum of Agreement and the Filtration
Avoidance Determination for the NYC Water Supply. These activities and
experiences inform my understanding of the environmental and regulatory
issues this project proposal presents and therefore I offer my comments.

A legal review of this proposal, a proposal that depends upon the taking
of NYS Forest Preserve Lands that are protected by the NYS Constitution
and the use and taking of NYC Watershed lands that are also protected
and regulated, appears to present insurmountable legal hurdles. Adding
the need for DEC permitting of operations that will disrupt the already
fragile geological structures of this region and the known issues with
glacial clays, and thereby disrupt and harm the wild fisheries and the
water supply for 9 million people demonstrates that that this is a
poorly conceived proposal that should not be allowed to proceed at this
phase by the precedents established by FERC. A review of the failed
Prattsville Pumped Storage Project, No. 2729 on the NYC Schoharie
Reservoir in the Catskills illuminates the issues and the probabilities
of receiving needed permits within a critical water supply ecosystem.
One of the most significant ecological and health risks in this Water
Supply is turbidity. Turbidity is a product of the geology of the
Catskills. It is insurmountable and has been a product of the erosive
formation of the Catskills over the last 10,000 years. Introducing more
turbidity or disrupting the natural cycles of turbidity will affect not
only the environment and fisheries, but also the NYC water supply and
potentially the water supplies of communities dependent upon the Hudson
River. The management of this unfiltered water supply is guided by the
NYC Memorandum of Agreement with the EPA, NYS and watershed communities
and now monitored by the NYS DOH. That MOA created a set of Filtration
Avoidance Determination obligations, and the most significant management
issue for water quality is turbidity. The applicant has not considered
any of this in their Project Proposal. A review of the National
Academies of Sciences, Engineering and Medicine reports from 2000, 2010
and 2020 highlight the challenges and requirements for the watershed
wide management of this critical water supply ecosystem to avoid water
supply filtration and its costs.

From the National Academies of Sciences, Engineering and Medicine
report "Watershed Management for Potable Water Supply: Assessing the New
York City Strategy" (2000), p.88.
"The Watershed Rules and Regulations of the New York City Memorandum of
Agreement (MOA) are among the most comprehensive and detailed
regulations regarding watershed activities found in this country.
However, they cannot be considered in isolation given the large number
of federal, state, and local statutes and regulations with which New
York City must comply. This chapter briefly describes the initial
impetus for the creation of environmental regulations relating to
drinking water, it outlines certain federal regulations that pertain to
the New York City drinking water supply, and it describes how the MOA
attempts to fill gaps between federal, state, and local environmental
regulations." ….
"Although watershed management is important for any surface water
supply, it is critical for an unfiltered supply. The MOA is a remarkable
document and a significant milestone in the City’s water supply and the
region’s development. Successful implementation of the MOA is the most
important challenge facing the City’s water supply managers. " There was
no analysis by the applicant of how this pump storage proposal will
affect the current predictive models for water supply operations which
will impact water supply quality or quantity and potentially impact
community safety by disrupting the flood control component of water
supply management. This will affect communities downstream of the
Ashokan Reservoir, all the way to the Hudson River, and potentially
affect the communities the use the Hudson River for their water
supplies.
The alternative sites for an upper reservoir will dam streams that carry
high loads of coarse sediment (bed load) through steep mountain valleys.
As proposed, the upper reservoir dams will interrupt 100% of the coarse
sediment supply. Bed load is needed to re-form stream riffles and other
channel stabilizing features downstream of the reservoir dam. Stream
riffles and other natural channel features armor stream beds against
erosion. Streams located downstream of newly constructed dams are highly
likely to become unstable and erode downward and laterally following dam
construction during a period of adjustment. This adjustment period or
channel evolution is critical to the stream returning to an equilibrium
state following the disruption to hydrology and sediment supply caused
by dam construction and would likely occur over a period of decades. In
addition to downward adjustment of channels, a reduction in stream flow
downstream of a dam can lead to sediment accumulation in the channel bed
triggering stream bank erosion. In accordance with modern understandings
of stream physics confirmed through scientific study, it can be expected
that streams below a newly constructed dam will undergo erosion and
adjustment before a new channel configuration achieves hydraulic
stability (Williams and Wolman, 1984; Church, 1995; Grant, 2003). The
Ashokan Watershed’s geology is such that coarse bed load transported by
streams is frequently deposited over relatively deep deposits of clay
sediments that historically formed under glacial lakes. Channels starved
of bed load below a dam would likely erode into glacial lake clays and
substantially increase fine sediment loading to downstream water bodies,
including the Esopus Creek and Ashokan Reservoir. Adjustments to the
channel bed and stream bank erosion raise the following concerns:

1)  Banks in this watershed include large hillslopes that are layered
    with the glacial lake clays that threaten water quality.

2)  Extensive bank erosion could undermine existing public culverts and
    bridges located on affected streams.

3)  Public roads by necessity are located near or adjacent to streams in
    steep mountain valleys and could be undermined.

4)  In this heavily forested watershed, bank erosion would likely
    increase the supply of large wood to channels, further contributing
    to channel instability and threatening public infrastructure.

5)  Private septic systems, buildings, and stream crossings could
    similarly be undermined.

The Upper Esopus Creek and minor tributaries between the Ashokan
Reservoir and Allaben are included on the NYS Section 303(d) List of
Impaired Waters. The NYC water supply, aquatic invertebrates, and
fishes, as well as recreational uses will be impaired by this increased
turbidity, silt and sediment. The upper pumped storage reservoir will
also disconnect spawning trout from upstream habitat and interrupt the
cold water wild trout needed to survive downstream of the new upper
storage reservoir.
Additionally, any waters pumped from the Ashokan Reservoir into the
upper pumped storage reservoir could significantly impact the existing
fragile ecosystems of the headwater tributaries:

1)  The pump water in the upper reservoir could introduce two
    significant pollutant into the fragile ecosystem and especially the
    downstream stream: warm water, and turbid water. Water pumped up to
    the new reservoir from the Ashokan will be significantly warmer than
    the ambient water temperatures and will be significantly more
    turbid. Any release into the downstream reaches would require SPEDES
    Permit from the DEC.

2)  Pumping water from the Ashokan Reservoir into the upper pumped
    storage reservoir can also introduce non-native species of fishes
    and organisms into the upstream and downstream ecosystem of that
    upper reservoir.

3)  Unique heritage strains of wild brook trout populations that have
    been compromised and reduced until they can only be found in
    isolated headwater streams, will be at risk due to these pumping
    operations into headwater areas.

A review of the alternative sites for pumping and discharge
infrastructure in the Ashokan Reservoir as proposed indicate a poor
understanding of the Ashokan Reservoir upper basin water levels,
topography, and existing land use. The elevation of the upper basin
historically ranges from 594.84 feet above sea level to 530.56 feet
above sea level. Although the highest reservoir level is managed for dam
and community safety, and operated to provide a continuous water supply,
the lowest levels in the reservoir are dictated by natural
precipitation. Climate change will also have a significant impact on
these reservoir levels in the future. In 5 of the last 6 years the upper
basin of the Ashokan Reservoir has fallen below an elevation of 570 feet
above sea level. Based upon the proposal for a western bank pump
operation, it appears that the terminus of that operation would have to
be hundreds of yards away from the western shoreline. Having pump and
discharge operations below 570 feet will have a dramatic impact on
sediment movement in the reservoir and affect the delicate balance of
the thermocline in summer months. These operations could also create
other nonlinear disruptions that would result in seiches waves and would
further disrupt turbidity in the reservoir. A constant turbid state in
the Ashokan from operation of this project will adversely impact both
zooplankton and therefore affect the wild rainbow trout population. The
interconnection of the Ashokan Reservoir and Esopus Creek fisheries has
long been recognized. Recently the NYS Department of Environmental
Conservation reclassified the Esopus Creek as a Wild-Quality stream,
under their newly approved Trout Management Plan. Locating the pumping
and discharge infrastructure on the North Eastern side of the Upper
Basin of the Ashokan Reservoir pose other unique issues. The Ashokan
Rail Trail, a linear park on Ulster County lands that pass-through NYC
Lands, runs along the entire shoreline where this alternative pump
infrastructure is proposed. With over 200,000 visitors in 2020, any
construction in this area will pose both another legal challenge and
significantly impact regional tourism.

Residents of Ulster County depend upon NYC DEP to provide Dam Safety and
Flood mitigation services. The applicant would need significant
coordination with NYC DEP and Reservoir Operations to continue to ensure
flood mitigation and safety to downstream residents of their upper
reservoir, but also as a part of the Ashokan Reservoir flood control
processes. The applicant must be responsible to ensure Dam Safety as
guided by FERC. The applicant would also have to provide Security and
Safety to the 9 million water supply customer against any terrorist
threats to the water supply commensurate to the efforts provided by the
NYC Water Supply Police and the NYC DEP.

As argued by the NYC DEP and based upon analysis of many environmental
experts, this application should be denied at this point in the process.
There are many fatal flaws in the Project Proposal including a lack of
site-specific considerations for very significant regulatory, legal,
environmental, safety and water supply requirements. Coordination of
system wide operational management, predictive modeling and planning,
Flood control and other environmental and regulatory requirements are
critical to operate within a water supply ecosystem.

Therefore, for all these reasons, I urge you to reject Premium Energy
Holding’s proposed preliminary application for Docket P-15056 for the
Ashokan Pumped Storage Project.

Respectfully,

Chester Karwatowski
References:

Church, M. 1995. Geomorphic response to river flow regulation: case
studies and timescales. Regulated Rivers 11: 3–22.

Grant, G.E., Schmidt, J.C., and Lewis, S.L. 2003. A geological framework
for interpreting downstream effects of dams on rivers. In O’Connor, J.E.
and Grant, G.E., editors. A Peculiar River. American Geophysical Union,
Water Science and Applications 7, pp. 203–219.

Williams, G.P. and Wolman, M.G. 1984. Downstream Effects of Dams on
Alluvial Rivers. United States Geological Survey, Professional Paper
1286.

Davis, Dans, Knuepfer, Peter L.K., Miller, Nicolas, and Vian, Mark.
2009. Fluvial Geomorphology of the Upper Esopus Creek Watershed and
Implications for Stream Management.

National Academies of Sciences, Engineering and Medicine reports dated
2000, 2010, 2020. "Watershed Management for Potable Water Supply:
Assessing the New York City Strategy"

Dear Secretary Bose,

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR
Section 385.314) Leonard Navarro and Amy Blackman hereby petition the
Federal Energy Regulatory Commission to grant them full party status in
the above-captioned proceeding (Premium Energy Holdings, LLC Project No.
15056-000).

The persons to whom communications should be addressed and to whom
service should be made are as follows: Leonard Navarro and Amy Blackman
– 23 Hickory Rd, Willow, NY 12495.

As grounds for this motion, we submit the following: Leonard Navarro and
Amy Blackman live within the geographic area affected by the proposed
projects. Ramifications of the proposed project affects the roads,
transportation, recreational activities and future risks to schools
within their community.

Leonard Navarro and Amy Blackman

4/10/2021

  Kimberly D. Bose, Secretary 

  Federal Energy Regulatory Commission 

  888 First Street, NE, Room 1A, 

  Washington, DC 20426 

  Re: DOCKET P-15056-000 

  MOTION TO INTERVENE of Melissa Rabuffo for the Premium Energy
  Holdings, LLC, Project No. 15056

  Dear Secretary Bose, 

This correspondence is in direct response to the Federal Energy
Regulatory Commission (FERC) proposed PROJECT NO. 15056-000, Ashokan
Pumped Storage Project, submitted by Premium Energy Holdings LLC,
Walnut, CA. Melissa Rabuffo is filing a motion to be an intervener and
meets the requirements of 18 CFR 385.214 of the Commission’s regulations
to be granted full party status. 

The basis for intervening is due to the proposed location of the project
Project No. 15056-000 would affect our business and the project path of
the tunnel would directly go under our property endangering our access
to clean water for our family and substantially affect the property
value of our home. Therefore, I have substantial interest in the matter.
I reside on 59 Cinder Road, Chichester, NY.  

Melissa Rabuffo respectfully requests that the Federal Energy Regulatory
Commission grant this motion to intervene. 

  Respectfully, 

  Melissa Rabuffo

  59 Cinder Road, Chichester, NY 12416

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to you as a resident of Lanesville whose historic house
sits right in the middle of one of the proposed sites and a local
business owner in response to the deeply flawed proposal by Premium
Energy Holdings to build a hydroelectric power plant in New York’s
Catskill Mountains. I urge FERC to decline their request for a
preliminary permit for the Ashokan Pumped Storage Project P-15056, as it
would be devastating to the environment, highly disruptive to local
communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric
projects will play a key role in our country’s transition to renewable
energy, the pristinely protected forests, streams, and wildlife of
Catskill Forest Preserve must not be sacrificed in the process. Under
Article XIV of the NYS Constitution, it is clearly guaranteed that these
lands “shall be forever kept as wild forest lands. They shall not be
leased, sold or exchanged, or be taken by any corporation, public or
private.” The Preserve currently contains 700,000 acres of continuous
wildlife habitat (very rare in our increasingly fragmented environment),
and the forest around the proposed sites ranks among the top 1% of
forest habitats region-wide, according to the New York State Forest
Condition Index. It would be a true crime to destroy this sacred and
wonderfully preserved land, and would set a doomed precedent for
protected lands across the country.

Even once construction is complete, there would be further environmental
devastation due to the interconnectedness of the Ashokan watershed and
its tributaries. Pumped storage is notorious for wreaking havoc on
nearby stream ecology and on both aquatic and land habitats, because
within a pumped storage system, the upper reservoir is subject to rapid
fluctuations as the water is pumped up and down. In addition to
affecting wildlife, this can alter the sediment regime in connected
tributaries, which has a cascading effect. The Ashokan Pumped Storage
Project would ultimately affect the sediment regime in the Esopus Creek,
which is one of the Catskills’ most vital trout breeding waters, and one
of the key creeks feeding into the Ashokan Reservoir, which supplies 40%
of NYC’s water supply, serving 1 billion gallons of water a day to 9.5
million people. Plus, Premium Energy’s proposal is not a closed-loop
system as they claim—it is in fact an “add-on,” and the water
fluctuations would no doubt increase turbidity within the Ashokan and
its watershed. Taking all this into account, it would be reckless to
allow a project to proceed that would threaten such a valuable asset as
the Ashokan Reservoir, which is the largest unfiltered water supply in
the nation, and represents over $1.7 billion of investments since the
1990s alone.

In addition to its negative effects on the environment and water supply,
Premium Energy’s proposal would be deeply damaging to local communities.
Any conceivable upper reservoir site in the Catskill Forest Preserve
would require the seizing of homes and private property via eminent
domain—a process that already displaced thousands when the Ashokan was
constructed 100 years ago. Residents displaced by the Ashokan Pumped
Storage Project would likely have a hard time securing new housing, as
there is currently a housing shortage in Ulster County, and for homes
that are available, prices are through the roof. Beyond the problem of
community displacement, there is also the proposed project’s effect on
the Catskills’ growing tourism economy, which generated 17% of
employment in the Catskill region in 2019, and is a $1.6 billion
industry, supporting roughly 20,000 jobs. Premium Energy’s project would
limit access to hiking, fishing, and other forms of recreation in the
Catskills, decrease the area’s natural beauty, cut off access to skiing
and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise
dampen tourism in the region, negatively affecting businesses in Ulster
County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped
Storage Project, it must be pointed out that their proposal does not
even represent the kind of innovation that the Department of Energy
wants to see. Closed-loop pumped storage projects have smaller
environmental impacts than those that make use of existing watersheds,
and are thus eligible for streamlined FERC approval. This is why Premium
is claiming this project to be “closed-loop” rather than being honest
about what their project actually is: an “add-on,” using an existing
body of water as a lower reservoir. This kind of project carries with it
significantly higher risks, even when the lower reservoir is not a vital
source of drinking water for our nation’s largest city. How can we trust
a company that would lie in their proposal simply for the advantage of
being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not
come at the cost of environmental and community devastation. I hope
Premium Energy will be able to find a suitable alternative location for
a pumped storage project—one where the construction and operation will
not destroy protected wilderness, displace vulnerable communities, and
threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a
preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

David Schneider

New York Chapter of Backcountry Hunters & Anglers

_“The sportsmen’s voice for our wild public lands, waters and wildlife”_

www.backcountryhunters.org

  April 11, 2021

_ONLINE SUBMISSION_

Ms. Kimberly Bose, Secretary

Federal Energy Regulatory Commission

888 First Street NE

Washington DC 20426

RE: COMMENTS

  DOCKET # P-15056 – ASHOKAN PUMPED STORAGE PROJECT

Dear Secretary Bose:

On behalf of the New York Chapter of Backcountry Hunters & Anglers (“NY
BHA”), a dedicated group of conservation-minded hunters and anglers in
the Catskills region and more broadly, the State of New York, we write
with respect to the Preliminary Permit application submitted to the
Commission by Premium Energy Holdings (“PEH”) for the Ashokan Pumped
Storage Project (P-15056) (the “Project”). In particular, NY BHA intends
to convey our concerns about the potential negative impacts that the
Project will have on the Ashoken Reservoir and Esopus Creek watersheds,
as well as other sensitive Catskills resources important to the hunting
and angling community in this geographic area.

NY BHA is focused on advancing proven approaches to conserving wild
places and rich outdoor heritage. We strive to shine a positive light on
American wildlife and land conservation. New York has a strong history
of conservation, as well as some of the best hunting and fishing in
North America. NY BHA aims to carry on that legacy by providing bold,
science-driven conservation leadership led by hunters and anglers, and
to benefit residents of New York and beyond. To ensure high-quality
wildlife habitat, we stand for proper, sustainable management and
protection of the lands and waters that give New Yorkers the opportunity
to peacefully cast a fly to sipping trout or slip through the November
deer woods.

As a nonprofit organization with approximately 1,000 members in New York
State, many of which who reside in the Catskill Mountains, NY BHA has
numerous concerns regarding the potential negative impacts from the
Project. The Ashokan Reservoir and Esopus Creek watershed are noted cold
water fisheries important to the angling community. Additionally, the
surrounding lands are pristine habitat for flora and fauna (including
deer, bear, turkey and other game species) that act as a key piece of
the fishery ecosystem. These resources are important to the hunting and
angling community and thus, NY BHA has a special interest in their
preservation.

CATSKILL PARK

The Project lies within the “blue line” of the Catskill region of New
York. Catskill Park lies within this blue line, which are protected
lands designated as “forever wild” under the New York State
Constitution. Before the turn of the last century, New York State wisely
set aside certain areas of state forest land from industrial and
large-scale commercial development as part of the state constitution.
NYS Const. Art. XIV.

The PEH project would require a taking under eminent domain. Assuming
its permit application were granted, a threshold issue PEH will face is
whether such a taking is legally possible. In a case involving a FERC
certificate issued under the Natural Gas Act (“NGA”), the Third Circuit
Court of Appeals held that under the Eleventh Amendment a state’s
sovereign immunity prevents a private party from forcing the state into
court to enforce a condemnation order to seize state land. _In re
PennEast Pipeline Co._, 938 F.3d 96 (3d Cir. 2019). The Supreme Court
has granted certiorari and will hear arguments this month. Even if the
Court overturns the Third Circuit, this can only resolve the threshold
issue of whether the courts will even hear the case and not whether the
pipeline owner will prevail. The proposed “taking” by PEH would be much
more extensive than simply providing a right of way for a pipeline
across state land at issue in _PennEast_. More significantly, PEH would
need to condemn land protected under a state constitution which may
raise a host of constitutional issues.

PROJECT IMPACTS

The trout streams of the Catskills are revered among fishermen across
the nation as the birthplace of American Fly Fishing. Further, the
Esopus watershed has been established as a historical and recreational
treasure of the Catskills that continues to attract thousands of
anglers, hikers, birders and hunters every year, benefitting local
businesses of all types. As an angling and hunting organization, NY BHA
is very concerned with the health of the trout that inhabit the Esopus
Creek. Water quality is the single most important element for a healthy
trout population. Trout require very clean, cold, well-oxygenated water,
and their current population in the Esopus indicates a high quality
stream for all forms life in the ecosystem. By the same token, trout are
very sensitive to habitat degradation. As it is, every year the
ecosystem of the Esopus is stressed with problems of maintaining cold
temperatures and adequate water levels during the hot summer months and
the negative impacts from a project of this size clearly threatens to
significantly alter this precious habitat.

Construction of the facility is incompatible with largely undisturbed
forest preserve provided by the Catskills Park. Based on PEH’s First
Amended Permit, any of the three proposals would require the delivery of
many thousands of tons of concrete and steel through the Park to
construct the impoundment dams, tunnels and halls for turbines and
transformers. More than 100 million cubic feet of rock and soil will
need to be excavated and transported out of the park. With the exception
of the construction of New York City’s water reservoirs, no construction
on this scale has occurred within the Catskills.

The operation phase of the Project would have a significant impact on
protected waterways. The PEH facility will continuously degrade the
aquatic ecosystem of the Esopus Creek, which is a “natural waterway”
that was impounded to create the Ashokan. Operating the PEH facility
will also change groundwater flows, eliminating at least one tributary
to the Esopus. We expect numerous species a flora and fauna may be
negatively impacted by operation of the PEH facility, including without
limitation, the trout.

Operating the PEH facility will also endanger the water supply for
millions. The Ashokan is the largest reservoir in the NYC water supply
system. By maintaining an undisturbed watershed around its reservoirs,
New York City has created a high quality water supply for its residents.
Even so, silt has been an issue for the Ashokan resulting in turbid
discharges into the Esopus Creek. For over 100 years, the West Basin has
served as a settling pond for water entering the reservoir; silt drops
from suspension before flowing over a weir into the East Basin where the
City’s intake port is located. A study of water years from 2010 to 2012
found between 30,000 and 600,000 tons of silt flowed into the West Basin
annually. Even assuming the average year’s silt load is 100,000 tons per
year, after 100 years of operation there are 10 million tons of silt
resting on the bottom of the West Basin. PEH estimates it will pump
15,800 acre-ft of water into and out from the West Basin on a daily
basis. Disturbance of the West Basin will no doubt re-suspend
accumulated silt, impacting the ability of the West Basin to absorb
incoming silt and consequently, potentially causing higher temperatures
and turbidity with the releases into the Esopus Creek.

Based upon the application materials provided, NY BHA identifies
potential negative impacts to the following: water quality; fish,
insect, wildlife and habitat; numerous intermittent streams and
wetlands; and historical and recreational preservation.

CONCLUSION

 

NY BHA, by this letter, presents some significant issues that concern
our members regarding this Project. Due to the numerous foreseeable
negative impacts mentioned above, the continued preservation of one of
the most unique cultural and recreational resources in the Catskills is
in serious jeopardy. Any negative impacts to the trout habitat and/or
the diverse ecosystems on the Ashoken and Esopus watershed will have
far-reaching effects for fishing and hunting, and the many aspects of
the local economy related to it, in this portion of the Catskills.

NY BHA recognizes the need for energy storage alternatives. Adequate
capacity to store energy generated by renewable, but intermitted,
sources makes alternative energy more economically viable. However, such
development can, and must, be undertaken in a thoughtful, responsible
manner that does not jeopardize the tremendous natural resources that
make the this portion of the Catskills so special, unique, and
environmentally and economically important. A project on the scale
proposed by PEH is incompatible with the Catskill region and any
proposed development which cannot be undertaken without such negative
impacts, should not be allowed to proceed. Thus, we respectfully request
that FERC deny the pending Permit application and this proposed Project.

Thank you for your considerations.

  Very truly yours,

  [johns signature]

  John L. Barone

  NY BHA Board Member

Jacqueline Kuhls, Bronx, NY.
The proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains is deeply flawed. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The watershed area is also a critical source of drinking water for the City of New York.  Planning for double use of this water is risky for the reliability of both the drinking water and for energy planning.
The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

The proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city.

I urge FERC to decline this request.

pip merrick, phoenicia, NY.

The Premium proposal states that excess water from the proposed upper reservoir ( Woodland Valley) would be discharged to the Woodland Creek.  I am concerned  this 'excess of water' could tragically impact the area during a  flood. 

 Could you tell me the quantity of water that Premium intends to  discharge per hour?

There have been 11 major floods between 1933 and 2011.  I have lived in Phoenicia and witnessed the floods of 1980.1987,2005, 2010,2011.

In the spring of 1980 I was renting a house on the Esopus and watched as the water flowed over the nearby bridge.  When I returned to my house, water had filled 2 feet of the first floor.

In the fall of 2011, I was interested in buying a house on the Esopus.  During the flood a picture was taken. The house was enveloped in water with only the chimney sticking out.  Of course, the house was ruined and the property lost the backyard to the Esopus. 

I doesn't take much imagination to recognize that if a large body of water increases in size due to quick spring thaws, days of rain, hurricanes,etc, the discharge from the reservoir will add to the flooding problems of the already swollen tributaries.

Patricia Reed, West Hurley, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am deeply disturbed by the proposal Premium Energy Holdings has made to build a hydroelectric power plant, Ashokan Pumped Storage Project P-15056, in New York’s Catskill Mountains. This would be a devastating assault on the environment, on personal properties, on the exquisite way of life The Catskills offer, and on NYC drinking water. It is completely unacceptable I urge FERC to decline their request for a preliminary permit.

I’m certain you have received numerous science-based reports detailing the negative effects of a project like this one so I will not repeat what has been submitted. As a resident of the area I am disgusted by even the idea that a company would ravage these beautiful Catskill Mountains, displace homeowners, and ignore the will of the people all for monetary gain.
 
We are at an important juncture in our life on this planet and if companies do not start making better, ecological and ethical decisions in how they conduct business this planet will not survive, and neither will my grandchildren. 

We must transition to renewable, green-energy sources. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

It's in your hands Ms. Bose! Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Patricia Reed

Claudia Kuhn, Woodstock, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project will take away from the wilderness and places used for recreation and is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Maxwell Hegley, Staatsburg, NY.
Hello,
I am writing today as a very concerned resident of New York State. The proposal to build a dam, reservoir and hydro electric power plant in the Catskills Forest Preserve is a dangerous and unwelcome project. It would effect the surrounding area and eco system of the Hudson Valley in a very scary way not to mention risk community displacement for folks living on private property near the proposed dam/plant. It would also directly effect the NYC water supply to over 9.5 million residents. As someone who has spent his whole life in the state of New York admiring its beauty and resilience I can’t help but feel I must speak up against any injustice that would be done to this state and it’s natural wonder. This proposal is dangerous and risky and should not be approved. I hope you hear our pleas and reject it. 
Thank you,
Maxwell Hegley

Brian Shultis, Freehold, NJ.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Brian Shultis

Terry Kolb, West Shokan, NY.
Being a resident of both New York City and West Shokan, I stand in firm opposition to Premium Energy Holdings’ ill-conceived proposal for a Preliminary Permit for the Ashokan Pumped Storage Project, FERC Project No. 15056 - a proposal which would have a serious negative impact on both communities.  

The Ashokan Reservoir was built over 100 years ago for the sole purpose of providing drinking water for NYC and now provides 40% of the drinking water for its 9.5 million people.  Subsequently, the streams that flow into it are strictly monitored and protected, as are the surrounding lands and forests so as not to disrupt NYC’s water quality and quantity.  Premium Energy Holdings’ proposal to build a hydroelectric pump station in the upper basin of the Ashokan Reservoir would violate strict regulations of the surrounding land and water use.  It would increase turbidity in both the streams and reservoir, thus negatively impacting the drinking water for over  9.5  million people in the City of New York. 


The building of this reservoir over 100 years ago destroyed 12 towns and displaced 1000’s of people.  Now, Premium Energy Holdings’ proposal to build a hydroelectric pump station in the Ashokan Reservoir, along with tunnels, dams, turbines and additional reservoirs, would again displace and/or destroy surrounding communities, as well as destroy parts of the Catskill Forest Preserves.  The Catskill Forest Preserves are protected by New York State and considered as Status #1 land.  Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Any change in land management of  the Catskill Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. This, in itself, should prove how seriously ill-conceived and flawed this proposal by Premium Energy Holdings is.

The massive underground installations and tunnel boring would undoubtedly affect the aquifers that provide the locality with drinking water. The high voltage towers that are planned to carry 230,00 volts of electricity to the grid would traverse even more of the local forest preserve, disrupting a long path of private property to link to the grid. What are the health effects of this high voltage on the local populace?


Additionally, with climate change, we have already been witnessing frequent drought conditions in the upper basin of the Ashokan, therefore already rendering unreliable the amount of water available just to adequately meet NYC’s needs which is the primary and sole purpose for the existence of the Ashokan Reservoir in the first place.  Building a hydroelectric pump station would compete for usage of the same water supplying NYC and would subsequently be an additional strain on the system.  This would result in both systems being seriously compromised and rendered incapable of performing the functions they were meant to fulfill. 

Sustainable and renewable energy is important, but it must be done with a smart, well researched,  and well considered plan.  This plan is ill-conceived and full of outrageous assumptions and serious flaws not mentioned here.  

We urge you to do everything in your power to prevent this proposal from moving forward and deny Premium Energy Holdings’ proposal for a preliminary permit for the Ashokan Pumped Storage Project P-1.

Thomas Efinger, Brooklyn, NY.
Dear Sir/Madam:

Please, please do not allow the permit for this Energy project to go forward. I strongly believe that this is not the right type of energy project to best serve this area and will have profound negative effects on the Catskill Preserve and the local neighborhoods, who lie in the path of these plans.

I urge you to deny this permit.

Sincerely,
Tom Efinger

Brian Bell, Fleischmanns, NY.
Re:docket P-15056

I strongly recommend that you do not approve this Permit.

I live in the town of Fleischmanns and frequently hike
in the areas where the upper level reservoirs are planned.

I am strongly in favor of renewable energy and recognize
that we will need to increase our ability to store excess
renewable power. I agree with the studies that have shown
that pumped storage facilities, like the one proposed, are
net energy consumers and can cause significant changes
to the environment and ecosystems in which they are sited.

For this reason, there must be a compelling reason to locate
a Pumped Storage facility in an environmentally sensitive region.

The proposed site is in a region that is:

Part of one of the largest State parks in NY.
Part of one of the best Trout fishing regions in NY state.
Part of the Drinking water system for NYC and other towns
Part of one of the best locations for outdoor activity (Hunting, Hiking, Skiing) in NY state.

I see no reason why this permit should be approved before the company
has shown that there are no sites where a Pumped storage facility
could be located that are less environmentally sensitive.

I recommend that you deny the permit

Brian Bell

Margaret Casagrande, Fort Lee, NJ.
I understand the need for energy. There must be a better place for the project other than taking land from the Catskills park. The park is already overused and reducing access and parking will just make it worse. What about New York’s drinking water?

Michael Goss, West Hurley, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am deeply disturbed by the proposal Premium Energy Holdings has made to build a hydroelectric power plant, Ashokan Pumped Storage Project P-15056, in New York’s Catskill Mountains. This would be a devastating assault on the environment, on personal properties, on the exquisite way of life The Catskills offer, and on NYC drinking water. It is completely unacceptable I urge FERC to decline their request for a preliminary permit for the.
I’m certain you have received numerous science-based reports detailing the effects of a project like this one so I will not repeat what has been submitted. As a resident of the area I am disgusted by even the idea that a company would rape these beautiful Catskill Mountains, displace homeowners, and ignore the will of the people all for monetary gain.
We are at an important juncture in our life on this planet and if companies do not start making better, ecological and ethical decisions in how they conduct business this planet will not survive, and neither will my grandchildren.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Michael Goss

Dennis E. Anderson, Ballston Lake, NY.
     I am writing to you about a subject that concerns me deeply - Keeping NYS Forever Wild land truly forever wild.  A proposed hydroelectric facility in the Catskill Ashokan Reservoir would irreversibly damage areas of the Catskill Forest Preserve, threaten the experience of hikers and nature enthusiasts, endanger the ecological sustainability of the Forest Preserve and threaten the quality of New York City's water supply!
     Please do not green-light this terrible project!  Putting the profits of a private California Company ahead of the safety of the water supply of the nation's largest Metropolitan Region is not only an indefensible, unpopular policy, it is clearly contrary to the public good and could be fairly characterized as bordering on depraved indifference to the safety of the drinking water for millions of U.S. citizens!!!

Stuart Felberg, Soldotna, AK.
I am writing this letter to object to the issuance of a permit for the plan proposed by Premium Energy Holdings, LLC to the FERC Project No. 15056-000 .
While I am a proponent of the government investing in infrastructure as has been done successfully in the past, I feel that this plan is ill conceived and will be a great detriment to the Catskill Forest Preserve and Watershed Management area which is protected by the NYS constitution.  It will take the well being of this valuable wild resource for the profit of a power company which will be able to sell power at times of high demand for more money while damaging the Catskill Mountains.  The Catskill Mountains are one of the few wild places remaining in the crowded North East, within easy reach of NYC and other populated areas.  The Catskills provide recreation for many users and are protected by the NYS Constitution. 
The proposed application is described in paragraph two of the proposed application “AS A CLOSED LOOP SYSTEM”   “EXHIBIT 1”  DESCRIPTION OF THE PROPOSED PROJECT”  and sworn to by Victor Rojas Managing Director of Premium Energy LLC as follows “Being duly sworn, deposes, and says that the contents of this application for a preliminary permit are true to the best of his knowledge or belief. The undersigned applicant has signed the application on this 18th day of November of 2020”    
As described by the Office of Energy Efficiency and Renewable Energy“ A CLOSED LOOP SYSTEM IS ONE WHERE THE RESERVOIRS ARE NOT CONNECTED TO A NATURAL BODY OF WATER”.  This is not the case as the system described in the proposed plan for FERC Project number 15056-000 since it includes impounding of water from the Stone Clove Creek and other creeks included in the proposal. It supports native Brook Trout as well as rainbow trout.  The Catskills cover 5892 square miles and the Stoney Clove Creek is 10.3 miles long and drains a basin of 32.4 square miles, hardly a closed system as described by Premium Energy Corporation.
The basic concept of this project is misrepresented and certainly doesn’t instill confidence in Premium Energy LLC or in the projects for which they are making application.  
Furthermore as I read the New York State Constitution Article XIV clearly states as follows
“The Constitution of the State of New York
ARTICLE XIV 
CONSERVATION
[Forest preserve to be forever kept wild; authorized uses and exceptions] 
Section 1. The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private”
The proposal is very vague and incomplete.
I object strenuously to the lack of time allowed for public comment.  By the time I became aware of the project more than half of the allowable comment period had expired.  Others with whom I have spoken were also unaware of the project for more than half of the sixty days allotted for comments.  
As I reviews the project information that was available to me I found it woefully inadequate.  It took significant time for me to locate for example, where the location of the dam to impound the Stoney Clove Creek was to be located.  All mention in the plans to headrace tunnels, surge shafts, horizontal tunnels, penstocks and tailrace tunnels cannot be located on top maps and for the general public it is not obvious even if these areas will be laid bare to build tunnels or power houses or if they will be built from underground by boring tunnels.  No mention is made as to where debris such as demolished homes removed and earth and rock removed will be disposed.   
No mention is made in the proposal of the economic and social damage that will result in the area.
There is also no discussion as to anticipated  damage to the environment,  the local population, home owners and recreational users who come from large surrounding areas including but not limited to NYC, Long Island New Jersey.  
Even after reading everything I could find I still don’t know it the streams involved will be totally eliminated by impounding water which will subsequently be removed through tunnels to drive electric turbines and disappear to someplace down stream to be piped back up to the upper reservoir.  
We are all aware of the value of clean fresh water, and although the water to be used for generation of power will still be available for domestic use in NYC, it will not any longer be available for fish breeding or fishing or other recreational uses.     

I have seen over many years the flooding and soil erosion increase in the Catskills.  It has accelerated significantly in recent years.  It appears this pattern will continue to increase in the future.  If these streams are to rise and fall depending on generation schedules we can easily anticipate more siltation of the water in these streams, which will degrade the waters as fish habitat over larger areas than the immediate construction and be detrimental to the water quality itself perhaps even require NYC to require filtration, a process that have been trying to avoid for years
The Catskills is an especially unique place being that it is a wild and beautiful mountainous area close to large metropolitan areas and is used in many ways by numerous recreational users.  We would be wise to foster that recreational use in the Catskills rather than disturb it and discourage recreational use.
We have far too few wild places and wild streams, especially in the East.   Keeping the Catskills in its natural state is a worthwhile effort and we should not dam any wild streams in those few locations where they still exist.  Saving the Catskills is more important than this effort at making money for the power company and a misguided effort to reduce carbon emissions in this way.  
Stuart Felberg alaskabushflying@yahoo.com 907-841-5410

Brooke Perkins, Bend, OR.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I'm reaching out to express my concern with the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to DECLINE their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it will not only devastate the area's vibrant natural environment, but will also be highly disruptive to local communities, and risk the purity of New York City’s drinking water.

As a former resident of the area, I'm greatly concerned with its well-being. While pumped storage and new hydroelectric projects will undoubtedly play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. This cannot happen!

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Brooke Perkins

stephanie torkilson-bambina, Stone Ridge, NY.
  I believe that the Ashokan Pump Storage Project is a bad idea.  The Catksills are a state preserve protected by the NYS Constitution.  Under Article XIV of the NYS Constitution the lands "shall be forever kept as wild forest lands.  They shall not be leased, sold, or exchanged, or be taken by any corporation public or private."  The pump storage project would violate this article.            

This project would flood bird and wildlife habitats.  The rapid fluctuation of water will destroy aquatic and land habitats.  Trout breeding habitats, for example, will be lost.

This project will negatively impact tourism which is an integral part of our economy.  Tourism is a $1.6 BILLION dollar industry which provides almost 20,000 jobs.  Ulster County represents 43% of that market.

In addition to the above, over 100 years ago our valleys were flooded.  Businesses were destroyed, homes and farms were destroyed, families were torn apart, and numerous towns disappeared from the face of the earth.  The history of our area was erased.  Now, they want to do it again.  It is time for the rape of the Catskills to stop

Barry Price, Bearsville, NY.
Thank you for the opportunity to comment.
As a taxpayer, Architect and environmentalist I strongly oppose a project that remains unclear in terms of its intent and any transparency about long term benefits relative to near term disturbance to natural landscapes.
The project at best is confusing and unclear in intent.  I welcome dialogue about compromise and cost/benefit considerations, but not at the expense of clarity about intent, full disclosure and acknowledgement of the environmental sacrifice.  On the basis of how the project was introduced to the public alone, I reject it and its sponsors for the carelessness of its introduction.  If this is any indication, I fear for the worst in the execution and administration of the project.
thank you

Stephen Willie, Rockville, MD.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

As a visitor to the Catskills bi-annually, it would be crushing to lose the communities, wilderness and overall peace and serenity of the region if this proposal was to move forward.

PLEASE DENY PREMIUM ENERGY'S REQUEST!!!

Sincerely,

Stephen M. Willie

erwin a silverstein, phoenicia, NY.
Re:  Premium Energy California Corporation plan to flood and create a water storage dam in Woodland Valley Phoenicia NY 12464

Folks:

As a long time 20+ year resident of Woodland Valley and the owner of two homes there...one for our grand children and the other for our children...we register our strong objections to this proposal.  Our family has had a presence in the Catskills for over a century.

This Company...apparently unfamiliar with and unknown to our local community...is hunting for a site and has proposed several I believe.  I also think they are merely on a "fishing expedition" to locate the "least objectionable" site with the least objections locally...which seems a very unsound and unscientific way to do things.

Woodland Valley is a pristine part of the larger Catskill Preserve and NYC/NYS Watershed areas.  As such it provides much needed and valued recreational opportunities such as camping.fishing, swimming, tubing, hiking, biking and simply communing with nature and meditating.

The negative impact on people...some of whom will lose their homes, lose access to historic and recreational sites, see the water table and stream systems altered and destroyed...will only be matched by the negative impact on the abundant wildlife, which includes bears, turkeys, deer, rabbits, ducks, trout, bass and countless others.

We humbly beg that you not allow this to happen!

Thanks,
Erwin A. Silverstein and family..all prud residents of the great state of New York and the United States of America

Jonathan Gordon, Bearsville, NY.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jon Gordon

Ann Bauch, Hurley, NY.
We are quite concern about how this project will impact our small hamlet of Hurley and surrounding towns. Wires from utility lines will cross our property after we spent our own money to bury our own utility wires years ago. The number of wires crossing land belonging to many neighbors will impact land values. The impact on our water supplies and the natural beauty of our area will be impacted forever. It is time to explore more solar options rather than ruin the water and beauty of our Catskills. Leave the beauty and water safe for future generations!

Wendy Wolfenson, West Shokan, NY.
Comments of Wendy Wolfenson regarding Premium Energy’s Proposal for the
Ashokan Reservoir Pumped Storage Project

Docket: P-15056

April 8, 2021

I am respectfully requesting that FERC deny the application of Premium Energy in the above-referenced project.  

Premium Energy has clearly not given this project the attention that it deserves, as evidenced by the numerous errors and omissions that pervade both the original and amended applications for a permit.

Please note just some of these mistakes:

1)	There is no “Shokan City,” “West Shokan Town,” or “Olivebridge Town.” The fact that Premium has gotten so many of the locations of its project incorrect suggests either incompetence or indifference to the affected communities.  These errors, either deliberate or accidental, have delayed the ability of the local municipalities to alert their citizens in a timely way.  Through incorrect addressing by Premium, the time in which officials and citizens could prepare their responses was also wrongly shortened.  Compelling Premium to correct these errors and resubmit its application would provide the municipalities and citizens with the comment period they are supposed to have during the permit application review process.

2)	Using Hudson Valley One as a means of satisfying the requirement to inform the public is inadequate.  Hudson Valley One is a weekly newspaper that is not widely circulated in the affected areas.  Its focus is on the more urban areas of Ulster County, such as Kingston, New Paltz, Woodstock and Saugerties.  By contrast, the Daily Freeman has a much larger circulation in the rural parts of the county and also includes Greene County in its base.

3)	 By failing to inform all the municipalities in a timely way, if FERC approves this application now, they are denying elderly citizens their right to become informed, file as intervenors, and comment at this stage.  Due to Covid-19, the normal process of face-to-face town meetings has been impossible.  As a result, many towns have tried to get the word out about this project through Zoom meetings and websites.  Since many of the elderly residents are unfamiliar or uncomfortable with these means of communication, the elderly are less likely to participate fully in this process.  Consequently, in order to protect the rights of the elderly, every aspect of timely notification should be enforced.


4)	There is no mention of the tunneling under private property that would be required as part of the plan.  It is unclear what damage to home foundations and wells this would cause or whether Premium even has the right to do this, absent the consent of the landowners.  Without the tunnels, the project is not buildable.  To approve the permit at this juncture, without resolving this issue in advance, allows Premium Energy to effectively “land bank” for years, without the possibility of successful completion.

5)	There is no mention of the Bushkill Cemetery, which exists within 300 feet of the access road to the upper Wittenberg reservoir (Moonhaw Road).  How does Premium Energy intend to protect the graves on this site during a lengthy construction period?  Many of these graves were actually moved from their original location, underneath the Ashokan Reservoir, when that reservoir was built over 100 years ago.  Are the graves supposed to be moved a second time or disturbed for years by countless heavy-duty construction vehicles?

6)	Premium states the high-voltage high-tension wires would run 12.9 miles.  This measurement is actually a straight line, as the crow flies, It would mean running these wires across the Ashokan Reservoir itself, which is an impossible scenario.  The actual running distance from the Hydro Plant in West Shokan to the Hurley Substation is closer to 20 miles.  This means that the use of these unsightly and potentially dangerous wires and towers is roughly 50% more than Premium states in the application.

7)	There is no indication of how Premium intends to obtain the property to build the miles of high-tension power lines.  Specifically, Premium does not disclose whether they will be putting these lines on New York City property, taking additional private land by Eminent Domain, or insisting instead that people in residential and protected areas will simply be forced to live with these eyesores and potential dangers on their property or near their homes.

8)	Premium Energy failed to address the potential for flooding in the project area.  They should be compelled to do a thorough FEMA review and mitigation plan.  The area around the proposed Wittenberg Reservoir is so flood-prone, that Federally subsidized flood insurance is required in order to obtain a mortgage.  The impact of spillage from the upper reservoir in times of excessive rainfall could be life-threatening to downstream residents. 

9)	 In its resubmission, Premium Energy said that “soil and rock borings will be necessary to determine the rock/soil structure and stability for the proposed dams and power plants foundations.  Soil and rock samples shall be extracted to conduct studies and determine the soil mechanical properties.”  Premium Energy does not explain how it will obtain these necessary samples, or even obtain permission to cross private land to get to New York State land.  At this juncture, it has become abundantly clear that the local landowners are vigorously opposed to the project and have no intention of cooperating with Premium Energy.
 

This project is clearly opposed by all the different communities and stakeholders.  Out of over 600 comments so far, there are only 2 that support it.  With a community-wide disapproval of over 99 ½%, and evidence of incompetence on the part of the applicant in so many areas, large and small, FERC, as the public’s Energy Regulatory defender and overseer, needs to put a stop to Premium Energy’s Ashokan Pumped Storage Project immediately.

Lisa Phillips, Woodstock, NY.


Premium Energy has submitted a proposal to the Federal Energy Regulatory Commission (FERC) that seeks permission to do a feasibility study that would clarify the project’s scope and viability. This is an inappropriate project that threatens the environmental and economic viability of our region. 

The project’s proximity to the Catskills is of great concern, as the Catskills are a State Preserve protected by the NY State Constitution. The project would also increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water. I’m also worried that the project would displace residents. My understanding is that the Ashokan watershed agreement limits development to keep the watershed safe. This has shaped the character of our region. It’s incomprehensible that a project on such a scale would even be possible, given the need to protect the drinking water of 9 million New Yorkers. 

Please do not allow Premium Energy to move forward with this plan. 

Sincerely, 
Lisa Phillips
12 Vandermark Road
Woodstock, NY 12498
docket number P-15056-000

carol folino koerner, Charlotte, VT.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities (My niece and her husband live smack dab in the middle of this proposal), and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,

Carol Koerner

Hannah Koelbl, West Shokan, NY.
To whom it may concern, 

As a resident of West Shokan and New York City, I am extremely troubled by FERC’s proposal. In addition to our home in the town of Olive, we have two long-term residents who would be displaced by the proposal in a community that is already experiencing a housing shortage. Not to mention the disruption to the economy and local tourism that such a project would cause.  Even more concerningly is the long-term negative impact it would have on the ecosystem, aquatic and land habitats, and certain loss of habitat for innumerable species. Disruption to the water supply feeding the Ashokan reservoir would also impact a critical drinking water supply for both local residents (well water) and for New York City. 

The  Catskills are a State Preserve and protected by the NY State Constitution. Under Article XIV of the NYS ConsItuIon, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protectIons designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

This plan is seriously flawed, does not appear to be well thought out, and should not be allowed to move forward. 

Hannah Koelbl MS OTR/L

Stephen Molmed, West Shokan, NY.
Stephen Molmed, P.E., West Shokan NY, Docket #P-15056-000

The initial permit application, as well as the amended version, clearly demonstrate that Premium Energy has not performed even the minimum due diligence that is required for the application. It brings to question their ability to safely construct a dam that is over 300 feet tall and upstream of many homes. 

Following are a few of the many deficiencies found in the Premium Energy Holdings Ashokan Pumped Storage Project Preliminary Permit Application.

County, City, Town, Or Similar Local Political Subdivision Not Identified

Premium Energy has not identified every county, city, town, or similar local political subdivision in which any part of the project would be located, including names and mailing addresses, as must be provided for a preliminary permit application by Sections 4.32(a)(2)(i) and 4.32(a)(2)(ii).

The proposed Stony Clove reservoir would be located in the hamlet of Lanesville, NY, in the Town of Hunter, NY which is located in Greene County. None of these are identified, nor is a mailing address provided in the Permit Application.

In addition, high voltage transmission lines will pass through the towns of Marbletown and Hurley. These, too, are not identified in the Permit Application.

The application cannot be considered complete and must be considered deficient unless it includes all of the political subdivisions in which the project is proposed to be constructed as well as “Every other political subdivision in the project area that would likely be interested in or affected by the application.” (FERC Checklist For Applications For Preliminary Permits, item II(D) and 4.32). All of the above listed towns, political subdivisions and Greene County are not listed in the application, are those in which the project would be located and are required to be provided under Section 4.32, if not, the application must be rejected.

Non-existent City, Town, Or Similar Local Political in Application

Page five of the Permit Application states that the proposed project is located in Ulster County, New York. While this is correct for two of the proposed upper reservoir locations, the proposed Stony Clove reservoir is located in Greene County, New York.

Page five of the Application also states that the project is located in the Township, or nearby towns of Shokan City and West Hurley City, neither of these exist. 

It is reasonable to expect that Premium Energy is able to identify, and correctly name, all of the politico subdivisions and towns in which they propose to construct this project in their application. By using non-existent names, the application does not identify every city, town, or similar local political subdivision in which any part of the project would be used or located, as required by Sections 4.32 and 4.81 and is required to be rejected.

Lack of Emergency Spillway Description

FERC’s deficiency letter states that Exhibit 1 of the application does not mention any emergency spillways for the upper reservoirs. 
Premium Energy provides a wholly inadequate response, which does not address emergency spillways: “The new upper reservoir alternatives site would naturally discharge runoff water through its own concrete spillways to the existing streams which would be impounded.”  Premium Energy states information about emergency spillways has been included in Exhibit 1 of the amended application, it has not.

Exhibit 1 of the amended application  does not mention any emergency spillway or contain a description for any emergency spillway, to any extent, at any of the proposed reservoir sites, including at a minimum number, dimensions and general configuration of the emergency spillways, as required by Section 4.81(b)(1). FERC’s noted deficiency has not been addressed, resulting in the application remaining deficient. 

Inadequate Maps

FERC’s deficiency letter states the maps do not meet the requirements of Section 4.81(d)(5) “You provide the series of maps for the project layout.  However, the scale of maps is not sufficient to show clearly and legibly all of the information.  Please revise and submit the maps enlarged to a scale that is adequate for that purpose.” Premium Energy responds that a new series of maps for the project layout is provided in Exhibit 3.

A review of the maps in both the original and amended applications shows that a few maps have been added. The scale of the original maps has not been changed, the scale of the new maps is also not sufficient to show the required information clearly and legibly. The maps also lack detail and notations which makes them inadequate properly show information required by Section 4.81 to be provided in Exhibit 3 including. Some other ways the maps do not meet requirements of Section 4.81 are:

1.	They are not prepared on USGS topographic quandrangle maps or a similar maps of a state agency. USGS topographic quadrangle maps are readily available online.
2.	When multiple maps are provided, Section 4.81 requires that an index sheet is included. The application is lacking an index sheet.
3.	Many principal project features are not identified on the maps, including, but not limited to the proposed upper reservoirs, dams and water conveyance facilities.
4.	Four of the maps lack sufficient detail, have no notation, legend or other means to clearly identify what is being represented.

Transmission Lines

The application is inconsistent in its reporting of the high voltage transmission lines running from the power plant to the Central Hudson substation.

The written description in the application states that 230 kv transmission lines are proposed. The maps show 500 kv transmission lines. The difference is significant in many aspects including, that 500 kv transmission lines require higher towers, additional clearance, wider right-of-way, further affecting the use of private properties and residences through which the route of the transmission lines pass.

Neil Harley, LANESVILLE, NY.
It has come to my attention that Premium Energy Holdings LLC has applied for permission to construct a dam, reservoir, pipeline, powerhouse and high voltage electrical lines in my beloved and pristine Stoney Clove Valley. The Lanesville home that I have lived in for the past 50 years is right smack in the middle of this proposed site. Has this so called company heard that the area we live in has been designated as a forever wild Forest Preserve?

Would you allow them to destroy an ancient ecosystem, where native brook trout, whitetail deer, black bear, bobcat, fox, eagles, hawks and yes even blue heron's call home. As a senior citizen who loves the outdoors do I want access to my favorite, local, hiking trails eliminated. To this I answer with a resounding NO!

Our beloved scenic byway Route 214 is our only access to our recreational ski mountains, hiking trails and favorite fishing spots along the pure waters of the Stoney Clove Creek. You would allow them to destroy all of this in the name of supposedly renewable energy. That makes no sense to me at all. Let's ruin something thats good and beautiful to satisfy some ludicrous political agenda.

Please be warned that we fought and won to outlaw fracking in our Forest Preserve  and we will fight and win in shutting down this ridiculous idea also. I am willing to spend whatever it takes to pay for lawyers and support grass roots community activists, who will fight with us, to end this abuse of power.

Thank you for this platform to convey my unyielding opposition to this proposal.

Yinan Lu, West Kill, NY.
This action will negatively impact the residents of the construction areas, as well as the surrounding area. The eco system will be the external cost of the whole project. While the private company enjoying the income, local residents and environment are paying for the loss.

Shelley Levine, New York, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

My daughter and son-in-law are farmers at 1375 Hurley Mountain Road in Hurley, NY and my husband and I jointly own the property that includes land that would be negatively impacted by the Premium Energy Holdings proposal.

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Shelley Levine

Sharon Calcote, Austin, TX.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Sharon Calcote

David C Burkhart, Binghamton, NY.

April 8, 2021


Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426


Re: Project P-15056 Ashokan Pumped Storage 


Dear Secretary Bose:

My family owns a home at 791 Vly Road, in the affected Town of Olive.  I have a number of questions and concerns regarding this project: 

1.	Proposal Depends on Future Event – Change to the State Constitution 
Each proposed site in the application would use (or acquire) land that is designated by New Your State as a forest preserve.  Forest preserves are protected under Article XIV in the New York State Constitution.  It says, “The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private…”  Consequently, wouldn’t a change to the State Constitution be required to fully enable the proposed project?  FERC 18CFR 4.32(J) states, “An application the effectiveness of which is conditioned upon the future occurrence of any event or circumstance, will be rejected.”  Therefore, shouldn’t the application be denied?

2.	Proposal Depends on Future Event – New Transmission Line 
The proposals states, “In order to store energy or deliver power to the regional electrical utility network, construction of a new 230 AC transmission line will be necessary to transmit power from the Ashokan Pumped Storage Switchyard to the existing Hurley Avenue Substation.”  FERC 18CFR 4.32(J) states, “An application the effectiveness of which is conditioned upon the future occurrence of any event or circumstance, will be rejected.”  Therefore, shouldn’t the application be denied?

3.	Project Is Not Closed-Loop, as Claimed by the Applicant
The proposal claims the project is closed-loop.  It is not.  The Esopus Creek continually runs into the Ashokan Reservoir.  The Esopus Creek also runs out of the Ashokan Reservoir.  In addition, there is a parallel and continual outflow the Catskill Aqueduct, which supplies drinking water to New York City.  At the very least, shouldn’t the application be required to resubmit, defining the system as open-loop?  Also, as I understand it, open-loop pumped storage systems present a higher risk of water contamination than closed-loop systems, due to increased turbidity.  The scientific research on the water quality associated with open-loop systems appears to be sparse.  Given this proposed system would be tied to a critical unfiltered water supply for a major metropolitan area, aren’t the risks too great to grant approval even for a preliminary study at this time?  

4.	Does the Region Need for More Power Generation?
The proposal is based on the assumption that more power generation is required for this region in the foreseeable future.  Are there credible projections that suggest that is the case?  If not, shouldn’t the application be denied?

Based at least on 1-3 above, I respectfully request the FERC deny application approval at this stage. 

Sincerely,

David Burkhart, PMP
Program Manager
PO Box 1475
Olivebridge, New York 12461


DOE Report
https://www.energy.gov/sites/default/files/2020/04/f73/comparison-of-environmental-effects-open-loop-closed-loop-psh-1.pdf
NYS Constitution Article XIV Conservation: https://www.dos.ny.gov/info/constitution/article_14_conservation.html

Micah Yannatos, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Micah Yannatos

Smiley David, New York, NY.
I am writing in response to the flawed proposal by Premium Energy to build a hydroelectric power plant in the Catskills. FERC should decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, disruptive to local communities, and risky for NYC’s drinking water.

Pumped storage and new hydroelectric projects will play a key role in our transition to renewable energy but the pristine forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. The NYS Constitution clearly guarantees that these lands “shall be … forever wild." Such lands will not be leased, sold or exchanged, nor held by any corporation, public or private. The Preserve's thousands of acres of continuous wildlife habitat cannot be traded away, setting a dire precedent for protected lands across the country.

Pumped storage is notorious for wreaking havoc on stream ecologies and on aquatic and land habitats. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries. The Project would negatively affect Esopus Creek, one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply. It would be short-sighted to allow a project to proceed that would threaten the Ashokan Reservoir, the largest unfiltered water supply in the nation, representing billions of dollars in public investment. If the Reservoir succumbs and fails to meet water quality standards, the State will bear massive costs for remediation.

Premium Energy’s proposal would be deeply damaging to local communities, requiring the seizing of homes and private property via eminent domain. Given the real estate "boom" in the Valley, displaced residents would have a hard time securing new housing. Beyond the problem of displacement, the project would hurt the vital Catskills tourism economy by limiting access to hiking, fishing, and other forms of recreation, decrease the area’s natural beauty, cut off access to skiing and concerts in the region, and dampen tourism across the region, hurting businesses in Ulster County and beyond.

Finally, the Project does not represent the kind of innovation that the Department of Energy seeks. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium claiming the project is “closed-loop” when, in fact it is not. The State cannot trust a company that lies in their proposal for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project (and honestly "closed-loop"), where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

William Huhn, Dobbs Ferry, NY.
Hello -

I must protest this project.  I used to be an Environmental Chemist for Westchester County and am now a staunch environmentalist.  We found serious problems with sediment in reservoir water, and that is without even involving a major construction project as this one.  I cannot believe this is environmentally sound, and the consequences are difficult to predict.  New York State has other sources of energy much less intrusive than this project.  Thank you.

Nancy Martin Costa, Denver, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Nancy Martin Costa

Susan H. Gillespie, Rosendale, NY.
Ms. Kimberly D. Bose					April 8, 20212
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

Premium Energy’s above-captioned proposal to FERC was developed without any familiarity with the terrain or the communities where the pumped storage facility would ostensibly be located. Nor did they contact any of the affected municipalities, including Ulster County, before submitting their proposal. It is hard to believe that this is a serious proposal at all, given Premium Energy’s failure to consider the most basic problems with its scheme.

Premium Energy’s proposal is internally contradictory, stating on page 6 of its letter (dated January 9, 2021) in response to the FERC’s notification of deficiencies that it “would use the existing Ashokan reservoir as a lower pool and proposes a new upper reservoir in the Catskill Mountains to serve as upper pool. The filling of these reservoirs would be done through the Esopus Creek and the existing Ashokan Reservoir,” and on page 11 of the same letter that the proposed project would operate in a “closed loop. Aside from evaporation and percolation losses, the project’s water would stay within the system. Therefore, the existing Ashokan Reservoir’s remaining water storage would not be used for project operation.”

The Woodland Valley and Wittenberg Reservoir sites proposed for the creation of a second reservoir are located within the Slide Mountain Wilderness Area, a constitutionally protected wilderness in New York State. At 47,500 acres, it is the largest tract of state-owned Forest Preserve in New York's Catskill Park, and the largest area under any kind of wilderness area protection between the Adirondacks and the southern Appalachians.

The Catskill Park is protected from development. “The state constitution requires that any property owned or acquired by the state in those parks ‘be forever kept as wild forest lands’ and prohibits it from selling or transferring them in any way (save amending that section of the constitution to allow specific transactions)” (Wikipedia).

The area is home to rare and threatened species, including the nodding pogonia and other endangered animal and plant species. According to the Slide Mountain Wilderness Unit Management Plan: "Rare Plants: A large colony of the orchid nodding pogonia (triphora trianthophora) occurs at a low elevation in one ravine in the unit. Rare in the northeast, this orchid is found in only three other locations in New York State" (p. 6).

Thanks to New York States unique management approach, the Catskill Park is not only a protected wilderness, but one that serves the recreational and educational needs of hundreds of thousands of people every year. 

Should the Woodland Valley location be selected, the new reservoir would not only inundate many properties but would block access to additional homes at the head of the Valley, as well as to the State-managed Woodland Valley Campground, which offers 70 tent and trailer sites, along with easy access to fishing and hiking. The Woodland Valley campground serves as the trail-head for both the Slide-Wittenberg Trail (the Burroughs Range) and the Woodland Valley-Denning Trail, which provides access to the Giant Ledge-Panther Mountain Trail.

Woodland Valley Stream is a famous trout fishing stream, containing brook trout, brown trout, and rainbow trout, as well as cutlips minnow, blacknose dace, longnose dace, sculpin, and white sucker. 

All of the proposed sites have important historical resonance. At the heart of the terrain is the Burroughs Range, named for naturalist John Burroughs, an eloquent advocate for the region. His 1910 essay In the Heart of the Southern Catskills describes his first experiences exploring the Wittenberg-Slide-Cornell area. Burroughs, whom The Atlantic once called “the single most popular nature writer in America for many decades (The Atlantic, May 2006 issue), helped found the environmental movement in the US. Destroying the historic heart of the place he so loved would send a terrible message about this country’s environmental values and appreciation of wild places. 

There is another history in the region that also militates against the proposed project. Between 1907 and 1915, 16 communities were inundated and approximately two thousand residents were forcibly relocated, while roads, homes, shops, farms, churches, and mills were taken by eminent domain and either moved, abandoned, or torn down, with laughably small recompense. The vent has recently been memorialized in a beautifully illustrated series of four articles, beginning in November 2020, in Places journal. As stated there, “For upstaters, the reservoirs that provide water to New York City represent at best an imposition and at worst an imperial pillage of the landscape” (https://placesjournal.org/article/reservoir-an-account-of-human-costs/).

Last but not least, the movement of millions of gallons through the Ashokan reservoir and Esopus Creek would further threaten the water quality of New York City, which is the largest city in the US to offer unfiltered drinking water to its residents. The Ashokan provides 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. The city is already struggling to maintain the quality of its drinking water, as demonstrated by its frequent releases of muddy water into the Esopus, turning it cocoa brown and generating resistance and heated negotiations between New York City and the local municipalities whose own natural resources and attractiveness for tourism are directly impacted. 

My family has been resident in the Woodland Valley since the 1800s. I strongly urge the FERC to decline the request by Premium Energy Holdings for a preliminary permit to further develop its hare-brained scheme scheme (with apologies to hares) to build Ashokan Pumped Storage Project P-15056. 
Sincerely,
/s/
Susan H. Gillespie

Eugene Ruffolo, Phoenicia, NY.
To whom it may concern,
I am a resident of Woodland Valley in Phoenicia New York, and have recently become aware of the outlandish proposal put forth by Premium Energy Holdings. While I am a firm believer in- and proponent of- clean energy alternatives, I am vehemently opposed to the aformentioned project on more levels than I can even begin to express in the space allotted.

After studying the proposal in great detail, it seems obvious that its completion would have a profound negative effect on the precious Catskill preserve- a unique and sacred area that is singular and cherished by so many. Its effect on the Eusopus and its tributaries alone make it unthinkable to anyone who delights in the pristine streams that make up this area. 
It would negatively impact the New York City water supply and undoubtedly have a delirious effect on local tourism-which is vital to the livelihoods of so many residents.
I could go on and on with technical objections to the project—but why point out what you clearly already know?

On a personal level- I am neighbors with a family living in a home that was moved from the Ashokan reservoir nearly a century ago. They have personally recounted to me on several occasions the emotional impact and trauma that their family, and so many others, experienced when their homes were destroyed and their lives uprooted. It’s unthinkable to imagine something like that happening in our backyard today.

I know I speak for nearly all of my neighbors- many of whom may have no doubt already voiced their objections-when I say that this is a highly unpopular proposal of which virtually no resident is in favor.

We sincerely hope you will put an end to it in its early stages.

Thank you
Eugene Ruffolo

Weston Fenner IV, Brodheadsville, PA.
I vehemently oppose this project for the following reasons: 

The Catskills are a State Preserve protected by the NY State Constitution.

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would increase turbidity and negatively impact NYC’s drinking water.

It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.

The loss of tourist dollars and business revenue would directly hurt our communities.

The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Howard J Fisher, Santa Fe, NM.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I oppose the misguided proposal by Premium Energy Holdings to build a hydroelectric power plant—the Ashokan Pumped Storage Project P-15056—in New York’s Catskill Mountains.  this project would ruin the environment and disrupt many local communities.  It also poses a serious risk to the safety and purity of New York City’s drinking water.   I urge you to deny their request for a preliminary permit.
Although I live in New Mexico, I and millions of other tourists around the country travel to the Catskills area to enjoy the very beauty and calm that this ill-conceived project threatens.  Please do not allow it to proceed.
Sincerely,
Howard J. Fisher
Santa Fe, New Mexico

DAVID SHENGOLD, Stone Ridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose--

I write to ask that FERC turn down Premium Energy Holdings' request for a preliminary permit for the misguided Ashokan Pumped Storage Project (P-15056).
 
The authors of the proposal either don't know or are misrepresenting the location of the proposed project. Well-placed hydroelectric power facilities are clearly key to sustainable energy maintenance, but Premium Energy Holdings-- a California concern--falsely characterizes the target are as being "near" the vital Catskill Forest Preserve. The locations they put forward, and the Ashokan Reservoir--we live a few minutes from Olive, one of the three sites under consideration for the additional reservoir--are indeed at the CFP's very center and are thus protected from commercial exploitation and acquisition by eminent domain by the New York State Constitution. As I understand it the Department of Energy's own policies counsel avoiding development in protected ecosystems such as this remarkably well-preserved area.

In addition, I am deeply concerned about the impact on the sediment levels in the local watershed, including the Esopus Creek, famed for trout fishing and for tubing. We have cousins from Syracuse who visit the area for the trout season and friends, plus relatives from other states and even other countries who come up here to access Hunter Mountain for skiing. They bring revenue to the local motels and beds-and-breakfasts, gas stations, restaurants and sporting goods stores. So not only the natural beauty of this area is under jeopardy but--multiplying our acquaintances and relatives' examples by the tens of thousands--the vibrancy and viability of its tourism industry. 

Add on the possible threat--since the proposal as I understand it does not in fact constitute an ecologically sound closed-loop system as it claims to--to the water supply of the 9 million residents of New York City, where we also own property. As it is, the reservoir outflow's turbidity has been an issue of much recent concern by local residents and New York City officials as well. Why on earth should a potential additional threat to that drinking water be fast tracked? Premium Energy’s flawed and clearly mendacious proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056 must be turned down!

Many thanks for your attention in this matter.

David Shengold
64 Buck Road 
Stone Ridge NY 12484
(845) 687-2417

Robin Michel, Madison, CT.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would:
1. devastate the environment and ecosystem, 
2. disrupt and displace local communities and local businesses, 
3. put the purity of NYC’s drinking water at risk.

Pumped storage and new hydroelectric projects will play a key role in transition to renewable energy, but the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

America’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Robin Michel

Submission Description: (doc-less) Motion to Intervene of BORIS BELENKY under P-15056-000.

Submission Date:        4/8/2021 5:19:15 PM

Filed Date:             4/9/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               borisny2000@yahoo.com                                                            

Basis for Intervening:
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to
build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to
decline their request for a preliminary permit for the Ashokan Pumped Storage Project
P-15056, as it would be devastating to the environment, highly disruptive to local
communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a
key role in our country’s transition to renewable energy, the pristinely protected forests,
streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process.
Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall
be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be
taken by any corporation, public or private.” The Preserve currently contains 700,000
acres of continuous wildlife habitat (very rare in our increasingly fragmented
environment), and the forest around the proposed sites ranks among the top 1% of
forest habitats region-wide, according to the New York State Forest Condition Index. It
would be a true crime to destroy this sacred and wonderfully preserved land, and would
set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation
due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped
storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic
and land habitats, because within a pumped storage system, the upper reservoir is
subject to rapid fluctuations as the water is pumped up and down. In addition to
affecting wildlife, this can alter the sediment regime in connected tributaries, which has
a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the
sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout
breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which
supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5
million people. Plus, Premium Energy’s proposal is not a closed-loop system as they
claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase
turbidity within the Ashokan and its watershed. Taking all this into account, it would be
reckless to allow a project to proceed that would threaten such a valuable asset as the
Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and
represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium
Energy’s proposal would be deeply damaging to local communities. Any conceivable
upper reservoir site in the Catskill Forest Preserve would require the seizing of homes
and private property via eminent domain—a process that already displaced thousands
when the Ashokan was constructed 100 years ago. Residents displaced by the
Ashokan Pumped Storage Project would likely have a hard time securing new housing,
as there is currently a housing shortage in Ulster County, and for homes that are
available, prices are through the roof. Beyond the problem of community displacement,
there is also the proposed project’s effect on the Catskills’ growing tourism economy,
which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion
industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access
to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s
natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and
Tannersville, and otherwise dampen tourism in the region, negatively affecting
businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage
Project, it must be pointed out that their proposal does not even represent the kind of
innovation that the Department of Energy wants to see. Closed-loop pumped storage
projects have smaller environmental impacts than those that make use of existing
watersheds, and are thus eligible for streamlined FERC approval. This is why Premium
is claiming this project to be “closed-loop” rather than being honest about what their
project actually is: an “add-on,” using an existing body of water as a lower reservoir.
This kind of project carries with it significantly higher risks, even when the lower
reservoir is not a vital source of drinking water for our nation’s largest city. How can we
trust a company that would lie in their proposal simply for the advantage of being
fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost
of environmental and community devastation. I hope Premium Energy will be able to
find a suitable alternative location for a pumped storage project—one where the
construction and operation will not destroy protected wilderness, displace vulnerable
communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit
for the Ashokan Pumped Storage Project P-15056.

Submission Description: (doc-less) Motion to Intervene of Mark O Bailey under P-15056-000.

Submission Date:        4/8/2021 8:59:25 PM

Filed Date:             4/9/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               Mob1110@aol.com                                                                  

Basis for Intervening:
I am a land owner on the site of the proposed project and as a former hydro supervisor for Central Hudson gas and electric., who was in charge of Four FERC regulated run of the river and pond storage hydro facilities.n
  I wish to have all information regarding the pumped storage proposal including site updates , any proposed plans and filings that are submitted by all parties to FERC. 
   I am opposed to this project on many levels not just as a land owner and land access and loss issues but also preservation of the Catskills park and the surrounding areas.

Jerry Sforza, Mount Tremper, NY.
				Jerry and Monica Sforza
				227 Beaverkill Road
				Mt. Tremper NY 12457
April 9, 2021


Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Re:    FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA.

Dear Ms. Bose,
I am writing as a concerned resident of Mount Tremper, NY regarding a proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

My wife and I recently sold our primary residence in NJ and decided to move full time to what was our weekend home in Mount Tremper.  Our decision to make Ulster County and the Town of Shandaken in particular, our permanent home is primarily the community.  We thought this tight knit, hardworking community who care about each other were as protected from development as the pristine forests where we all reside.

To think that whole communities will be displaced by permanent, engineered flooding if this project were to be approved is hard to comprehend.   Particularly during a time when many residents are struggling to stay healthy and literally keep their head above water financially.  Government dictated compensation for displaced homeowners will not allow these friends and neighbors to remain in the area.

Coming from a State with a history of awful environmental and eminent domain abuses (i.e. Long Branch, NJ), I thought living within the protected watershed for NYC’s 8 Million + residents would ensure that the local community and its environs would stay intact and safe from developmental abuses of any kind.

I urge FERC to decline Premium Energy Holdings request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, primarily because it would displace long-time residents in a very tight housing market, have a devastating impact on local wildlife, and reduce much needed tourism to the area.

Visitors and residents hold dear the undisturbed natural beauty of Catskill Park.  Tourists from NYC and NJ seek to escape the disruptive power generation and transmission projects that have no place in a “forever wild” park.

Renewable, green-energy sources should not come with irreversible community and environmental costs. 

Please use your power to stop this misguided project and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,


Jerry and Monica Sforza
Mt Tremper Residents



Cc:
Congressman Antonio Delgado
US Senator Chuck Schumer
US Senator Kirsten Gillibrand

George Preoteasa, Middle Village, NY.
As a resident of New York City, which is using the Ashokan Reservoir as a source of water, I am concerned about using that water for other purposes. In particular, I am concerned about the possibility of introducing invasive species that can affect the water or the distribution system. By effectively extending the reservoir, especially into an area not controlled by the NYC DEP, additional opportunities for invasive species to enter the water are created.

George Preoteasa
6317 75th ST
Middle Village (Queens), NY 11379

greg meola, olivebridge, NY.
I think this proposed hydro electric plant is crazy.  It's right in the middle of a watershed for New York City.  There is no way to guarantee the safety of the water with a project like this in the drainage basin.  Plus, this project is in the Catskill Park, which is comprised of a lot of forever wild land.  FOREVER WILD.  That still means something. Doesn't it?  Our area is seeing a boom in eco tourism. This is hiking, camping, biking, fishing, and many other outdoor activities that are dependent on the wilderness.  Remaining wild.  Please deny this application. It does't suit the intended use of this area.  Thank you.
    Greg Meola, Captain, Olive Fire Department Co. 1 and resident of Olivebridge, NY.

Chris Kiel, Stone Ridge, NY.
I am frankly appalled at this proposal. The plan is completely reckless and is totally without regard to the local environmental system. The word preposterous comes to mind.

Here are just a few things that would change for the worse:
1: Hiking up to Friday and Balsam Cap Mountains would be eliminated thanks to the flooding of Moonhaw Road. 
2: The area is a spawning area of trout fisheries. Something Shandaken is well-known for.
3: The construction will disturb one of the most pristine views in the Catskills with added power lines, not to mention that the construction process itself will be invasive, loud, dirty, and inconvenient to residents in the area.
4: The proposed sites in the the area are Status 1 Land. The DOE has said that Status 1 and 2 land must be avoided for development. The Catskill Park can not be developed on without an amendment to the state constitution which protects the park specifically.
5: This project is likely to damage local lands, roads, and streams, and it will cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City.

Lisa St. John, Cottekill, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

Under no circumstances should the Federal Energy Regulatory Commission proceed with its application for Preliminary Permit for the Ashokan Pumped Storage Project. The impact of this project on the community and environment would be unethical and illegal.

Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. 

All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area. According to the National Audubon Society, the Ashokan site has supported a nesting pair of Bald Eagles for the past ten years and hosts up to six Bald Eagles during the winter. Our national bird, the symbol of justice and democracy, would be displaced. Hopefully, you can see the irony in this situation.

I am certain that the Federal Energy Regulatory Commission can find a more suitable place for a pumped storage project, one that would not disrupting the Ashokan Reservoir community to a devastating degree.

Thank You,

Lisa St. John

Julie Brewer, Wilmington, DE.
Dear Secretary Bose, 

I write in opposition to the Ashokan Reservoir Power Plant Proposal filed by Premium Energy Holdings LLC. This is a highly flawed proposal. The impact of this power plant, if implemented, will devastate the environment, wildlife, and recreation in the area, as well as, the local community and economy.

Most importantly, it threatens the water quality and supply for New York City.

It is difficult to understand the benefits of this plan in relation to all the harm it will cause. The plan does not address an identified energy deficit. While hydroelectric power can be a green energy solution in some scenarios, this is not one.

Please include these considerations in the evaluation of this proposal.

Thank you,

Julie Brewer

Laura Draper, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Laura Draper



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Jennifer Frank, Mt. Tremper, NY.
Docket number P-15056-000

Dear Ms. Bose,

As a member of the community that greatly appreciates and strives to live in a protective of the environment way, I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, which will be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

We have been here before as communities--putting quick fixes and short term gains above respect for our immediate surroundings, awareness of how linked the physical environment is, with one impact rippling into others, and profit over people. Please, let's do things better this time.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

I am the mother a fifteen year old and seventeen year old who go to school within sight of the mountains that layer over to the reservoir, and regularly enjoy walking and biking in the surrounds. I want to protect their world as I seek to protect them. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

My best,

Jenny Frank

George Huhn, Shelter Island, NY.
Hello,

I am writing to oppose the Ashokan Reservoir Power Plant Proposal filed by Premium Energy Holdings LLC. This is a dangerous proposal. This power plant will devastate the environment, wildlife, and recreation in the area, and hurt the local community and economy.

Plus it will threaten the water quality and supply for New York City.

While I am all for clean renewable energy, this hydroelectric plant will destroy a priceless area of New York's famed Catskills.

I encourage you to consider the detailed information provided by the Coalition to Save the Catskills Preserve http://savecatskillspreserve.org during your evaluation of this proposal, and reject the proposal.

Thank you,

George F. Huhn
Shelter Island, NY

James Harris, New York, NY.
James Harris
247 Driggs Ave
Brooklyn NY 11222

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the irresponsibly flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. This must not move forward. 

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
James Harris

Maire H., Schenectady, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

As a native of Upstate NY and having family that has lived in the Catskills for at least five generations, I am not only saddened but angered at this proposal. I got my masters degree in clean energy, and I currently work for a clean energy firm. I know the importance of addressing climate issues, and I am passionate about it. I am not passionate about destroying water systems, several different species, the environment, and the communities in the region. What sense does that make?

Premium Energy Holdings' plan to build a hydroelectric power plant in New York’s Catskill Mountains is disturbing. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Maire H.

Linda Boyer, Kingston, NY.
It would be environmental devastation and a threat to our water supply to allow the proposed power station by Premium Energy to be allowed to happen. It is an unnecessary project that seems to be more interested in making a profit at the cost of the people that would be affected adversely. There is much natural beauty and wildlife in our beautiful region. This project should not be allowed to happen.  Linda Boyer, Kingston, NY
.

Karin Houben, Boiceville, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. As a person who lives, works and raised a family in Ulster County, I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

The protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Karin Alisa Houben

Kayla j Schwarz, Brooklyn, NY, NY.
Building a new hydro-electric dam in the Catskills, in a protected wild area is not congruent with the law nor the needs of the future. Although we need clean energy to combat climate change, destroying protected wild areas and reservoirs that supply clean water to NYC is not the way to do it. This ill thought out and destructive project should be immediately dismissed.

Terri Basilone, West Shokan, NY.
I am vehemently opposed to Premium Energy Holdings proposal of a pumped storage system at the Ashokan resevoir p-15056. 

I moved to West Shokan 20 years ago because the pristine 700,000 acres in the Catskill Preserve is to be left wild and untouched. The protected Catskills are considered Status 1 land under USGS “Gap Analysis Program” created in 1885. Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

As well as the transmission lines going right through our property,I have a business that would also directly be affected. Tourism is a big part of our economy.
Premium Energys proposal would be a complete devastation to our eco system, community,wildlife,streams and the millions that come to hike,bike,eat,visit our shops and take in the natural beauty every year.

None of the 3 locations proposed are right for this enormous, intrusive project.


Premium Energy is saying this is to be "closed-looped". It is not ,it is an "add on" and would likely increase turbidity within the Ashokan and its watershed.The redirection of water would likely impair the interconnectedness of the Ashokan watershed and its tributaries.

NYC has been famous for their drinking water because it comes from here! 
One little likely mishap could threaten the drinking water of nine million plus.

I urge FERC not to grant this preliminary permit to Premium Energy Holdings.

Thank you,Terri

Matt Shaw, Stone Ridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Matt Shaw

Linda  Armstrong, Olivebridge, NY.
I am writing in response to the proposed Ashokan pump storage project to be located in the Town of Olive, docket number P-15056-000.  The preliminary proposal was poorly thought out. It should be denied because of lack of facts and a general lack of merit. It should be rejected for legal reasons, for the impact on citizens’ use of the land for recreation, for the impact on a unique and important non fragmented ecosystem, for disruption of stream ecology, and for the impact on a tourist industry.
The legal ramifications of allowing a private company to ignore the New York State Constitution sets the stage for a destructive precedent. I, and my family, should be protected by our NY Constitution. I chose to live in the Town of Olive and raise my family there because of the protected land. My family makes use of the hiking trails in the Forever Wild Land and State Forest land. We also recreate on the Esopus. As bird watchers we spend considerable amount of time exploring the many species of birds in the protected Catskill Park. The Park is protected as a unique set of wilderness mountains in NY State. As a protected ecosystem, the Park harbors high elevation spruce/fir woodlands and the birds and animal species that inhabit these. The Park also protects the mixed hardwood forests. Important to each of these areas, the fact that they are protected in our Constitution makes the Catskill Park one of the only areas in the state where woodlands are not fragmented. Research has shown that fragmentation creates a vulnerability that disrupts the animal inhabitants. Research has used the wood thrush as an example. When wood thrush territory is fragmented the birds have a significantly poorer rate of reproduction. Bicknell’s Thrush inhabit the currently non fragmented high elevation areas in the Catskill Park. The negative impact on the ecosystems and its inhabitants will impact the local ecology of the Park, and my, and my family’s use of the area. Our mountain hiking will be impacted, our snowshoeing in the mountains will be impacted. Our mountain biking and fishing will be impacted, all in negative ways.
Turbidity naturally occurs in the Esopus with heavy storms or seasonal runoff. This impacts trout particularly. This project will significantly increase the levels and frequency of turbidity in the Esopus. As a result of stream degradation, the stream ecology and trout populations will be negatively impacted. Bald Eagles hunt the Esopus and need clear water for spotting fish. Thus the wildlife, and my family's use of the Esopus, for recreating, and particularly for fly fishing, will be negatively impacted. I chose to live here in the Town of Olive because these wild areas are protected by the State Constitution. Protected land should remain protected, that is the definition of the word. Projects such as this pump storage one need to be located on land that is not so special and important for ecosystems, recreating, and functioning for the local tourist industry. The Catskill Park is protected legally for good reasons. Energy projects need to be located on non protected land. That way green energy could be made use of, but not at the expense of unique lands in our state. I represent but one family, however my family is typical of countless people and families that recreate in the Catskill Park.
There is a successful tourist industry in this area. Countless people from New York City and New Jersey travel here to look at the fall colors, to ski at the ski centers, to hike and bird watch, and to enjoy the lovely vistas and clean air. Disruptions of roads, the presence of new high tension wires, the creation of a new reservoir which will actually look more like a huge bathtub that is filled and emptied  on a daily basis, and the years of infrastructure creation, could have a negative impact on the tourist industry. The need for energy and energy storage, is a fact, but there must be a consideration of obtaining this energy or energy storage in an area that is not so unique that it is legally protected by a State Constitution.

I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit.


Linda Armstrong
188 Grassy Ridge Rd
Olivebridge, NY 12461
P-15056:000

Maya Branman, Olivebridge, NY.
To Whom This May Concern:

I am yet again disturbed by the rush by inconsiderate corporations and entities to use and forever damage public lands for private gain.

The reasons why it matters to me is that I live here. This land is a buffer between the over development of cities and the expansion of human habitation. It is no joke. We need the land to be as it was designated to be in 1885. Even back then they appreciated the value of nature. this is my land. Not theirs. You need to protect the rights of citizens.

It would be easy for the developers to ignore the many scientific and moral reasons and go with something like, "Get over it." That's what happens time and time again with the powerful components of our society. They ignore the facts and use propaganda and power to take from us what is ours.

Here are some actual, intelligent, rational, scientific, moral, and humane reasons it is a bad proposition to take over public lands that are earmarked for recreation and heritage purposes:

1. Legal: It is currently illegal to develop this land as it was designated in 1885 as a Forest Preserve, which is Status 1 land. The Department of Energy designates Status 1 and 2 lands as being avoided for development. Given that fact, why was this project allowed to even start? That should be investigated. Someone dropped the ball at square one. Start a project where is legal in the first place instead of trying to bully taxpayers and trying to mislead everyone. It is not ok. We should not have to spend time like this trying to fight another battle with greedy people who move the lines of legality to suit themselves only.

2. Scientific: Stream ecology will be impacted, animal habitats will not withstand the fluctuations of water flow, trout breeding grounds will be impacted if not lost. They will be destroying habitats of millions of animals. How is that unimportant? 

3. Moral: the project is a lie, this is an add-on project, not a closed loop one. It would have significantly higher impacts than they say, and will cost significantly more. This project is manipulating information and should be stopped altogether and should be penalized for false representation and wasting valuable time of our officials and scientists. It is a major impact and is dressed as a minor one. This is not land for commercial use.

4. Humane: Animals will lose their habitats. Land will be destroyed, Our tourism in the Catskill will be impacted. 

I hate to bore people with reasons, when they are deluded with greed for money, and are propelled by that. Whereas the community at large are not aware or impelled as much and will sorely regret not having made their voices heard because they are not being driven by those same forces of monetary gain.

-- 
Thank you,
Sincerely,
Maya Branman

Jay Mahler, Kingston, NY.
April 9, 2021


Federal Energy Regulatory Commission
Attention: Vine Yearick, Director
888 First Street, NE
Washington, DC 20426

RE: P-15056 Premium Energy Holdings LLC Preliminary Permit application for the Ashokan Pumped Storage Project

Dear Director Yearick,

We, the below signed members of the Ulster County Legislature, hereby unanimously submit the following to be considered public comment in the matter of Premium Energy Holdings LLC Preliminary Permit application for the Ashokan Pumped Storage Project: P-15056.

Our commitment to sustainable, renewable power enterprises notwithstanding, projects of this nature should not, and cannot be initiated under a shroud of secrecy. We are appalled at the lack of transparency demonstrated thus far for a proposal of this size and scope located in one of New York State’s most protected regions. For the past month we have received repeated protests from local and state officials and community stakeholders who were caught off guard and by surprise. Regrettably we must count ourselves among those who were blindsided by the existence of a permit application for a Pumped Storage Hydroelectric power system under and upstream of the Ashokan Reservoir. 

It is incumbent upon us as Ulster County elected representatives to make sure that there is no harm caused to our communities. Even under the best of circumstances this proposal will cause serious upheaval to residents and visitors alike. It’s sad that Olive and the mountain communities have, for the last 100 years, worked with New York City to supply and protect one of the best water resources in the world. Now Ulster County communities, already stripped of 118,000 acres owned by NY City and another 250,000 owned by NYS, are once again being asked to cede more property both public and private. 

The current proposal appears to raise more questions than answers. Each of the proposed sites for the new upper reservoir present numerous concerns and questions. A quick and cursory reading of the proposal point to the blocking of spawning areas of a number of trout fisheries, potential, if not assured flooding of residential communities and access points to popular hiking trails, and serious encroachments on constitutionally designated forever wild lands.  Additionally, there are unknown effects on underground aquifers and private wells upon which hundreds Ulster County’s rural residents depend, and question as to how will this plant effect the turbidity in the Ashokan and by consequence the Lower Esopus; an issue this body has been struggling to have adequately addressed for more than a decade? 

We understand that this proposal is in its infancy and at a very preliminary point in the environmental review process. With that said, there has been an inexcusable lack of public notice and transparency. A project of this size and scope demands and deserves review and comment by elected representatives, residents, and community stakeholders. We take seriously our responsibility as the stewards of Ulster County’s unique and amazing natural resources and will continue to advocate for their preservation and protection. 

We appreciate your time. 
 

Sincerely, 


David B. Donaldson – Chairman, Tracey A. Bartels – Vice Chair, Jonathan Heppner – Majority Leader, Kenneth J. Ronk, Jr. – Minority Leader, Lynn Archer – District 21, Albert Bruno – District 2, Brian Cahill – District 4, Thomas Corcoran – District 11, Peter Criswell, – District 7, James Delaune, – District 17, Dean Fabiano, – District 3, John Gavaris, – District 15, Manna Jo Greene, – District 19, Heidi Haynes, – District 18, Herbert Litts, III, – District 9, Craig Lopez, – District 14, Mary Beth Maio, – District 10, John R. Parete – District 22, Laura Petit, – District 8, Kevin Roberts, – District 12, Abe Uchitelle, – District 5, Eve Walter, – District 20, Mary Wawro, – District 1


cc:	Paul Rush, Deputy Commissioner – NYC DEP Bureau of Water Supply     
	Kelly Turturro, Regional Director, NYS DEC, Region 3

Jennifer Amenta, ACCORD, NY.
(Jennifer Amenta]
[293 County Route 2, accord, Ny 12404]

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. I enjoy hiking and taking in the beauty of the Ashokan - I’d hate to see that devastated. 

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. 
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. 

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056!

Sincerely,

Jennifer Amenta

Sarah Bailey Hogarty, Ardsley, NY.
Sarah Bailey Hogarty
3 Chauncey Circle
Ardsley NY 10502

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risk compromising the integrity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a disastrous precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Be well,
Sarah Bailey Hogarty

Alex Teplitzky, Brooklyn, NY.
Dear Ms. Bose,

I am writing to you in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I feel that it is a deeply problematic proposal and I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. It’s clear that the project would have a devastating to the natural setting, to the community that lives there, and to New York’s drinking water supply.

The Preserve contains hundreds of thousands of acres of continuous wildlife habitat. I have visited this area often, and it’s a welcome respite for New York City denizens like myself. It would be a travesty to destroy this sacred and wonderfully preserved land. In a time when natural landscapes like the Catskill Mountains are increasingly a luxury commodity, it would set an awful precedent for protected lands across the country—not to mention in New York State, a place that prides itself on its natural environs.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Alex Teplitzky

David G Carroll, New Paltz, NY.
I am writing in response to the proposed Ashokan pump storage project to be located in the Town of Olive, docket number P-15056-000.  The preliminary proposal fails any basic “due diligence” test.  It should be denied because it ignores many basic critical facts pertaining to the proposed site. The impacts on a protected wilderness, on important recreational resources, on an important tourism industry, and perhaps most importantly on the availability of drinking water for 9 million people have all been ignored in this badly done proposal.
The Catskill Park is home to protected ecosystems including plants and endangered animals.  This protection is established in the New York State Constitution, and overriding that protection would set a dangerous precedent. 
Turbidity naturally occurs in the Esopus with heavy storms or seasonal runoff.  This ill-conceived project would make such turbidity a daily event.  The proposed lower reservoir is the Ashoken Reservoir, a major source of water for the 9 million people in New York City.  Currently this is one of the few major water systems which can operate without filtration requirements, but this project would destroy that.  A private for-profit company has NO right to inflict such a staggering costs on a unit of government while they pocket some profits. 
The tourist industry is critically important to this area. Many people from New York City and throughout the Northeast travel here to hike and bird watch, to see the fall foliage, and to ski at the ski centers.  Disruptions of roads, the presence of new high tension wires, the creation of a new reservoir which will actually look more like a huge bathtub that is filled and emptied  on a daily basis, and the years of infrastructure creation, could have a negative impact on the tourist industry. The need for energy and energy storage, is a fact, but there must be a consideration of obtaining this energy or energy storage in an area that is not so unique that it is legally protected by a State Constitution.

I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit.

David G. Carroll
11 Rousner Ln.
New Paltz, NY 12561
P-15056-000

Donna Winnie, Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

My family has lived in the Catskill Mountains for over 100 years and oppose the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment and wildlife, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you
Donna Winnie
80 Mountain Rd
Shokan, NY 12481

Eric Davison, West Kill, NY.
To whom it may concern,

I stand with Senator Michelle Hinchey and the Catskill Center in opposition to Premium Energy Holdings proposal for the Ashokan Pumped Storage Project. As a citizen living in close proximity to the reservoir I am against the construction and infrastructure required in the proposal. I greatly enjoy the scenic landscape and the life that abounds in and around the Ashokan and do not want increased traffic, noise, pollution and potential problems that come with a large scale project like this. As a fisherman I oppose the project for the impact it will have on the wildlife and water quality for years to come. Please reject this proposal. 

Eric Davison

Ingrid Price, Stone Ridge, NY.
Re: docket number P-15056-000, the proposed Premium Energy hydroelectric plant on the upper end of the Ashokan Reservoir.

This project would be detrimental in so many ways that I can hardly believe it is even being considered. For starters, the Askokan is an open system, meaning that the turbidity created by the daily release of water would impact both New York City’s drinking water quality, but also be the death knell for aquatic life in the already heavily-impacted Esopus Creek. 

Construction of a system of this scale would damage pristine and near-pristine natural areas in a place famous for its beauty and its healthy ecosystem. The creation of water basins would disrupt fish spawning, and bird and animal habitat. Human beings live in these areas, too. It is unthinkable that homes in families for generations could be razed, or their value reduced, by the intrusion of this massive project.

This proposal will benefit no one in the immediate area. The benefit to the power reserve in general is far outweighed by the negative impact it would have on local communities and natural habitats. 

Ingrid Price
PO Box 542
Stone Ridge, NY 12484
Re: Docket number P-15056-000

Davis Hall, Stone Ridge, NY.
The “Premium Energy” plan for a new hydro electric system is a terrible idea.


Frankly, I don’t see anything beneficial in this plan, but I do see damage to an area known for its beauty, its sports, and its wildlife.

I understand this has been tried before in “closed systems” (not affecting places where people actually live). But they’re talking about disturbing some of the most beautiful countryside in the Sate. Taking away land, places where people live, fish, hike -- affecting tourism, and the various reasons why people live in and visit the area. Furthermore, the quality of the water reaching New York City is bound to be adversely affected as more water churns up the Ashokan Reservoir.

With no guarantees that residents would see any real financial benefit. To me, a New York City resident who bought property in the area 30 years ago and pays taxes, I see a lose/lose situation.

A hundred years ago, the Ashokan Reservoir uprooted thousands of people, and the water which flowed to New York City came at the cost of towns, communities, and local history. That’s done, and the result is a delicate balance of beauty and infrastructure. Please, please, please, don’t mess with what we already have.

Trevor Hotz, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Trevor Hotz

FRANCESCA ORTOLANO, BOICEVILLE, NY.
Hello,
I am a homeowner and business owner in Boiceville, NY for the last 7 years. It will be a detriment to our community to have this Pumped Storage Project approved. Not only will it reduce home values in our area but will have an enormous impact on those who live around the area where the project will be located.
I am a realtor with an office in Boiceville, NY. The area in which I conduct most of my business is Olive, West Shokan, Woodland Valley, West Hurley, and Mt Tremper. It will seriously affect home prices! It will sway people from buying in the area where the proposed powerhouse will be. It will be a blight on the land where the proposed reservoir will be. The flora and fauna will suffer and there will be a terrible consequence to pay for lost habitat.
Let me make myself perfectly clear, I am deeply opposed to this project and will do all that I must to prevent this from happening.
Sincerely,
Francesca Ortolano
Boiceville, NY 12412

Katherine Burger, Kingston, NY.
Katherine Burger
41 West Bend Drive
Kingston, NY 12401
646-303-2409
Katherine.burger@icloud.com

April 9, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I am a long-time resident in Ulster County and frequent visitor to the Ashokan Reservoir. I’m aware of the history of the construction of this reservoir; that many communites were uprooted to build it. It obviously serves a crucial function, as New York City’s primary water source, but I am very opposed to another such project. In addition to displacing communities, it would negatively impact wildlife and the purity of our watershed.

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Kimberly Constable, Marlboro, NY.
The proposed hydroelectric plant is a threat the the Ashokan Reservoir. The Ashokan Reservoir, as part of the Catskills system for the NYC area, supplies up to 40% of the city’s daily needs. The reservoirs was carefully constructed, considering the local ecosystems and habitats to ensure safe drinking water. The hydroelectric plant could greatly damage this system in various ways. The powerlines will fragment habitats and ecosystems and disrupt the environment. It also would be disastrous for the tourist economy that exists as one of the few sources of support for the region. A hydroelectric plant would do more harm than good!

Jonathan Kaufman, Kingston, NY.
As a lifelong resident of Ulster County and passionate Catskills region advocate, I am submitting here my grievance with Premium Energy Holdings of California and the attempts to build a hydroelectric power plant underground. The drive to use green energy must continue, but not in a manner which contradicts the ultimate purpose to preserve nature. Once is enough! This project must not be allowed to begin nor continue any types of negotiations on the matter.

Marissa Ryan, Phoenicia, NY.
I am writing in response to the outrageous proposal by Premium Energy Holdings to build a plant in the Catskills. I strongly urge FERC to deny their request for permit for a number of reasons. If this project is allowed to proceed, it would be devastating to the environment, displace people from their homes, disrupt the local community, and risk the purity of NYC water. While these types of plants are necessary to move us towards more renewable energy, the Catskills are not the place to do this. This land is meant to remain protected. The pumped storage will wreak havoc on the local ecology. In addition to environmental impacts, the community would be ripped apart, displacing people from their homes in order to seize the land. There is already a housing shortage as more and more people are leaving city areas to move to upstate communities. These people will have no where to go if displaced from their homes. The local economy thrives partly on tourism due to the beautiful hiking and outdoor recreational opportunities it has to offer. This would also be severely damaged if this project proceeds, which would in turn have a large impact on local businesses. The impacts of this trickle down to all aspects of life in this community. Please consider this and put an end to this project. Save our community!

Lucy Childs, Big Indian, NY.
I am writing to voice my strong objection to the Ashokan Hydroelectric Storage Facility proposed by Premium Energy Holdings of California. The impact on the natural environment and our beautiful wilderness, as well as on the people of the Catskills Mountains will be egregious. Please say NO. Lucy Childs, Big Indian, New York

Clay von Carlowitz, Brooklyn, NY.
Hey there. I’ve fallen in love with the Hudson Valley over the last 9 years with my wife. Ever since our first trip there to celebrate our engagement, we’ve been returning multiple times a year, including for our wedding. Additionally, we’ve used the beautiful region for our film projects as actor-filmmakers, and the idea of that land being infringed upon truly hurts. Please don’t let this company destroy what is already good.

Yours,

Clay von Carlowitz

SUSAN JAWORSKI, Shokan, NY.
I am writing to FERC to encourage the rejection of the Application for Preliminary Permit for the Ashokan Pumped Storage Project as applied for by Premium of California.  

In reading the Premium of California application in section 1. General Construction, the application states  “The Project proposes to use the existing Ashokan Reservoir as a lower pool” and immediately contradicts that statement in the following paragraph “ The proposed Ashokan Pumped Storage Project would operate in a closed loop. “
The application continues to comment on the value of a closed loop plan proposal, but in review of the plans laid out in the application and with a local understanding of the Ashokan Reservoir upper basin, the plans do not meet the most basic commitment of closed loop.  The non closed loop plan as documented references the impact on the reservoir basin water with respect to water level changes but fails to consider or comment on the potential impact of increased turbidity in the existing reservoir system providing approximately 40% of the drinking water for New York City. 

In further reading of the application, it is clear that this proposal is so poorly prepared that a lay person as myself would hope that this proposal is rejected outright.  As a strong proponent of renewable energy and hence an understanding that pumped storage hydro will be an important part of our future renewable power needs, I read this proposal with interest.  For that reason, I also want to comment that all energy creation and storage is not equal.  If preserving a sustainable environment and meeting our human resources needs is our goal then a poor choice of location or strategy of locations for pumped storage must also be considered.  I advocate that the locations chosen in this proposal should also be rejected.  I will comment on those environmental reasons for rejection below. I advocate for a future looking strategy, understanding that it may well challenge our engineers and technologists, but a strategy that selects locations that avoid further impacting environmentally pristine wildlife habitat, which require generations to restore, should be the goal.  Preservation of existing natural environments is critical to any sustainability model.  Given our history of damaging environmentally sound sites to meet our resource needs in the past, we now have the opportunity to challenge our brightest minds to choose locations wisely.  With improved selection of locations, there is also an opportunity to restore native environments to locations that are currently being damaged or were previously damaged to meet  human needs.  I challenge our engineering communities to identify such locations, for example locations that are being or have been mined or quarried and have not yet recovered environmentally.

Notable aspects of the land being considered in this proposal:

The Department of Energy Hydropower Vision report documents their framework with “Sustainability” as one of three pillars indicating  “Ensure that hydropower’s contributions toward meeting the nation’s energy needs are consistent with the objectives of environmental stewardship and water use management.”  Further 3.3.4 Hydropower Environmental Considerations of the Hydropower Vision report highlights among others: critical habitat, species of concern, and protected lands.


Critical Habitat and Species of Concern:
The land identified in the proposal is home to several species that have received notable statements for protection:  the protected Three Birst Orchid registered in the Biological and Conservation Database for Northern America, identified Audubon Catskills Peaks Important Bird Area, northern long-eared bat summer foraging habitat and timber rattlesnake habitat identified NY-Threatened, black-throated blue warbler, scarlet tanager, and wood thrush habitat identified NY-Species of Greatest Conservation Need, raptors Cooper’s hawk, red-shouldered hawk and sharp-shinned hawk and eastern hognose snake habitat identified NY-Special Concern.

The streams and creeks impacted are both trout waters and trout spawning habitat.

Protected Land: 
The proposal’s impact to the Catskill Forest Preserve has had special protection under the NY State Constitution since 1885. Article XIV of the NYS Constitution specifically states that these forested lands "shall be forever kept as wild...". And that they "shall not be leased, sold, or exchanged, or be taken by any corporation, public or private." 

State Forest Preserves which includes the Catskill Park Preserve, are classified under USGS Gap Analysis Program. The Department of Energy Hydropower Vision report states “Areas with formal protections designated as Status 1 or 2 under the U.S. Geological Survey’s Gap Analysis Program are avoided for development.”

Lastly, a few generations back the communities and the natural environment contained within this proposal were severely impacted to meet the drinking water needs of nearby New York City.  There is an ongoing relationship that requires significant management to meet the needs of our NYC neighbors and the livelihoods of our remaining communities.  I will let NYC comment on the impact of this proposal to the NYC drinking water, but I will note that our communities' livelihoods are significantly built on a tourism economy from our amazing protected natural resources.

Thank you for consideration

Ryan Oskin, Big Indian, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Ryan Oskin

Steve zaniel, Olivebridge, NY.
am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  The proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Annarose Lipkin, Chichester, NY.
Dear Kimberly D. Bose and the Federal Energy Commission,

I am a resident of Chichester, Ulster County, New York just south of a potential dam in a project proposed by Premium Energy Holdings, under review by FERC (docket #P-15056-000). I must state my opposition of the granting of even a preliminary permit. There are many problems with the proposed hydropower plant currently under consideration. It appears there was little consideration of a multitude of factors that make the Catskills Park an inappropriate place for this project. Below I list a few of them.

First of all, the Catskills are a State preserve protected by the NY State Constitution. The Catskills Forest Preserve, in the midst of which this project would be situated (the project states falsely that it lies outside of the protected Catskills Preserve, but it does not), is considered status 1 land under the USGS gap analysis program according to the US Dept. of Energy’s own Hydropower Report. Stoney Clove Stream (and the entire Ashokan Reservoir connective tissue of streams and rivers)is a very important and living resource for wildlife that depend on it for survival, the whole reason the preserve exists to begin with.

This proposal is both deficient and misleading. The system is not a closed loop as stated. As proposed it is actually an open loop system. The damage from this kind of system on the environment would be quite significant and destructive to the surrounding area for wildlife as well as for the local economy. Giving an example of its impact on humans and nature together, it contributes to the life of aquatic organisms that feed trout, who then in turn supply the surrounding area with fisherman who contribute to the economies of many towns and hamlets involved in the ecosystem. It is a source of food and water for the deer, bear, coyote, other smaller animals and birds of the area as well.

There would creation of increased water turbidity in the Ashokan Reservoir, which is dealing with these problems already and would negatively impact the water system that serves as NYC’s drinking water. 

I support the movement away from fossil fuel reliance towards renewable energy, and understand that hydropower is a strong component of this progress. The Catskill region however is the wrong placement for such projects. Please do not allow this project to continue.

Sincerely,
Annarose Lipkin

Sandra Friedel, West Shokan, NY.
I am 81 years old , lived in Olive since 1981 and just can’t fathom leaving my home which is in the center of this proposal. It would put my home 50 feet under water. The only way I plan on leaving is dead in a pine box.

Our area would be impacted with high tension wires, compromised wells, disruption of businesses, lives , tourism, and flood plain risks for those near the project. The water quality feeding the reservoir which feeds NYC will be disturbed. If water temperatures are warmer bacteria grows. Like Texas this past winter, their system was damaged resulting in loss of power for days in freezing temperatures. 
The only thing green about this for profit project is the green in the pockets of the outfit proposing the underground hydroelectric project.

Please do not let this happen. We lost a whole town when the reservoir was built. We do not such development again.

Respectfully,
Sandra Friedel property owner here in Olive.

Jonathan Nathan, Boiceville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am a fulltime resident of Olive, NY and I am deeply concerned and opposed to the woefully flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains, my home. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the treasured environment, highly disruptive to me, my neighbors, and other local communities, as well as presenting a significant risk to the quality NYC’s drinking water.

I am well aware of the need for additional sources of energy to meet the increasing demands of our society. This proposal is not the way to do it, not by any means. The environmental devastation, social disruption, and host of other negatives far outweigh the benefits this hydroelectric power plant would provide.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jonathan Nathan
Olive, NY

Laura Ireland, Prattsville, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Laura Ireland

Deborah Bagg, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Deborah Bagg

Joshua D Holz, Phoenicia, NY.
Dear Ms. Bose,

I am writing in response to the destructive proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains.

I grew up and spent my childhood on my family's farm at 1118 Woodland Valley Rd., where an enormous dam threatens to carve out and flood the Esopus. Us residents of Woodland Valley are no stranger to our ecosystem and community being threatened by big business and water projects. Even so, Premium Energy Savings has proposed the most invasive and radically destructive plan I have witnessed in Woodland Valley. Putting a dam in the Esopus would be detrimental to wildlife and the environment, destroying an entire community of fauna and flora in the stream.

I immensely worry for my parents who have lived in Woodland Valley for most of their life and have built a community there. We hosted a 4H Club for over a decade where local youth got hands-on experience with farming and agriculture. My mother continues to use the land and raises some livestock and my father grows much of our food in our garden. I fear for my parent's safety with a power plant obliterating the Esopus, potentially flooding our home and destroying an ecosystem. This invasion has no place in our community. 

Our property floods most summers from rain storms, and I can only imagine how a massive reservoir would corrode or destroy our house and neighbors'. Premium Energy Holdings's plan is purely big business, and happily uses our community and the environment as collateral. It is not a realistic or safe plan, and will have a catastrophic impact on our road. 

It's a toxic plan that will have unforeseeable consequences on our ecosystem for decades. FERC must decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Signed,

Joshua Holz
1118 Woodland Valley Rd.
Phoenicia, NY
12464

Christine pfister, Hudson, NY.
This proposal is a slap in the face that we cannot stand for. A California company with no concept of the unique infrastructure and glorious environment of the Hudson Valley has made it their mission to contaminate our waters and decimate our ecological systems. This is a blasphemous catastrophe under the guise of environmentalism.
The Hudson Valley land is our home and this water is our life- the proposal aims to strip our community of a safe and healthy future. To even consider this is a betrayal.

Lisa Hatfield, Lanesville, NY.
The flawed application should be denied for multiple reasons, including:

The project would disrupt the environment of the Catskill Forest Preserve, 700,000 acres of critical habitat in an increasingly fragmented world. Any feasible site in the Catskills would impinge on USGS-designated Status 2 land. Federal policy directs that Status 1 and 2 land areas are highly protected and must be avoided for development.
The proposed project will severely disrupt streams within the Ashokan watershed, and increase turbidity in the Ashokan Reservoir itself—which serves as a primary source of unfiltered drinking water for 9 million New York residents.
The flawed application misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design, which means it has worse environmental impacts than closed-loop hydroelectric projects.
The project raises numerous legal issues regarding States’ rights and land preservation.
The proposed site is home to protected species of wildlife and flora/fauna, as well as historical and cultural artifacts and

Melanie Bybee, Kingston, NY.
The proposed hydroelectric power facility would be against the public’s interest and would greatly impact the Catskills beauty. NYC has always protected the water supply and made a significant effort to protect the environment. Moving forward with this permit goes against that initiative entirely. Don’t. Allow. It.

Submission Description: (doc-less) Motion to Intervene of Richard Lipfert under P-15056-000.

Submission Date:        4/9/2021 12:36:38 PM

Filed Date:             4/9/2021 12:36:38 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               richlipfert@gmail.com                                                            

Basis for Intervening:
Submission Description [ doc-less ] motion to intervene of Richard Lipfert under P15056-000

Basis for intervening
As a homeowner at 52 Brodhead rd West Shokan, NY within the Town of Olive NY , I and my home will be directly impacted by the proposed Pumped storage project due to the proposed high tension lines going directly over to top of my home. I request intervener status.

Submission date 4/9/2021
Filed date 4/29/2021

Dockets P-15056-000 application for preliminary Permit for document of Premium Energy Holdings, LLC Ashokan PSP under P15056

Richard Lipfert
52 Brodhead Rd
West Shokan, NY 12494
845 417-6974
richlipfert@gmail.com

Jennifer Hamblett, WEST SHOKAN, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jenny Hamblett
West Shokan Resident

Nathaniel Gillespie, Phoenicia, NY.
April 9, 2021

Dear Ms. Bose,

I am writing to voice strong opposition to Docket P-15056-000 Ashokan Pumped Storage Project submitted by Premium Energy Holding, LLC.  Our family would be directly impacted by the proposed reservoir planned for Woodland Valley.  Our property at 624 Woodland Valley Road, Phoenicia, New York, held in the family and occupied since the 1830’s, would be sacrificed for the construction of the proposed reservoir.  I am a member of Woodland Valley Farm, LLC, 20 acres in size, and my extended family owns Woodland Valley Woods, LLC, approximately 105 acres in size, and Botchford Heritage Preservation, LLC, approximately 60 acres in size, which are under permanent conservation easement with New York City Department of Environmental Protection.  These properties are bordered by New State Forever Wild Lands and other lands owned by NYC DEP.  All of these land designations would be make it illegal to obtain under eminent domain and would be illegal to develop under current New York State Law.  The proposal is ill-conceived, would pose great risk to New York City’s unfiltered drinking water system, would irreparably harm local communities, would significantly impact valuable recreational fisheries and the local tourism economy, would negatively impact New York’s decarbonization objectives on balance, and would degrade an irreplaceable valley of global significance.  For these many significant impacts and flaws, I urge you to reject Premium Energy Holding’s preliminary permit request.

Beyond the loss of our family property invaluable to me and my family, Premium Energy Holdings, LLC proposed reservoir construction and operation would generate unacceptable risk to New York City DEP’s unfiltered water via numerous acute short-term and chronic long-term impacts. Our property, most of which is under Conservation Easement with NYC DEP to protect quality, and the larger Woodland Creek watershed, currently serve an important role in maintaining the unfiltered water supply for New York City via their contribution to the high- water quality currently found in Woodland Valley Creek, several tributaries and wetlands located on the property, and the local groundwater sources.  The proposed reservoir and pumped storage operation would highly alter and negatively impact all of these important hydrological resources.  Construction of the reservoir dam, associated blasting for the dam and connecting underground tunnels, land clearing and clearcutting to remove standing vegetation beneath the reservoir pool, and roadbuilding to replace many miles of Woodland Valley Road would all cause significant fine sediment, turbidity and water quality impacts to Woodland Creek, Esopus Creek and the Ashokan Reservoir for many years.  The proposed construction of a receiving reservoir adjacent to the Ashokan Reservoir would double the impact via these acute disturbances and associated turbidity to the New York City unfiltered drinking water supply, therefore the proposal is far too risky to approve.

But the major water quality impacts would not be limited to the 5 or more years of construction and disturbance: the proposed reservoir site within Woodland Valley is highly problematic.  This proposed site contains numerous natural deposits of glacial clay, which when eroded periodically by Woodland Creek produce high levels of turbidity within Woodland Creek and Esopus Creek.  The daily fluctuation of the proposed Woodland Valley Reservoir to serve the pumped storage needs would erode and resuspend fine sediment and colloidal clay found in numerous naturally-occurring glacial lacustrine clay deposits throughout the stream, floodplain and valley.  The proposal has not identified this risk to Ashokan reservoir, which provides 40% of the unfiltered drinking water to 9 million New York State residents.  Operation of the proposed hydropower pump storage reservoir typically results in reservoir water levels fluctuating greatly over the course of a day in response to energy needs.  This frequent reservoir fluctuation, however, will cause bank erosion, and stream bank and stream bed erosion by Woodland Creek at the reservoir inlet will contribute to much greater and more frequent inputs of fine sediment and turbidity into the proposed reservoir, Woodland Creek, and ultimately into Esopus Creek and the Ashokan Reservoir.  

The proposed reservoir site is currently unstable and prone to erosion and heavy turbidity events.  The Ashokan Stream Management Program’s Woodland Creek Stream Management Plan from 2015 https://www.dropbox.com/s/bnw0t97tb7cfb1j/Woodland%20Creek%20SMP.pdf?dl=0
determined that 49% of the total stream length of Woodland Creek was not stable, but needed assisted restoration or full restoration in order to reduce bank erosion and stream instability. Creation of the proposed reservoir, a massive disruption to stream equilibrium, will increase erosion rates of stream banks upstream of the proposed reservoir pool, thereby increasing fine sediment and turbidity inputs into Esopus Creek and the Ashokan Reservoir.   The Ashokan Stream Management Program’s Woodland Creek Stream Management Plan notes each of the 7 management units along 6.3 miles of Woodland Creek assessed in 2015 contain multiple deposits of lacustrine clay, but these colloidal clay deposits are particularly problematic for NYC DEP reservoir management in the Ashokan, and heavy amounts of these suspended clay particles have necessitated the use of alum by NYC DEP to ensure clarity for drinking water delivery over time, therefore, these clay deposits will be mobilized with much greater frequency from greater stream instability.  How would the proposed hydropower pump storage project therefore manage or mitigate chronic turbidity impacts that would risk significantly threatening the ability of NYC DEP to achieve its drinking water supply objectives, and meet the terms of the 2017 Filtration Avoidance Determination? 

(letter continued)

Ginger Strand, Phoenicia, NY.
Secretary Kimberly Bose 
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426 

Dear Secretary Bose,

I am writing to raise concerns about Premium Energy's proposal, docket # P-15056, to build a pumped storage hydroelectric plant utilizing the Ashokan Reservoir as its lower reservoir. This proposal does not meet the FERC standard for granting a preliminary license. As an environmental journalist, I am aware of the critical importance of energy storage to our increasingly renewable grid, and am in favor of new pumped storage plants. However, we should not let our haste to build storage capacity blind us to the problems with this proposal.

Key ways the proposal is deficient:

1. Premium Energy seems completely unaware that their proposed project is situated in a highly protected State Forest Preserve, and--like any conceivable project damming a valley in the Catskill Forest Preserve--would necessitate the taking of state land via eminent domain. The Catskill Forest Preserve, created in 1885, is enshrined in the New York State constitution, which states that the land in the preserve "shall be forever kept as wild forest lands. They shall not be leased, sold, or exchanged, or be taken by any corporation, public or private." Removing any of these lands from this level of preservation for any purpose requires a state constitutional amendment, voted on and approved by two consecutive sessions of the state legislature, then submitted to a statewide referendum. Of the 2000 amendments proposed in this way since the formation of the Preserve, only 20 have passed. Premium Energy's proposal seems based on the unlikely assumption that such a state constitutional amendment will pass.

2. Premium Energy seems unaware that to develop land in such a highly protected area goes against the Department of Energy's own statement of mission. Any conceivable reservoir project inside the Catskill State Forest Preserve would impinge on highly protected state land in the Catskills that is considered Status 2 land under the USGS Gap Analysis Program. According to the Department of Energy's own "Hydropower Vision" report of 2016, "areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development." 

3. Premium Energy states that this proposal is for a "closed-loop" project. Clearly they are calling it such because the Department of Energy has an interest in supporting closed loop projects. However, the system Premium Energy describes is NOT  a closed-loop system. It is an add-on project to an existing reservoir that is continuously connected to a naturally flowing water feature. According the Department of Energy Report "A Comparison of the Environmental Effects of Open-Loop and Closed-Loop Pumped Storage Hydropower" (2020), add-on systems have initial construction impacts that are lower than open-loop systems, but "operational impacts are still likely to be higher than for closed-loop projects because the add-on project's lower reservoir is still continuously connected to, and may affect, the naturally flowing water feature that was dammed for its original construction." Premium Energy's proposal engages in a concerning level of misdirection and falsification.

4. The naturally flowing water feature that was originally dammed to construct the Ashokan Reservoir is Esopus Creek, which is not only an asset of high environmental value in the Catskills ecosystem, but is part of the New York City water supply, the largest unfiltered water supply in the nation, and an infrastructure asset worth tens of billions of dollars to the city of New York. The quality of this water supply is governed by a regularly updated Filtration Avoidance Determination issued by the EPA. The most recent EPA FAD of 2017 included the implementation of turbidity reduction measures and the continuation of monitoring of these measures by an expert panel at the National Academies of Science, Engineering, and Medicine. The fact that Premium Energy appears completely ignorant of these additional protections to the water supply, and has not addressed how turbidity would be affected by a pumped storage project on the reservoir, suggests a total failure to understand both the complex ecosystem, and the complex regulatory environment in which they are proposing to work.

5. That complex regulatory environment also includes the Delaware River Basin Compact, a federal-interstate agency created in 1961, to which many Catskills towns, including the town of Shandaken, home to two of Premium Energy's alternative reservoir sites, are signatories. Article 9, Section 2 of the DRBC states that " The commission may develop and operate, or authorize to be developed and operated, dams and related facilities and appurtenances for the purpose of generating hydroelectric power and hydroelectric energy." At the very least, the failure to notify the DRBC of the plan means that Premium Energy is inadequate on FERC Section 4.32 II C.

6. Premium Energy failed to notify Greene County (inadequate on 4.32 II A), the Greene County Soil and Conservation District (inadequate on 4.32 II C), the town of Hunter (inadequate on 4.32 II D).

7. The application if also deficient in its failure to provide specifications of the existing dam, the dividing weir (of which they seem totally unaware) or the spillway in the existing Ashokan Reservoir (inadequate on 4.81 VII A 1 a-e.

7. A host of other problems with the proposal--blurry maps utilizing outdated topographic views, GPS locations that don't match up with the maps or the narrative--suggest that this proposal was hurriedly and carelessly created. This is not the kind of work that should be allowed to proceed in land as highly protected as the Catskill Forest Preserve and the New York City watershed. I respectfully request that FERC deny this preliminary license application.

Sincerely yours,

Ginger Strand
198 Pantherkill Road
Phoenicia, NY 12464

Nathaniel Gillespie, Phoenicia, NY.
(Continuation of Opposition Letter)

The proposed reservoir’s disruption of the natural sediment regime of Woodland Creek and Esopus Creek is not limited to water, but will eliminate many miles of important trout habitat needed by both of these economically important and historically famous fisheries.  Woodland Creek itself serves as an important and valued recreational resource in its current state for me and my family, but the proposed reservoir will cause irreparable harm to this this stream, eliminating 3 miles of it beneath the reservoir.  Woodland creek serves as an important spawning tributary to Esopus Creek, and the proposed reservoir would damage the valuable recreational trout fishery on Esopus Creek, as it provides critical spawning and rearing habitat for wild brook, brown and rainbow trout which migrate annually from the Ashokan Reservoir and the Esopus Creek to use these fertile headwaters to spawn.  A proposed reservoir at 300 feet in height would form a complete fish passage barrier to upstream movement and migration of trout and other fish species.  The migratory trout of the Ashokan Reservoir/Esopus Creek system is a world-famous wild rainbow trout fishery that generates significant dollars in local economic activity as a recreation destination, but the proposed dam but would force the complete loss of access for trout to more than 5 miles of Woodland Creek, which is classified as Trout Spawning by New York State Department of Environmental Conservation (NYS DEC), and 8 miles of tributary habitat, which is classified as Brook Trout habitat by NYC DEC.  This complete severance of more than 13 miles of trout habitat to spawning and rearing habitat of the larger Esopus Creek system would negatively impact the trout population and degrade this popular and acclaimed recreational fishery. 

If the proposed project is permitted to be constructed, it would also degrade the Esopus Creek fishery downstream from altered water temperature, sediment regime and water quality impacts from the proposed reservoir construction and operation.  The reservoir would damage this highly-valued coldwater aquatic ecosystem and trout fishery with increased summer water temperatures caused by solar radiation of the reservoir surface.  Has the applicant recognized to the potential negative effects of the proposed pumped storage reservoir on the Woodland Creek, Esopus Creek and Ashokan Reservoir and their cherished wild trout fishery?  How would these be mitigated? They cannot be replaced.

As New York State begins to activate on its statewide decarbonization goals, this proposed project would apply to destroy hundreds of acres of intact, highly functioning forest and soils that are sequestering carbon.  Has the applicant defined the amount of carbon loss that would occur from the elimination of hundreds of acres of forest for the two proposed reservoir pools, the thousands of acres of forest and soil disturbance from associated development or roads and infrastructure, and the installation of many miles of powerline infrastructure?  As a society, we need to protect and increase the health and function of these forests so they can help our country sequester carbon and ultimately mitigate climate change.  What are the carbon costs to the state for the construction of the 300 foot tall concrete dams? What are the carbon costs associated with the electricity needed to pump water to the upper reservoir over the life of the project?  All of these questions need to be answered before claiming the project will not be contributing to carbonization of the atmosphere and the associated negative impacts on New York State from a changing climate.

Finally, Woodland Valley and the Upper Esopus Creek are confirmed be a circular drainage formed by an ancient asteroid impact, representing a unique geologic phenomenon of global significance (NASA 1992), but Premium Energy Holding’s proposal for a potential pumped storage reservoir, tunnel drilling, infrastructure and associated land disturbance fails to recognize this outstanding and rare designation. The Panther Mountain circular drainage, formed approximately 375 million years ago, represents one of only a handful of such places on earth.  The Panther Mountain watershed including Woodland Valley should be designated a world heritage site and be afforded the protection from large scale development as proposed by Premium Energy Holding.

For all of these reasons described above, I urge you to reject Premium Energy Holding’s proposed preliminary application for Docket P-15056-000, Ashokan Pumped Storage Project.

Respectfully,
Nathaniel Gillespie

Ian Marchant, Rhinebeck, NY.
I am in support of this concept, however there are some concerns with this project. The need for this type of project is important to support the development of renewable energy generation. As a Certified Energy Manager I am have a good understand of the energy needs of this state and country and the efficient utilization of energy.  Pumped storage is a proven technology and once constructed is environmentally friendly. 
As a frequent visitor to state public lands, my major concern of this project is the impact on public lands. The Catskill Park is protected by the State Constitution to be forever wild.  Additionally this land is open for all visitors to enjoy.  Any pumped storage project must maintain this public access to state lands.  While some people feel flooding of this land by such a project violates the State Constitution, I see it as a benefit as long as the newly created lake becomes publicly accessible both that on current public land and that land purchased for this project for the purpose of creating the upper reservoir. Additionally, any new infrastructure (Dams, Intakes, Pumps, pipelines and transmission lines, etc.) must be located on land that is not currently protected state land.  If any state land is required it must be replaced with a greater amount and value of land being used for this project. Such a land swap must be achieved through a statewide ballot refrendum to amend the State Constitution.

Michelle Koval, Brooklyn, NY.
Please do not proceed with this project. It damages many acres of beautiful forest around the reservoir and it impacts the life of my mother who lives in west shokan and wires are going to be put on her property. Many of us in the community oppose this project

Michelle Koval, Brooklyn, NY.
Please do not proceed with this project. It damages many acres of beautiful forest around the reservoir and it impacts the life of my mother who lives in west shokan and wires are going to be put on her property. Many of us in the community oppose this project

Beth Lamberty, Oconomowoc, WI.

Dear Ms. Bose,
I’m writing to OPPOSE the Proposed Pump Storage Hydroelectric Plant, FERC project number, P-15056.
I agree we should be finding new and better ways to use renewable energy and a storage plant does sound useful, the Catskill Mountains are not feasible for several reasons. It will hurt the tourism economy, displace people who won’t be able to afford or find housing in the area, be devastating to the environment and risky for the purity of NYC ‘s drinking water.

*Being retired we’ve traveled to the Catskills’area four to five times a year from our home in Wisconsin for more than ten years, spending our only tourism dollars at Orchards, Restaurants, Stores and Parks, Vacation Rentals and Hotels. New York’s Economy depends on visitors, with 17% of employment in the Catskill region in 2019 bringing in 1.6 billion dollars and supporting 20,000 jobs. 43% of that market being Ulster County. Second Homes generate $360 million in economic activity. (Source: Tourism Economics, “Economic Impact of Tourism in NY”, 2019.) 
Whichever proposed area you use would have a negative impact on the tourism of the area, due to the construction, lane closures, etc. I can’t imagine miles of cement trucks and construction vehicles even driving on the twisty roads through the forest, bumper to bumper up and down the narrow roads in the area. 
*With the real estate values almost double in the last three years in the Catskills area and New York City workers realizing this two-hour drive from their corporate offices provides the perfect placement of their work from home offices, this trend will continue, unless of course, they must relocate their homes and business with this plan. Displaced families may very likely find that they can no longer afford the area.
Since the beginning of time the Catskills have been home to people who care for and about this land. Walking the trails in the parks you feel the presence of the Esopus Tribe of Native Americans and know that you are seeing the land as they saw it. Upstate New Yorkers, and visitors are privileged to have this place to be in nature and with nature close to how it once was and they respect it, and it is to be RESPECTED by all.
*This must be what inspired them to, in 1885 create The Catskills Forest Preserve and later to PROTECT it. It enchants visitors and residents with 700,000 acres of continuous wildlife habitat. The forest around the proposed sites ranks among the top 1% of forest habitats region wide according to New York State Forest Condition Index. As a State Forest Preserve, the Catskills are considered Status 1 Land under USGS” Gap Analysis Project”. According to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under USGS Gap Analysis Program are AVOIDED for development”.
*Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

*According to The Catskill Park: Inside the Blue Line - Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then summited to the public in a referendum. 

One reason for all of this is to protect the land, wildlife, the birds, which fall within Audubon’s Catskills Peaks Important Bird Area, and the trout waters in the Esopus River. The trout breeding habitat would be lost if this proposed project goes through. Not to mention the historical buildings that may be lost in the area.

* A pumped storage upper reservoir will be subject to rapid fluctuations of water which will severely damage both land and aquatic habitats. The sediment regime will be altered in tributaries to the Esopus River and also the NYC water supply!

*Forty per cent of NYC’s water supply, provides 1 billion gallons a day to 9.5 million people that will be impacted, according to the DEP.  When the Ashokan Reservoir was built 25 communities were displaced and billions of dollars were invested, $1.7 billion since 1990’s alone. It’s currently the largest unfiltered water supply in the nation and it currently meets the needs of NYC but it must be protected. Climate change evaporation, heat events, and decreasing snowpack already produce uncertainty and adding a storage plant will produce turbidity of the Ashokan Reservoir that will greatly affect its water quality.

*And lastly, the Department of Energy prefers closed-loop projects that have smaller environmental impact and may be eligible for streamlined FERC approval, but adding to the existing lower Ashokan Reservoir/Watershed will be an add-on project, not a closed-loop project. 
By Premium Energy lying in their application, to the public and FERC, with their sole purpose of being fast tracked for approval, they are telling us they cannot be trusted in anything they promise to do. 

Transitioning to renewable, green-energy sources must not devastate this pristine environment! 
One hundred years ago, 25 communities were affected by the building of the Ashokan Reservoir and people are still not over it. If you must affect the lives of several more communities for generations, choose an area that is not as beautiful and cherished by so many. And at least do not re-traumatize the same people!
PE should follow the Department of Energy’s Hydropower plan, and the NYS Constitution and don’t create mistrust by lying.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Beth Lamberty
W383N9049 Mill Street
Oconomowoc, WI 53066

Joe White, Kerhonkson, NY.
DOCKET# P-15056-000

I am writing to voice my strong opposition to the Premium Energy Holdings proposal for the Ashokan Pumped Storage Project. DOCKET# P-15056. 

The company in question is being duplicitous about its intentions in order to ram through this shoddy project.
Premium is claiming to be “closed-loop.” project. 
Closed loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval. Contrarily, projects where an upper reservoir is added to an existing lower reservoir are known as
“add-on” projects; that’s what this really is. They are lying.  

This project will be devastating, not only to The Catskill Preserve, but also to its wildlife, the surrounding water systems, all the residents of the area, the thousands upon thousands of tourists who visit this pristine and beautiful area every year (which is an economic boon to the area) and the millions of New York City residents, whose drinking water will be adversely effected. 

According to the DEP. The Ashokan Reservoir and watershed, provides 40% of NYC’s water, a water supply that provides 1 billion gallons a day to 9.5 million people. This valuable capital asset, represents $1.7 billion since the 1990s alone. Another reason that this economically unsound project should be denied.

‘The Environmental Species Act’ protects much of the wildlife on this preserve. Which is yet another reason to deny Premium.

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Under Article XIV of the NYS Constitution, the Catskill Preserve lands “shall be forever kept as wild forest 
lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
FERC cannot selectively choose if they will abide by the NY State Constitution.

It is for all these reasons (stated above) that I vehemently oppose this proposal. It must be struck down. I Vote NO!

Best,

Joe White
20 Tilly Rd
Kerhonkson NY 12446

Coalition to SaveCatskillsPreserv, West Shokan, NY.
Coalition to Save Catskill Preserve

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426

Docket P-15056-000

Dear Ms. Bose

We are submitting these comments on behalf of the Coalition to Save Catskill Preserve.

The Coalition is a newly formed grass-roots network composed of a growing number of residents and community groups of the Catskill Region of New York State and their allies.  In our dedication to protecting the environment, wildlife, recreation, cultural heritage and local communities, we are expressing profoundly serious concerns with the deeply flawed proposal submitted to FERC by Premium Energy Holdings to construct a hydroelectric plant in New York’s Catskill Mountains
  
The Coalition now consists of more than 200 members from the region and 20 organizations and is growing daily. Coalition members live both in and out of the region and are dedicated to protecting the ecology and history of the Catskill Preserve from misguided and inappropriate exploitation of this area, as exemplified by the Premium proposal.

This project must be rejected because it would disrupt the environment of the Catskill Forest Preserve, 700,000 acres of critical habitat in an increasingly fragmented world. 

Any feasible site in the Catskills would impinge on USGS-designated Status 2 land. Federal policy directs that Status 1 and 2 land areas are highly protected and must be avoided for development.



Furthermore
•	Implementation of this project would require a NYS Constitutional Amendment requiring passage of both Houses of New York State Legislature, a public vote, and a sign off by the Governor. 

•	It will flood over 200 acres of private land and protected state forests to construct a new reservoir

•	The new reservoir would be connected to the Ashokan Reservoir by a tunnel up to 50 feet wide and many miles long, drilled under both public and private lands, and the erection of at least 12.9 miles of 230kV high-tension transmission lines.

•	The project will threaten endangered species, impact the NYC water supply, discourage tourism, and have a serious negative economic impact on the region

•	It will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for over 9 million New York residents. 

•	It will severely disrupt existing regional wells and septic systems which in turn will negatively affect the quality of water regionally and in New York City.  

•	Premium Energy misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design with worse environmental impacts.

•	The project would require the seizing of many private parcels via eminent domain, the devaluation of even more additional private parcels and the construction of a massive concrete dam up to 300 feet tall. 

•	The applicant, Premium Energy, has failed in its due diligence obligations. They have made numerous factual errors and omissions in both the original and amended application. They are clearly unqualified to design, construct or maintain a project of this scope.  

We clearly recognize the need for our nation and world to transition to green-energy sources. However, this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, contaminate local wells and septic systems, and negatively impact the drinking water of over 9 million New Yorkers.


The Coalition urges FERC, as responsible public officials, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Kristy L. Barnes, Saugerties, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

WE MUST PROTECT OUR DELICATE 
LY BALANCED ENDANGERED SPECIES, ECO SYSTEMS & WILDLIFE AS WELL AS OUR HOMEOWNERS & FIGHT THIS! ~~~PLEASE DO THE RIGHT THING & DENY PREMIUM ENERGY'S PROPOSAL~~~ for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

John Patten, West Shokan, NY.
The environmental destruction of protected lands and economic and social disruption from this project far outweigh the purported benefits. The project only benefits Premium Energy, while severely degrading the local area. It is uncertain whether or not it would actually lower energy costs.   

Commenters have been advised that FERC does not weigh harmful human and social damage of proposed projects, which is in itself appalling. However please consider that when the Ashokan Reservoir was constructed between 1907 and 1915,  the New York City Board of Water Supply impounded the Esopus Creek, submerging thousands of acres of farmland. The impoundment covered twelve communities located in a valley where farming, logging, and quarrying prevailed. Approximately two thousand residents along with roads, homes, shops, farms, churches, and mills were either moved or abandoned, but most of them were torn down. Substantial bitterness remains among the residents of these towns whose families and ancestors were so cavalierly dislocated. 

The massive statutory and procedural barriers to implementation of this project indicate protracted, expensive legal proceedings for Premium Energy and it's legions of opponents. 

Please reject this outrageous application to destroy natural areas for corporate profit.

Linda Meyers, Chichester, NY.
Linda I. Meyers, 152 Stoney Clove Lane, Chichester, NY. 12416


I am a resident of Chichester, NY in Ulster County, and I am writing to strongly oppose the granting of a preliminary permit to Premium Energy Holdings. While I support our nation’s transition to renewable energy, I believe the Catskills region is not the right location for such a project as it will significantly impact state preserved forest land, streams, species, and the New York City water supply. The harm that would be done is unlawful and in violation of the New York State Constitution. Further, Premium Energy does not provide the kind of innovation sought by the Department of Energy as its proposal is deficient and misleading. Premium Energy’s claim that it will build a closed loop-system is false. Their proposal is actually an open loop system, an add-on project where an upper reservoir would be added to an already existing lower reservoir connected to a natural water source.  As you know, the environmental and aquatic impact of such an open loop system would be significant and damaging. 

The company also falsely states that the project will take place outside the boundaries of the protected Catskills Preserve. Closer study indicates that its proposed sites are actually located squarely within the Catskills Forest Preserve (established 1885). This area is protected under Article XIV of the New York State Constitution, which deems the lands shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any changes in the management of State Forest Preserves have to be passed by constitutional amendment, which involves both state legislative approval and a public referendum. Otherwise, it is unlawful and unconstitutional. Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. According to the US Department of Energy’s own Hydropower Vision report, areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.

I believe the protected status of the Catskills Forest Preserve; the misleading nature of Premium Energy’s proposal; and DoE’s mandate to avoid Status 1 land are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.
Sincerely,
Linda I. Meyers

Sara M Van Eerde, New Jersey, NJ.
Please don't build a dam in the reservoir. The Catskills are a State Preserve protected by the NY State Constitution.
It would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water. It would affect the 9.5 million new yorkers who rely on this drinking water.

Gail Margulis, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a hydro electric power plant in the heart of the Catskills Mountains in New York. I desperately urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment. 
I am a resident here and am thus learning as much as I can about both hydroelectric power and the appropriateness of such a plant in this place, which is protected by its "forever wild" status. It says in the NYS Constitution that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Given this, and the special, uniqueness of the environment- The Preserve currently contains 700,000 acres of continuous wildlife habitat which is very rare and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir. There are other reasons, including the fact that I, and my neighbors, as residents of one of the proposed sites- would be displaced and our community would be destroyed. I have no idea how we would be able to  secure new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. 
I sincerely hope that our country’s transition to renewable, green-energy sources does not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
I implore you to do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Thank you.
Sincerely,
Gail Margulis

Ben, Hurley, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Ben Ratliff

Emmanuel Harent, chichester, NY.
To whom it may concern, 

I am totally opposed to this project. main reason being that i would not want to see any alteration to the original lifestyle of the Catskills. + this kind of heavy construction project will for sure damage wildlife and the preservation of wilderness in the area. 

Regards,

Emmanuel Harent

Mary Strauhs, Olivebridge, NY.
I am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  The proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

John Lepak, Newtown, CT.
The Catskills are a special place; one that I have frequented with family and friends for years. The natural environment is an incredible resource, as is the gateway communities that provide access to it. This proposal, for the Ashokan Pumped Storage Plan, seems to take all of that for granted.

That it has been filed without input by the New York State Department of Environmental Conservation or the New York City Department of Environmental Protection is unsurprising as the impact of the construction of new dams, power lines, and tunnels on the local communities and critical wildlife habitat seems totally unconsidered.

That is has been summarily opposed by local government and the region's outdoor community is less surprising. The impacts on tourism and recreation—of incredible importance to the Catskills in all seasons—are potentially devastating. 

I'm writing in total opposition to this plan and ask that it rejected immediately.

Season Daniels, Olivebridge, NY.
I am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  The proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

BENJAMIN JACKSON, Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

[PREFACE: According to an article in the Kingston Daily Freeman, Premium Energy Holdings is going to withdraw their current proposal and submit a new proposal seeking evaluation of a different upper reservoir site in an unknown location. However, I remain vehemently against any hydroelectric project in the Catskills Forest Preserve, especially involving the Ashokan Reservoir for reasons following.]
===========================================

Dear Ms. Bose,

I am writing in regard to Premium Energy Holdings’ proposal to build a pumped storage hydroelectric plant in at the Ashokan Reservoir, docket P-15056. I am a resident of Phoenicia, NY and I am strongly opposed to the proposal. 

The proposal submitted by Premium Energy Holdings states that this is a closed-loop system, when clearly it is not: the proposal is to add a new reservoir built at one of three possible sites to connect to the Ashokan Reservoir, the largest source of unfiltered water in the nation and supplier of 40% of New York City’s water needs. This haphazard and deceptive description of the project by the California-based company should be enough to disqualify them from undertaking such a project where they have no interest other than profit. 

The nature of this type of project would be permanently devastating to the environment and wildlife, and therefore the livelihood of the local economy, which depends so much on the tourism that the beauty of this area attracts. 

The rapidly fluctuating water levels would destroy the natural habitats of so many vital and endangered species, including trout, turtles, bald eagle and many others. It would greatly increase turbidity of the tributaries of the Ashokan Reservoir, jeopardizing water quality for millions of New York City residents. Not addressed in the proposal is investigating the effects of such a project on the local groundwater table that supplies water to most of the area’s residents and businesses. 

Under Article XIV of the New York State Constitution, the Catskills Forest Preserve, created in 1885, “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, and then submitted to the public in a referendum. The effort to push this project through will be a long and costly process that should ultimately fail. This is not just a local concern, and will bring widespread opposition. 

I understand the vital benefit offered by pumped-storage hydroelectric plants to reduce the daily demand for fossil fuel-generated power, but for the reasons stated above (and stated by so many other concerned citizens) the Catskill region and New York City water supply are inappropriate for this type of project.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely yours,
Benjamin Jackson

Mary Strauhs, Olivebridge, NY.
am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  The proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Jason Kurtz, West Shokan, NY.
My name is Jason Kurtz and I am a resident of West Shokan, NY.  I recently became aware of the proposal by Premium Energy entitled “Ashokan Pumped Storage Project.”  I was surprised by many aspects of this proposal because of the immense ramifications on so many levels. Simply put, Premium Energy does not deserve the special consideration FERC may give to closed-loop projects. For starters, these highly preserved state lands are kept so for important ecological reasons, most notably the important bird and fish wildlife habitats. This highly preserved land has been so since 1885, when the NYS Constitution declared this 700K acres of continuous wildlife habitat of Catskills forest be “forever kept as wild.” As a State Forest Preserve the Catskills are considered Status 1 land under the USGS Gap Analysis Program – and the DEP has said land areas designated as Status 1 or 2 will be “avoided for development.” If this proposal did in fact get any traction, it would have to be passed by a constitutional amendment by the NYS Constitution, voted on by two consecutive sessions in state legislature and then submitted to the public for referendum. Is Premium Energy even aware they are proposing a project in such a protected environment? Also, please note, this proposal by Premium Energy is not factual. This proposal is NOT for a closed-loop project, it is an add-on project since an upper reservoir would be added on to a lower reservoir – so this proposal is, in fact, deficient and misleading. This proposed project cannot happen. Thank you.

Marie Cieri, Lanesville, NY.
April 9, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose:

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there are currently housing shortages in Ulster County and Greene County, and, for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster and Greene Counties and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Taking all this into account, I hope you will deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Marie Cieri 
Lanesville, NY

Eleanor Lunn, Olivebridge, NY.
I strongly object to the proposed Ashokan Pump Storage Project. 
There will be environmental degradation, there will be the possibility of accidents which could possibly affect hundreds of thousands of people.
This project is a grab,by an out of state company, for enormous profit at the expense of New Yorkers.
The 21 century is on the cutting edge of new energy producing technology. We don't need a variation on old school technology to foul our land. Be forward thinking.
This project will be fought tooth and nail and is dead on arrival.
Eleanor Lunn

Eleanor Lunn, Olivebridge, NY.
I strongly object to the proposed Ashokan Pump Storage Project. 
There will be environmental degradation, there will be the possibility of accidents which could possibly affect hundreds of thousands of people.
This project is a grab,by an out of state company, for enormous profit at the expense of New Yorkers.
The 21 century is on the cutting edge of new energy producing technology. We don't need a variation on old school technology to foul our land. Be forward thinking.
This project will be fought tooth and nail and is dead on arrival.
Eleanor Lunn

Robert Janiszewski, Tannersville, NY.
Federal Energy Regulatory Commission					April 9, 2021
888 First Street, NE. Room 1-A
Washington, DC  20426

ATT: Kimberly D. Bose, Secretary to the Commission
RE: The proposed Ashokan Reservoir Pumped Storage and Hydro-electric Project
        Docket P-15056
 
Dear Commissioners:  

	The Mountain Top Progressives (MTP) is an environmental activist group of 400 residents of seven Towns, several Villages, and a number of Hamlets who call the Mountaintop home. Located in Greene County, our communities stretch from Hunter on the South and East to Windham on the North and East. Traveling west on Route 23A in the South and on Route 23 in the North, we get to the western border at Prattsville - at the Gilboa Dam and the Schoharie Watershed Reservoir – all part of the NYC-DEP Watershed.  We are, for the most part, located within the Catskill Forest Preserve.  We write today in response to a proposed 2-year study put forth by Premium Energy Holdings LLC of California as indicated above.  In doing so, we join in protest with a massive number of local and State Government Officials within the proposed project area. These include our own Mountaintop Town governments, Officials in both impacted Counties - Ulster and Greene Counties - as well as our NY State Representatives – State Senator Michelle Hinchey and Assembly Member Chris Tague. This list includes the Mountaintop Town Supervisors, the Mayor’s Mountaintop Coalition, and the Coalition of Watershed Towns. 

Awareness of this proposal was delayed for some reason, yet a broad range of community organizations have also added their opposition as well.  These include the Sierra Club, the Catskill Center, the Catskill Mountain Keeper, the Catskill 3500 Club, the Ashokan Center, Trout Unlimited, the River keeper, the Mountaintop Arboretum, and many other entities who have expressed opposition to this proposal. As the Mountain Top Progressives, we join in voicing our concern and our position encouraging you to reject this proposal.  The following is a list of major reasons that have provoked our opposition. 

1.	HYDRO-ELECTRIC POWER GENERATION – COMMENTARY.

Given the need for power generation, many alternative options present themselves. Hydro-electric power is just one of those.  Although far more attractive than burning coal or other fossil-based petroleum non-sustainable products to generate power, other less intrusive options – solar, wind, and nuclear sustainable sources are also options.  Which options are sustainable, attractive, efficient, and less intrusive in a given environment or location raises serious concerns regarding this proposed project study.  Compared to both solar and wind generation, this hydro-electric pumped project is a far more intrusive and destructive proposal.  The required construction results in disturbing, altering, or destroying the surrounding environment. Such an action also results in an erosion of regional economic attraction as well as recreational tourist access. Aside from carbon-based energy generation, this proposal is the least attractive compared to the other sustainable options.  As water is pumped-up to the flow-down reservoir with a 215-225 foot dam and hundreds of submerged acres, piping installation and more, the power required to pump water to a higher altitude in order to create a return flow over turbines is far less productive than solar and wind stations. Further, such an undertaking is far more expensive to construct and substantially intrusive within the host environment.  

2.	THREE OPTIONAL SITES FOR STUDY – INCLUDING STONY CLOVE NOTCH, HUNTER

The Catskill Mountains – particularly the Northern Catskills – are largely contained in the CATSKILL FOREST PRESERVE. Established in the NY State Constitution in the 19th Century, this 700,000 acre “preserve” was designed to protect the forest and the environmental flora and fauna, provide tourist access and recreational opportunity for visitors, and grow appreciation for the beauty and vistas that have been enjoyed for generations.  Mountaintop tourism was ignited and launched in the 1830-50s by the HUDSON RIVER SCHOOL OF ART led by artists like Thomas Cole, Asher Duran, Frederic Church, and others.  Their landscape artwork toured the US and Europe as well and generated much visitor interest in personally exploring “the Mountaintop.”  One of the well-known pieces of art, in fact, depicts Stony Clove Notch - one of three selected optional sites for the construction of a dam and reservoir, including a 225 foot tall dam, installation of flow pipes and pumps, acres of land absorbed, and Rt. 214 cut-off and closed. The Stony Clove site, although an attractive option with the highest altitude of the three sites presented, is within the Catskill Forest Preserve. Stony Clove features the Devil’s Tombstone Campground – one of the oldest camps in the Catskills and among the most active. It is an access point to numerous trailheads including Devil’s Path and the famous Long Path. This historic location may very well be denied access, devastated, drowned, or destroyed by the project. 

ROAD ACCESS FROM THE SOUTH: Access to the entire Mountaintop from a single southern access road – Route 214 – is also destroyed in this option with the creation of a remote receiving reservoir at Stony Clove Notch.  The road closure of Route 214 as shown on the maps contained in the proposal severs the road connections between Phoenicia (Ulster County) and Hunter (at Lanesville – a village of Hunter in Greene County, NY). Route 214 is the primary link between East/West Route 28 at Phoenicia and East/West Route 23-A located in Hunter.  This limitation on access points to the seven Mountaintop Towns - including Hunter on the southern border and Windham on the north via Route 212 - includes seven towns, several Villages, and a number of Hamlets - most in the Schoharie Watershed). East/West access to the entire Mountaintop is limited to Routes 23 and 23A. Route 212 from Rte. 23A South to Rte. 23 North connects the two.  The southern Mountaintop access connector between Route 28 (Ulster County-Phoenicia) and Route 23A (Greene County-Hunter and access to the Mountaintop) is Route 214.  If selected, the Stony Clove Notch Option would erase Route 214 – the southern access road.  

DESTRUCTION OF PROPERTY, HOMES, AND ACREAGE:  Once construction gets underway and the related environment, acreage, and properties are acquired, homes will disappear, farms, camps, and trails will be closed, retreats demolished, and trees removed.  Digging, installation of pipes and pumps, stoppage of streams and ponds, and the closure of roads will take place as well.  Such sacrifices and risks undertaken can forever diminish our environmental quality, our forested beauty, and our recreational opportunities and attractions. Worse, and potentially illegal, this option would invade the Catskill Forest Preserve as set aside in the NY State Constitution. This is completely unacceptable, impacting our environment, water quality, access, and attraction for visitors – the basis of our rural Mountaintop economic vitality.   

3.	ENVIRONMENTAL/WATERSHED RISKS: DISRUPTION AND DESTRUCTION.   

From flora and fauna, to fish, birds, and trees as well as to other forest growth that has reflected the policy of Forest Preservation for more than 100 years, we object to its destruction and to the accidental importation of invasive species into the our protected Forest Preserve. Further,  along with other Watershed communities, we express deep concerns regarding water quality and turbidity consequences. The long existing Watershed on the Mountaintop and between our communities and the Ashokan will be disturbed and potentially be diminished or denigrated.  

And, a further series of concerns and questions have been raised. Will clean water access via the Watershed system of collection and supply be disrupted for an inefficient hydro-electric power project that may prove to be invasive? Shall we violate the more than 100+ year Catskill Forest Preserve status and erode our commitment to environmental preservation for electric power with other less-intrusive options in solar and wind power? And, how desperate is the need for such a project?  

In closing, we encourage you to reject the proposed $5 million, 2-year study submitted for review by your Commission.  We have witnessed a rapid growth of community opposition as well as governmental calls for rejection from the Town Level, to the Counties involved – Greene and Ulster, and to our State Elected representatives.  And, there is no support from the NYC DEP which manages the Watershed assets, or from the NY State Department of Environmental Conservation.  Support is absent and opposition abounds.  We join in opposition. Please reject this proposed project. 

Respectfully Submitted, 


Mountain Top Progressives
On Behalf of the Executive Committee:


Ellen Schorsch			Jonathan Gross			Sheila and Paul Trautman

Stan Hellman			Robin Levin 			Gayle and Maret Panzenbeck

Robert Janiszewski		Ron Lipton

christina himberger, boiceville, NY.
To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a
hydroelectric power plant in New York’s Catskill Mountains. As landowners, we take our responsibility to protect the birds, pollinators, wildlife, water and ecology this fragile area very seriously. I am part of a large and
engaged community and I urge FERC to decline their request for a preliminary
permit for the Ashokan Pumped Storage Project P-15056 based on the following
reasons:
1.) NOT CLOSED LOOP -The application is sloppy and flawed in it’s local
references and assertion of being a “closed loop system” when it is an “add
on” system.
2.) BIRDS-All proposed reservoirs are within the Audubon NY Catskill Peaks
Forest Important Bird Area (IBA). If you have ever heard the flute song of a
Forrest Thrush, you would defend it’s habitat from development without
question or hesitation. https://ny.audubon.org/conservation/catskill-peaksforest
3.) TROUT -The system’s environmental impact on the sediment regime in the
Esopus Creek, which is one of the Catskills’ most vital trout breeding waters,
and one of the key creeks feeding into the Ashokan Reservoir.
4.) DRINKING WATER - The system’s impact on turbidity levels of the Ashokan
Reservoir which supplies both local and 40% of NYC’s water, serving 1 billion
gallons of water a day to 9.5 million people. The proposal threatens this
valuable asset, which holds the distinction of being the largest unfiltered
water supply in the nation.
5.) PRESERVED LAND -The three sites for the proposed reservoirs and tunnels
are on highly protected land of the Catskills Forrest Preserve created in 1885
under Article XIV of the NYS Constitution “shall be forever wild… not be
leased, sold or exchanged, or be taken by any corporation, public or private.”
6.) PROTECTED LAND -The Catskill Forrest Preserve is considered Status 2 land
under the USGS “Gap Analysis Program.” According to the U.S. Dept. of
Energy’s own Hydropower Vision, “areas with formal protections designated
as Status 1 or 2 under the USGS Gap Analysis Program are avoided for
development."
7.) CONTINUOUS HABITAT - The Preserve currently contains 700,000 acres of
continuous wildlife habitat (very rare) and the forest around the proposed
sites ranks among the top 1% of forest habitats region-wide, according to the
New York State Forest Condition Index. It would be a true crime to destroy
this sacred and wonderfully preserved land, and would set a doomed
precedent for protected lands across the country.
8.) COMMUNITY DISPLACEMENT, AGAIN- Premium Energy’s proposal would be
devastating to local communities as it would require the seizing of homes
and private property via eminent domain—a process whose scars are still
felt here from when the Ashokan was constructed 100 years ago. Residents
displaced by the Ashokan Pumped Storage Project would be unable to secure
new housing, as there is currently a severe housing shortage in Ulster
County.
9.) TOURISM – The proposal would negatively impact the Catskills’ growing
tourism economy, which generated 17% of employment in the region in
2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium
Energy’s project would limit access to hiking, fishing, and other forms of
recreation in the Catskills, decrease the area’s natural beauty and otherwise
industrialize the region, negatively affecting businesses in Ulster County and
beyond.
As a last point to make in opposition, the irony must be pointed out that the solution
to fossil fuels and extractive energy methods should not be to usher in a new
environmentally damaging system! Our country’s transition to renewable, green energy
sources must not come at the cost of environmental and community
devastation. I hope Premium Energy will be able to find a suitable alternative
location for a pumped storage project—using innovation where the construction
and operation will not destroy protected wilderness, displace vulnerable
communities, and threaten incredibly important natural resources.
Please deny Premium Energy’s proposal for a preliminary permit for the
Ashokan Pumped Storage Project P-15056.  Thank you for your attention to this important matter. 
All the best,
Christina Himberger

Margaret Taddy, Lanesville, NY.
Dear Secretary Bose:
I am writing as a resident and homeowner in the area of the Catskill mountains that Premium Energy Holdings’ Ashokan Pumped Storage Project (P-15056) proposed location is.  This is my unequivocal opposition to this project, as it will decimate the ecology of the area and wrongly and tragically destroy this community and its livelihood, in addition to harmful impacts to New York City’s drinking water.  This proposed project is green-washing at its worst, which relies on an absolute desecration of this New York State protected land.  This proposal is without merit as to its location, its method and its scale.
My husband and I bought our property in order to live with nature and its simplicity, and having our now 9 year-old son grow up on this land has been our greatest joy.  Some families in our community have been here for generations, and their livelihood is based on their ingenuity and careful stewardship of the land. New York State, unlike other states, had the foresight in creating protected land that would support the natural ecology of this area.  The FERC needs to stop this proposal at its current state, as it is completely infeasible and will be found without merit – it is a waste of your agency’s resources and time.  
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are astronomical. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
Their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Margaret Taddy

Michael Billig, Hastings on Hudson, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Michael Billig

Allison Irwin, Shokan, NY.
Allison Irwin
PO Box 202
Shokan NY 12481

To: Kimberly D. Bose 
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A 
Washington, D.C. 20426. 

Docket number P-15056-000 

Dear Ms. Bose,

I am writing  to say that I am against the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

When I first heard about this project,  I thought about two things.  First, on PBS last week, there was a special on climate change and it stated that deforestation was a really large reason for climate change and it cited all the deforestation in the rain forests other countries over the last several years.  It talked about how re-foresting would help fight climate change.  How can we be doing this project supposedly to help be more environmentally proactive if it would be ripping up forever wild forests and streams?  The second was a speech made by Vice President Kamala Harris in Chicago this past week that stated: "In the past wars were fought over oil.  In the future, wars will be fought about water."  I thought, how can we be even considering a project that would ruin the water in the area now and in the future?  Again, in an effort to be environmentally proactive, they would be ruining the environment from a water perspective also.  This would involve killing fish and other wildlife. 

In our area, we have to obtain permission to do just about anything with our water ecosystem. Home owners have to conform to guidelines to protect the watershed, which ultimately affects the NYC water supply.  How can this project ,which would totally rip up the land are affect the streams that run into the Ashokan Reservoir, be proposed without giving a heads up to the NYC water supply authorities and the community governments and planning boards?  Why would they NOT do that?

Later, I wondered how we would get from the Shokan area over the mountain to Peekamoose /  Sundown  / Grahamsville without going all the way around via 28 to 209 to 55, which is about twice the amount of time.  Watson Hollow Road, the road that passes near Moonhaw, is the only road over that mountain.

This project would devastate our environment, our local communities, and the purity of NYC’s drinking water.  The project might in theory be an environmentally proactive project but at what cost. This will forever ruin protected forests, streams, and wildlife of Catskill Forest Preserve. 

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat..  The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. Please don't destroy this beautiful preserved land.

There would be even MORE environmental devastation after construction is complete.  The Ashokan watershed and its rivers and streams would all be affected. Pumped storage will ruin stream ecology,   aquatic habitats and land habitats.  When the water is pumped up and down in the project, it will affect wildlife and the sediment in connected tributaries.  The Ashokan Pumped Storage Project would have farther reaching effects,  affecting the sediment in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir.  

This will affect the NYC water supply! The Ashokan Reservoir supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.  Because the Premium Energy’s proposal is not a closed-loop system —it is an “add-on” -- the water fluctuations would increase turbidity within the Ashokan and its watershed.  The Ashokan Reservoir is a valuable asset.  It is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities.  The project in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain.  We already had this happen when the Ashokan Reservoir was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would have a hard time buying new housing.  Because of the pandemic, housing prices are high and houses are in short supply in Ulster County and the surrounding areas. 

This past year, the entire world shut down and the economy of the area was devastated by the shutdown.  Things are finally starting to open and customers are finally coming out again improving the tourism economy.  In 2019, tourism generated almost 20 percent of the jobs in the Catskill region,  a $1.6 billion industry, supporting roughly 20,000 jobs. The numbers this year for hiking, biking fishing and other outdoor activities were so much larger this year because of the pandemic.  Experts predict this trend will continue due to the movement of NYC residents to our area.  Please don't let the Premium Energy’s project ruin this revitalized recreation in the Catskills.  

I don't understand why they are not using the Closed-loop pumped system instead of the one they are proposing.  Wouldn't that have a  smaller impact?  . This project to NOT a “closed-loop” project. It is an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks and is NOT the kind of project the country needs right now.

Please deny Premium Energy’s proposal for a preliminary permit for the Premium Energy’s Ashokan Pumped Storage Project, Docket number P-15056-000.

Sincerely,

Allison Irwin

Lloyd S. Hoffstatter, Olivebridge, NY.

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426
Docket P-15056-000

Dear Secretary Bose,
I am submitting the following as a resident of the town of Olive, NY which would suffer significant negative environmental impacts from the proposed project.

The following are a few of the omissions in the amended Application for Preliminary Permit proposal submitted 2/1/21:
18CFR § 4.32(a)(2)(i)(A): Greene County is not identified. (a)(2)(iii)(A) Greene County Soil and Conservation District is not identified.
4.81(b)(1) the proposal does not identify or describe the existing spillways and dividing weir at the Ashokan reservoir.
4.81(b)(6) the proposal fails to demonstrate how the proposed project would develop, conserve, and utilize in the public interest the water resources of the region.

18 CFR § 4.32(j) states that “Any application, the effectiveness of which is conditioned upon the future occurrence of any event or circumstance, will be rejected.” 
For this project to move forward it would require electrical transmission line studies and improvements external to the project that are yet to be done / completed. The Filtration Avoidance Determination (FAD) as it relates to the NYC watershed and water supply would need to be renegotiated with the USEPA before preliminary work on this project could proceed. An Amendment to the NY State Constitution would be required as well.  As all of these would occur in the future, and as the constitutional amendment and revised FAD are at the least extremely unlikely to occur, this proposal should be rejected.

Comments 
The project is an add on, open loop project, not closed loop despite being described as such, as the Esopus Creek runs into and out of the Ashokan Reservoir. The DOE has promoted closed rather than open loop projects.
The project as proposed would be powered primarily by non-renewable sources. This is counter to the intent of recent NYS Clean Energy legislation. 

Proposal Section 4: “The project would store excess renewable energy, helping to integrate renewables into the grid, and to supply firm peaking power generation with primary load following capability.”  

Renewables make up about 6% of NY Downstate region generation. NYISO seasonal load profiles show that peak demand is not concurrent with PV production, rather it occurs during evening hours when 94% of generation is from fossil fuels (69%) / nuclear power (25%). Likewise only 1.6% of upstate (not local) wind energy was curtailed (2019) due to capacity / transmission issues. Economics point to pumping during late night hours when demand is lowest, utilizing no PV generation and little if any wind generation.

https://www.nyiso.com/documents/20142/13056398/Figure-10.png/d74de7f7-dfaf-ce4d-36ac-6451ae3a992c?t=1591726511999

https://www.nyiso.com/documents/20142/13056398/Figure-14.png/b6bac4bc-62b7-f57b-c3cf-85c34dac0557?t=1591726458398

https://www.nyserda.ny.gov/About/Newsroom/2020-Announcements/2020-04-03-NEW-YORK-STATE-ANNOUNCES-PASSAGE-OF-ACCELERATED-RENEWABLE-ENERGY-GROWTH-AND-COMMUNITY-BENEFIT-ACT-AS-PART-OF-2020-2021-ENACTED-STATE-BUDGET

Further, NYS utilities have argued before FERC that incentives for additional generation in the downstate region are unnecessary due to ongoing and planned transmission upgrades. 

https://www.cenhud.com//my-energy/our-energy-future/capacity-zone/

In consideration of the above and cited information, I request that you reject this Application for a Preliminary Permit.

Respectfully yours,
Lloyd S. Hoffstatter
Olivebridge, NY

Laura OConnell, Chichester, NY.
Hello, I am writing as a resident of Shandaken, NY to express my opposition to Premium Energy Holdings’ proposal and request that the Federal Energy Regulatory Commission deny their application for a preliminary permit.

If constructed, the proposed project would damage local lands, roads, and streams in a way that would permanently damage a crucial piece of the Catskills. Route 214, a scenic byway and one of the sites the company is exploring, would almost certainly have to be re-routed which would be devastating to tourism and outdoor activities. Route 214 is a key access road for skiing at Hunter and Windham mountains, and is the only place to access world famous Catskills ice climbing - limiting traffic or re-routing this road would remove access to hundreds of ice climbing routes within Stony Clove and Deep Notch which would negatively impact outdoor enthusiasts and ice climbers (including myself), local guiding and rental businesses, and local bars and restaurants.

If constructed, the proposed project would also be illegal. New York State is the largest property owner within the Catskills and pursuant to Article XIV, Section 1 of the New York State constitution, the lands of the state “shall not be leased, sold or exchanged, or be taken by any corporation, public or private” - the proposed upper reservoir would be located within the lands that this article applies to. With this in mind, even allowing for preliminary permits would mean a pointless disruption to important part of the Catskills, as the project would not be approved.

Even allowing for preliminary permits would negatively impact Route 214, a critical and scenic byway connecting towns with outdoor activities, would lead to a loss of tourist dollars and business revenue, and could have impact on streams that would affect fishing, boating, and swimming. I ask you to consider all these factors and deny the preliminary permits for this ill-planned project.

marcy berman-billig, hastings on hudson, NY.
I am writing to voice my strong opposition to the proposed hydro project.

What a amazing wonder NY state has created in the form of the Ashokan Dam Rail Trail. We have enjoyed walking, biking and skiing along this trail along with many other nature lovers. I would suggest that it is a GREAT draw for NY state tourism, we certainly brought our business to the region to enjoy the beauty of this treasure along Route 28.

This new project would disturb the pristine forest that surrounds the trail, would potentially affect streams and even the NYC reservoir watershed. I am absolutely opposed to sending high voltage wires over Route 28. The spectacular views of the historic Catskill mountains would be marred. 

Please do not allow this project to proceed!

Marcy Berman-Billig

Chris Kronus, Brooklyn, NY.
Hello, I am writing as a homeowner in Shandaken, NY to strongly oppose the granting of a preliminary permit to Premium Energy Holdings. While I am very much in favor of moving towards renewable energy, the Catskills is not the right location for this project and the proposal shows that the company has not done the proper research to understand the impact on the region and the company is attempting to be misleading in their characterization of the project as closed loop.

The Catskills is a protected region, and the proposed sites within the project are located within the Catskills Forest Preserve (though the company falsely states the project will take place outside the protected boundaries - it won’t. This area is protected within the New York State Constitution, which deems these lands shall be forever kept as wild forest lands and shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any change would have to be passed by constitutional amendment, which would involve state legislative approval and a public referendum - this would almost certainly never be passed, so this project would be unlawful and unconstitutional.

As a fly fisher, snowboarder, and ice climber I’m also very concerned about what this project might do to the outdoor activities that the Catskills are known for. Pumped storage reservoirs are subject to rapid fluctuations in water, which would wreak havoc on surrounding wildlife habitats and alter the sediment regime in the Esopus which typically provides world class trout fishing. Route 214 is also one of the proposed sites for exploration, and re-routing this critical byway would be devastating. Route 214 provides access to skiing and snowboarding at Windham and Hunter Mountains, access to hiking trails across the area, and access to the best ice climbing routes in the Catskills. Modifying access to this road would mean limiting access to these critical outdoor pursuits and decreasing revenue from tourists engaging in these pursuits.

Finally, the company has either not done their proper due diligence or they are intentionally lying about characterizing their project as closed loop. This project is an open loop system, an add on project where an upper reservoir would be added to an already existing lower reservoir connected to a natural water source. The fact that they are attempting to distract and use the term “closed loop” to infer a smaller environmental impact is misleading and concerning - it shows they either do not know the land they wish to explore or worse, they do not care about the land they wish to explore and that will have horrible lasting effects for this region.

Other formats

My name is Salomon Weir. I live in the hamlet of Chichester, Town of
Shandaken, Ulster County, in New York State. My FERC ID is #F648314.

I strongly oppose the granting of a preliminary permit to Premium Energy
Holdings (PEH) for the project to build a pumped storage hydroelectric
plant utilizing the Ashokan Reservoir (docket number P-15056).

I oppose it for the following reasons:

1.  The entire proposed project lies within the Catskill Forest
      Preserve, which has been protected in the New York State
      Constitution since 1894.

2.  The proposed project would violate the designation of the Catskill
      Forest Preserve as Status 1 land by the Federal government, a
      protection which explicitly bars development

3.  The project would severely impact traffic on New York State Route
      214, wreaking economic havoc on the affected hamlets, towns, and
      counties.

4.  Key players were not notified beforehand, as legally required.

5.  The topography of the land would make rerouting or replacing New
      York State Route 214 impossible,

6.  New York City’s Department of Environmental Protection operates the
      city’s drinking water supply under a Filtration Avoidance
      Determination (FAD) issued by the US Environmental Protection
      Administration.

7.  As proposed, PEH’s project is not a closed loop system

8.  With so much private property located within close proximity to the
      Stony Clove creek, and surrounded by the Catskill Forest Preserve,
      relocation of homes and businesses along the creek is impossible
      without amendment of the New York State Constitution.

I urge the Federal Energy Regulatory Commission to deny Premium Energy
Holdings the permit.

We are members of the Chichester Property Owners Association, a
community organization of three dozen households located in the hamlet
of Chichester, Town of Shandaken, Ulster County, in New York State. Our
FERC ID is #F648342.

We are opposed to the granting of a preliminary permit to Premium Energy
Holdings (PEH) for the project to build a pumped storage hydroelectric
plant utilizing the Ashokan Reservoir (docket number P-15056).

We believe PEH’s proposal is filled with erroneous and misleading
information, and oppose it for the following reasons:

1.  The entire proposed project lies within the Catskill Forest
      Preserve, which has been protected in section 2.1 of the New York
      State Constitution since 1894.

2.  Key players were not notified beforehand, as legally required,
      including:

    a.  New York City

    b.  The hamlets of Lanesville, Chichester, Phoenicia, Mt. Tremper

    c.  Towns of Shandaken, Olive and Hunter

    d.  Ulster and Greene counties

    e.  Hunter Mountain Ski Resort, and its parent company Vail Resorts

3.  Local and vacationer traffic on New York State Route 214, connecting
      Hunter Mountain, and the hamlets of Tannersville and Hunter to all
      points south, would be severely disrupted, wreaking economic havoc
      on the affected hamlets, towns, and counties.

4.  Replacing New York State Route 214 will prove impractical, if not
      impossible, given the topography of the land.

5.  New York City’s Department of Environmental Protection operates the
      city’s drinking water supply under a Filtration Avoidance
      Determination (FAD) issued by the US Environmental Protection
      Administration.

6.  As proposed, PEH’s project is not a closed loop system

7.  With so much private property located within close proximity to the
      Stony Clove creek, and surrounded by the Catskill Forest Preserve,
      relocation of homes and businesses along the creek is impossible
      without amendment of the New York State Constitution.

We urge the Federal Energy Regulatory Commission to deny Premium Energy
Holdings the permit.

My name is Salomon Weir. I am president of the Chichester Property
Owners Association,

PO Box 217 Stone Ridge, NY 12484 1925 Lucas Ave, Cottekill, NY 12419

  845.687.7500 - marbletown.net supervisor@marbletown.net

  MOTION TO INTERVENE: PROJECT P-15056 ASHOKAN PUMPED STORAGE PROJECT

  March 23, 2021

  Ms. Kimberly Bose, Secretary

  Federal Energy Regulatory Commission 888 First Street NE

  Washington DC 20426

  Dear Secretary Bose:

  Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR
  Section 385.314) the Town of Marbletown, Ulster County New York hereby
  petitions the Federal Energy Regulatory Commission to grant it full
  party status in the above captioned proceeding. The persons to whom
  communications should be addressed and to whom service should be made
  are as follows:

  Town of Marbletown - Supervisor Town of Marbletown - Deputy Supervisor
  Rich Parete Don LaFera

  PO Box 217 PO Box 217

  Stone Ridge, NY 12484 Stone Ridge, NY 12484

  supervisor@marbletown.net dlafera@marbletown.net

  As grounds for this Motion, the Town of Marbletown, Ulster County, New
  York states as follows:

  The Town of Marbletown has a vital interest in the Preliminary Permit
  application submitted to the Commission by Premium Energy for the
  Ashokan Pumped Storage Project (P-15056). The Town of Marbletown seeks
  to become a party to this proceeding to ensure the public interests of
  our residents are adequately represented. The Town of Marbletown
  encompasses all or parts of what is marked in the draft environmental
  impact statement (EIS) as sections 1A, 1B and 2C of the lower Esopus
  Creek.

  The Town of Marbletown was not notified in the original notification
  process. Neither disruption to the proceedings nor any additional
  burden to any party will result from the granting of this Motion.
  Considering the foregoing, the Town of Marbletown respectfully
  petitions for intervention.

  Sincerely,

  Rich Parete Supervisor

  Town of Marbletown

CJ Harvey, Margaretville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
CJ Harvey

Denise Anderson, New York, NY.
PLEASE BLOCK THIS PERMIT

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.

Emily Becker, Massapequa, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Emily Becker

David Lizmi, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to oppose the Ashokan Pumped Storage proposal by Premium Energy Holdings to build a hydroelectric power plant in the Catskill Mountains. I encourage FERC to decline this request for Project P-15056, because it would:

• Wreak havoc on a designated wildlife preserve under the protection of the New York Constitution

• Devastate the local communities as well as the tourism the Catskill mountains rely on economically

• Would harm the quality of the drinking water sourced from the Ashokan Reservoir which provides water to 40% of New York City's 9.7 million residents.



Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

David Lizmi

Mona Jacobs, Shandaken, NY.
Re: Docket # P15056:000
Proposed Ashokan Pumped Storage Hydro Plant

As a resident of Shandaken since 1998, and of NYC prior to that since 1952, I would like to vigorously object to the proposal put forth by Premium Energy Holdings to build a Pumped Storage facility that incorporates the Ashokan Reservoir. At the very least, this project in this place will cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in NYC. Additionally, pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. All proposed  reservoirs fall within a State Forest Preserve, considered Status 1 land by the US Geological Survey. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development”. 
Although this project is presented by Premium as Closed-Loop Pumped Storage Hydropower, this is not the case. This is an “add-on” project since it incorporates the existing Ashokan Reservoir. The danger to the natural flowing water feature that was dammed for the origin of the Ashokan can not be determined, and if negatively impacted may cause untold expenditures to correct.
As we move toward the goal of 70% renewable power by 2030, we must make sure we are selecting locations for pumped storage that will not create more environmental and economic damage than they attempt to alleviate.
Mona Jacobs

Victoria Chesler, OLIVEBRIDGE, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing to urge you to decline Premium Energy Holdings’ request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 proposal to build a hydroelectric power plant in New York’s Catskill Mountains. 
Among other problems with this proposed project, it would further damage an economy and community that has been severely impacted by the New York City water supply system in its midst for over 100 years. The Ashokan Reservoir destroyed hundreds of homes, dozens of towns, and thousands of livelihoods when the it was built by eminent domain in the late 1800s to early 1900s. Ever since, the surrounding towns and their residents have been impacted daily by the existence of the reservoir, the vast tracts of land surrounding it that are not under local jurisdiction, and the vast areas beyond that that are governed by regulations of the City’s Watershed oversight agencies. 
Not only would such a plant impact our region, but it would have a negative impact on the New York City water supply, which the City has invested billions of dollars and countless oversight hours in protecting for over a century.
Sincerely,
Victoria Chesler
Olivebridge NY

Katie Reedy, New York, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Katherine Reedy

Eric Shapiro, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Eric Shapiro

MaryEllen Raskopf-Kawauchi, Middletown, NY.
The Catskill Forest Preserve has been protected by the NY State Constitution since 1885. Designated Status One Land, the Dept. of Energy respects this land as requiring strict protection against development. Article XIV of the NYS Constitution specifically states that these forested lands "shall be forever kept as wild...". And that they "shall not be leased, sold, or exchanged, or be taken by any corporation, public or private." 

The Ashokan Pump Storage Project would be in violation of the NY State Constitution, increasing turbidity in NYC drinking water (approximately 1 billion gallons for 9.5 million persons daily), scarring the Ashokan Watershed area, disturbing wildlife habitats, displacing area residents for a second time, and disrupting the area’s tourism industry. 

As a pristine 700,000 acres of continuous wildlife habitat, the forested area ranks among the top 1% of such habitats region-wide. The Catskill's own State Forest Preserve is considered Status One Land under the USGS "Gap Analysis Program". Areas considered Status One, with formal protections under the Dept. of Energy "Hydropower Vision" are specified as to be avoided for development. 

This proposed Ashokan Pump Storage Project is an unacceptable project for the intended area. As this proposal has been earmarked by Premium of California to be a "Closed-Loop" system - which given the existence of the connected Esopus River it most certainly would not be, but rather an "Add-on" - their proposal should not even be considered.


Thank you for your careful consideration of this important matter. 

MaryEllen Raskopf-Kawauchi
172 Last Rd., Middletown, NY 10941

Frank Genna, Mahwah, NJ.
I am strongly opposed to the proposed hydroelectric plant for reasons that include the following:

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Christopher Tyler, Shokan, NY.
Christopher Tyler
18 Mountain Road
Shokan, NY 12481

To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in regard to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. This proposal is problematic and short-sighted, and I urge FERC to decline Premium Energy’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The project, if completed, would negatively impact tourism, local communities, the area’s environment, and New York City’s drinking water.

One of the main problems is that the project will have a negative effect on tourism in the Catskills. In 2019, tourism generated 17% of the employment in the region; it is a $1.6 billion industry which supports thousands of jobs. The Catskill region is justly celebrated as a haven for hikers, fishermen, and skiers. Premium Energy’s project would cut off access to these and other forms of recreation. Furthermore, the project would irreparably damage the area’s natural beauty. With a decrease in tourism, businesses in Ulster County will suffer. 

Additionally, the project would be deeply damaging to the housing situation of local communities in the Catskills. Completion of the project would require the seizure of homes and private property via eminent domain, and displaced residents will have a difficult time finding affordable housing in the area. Ulster County is experiencing a severe housing shortage and the properties that are available are extremely expensive. Furthermore, many in the area are already struggling with loss of income due to the pandemic.

Premium Energy’s project will also cause egregious harm to the environment. Large areas of wildlife habitat are rare in our country: the Catskill Forest Preserve comprises almost 700,000 acres of contiguous habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats in the region, per the New York State Forest Condition Index. In addition, Catskill Forest Preserve lands, under Article XIV of the New York State Constitution, are clearly designated as “forever. . .  wild forest lands. They shall not be leased, sold, or exchanged, or be taken by any corporation, public or private.” 

Finally, Premium Energy’s project is a serious threat to New York City’s drinking water. The project would make use of the already-existing Ashokan Reservoir, which serves the city and which is the largest unfiltered water supply in the nation, providing 1 billion gallons of water a day to 9.5 million people. In the 1990s alone, $1.7 billion was invested in the reservoir. It would be foolish to endanger this essential resource in the ways that Premium Energy’s project proposes. Their proposed pumped storage plant would adversely affect the sediment regime in tributary rivers and streams that feed the reservoir—ultimately harming not only the fish and wildlife that depend on them but also the millions of  New York City residents who do as well.

I am in favor of renewable energy, and that I hope it will play a large part in our transition away from fossil fuels and toward more sustainable sources. However, we cannot sacrifice community and environmental well-being in pursuit of this goal. Though Premium Energy claims their project is a “closed loop,” a type of pumped storage project that would have a smaller impact on the surrounding ecosystem, this is false: the project is in fact an “add on” since it would use an existing body of water, the Ashokan, as a lower reservoir. In putting the project forward as a “closed loop,” Premium Energy has already lied to us. How can we trust them to maintain high standards and care for the community if they have based their proposal on a falsehood?

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Christopher Tyler

dharmadogg@gmail.com

David Hayes, Hurley, NY.
I am a full-time resident of the Catskills. I am also a hiker and birder who enjoys the Catskills on a daily basis. I write to strongly oppose this ill-considered and damaging project.

The proposal is located within the Catskill Park, a State Preserve protected by the NY State Constitution. The park consists of over 600,000 acres of forest and wilderness land within easy driving distance of millions of residents in metropolitan New York, New Jersey, Connecticut and Pennsylvania. Visitors come to enjoy hiking, camping, fishing, hunting and nature study They also come to experience solitude, quiet contemplation and rejuvenation. 
 
The proposed reservoirs are especially troubling. They will permanently prevent hiker access to mountains in the Burroughs Range, disrupt traffic on the only route north-south highway through the region, and prevent access to campgrounds and trout streams.  Loos of access to one area would result in overuse in others, and the pandemic has already caused a tectonic shift in use levels. This would directly impact hundreds of thousands of visitors and cause significant economic hardship to many small tourism-based businesses. This would harm the may small communities that make up the region.

Sensitive ecosystems would be disrupted by the requisite utility infrastructure required by a development of this scale.  Even the reservoirs themselves would have little ecological benefit since the water levels constantly change.

In summary, this is not the right place for this proposal, and I urge you to deny the permit.

Marjory Widensky, Phoenicia, NY.
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project
P-15056, as it would be devastating to the environment, highly disruptive to local communities, and homes for which we live in and businesses we own, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process.
Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which
supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium
Energy’s proposal would be deeply damaging to local communities. Any conceivable
upper reservoir site in the Catskill Forest Preserve would require the seizing of homes
and private property via eminent domain—a process that already displaced thousands
when the Ashokan was constructed 100 years ago. Residents displaced by the
Ashokan Pumped Storage Project would likely have a hard time securing new housing,
as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage
Project, it must be pointed out that their proposal does not even represent the kind of
innovation that the Department of Energy wants to see. Closed-loop pumped storage
projects have smaller environmental impacts than those that make use of existing
watersheds, and are thus eligible for streamlined FERC approval. This is why Premium
is claiming this project to be “closed-loop” rather than being honest about what their
project actually is: an “add-on,” using an existing body of water as a lower reservoir.
This kind of project carries with it significantly higher risks, even when the lower
reservoir is not a vital source of drinking water for our nation’s largest city. How can we
trust a company that would lie in their proposal simply for the advantage of being
fast-tracked for approval? Our country’s transition to renewable, green-energy sources must not come at the cost
of environmental and community devastation. I hope Premium Energy will be able to
find a suitable alternative location for a pumped storage project—one where the
construction and operation will not destroy protected wilderness, displace vulnerable
communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit
for the Ashokan Pumped Storage Project P-15056

Aubrey O'Neal, BOICEVILLE, NY.
To:

Kimberly D. Bose

Federal Energy Regulatory Commission

888 First St. NE, Room 1A

Washington, D.C. 20426.

 

Docket number P-15056-000

 

Dear Ms. Bose,

 

I am writing to urge you and your team at FERC to decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it is incredibly flawed and would be devastating to the place my family calls home. Allowing this proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains would mean destroying an ecosystem, disrupting local communities, and risking the purity of NYC’s drinking water. This idea is not worth the negative long-term cost.

 

Here’s a bulleted list as to why this idea is flawed:

 

·        Catskill Forest Preserve, wildlife and ecosystem are at risk of being tampered with. Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat. It would be a complete shame to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

·        Pumped storage wreaks havoc on nearby stream ecology and on both aquatic and land habitats. Our home is part of the Ashokan watershed and I know how delicate the ecosystem is. Without a doubt of the rough water continuously moving up and doing that it would impair the interconnectedness of the Ashokan watershed and its tributaries.

·        The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.

·        Premium Energy’s proposal would be deeply damaging to local communities, which we are a part of. This project would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are not affordable for those that are displaced.

·        The proposed project would effect the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs.

·        The project would impair the connectedness of Rt. 214 between Ulster and Green counties, impacting skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

 

I could outline many more reasons, but the major points are that this project will directly hurt the environment, local community and even tourism. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.

 

Sincerely,

Aubrey, Adam, Billie and Llewyn O'Neal

Brian Kunath, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

Article XIV of the NYS Constitution clearly states that the lands of the Catskill Forest Preserve “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

This letter should begin and end with this simple, clear and binding promise. And yet the value of a promise is really only determined during periods of temptation, and this is one of those times we need to hold fast in the face of pressure from those who offer jobs and energy in exchange for the right to break this contract.

Without a doubt, we must look for sources of sustainable energy. But why must that come at the cost of one of the few pristine ecosystems left in the country? Why displace people, disrupt waterways, threaten NYC drinking water, decimate thriving species and test the entire local ecosystem in order to take a single step forward renewable energy? Why spoil the very thing we are trying to preserve?

More than 120 years ago, some wise people decided that it was in our collective best interest to protect the forests and waterways of the Catskills. They proclaimed that these lands should remain "forever wild," a haven that would be unsullied by the stresses and pollutions of industry. Until now, that promise has been kept. Help ensure it remains so.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Brian Kunath

David Ilku, Phoenicia, NY.
As a resident of Woodland Valley, I would like to make my strong opposition to the proposed hydro electric reservoir project known.  This is a historic, bucolic valley with sensitive wildlife, and an important tourism industry to the area and community. I have been in Woodland Valley and the Hamlet of Phoenicia for over 20 years. I have seen derelict buildings, plazas and struggling businesses, turn around and finally start to thrive and employe local residences. This has brought much needed income to the region and the Mom and Pop small businesses.  Along with these flourishing and successful businesses, there are Historic Inns, campgrounds and world renowned trout fishing that would all be devastated if not permanently destroyed. I am all for "green" energy, but not when the "energy" is destroying the "green" it claims to want to protect!  Sincerely David Ilku

Tanya Zeh, Hurley, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Maxine Davidowitz, West Shokan, NY.
I want to strenuously object to the Premium Energy Holdings proposal to build a hydroelectric power plant in New York’s Catskill Mountains. Please decline their request...it would be devastating to the environment and will not provide the net positive clean energy we need. As well, it will be disastrous to tourism, to the natural environment, and be highly disruptive to local communities. Not to mention risky for the purity of NYC’s drinking water as well as local wells.
Under Article XIV of the NYS Constitution, it is clearly guaranteed that the lands that are earmarked for destruction “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” It would be a true crime to destroy this sacred and wonderfully preserved land and would set a terrible precedent for protected lands across the country. The Preserve currently contains 700,000 acres of continuous wildlife habitat. The forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index.

Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a traumatic event that happened here over 100 years ago, and the region still bears the scars. Residents displaced would likely have a hard time finding new homes in the area, given our current housing shortage in Ulster County. The Catskill region is also a $1.6 billion tourism industry, generating 17% of the employment  in 2019, and supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir. It supplies 40% of NYC’s water, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal mis-identifies it as a closed-loop system—it is in fact an “add-on,” which is not recommended by your agency. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds and are thus eligible for streamlined FERC approval. The water fluctuations would no doubt increase turbidity within the Ashokan and its watershed—the largest unfiltered water supply in the nation that represents over $1.7 billion of investments since the 1990s alone.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056, so that they can go back to the drawing board and find an alternative location — one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, threaten the water supply of the nation's largest city, and wreak havoc on incredibly important natural resources.

Anne Bloomfield, Olivebridge, NY.
Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose:

I am an Ecologist at the manager level for a local non-profit along the Esopus Creek in Hurley, NY. In addition, I hunt, hike and fish in the Catskills and own property in the Town of Olive. Finally, I will include that, as a supporter of renewable energy, I own solar panels in a local community solar array on property owned by a local church. All of these credentials have allowed me to examine the request for preliminary work for the pumped storage project by Premium Energy Holdings, LLC in a holistic manner.  As an Ecologist, I tend to review such cases as scientifically and objectively as possible. I have concluded that this is not merely a “not in my backyard” situation. Renewable energy production and storage is important infrastructure to consider. But it must be “the right project in the right place”. Based on the evidence I have in front of me, this project is not a good for fit the geographic area. I have outlined the reasons below. 

1.	State Constitution ARTICLE XIV- CONSERVATION This project is not compatible with the states desire to protect and preserve forests and wildlife.  Article XIV in the New York State constitution states, “ Forest preserve to be forever kept wild; authorized uses and exceptions] Section 1. The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private… forest and wildlife conservation are hereby declared to be policies of the state”. Honor the State’s constitution as it pertains to biodiversity conservation, clean air and water when evaluating such projects
2.	Ecological Services and the “Public Benefit” The potential benefits of the project are minimal to the “public good” compared to the value of these lands for conservation of biodiversity as well as the ecological services provided to the People of the Unites States by such lands. The benefits of unfragmented, protected forest preserve land to the people of the United States are many but to name a few: mitigation of extreme weather events, pollination and pest control services, clean water and clean air. The potential benefits of this project do not outweigh the loss or reduction of these services. Considering a project such as this within the “Blue Line” of the Catskill Forest Preserve is irresponsible and sets a dangerous precedent. A project such as this should not even be considered on protected public lands state, federal or otherwise due to their value to the public benefit as well as to biodiversity conservation. Recognize the public benefit of services provided by protected public land
3.	Premium energy proposal is not the type of project encouraged by DOE The project is not closed loop as proposed due to the fact that the Esopus Creek runs into and out of the Ashokan Reservoir. The DOE has promoted closed loop projects, which this project is not, despite its proposal as such. An April 2020 Department of Energy report (Hydrowires) concluded that “the environmental effects of closed-loop projects are generally lower (i.e., more localized and of shorter duration) than those of open-loop projects because they: (1) are located “off-stream,” potentially minimizing aquatic and terrestrial impacts, and; (2) often have greater siting flexibility than open-loop projects. In particular, the impacts to aquatic resources are typically lower for closed-loop projects than for open-loop, as closed-loop projects are not continuously connected to any naturally-flowing body of water. This avoids the movement of water between reservoir and free-flowing water that drives many impacts of open-loop projects. For closed-loop projects, the impacts on aquatic resources are primarily related to the initial withdrawal of surface water for reservoir fill, which could reduce the availability of surface water for other uses.”  Deny  projects that are not in line with the type of projects the DOE is encouraging 
4.	Impacts to forest preserve ecology As stated previously, such lands not only provide valuable services to the People of the United States, they also provide immense value in terms of biodiversity conservation. The biodiversity crisis is a global crisis. Unfragmented protected lands such as the Catskill Forest Preserve are critical to reversing the rapid and alarming loss of biodiversity globally. Siting a project such as this within the Catskill Forest Preserve would be unforgivable from a biodiversity conservation prospective. Help solve, not worsen the biodiversity crisis, respect and protect our forest preserve lands.
5.	The Filtration Avoidance Determination The FAD as it relates to the NYC watershed and water supply would need to be renegotiated with the USEPA before preliminary work on this project could proceed. Protect the NYC watershed and drinking water supply for nearly 9 million Americans

To conclude my examination of this project proposal, I respectfully request that FERC deny approval at this stage. 

Sincerely,

Anne Bloomfield, Wildlife Biologist, Olivebridge, NY 12461



DOE Report
https://www.energy.gov/sites/default/files/2020/04/f73/comparison-of-environmental-effects-open-loop-closed-loop-psh-1.pdf
NYS Constitution Article XIV Conservation: https://www.dos.ny.gov/info/constitution/article_14_conservation.html

Carol Seitz, Phoenicia, NY.
Carol Seitz /Harry Jameson
1230 Woodland Valley Rd
Phoenicia, NY
12464

4/7/21

Ms Kimberly Bose, Secretary							
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC
20426

Re: Project P-15056-000

Dear Secretary Bose,

  We are writing in opposition to the project proposed by Premium Energy for the Catskill Park region. 

   The permit application filed by Premium Energy should be rejected for it’s large number of mistakes, falsehoods and omissions. The first and most glaring falsehood is that the Premium Energy project is not a closed loop project. The Ashokan reservoir, which is proposed as the lower reservoir, is an open body of water that ultimately flows through the Lower Esopus and into the Hudson River. So the “closed-loop” system claim is false.  An open loop system will have a greater amount of potential impacts all the way down the line. And, in any project that uses this body of water, the residents of the downstream towns should be identified and notified before any permit is approved. 

   The preliminary maps for the upper reservoirs show that two are, in whole or in part, within the boundries of the Town of Shandaken. The town should have been named as an interested party as should all the towns of 5000+ residents within fifteen miles of Shandaken. Not all of these towns have been identified or notified.

  And, while we understand the maps are preliminary, and Ulster County has already been named within the application, the map of the Stony Clove site on Rt 214 clearly shows the project crossing into the next county and town, neither of which has been named as an interested party on this application.

  The following statement from the permit application is wholly incorrect.  “The proposed upper reservoir alternatives: Stony Clove Reservoir, Woodland Reservoir or Wittenberg Reservoir, would be created in the New York’s State lands.” It seems that the maps of the area have been egregiously misread. The park was created many, many years after the lands within its boundaries were bought and settled by individuals. So, while still being in the confines of the Catskill Park, most of the land proposed for the upper reservoirs is privately owned. In Woodland Valley alone 75 to 100 homes would be flooded to make way for the “upper reservoir”. As well as another 100+ homes , ours included, would lose the use of Woodland Valley Road, which is their only access to their property. None of the home/property owners of the Woodland Valley properties or the other two upper reservoir sites have been identified or notified. 

  Also, flooding Woodland Valley would cut off access to the Woodland Valley Campground. This campground is a NY State owned facility (one of the state’s oldest) that, according to the DEC’s most recent Unit Management Plan, 1994, has 70 campsites and is used by over 5400 campers and at least 2600 day use visitors annually.  There is also a second privately owned campground in Woodland Valley,  that also serves the many tourists who come to visit this area and contributes to the tourist economy of the area. This facility was also not named in the permit application but would be flooded if the current maps are followed and as such should have been identified and notified. 

   The majority of the NY State lands that are proposed for use within this application are part of the Catskill Park “forever wild” designated lands. This historic designation was intended to preserve these forests for the protection and enjoyment of the residents and our visitors. These protections were legislated by and for the people of New York State and would require a New York State constitutional amendment to change. No mention of this fact was made in the application.

     For these reasons as well as others we feel this application is poorly executed and deficient and as such should be rejected. And while we understand the need for hydro-electric energy in our future renewable energy mix we want to make clear that we feel this project comes at too high of a cost to our state and our community. 

  Sincerely,
Carol Seitz and Harry Jameson

Jeff Notti, Mount Tremper, NY.
The Catskill park was established in 1885 and protected by the New York State Constitution  which declares the park  “shall be forever  kept as wild forest lands [and] shall not be leased, sold or exchanged , to be taken by any corporation public or private”. 

The proposal of a 300 foot deep hydroelectric plant and a 200 foot dam, will devastate the highly preserved and protected land.  It would negatively impact the stream ecology of the Ashokan watershed. This will directly threaten NYC’s water supply.  

The upheaval and destruction of the Ashokan Reservoir is a disastrous plan.  The damage to the watershed arises from the construction of the dam and the pipe line to underground plant.  This will severely damage the trout spawning tributaries of the Esopus. Not to mention the tearing up the sides of two mountains is never a good idea.  

The alternative location is an even worse disaster.  Route 214 going up the Stony Clove to hunter is extremely narrow, with stunning views of the mountains with incredible hiking through out. 

Moon Haw Road, and Chichester communities may be removed by eminent domain, this is not a pretty picture.  The Sundown Wild Forest could be impacted as well as the communities along the Dry Brook (creek). The water way between Phoenicia and Chichester along the Stony Clove is stunningly beautiful as it the dive to Peekmoose  passed Moon Haw Road.  The level of construction necessary could potentially be a disaster for the Catskill Preserve.  Heavy construction along 214 could demand a revamping of the entire road way in order to accommodate heavy construction.  There would be effects on the Hunter West Kill Wilderness and the Indian Head Wilderness.  The cement production alone for the related constructions produces more pollutants than will be saved by the “clean” power form the electric plant.  

Clearly the Sturgeon Pond Hydro plant can be upgraded refitted with modern turbines with far less impact and less cost, similarly the way the Niagara turbines were revamped.    

Do you really want to be seen as a representative that condoned the destruction of this beautiful environment?

Glennon Beresin, Medford, MA.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Finally, it must be highlighted that Premium Energy’s Ashokan Pumped Storage Project proposal does not represent the kind of innovation that the Department of Energy wants. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Glennon Beresin

Cathy Elton, Brooklyn, NY.
Premium Energy’s project threatens so much that is precious about the Catskills - from wildlife and ecosystems to the health of NYC’s water supply. It is a deeply flawed plan that must not move forward. It could also cause residents to lose their beloved homes - all for the sake of profit. The Catskills Forest Preserve MUST be preserved.

Jeremy Bernstein, chichester, NY.
Dear Federal Energy Regulatory Commission, 
I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook, Werner/stoney clove creek and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 

Thank you for your time, 
Sincerely,
Jeremy Bernstein

Ruth DeFries, Mt. Tremper, NY.
I oppose docket P-15056. This land is part of the Catskills State Preserve and is protected by the NY Constitution. The proposed project will damage the ecosystem.

Philip Ficks, Cincinnati, OH.
To:
Kimberly D. Bose 
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A 
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

As an ardent Catskills hiker and fisherman, I am writing in opposition to the proposed pumped-storage hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Preserve. This project will have negative impacts on both the Ashokan Reservoir and its surrounding area. The proposal directly threatens the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, the quality of the New York City water supply, and the economy of the region.

The Catskills are a State Preserve protected by the New York State Constitution. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The Catskills are a major hiking destination that draws people from all over the Northeast. 
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and the trail user experience on multiple hiking trails in areas designated as Wilderness. 

The road closures caused by the proposed pumped storage project will eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that have happened over the past 12 months due to the unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems fragmenting habitat, cause the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of facilities, as was cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways that support the native flora and fauna, which are synonymous with the Forest Preserve, would be irreversibly damaged and affected by the construction of new dams and reservoirs. The forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Also, all proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area. See https:// www.audubon.org/important-bird-areas/catskills-peaks-area 

Additionally, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

This plan would increase turbidity and negatively impact New York City’s drinking water. Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the New York City water supply. Valuable trout breeding habitat would be lost. It would also affect fishing, boating, and swimming, all critical draws for a region dependent on tourism.

Rerouting Route 214, a Scenic Byway, would be incredibly disruptive. It is a major transportation artery for the Catskills, one of few roads that connect the central and northern regions. The loss of tourist dollars and business revenue caused by this construction project would directly hurt the local communities. It would significantly impact access to skiing at Hunter Mountain and summer concerts in Phoenicia, Hunter, and Tannersville.

I understand that sometimes sacrifices need to be made for our country’s transition to renewable, green-energy sources, but I do not believe it should come at the cost of environmental and economic devastation. Please reject the Premium Energy proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.  

Sincerely,
Philip Ficks

Zachary Beresin, Philadelphia, PA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

Protected lands impact our communities in profound ways. Catskill park not only provides safe drinking water for New York City, but contains an ecosystem that is home to hundreds of important animal and plant species. I spent every summer of my childhood visiting Catskill Park, and the experiences I had were instrumental in shaping my understanding and appreciation of the natural world and of my role in helping to protect our planet. These protected lands, which are disappearing rapidly, are priceless.

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Zachary Beresin

David Black, Briarcliff, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

David W. Black

Dan Elmendorf, West Shokan, NY.
Hi folks,
As a Town of Olive resident, I am opposed to the Ashokan Pumped Storage Project. 

My family has been through something like this before. It was my great grandpa, Henry Clay Elmendorf, who had his land taken by the original Ashokan Reservoir project, and he was paid pennies on the dollar. 

In the current proposal, it includes "taking" people's land. 

Another objection has to do with conservation of energy. You propose pumping massive amounts of water from a lower elevation to a higher elevation, then later releasing that water, running it though a generator so you can make energy.

Does that really make good energy sense? Seems it would be much better to devise a method whereby you could have continues power generation capability. Something more must be at stake here. I am fully aware of the problem of renewables and that they are unreliable. In fact I have deployed solar at my home. 

Why try to put a band aid on an idea, use energy inefficiently, and displace 
people from their homes, to pursue an unstated goal of renewable energy. 

This Ashokan Pumped Storage Project is a BAD idea, and as a resident in the area, I am strongly opposed.  

Respectfully yours,
Dan Elmendorf

Dan Segal, MAPLEWOOD, NJ.
The Catskills are a State Preserve protected by the NY State Constitution.
The plan as proposed would have very negative impacts on the NYC's drinking water.
Also, other negative impacts are on the ecology of the Preserve, on the streams, on fishing, and boating and swimming.
Rerouting Route 214 would be extremely disruptive.
There would be a loss of tourist dollars.
It is vitally important to future generations to preserve the State Preserve.

Jennifer E Rossa, Beacon, NY.
Dear Ms. Bose,

I am writing in opposition to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. 

I am one of many people who currently enjoy hiking in this protected area, and I believe it is vital for the economic health and environmental sustainability of the region that this project not go forward in this region.

I understand the need for new hydroelectric projects, but protected forests, streams and wildlife should not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment).

This project is not the kind of innovation that the Department of Energy wants to see. Premium's claim that this project is “closed-loop” is false. This is an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

A transition to green energy should not be attained at the cost of other sustainable living goals. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, Jennifer Rossa

Jonathan F Lief, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. My wife's family has owned property in Halcott Center since 1959; she and her siblings and our children have grown up cherishing the beauty of the Catskills, and in fact have an easement agreement with the NYC DEP to prevent overdevelopment and further damage to the environment.

I urge FERC to decline Premium Energy's request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jonathan Lief

Tomos Evans, Hurley, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in regard to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, the negative impact on the local environment -  ecological, economic and at a grassroots community level - simply vastly outweigh the benefits. 

I’m a huge advocate for green power, but believe the correct green solutions should be to the benefit of all - local and national - not at the cost of stunning wildlife, already hard hit communities and in this case threaten to disrupt the water supply of millions. 

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The precedent for protected lands across the country here is a terrible example - NY should lead in the protection of our country, not follow the reckless, destructive example set by the country’s leadership in the last four years. 

The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Also of extreme concern is the economic impact - in a year when many have lost jobs, had earnings vastly reduced (as a small biz owner it has been brutal and the lack of support deeply depressing) putting further strain on the community is unacceptable. How can anyone justify the one bright light of recent years - growing tourism and investment.   

It also appears from my research that this project does not represent the kind of innovation that the Department of Energy wants to see.  How can we trust a company that would mislead in their proposal simply for the advantage of being fast-tracked for approval?

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Tomos Evans, 
412 Wynkoop Rd, 
Hurley, NY. 12443.

Clara Ferraro, Bronxville, NY.
Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A
Washington, DC 20426


Re: Motion to Oppose Project #15056-000, Ashokan Pumped Storage Project

Dear Ms. Bose: 

I am writing to express my opposition to Project #15056-000, Premium Energy Holdings, LLC’s proposed Ashokan Pumped Storage Project.  My family has lived and owned property in the Woodland Valley for nearly 200 years.  We have enjoyed summers, winters, and all seasons in between in this beautiful valley.  This dam has many negative impacts on this unique and wonderful ecosystem, including but not limited to: unacceptable risks to NYC DEP's unfiltered drinking water caused by increased turbidity and sediment to the Ashokan Reservoir which meaningfully impact New York City’s water supply; unacceptable impacts to communities working to protect NYC DEP's water supply; negative impacts on the Catskills tourism economy; negative impacts to Esopus Creek's valuable recreational fishery; the loss of the Woodland Valley Stream and its recreational fishery; the carbon loss of the forest and soil of more than 200 acres for the reservoir and associated roads, dam and other infrastructure; and irreversible impacts to wildlife in the project zone.  

Our family, as well as all of those living in the valley, would be impacted financially, physically, and on a very real level, spiritually, from the proposed project #15056.  

I urge FERC to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, 


Clara Gillespie Ferraro

Amy Fradon, Woodstock, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE Room 1A
Washington, DC 20426

Docket number P-15056-000

Dear Ms.Bose,

I am writing in reference and opposition to the proposed Hydroelectric pumping station project with Premium Energy Holdings for the Ashokan Reservoir area in upstate NY. I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The environmental and community-wide disruptive extent of this project would be immense.

Two points that stand out to me.   

The Catskill Forest Preserve is protected by our NY State Constitution Article XIV, for important reasons. Wildlife and plantlife need vast swaths of land to be successful and this preserve is 700,000 continuous acres of land. This is an increasingly rare occurrence in our modern world. Continuous preserved land is essential to biological success and necessary to our overall survival on the planet. The Constitution clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

The second point is the almost complete disruption and displacement of entire communities that are the fabric of our economy, our character, our tourism and our history. People have visited the Catskills for decades because of the rural, historic beauty and charm of our local communities. This must be considered.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. I would also hope that our government would begin to really introduce the practice of conservation of resources as a collective and viable way to generate less and less energy so that storage that can devastate large, protected areas, is not the first option we seek.

Thank you for your consideration,

Amy Fradon

Laura Lou Levy, Wayne, NJ.
Laura Lou Levy
75 Beech Terrace
Wayne, NJ 07470

April 8, 2021


Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000


Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Laura Lou Levy

Donald Kass, Boiceville, NY.
Greetings---As a property owner in the Town of Olive, NY and a former investor and member of an Electric Co-op in the State of Vermont and an avid advocate of hydro electric power; I must express my serious opposition to this proposed plan.  After studying the details I am convinced that it would be a serious blight on the local environment and it would likely put a damper on tourism in our locale.  I see no benefit to the people of this area from this proposed project. PLEASE do not approve this proposal.
Respectfully-
Donald Kass
Boiceville, NY

Louise, Olivebridge, NY.
Docket number P-15056-000
Dear Ms. K. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Though new hydroelectric projects may be key in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process as this is highly preserved land that must be protected:
-	The Catskills Forest Preserve created in 1885 in Ulster County 
-	Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
-	The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. 
-	All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: see https:// www.audubon.org/important-bird-areas/catskills-peaks-area 
-	As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
-	According to The Catskill Park: Inside the Blue Line-Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum

This would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. 

Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Finally, Premium Energy’s Ashokan Pumped Storage Project proposal cannot represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Louise DeLucas
PO Box 1310, Olivebridge, NY, 12461
845-657-5762

sy gruza, new rochelle, NY.
I am opposed to the current proposal.  It will significantly and permanently adversely impact the viewshed from several hiking trails.  The proposed road closures will eliminate access points to popular hiking trails and overburden other areas of the Forest Preserve.  Sensitive vegetation is proposed for clearing which will result in ecosystem fragmentation.There is an unacceptable potential to increase turbidity and negatively impact NYC drinking water.

Peter Weeks, Ulster Park, NY.
Premium Energy must not be allowed to build a dam, reservoir, and power plant in the Catskill Forrest Preserve. While I understand the need for clean renewable power I believe that this project would do more harm than good. The watershed has significant historic and cultural value as one of the most important trout streams in the world. There is a significant wild rainbow trout run in the Esopus and the brown trout population in the upper Ashokan basin uses the Esopus as a spawning run as well.
The proposed 226-acre reservoir and associated 300+ foot tall dam would cause tremendous habitat destruction and alter the local wild scenery in one of the most celebrated outdoor regions of the State.
What makes the project such a bad fit for the area is the large flow fluctuations it will cause n the Ashokan reservoir and the proposed reservoir. They fact that the water levels will be rising and lowering rapidly and at ecologically random intervals will cause harm to the aquatic wildlife as well as the forrest wildlife attracted to the shorelines.
Imagine looking down on a 20’ wide, mud-bank rimmed reservoir from Slide Mountain. This would be enough to cause John Burroughs to roll in his grave.
Please, lets stop this terrible idea before it wastes any more time.

Marilynn Taylor, Williston Park, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 888 First Street
Washington DC 20426
Docket P-15056-000

Dear Ms. Bose,
I would like to register my objection to the proposed construction of a dam on the Ashokan Reservoir.

I am a lifelong resident of NYS and my family and I have vacationed in the area of Woodland Valley since 1976. We enjoy the nature activities of hiking and swimming and pristine nature of the surroundings. My husband does fly fishing for trout in the Woodland Valley stream, and as I state below it is a critical habitat for many animals.

Following are my objections to this project:

• Environment and Water Supply:
The project site is inside of Catskill Forest Preserve, and would destroy highly preserved forests, wildlife, and stream ecology, the Esopus is one of the Catskills’ most vital trout breeding habitats, and the area is one of the premier birding areas of NY State. This project would muddy the waters in the Ashokan Reservoir, which by the way supplies NYC with a high percentage of drinking water.

• Tourism and Small Businesses:
I have witnessed the growth of tourism in this area over the years and many small businesses have prospered. This will be devastating to them. Many local people would be put out of work, thus it is a another negative impactment.

• Private property would be taken by eminent domain—a process that
already displaced thousands in this area when the Ashokan Reservoir was built.

The Catskills Forest Preserve created in 1885 in Ulster County and I believe under the Constitution of New York it is protected and not to be sold or leased or exchanged by any corporation public or private corporations.

I urge you, as a responsible public official, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Marilynn Taylor

Louis Mellet, Armonk, NY.
I agree with all of the reasons below why this project should not move forward:

• Impacts on highly preserved land
o A Highly Preserved Land
▪ The Catskills Forest Preserve created in 1885 in Ulster County
▪ Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild
forest lands. They shall not be leased, sold or exchanged, or be taken by any
corporation, public or private.”
▪ The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly
fragmented environment; the forest around the proposed sites ranks among the
top 1% of forest habitats region-wide according to the New York State Forest
Condition Index.
▪ All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area:
see https:// www.audubon.org/important-bird-areas/catskills-peaks-area
▪ As a State Forest Preserve, the Catskills are considered Status 1 land
under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own
Hydropower Vision, “areas with formal protections designated as Status 1 or 2
under the USGS Gap Analysis Program are avoided for development.”
▪ According to The Catskill Park: Inside the Blue Line-Changes to land management
in the State Forest Preserves must be passed by constitutional amendment,
voted on by two consecutive sessions in the state legislature, then submitted to
the public in a referendum
• Impacts on Stream Ecology
▪ Pumped storage upper reservoirs are subject to rapid fluctuations of water
which wreak havoc on both aquatic and land habitats 
▪ Altering the sediment regime in tributaries to the Esopus will alter the sediment
regime in the Esopus, one of the Catskills’ most vital trout waters and part of the
NYC water supply
▪ Valuable trout breeding habitat would be lost
• Impacts to NYC water supply
o According to the DEP-Provides 40% of NYC’s water, a water supply that provides 1 billion
gallons a day to 9.5 million people
o The largest unfiltered water supply in the nation, built at the cost of displacing 25
communities
o A NYC valuable capital asset, representing billions of dollars of investment; $1.7 billion
since the 1990s alone
o Meets current NYC needs, but climate change produces uncertainty about its future
ability to do so: evaporation, heat events, and decreasing snowpack.
• Impacts on Catskills tourism economy
o Tourism is an integral part of the NYS economy and continues to grow
o Tourism generated 17% of employment in the Catskill region in 2019
o A $1.6 billion industry in the region, supporting roughly 20,000 jobs
o Ulster County represents 43% of that market
o Second homes generate $360 million in economic activity
▪ Source: Tourism Economics, “Economic Impact of Tourism in NY, 2019”
• This is not the innovation that Department of Energy would want
o Closed-loop projects are considered to have smaller environmental impact and are thus
eligible for streamlined FERC approval; that’s why Premium is claiming to be “closedloop.”
o • Projects where an upper reservoir is added to an existing lower reservoir are known as
“add-on” projects; that’s what this really is. They are lying.
o • “Initial construction impacts” for these projects are lower, but “operational impacts are
still likely to be higher than for a closed-loop project because the addon project’s lower
reservoir is still continuously connected to, and may affect, the natural flowing water
feature that was dammed for its original construction.”
▪ Source: DoE: “A Comparison of the Env. Effects of Open Loop and Closed-Loop
Pumped Storage Hydropower.” April 2020

Patrick W Floyd, Brooklyn, NY.

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the hearing of the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to DECLINE their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

As a resident of New York City, I have been lucky enough to enjoy the natural beauty of the Catskill Forest Preserve -- an area which Article XIV of the NYS Constitution clearly states “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Patrick Floyd

Kristina Buschang, Farmington, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Kristina Buschang

Melissa Brophy, West Shokan, NY.
NYC drinking water must be preserved at all cost. To construct a new upper reservoir in the Town of Olive would be a horrible mistake. The project would be devastating to ecosystems in the Catskills preserves, to people whose houses would be acquired by eminent domain and major disruption in the Town of Olive and surrounding communities. Stop the deal!!

Trevor Basset, Seattle, WA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Trevor Basset

Ellen A Lerner, Chichester, NY.
Ellen Lerner, Chichester, NY
FERC Project Number P-15056:000

To Whom it May Concern,
I am a resident of Chichester, NY (Ulster County) and am writing to oppose granting a preliminary permit to Premium Energy Holdings, it is misleading and deficient.

There is definitely a need to reduce our need for fossil fuels and become more reliant on renewable energy.  The Catskill area is not the place for a project like this without irreversibly damaging the state preserved forest land, wildlife and waterways. 

Premium Energy Holding's proposal is misleading and deficient.  The project is located in the heart of Catskills Forest Preserve when the proposal says it is not...This is  700,000 acres of land protected by Article XIV of the New York State Constitution.  The Article states these lands shall be forever kept as wild forest lands.  They shall not be leased, sold and exchanged, or be taken by any corporation, public or private.  To change the above would require a constitutional amendment that is voted on twice by the New York State Legislature and submitted to the public in a referendum.

In a hydropower project such as what is being proposed , the fluctuations of pumped water would increase the turbidity of the New York City water supply.  The Catskills provide 40% of New York Cities drinking water.  This project would wreak havoc on land and water wildlife and their habitat.  

The Catskills Forest Preserve is essential to many protected, rare and threatened species such as:

Northern long-eared bat, black throated blue warbler, scarlet tanager, wood thrush, cooper hawk, red-shouldered hawk, sharp-shinned hawk, Eastern hognose snake and timber rattlesnake, northern cricket frog.  Trout's ability to spawn would be destroyed.

Also misleading in Premium Energy Holding proposal is describing it as a closed-loop system when it is clearly an open-loop design. This will have major impact on the free-flowing Stony Clove Creek.  My family has lived on the Stony Clove creek Since 1927.  This area has received funding from the NYC DEP Stream Management Program, the US Army Corps of Engineers under the Watershed Environmental Assistance Program and New York State DEC.  The effort and money put into these projects has greatly improved the quality of water, the health of the creek and the turbidity that had been plaguing the waterway

The proposed project would inflict damage on the ecology of the state protected land in a way that would be immeasurable.  In addition to the financial well being of the area and its businesses.  I urge  you to deny Premium  Energy Holding's preliminary permit so the Catskills Forest Preserve is not destroyed permanently.

Sincerely,

Ellen Lerner
5 Stony Clove Lane
Chichester, NY 12416

Leonard Lerner, Chichester, NY.
Leonard Lerner, Chichester, NY
FERC Project and Sub-docket Number: P-15056:000
To Whom it May Concern, 
I am a resident of Chichester, NY (Ulster County).  I strongly oppose the granting of a Preliminary permit to Premium Energy Holdings, it is misleading and deficient.
I believe the Catskills Forest Preserve is not the right location of such a project given the significant impacts to the forest lands, streams and wildlife and the New York City water supply.  This proposal would be in violation of the New York State Constitution Article XIV.  The Article states these lands shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any management of the State Forest Preserve.  A constitutional amendment is required, one that is voted on twice by the NYS legislature and submitted to the public in a referendum.
Premium Energy claims it will build a closed loop system and this is false. when it is actually an open loop system, where an upper reservoir would be added an already existing lower reservoir connected to a natural water source.  The environmental impact to aquatic and wildlife would be significant. 
As a State Forest Preserve, the Catskills are considered Status 1 under the USGS Gap Analysis Program.  According the US Department of Energy's own Hydropower Vision report,  Areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development. 
 Given the protected status of the Catskills Forest Preserve, the misleading nature of Premium Energy's proposal and the US Department of Energy's Hydropower Vision report to avoid Status 1 land, are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.
Sincerely,
Leonard Lerner
5 Stony Clove Lane
Chichester, NY 12316

Sharon Turner, Highland Mills, NY.
This proposed project is NOT good for the Catskills.  It is truly an assault on the intended purpose of Catskill Park, which was set aside to remain a forever wild tract of land.  If a hydroelectric plant is needed in the Catskills, it should be built outside of designated preserves.  Otherwise, what is the point of calling something a preserve??  What are we 'preserving' if we allow such a project to proceed, knowing it threatens the ecology of the park, the recreational access to trails, and the drinking water supply of NYC?  Let me repeat that last part.  This project threatens the drinking water of millions upon millions of people living in our country's most populous city.  Permission for this project needs to be denied.

Meghan Taylor, Rockville Centre, NY.
I am writing to urge you to reject the proposal submitted by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains. I write as a lifelong visitor to the area - to see the destruction of this key resource in New York is devastating.  This project is deeply flawed on a number of fronts: It is extremely invasive to the community that resides there and will impact not just their environment but the thriving tourism that currently exists there. Even more critical is habitat destruction for the local wildlife, flora, and fauna. Finally, this project will have a lasting negative impact on the reservoir that is New York’s drinking water supply.  Technically I urge that the project must be rejected because:
 
1. The proposed site is on designated Status 1 land, and federal policy explicitly directs that Status 1 and 2 land areas are highly protected and must be avoided for development. This proposal would demand a Constitutional Amendment passed by the NYS Legislature and signed by the Governor. This barrier alone is sufficient to stop the proposal, in its tracks, at this very moment.
 
2.The proposed project will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for 9 million New York residents.
 
3. The flawed application misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design with worse environmental impacts.
 
4.The project raises numerous legal issues regarding States’ rights and land reservation.
 
5. The proposed site is home to protected species of wildlife and flora/fauna, as well as historical and cultural artifacts and sites.

Additionally, comments from Premium Energy's Leadership demonstrate that the Company itself has seriously erred in their proposal development by presenting a plan that even they admit is faulty:

 "The Ashokan project will be built only with the cooperation of the community. We don’t want to harm or damage nothing or no one. It looks like the first choice of upper reservoir was a bad choice. There is a community in that location. This site alternative therefore will not be any longer pursue it."
 
"Also, since this reservoir belongs to the city of New York, if the city of New York deems this project not safe for the integrity of the water supply to the City, this project will not happen."

We clearly recognize the need for our nation and world to transition to green-energy sources. However, this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, contaminate local wells and septic systems, negatively impact the drinking water of 9 million New Yorkers.
 
I urge you, as a responsible public official, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.    

Submission Description: (doc-less) Motion to Intervene of Barbara J Runz under P-15056-000.

I am filing this motion to intervene, on the basis of EMINENT DOMAIN. I live directly behind the proposed site of the Wittenburg Reservoir and in the path of proposed high tension wires.

Submission Date:        4/8/2021 12:07:40 PM

Filed Date:             4/8/2021 12:07:40 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               Bjtr303@gmail.com                                                                

Basis for Intervening:
I am filing a motion to be an intervener and I meet the requirements of 18CFR 385.214 of the Commission's regulation to be granted full party status.

My home is within the Catskill Park and in fact lies directly in front of the proposed site of the upper reservoir and the proposed location of the high tension wires required for the project. Therefore I am filing under the threat of EMINENT DOMAIN. 

Further, if my home were not taken by eminent domain, the project would ravage the area and cause loss of property value. I would also be living with the fear of damn failure and flooding to my home. 

I, Barbara Runz, respectfully request that the Federal Energy Regulatory Commission grant this motion to intervene.

Respectfully,
Barbara Runz
454 Watson Hollow Road
West Shokan, NY 12494

Diane Silvergleid, Stone Ridge, NY.
I am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  Thw proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Tania Zamorsky, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Because of the proposal’s numerous deficiencies, I am asking FERC to decline their request even for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as in my opinion, it is flawed from a legal, procedural, technical and moral perspective.

Legally and procedurally/practically, the proposal is ill-advised:
 
•	NYS Constitution’s Article XIV provides that the Catskill Forest Preserve, created in 1885, “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
•	As a State Forest Preserve, the Catskills are also considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”  
•	According to The Catskill Park: Inside the Blue Line-Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. 

Next, based upon my research, I do not believe this company’s project description is even technically accurate. No doubt aware that the Department of Energy views “closed loop” pumped storage projects favorably, given their smaller environmental impacts, Premium Energy mischaracterizing their project as such when in fact it is actually an “add-on” project due to its use of an existing watershed as a lower reservoir.
 
While initial construction impacts for these projects may seem lower, they will ultimately be higher (than for a true closed loop project) because the add-on project’s lower reservoir is still continuously connected to the natural flowing water feature that was damned for its initial construction. Such add-on projects are risky and disruptive enough, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city, New York City, as the Ashokan Reservoir in this case is, and which this project will directly jeopardize. 

How can we trust the quality¬¬--and ongoing attention and care that will be required—of a project that is, at best, this arguably sloppy and inexact from the get-go? Please do not reward this company by granting them the streamlined FERC approval they are trying to gain with what in my opinion is a mischaracterization of this project’s essential and technical nature.

Finally, from a moral perspective Premium Energy’s proposal would be deeply and disproportionately damaging to local communities. (And dismissing this point as a mere “NIMBY” argument would be as inaccurate as the characterization of this as a “closed loop” system.)
 
Any conceivable upper reservoir site in the Catskill Forest Preserve would require the eminent domain seizure of homes and private property that already saw thousands of such seizures (including the flooding of entire valleys; the loss of entire towns; the taking of homes, churches, schools and graveyards of extended and multigenerational families) when the Ashokan itself was constructed, only a few generations ago. 

To the NIMBY point, I would ask you to consider, exactly how many “backyards” must one community be asked and expected to surrender? 

History aside, residents displaced by the Ashokan Pumped Storage Project would face real difficulties securing new housing, as there is currently a severe shortage of affordable housing in Ulster County, which has only been exacerbated by the Covid pandemic. And, even if they could find alternate housing, this project’s devastating impact on the local tourism and outdoor recreation economy—which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs—would threaten their ability to afford these new homes. This ripple effect would in turn negatively affect businesses in Ulster County, and well beyond. These effects are unjustifiably disproportionate.

In sum, our country’s critical transition to renewable, green-energy sources demands that we proceed responsibly, and with accuracy, fairness, due process and proper proportion. If that transition is undertaken and implemented crudely and incorrectly—and in name only—we will defeat its very purpose and cause significantly more harm than good. 

I thank you for the important role you play in this process and urge you to deny this proposal for the Ashokan Pumped Storage Project P-15056.


Sincerely,

Tania Zamorsky

Kevin Riklin, BETHESDA, MD.
I urge that this project be rejected because

1. The proposed site is on designated Status 1 land, and federal policy explicitly directs that Status 1 and 2 land areas are highly protected and must be avoided for development. This proposal would demand a Constitutional Amendment passed by the NYS Legislature and signed by the Governor. This barrier alone is sufficient to stop the proposal, in its tracks, at this very moment.

2.The proposed project will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for 9 million New York residents.

3. The flawed application misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design with worse environmental impacts.

4.The project raises numerous legal issues regarding States’ rights and land reservation.

5. The proposed site is home to protected species of wildlife and flora/fauna, as well as historical and cultural artifacts and sites.

Sarah Hemingway Lynch, West Shokan, NY.
Thanks for offering the opportunity to register my concern about this project. As a homeowner, business owner, mother and neighbor in West Shokan, NY I know we can do better than this flawed proposal puts forward. This Premium Energy plan would ruin my house and my business which are on the banks of the Bushkill River. We run the only cafe and market (Marty’s ‘Mercantile) serving our hamlet. This plan is bad for tourism (we were just written up in Hudson Valley Magazine!) 

Ulster county makes up 43% of NY state’s tourism income and the adverse impact of this project would greatly diminish the stream ecology which would also kill the trout and limit fly fishing tourists. My personal home, my three kids’ welfare and our community are also on my mind. 

Please consider the pump in a location near the aero rater where less personal and professional harm could be done to our community.

Thanks,
Sarah

Vera Zamorsky, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

Premium Energy Holdings has proposed to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as this add-on (NOT closed loop) system would be devastating to the environment.

The Catskill Forest Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. 

And the destruction would not simply stop when construction on this project did. Premium says this is a “closed loop” system but the project’s lower reservoir would remain continuously connected to the natural flowing water feature that was damned for its initial construction. Pumped storage will disrupt nearby stream ecology and both aquatic and land habitats as the pumping causes rapid water and unnatural and violent fluctuations. This in turn would affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters. There is nothing “closed” about it. 

The Esopus is also of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. It would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation and represents over $1.7 billion of investments since the 1990s alone.

Our country’s transition to renewable, green-energy sources is an undeniable and very important goal, and I certain recognize the scope of the task you have before you. However, I hope you will agree that it makes no sense to approve projects, such as this one, which will decimate and destroy the very environment they are purporting to protect. 

I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Vera Zamorsky

Karen Ludemann, Stone Ridge, NY.
I am writing to object to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to reject Premium's application for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The application is facially defective and the proposed project would devastate the environment, the local communities, and would risk the purity of NYC’s drinking water.  Pumped storage and new hydroelectric projects may play a key role in our country’s transition to renewable energy, but the constitutionally protected Catskill Forest Preserve is not the right place for one. 

	1) Article XIV of the NYS Constitution guarantees that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. Changes. if any, to the status of this land would require a constitutional amendment, voted on by two consecutive sessions of the state legistalure and then subnmitted to a public vote by referendum.

	2)  Contrary to the description in Premium's application, this is not a closed-loop project, which is the kind of project the Department of Energy wants to see due to its lower environmental impacts.  It is an add-on project, using an existing body of water as the lower reservoir.  Add-on projects have significantly higher risks.  The Esopus Creek and other streams flow into and out of the Ashokan Reservoir (which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people). The  proposed project would therefore directly interact with an unfiltered public water source. Since the Catskills are within a State Forest Preserve, they are designated Status 1 land under the USGS Gap Analysis Program. The Department of Energy's own materials on hydropower state a clear preference for closed-loop and not add-on projects and indicate that development of Status 1 or 2 lands should be avoided.  

	3)  Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters.  Water level fluctuations would also increase turbidity within the Reservoir itself.  NYC is not presently required to filter the Ashokan water pursuant to long-standing EPA consent to the New York City Filtration Avoidance Program (FAD).  EPA's consent was just renewed in December 2017.  If Premium's application were to be granted, this would potentially create a conflict between the positions taken by two federal agencies.

	4)  Ulster County should not have been the only county notified of Premium's proposal.  The proposed Stony Clove Reservoir actually falls within the Town of Hunter in Greene County.  Upon information and belief, Greene County was never notifed of Premium's application, rendering it defective on its face.

	5) In addition to its negative effects on the environment and water supply, Premium’s proposal would be deeply damaging to local communities, requiring the seizing of private property by eminent domain in any of the locations proposed by Premium. Displaced residents would have difficulty securing new, affordable housing, as there is currently a housing shortage in Ulster County.  There would also be a negative effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Dulcy Israel, Brooklyn, NY.
I am a frequent visitor to and renter in West Shokan, a hamlet in the town of Olive, New York. 

West Shokan, as well as the very road I live on, Moonhaw Road, is one of the towns being proposed by Premium Energy Holdings as a site for a 300-foot dam, giant reservoir, turbine, and 50-foot tunnels for use in pumped storage and generation of electricity. There will also be unsightly transmission towers up and down many roads, the mountain and valleys, and along the Ashokan Reservoir, which supplies drinking water 40% of water to New York City. A power plant would be built right next to the Ashokan reservoir. 

I reject this proposal, object to this proposal and downright am horrified by this proposal, which would negatively impact the environment, destroy communities, upend the homes of many wild creatures great and small. The construction would permanently damage the rivers and streams, and the power plant would disrupt the flow to and increase the turbidity of the Ashokan Reservoir, destroy mountains, as well as the quiet beauty of the Catskills, where people have been coming for centuries for respite. I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. Whoever is reading this, please do everything you and your FERC colleagues can do to stop this proposal from going one step further. Thank you, Dulcy Israel

john keane, middletown, NY.
I strongly oppose this terrible plan to build a new dam within Catskill Park. It will damage our natural resources and diminish the quality of life for everyone in the hudson valley. Do not let this plan move forward. Deny this motion.

karen s howenstein, mount tremper, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Karen Howenstein

Lynn Schmeidler, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
Regarding the deeply flawed proposal to build a hydroelectric power plant in New York’s Catskill Mountains, I am writing to urge FERC to decline Premium Energy Holdings’ request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The project would be devastating to the environment, disruptive to local communities, and dangerous for NYC’s drinking water.
The crucially protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Additionally, all proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area, habitat for NY-species of Greatest Conservation Need including the black-throated blue warbler, scarlet tanager and wood thrush. The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment). Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program,” and according to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
Even once construction were to be completed, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.
Disturbingly, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
I am a strong advocate of transitioning to sustainable and renewable energies, but not at the cost of environmental and community devastation. Surely Premium Energy can find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten crucial natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Lynn Schmeidler

Gregg Ury, Woodstock, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I’m writing to oppose Premium Energy Holdings’ flawed proposal to build a hydroelectric power plant in New York’s Catskill Mountains and to urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The project would be a disaster for our environment, traumatic to local communities, a threat to NYC’s drinking water.
In the necessary move to sustainable energies, the protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed. I am proud to live near the Preserve which currently contains 700,000 acres of continuous wildlife habitat, a sadly rare occurance in our increasingly fragmented environment. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Furthermore, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program,” and according to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
Even once construction were to be completed, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.
Also, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
I support transitioning to sustainable and renewable energies, but not at the cost of environmental and community devastation. Premium Energy ought to find a suitable alternative location for a pumped storage project where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten crucial natural resources.
I urge you to do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Dr. Gregg Ury

John Giacalone, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

John Giacalone

Casey Kelbaugh, Lanesville, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, our four-season tourist economy and risky for the purity of NYC’s drinking water, where I also have an apartment.

Perhaps pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain (perhaps even mine?!) —a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills (all of which I enjoy), decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Bellearye, Windham, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would cut corners in their proposal simply for the advantage of being fast-tracked for approval?

There are those that believe that Premium Energy never even intended that this project come to fruition - that their goal is to get a feasibility study approved, in which they take on massive investment and profit along the way. They will make their money whether the project is green lighted or not. Perhaps this lack of respect for our community is what's most disturbing.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Casey Kelbaugh
2384 Route 214 
Lanesville

Deborah Glick, New York, NY.
April 8, 2021

Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Re: FERC P-15056-000

To Whom It May Concern,

As the New York State Assemblymember representing the 66th district in Manhattan, I am writing to vehemently oppose the application by Premium Energy Holdings LLC for a preliminary permit to explore building an underground hydroelectric power plant at the Ashokan Reservoir (docket P-15056-000). 

The Ashokan Reservoir, located in Ulster County, is a critical water source for New York City, and provides over 40 percent of the city’s drinking water. Premium’s proposal would create a large and intricate new underground power plant, with construction including the creation of a new reservoir, new tunnels to pump water to and from the existing reservoir, and generators to capture energy created by the flow of water between the two reservoirs.

The proposal is concerning for a number of reasons. Most importantly, it was undertaken without any consultation with New York City’s Department of Environmental Protection (DEP) or with the local municipalities surrounding the Ashokan Reservoir. The DEP and local governments were only notified of the proposal following your agency’s release of a notice of application in February, and have raised significant concerns. Premium, the applicant, is based in California and local authorities have pointed to a lack of knowledge of the Ashokan and surrounding areas, ranging from basic errors in their mapping to the proposed placements of the new upper reservoir, which in one case would require the flooding of an entire residential community (Woodland Valley). The proposed new reservoir sites also appear to fall within State lands that have been designated as “forever wild,” a major legal hurdle that the project would have great difficulty overcoming. 

Of greatest concern for my constituents, Premium’s proposal would also represent a substantial risk for the city’s water supply. Catskill Moutainkeeper, a regional environmental advocacy group, has stated that the project has the potential to increase turbidity in the Ashokan, stirring up solids and compromising the quality of the reservoir. Turbidity is already a challenge for the Ashokan, and this project presents an unacceptable threat to the water supply of over 9 million New Yorkers. 

Premium has argued that hydroelectric power is a necessary component of moving to fully green energy sources, as they’re able to provide power at night when solar and wind power are less effective. I do not disagree - I am committed to New York State’s plans to move toward renewable energy, and believe that hydroelectricity will be essential to meeting our goals. We are lucky that New York State has a number of waterways that would be good candidates for smaller scale hydroelectric projects that would make use of our existing landscape and produce minimal impacts on the surrounding land and communities. Premium states that the value of the plant they propose is in the substantial amount of energy that would be captured, but that energy is not worth the impacts or risk, especially when the opportunity for more suitable projects exists. 

The Ashokan Reservoir also provides a substantial economic benefit to its surrounding communities. The Ashokan Rail Trail, which opened in 2019, offers 11.5 miles of accessible trail that gives users access to the north rim of the reservoir for the first time in  a century. The Rail Trail has proven to be extremely popular, drawing users from New York, New Jersey, Connecticut and beyond, and bringing millions of dollars in local spending with them. The economy of the region relies on the Rail Trail’s recreational value, as well as the many investments New York State has made to support agriculture and a growing industry of craft beers and spirits distillers that depend on other fresh water sources that could be imperiled by extensive construction in the areas around the reservoir. The Rail Trail has been especially valuable during the COVID-19 pandemic, offering New York City residents and others a safe place to get outside and enjoy nature while remaining socially distanced. The extensive construction required by Premium’s proposal would substantially impact the use and enjoyment of this important resource, and with it the economy and health of the region.  

I encourage FERC to support projects that show a deep understanding of the natural resources being developed; include the meaningful engagement of local and impacted governments and communities; and whose risks to communities are minimal unless shown to be absolutely necessary. The Premium proposal meets none of those standards, and instead risks the contamination of New York City’s drinking water and the wellbeing of upstate communities. For these reasons, I ask that you reject this application.

Thank you for your time and attention.

Sincerely,

Deborah J. Glick
Assemblymember

Matthew Kulukundis, LIC, NY.
FERC should block this application because it will likely fail at later stages.  The proposal impacts lands that are protected in the NY constitution and the barrier to bypass those protections is so large that it wastes government resources to proceed at this point.

Gretchen Hartman, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426

Docket P-15056-000

Dear Ms. Bose

I am Gretchen Hartman. I have lived at 945 Woodland Valley Road, Phoenicia since July 1977.

I am writing to urge you to reject the deeply flawed proposal submitted by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains.

This project must be rejected because it will have a serious negative economic impact on the region.  And an additional complexity as implementation of this project would require a NYS Constitutional Amendment involving passage through both Houses of New York State Legislature and a sign off by the Governor. 

The proposed project would disrupt the environment of the Catskill Forest Preserve, 700,000 acres of critical habitat in an increasingly fragmented world. It will Flood over 200 acres of private land and protected state forests to construct a new reservoir

The new reservoir would be connected to the Ashokan Reservoir by a tunnel up to 50 feet wide and many miles long, drilled under both public and private lands, and the erection of 12.9 miles of 230kV high-tension transmission lines.

It will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for 9 million New York residents. It will severely disrupt existing regional wells and septic systems which in turn will negatively affect the quality of water regionally and in New York City.  

Premium Energy, in a proposal that demonstrates total lack of understanding of the Catskill region, misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design with worse environmental impacts.

We clearly recognize the need for our nation and world to transition to green-energy sources. However, this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, contaminate local wells and septic systems, negatively impact the drinking water of 9 million New Yorkers.

I urge you, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.    

Gretchen E Hartman

Ciarra Fragale, Montgomery, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

I have been a lifelong resident of the Hudson Valley, and although I have lived in many other places in my life, I always come back to here. This is largely due to the environmental integrity of the Catskills, the Shawangunks, and everything in between. This land is so sacred, and moving forward with this project I ensure you will bring immense damage to the integrity of the land that keeps people like me coming back. This will be devastating to the ecosystem, the water supply, and the the beauty of the natural landscape.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ciarra

Dan Taylor, Rochester, NY.
To whom it may concern:

I am writing in strong opposition to Premium Energy's proposal to build a hydroelectric dam in the Catskills.   The impacts of such a construction project would be devastating to the wildlife, water supply, and people's homes and businesses.  This project does not have the consent of the communities it will impact the most, let alone the people in NYC who drink the water from the current reservoir.  

While I am not a resident of this area, I have family that has lived on Woodland Valley road since 1977.  I spent the winters and summers of my youth there tubing on the Esopus, hiking Giant's Ledge, and camping in Woodland Valley State Park.  Now I bring my own children there to take enjoy this beautiful section of New York. To lose these natural resources and rob people of these experiences would be an unforgivable crime.   

Do not allow this project to move forward.  

Sincerely,
Dan Taylor

Jesse Vadala, Albany, NY.
This land was designated many years ago as “Forever Wild”, as it should remain for generations to come. There is no excuse for the proposed compromise beyond the selfish exploitation of protected resources. These types of actions can not be undone and will certainly prove destructive if not disastrous, and directly impact the beauty of our beloved Catskill region. 

Like the myriad of other locals commenting here, this is not a delusional attempt to halt the progress of energy and expansion within our home territory. However, the time is now to discuss ways in which advances can be made, yet not at the expense of diminishing natural resources.

emilie sinkler, mt tremper, NY.
Dear Ms. Bose,

I am writing (along with many of our town members) in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Emilie Sinkler

Paul Dippolito, New York, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to express concern and voice opposition to the proposal by Premium Energy Holdings to build a hydroelectric power plant and storage dam/reservoir in the Catskill Mountains of New York State (Ashokan Pumped Storage Project P-15056).  The plans for this project are vague and poorly described in the proposal, and have been egregiously misrepresented in their application to FERC.

Two of the three options proposed--Alternatives 1 and 2 in the application--will flood large sections of land that is designated Wilderness Preserve by New York State, protected under Article XIV of the state constitution, which states that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

For over 40 years New York State has been fiercely protective of the ecology of the Mid-Hudson Valley, particularly of those lands that fall within the watershed providing potable unfiltered drinking water to the 9 million residents of New York City. Any effort to compromise these lands will certainly be met with a protracted legal challenge by the state, and I have to wonder if Premium Energy has taken into account in their plans the lengthy, costly, and well-publicized resistance they are sure to meet.

The third proposed location (Application 3)--as it is described in the proposal--would almost certainly require severing north-south access on State Rt. 214. Even a brief topographical study of the terrain leading north to Stony Clove Notch makes clear the impossibility of providing vehicular access around such a dam and reservoir.  NYS Rt. 214 is the only road between Ulster and Greene counties for 25 miles, and the vehicular fuel necessary to circumvent this loss of access to residential, commercial and recreational traffic is sure to offset any possible benefit of energy storage provided by the facility.

Finally, Premium Energy Holdings describes the facility inaccurately to FERC.  Page 11 of the proposal states “The proposed Ashokan Pumped Storage Project would operate in a closed loop.”  This is not correct; the Ashokan is not a closed waterway, but part of the continuous flow of water from the upper reaches of the Catskills to the Hudson River. Such a clear oversight--if not intentional misrepresentation--in their proposal should alone disqualify Premium Energy from approval for a preliminary permit.

I thank you for the opportunity to express my opposition to this proposal.

Best Regards

Paul Dippolito
928 Columbus Avenue 3S
New York, NY 10025

917-646-9708

bethann M miale, Tivoli, NY.
PLease keep this power plant out of the Catskills. It will destroy protected wildlife habitats, displace residents  and pollute a water supply that delivers to 9+ million people.

Karen Greenstein, NEW YORK, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. My children attended a YMCA camp in the Catskills for eight summers. As part of that camp, they hiked and camped in preserve. To think that any part of the preserve would be compromised, is so disheartening.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond. 

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Karen Greenstein

siobhan joan dolan, Phoenicia, NY.
                                                                                                                                                                                                                       William Apfel & Siobhan J. Dolan
1380 Woodland Valley Road
Phoenicia, NY 12464
April 7th, 2021

Secretary Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000 

Dear Secretary Bose,

We strongly oppose Premium Energy’s proposal to build a hydroelectric power plant, in NYS’s Catskill Mountains.  We urge the Commission to reject their request for any kind of permit for the Ashokan pumped storage project (P-15056-000).  It would:
•	Highly disrupt many local communities
•	Contaminate NYC’s drinking water
•	Devastate the natural environment

The pumped storage and hydroelectric project could play a role in the United States transition to renewable energy, but the pristinely protected forests, streams and wildlife of the Catskill Forest Preserve cannot and must not be sacrificed.  Article XIV of the New York State Constitution guarantees that these lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private”.  The Catskill Preserve currently consists of 700,000 acres of continuous wildlife habitat and the forest surrounding the proposed sites rank among the top 1% of forest habitats in the region, as per the State Forest Condition Index.  It would be a horror to destroy this jewel of land and set a terrible precedent.

We understand that pumped storage is known to destroy the ecology of water and land habitats. In the complicated process of a pumped storage system, the upper reservoir is subject to rapid fluctuations as water is pumped in both directions. 
This will affect:
•	Wildlife
•	Trout breeding waters
•	The Esopus Creek feeding the Ashokan Reservoir

In addition, we are concerned about people losing their homes and creating an even further shortage of housing. We worry about the negative consequences to the tourism industry, the economic engine of the area. Recreational activities like hiking and fishing would be seriously altered, especially since the area has so long been a “trout capital” of the nation.  We also are concerned about threatening or endangering certain animal species of the region.

Lastly, we have been informed by reputable sources of questionable statements made by Premium Energy Holdings, as stated in their plan.
Needless to say, we are terribly alarmed.  Please reject Premium Energy Holding’s proposal for a permit.

Sincerely,

William A. Apfel
Siobhan Joan Dolan

Adam P. Barsky, Esq., Philadelphia, PA.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Very truly yours,

Adam P. Barsky, Esquire

Shea Belsky, Boston, MA.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Shea

Submission Description: (doc-less) Motion to Intervene of Valerie C Griffin under P-15056-000.
I am filing this motion to intervene on the basis of Eminent Domain.  The proposed reservoir is directly above my house
My property will be in the path of proposed high tension lines.

Submission Date:        4/8/2021 3:31:26 PM

Filed Date:             4/8/2021 3:31:26 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               Vg210050@gmail.com                                                               

Basis for Intervening:
I am filing this motion to intervene on the basis of Eminent Domain.
The proposed storage plant is directly above my property.  My
property will be in the path of the proposed high tension
wires.

Elizabeth Riklin, Bethesda, MD.
Dear Ms. Bose

I am Elizabeth Riklin. I live at 10649 Montrose Avenue, Bethesda, Maryland and for the past 45 years, my family and I have been visiting Woodland Valley, Phoenicia.

I am writing to you to urge you to reject the deeply flawed proposal submitted by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains.

I urge that the project be rejected because it would have a highly negative impact not only on the people, wildlife and organizations in Catskill region, but also the 9 million residents of New York City. The proposed project would severely disrupt and increase turbidity in the Ashokan Reservoir, the source of 40% of NYC drinking water, and surrounding streams. 

While I fully support efforts to develop  green-energy sources, this proposed effort would destroy protected wilderness areas, negatively affect wildlife and contaminate local wells and septic systems, in addition to negatively impact the drinking water of 9 million New Yorkers.  This is not a green-energy effort. 

I urge you, as a responsible public official, to reject the Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.    

Elizabeth S. Riklin

Eric Mann, Saugerties, NY.
I thoroughly oppose any development around the Ashokan  reservoir.
This is back room cronyism. 
We aren’t coming out to California, with our “investors” to
Clandestinely change the very heart of your community,
Please, STAY OUT OF OURS.
Eric Mann

Margaret Cogswell-Kolb, West Shokan, NY.
As a resident of both New York City and West Shokan, I stand in firm opposition to Premium Energy Holdings’ ill-conceived proposal for a Preliminary Permit for the Ashokan Pumped Storage Project, FERC Project No. 15056 - a proposal which would have a serious negative impact on both communities.  

The Ashokan Reservoir was built over 100 years ago for the sole purpose of providing drinking water for NYC and now provides 40% of the drinking water for its 9.5 million people.  Subsequently, the streams that flow into it are strictly monitored and protected, as are the surrounding lands and forests so as not to disrupt NYC’s water quality and quantity.  Premium Energy Holdings’ proposal to build a hydroelectric pump station in the upper basin of the Ashokan Reservoir would violate strict regulations of the surrounding land and water use.  It would increase turbidity in both the streams and reservoir, thus negatively impacting the drinking water for over  9.5  million people in the City of New York. 

The building of this reservoir over 100 years ago destroyed 12 towns and displaced 1000’s of people.  Now, Premium Energy Holdings’ proposal to build a hydroelectric pump station in the Ashokan Reservoir, along with tunnels, dams, turbines and additional reservoirs, would again displace and/or destroy surrounding communities, as well as destroy parts of the Catskill Forest Preserves.  The Catskill Forest Preserves are protected by New York State and considered as Status #1 land.  Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Any change in land management of  the Catskill Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. This, in itself, should prove how seriously ill-conceived and flawed this proposal by Premium Energy Holdings is.

Additionally, with climate change, we have already been witnessing frequent drought conditions in the upper basin of the Ashokan, therefore already rendering unreliable the amount of water available just to adequately meet NYC’s needs which is the primary and sole purpose for the existence of the Ashokan Reservoir in the first place.  Building a hydroelectric pump station would compete for usage of the same water supplying NYC and would subsequently be an additional strain on the system.  This would result in both systems being seriously compromised and rendered incapable of performing the functions they were meant to fulfill. 

Sustainable and renewable energy is important, but it must be done with a smart, well researched,  and well considered plan.  This plan is ill-conceived and full of outrageous assumptions and even more serious flaws not mentioned here.  

Please do everything in your power to prevent this proposal from moving forward and deny Premium Energy Holdings’ proposal for a preliminary permit for the Ashokan Pumped Storage Project P-1.

Thank you.
 
Sincerely,
Margaret Cogswell-Kolb

Wendy wrothkopf, West Shokan, NY.
Wendy Rothkopf
3683 Route 28A
P.O. Box 52
West Shokan, NY 12494

									April 8, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

RE: FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA.

Dear Ms. Bose;

As a resident of West Shokan, NY and the preserved lands of the Catskill Watershed, I am writing to protest the application of Premium Energy Holdings LLC for a pumped storage system in this area.  

1.	 The application refers to a closed loop system.  This is false.  They plan to create a secondary body of water, rather than connect an existing body of water, to the Ashokan Reservoir.  This is not a closed loop system but an add-on system which, aside from the fact that it is not energy efficient as claimed, would have a negative impact on a.  the environment and the endangered species and waterways therein b.  create turbidity and pollution in the streams of the Esopus Creek and the Ashokan Reservoir, the former containing a fragile trout population/ecosystem and the latter supplying 40% of New York City’s drinking water and c. countermanding NY State Constitutional Article XIV, which states that the lands of the Catskill Forest Preserve “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

2.	It is required by law that any change to this land provision requires an amendment to the state Constitution, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.


3.	The lands surrounding this proposed referendum would necessitate the implementation of Eminent Domain, a process that is unacceptable in these preserved lands – a process that can devastate both public and private properties in the area now as it did when the original Ashokan Reservoir project was built in 1905.

4.	The county of Ulster contains a highly valuable tourism business with a commensurate employment rate, all of which would be disrupted by the proposed Storage project.  Premium Energy’s proposal would limit access to hiking, fishing , dining, and skiing as well as other forms of entertainment and recreation in the area.

All told, The Ashokan Pumped Storage Project has been submitted under false pretenses, is antithetical to the fundamentals of “Green Energy” and would have a long-term, negative impact on the lives of local community members and the fragile, preserved Catskill Watershed lands in which they have chosen to live.

Respectfully yours,

Wendy Rothkopf

Ron Cohen, MT Tremper, NY.
Dear Ms. Bose,

I am writing to ask that FERC decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

I am situated nearby and have been appraised of the negative impact this project will pose for the environment- and the drinking water of NYC.

Thanks for your time,

Ron Cohen

howard widensky, Phoenicia, NY.
I am a resident of Woodland Valley, Phoenicia NY.
I am completely disturbed by this proposal for a permit to be submitted or approved for Premium Energy Holdings,LLC. Have these people researched the area in question at all? Do they care about the natural resources at all?
At this time the project site is inside of Catskill Forest Preserve, and would destroy highly preserved forests, wildlife, and stream ecology. The Catskills Forest Preserve was created in 1885, and the NYS Constitution states that the lands “shall be forever kept as wild forest lands, [and] shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The forests around the proposed sites rank among the top 1% of forest habitats region-wide, and are considered Status 2 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
Are you aware that at any time in this preserved area that a home owner needs to do repairs of any kind that involve the land, we have to get special permissions and approvals from The State agencies of DEC and DEP especially when it comes to septic systems. We cannot do anything without their watchful eye to make sure our ground waters are not contaminated. As homeowners we have come to expect excellence in protecting our natural surroundings. This has got to be addressed that a proposal and project of this magnitude will destroy our homes, our environments and natural surroundings. One can read any magazine these days and see that the Catskills are a tourist destination now. It is ever so popular and has remained that way all during the 2020 Pandemic. Do not let this California based company come and destroy our home! Let them do in in their own backyard... Not ours! Thank you

Other formats

Kayleigh Zaloga, Saugerties, NY.
As a Saugerties resident and frequent hiker and paddler, I oppose the granting of a preliminary license for this proposal. This project is not in the best interest of the people or the environment of the Hudson Valley, and it is so wrong that no local stakeholders have been consulted on it. The Catskill Forest Preserve is beloved and State Constitutionally protected, which should not be taken lightly.

This project would irreversibly harm sensitive ecosystems we have long fought to protect throughout the Preserve, from the powerline right-of-ways to the dams and the powerhouse itself. It will also likely lead to the introduction of even more invasive species. During and after construction, hikers will be denied access to the trails and views that are part of our New York heritage. Many of these hikers will be diverted to other trails that are already struggling under overuse and cannot withstand further ecological degradation. Depending on the location, roads will have to be rerouted, causing even more disruption to people and our forest land.

I support the shift to renewable energy, and we need to do it intelligently. Pumped storage is a net consumer of energy, not a producer of it. It doesn’t make sense to cause all this disruption in an ecologically rich and sensitive area for a project that isn’t actually moving us forward. There is no upside for our forests and waterways in this proposal, and there is no upside for all of us trail users from near and far. At the very least, this proposal needs serious consideration and input from all municipalities affected by it before the FERC grants any preliminary license.

Kimberly Fisher, Beacon, NY.
I am an avid recreational user of the Catskills. I hike and kayak there and love the natural scenic beauty. I'm very upset to learn about this proposal. 

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would also increase turbidity and negatively impact NYC’s drinking water. It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive. The loss of tourist dollars and business revenue would directly hurt our communities. The plan could also limit access to skiing, festivals, and concerts at Hunter Mountain, Hunter, and Tannersville.

Please take all of this into consideration as we urge you to not move forward with this project. Thank you.

Christopher Puleo, Hamburg, NJ.
Hello,

I am writing today to express my direct opposition to the proposed hydroelectric facility that would irreversibly damage areas of the Catskill Forest Preserve.

Premium Energy Holdings of Southern California has proposed a pumped-storage hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Preserve that would have negative impacts on the Ashokan Reservoir and surrounding area. This proposal directly threatens the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, the quality of the New York City water supply, and so much more.

Below is a list of my concerns regarding the proposed facility: 

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would increase turbidity and negatively impact NYC’s drinking water.

It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.

The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

I certainly hope you take all of these concerns into account and arrive at the only logical conclusion, which is to shut down this proposed project. Thank you for your attention to this matter.

Rachel Guinn, Berwyn Heights, MD.
I am writing my concerns regarding the proposed hydroelectric plant at Ashokan Reservoir, submitted by Premium Energy. This proposal should not be considered without input from New York City’s Department of Environmental Protection (NYCDEP), New York State’s Department of Environmental Conservation (NYSDEC), and local leaders and stakeholders. 
If Premium Energy had consulted with the above groups, they likely would not have proposed building the hydroelectric plant in a Forever Wild area. Any amendment to a Forever Wild area should be carefully considered, considering the loss of extremely valuable habitat, species, and water supply protection these lands provide. Additionally, any historic structures in the vicinity of the proposal should be studied carefully and avoided if possible, before the proposal even initially proceeds. 
It seems the Premium Energy has not carefully considered the location of the hydroelectric plant from the onset of the project and does not value the input of local stakeholders. Please hold Premium Energy accountable for providing the state of New York a project that provides clear benefits and considerations to the environment and people.

David A Copperman, Highland Park, NJ.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.

It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt NY communities.

Lindsey Danis, Kingston, NY.
As a local resident who often visited the Catskills and the Ashokan reservoir for recreational purposes, I'm dismayed that an out-of-state company would consider coming into the ecosystem to put up a hydro power storage station. This project will have a negative impact on the local trails, local waterways, nonhuman populations and the quality of life, quite frankly, due to construction impact. There must be suitable locations in California to consider siting this project.

Yuriy Klementyev, STIRLING, NJ.
Hello,
I am frequent hiker in Catskills, when I spend almost every weekend with family and friends. I got myself familiar with the project documentation as well as spoke/read opinions of people familiar with project/technology, including engineers in this field, and I stay against it. I have following concerns and hope that it will be heard:
 - The Catskills are a State Preserve protected by the NY State Constitution.
 - The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
 - The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
 - The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
 - The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
 - This plan would increase turbidity and negatively impact NYC’s drinking water.
 - It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
 - Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
 - The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Brad Barnes, West Shokan, NY.
To Federal Energy Regulatory Commission                                                               April 6, 2021

Re: Project Docket P-15056

Ashokan Pumped Storage Project Proposal

 

The Town of Olive has a great natural beauty that is breath taking to behold. It is shared by all of us, as our greatest source and asset. It should be respected and treated as such. It must be guarded and protected by all of us. In these times, it is more fragile than ever before. It can be easily attacked and damaged beyond repair. This proposal in itself shows this to be true. It is our duty to pass on this great natural beauty to future generations, untouched and pristine. How could a project of this size and scope even be allowed, for consideration as a proposal, within the boundaries of the forever wild blue line of the Catskill Park? How could high voltage transmission lines be allowed in forever wild? No, this must not come to be!

In many ways this project would be very harmful to the Town of Olive. Although it would only despoil this side of the reservoir, the high voltage transmission lines would be quite visible from both the Ashokan dam and dike parks but also the Ashokan rail trail as well. It would also be visible from many mountain top trails! This would be an awful eyesore and distract from our towns’ best attractions. This must not come to be! Therefore I am vehemently opposed to and against this proposed project! It would be a devastating catastrophe for West Shokan and many other places.

As for me, the high voltage transmission lines would pass within a few hundred feet of my home. I would undoubtedly be forced to move away and leave the area, after 50 plus years. My life and this side of the reservoir as I know it will be over. Then as I move south, what then will my house be worth? Somewhere less than half of its current value? This must not come to be!

The benefits of this project to our town and area are little to none. On the balance sheet this is a big negative for us. It is worth far more for us not to have this damaging project, generating electricity for other remote places. The few permanent jobs this would create are not worth it, do not be fooled!

This project is unnecessary as people all over continue to put up more solar panels. Offshore wind would be closer to where this power is needed, with fewer transmission lines. Offshore wind would not be disruptive or ruin mountain views; it would be more gentle and politically correct for these times. Is there really such a shortage of electric power that this must be built within a very beautiful and protected park? Where it is not wanted by the people? I don’t think so, no, this must not come to be.

It is my sincere hope that every person and party in the Town of Olive and everyone in the affected areas of this project will join me in my opposition. Together with everyone who loves and cares and wants this project this special part of our environment, united in opposition to his very bad idea and unnecessary project. Let us all put a stop to this project now before it gains any traction.

Over 100 years ago, against the will of its citizens, New York City caused West Shokan and much of Olive to be forced out and flooded over. Now is an opportune and crucial time for our good friends at the New York City Department of Environmental Protection to protect their reservoir ( by avoiding unnecessary torpidity), and join together as allies with the Town of Olive in opposition to this unwanted proposal.

Everyone in opposition to this project should think about what we can all do to be a most effective force. We must plan to work together, organize and coordinate. We must all fight this tooth and nail! We must stop this misguided and unnecessary proposal. We must stop this project before it starts, and for good. Remember there is so much at stake. We have so much to lose that once blighted we could never get back!

 

With Broken Heart,

Bradley M.  Barnes

West Shokan, New York

 

Re: Project Docket P-15056

Jennifer Costley, Olivebridge, NY.
April 6, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, DC 20426

Docket number P-15056-000

Dear Secretary Bose:
I am writing to request that this application be rejected on the basis that it contains a serious defect. The applicants rely upon the designation of this project as a closed loop system which it is not.
 
Premium Energy Holdings’ Application for Preliminary Permit for the Ashokan Pumped Storage Project states the project would “operate in a closed loop. Aside from evaporation and percolation losses, [the proposal claims] the project’s water would stay within the system.” The Project proposes to use the existing Ashokan Reservoir as a lower pool and a new reservoir in the Catskill Mountains to serve as the upper pool.
  
U.S. Department of Energy's (DOE's) Water Power Technologies Office defines closed-loop PSH as “not continuously connected to a naturally flowing water feature” and open-loop Pumped Storage Hydropower (PSH) as “continuously connected to a naturally flowing water feature.”(1)

The Ashokan Reservoir, which is proposed to be the lower reservoir of the system, receives water from the Esopus Creek.  Although streamflow in the Esopus is altered by diversion of water from the Schoharie Creek watershed to the Esopus Creek through the Shandaken Tunnel, overall, the Esopus Creek continues to be a naturally flowing water feature with estimates of natural discharge reflecting the absence of effects of flows in the Esopus Creek over broad time frames.(2)

Water from the Ashokan Reservoir flows naturally, by gravity, into a system of reservoirs, and ultimately into New York City’s distribution system.(3) Importantly, there is a continuous flow of water out of the Ashokan Reservoir into the Lower Esopus.(4)

Therefore, the proposed lower reservoir for the system is continuously connected to a naturally flowing water feature, the Esopus Creek.  The designation of this project as a closed loop system, a critical distinction in the review process, is defective and the proposal should be rejected on this basis.

Sincerely
Dr. Jennifer L. Costley 

(1) https://www.energy.gov/eere/water/pumped-storage-hydropower [accessed Mar 28 2021]
(2) https://www.researchgate.net/publication/275344137_Estimates_of_Natural_Streamflow_at_Two_Streamgages_on_the_Esopus_Creek_New_York_Water_Years_1932_to_2012  [accessed Mar 28 2021].
(3) https://www.dec.ny.gov/docs/water_pdf/catalumdrafteissec1to4.pdf [accessed Mar 28 2021]
(4) https://waterdata.usgs.gov/nwis/uv?01364500 [assessed Mar 28 2021]

Joshua Weitzner, Stamford, NY.
The Ashokan reservoir is located in the middle of The Catskills state park area.  It is a unique and environmentally fragile location that serves as New York Cities drinking water supply as well as a vital green space in an area of ever increasing urban sprawl.  

The trails, vast forests and fragile ecosystems that would be damaged by this project are seemingly endless. 

As a resident of the Catskills I ask that you deny this permit.

Michael Nassar, New York, NY.
This proposed project is not good for the Catskills.
It was submitted with no input from New York City’s Department of Environmental Protection (NYCDEP), New York State’s Department of Environmental Conservation (NYSDEC), or from local leaders and stakeholders.
•	The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
•	The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
•	The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
•	The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
•	This plan would increase turbidity and negatively impact NYC’s drinking water.
•	It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
•	Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
•	The loss of tourist dollars and business revenue would directly hurt our communities.

Christopher Kirkman, Sandy Hook, CT.
I oppose the hydroelectric facility in the Forever Wild lands of the Catskill Forest Preserve for the following reasons: 
- The Catskills are a State Preserve protected by the NY State Constitution.
- The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
- The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
- The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
- The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
- This plan would increase turbidity and negatively impact NYC’s drinking water.
- It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
- Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
- The loss of tourist dollars and business revenue would directly hurt our communities.
- The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.
Thank you.

Barbara Prete, Olivebridge, NY.
Barbara Prete

1873 County Road 3

Olivebridge, NY 12461

 

Kimberly D. Bose

Federal Energy Regulatory Commission

888 First Street NE, Rm 1A

Washington, D.C. 20426

 

 

April 6, 2021

 

Docket number  P-15056-000

 

Ashokan Proposal to FERC for a Pumped Storage Add-On* Project in the Catskill State 

       Forest Preserve

 

 

Dear Ms. Bose:

 

We all understand the need for electrical power infrastructure, and most of us see the imperative to replace fossil fuels, but must ask At what cost?  The Catskills Park is a critical watershed, a recreation area, and a protected ecological and scenic reserve. Because the proposed pumped storage project will adversely affect this essential watershed and forest preserve, I submit that the cost is too high. Please deny this request by Premium Energy for a preliminary permit.

 

In considering this project, FERC is being asked to bargain with dangerous trade-offs – electricity vs. water safety and security; electricity vs. a vitally important tourism economy.

 

Concerns about Water -

The Ashokan Reservoir System is fed into by the Schoharie Reservoir and Esopus Creek. It is the largest unfiltered water supply in the nation. The Ashokan supplies 40% of New York City water to some 19 million people. With this proposed pumped storage project:

-       The turbidity of the Reservoir is likely to increase, impacting the quality of the water

-       Sediment changes in tributaries to the Esopus will alter sediment in the Esopus proper as well as the Ashokan Reservoir because they are all connected; *this is not a closed-loop project

 

Economic Concern -

Catskill Tourism is integral to the New York State economy.

-      Tourism is a $1.6 billion industry supporting ca 20,000 jobs

-      Tourism generated 17% of employment in the Catskill region in 2019 (and is

                     growing)

 Earth-moving blastings/construction trucks and noise, will be destructive to habitats, jarring to the peace and beauty of the natural environment, thereby eating away at what makes the Catskills desirable and therefore a place people want to visit, live and work.

 

As residents -- whether new, multi-generational, or part-time with second homes outside of New York City, of all ages, incomes, political persuasions, etc. – we are joining together with our elected officials and civic/environmental organizations to prevent this harmful project. We understand that any changes in our State Forest Preserve must be passed by constitutional amendment voted on by two consecutive sessions of the NY State Legislature, and submitted to the public in a referendum. We stand committed to see this battle through, as long as the legal, legislative and lobbying actions may take, but we hope and pray that FERC will join us now in rejecting project P-15056 at an early stage, before years of great cost, litigation and angst.

 

Thank you for your careful consideration of this urgent matter.

 

Sincerely,



 

 

Cc:

 

Congressman Antonio Delgado

 

Senator Kirsten Gillibrand

 

Senator Charles Schumer

 

Governor Andrew Cuomo

 

New York City DEP Commissioner Vincent Sapienza

 

Ulster County Executive Patrick Ryan

 

New York State DEC Commissioner Basil Seggos

 

Catskill Mountainkeeper Research Director Kathy Nolan

 

Coalition of Watershed Towns

Aidan Ferris, Phoenicia, NY.
As a life long resident of the Catskills I am strongly opposed to the Ashokan Pumped Storage Project. This project would ruin what makes this area so special and threatens the integrity of most amazing places. I will not stand by while my  home is under threat and I will do everything it my power to make sure this project does not go forward. These mountains must be protected for generations to come.

John M Carey, GOSHEN, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Elizabeth Ibarra, Palenville, NY.
I am writing in regards to the Ashokan Pumped Storage Project - I am STRONGLY AGAINST this project taking place in any of the three proposed locations. 

As a resident of Palenville, I know that the Catskills are a small mountain range, and there is limited access to the mountaintop. Any dam built, specifically the dam proposal along Route 214, would funnel traffic and human impact onto roads that are already over capacity, drastically inhibiting tourism, which is the biggest industry we rely on in the region. Our infrastructure can not handle any more traffic -  our rivers are clogged with trash, the vehicle traffic is insane, and human impact is severe and needs to be mitigated.

In addition, the NYState constitution clarifies the preservation of the Catskills to be untouched and left as wilderness. In a dissipating “wild” landscape, this is of utmost primary concern. The resources that the Catskills have to offer exceed just tourism, but also provide a sanctuary to the LIMITED natural resources of water, fresh air, and animal life that we all depend on as humans. To impose a dam which would DRASTICALLY change the landscape of a space that is CRITICAL to preserve would be an irreversible and tragic error. It would affect not only the natural ecosystems, but the water supply directly tied to *8.3 million people in New York City*. I don’t think anyone needs to deal with a problem that large on their hands.

Please DENY the permits that would only benefit a for-profit company that does not even operate from within New York State, but from across the country in California. New York’s Catskill Mountains is not a place for extraction of resources, but a delicate mountain range that needs to be left as it is to preserve and honor the current laws in place as well as the protection of the natural landscape and it’s limited resources.

The dam should NOT be built in an environment as fragile as the Catskill Mountains.

Elizabeth Ibarra

Katherine Rodrigues, New York, NY.
To whom it may concern,

I’m very concerned about the proposed hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Preserve that would impact the Ashokan Reservoir. This proposal directly threatens the ecological sustainability of the Forest Preserve, trout breeding grounds, and the quality of the NYC water supply. In addition, it would significantly and negatively impact the use surrounding trails. As an avid trail user, this is very important to me. I strongly urge you to stand with fellow New Yorkers in disapproving this proposal. 

Thank you in advance,
Katherine Rodrigues

Wendy Wolfenson, West Shokan, NY.
Premium Energy’s Ashokan Reservoir Pumped Storage Project

Docket: P-15056

I respectfully request that Premium Energy’s permit application for the above project be denied.
  
There are major factual errors and omissions in Premium’s current application:

1)	In its initial application, Premium incorrectly states, “The lands enclosed within the proposed project boundary are New York State Lands.”  This is simply wrong.  The proposed Wittenberg reservoir is also sited on private residential property.  Premium acknowledges immediately after that “The project layout study boundary…encompasses both federal and private lands.”  There are no federal lands here. By misrepresenting the location of the upper reservoir, which is on numerous parcels of private land as well as State land, Premium hides that taking parcels of private land by Eminent Domain and devaluing numerous residential properties downstream, will be integral to the project.

2)	Premium fails to disclose in its maps or descriptions that the path it has selected for miles of high-voltage, high-tension wires would also be on private property .  This would also involve taking residential property and/or New York City watershed property through Eminent Domain.

3)	Premium wrongly characterizes the project as a Closed Loop project.  This is completely incorrect.  This is an add-on Open Loop project.  The U.S. Department of Energy defines the difference: “PSH capabilities can be characterized as open loop-where there is an ongoing hydrologic connection to a natural body of water-or closed loop, where the reservoirs are not connected to an outside body of water.” (www.energy.gov/eere/water/pumped-storage-hydropower).  This project involves the Esopus Creek, Maltby Hollow Brook and Ashokan Reservoir, all of which are comprised of running water at both ends. Premium’s project fails to qualify as a Closed Loop under any circumstances.  It is evident that Premium has deliberately mischaracterized the project in an attempt to secure expedited processing and to skirt the standard review process.  FERC has sometimes ruled that the distinction between Open and Closed Loop is not grounds for rejection at this stage in the process. In this case, however, the factual error affects the drinking water of 9 million people.  This mistake should be corrected before the applicant can proceed. Furthermore, Premium Energy should not be allowed any expedited permitting or licensing.

4)	Premium failed to notify several relevant municipalities that are clearly impacted by this project.  There was no notification to the Town of Hunter or to Greene County.  There was no identification or notification to the Towns of Marbletown or Hurley (where the high-voltage wires would be built).  These towns have populations of more than 5,000 people.  In its deficiency letter, FERC points out that “the Commission’s regulations require the applicant to identify every city, town, or similar local political subdivision which has a population of 5,000 or more people.”  It is up to Premium Energy, not the responsibility of FERC, to correctly identify and inform these political entities.  The current application is incomplete. Relevant municipalities have not been properly notified.  To say that these municipalities know now, by word-of-mouth, is an inadequate response.

5)	  Premium wrongly identifies the affected body of water on the first page of its executive summary.  Premium lists the “Bush Kill Creek,” in addition to the Ashokan Reservoir.  The actual affected body of water is the “Maltby Hollow Brook.”  Premium does not use the correct name until page 11 of its application.  The difference here is substantial.  The mouth of the Maltby Hollow flows into the Bush Kill.  It is the Maltby Hollow that will be “impounded.”  While it is not wrong to include the Bush Kill, it is incorrect to omit Maltby Hollow Brook.  This is akin to proposing a project in Pittsburgh that would impound the Ohio River, but listing the Mississippi River as the only affected waterway.

6)	Premium Energy failed to adequately answer FERC’s deficiency comment about emergency spillways.   FERC correctly noted that Premium “does not mention any emergency spillways for the upper reservoir. If applicable, please provide dimensions and the general configuration for any emergency spillways.”  All Premium did in its amendment was say there would be a “concrete spillway” without providing any details.  This is an insufficient response. The Wittenberg reservoir is in an area that is so prone to flooding that flood insurance is required as a condition of receiving a mortgage.  Before approval of the permit, Premium Energy needs to specify, at a minimum, the details and dimensions of the spillway, as required in FERC’s letter of deficiencies.  This is especially important because there are many people who live immediately downstream from the dam.

7)	In its deficiency letter, FERC notes that “the scale of (your) maps is not sufficient to show clearly and legibly all of the information. Please revise and submit the maps enlarged to a scale that is adequate for that purpose.”  Premium Energy has again failed to provide legible maps in its resubmission.  All they did was to blow up fuzzy maps that continue to obscure the names of towns, roads and other relevant site information.

Due to the numerous factual errors in its original and amended applications and failure to correct the deficiencies already noted by FERC in its initial response on December 29, 2020, the application of Premium Energy should be denied.  At the very least, Premium Energy should be compelled to resubmit their application, correcting all of the deficiencies. Premium Energy should not, under any circumstances, be allowed to proceed to the next phase based on its amended application dated January 29, 2021.  Moreover, if Premium Energy is given permission to proceed, they should not be allowed any expedited processing.

Wendy Wolfenson 4/6/21

Genevieve Chow, Brooklyn, NY.
I am writing to protest and voice my concerns regarding the proposed hydroelectric project in the Catskills.  My family has been living and enjoying the Ashokan Reserve and surrounding area for over 20 years. It is a treasured piece of 
breath taking beauty, where we have taken hundreds of walks with our children over the years and marveled in the serenity and peacefulness of the land. 
Notwithstanding the devastation and potential damage this project will cause in this beautifully protected areas, there are numerous reasons why this project should not be permitted to move forward, including: 

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

I urge to reconsider allowing this destructive project to move forward as proposed.  Thank you in advance for taking my concerns into consideration.

Shane Caffrey, Catskill, NY.
Hello,
We do not want this proposal to go through.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Thank You, 
Shane

Joe Lauriello, Nyack, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Joe Lauriello

Graham Brown, Westhampton Beach, NY.
To The FERC,

	I’m writing this letter in response to Premium Energy LLC’s proposal to construct a hydroelectric dam within the Catskill Forest Preserve. Although hydroelectric energy is an essential step in shaping a greener and better energy future for our country, this proposal is deeply flawed. It would have dire consequences for the state of New York. 

	The first and perhaps most pressing of these consequences would be the dam’s effect on the Ashokan Reservoir. As it stands right now, the reservoir is protected. But if the dam were approved, it would increase the turbidity and pollution in the reservoir, which supplies drinking water to 40% of New York City residents. It would be a severe moral transgression to put these citizens’ lives and health at risk just as the state is recovering from the carnage of COVID-19. 

	Additionally, in order to construct the dam, private property would have to be taken through eminent domain. This seizure of property would displace our communities that have long called the Catskills home. Thousands of Catskill residents were already displaced once when the reservoir was built; uprooting these communities again would be unjustifiably cruel. 

	And finally, the dam would wreak havoc on the highly prized and preserved forests, wildlife, and ecology of the area. Green energy is the future. But if we have to destroy our world to get there, is the energy truly green at all? 

	Thank you for taking the time to listen to my comments. I hope you find that Premium Energy’s dam does not meet the bar for sustainable green energy and reject their proposal. 

Best regards,
Graham Brown

Cathy Marczyk, Highland Mills, NY.
    The Catskills are a State Preserve protected by the NY State Constitution.     The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails. The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
    The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
    This plan would increase turbidity and negatively impact NYC’s drinking water. It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
    Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive. The loss of tourist dollars and business revenue would directly hurt our communities. The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Nick Orton, Bronx, NY.
It has come to my attention that there has been an application with the intended end of creating a "pumped storage" project on lands that currently serve the public good for residents of New York State.  The land identified for the project is a State preserve protected by the NY State constitution.  The proposed changes will not only threaten local wildlife and ecosystems, but will remove valuable outdoor recreation opportunities from the citizens of the local communities.  Additionally the proposed changes will negatively impact the drinking water which is consumed by myself and my children.  

An organization of which I am a member, the NYNJ Trail Conference, is seeking status as an intervenor.  I would like to register my support for that application as well as register my opposition to the proposal as it stands.

Collin LaFleche, West Shokan, NY.
Hello,

My name is Collin LaFleche. I live in West Shokan NY, on the southern side of the Ashokan Reservoir. My partner and I are here returning the property into a working organic farm, growing vegetables and fruit. Our property would likely be impacted by the infrastructure required for the Ashokan Pumped Storage Project, and so I wanted to submit a comment regarding the proposal.

I am certainly not an engineer, but I am a project manager, and the proposal on its face is incomplete, sloppy, does not approach the overall goals at hand — renewable energy storage — from a thoughtful standpoint, and in the way that the Department of Energy has stated it wants. Specifically, this would be an open-loop project, not a closed-loop project as the DOE has requested. The proposal states this is a closed-loop project, but this is incorrect, as the Ashokan has an outflow on its southeast end.

Secondly, there are likely to be significant legal challenges facing this proposal and project. The state is almost certainly going to object on various grounds. Significantly, any changes to land management for the state forest preserves must be passed by constitutional amendment, ratified by public referendum. Through 1999, 2000 or more amendments were proposed, with only 20 passing.

Most importantly, the project would have detrimental impacts on the land and stream ecologies in the areas surrounding the Ashokan Reservoir, ecologies which are highly preserved. The lands of the Catskill Forest Preserve are protected by the state constitution and may not be leased, sold or exchanged, or be taken by any public or private corporation. The forest surrounding the proposed sites is, according to the New York State Forest Condition Index, among the top 1% of forest habitats in the region. All of the proposed reservoirs are within the Audubon Society’s Catskill Peaks Important Bird Area. Finally, the Catskills are categorized as status 1 land as part of the USGS “Gap Analysis Program,” which means that it should be “avoided for development.” 

Premium Energy appears to be unaware that the project would encounter the above challenges, speaking further to the unseriousness of their proposal.

I urge you to reject Premium Energy’s proposal on the grounds that it is incomplete, inaccurate, and poorly assembled.

Thanks very much for your time,

Collin LaFleche

Alex Todaro, West Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I know you are probably receiving a lot of these but I believe deeply in all of these words below. Please decline the preliminary permit for the Ashokan Pump Storage Project. 

I am writing against the troubling proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alex Todaro

Jason L. Baptiste, Boiceville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
 
Docket number P-15056-000
 
Dear Ms. Bose,
 
The Catskills and the surrounding areas have become my sanctuary in a world that has gone through so many troubling times.  I am all for clean energy, but not at the expense of nature and the environment that it is supposed to protect.
 
I am writing to you, urging you and your team at FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the place I call home. The proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains is incredibly flawed. Bringing this to life would mean destroying an ecosystem, disrupting local communities, and risking the purity of NYC’s drinking water. This idea is not worth the negative long-term cost.
 
Here’s a bulleted list as to why this idea is flawed:
 
Catskill Forest Preserve, wildlife and ecosystem are at risk of being tampered with. Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat. It would be a complete shame to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Pumped storage wreaks havoc on nearby stream ecology and on both aquatic and land habitats. My home is part of the Ashokan watershed and I know how delicate the ecosystem is. Without a doubt of the rough water continuously moving up and doing that it would impair the interconnectedness of the Ashokan watershed and its tributaries.

The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.

Premium Energy’s proposal would be deeply damaging to local communities, which I am a part of. This project would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are not affordable for those that are displaced. 

The proposed project would effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 
The project would impair the connectedness of Rt. 214 between Ulster and Green counties, impacting skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
 
I could outline many more reasons, but overall, this project will directly hurt the environment, local community and even tourism. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.
 
Sincerely,
Jason L. Baptiste

Melissa Stern, Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be an irreversible loss to NYS to destroy this preserved land, and would set a terrible precedent for protected lands across the country.

Once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would have a difficult time securing new housing, as there is currently a huge housing shortage in Ulster County . Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

And finally-  it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

sincerely-
MELISSA STERN

Jessica Simao, Hackettstown, NJ.
I am writing in concern with the Premium Energy Holdings of Southern California has proposed a pumped storage hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Preserve. This facility would have a significant negative impact on the lands by eliminating vital  access to popular trailheads and recreation areas. Closing these areas would put undue strain on the remaining trailheads and would magnify negative ecological impacts seen by increased trail use during the pandemic.  As a trail maintained I am significantly concerned with the negative impact on the various habits and ecosystems that are currently protected as a State preserve by the NY State constitution. The construction of these new dams would irreversibly damage the native flora and fauna which make the state preserve such a treasured place in our community. Furthermore, this project would have a significant impact on tourism and the business revenue which benefits from this. Thank you for your attention to this matter.

Ellen Carl, West Shokan, NY.
As a lifetime resident of Ulster County, I am writing to ask you to deny the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The environmental impact this project would have on the surrounding area, not to mention the potential impact on New York City’s water supply, would be far more devastating than the benefits such a project would have to the electrical grid. 

The project proposes to use private and state land. That state land is part of the Catskill Forest Preserve, which has been designated as “forever wild” under the New York State Constitution. It is “status one” land that the Department of Energy itself says should be avoided for development.

A pumped storage facility, not to mention the years of heavy construction needed to build it, would wreak havoc on the local streams and the surrounding land habitats. It would also displace residents and have a negative impact tourism, which is a major source of jobs in the region.

Even though we undoubtedly need to upgrade our electrical grid in this country and make it more “green,” these kinds of projects do not seem to be the kinds of projects the department should be developing given they are net consumers of energy and not producers. 

Please deny the preliminary permit application by Premium Energy Holdings.

Thank you,
Ellen Carl

Becca Leitman, Willow, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Becca Leitman

Amy Kapczynski, New Haven, CT.
April 6, 2021

Re: Docket number P-15056-000, Premium Energy Proposed Ashokan Pumped Storage Project 

Dear Commissioners, 

I write in strong opposition to the proposed pump storage project in the Ashokan Watershed and Catskills State Preserve.  Pumped storage makes sense in very particular settings, but this is not one of them.  The ecological disruption that would be caused by this proposal, which is not a true “closed loop” system, is immense.  The real and unwarranted risks to the area include:

-	Risks to the purity of New York City’s water supply.  The Ashokan provides 40% of that supply, and would take billions of dollars to replace.

-	Disruption of the local habitat and fisheries.  Pumped storage creates major fluctuations in water levels and alters stream sediment, harming local fish and recreational fishing.

-	Damage to the Catskills Preserve.  The preserve is pristine and considered Status 1 under the USGS Gap Analysis Program. These are to be avoided for development, according to the DOE’s own Hydropower Vision.  The proposal would inundate more than 200 acres for the reservoir and associated roads, dam and other infrastructure.  This would lead to carbon loss, and irreversibly impact local wildlife.  

-	Disruption of the local community.  The project would inundate much of Woodland Valley and do significant damage to tourism in an area where much of the local economy is tourism-dependent.

I support clean energy, and strongly support proposals to introduce real green energy in sensible ways.  But this cannot be the way that we green the economy.  There is nothing suitable about this setting, and we will do grave damage to the political will needed to really bring green energy about if we contemplate proposals like these.

Amy Kapczynski


New Haven CT and Woodland Valley Road, NY

Tayler VanNosdall, WOODLAND PARK, NJ.
To Whom It may Concern,

  The following project proposal of a Hydroelectric Plant on Ashokan Reservoir will have long lasting negative impacts for the local environment of the Catskills area. I am all for eliminating greenhouse emissions, however not at the expense of the local community. Not only will the people living nearby be at risk for possible flooding, but the habitat of the dam and land will be greatly impacted too. During the warmer season, I enjoy taking time away from the chaos of the world and going into nature whether it be hiking or fishing (catch & release). If this hydroelectric plant were to be built, hiking in that area would slowly decrease along with the fishing which will eventually also affect the feeding cycle of the ecosystem. During the colder season, I find myself enjoying winter activities at Hunter mountain. If the dam were to be built it'll impact the mountain as well. I vacation up frequently at the Catskills and enjoy the solitude the area has to offer. I am from the NJ/NYC area, if this dam were built not only would my vacation spot be greatly impacted, my hometown tap water would also be greatly impacted. Please reconsider your proposal to help maintain the sacred and already stable environment of Ashokan Reservoir. Thank you for your time. 

Regards, 
Tayler VanNosdall

Lorraine A Salluzzi, Lanesville, NY.
Lorraine A Salluzzi 516-708-5213

I vote NO 

This action will impact highly preserved land

It will destroy our streams and the ecology of our streams creating filth and destruction 

The NYC water will become muddy and filthy and unhealthy

We rely on our waterways for tourism +, Catskills tourism will be destroyed !  We will experience No employment and no money for the people who live here and rely on tourism.

This is not the proper innovation that the Dept of Energy would want !


We say NO to this proposal
Thank you 
Lorraine Salluzzi

Susan O'Neill, Westbrookville, NY.
I am concerned about the effects on flora and fauna caused by habitat fragmentation, introduction of non-native, invasive species caused by powerline clearing, and the degradation of drinking water.

Delia O'Donnell, Wallkill, NY.
I enjoy visiting the Ashokan Reservoir and surrounding Catskills and am extremely concerned about the impact of this project. 
This land is part of a state preserve protected by the NYS constitution and the proposed project will permanently damage the its ecosystem. 
These areas are also used by New Yorkers to hike, ski, boat, fish, and more. 
Please protect these lands.

Richard Rawson, East Jewett, NY.
Re:  docket number P-15056-000
My partner and I live in Greene County and frequently travel through Ulster County and take advantage of recreational opportunities at the Ashokan Reservoir.  Our closest friends have lived in West Hurley for 30 years.
I oppose the proposal put forward by Premium Energy to FERC to study the feasibility of a massive program that will disrupt the Catskill State Preserve.
My principal concerns include: 
--the disruption to the lives of residents uprooted by the process of eminent domain
--ecological impact and threat to NYC drinking water due to increased turbidity in the Ashokan Watershed
--the Catskills are a State Preserve protected by the NY State Constitution (“shall be kept forever wild”)
--loss of recreational opportunity 
--Premium Energy’s fundamental justification of project as “closed loop” when in fact the upper reservoir component is clearly an “add-on”.  This is dishonest on its face.
Please deny Premium Energy’s request to proceed with a feasibility study.

Lisa Mansback Berk, Vestal, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Submission Description: (doc-less) Motion to Intervene of Peter Friedel under P-15056-000.

Submission Date:        4/6/2021 7:54:24 PM

Filed Date:             4/7/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               pfriedel9395@gmail.com                                                           

Basis for Intervening:
April 1, 2021

Kimberly D. Bose, Secretary 
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A, 
Washington, DC 20426

Re: Docket P-15056-000
MOTION TO INTERVENE of Peter Friedel for the Premium Energy Holdings, LLC, Project No. 15056

Dear Secretary Bose,

This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. Therefore, Peter Friedel is filing a motion to be an intervenor and meets the requirements of 18 CFR 385.214 of the Commission’s regulations to grant them full party status.

The basis for intervening is due to the proposed location of the project which encompasses the private property where one of the proposed site projects would be located- Wittenberg Reservoir/Dam. Hence, Peter Friedel along with his children will lose and not have access to their land as well as to their home which leads them to have substantial interest in the matter, since the property is their primary residence which is located on 55 Friedel Drive that is directly off Moonhaw Road, West Shokan, NY 12494. 

Peter Friedel respectfully request that the Federal Energy Regulatory Commission grant this motion to intervene.

Respectfully,

Peter Friedel
PO Box 35
55 Friedel Drive
West Shokan, NY 12494

Submission Description: (doc-less) Motion to Intervene of Michael Dean under P-15056-000.

Submission Date:        4/6/2021 9:08:48 PM

Filed Date:             4/7/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               mikedean.10987@gmail.com                                                         

Basis for Intervening:
I am a private landowner and my land is sited in Lanesville in the immediate vicinity of the potential Lanesville upper reservoir site.  My use, enjoyment of and the value of my land will be directly negatively impacted by the proposed Lanesville reservoir.

Submission Description: (doc-less) Motion to Intervene of Ellen Carl under P-15056-000.

Submission Date:        4/6/2021 9:42:32 PM

Filed Date:             4/7/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               ellencarl24@gmail.com                                                            

Basis for Intervening:
April 6, 2021
 
Kimberly D. Bose, Secretary 
Federal Energy Regulatory Commission 
888 First Street, NE, Room 1A, 
Washington, DC 20426
 
Re: Docket P-15056-000
 
MOTION TO INTERVENE of Ellen Carl for the Premium Energy Holdings, LLC, Project No. 15056
 
Dear Secretary Bose,
This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. Ellen Carl is filing a motion to be an intervener and meets the requirements of 18 CFR 385.214 of the Commission’s regulations to be granted full party status.
The basis for intervening is due to the proposed location of the project (Wittenberg Reservoir) would mean that I would lose my home and access to my property. Therefore, I have substantial interest in the matter. I reside at 39 Shultis Lane, directly off Moonhaw Road, West Shokan, NY 12494.
 
Ellen Carl respectfully requests that the Federal Energy Regulatory Commission grant this motion to intervene.
 
Sincerely,
Ellen Carl
PO Box 125
39 Shultis Lane 
West Shokan, NY 12494

Shannon O'Keefe, Olivebridge, NY.
As a resident of Olivebridge, where Premium Energy Holdings company is requesting to put in a large dam, reservoir, turbine, and tunnels for the use of pumped storage and generation of electricity, I vigorously object to the proposal. The proposed project is massive, intrusive, and will likely damage local lands, roads, and streams. Our land is valuable and important to us. While we understand the importance of green energy, destroying parts of our town is not the way to achieve this. Please do everything in your power to prevent this proposal moving forward. Docket number P-15056-000

Michael J DAnniballe, HOPEWELL JUNCTION, NY.
This am awful idea. Allowing an out of state company to come into a protected area and disturb it, the local residents and the local balance of nature.

It's unbelievable that we even have to comment on this issue, you already know it's not in the best interest of New Yorkers.

dana cohen, Philadelphia, PA.
Dana Cohen
5823 Ashland Ave.
Philadelphia, PA 19143

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Though I live in Philadelphia, my mom and many other close family and friends live in the Catskills region and I visit often. The project they are proposing, the Ashokan Pumped Storage Project P-15056, would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. Because of this I urge FERC to decline their request for a preliminary permit.

I know that pumped storage and hydroelectric projects will play a key role in our country’s transition to renewable energy, however the forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a travesty to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats because of the rapid fluctuations of the large mass of water in the upper reservoir as it is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. 

The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Dana Cohen

Lara Cely, Montclair, NJ.
I'm writing to oppose this application for a large and poorly conceived “pumped storage” project. It would draw from the existing Ashokan Reservoir, plus a newly created dam and reservoir at one of three alternative sites near the Ashokan.

The Catskills are a State Preserve protected by the NY State Constitution. The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the natural areas and have significant impact on the streams, affecting fishing, boating, and swimming.

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs. This plan would also negatively impact NYC’s drinking water.

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.

In conclusion, I oppose this proposal because it directly threatens the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, the quality of the New York City water supply, and so much more.

Adam Sternin, Hunter, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am a resident of Hunter Township, NY and live about 5 miles from the proposed Damming of Route 214 as indicated in the proposal from Premium Energy Holdings new hydroelectric project based in the Catskills Preserve. I would like to include my voice of opposition to this proposal. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank You for adding my voice of opposition;  my personal concerns and my community concerns to this process.
Best Regards,

Adam Sternin
Hunter, NY 12442
646-543-9011

William Kuipers, Haskell, NJ.
I am writing to express our strong opposition and heartbreak concerning the proposed development of a hydroelectric plant at the protected Ashokan reservoir in the Catskills.  The Ashokan and surrounding area is a true jewel among NY States natural assets, and is a treasured resource not just for New Yorkers but from visitors from surrounding states as well - all bringing money and jobs to the area.  The hydroelectric plant would cause catastrophic and permanent damage.  It is unimaginable to me how the PROTECTED status of such a precious resource can so easily be brushed aside.  Please use the full influence of your office to prevent this environmental nightmare.  

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.

Hugh Cushing, South Orange, NJ.
The Catskills are a State Preserve protected by the NY State Constitution.

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience.

This plan would increase turbidity and negatively impact NYC’s drinking water.

It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.

The loss of tourist dollars and business revenue would directly hurt our communities.

The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Susanna Margolis, New York, NY.
Deeply concerned about pumped-storage hydroelectric project prosed by Premium Energy Holdings in the heart of the Catskills region. I am a longtime trail user, onetime fisherwoman, and nearby homeowner. Some things just deserve being preserved: the Ashokan watershed, the streams that feed it, the trails that enable people to walk it, the wildlife and human lives that derive essential sustenance from it are among those things. The state and the public have already safeguarded the area in legislation. Please don’t mess it up.

Submission Description: (doc-less) Motion to Intervene of Howard Altarescu under P-15056-000.

Submission Date:        4/7/2021 8:42:00 AM

Filed Date:             4/7/2021 8:42:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               haltarescu@gmail.com                                                             

Basis for Intervening:
I hereby submit a motion to be an intervenor in connection with FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA.

I am a resident of West Shokan, New York, and am concerned by the application made by Premium Energy to construct a hydroelectric power plant in the vicinity of my home and in the vicinity of the natural resources of the Catskills, which I and my family use and enjoy and which are tourist attractions that create sorely needed revenues for the local community.

Keri Toye, Poughkeepsie, NY.

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Keri Toye

Mary Anne Malkine, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
Sincerely,
Mary Anne Malkine

Kaylee Knowles, Brooklyn, NY.
I am writing to express concern about the environmental impacts that would be caused by this proposal to build a new hydroelectric dam in the Catskills. Dams and construction of dams have an overwhelmingly negative impact on native flora and fauna, disrupting the ecosystems of precious wildlife in the area. Additionally, building on the Ashokan reservoir will negatively impact the drinking water that comes from there, particularly in NYC where I live. I believe it is important to protect our natural resources and wildlife, and that the permit application for this hydroelectric dam should be immediately denied.

Amber Ray, Warwick, NY.
I am writing in reference to docket P-15056. I am a concerned resident of New York State who is extremely disappointed that such an ill-conceived proposal would be submitted for a preliminary permit. No input from stakeholders was solicited. This proposal would destroy the unique and vital open space of the Catskill Forest Preserve, which is protected by the New York State Constitution because we believe in the importance of healthy ecosystems and nature for the wellbeing of all people. My objections to the proposed project are as follows:
•	The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
•	The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
•	The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
•	The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
•	This plan would increase turbidity and negatively impact NYC’s drinking water.
•	It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
•	Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
•	The loss of tourist dollars and business revenue would directly hurt our communities.
•	The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.
Sincerely,
Amber Ray

Helen Toomer, Kingston, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Helen Toomer

Susan Johnson, Croton on Hudson, NY.
I am appalled that the Premium Energy Holdings of Southern California has supplied documents without input from the NYCDEP and the NYSDEC concerning the impact of their plans on the area around the Ashokan Reservoir. Water, land, people and wildlife in protected areas will be adversely affected.

 I am a resident of Croton on Hudson, a  neighbor of one of NYC's reservoirs, and a hiker, canoer and visitor of the wonderful parks and rivers in the Ashokan Reservoir area. I have enjoyed this area since the late 1990's. I do not want to see the Forever Wild lands polluted,  and disrupted by noise, or have a loss of contiguous wildlife corridors.  I do not want the Catskill Forest Preserve violated by these things either.  I do not want an out of state entity having legal control over NY State's and NYC's water supply.  As my area is contiguous to the New Croton Reservoir and Croton Aqueduct this is personal.

I request that all agencies, municipalities and non-profits currently filing for intervenor status  get 
their chance to submit relevant data about the effect of these plans on the environment. I request that the comment period be extended for another 3 months. 

Thank you,
Susan Johnson

Eric Romano, Kingston, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Eric Romano

Kristianna Segura-Hall, Brooklyn, NY.
EW YORK-NEW JERSEY TRAIL CONFERENCE
Proposed Hydroelectric Plant Threatens Catskills' Ashokan Reservoir


The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

Travis Weber, Glen Spey, NY.
I am extremely disappointed to have recently learned about the proposed dam near Ashokan reservoir. As a resident of the southern Catskills and frequent visitor of all parts of the Catskill region I have to voice my strong opposition to this project for all the reasons I have outlined below.

• The Catskills are a State Preserve protected by the NY State Constitution.

• The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

• The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.

• The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience.
 
• This plan would increase turbidity and negatively impact NYC’s drinking water.

• It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.

• The loss of tourist dollars and business revenue would directly hurt our communities.

• The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Samara Prywes, NEW YORK, NY.
I am writing to express deep concern over the proposed hydroelectric plant at Ashokan Reservoir.

The Catskills are a State Preserve protected by the NY State Constitution.

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will SIGNIFICANTLY AND PERMANENTLY DAMAGE the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and MAGNIFY NEGATIVE ECOLOGICAL IMPACTS that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also UNNECESSARY RISK OF INTRODUCTION OF INVASIVE SPECIES into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 

The lands and waterways supporting native flora and fauna that are synonymous with the Forest Preserve would be IRREVERSIBLY DAMAGED and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would increase turbidity and NEGATIVELY IMPACT NYC'S DRINKING WATER.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be INCREDIBLY DISRUPTIVE.
The loss of tourist dollars and business revenue would directly hurt our communities.

The plan could also limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

David Andrews, WEST SHOKAN, NY.
To whom it may concern,

As president of the High Point Neighbors Association located in West Shokan, NY, I call on FERC to stop the hydroelectric plant proposed by Premium Energy Holdings. 

I list below our initial objections to the granting of a Preliminary Permit by FERC. We feel strongly that the location, and the project overall, is not suitable or viable. Here’s why:

LEGAL ISSUES
-The are falls under Status 1 of the USGS Gap Analysis, and therefore not eligible for development.
-NYS has already expressed severe concern about this project, and it is expected that legal objections to this issue may well elevated to the Supreme Court, increasing costs for all concerned.
-The developer has been dishonest from the onset - the project is NOT closed loop, but an add-on project which is not what the DoE really wants to promote.
-The local area constitutes 700,000 acres of forest habitat and is among the top 1% region wide.  Under Article XIV of the NYS constitution, the lands “shall be forever kept as wild forests lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private”.

ECOLOGICAL ISSUES
-There are several protected species that will be dramatically damaged by development of this size and impact.
-The impact on the land and streams will be significant. A DoE 2013 study found that rapid fluctuations in water levels (which this project would create) “wreak havoc on the ecologically rich areas where terrestrial and freshwater ecosystems overlap.”

SUITABILITY ISSUES
-Hydropower seems to be a net producer of greenhouse gasses overall - true, it reduces gasses from fossil fuels, but reservoirs create methane. The forrest area that would have to be cleared to create the project currently serves to reduce pollution, and this would be lost.
-This is a shortsighted solution from a location point of view, due to uncertainly in the climate here with the potential of a much reduced snowfall and therefore runoff.

FINANCIAL ISSUES
-Local tourism constitutes a major component of the local economy, and due to recent new hiking trails, this is increasing dramatically. This project would irreversibly reduce that revenue and therefore economically damage an area of the State that is already under pressure.

CULTURAL ISSUES
-Although we realize that FERC is not mandated to consider the human impact of proposed projects, I would be remiss if I did not mention that the area’s cultural cohesion was devised when the original Ashokan reservoir was constructed, mostly due to the use of eminent domain to obtain land, and the fragmentation of all the towns that were moved to outlying areas. The through the this will happen again would most probably create a major backlash in the area.

I appreciate your time in reviewing this letter and ask that you take into consideration when reviewing the application.

David Andrews
President:  High Point Neighbors Association


About the Association.
The association was created in 2017 by a group of West Shokan Residents, specifically to stop the use of one of the most scenic local residences as a wedding venue. The association was able to galvanize local activists, harness substantial legal funds and implement a multi-faceted public campaign. These efforts were a resounding success as the wedding venue application was subsequently dramatically restricted and no longer operates.

Peter Reiner, New City, NM.
I live in New City New York.

       I am contacting you regarding docket P-15056 proposed hydro electric facility in the Catskill region of New York. 

      The Catskills are a State Preserve  and are protected by the NY State Constitution. The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

      The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources.

      The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species.

      I am also opposed because the lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve and would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience in this area.
      It would cause a significant impact on the streams, affecting fishing, boating, and swimming. The rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
For these and other environmental and economic reasons I am opposed to the approval of this project in the Catskill region.

Skip Blumberg, NYC, NY.
I am a frequent visitor to Stony Clove, Greene County, NYS, having lived there for 6+ years in the 1970s, and now reside in New York City, including as President of Friends of City Hall Park.  

I vehemently oppose flooding the valley, and oppose a proposed feasibility study for same. 

Although I support renewable energy production in general and specifically for New York City, it should not be accomplished at the expense of the rare natural environment. 

You must understand that this valley has likely the cleanest air, is quietest and contains the most natural environment within 100 linear miles of NYC. This is natural land preserved to “be forever kept as wild forest lands.”

Those of us who depend on this respite from hectic urban life rely on this valley for the experience of nature, and even knowing that it’s there. 

It would be a devastating loss to not have this valley available to my family and me. 

Losing the tourist destination will demand seeking another convenient alternative… in New Jersey or Massachusetts... or further, discouraging frequent visits and diminishing my quality of life.

It would also tragically destroy important sentimental memories of my earlier life.

I IMPLORE YOU: PLEASE DO NOT PROCEED WITH A FEASIBILITY STUDY THAT WOULD CLARIFY THE VIABILITY OF FLOODING STONY CLOVE!

Caroline Baillie, Hankins, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
April 5th 2021

Dear Ms. Bose,

I am writing in response to the problematic proposal by Premium Energy Holdings to build a hydroelectric pumped storage plant in New York’s Catskill Mountains. I recommend FERC decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, and I would like to provide my professional reasons for supporting this position. 

I am a materials engineer, an engineering professor, and I run a not for profit (501c3) organization on environmental education, forest school and waste recycling. I am also a local resident and enjoy the beauty of the Catskills. My area of specialization is to consider the social and environmental impact of what engineers do, and I will adopt a similar framework to address my concerns about the proposed hydro pump storage plant, through this letter. It is clear to me and I hope to the readers of this letter, that the negative impacts far outweigh the positives overall, and that we must look closely at who benefits and who pays the cost of these negative impacts in the long term. Who pays the price for the benefit of those who gain?

The idea of pumped storage energy is ostensibly an elegant solution to the need to store energy in areas of weak or changing supply. If done well, and with no negative environmental impact, it would add immeasurably to the suite of tools and facilities currently being developed in support of a just transition away from fossil fuels, so critically necessary in our consideration of climate change and sustainability of resources. 

However, if we look at the potential negative impacts in this case we can see that these are many and they are unevenly distributed. In Table 1 (inspired by the brilliant Ursula Franklin and her ‘Real world of technology’ book by Anansi Press, 1995) a + or - sign is where there is an expected positive or negative impact, either socially, environmentally or economically. Each stakeholder group is taken separately. This table is not complete (there may be stakeholder groups not included) but the categories within serve to support the points being made in this letter. The only group to benefit long term from this project are a private, profit making Californian company. Tourism (with its associated health benefits and local jobs), NY water supply, local residents (who have been fighting the injustice of eminent domain for years), residents within the broader area (who visit the Catskills regularly for leisure and sport), the fauna and particularly the fish, the flora and the entire ecosystem will all pay the costs and suffer the neglect of an adequate and considered approach to solving the challenge of energy storage. This all despite the fact that under Article XIV of the NYS Constitution, it is clearly guaranteed that lands which include the Catskill Forest Preserve “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 


Type of impact	social	economic	environmental 

Stakeholder 		
		
Local residents	-ve	         -ve	               -ve

Flora and fauna 				               -ve

NY citizens 		-ve	         -ve 

(turbidity in water - possible tax increase to clean water)	

Premium Energy	+ve	         +ve	

Tourists		         -ve		                        -ve

DEP  		         -ve 	  -ve.                -ve

(reputation, cleaning costs, environmental damage)

Residents of broader area		
                                  +ve/-ve    -ve/+ve        -ve

(+ve possible if less power cuts 
-ve damaged local environment 	-ve tourism job losses long term 
+ve jobs in short term for the project)


Table 1 Who pays and who benefits? (The Table does not format well in this comment but I'd be happy to provide it in another format as required.) 


There are two critically important points to reinforce relating to the above. Premium Energy’s Ashokan Pumped Storage Project claims to be a closed-loop pumped storage projects which has a smaller environmental impact than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval (although closed loop still has its problems). However this is not technically accurate. The system is not closed from local water supply – as the Esopus river runs into the reservoir. Furthermore, the water is drawn from the reservoir for the NY city water supply, which will experience hugely increased turbidity due to the changed water levels. 

I strongly urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. But in addition I would stress the importance of not simply pushing the project further onto other at-risk lands. The company, and others who use this technology needs to do due diligence and research the impacts using independent researchers, to find a solution to the issue of energy storage which adopts the same elegant solution but without creating harm to the environment it had been designed to save. For centuries we have created solutions which seem to be the panacea at the time and only later have we discovered the profound damage that we have caused. Let us set a new pathway where we care for our common home. 

Sincerely, 
 
Dr Caroline Baillie, Professor, Shiley-Marcos School of Engineering, USD and director of Waste for Life/Forest Exploratorium Sullivan County, NY. 
Acknowledgment: With thanks also to Mark Baillie , Civil Engineer, Fellow Institute of Civil Engineering

Amy A Monahan, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

As a local resident and active user of the Ashokan Reservoir, I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Amy Monahan

Matt Hill, Catskill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Matt Hill

Sherry F. Adams, Boiceville, NY.
April 7, 2021


To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing today to urge you and your team at FERC to decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The information that has been made available indicates that this reservoir project and dam construction would be devastating to the place I call home. The proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains is incredibly flawed. Bringing this to life would mean destroying our fragile ecosystem and disrupting local communities. I live in a home that was originally located in what is now the Ashokan Reservoir. The displacement of homes and people in this current climate would breed toxicity. I fear that this initiative will reignite the historical tension between the local community and the tourism that supports our area and provides NYC’s drinking water. This idea is not worth the negative long-term cost.

Here’s a bulleted list as to why this idea is flawed:

•	Catskill Forest Preserve, wildlife, and ecosystem are at risk of being tampered with. Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of wildlife habitat. It would be irresponsible to destroy this sacred and wonderfully preserved land and would set a doomed precedent for protected lands across the country.
•	Pumped storage wreaks havoc on nearby stream ecology and on both aquatic and land habitats. My home is part of the Ashokan watershed, and I know how delicate the ecosystem is. The redirection of water would impair the interconnectedness of the Ashokan watershed and its tributaries.
•	The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.
•	Premium Energy’s proposal would be deeply damaging to local communities, which I am a part of. This project would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are not affordable for those that are displaced. 
•	The proposed project would negatively impact the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 
•	The project would impair the connectedness of Rt. 214 between Ulster and Green counties, impacting skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

I could outline many more reasons, but overall, this project will directly hurt the environment, local community, and tourism. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.

Sincerely,

Sherry F. Adams

michael duva, brooklyn, NY.
To whom it may concern ? 

I have friends who live on and just off the road proposed for imminent domain. 

I am a huge fan of summer and winter and fall and spring Hunter area. 

It would be ludicrous to do the proposed, and quite frankly insulting that it is even a thought, no less a possibility. 

Drinking water, existing houses, one less route of ONLY two, that almost all  use to get to Hunter mountain via Thruway.  

I am a tourist to the area. 

I Visit the BEAUTIFUL park along that road. 

THAT ROAD is what makes Hunter area beautiful to arrive at.  and leave from.   One of the few useful and scenic roads to get to and leave Hunter. 

To go into Phonecia.  What about visits to Phonecia ? 

Ludicrous idea.

Don't do this folks.

I am for clean energy very much, but a responsible approach to clean energy, this is not. 

michael duva

James Stracka, Elka Park, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
James Stracka

Daniel Herscovitch, Philadelphia, PA.
I am an avid hiker, skier, and backpacker living in Philadelphia, PA.  Every year and in every season, I make the trip up to the beautiful Catskills to enjoy these activities.  When I am there, I also enjoy stopping in the local towns such as Woodstock, Shandaken, Hunter, and Tannersville, to name a few. 
 Needless to say, while I am visiting, I am also spending money.  I am firmly opposed to the proposed hydroelectric project as it threatens the viability of these activities in the area.

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.
 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.
 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience.
 
This plan would increase turbidity and negatively impact NYC’s drinking water.  It would cause a significant impact on the streams, affecting fishing, boating, and swimming.

Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt the local communities.

The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Please do not allow this project to move forward.

Sincerely,
Daniel Herscovitch

Eelco Kessels, Beacon, NY.
This project is flawed. The Catskills are a State Preserve, protected by the NY State Constitution for good reason. This project will negatively impact NY's drinking water, detrimental to our downstream communities, and disrupt the economy and displace residents.

Sara Chapman, Astoria, NY.
I am a lifelong resident of New York State, born and raised in Poughkeepsie, NY and currently living in Queens. I grew up camping in the shadows of the Catskills and the Adirondacks, and because of the public health crisis, I was fortunate enough to spend a significant period of time in the Catskills enjoying the great outdoors and spending much needed money in the local economy at small businesses and in the hospitality industry, which has suffered greatly due to the pandemic. I write today to express my dismay and opposition to the proposed Ashokan dam, docket P-15056. This plan, submitted by a west coast energy company, threatens the local economy and ecosystem of the Catskills. It will obstruct views, damage hiking trails, force road closures to valuable recreational areas and impact NYC’s drinking water. Historically, the Catskills was a summertime retreat for NYC residents back when people used the word “summer” as a verb. Over the years, as air travel became more popular and affordable, the Catskills fell out of favor and communities became blighted. That began to change recently, and with the influx of New Yorkers seeking a natural respite to their quarantined lives, communities are beginning to thrive again. This plan would erase that progress by discouraging continued tourism after the pandemic and threatening ski resorts. This plan, submitted with NO input from local regulators or stakeholders, will relegate burgeoning towns back to poverty and squalor. It will force naturalists into other areas like the Poconos and the Berkshires, pumping money into the economies of neighboring states instead of New York while profits from the project are enjoyed in California. The project will have negative environmental consequences as well. It will invite invasive species and interrupt fish breeding grounds. It will require clearing out sensitive vegetation. These are negative impacts that have long-term consequences on the environment. The positive impacts of this proposal are largely going to people in California while New Yorkers are left with an industrial plant ruining a nature preserve so important to our state that it was written into our constitution. New York has suffered greatly as a result of the pandemic. Many people left New York and will not return. The long-term impact of the pandemic is that people will be able to live anywhere they chose because they’re not tied to physical offices. Employment opportunities will no longer suffice to attract people to live in New York, and our tax base will shrink as a result. So will our numerical power in future censuses. If we want to keep New Yorkers in the state and continue to entice residents to spend locally, we must maintain local resources and recreation areas. I urge you to deny this project and preserve America’s First Forest for generations to come.

Michael Ogushwitz, Bloomfield, NJ.
I am strongly opposed for the following reasons:
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

This plant must not be approved.
Thank you

Katherine Levy, PHILADELPHIA, PA.
The Catskills are a State Preserve protected by the NY State Constitution. The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.

The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic.

The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 

This plan would increase turbidity and negatively impact NYC’s drinking water,  and cause a significant impact on the streams, affecting fishing, boating, and swimming. Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive, and the loss of tourist dollars and business revenue would directly hurt our communities.

Growing up in New York State and still visiting the state frequently, it's so critical to me that our natural resources and communities are protected. 

This project cannot go forward, should be opposed, and should not be allowed.

Bruce Monger, Lansing, NY.
I am writing in response to the flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it poses an unacceptable risk to the disruption New York City’s drinking water. 

I have heard the concerns of some folks about the possibility of enhanced water column turbidity from this proposed project, but my concern is with the potential of nutrient loading that has the potential to stimulate the outbreak of harmful algal blooms (HABs).  Given that New York City receives 40% of its water from the Ashokan Reservoir, it is imperative that the “Precautionary Principle” be invoked in this case.  Given the extreme catastrophic outcome should the waters Ashokan Reservoir become poisoned with HAB bloom toxins, the developer should be required to prove “with an extreme certainty” that HAB outbreaks would never occur.  This is a tall hurdle for the developer, but absolutely required in this case.  The HAB outbreak in the waters feeding Toledo Ohio in 2014 provides a clear word of caution for what HAB toxins can do to a public waterworks that serves a large metropolitan city.

Given the likelihood that the volume of upper reservoir will vary dramatically on a diel basis, it seems possible that in addition to resuspending bottom sediments, the process might also resuspend plant nutrients.  HABs, and associated toxins, could subsequently develop in the upper reservoir and be sent to the Ashokan and/or the suspended plant nutrients could be sent down to the Ashokan Reservoir, to stimulate HAB outbreaks directly.  This issue needs to be seriously addressed in my opinion. 

Sincerely, 
Bruce Monger
PhD Marine Science

Joshua Noreuil, stirling, NJ.
I am opposed to granting this permit.  The catskills is a beautiful and pristine wilderness that should be left untouched.  I often go hiking there with my family and it is a welcome change from the scenery along the Hudson, which is too often defaced by man man structures such as abandoned mines and power plants.  This proposal directly threatens the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, the quality of the New York City water supply, and so much more, including, but not limited to:

    -The Catskills are a State Preserve protected by the NY State Constitution.
    -The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
    -The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
    -The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
    -The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
    -This plan would increase turbidity and negatively impact NYC’s drinking water.
    -It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
    -Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
    -The loss of tourist dollars and business revenue would directly hurt our communities.
    -The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Thank you.

Liz DeCecco, Valhalla, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Liz DeCecco

Eileen McInerney, West Caldwell, NJ.
April 7, 2021

Dear FERC:

	I am writing in regards to docket P-15056. Please do not approve Premium Energy Holdings of Southern California’s proposed pumped hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Reserve as it would have negative impacts on the Ashokan Reservoir and the surrounding area.

	The Catskills are a State Preserve protected by the NY State Constitution, and should be kept protected. This project endangers the water supply of NYC, would ruin the beautiful experience of visiting the area leading to a loss of tourist and business revenue for the nearby communities, and open the area to the unnecessary risk of the introduction of invasive species into the Forest Preserve during construction. These are but a few of the foreseen problems with such a massive construction project in this beautiful area. 

	I had the pleasure of walking the Ashokan Trail for the first time last fall with a friend. It was beautiful, and to think it might be threatened is disconcerting, to say the least. There were so many people walking the trail, enjoying the beautiful day in a beautiful setting. 

	Please do not say yes to Premium Energy Holdings of Southern California. New York State does not deserve this. 

	Thank you for your attention.

Sincerely,

Eileen McInerney, MD

John O'Connell, Phoenicia, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First Street
Washington DC 20426

Docket P-15056-000

Dear Ms. Bose

I am John O'Connell. I have lived at 945 Woodland Valley Road, Phoenicia since July, 1977.

I am writing to you to urge you to reject the deeply flawed proposal submitted by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains.

First, may I quote Victor Rojas, the President of Premium Energy, whose firm has submitted this flawed proposal

"The Ashokan project will be built only with the cooperation of the community. We don’t want to harm or damage nothing or no one. It looks like the first choice of upper reservoir was a bad choice. There is a community in that location. This site alternative therefore will not be any longer pursue it." 

"Also, since this reservoir belongs to the city of New York, if the city of New York deems this project not safe for the integrity of the water supply to the City, this project will not happen. Nothing will be done without the consensus of all stakeholders."

As of this moment there has been no communication with stakeholders. NONE

Technically I urge that the project must be rejected because

1. The proposed site is on designated Status 1 land, and federal policy explicitly directs that Status 1 and 2 land areas are highly protected and must be avoided for development. This proposal would demand a Constitutional Amendment passed by the NYS Legislature and signed by the Governor. This barrier alone is sufficient to stop the proposal, in its tracks, at this very moment.

2.The proposed project will severely disrupt and increase turbidity in the Ashokan Reservoir and surrounding streams, which serve as a primary source of unfiltered drinking water for 9 million New York residents.

3. The flawed application misrepresents its project as a “closed loop” design. In truth, it is an “add-on” design with worse environmental impacts.

4.The project raises numerous legal issues regarding States’ rights and land reservation.

5. The proposed site is home to protected species of wildlife and flora/fauna, as well as historical and cultural artifacts and sites.

We are keenly aware that officials charged with reviewing proposals consider the NIMBY issues raised by going forward. In reply I would note that this project has a highly negative impact not only on the people, wildlife and organizations in Catskill region, but also the 9 million residents of New York City. The Ashokan reservoir is the source of 40% of NYC drinking into water.

Additionally, comments from Premium Energy's Leadership, noted above, demonstrate that the Company, itself, has seriously erred in their proposal development by presenting a plan that even they admit is faulty.  

We clearly recognize the need for our nation and world to transition to green-energy sources. However, it is clear that this proposed effort is not a green-energy effort. It will destroy important wilderness areas, negatively affect wildlife, contaminate local wells and septic systems, negatively impact the drinking water of 9 million New Yorkers.

I urge you, as a responsible public official, to reject the  Premium Energy Proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.    

John T. O'Connell

Ruth MI Bonapace, Lanesville, NY.
I own a home in Lanesville, Greene County, NY. The Stony Clove Creek intersects my property. I've worked with DEP Stream Management since Hurricane Irene to rebuild   with state-of-the art energy efficiency and grading the land to mitigate flooding. Now, my home is "ground zero" in one of the three sites that could up under 40 feet of water.
   I oppose the proposed hydropower project currently under review by FERC (docket number P-15056) because:
    1. It will destroy my home and those of my neighbors, some of whom have lives in Lanesville for many generations. Even if I were to relocate, I would still oppose the project because:
    2. It will destroy The Stony Clove Creek, a popular fishing stream and a beautiful natural tributary feeding into the Esopus.
    3. It will negatively impact the area’s popular streams for fly fishing 
    4. It will cause economic harm to residents and businesses in Hunter and Phoenicia since State Route 214 - the only road between the two - would have to somehow be relocated.
    5. If Rt 214 is not relocated:
         -- All Hunter Ski resort traffic would come off Exit 20 of the Thruway instead of 19 (right now people use both) and cut through the already treacherous winding road around Kaaterskill Falls for skiing and summer cultural events. 
         -- The road past Kaaterskill is continually clogged with illegally parked cars and pedestrians in the summer and the additional traffic will bring the area to a crawl and could result in more pedestrian injuries or fatalities. 
         -- Skiers and hikers would be cut off from traveling between towns and businesses along the state-owned Rt 28 including the Belleayre ski area and Phoenicia and the Hunter/Tannersville/Windham areas. This will have a severe impact on the local economies of these areas.   
    Please do not let this private for-profit enterprise destroy our homes, communities, way of life and natural resources.

Stefan Hagen, New York, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Kishan Patel, LITTLE FALLS, NJ.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Kishan Patel

Melanie Flannery, Catskill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Melanie R. Flannery

David B Paynter, Woodstock, NY.
This program could be detrimental to the way of life for the residence surrounding the Ashokan reservoir. A great deal of our recreation is based on fishing the reservoir and its tributaries.  Please do not let this plan go through.

Deborah Byer, Las Vegas, NV.
From:
Deborah Byer
566 Woodland Valley Rd.
Phoenicia, NY 12464
April 7, 2021

To:
Kimberly D. Bose

Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.



Sincerely,

Deborah Byer

Willa McClellan Koerner, West Shokan, NY.
Willa Koerner
304 Moon Haw Road
West Shokan, NY 12494

Dear Kimberly D. Bose/FERC,

I am writing to state my resounding opposition to Premium Energy Holdings’ proposed Ashokan Pumped Storage Project P-15056.

In 2018, my husband and I moved from NYC to West Shokan to establish a new home for ourselves in the woods, as well as to create a DIY retreat space for future-focused creative practitioners where they could come to recharge in the beautiful, restorative Catskills. Our mission is to support regenerative work that centers the environment, and aims to bring about a greener, more equitable and more sustainable future. At this point, we’ve now hosted over 150 artists, engineers, journalists, social entrepreneurs, organizers, scientists, and others at our home—which is a beautiful space surrounded by the “forever-wild” Catskill Forest Preserve, a spring-fed pond, Wittenberg Brook, and Friday and Wittenberg Mountains.

Premium Energy’s proposed Ashokan Pumped Storage Project would put a swift end to our work, as it would likely wipe our home and retreat space off the face of the earth—razing the forests we love, killing off many of the animals who call these forests home, and flooding this historic land, which was referred to by visitors of the 1900s as the “Eden of the Catskills.” 

While I would do almost anything to save our home, this is more than just a NIMBY plea. It is unimaginable to me to think that we could abandon our legally protected forests just because an opportunistic CA-based company sees these mountains and these waters as a cash cow. I assume FERC is smart enough to see this proposal for what it is—a plain-and-simple bad idea, with even worse execution—but of course I worry that the proposal will be taken seriously, despite its many flaws.

To me this project proposal screams, “Green energy, but at what cost?” Moving our state and country to renewable energy sources is a noble and worthy pursuit, for sure—but it shouldn’t be a game of addition by subtraction, where protected forests (also incredibly important for our green, eco-conscious future!) are sacrificed. We cannot justify that kind of irreversible devastation, at least not before other alternatives are fully investigated and pursued. Destroying any kind of protected land, and displacing communities—the very same communities that were devastated by the Ashokan Reservoir construction 120 years ago—should be an absolute last resort. Truly, we are not that desperate yet, and we have time to find better alternatives.

I believe in a future where green energy is abundant, and hydropower energy-storage solutions can be thoughtfully planned at sites that enrich and benefit their communities. Here, such a project would do nothing of the sort, and would instead be an abhorrent abomination, smashing through our community and this uniquely preserved land like a wrecking ball on fire. Nobody is asking for this, and it doesn’t even represent the kind of innovation needed for NYS to move to 70% renewables by 2030. The proposal is shoddy at best, strewn with false information to the point where it appears that whoever crafted it took a whack-a-mole approach, without doing due diligence to understand the actual landscape of the Ashokan watershed, or its highly preserved and protected status.

Best case, this project could be constructed with minimal damage to protected forests, and minimal sacrifice from our community. Even if this were the case, it still has major flaws that would continue to pose a threat far into the future. Perhaps the biggest of these threats is the risk it poses to the Ashokan Reservoir itself, and NYC’s unfiltered water supply, 40% of which comes from our watershed every day. As climate change continues to affect our weather patterns, who knows how the impending droughts and floods will affect the delicately balanced Ashokan. It would be downright careless to bring another vector of uncertainty into the equation, and using it as the lower reservoir for the Ashokan Pumped Storage Project would undoubtedly do just that, as the water supply becomes more and more unpredictable, murky, and turbid. We need to protect the valuable assets and resources we have, not needlessly endanger them with ill-conceived development.

At this early point in the process, I have already spent many hours working with the newly formed Coalition to Save Catskills Preserve—a hundreds-strong group of neighbors and organizations taking action against this horrid project. We are extremely aware of the flaws with Premium Energy’s proposal, we are organized, and we will be watching FERC’s process with eagle eyes, ready to pounce and fight to protect these lands, their wild inhabitants, and the homes of our families, neighbors, and friends. 

Now is the time to stop this proposal, before it’s allowed to wreak further havoc on our community, which has been thrown into an absolute furor over the mere idea of such a poorly thought-through project desecrating our beloved Catskills. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thanks for your time.

Sincerely,
Willa Koerner

Thomas Byer, Phoenicia, NY.
From:
Thomas Byer
566 Woodland Valley Rd.
Phoenicia, NY 12464

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Thomas Byer

Nicholas Needam, SAUGERTIES, NY.
To whom it may concern, 

I am a lifetime resident of the hudson valley, and I enjoy our robust and beautiful ecology. I am submitting this complaint against the recent application for an energy development plant filed by Premium Energy. A corporation not even based in the state of New York. Their production facilities would reap devastating effects on the Ashokan reservoir and it's tributaries, which are guaranteed by MY tax dollars to be preserved. I implore you to cease this process before it goes any further.

Laura Henzel, Germantown, NY.
Please do not move forward with this dam plan, it will ruin the beautiful Catskill area and harm the wildlife as well as the tourism that keeps this area flourishing. The Catskills are a State Preserve protected by the NY State Constitution.

Faedra Dagirmanjian, Olivebridge, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, DC 20426

Docket number: P-15056-000

Dear Ms. Bose, 

I am writing about Premium Energy Holdings’s proposal regarding the hydroelectric power plant in the Catskill Mountains using the Ashokan reservoir. I know that very few people want a project like this in their own neighborhood and I do not wish to add another of those voices just for the sake of preserving our own backyards. I believe that these projects are important. However, two of the issues raised have also concerned me enough that I feel compelled to add my voice. First, our area’s status as a forest preserve and designation as Status 1 land. I believe this corroborates the idea that these lands are particularly important to preserve and are likely to not be the best fit for a project such as this proposal. Second, the concerns related to the project not actually being “closed-loop” as they claim. In part because I do actually believe in the importance of these projects, please let us hold the companies accountable to do them correctly and as the agencies and offices involved require for good reason. 

Thank you very much for your time. 

Faedra Dagirmanjian
Olivebridge, NY
faedra.dagirmanjian@gmail.com
(914) 466-6965

Zoe Schlanger, Brooklyn, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to express my opposition to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. It would destroy an ecosystem I love, and threaten a community I love. 

The pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed for this project. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. 

Please refuse this reckless proposal.

Thank you for your time,
Zoe

Lynn Loflin, West Kill, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. I live inside the Catskill park and it is protected as a state preserve under the NYS Constitution.  This plan would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Lynn Loflin
Stuart Wexelbau

Katherine C Jueds, Shokan, NY.
Katherine Jueds
18 Mountain Road
Shokan, NY 12481

To: Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. This proposal is profoundly problematic and I urge FERC to decline Premium Energy’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. The project, if completed, would negatively impact tourism, local communities, the area’s environment, and New York City’s drinking water.

Firstly, the project would be deeply damaging to local communities in the Catskills. Completion of the project would require the seizure of homes and private property via eminent domain, and displaced residents would likely have a challenging time finding affordable housing in the area. Ulster County is experiencing a severe housing shortage and the properties that are available are extremely expensive. Furthermore, many in the area are already struggling with loss of income due to the pandemic.

In addition to the potential problem of displacement the project would create, it is also important to consider the project’s deleterious effect on tourism in the Catskills. In 2019, tourism generated 17% of the employment in the region; it is a $1.6 billion industry which supports approximately 20,000 jobs. The Catskill region is justly celebrated as a haven for hikers, fishermen, and skiers. Premium Energy’s project would cut off access to these and other forms of recreation. Furthermore, the project would irreparably damage the area’s natural beauty. With a decrease in tourism, businesses and workers in Ulster County would suffer. 

Premium Energy’s project would also cause lasting harm to the environment. Large, unbroken areas of wildlife habitat are, sadly, now rare in our country: the Catskill Forest Preserve comprises almost 700,000 acres of contiguous habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats in the region, per the New York State Forest Condition Index. In addition, Catskill Forest Preserve lands, under Article XIV of the New York State Constitution, are clearly designated as “forever. . .  wild forest lands. They shall not be leased, sold, or exchanged, or be taken by any corporation, public or private.” Please do not allow this very special place to be altered beyond repair by Premium Energy.

Finally, Premium Energy’s project is an immediate and serious threat to New York City’s drinking water. The project would make use of the already-existing Ashokan Reservoir, which serves the city and which is the largest unfiltered water supply in the nation, providing 1 billion gallons of water a day to 9.5 million people. In the 1990s alone, $1.7 billion was invested in the reservoir. It would be foolish and dangerous to endanger this essential resource in the ways that Premium Energy’s project would do. Their proposed pumped storage plant would adversely affect the sediment regime in tributary rivers and streams that feed the reservoir—ultimately harming not only the fish and wildlife that depend on them but also the many, many New York City residents who do as well.

I want to be clear that I am in favor of renewable energy, and that I hope it will play a large part in our transition away from fossil fuels and toward more sustainable sources. However, we cannot sacrifice community and environmental well-being in pursuit of this goal, and the Premium Energy project would do just that. Though Premium Energy claims their project is a “closed loop,” a type of pumped storage project that would have a smaller impact on the surrounding ecosystem, this is false: the project is in fact an “add on” since it would use an existing body of water, the Ashokan, as a lower reservoir. In putting the project forward as a “closed loop,” Premium Energy has already lied to us. How can we trust them to maintain high standards and care for the community if they have based their proposal on an enormous falsehood?

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Katherine Jueds

Bernadette Slovensky, Shokan, NY.
Reference:  Docket  # P-15056-000
Premium Energy Holdings, LLC has submitted a proposal to the Federal Energy Regulatory Commission (FERC)  referred to as the Ashokan Pumped Storage Project  that seeks permission to do a feasibility study that would clarify the project’s scope and viability. In the proposal they call it a closed-loop project as such designs  are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval.  
Projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects, that’s what this really is. The Ashokan Pumped Storage Project  therefore is not a closed-loop system.
 “Initial construction impacts” for these projects are lower, but operational impacts are likely to be higher than for a closed-loop project because the addon project’s lower reservoir is still continuously connected to, and may affect, the natural flowing water feature that was dammed for its original construction.”*
*Source: DoE: “A Comparison of the Env. Effects of Open Loop and Closed-Loop
Pumped Storage Hydropower.” April 2020
That’s why Premium Energy is claiming that the Ashokan Pumped Storage Project is to be “closed-loop.”  This is one of many reasons that this proposal should be denied.

Other formats

Dave Kaufman, Shokan, NY.
Here are a few reasons why this is a bad idea, and why people around the area dont want this to happen - 

1 - This is preserved land.  I didn't move into the middle of the mountains to have  a hydro electric plant ruining the ambiance.  its a state park preserve.  It should be kept that way.  As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

2 - If you do move forward with this - the changes to land management in the State Forest Preserves are of the Catskills must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.

3 - This will impact the NYC water supply as its about 40% of the water it receives.  If a hydro electric power station is developed NYC residents may not be able to get the supplies they need

4 - Tourism and parks land generates 17% of the regions employment.  I for one would not want to go to a state park and see an ugly power supply station.  without the tourist - there isnt a reason to have these people employed.  

5 - This is an add on project and not a closed loop project.  The environmental impact of this could be HUGE.  Stating that the project is closed loop is just incorrect.  Please see plans and their own provided materials as to why this is an add on project.  

Thanks, 
Dave

Sean Suchara, Seaford, NY.
Sean Suchara
3831 Marion Ct

Seaford NY, 11783

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. Our transition must be built on an ethical approach, in this time many will come and try to reap the benefits of claiming their projects are clean, but the reality is the proposal from Premium Energy will do greater damage to the nature carbon sinks of the Catskills then its storage pumps could ever help to subvert.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sean Suchara

bridget sweeney, shokan, NY.
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Morton S. Adams, West Shokan, NY.
I OPPOSE THE

ASHOKAN PUMPED STORAGE PROJECT

This is not a "green" project.
	That is a false claim of clean energy.

This project will harm recreational and 2nd home values.
	These two industries are drivers of the Catskill regional economy.

This project will harm water quality.
	The Catskill watershed is vital to the health of New York City. 

This project will disrupt local water wells.

This project will harm Quality of Life of the inhabitants of Catskill towns, villages, and rural areas.

Brigitte Engler, Phoenicia, NY.
It has come to my attention that a California company, Premium Energy, has filed for a permit to create a hydroelectric power plant on the Ashokan Reservoir property. Within this proposal are 3 different site proposals for an upper reservoir (only one will be chosen). One of these sites is in Woodland Valley. The fact that they would be making a dam at the bottom of a dead end road would impact and flood residential neighborhoods, roads, delicate watersheds, NYC drinking water, recreation, trout spawning streams and the flow of traffic on a very narrow road with big trucks, polluting a pristine nature preserve and the Catskills State Park at the end of the road.

As a member of the Woodland Valley association and a citizen volunteering in Cornell Extension's program to monitor and eradicate invasive species along the stream, I oppose this short-sighted plan that will have a significant adverse impact on the eco-system, permanently altering the natural setting, water quality, public lands, wildlife and communities.

Zac Schiff, Olivebridge, NY.
Dear Ferc,

Please do not approve Premium Energy’s plan to build their hydroelectric dam in the Catskills! If you do, you’ll be setting a dangerous precedent that will allow & encourage private companies to pillage this Status One protected land for their own profit for years to come. Do you really want to pave the way to the potential annihilation of one of New York State’s (and this county’s!) most pristine wildlife and forest preserves?

Zac

Blair Reynolds, Bearsville, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Docket Number P-15056-000

Lauren Baptiste, Boiceville, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing to you, urging you and your team at FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the place I call home. The proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains is incredibly flawed. Bringing this to life would mean destroying an ecosystem, disrupting local communities, and risking the purity of NYC’s drinking water. This idea is not worth the negative long-term cost.

Here’s a bulleted list as to why this idea is flawed:

•	Catskill Forest Preserve, wildlife and ecosystem are at risk of being tampered with. Under Article XIV of the NYS Constitution, these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat. It would be a complete shame to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
•	Pumped storage wreaks havoc on nearby stream ecology and on both aquatic and land habitats. My home is part of the Ashokan watershed and I know how delicate the ecosystem is. Without a doubt of the rough water continuously moving up and doing that it would impair the interconnectedness of the Ashokan watershed and its tributaries.
•	The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.
•	Premium Energy’s proposal would be deeply damaging to local communities, which I am a part of. This project would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are not affordable for those that are displaced. 
•	The proposed project would effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 
•	The project would impair the connectedness of Rt. 214 between Ulster and Green counties, impacting skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

I could outline many more reasons, but overall, this project will directly hurt the environment, my local community and even tourism. Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000.

Sincerely,
Lauren Baptiste

Carolyn Mow, Phoenicia, NY.
Carolyn Mow
131 Muddy Brook Rd.
Phoenicia, NY  12464
caromow@aol.com
845-688-2824

April 4, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Re:  Docket Number P-15056-000

Dear Ms. Bose,

I am writing regarding the proposed Ashokan Pumped Storage Project.  I have lived in Woodland Valley for 25 years and own a small home here.  My son attended the Phoenicia elementary school, and the Onteora middle/ high school in Boiceville.

Phoenicia is a lovely town and is becoming more and more popular as a tourist destination.  Woodland Valley is an integral part of the Phoenicia community, and the trails and campground located here are an important draw to the area.  It would be devastating to the residents here and damaging to the local economy if this project were to happen here.
As part of the Catskill Park, we prioritize maintaining the natural area that we live in, and the habitat we provide for wild animals.  This is part of what draws people here, and it would be endangered by the proposed project.

The larger community we are part of, the Onteora School District, suffered a great trauma when the community of Olive was destroyed to build the Ashokan Reservoir.  That harm has had long-lasting effects on our community and should not be repeated.

It is unclear to me at this moment whether I would lose my home should this project be approved, but it is clear that many of my neighbors would.  It is important for you to understand from the outset that the members of this community will unite in strong opposition to this project and do whatever we can to stop it.

Thank you for your consideration of our concerns,

Carolyn Mow

Edward Ojarovsky, West Shokan, NY.
No! I oppose this proposal as totally offensive and inappropriate. As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Thank you.

Elizabeth Murray, Lanesville, NY.
I am dismayed and distressed to learn that my town and the site of my home is being considered for a hydroelectric plant. Not only am I concerned as a homeowner who would  lose their home, in the event I did not lose my home I am concerned as a mother of a young child as I do not know what the impact of being so near such a plant would be. I am further concerned since I spend time in New York City and count on having clean drinking water which comes from Lanesville watershed. I cannot imagine it is a plant would be safe for the city water which I also count on. Additionally, I travel  Route 214 daily and cannot imagine being cut off from the rest of the world were this plant to destroy my means of travel.  Not to mention the economic impact on this region which relies on tourists who travel the scenic route from Phoenicia and Woodstock to skiing at Hunter. Finally, my neighbors have owned their homes some of them for decades some for centuries and I can’t imagine where they will go. They depend on the forest for logging or they depend on route 214 to connect them with the ski mountain where most of the economy is focused. To cut off this route would be unspeakably detrimental. With the value of property has raised so much in the last year there is no place else for people to live. I personally have poured my savings into my house and cannot imagine I could find anything comparable that I could afford given the current market. I am troubled and disgusted by the larger environmental impacts such a project would have especially when our community would reap none of the benefits since the electricity would be shipped to Orange County. I think even a proposal of putting the plant here is shameful and incredibly shortsighted.

Jonathan Nedbor, High Falls, NY.
Jonathan Nedbor
496 Towpath 
High Falls, NY 12440
										April 5, 2021
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am moved to write this in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
I have lived and hiked in this area for 40 years. In those 40 years I have seen endless proposals for projects that benefit those who do not live here in the Catskills. Projects that would spoil the natural beauty, disrupt the lives of local people, put our streams and creeks at risk and offer no long term benefits for the land or for those of us whose lives are here. 
I am sure that you are aware of the history of the Catskills Forest Preserve in Ulster County, created in 1885. And that under ArIcle XIV of the NYS ConsItuIon, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
 The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. 

I am sure that you are aware that as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. 
As for the environmental impacts on this area, it is known that these pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. As it is, we are now suffering from the releases from the Ashokan Reservoir into the Esopus Creek. These releases are laden with silt, smothering every living thing found in the creek with a dense layer of mud. Do we need more of this in this region? I do not think so, coffee colored streams and creeks, that are both unsightly and unhealthy. 
These additional releases will alter the sediment regime in tributaries to the Esopus as well as the Esopus, one of the Catskills’ most vital trout waters and part of the NYC water supply system. This also puts further strain on the NYC water system which is unable to manage the silt problem as it stands at this time. This puts our streams at greater risk as well as the water system for all of New York City.
Chocolate brown streams, loss of fish habitat, damage to the environment, removal of acres of trees, construction, etc., will damage the local businesses that depend on the resources in the area as well as much needed tourism. 
I don’t think I need to add more to this letter, the concerns I have mentioned already should be enough of an argument to stop this mega project before it goes any further. It is poorly designed with no thought for the damage and destruction it will cause to the environment and to the inhabitants of this region.  
Sincerely,
Jonathan Nedbor

Blake Macko, Philadelphia, PA.
Blake Macko
3851 Terrace Street
Philadelphia, PA 19128

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. There are many of us who are ready to put up a fight for all that stands to be destroyed by this project.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Blake Macko

Submission Description: (doc-less) Motion to Intervene of Michelle Friedel under P-15056-000.

Submission Date:        4/6/2021 6:50:49 AM

Filed Date:             4/6/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               mfriedel91@gmail.com                                                             

Basis for Intervening:
April 1, 2021

Kimberly D. Bose, Secretary 
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A, 
Washington, DC 20426

Re: Docket P-15056-000
MOTION TO INTERVENE of Michelle Friedel for the Premium Energy Holdings, LLC, Project No. 15056

Dear Secretary Bose,

This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. Therefore, Michelle Friedel is filing a motion to be an intervenor and meet the requirements of 18 CFR 385.214 of the Commission’s regulations to grant them full party status.

The basis for intervening is due to the proposed location of the project which encompasses the  private property where one of the proposed site projects would be located- Wittenberg Reservoir/Dam. Hence, Michelle Friedel along with her children will lose and not have access to their land as well as to their home which leads them to have substantial interest in the matter, since the property is their primary residence which is located on 55 Friedel Drive that is directly off  Moonhaw Road, West Shokan, NY 12494. 

Michelle Friedel respectfully request that the Federal Energy Regulatory Commission grant this motion to intervene.

Respectfully,

Michelle Friedel
PO Box 35
55 Friedel Drive
West Shokan, NY 12494

John Perry, Hurley, NY.
Madam Secretary:
The Town of Hurley respectfully requests intervener status with regard to the proposed pumped storage facility by Premium Energy Holdings of Walnut, California, for the upper basin of the Ashokan Reservoir.  
The project will have direct impact on the Town of Hurley as the electrical lines will run through the Town and terminate at the storage facility on Hurley Avenue.
Thank you for your attention to this matter.
John Perry
Supervisor 
Town of Hurley
10 Wamsley Place
PO Box 569
Hurley NY 124543
845-331-7474 x6

Stephen Lieb, Denville, NJ.
I write to ask that you deny PEH’s proposed project to construct a pumped-storage facility on Ashokan reservoir.  I am a fisherman who fishes the Esopus and its tributaries.  I recognize the need for energy storage alternatives, including pumped-storage.  Adequate capacity to store energy generated by renewable, but intermitted, sources like wind and solar, makes alternative energy sources more economically viable.   A project on the scale proposed by PEH , however, is incompatible with the Catskill region.  It would raise significant legal issues, would disrupt an ecosystem that has been protected for over a century, and would endanger a vital source of drinking water for millions of people.   I urge you to reject PEH’s proposal.  
Catskill Park lies within the “blue line” of protected lands designated as “forever wild” under the New York State constitution.  Before the turn of the last century, New York State wisely set aside certain areas of state forest land from industrial and large-scale commercial development as part of the state constitution.  NYS Const. Art. XIV.  The PEH project would require a taking under eminent domain.  Assuming its permit application were granted, a threshold issue PEH will face is whether such a taking is legally possible.  In a case involving a FERC certificate issued under the Natural Gas Act (“NGA”), the Third Circuit Court of Appeals held that under the Eleventh Amendment a state’s sovereign immunity prevents a private party from forcing the state into court to enforce a condemnation order to seize state land.  In re PennEast Pipeline Co., 938 F.3d 96 (3d Cir. 2019).  The Supreme Court has granted certiorari and will hear arguments this month.  But even if the Court overturns the Third Circuit, this can only resolve the threshold issue whether the courts will even hear the case and not whether the pipeline owner will prevail.  The proposed “taking” by PEH would be much more extensive than simply providing a right of way for a pipeline across state land at issue in PennEast.  More importantly, PEH would need to condemn land protected under a state constitution which may raise a host of constitutional issues.  
Construction of the facility is incompatible with largely undisturbed forest preserve provided by the Catskills Park.  Based on PEH’s First Amended Permit, any of the three proposals would require the delivery of many thousands of tons of concrete and steel through the park to construct the impoundment dams, tunnel s and halls for turbines and transformers.  More than 100 million cubic feet of rock and soil will need to be excavated and transported out of the park.  With the exception of the construction of New York City’s water reservoirs, no construction on this scale has occurred within the Catskills.  
Operation of the facility would have a significant impact on protected waterways.  PEH seeks to minimize the impact of the project by asserting that it is “closed loop.” See PEH First Amended Application at 11. If it were, PEH could take advantage of FERC’s expedited licensing process.  But PEH’s assertion is simply untrue.  A “closed-loop” facility is one that would  “(i) Cause little to no change to existing surface and groundwater flows and uses; (ii) Is unlikely to adversely affect species listed as a threatened species or endangered species, or designated critical habitat of such species, under the Endangered Species Act of 1973; (iii) Utilize only reservoirs situated at locations other than natural waterways, lakes, wetlands, and other natural surface water features; and (iv) Rely only on temporary withdrawals from surface waters or groundwater for the sole purposes of initial fill and periodic recharge needed for project operation.”   18 C.F.R. § 7.1(c)(3).  Operation of the PEH facility would degrade the aquatic ecosystem of the Esopus, which is a “natural waterway” that was impounded to create the Ashokan.  Water flows into and the out from the Ashokan making PEH’s project an “open-loop” system unlike, for example, the proposed Goldendale Energy Storage Project which would use specially constructed embankments to form a truly “closed-loop.”  See Federal Register 2017, 82 FR 60593 FFP Project 101 .  The proposed PEH facility will no doubt change groundwater flows, eliminating at least one tributary to the Esopus.  It remains to be seen what species may be impacted by operation the project, but the proposal cannot be considered one a closed loop that minimizes environmental impacts.  
Operation of PEH’s facility will also endanger the water supply for millions.  The Ashokan is the largest reservoir in the NYC water supply system.  By maintaining an undisturbed watershed around its reservoirs, New York City has created a water supply that is the envy of every major city on the planet.  Even so, silt has been an issue for the Ashokan.  For over 100 years, the West Basin has served as a settling pond for water from the Esopus and from City reservoirs further upstate; silt drops from suspension before flowing over a weir into the East Basin where the City’s intake port is located.  A study of water years from 2010 to 2012 found between 30,000 and 600,000 tons of silt flowed into the West Basin annually.  Even assuming the average year’s silt load is 100,000 tons per year, after 100 years of operation there are 10 million tons of silt resting on the bottom of the West Basin.  PEH estimates it will pump 15,800 acre-ft of water into and out from the West Basin on a daily basis.  Disturbance of the West Basin will no doubt resuspend accumulated silt and will impact the ability of the West basis to absorb incoming silt.  
The protected lands within the Catskill blue line are a wise investment New York State made on behalf of its citizens. In seeking to achieve the laudable goals of affordable, reliable, clean energy, FERC should not squander this investment.  I urge you to reject PEH’s proposed project in the Catskills.

Sarah Kinlaw, BROOKLYN, NY.
Sarah Kinlaw
1236 Atlantic Avenue
Unit 306
Brooklyn, NY 11216

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Kimberly Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, extremely disruptive to local communities, an unwise decision for the environment, with potentially awful implications on the purity if the drinking water in New York City.

The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats because, within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Sarah Kinlaw

Irwin Marcus, Boiceville, NY.
This Premium Energy project is ill conceived and unwelcome in a pristine environmentally protected water shed area. I am to believe that this project was supposed to act as a battery to provide ‘peak’ electric supply rather than increase our overall power generated.

The electrical generation of hydro-pumped storage consumes more electricity than it produces.

The money would be better spent to augment our areas’ electrical needs by using solar, wind and run-of-river hydro power.

For battery type storage – the current technology such as the Tesla Megapack can provide Megawatts of electricity for peak use in the future. The price for battery storage will decrease dramatically in the near future and the next wave of 80% reclaimed electric auto batteries can be used to increase storage capacity and at a lower cost.

So my question is why are we using such a destructive pumped hydro solution when we don’t have a problem at this time – if you say we have a peak issue – then please tell me what is our area’s current electrical drain during a 24 hour period and what do we need to provide peak power overload for now and for the next 5 – 10 years? 

An issue as far as the system proposed is ‘Not a Closed Loop’ system.
The proposal states falsely in Exhibit 1 on p. 11: "The proposed Ashokan Pumped Storage Project would operate in a closed loop. This is NOT a closed-loop system. It is an ‘add-on’ project for open-loop pumped-storage hydropower because the proposed project’s lower reservoir, Ashokan Reservoir, is still continuously connected to, and may affect, the natural flowing water feature that was dammed to construct the Ashokan Reservoir

The three sites proposed for the upper reservoir would cause major damage to highly preserved land in the Catskills Forest Preserve created in 1885 in Ulster County.

Under Article XIV of the New York State Constitution, the lands “shall be forever kept as wild forest lands.
The proposed project would destroy these irreplaceable natural areas, undermine the attractiveness of the area for tourism, weaken the local economy, pollute downstream, and probably wreck one of NYC's major capital assets, its water supply system.
Also – the Forest Preserve shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” As a State Forest Preserve, the Catskills are considered Status 2 land under the USGS “Gap Analysis Program.” According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development." 

In conclusion, granting the urgent need for more renewable energy in New York State and nationally, this preliminary permit application should be rejected at the outset, because the Ashokan Reservoir and surrounding forests and mountains are not the right place for this project.

The amount of digging and construction in the fragile area proposed would permanently dislodge wildlife, the flora and fauna and countless other forms of life.

Yours truly
Irwin Marcus 

Paul T Smith, Brooklyn, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Paul T Smith Jr.

matt kovner, olivebrdge, NY.
This proposal is unacceptable on many levels. it will be a years long construction project with hundreds of trucks moving thousands of tons of materials along quiet country roads, will require the state taking property by eminent domain, and will disrupt the lives of virtually all of the people who live in the town of olive for many years.

please do not approve this proposal.

thank you

Matt Kovner

Leana Nieves, boiceville, NY.
 As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Denis and Judith Moran, West Shokan, NY.

Hello. We strongly oppose the ill-conceived and ecologically destructive idea of this project. We live in West Shokan and most of the hamlets residents live within the area that would be impacted. It is also hard to conceive that a threat of this nature to the most important drinking water source for much of southern NYS would even be considered. Denis and Judith Moran, 269 Watson Hollow Road, West Shokan, NY

Gordon Perkins II, SOUTH WINDSOR, CT.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Gordon Perkins

Heidi Emrich, West Shokan, NY.
To Whom It May Concern,

My name is Heidi Emrich and I am a resident of West Shokan, NY in the Bushkill / Maltby Hollow / Whittenburg Stream neighborhood.  

Our recent discovery of the proposed Pump Project (FERC Project NO. 15056-000) which includes the building of a dam in one of three regions in our beautiful Catskills and 13-17 miles of transmission line, has us EXTREMELY alarmed.  Folks live here because we enjoy a peaceful life in harmony with nature.  And while we recognize the need for renewable energy sources, damming up our streams is not an environmentally-sensitive solution.
 
There is significant research about the detrimental and irreversible effects of dams.
  
See: 

DAMMING CONTRIBUTES TO CLIMATE CHANGE 
 https://www.earthlawcenter.org/blog-entries/2017/12/dams-climate-change-bad-news#:~:text=Dams%20store%20water%2C%20provide%20renewable,water%20and%20displace%20poor%20communities.

PROS & CONS OF DAMS, highlighting algae downstream, which is already an issue that is threatening our beautiful trout stream:
 https://environmental-conscience.com/dams-pros-cons/

HOW DAMS CHANGE RIVERS: 
 https://www.americanrivers.org/threats-solutions/restoring-damaged-rivers/how-dams-damage-rivers/

Our communities are FULL of critical environmental resources, wetlands ecosystems, rare habitats, threatened and endangered plants and wildlife.  Our communities are also full of active community members who frequent our parks, trails, local swimming holes and other recreational resources.  Our communities are also beautiful and thriving. Plain and Simple. Home sales are up, neighborhoods are growing and folks are investing time and money into restoring our beautiful rural heritage. 

In addition to environmental concerns and impacts of dam-building, our family is terrified of the possibility of large transmission lines running through our front or back yard. Our home is RIGHT in line with one of the proposed models. We have not invested hundreds of thousands of dollars into our home and landscaping improvements, all to see our property value decreased. 

Please listen to the community. The Town of Olive Residents do NOT want this, we don't need it. We haven't commissioned it. In fact, we didn't even know about it until late February!? How can a company from California come in and even propose such a project that the Community/County isn't asking for/commissioning?  This company is obviously in the business of making money- and they looked at some topographic and hydrogeological maps and picked us to be their guinea pigs.  

Everyone is scared this will steamroll its way in and our voices won’t be heard and our landscape will be forever changed. 


Thank you,
Heidi Emrich
67 Watson Hollow Road, West Shokan, NY

Marc Rubin, Lanesville, NY.
  As a long time resident of Lanesville NY and owner of a local business I would like to submit my vigorous opposition to the granting of a preliminary permit to Premium Energy Holdings. I am a strong advocate for renewable energy projects, however   the Catskill locations proposed are untenable.
  All the proposed sites fall within the Catskill Forest Preserve, which according to the NYS constitution “ shall be forever kept wild forest”. Usurping this caveat would require a constitutional amendment that is rarely passed. The original amendment was initiated to protect this precious land resource and should not be altered.  All the proposed sites fall within the Status 1 designation under the USGS Gap Analysis Program, which voids development according to the Department of Energy’s “Hydropower Vision”.
  The project would adversely affect the streams and waterways by increasing turbidity.  The streams are already fragile and any further development threatens the local ecology and fauna.  Recreational fishing is a prime attraction for this area and helps the local economy flourish. The project jeopardizes trout breeding grounds and falls within the  “ Audubon’s Catskill Peak Important Bird Area”. We cannot afford to threaten these resources. The turbidity also puts at risk the quality of the drinking water that serves 9 million residents of NYC. 
  The proposed site intersecting Route 214 in Lanesville is a designated “scenic byway” and a primary thoroughfare connecting difficult to access portions of the mountains.  Disrupting or voiding this passage   would increase travel times up to an hour and adversely affect the tourism economy of the town.
  The proposal by Premium Energy classifies the project as a closed loop system. This is misleading at best and deceitful at worst. The project is an add- on system with a much stronger environmental impact.  The affect on the existing reservoir could be extremely detrimental. 
  All the local municipalities are strongly opposed to this project.  Given the environmental and economic impact and political and legal hurdles to overcome… this project should be stopped in its tracks before further investments make it more difficult to halt.

Angelina Vezzetti, Hudson, NY.
Angelina Vezzetti
331 Allen Street 
Hudson, NY 12534

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. It is an insane idea to ruin this beautiful area for the sake of profit. 

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped 
storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely concerned,

Angelina Vezzetti

Joseph N Raguzin, Carmel Hamlet, NY.
Joseph N. Raguzin
19 Pleasant Drive Carmel, NY 10512
Docket Number P-15056-000
Subject: FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA
To Secretary Kimberly D. Bose:
My opposition to the proposed project by Premium Energy is made on the following basis. First and foremost, Section 1 of Article XIV of the New York State Constitution makes such a proposal within the Catskill Park Preserve unconstitutional. “Section 1. The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private, nor shall the timber thereon be sold, removed or destroyed.” There are these facts to also consider:
•	It would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water.
•	It would be detrimental to our local community by disrupting our economy and displacing residents.
•	There is really no reason for it other than the fact that some spineless energy executives from California are trying to generate revenue where my family has spent our lives fishing, camping, and hiking. 
•	Apologies for my language but it is also a fact that Premium Energy can absolutely fuck right off with their assertion that this is a “closed loop” project and will not have significant environmental impacts. We are not stupid. 

CC’d:
Congressman Antonio Delgado
US Senator Chuck Schumer
US Senator Kirsten Gillibrand

Rosemary Anderson, Watsonville, CA.
April 6, 2021

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056-000 as it would be devastating to the environment and highly disruptive to local communities. In a pandemic world, this is of no small matter. We need to preserve critical infrastructure, jobs, and environmental havens.

Tourism is an integral part of the NYS economy and continues to grow. Tourism generated 17% of employment in the Catskill region in 2019. A $1.6 billion industry in the region, supporting roughly 20,000 jobs o Ulster County represents 43% of that market o Second homes generate $360 million in economic activity. Source: Tourism Economics, “Economic Impact of Tourism in NY, 2019”

The Catskills Forest Preserve was created in 1885 in Ulster County. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index.

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” According to The Catskill Park: Inside the Blue Line-Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.

Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago.

This is not the innovation that Department of Energy would want. Closed-loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval; that’s why Premium is claiming to be “closed loop.” Projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects; that is what this really is. Premium Energy Holdings is grievously misrepresenting the facts.

Have we not learned our lessons from the past? Can we not seek a more suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources?
Looking at all the facts and negative impacts, it would be irresponsible to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation and represents over $1.7 billion of investments since the 1990s alone.

Please do the right thing, listen to the collective voices of those most impacted by this decision and the generations to follow, and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Passionately,
Rosemary L. Anderson
Frequent visitor to Ulster County
4rlaing@gmail.com

patrick crisci, lagrangeville, NY.
Dear Secretary Bose: 

These comments are submitted on behalf of the Mid Hudson Chapter of Trout Unlimited, a member of the New York State Council of Trout Unlimited. Our chapter has more than three hundred members. Roughly seventy-five percent of all of our members recreate in the Esopus Creek watershed. 

Ashokan Reservoir is part of New York City’s water supply system, meeting approximately forty percent of NYC’s water needs. It is the oldest of NYC’s six Catskill water supply impoundments, and the second largest. Since its construction in 1915, over one hundred years of sedimentation have settled in the west basin, where Premium Energy Holdings seeks to construct a pumped storage facility. To date, water utilized by NYC residents remains unfiltered. If a pumped storage project is built on the Ashokan, there is every reason to believe that turbidity would be created by the pumping and releasing of water from and into the Ashokan. 

In a similar request before FERC for a license to construct a pumped storage project on NYC’s Schoharie Reservoir at Prattsville, Project # 2729, New York City retained Lamont-Doherty Earth Observatory as a consultant. On page 12 of a report produced by NYC’s consultant it noted that such the operation of such could “create an unacceptable human health risk.” Furthermore, appropriately twenty municipalities draw water from NYC’s Catskill aqueduct as water is transferred downstate to NYC residents. These users would be placed at risk also. To further exacerbate this condition, during summer months, on most typical water years, up to ninety percent of the water in the Esopus Creek comes from water being diverted to the Ashokan via NYC’s Shandaken Tunnel. Often during these periods this water tends to be turbid. Hence, the operation of a pump storage facility on the Ashokan will only keep silt suspended in the water column that much longer. 

The Ashokan Reservoir currently is a two-story reservoir, that is, it stratifies into warm and cold-water sections throughout the year. As such, it supports a robust population of wild rainbow and brown trout in the cold-water portion. This provides sport fishing within the reservoir, which is an economic draw to recreational based Ulster County economy, and also a source of recruitment for the renowned Esopus Creek trout fishery. 

Recently the NYS Department of Environmental Conservation reclassified the Esopus Creek as a Wild-Quality stream, under their newly approved Trout Management Plan. This will benefit both the environment, plus the local economy as anglers come. Trout Unlimited conducted two “Heritage Brook Trout Studies”, in portions of the watershed that could be adversely affected by this proposal. Fin samples of brook trout were taken, and their DNA was analyzed by Dr. Spencer Bruce, of the University at Albany. Dr. Bruce is noted for his work in this field. In 2019 in West Shokan, on South Hollow, Dr. Bruce concluded from data collected that the brook trout were a unique Heritage strain. This tributary is in close proximity to Wittenberg, where one might conclude brook trout there are likewise also. In 2020 we studied a tributary in Stony Clove. Due to Covid, analysis of these fish samples has been delayed, but our chapter expects similar results. This study was done in partnership with the NYS Department of Environmental Conservation, Region 3 Fisheries as part of their ongoing Eastern Brook Trout Joint Venture studies. It is possible the headwaters of all three alternative sites support Heritage brook trout populations, that would be lost should this project be allowed. 

There are serious issues with how this proposal will affect the New York State Forest Preserve lands and their established, protected uses for the people of New York. Noted issues with this proposal will negatively impact drinking water quality, the environment, economy, NYS constitution protecting the Catskill Forest Preserve, and well-being of people living in the area of the P-15056. We believe these issues outweigh any potential benefits of the project. The applicant has not established a clearly defined need for such a project. Therefore, we respectfully request that FERC deny approval. 

Sincerely,
Pat Crisci
Region Three VP NYS Trout Unlimited & Mid Hudson Trout Unlimited

Jessica Fitzpatrick, Lake Peekskill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve MUST NOT be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. Thank you.

Sincerely,
Jessica Fitzpatrick

Trevor Harris, Astoria, NY.
New York City's watershed should not be threatened with a hydroelectric plant. Any infrastructure with machinery, along the shores of the reservoir is a potential threat for lubrication spills, construction spills and deterioration. Why threaten the watershed when there is so much potential for wind and solar closer to NYC and offshore?!? Deny this application.

Elizabeth Sorrell, Mt Tremper, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing to express my sincere concern about the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. It is my deepest hope that FERC will decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While I understand the need for renewable energy and support the goal to get to Net Zero by 2050 nationally, this goal cannot be achieved at the expense of natural habitat. As you may know, the Catskill Forest Preserve is home to many year-round and seasonal native wild species. I write to you now from the beginning of spring migration; I've already enjoyed the return of Tree Swallows and look forward to seeing Hooded Warblers and other migratory visitors in my yard soon. My home is mere steps away from the Esopus Creek so the land that surrounds us is well suited to sustain wildlife, and it must remain so. This project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

And I understand why it was protected. The Catskill Forest Preserve is a special place for those of us lucky enough to live here as well as for visitors who recreate here year round. In fact, Catskills’ growing tourism economy generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. 

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to the communities built and maintained by those of us who live here. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. When I watched a documentary about that project I thought, “That would never happen today.” Please don’t prove me wrong.  

It must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Elizabeth Sorrell

Kathryn Fink, Putnam Valley, NY.
Hello, I am writing to share my concerns about the plan with Premium Energy Holdings to erect a hydroelectric power plant. The Catskill Mountains are a critical habitat that must be protected from this kind of disruption. As a NY taxpayer and frequent visitor to the Catskills (and surrounding businesses) this change is alarming to me personally, as well as to my sense of communal wellbeing. 

Green energy is an crucial goal, but doing so in a way that further harms the environment and community is not a step forward, but a step back—and one that sets a precedent for further harm.

I implore FERC to reject Premium's request for a prelim permit (for the Ashokan Pumped Storage Project P-15056).

Robert W Moss, Bloomfield, NJ.
Docket #P-15056

The proposed pumped storage hydroelectricity facility in the Catskills is immediately on the boundaries of land protected by the "Forever Wild" clause of the New York State Constitution, and will obviously have an adverse impact on those lands. More generally, the Catskill park is one giant gem, no part of which should be disturbed by such a project.

Moreover, pumped storage is an inefficient way to replace fossil fuels. Its benefit is that it levels demand, making it possible to avoid building new generating facilities. However, the existing generating facilities still require more energy to pump the water uphill. Even if that energy is clean, it could have gone directly to consumers.

Whether or not FERC has jurisdiction over this question, you must act in accordance with reality. Our environmental crisis will not be solved until the population stops growing. It is not sufficient to say that such a facility could be built elsewhere. If we don't halt population growth, the alternate, less-damaging locations will all be utilized, and the problem will still not be solved, because the population will still be growing. World population growth must be stopped, or civilization will collapse.

I would also like to know what part of our U.S. Constitution grants FERC jurisdiction over such a project as this to begin with. It's a local supplement to the power supply.

The Yards Creek pumped storage project closed part of New Jersey's most beautiful park, Worthington State Forest, to the public. Don't let this happen to the Catskills.

Howard Altarescu, West Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Docket number P-15056-00

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I respectfully urge FERC to decline this request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it has the very real potential to be devastating to the environment, highly disruptive to local communities, and risky for the purity of New York City's drinking water.

I am a resident of West Shokan, New York. We are privileged in West Shokan to be surrounded by the beautiful Catskill Mountains, the Catskills Park, the Catskill Forest Preserve, the Esopus Creek and the Ashokan Reservoir. We are quite concerned by the application made by Premium Energy to construct a hydroelectric power plant in the vicinity of these resources, much of which is intended to be protected by Article XIV of the New York State Constitution: “The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private . . . .”
We are concerned that the construction and operation of the proposed facility will endanger the ecology of the Catskills Forest Preserve, including endangering threatened species. Construction and operation of the facility will also negatively impact recreational use of these natural resources by hikers, and by those who enjoy the streams, affecting fishing, boating, and swimming, and, as a result, would undoubtedly have a negative impact on tourism, resultant business revenues and sorely needed local tax revenues. This area of the Catskills is just recently and slowly recovering from years of economic decline and proceeding with the proposed facility would be a major setback to these communities and its residents.

Also, construction and operation of Premium Energy’s hydroelectric facility in the vicinity of the Esopus Creek, which feeds directly into the Ashokan Reservoir, and in the vicinity of the Reservoir itself, cannot but increase turbidity and put at risk the quality of New York City’s drinking water. According to the New York City Department of Environmental Protection, “[The] Ashokan Reservoir supplies about 40% of New York City’s daily drinking water needs in non-drought periods."

I do understand the need to develop alternative sources of energy. However, there must be areas where such alternative energy sources could be developed that are not adjacent to the source of critical water supplies for the City of New York and to the other protected resources of the Catskills, an area where construction and operation would not destroy protected wilderness, disrupt vulnerable communities, and threaten incredibly important natural resources.

I urge FERC to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you.

Respectfully yours,

Howard Altarescu
250 Brodhead Road
West Shokan, New York 12494

Robert Jaffe, Levittown, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.
The legacy of the Ashokan displaced many families and farms in the interest of supplying NYC with a pristine water supply; to allow this to happen now is a profound breech of the promises made not only to the families who sacrificed much for the Catskill Watershed project, but also to the citizens of NYC who fought to get clean water from the mountains as opposed to the polluted and dangerous reservoirs in Manhattan and the incorporated boroughs.

Fran Melmed, Kingston, NY.
Hello, 

I'm writing in opposition to this proposal from Premium Energy Holdings. The Ashokan Reservoir is more than a source of water. It is a source of peace and restoration and awe for visitors and sustenance for various habitants. 


This plan will do damage environmentally and monetarily. The plans will impact vegetation, animal life, and access to trails and roadways. The people who flock to the Reservoir and  the promenade for photos, breathtaking views, and appreciation of our landscape will also be negatively impacted. 

I oppose it and hope you grant intervenor status to the various groups and interests seeking to have a voice.

Regards,
Fran Melmed

Alicia Katsur, Woodstock, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Alicia Katsur

Paul Russell, Rosendale, NY.
I am writing in reference to docket P-15056, the Proposed pumped-storage hydro plant at the Ashokan Reservoir in New York State.  This proposal is problematic in any number of ways.  The Catskill land involved is a State Preserve protected by the NY State Constitution, and designated as either "Forever Wild" or "Wildlands."  The construction of the proposed reservoirs will be environmentally destructive, as will the necessary additional powerlines involved.  Native flora and fauna will be severely impacted, and there will be an increased risk of the introduction of invasive species into this environmentally sensitive area. The project will significantly increase the turbidity of New York City's drinking water (increased turbidity is already a local concern with the reservoir's periodic releases into the Esopus Creek). The vital tourist economy of the area will be adversely affected, as will the citizens of the neighboring towns and villages.  It is difficult to believe that Premium Energy has done any preliminary investigation of the multiple, disqualifying issues surrounding this project.  I strongly urge that you reject this application.

John Ellingboe, New York, NY.
The pumped storage project proposed by Premium Energy Holdings of Southern California near the Ashokan Reservoir is ill-conceived and should not be constructed within the boundaries of the Forever Wild lands of the Catskill Forest Preserve. This proposed project would directly threaten the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, and the quality of the New York City water supply. It seems that no local stakeholders were consulted before the proposal was submitted, and the nature of the area was not considered. Please do not allow this project to go forward.

P Keusch, Los Angeles, CA.
I am a property owner on Stony Clove Lane in Chichester New York just off route 214 and am opposed to the granting of a preliminary permit to Premium Energy Holdings (PEH) for the project to build a pumped storage hydroelectric plant utilizing the Ashokan Reservoir (docket number P-15056).

I believe PEH’s proposal is filled with erroneous and misleading information, and oppose it for the following reasons:

The entire proposed project lies within the Catskill Forest Preserve, which has been protected in section 2.1 of the New York State Constitution since 1894.

Key players were not notified beforehand, as legally required, including:  New York City, The hamlets of Lanesville, Chichester, Phoenicia, Mt. Tremper, Towns of Shandaken, Olive and Hunter, Ulster and Greene counties, Hunter Mountain Ski Resort, and its parent company Vail Resorts

Local and vacationer traffic on New York State Route 214, connecting Hunter Mountain, and the hamlets of Tannersville and Hunter to all points south, would be severely disrupted, wreaking economic havoc on the affected hamlets, towns, and counties.

Replacing New York State Route 214 will prove impractical, if not impossible, given the topography of the land.

New York City’s Department of Environmental Protection operates the city’s drinking water supply under a Filtration Avoidance Determination (FAD) issued by the US Environmental Protection Administration. The proposed project would drastically raise the turbidity in the Ashokan Reservoir watershed

As proposed, PEH’s project is not a closed loop system

With so much private property located within close proximity to the Stony Clove creek, and surrounded by the Catskill Forest Preserve, relocation of homes and businesses along the creek is impossible without amendment of the New York State Constitution.

I urge the Federal Energy Regulatory Commission to deny Premium Energy Holdings the permit.

Thank you,
P Keusch

Elizabeth Caprotti, West shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Max Friedlich, Shokan, NY.
I am writing to express my strong distain for Premium Energy Holdings diabolical plan to destroy our community. Perhaps this is an inflammatory way to begin a comment. Well...this is a highly inflammatory plan.

The idea of a California company coming in, displacing lifelong residents of our area, simply for their profit, is criminality. I don't know how to properly articulate how evil this is. My family and our community will be fighting this tooth and nail. 

This plan has the potential to be catastrophic for the Catskills and potentially dangerous for NYC residents who drink from the Ashokan reservoir. This is pure Capitalist greed under the thin guise of environmentalism. We live around a protected nature reserve. How is this not the most slippery slope imaginable? How will this effect tourism? How will this effect the balance of our fragile ecosystem, the trout breeding grounds, the habitats this will destroy. 

There is no possible justification for this plan moving forward. None. This must end now.

Julie Bergstresser, East Stroudsburg, PA.
I would encourage you to deny this permit as although it is a renewable energy tactic the impact on the environment would be extremely detrimental. It will not only impact views and access to this NY State Preserve but will also negatively impact local wildlife and harm NYC water supply access. I do not believe the impact outweighs the reward and while we should continue to embrace renewable energy sources there needs to be a balance with impact on the natural world. We cannot get back what we lose. Thank you.

Submission Description: (doc-less) Motion to Intervene of Ulster County Planning Department under P-15056-000.

Submission Date:        4/6/2021 3:49:58 PM

Filed Date:             4/6/2021 3:49:58 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Ulster County Planning Department        ddoy@co.ulster.ny.us                                                             

Basis for Intervening:
Ulster County Planning Department: Reasons to Intervene

Overview of Department Responsibilities: The Ulster County Planning Department is a regional planning entity that exercises planning functions that include review and approval of land use projects, comprehensive plans and zoning statutes in the Project area.  In addition, the Department provides oversight and planning for housing, economic development, agriculture, and environmental protection.  The Project, as proposed, has the potential to have significant impacts across nearly all of the Department’s areas of responsibility.
  
The Department is also host agency for the Ulster County Transportation Council, a federally recognized Metropolitan Planning Organization that is responsible planning and programming the use of federal funds for transportation infrastructure within the Project area. Project construction may have significant impacts on the transportation infrastructure. Of particular concern is transporting large pieces of equipment over critical corridors as well as the impact on local roads and bridges. 

The Department is also a member of the Ulster County Water Quality Coordinating Committee and the Ashokan Release Working Group.  These entities have a responsibility for the protection of water quality in the Project area.   Specifically, the Department is currently engaged in commenting on the Draft Environmental Impact Statement in relation to turbid discharges from the West Basin of the Ashokan Reservoir to the Lower Esopus Creek.  

The Project is proposing to utilize the West Basin of the Ashokan Reservoir as a lower reservoir. The West Basin is designed as a settling basin to capture and hold turbid water to allow the colloidal clays of the Catskills to settle out thereby protecting the City of New York’s Water Supply.  To further protect the water supply, discharges for operational and flood control purposes are made from the West Basin to the Lower Esopus. The operation of the pumped storage facility is highly likely to disrupt the normal settling pattern and timeframes in the West Basin of the Ashokan Reservoir and the length of the turbid discharges to the lower Esopus. These turbid discharges to the lower Esopus impact fish and wildlife, and economic opportunities along approximately 30 miles of the Creek.
  
It should be noted, that reduction in turbidity and improved flood control associated with the operation of the Ashokan Reservoir as it relates to the Lower Esopus Creek is subject to an order on consent by the New York State Department of Environmental Conservation.  In addition, the Catskill Turbidity Control Program (CTCP) is part of the Filtration Avoidance Determination (FAD) issued by US EPA that allows New York City to avoid filtration of its water supply. This program initiated the use of the measures described above to ensure the protection of the City water supply.  The Project effects of increasing the length of time turbid water remains in the Ashokan Reservoir may alter the operational requirements under the CTCP and impact the public water supply systems located in Ulster County that draw water from the Ashokan Reservoir through the Catskill Aqueduct as well as those drawing water from the 
Current data suggests that turbid discharges to the Lower Esopus which drains to the Hudson River impact the drinking water filtration systems that draw water from the Hudson River requiring additional filtration costs.  The Project is likely to lengthen the amount of time that turbid water will be present and discharged to the Hudson River through the lower Esopus to impact these facilities.

The Ashokan Reservoir is an important recreational destination for Ulster County’s strong tourism based economy.  The County recently completed the Ashokan Rail Trail that has drawn over 200,000 visitors in its first year of operation.  In addition, recreational fishing is permitted on the Ashokan that includes the use of non-motorized boats.  Finally, significant important views of the Catskill are available at the Reservoir site.  The Project's impacts on these activities during construction and operation are unknown at this time. 

The Catskill Park where the Project is located is a refuge for many threatened and endangered species. Active acquisition by New York City to protect its water supply and regional and national environmental groups is ongoing within the Project area.  In addition, New York State continues to acquire lands in the area that are protected under the New York State Constitution as forever wild.  Various land use controls and practices exist to protect lands that remain in private ownership. The proposed locations for the upper reservoirs may encroach on these protected areas and even if they do not may significantly impact the ecosystems that exist in these areas of the Catskill Park. 

Wherefore, Dennis Doyle Director of the Ulster County Department of Planning, respectfully requests that the Commission grant my Motion to Intervene as a party with full rights to participate in all further proceedings.

Respectfully submitted on this day of April 6, 2021 (04/06/2021)

Dennis Doyle, Director 
Ulster County Planning Department 
Box 1800
244 Fair Street 
Kingston NY, 12402

Noah Zakim, Franklin Lakes, NJ.
Proposed Hydroelectric Plant at Ashokan Reservoir. 

This project is a terrible idea and should not be permitted to proceed for the following reasons:

The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Arthur Linker, Scarsdale, NY.
I strongly oppose Premium Energy Holdings of Southern California’s proposed a pumped-storage hydroelectric facility within the boundaries of the Forever Wild lands of the Catskill Forest Preserve, which would have negative impacts on the Ashokan Reservoir and surrounding area. This proposal directly threatens the experience of trail users in the Catskill Forest Preserve, the ecological sustainability of the Forest Preserve, trout breeding grounds, the quality of the New York City water supply, and so much more. I also endorse The Trail Conference’s request to be an intervenor to the proposed Ashokan hydro dams.

For the following reasons:
•	The Catskills are a State Preserve protected by the NY State Constitution.
•	The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
•	The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
•	The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
•	The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
•	This plan would increase turbidity and negatively impact NYC’s drinking water.
•	It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
•	Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
•	The loss of tourist dollars and business revenue would directly hurt our communities.
•	The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Lois M Ostapczuk, Shokan, NY.
                                                April 6th, 2021
						69 Ridge Rd.
						Shokan, NY 12481

Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426

Re: Project P-15056 Ashokan Pumped Storage 

Dear Secretary Bose:

I am writing FERC to express my strong opposition to the referenced proposal, plus hopefully providing this agency additional insights regarding it.

To begin with, this proposal is NOT a closed system, but part of New York City’s (NYC) watershed that contains an unfiltered water supply with various stream inflows and outflows, including the Catskill Adequate.  Thus, it is a living body of water that acts as an important source of drinking water for millions of New Yorkers, plus provides recreational opportunities that support the local economy.  I find it disheartening that the applicant, Premium Energy Holdings (PEH), didn’t understand this simple fact, or chose to mislead FERC.

Furthermore, when NYC constructed the Ashokan Reservoir in the early 1900s, it did so utilizing two separate basins, where the western reservoir--- primary location of this PEH proposal--- served as a settling basin for incoming, and sometimes turbid waters.  As part of an effort to avoid water filtration, NYC helped by underwriting costs of minimizing turbid inflows through funding the Ashokan Stream Management Program (AWSMP).  Per information available to the general public, and found online,

“The Ashokan Watershed Stream Management Program was established as a joint effort between Cornell Cooperative Extension of Ulster County (CCE), the Ulster County Soil and Water Conservation District (UCSWCD), and the New York City Department of Environmental Protection (DEP). The three agencies work collaboratively to protect and restore the stability and ecological integrity of streams in the Ashokan Reservoir Watershed. 

Action planning in the Ashokan Watershed began with the development of stream management plans for the Broadstreet Hollow Creek in 2003, Stony Clove Creek in 2004, the Upper Esopus Creek in 2007, and the Beaver Kill in 2015. In subsequent years, AWSMP completed stream assessments of Woodland Creek, Beaver Kill, Warner Creek, Birch Creek, Bush Kill, Bushnellsville Creek, and the Stony Clove Creek was reassessed. 

A Filtration Avoidance Declaration (FAD) granted to NYC in 2007 requires DEP and its partners to develop an Action Plan for the coming year to show how the findings and recommendations of the stream management plans will be implemented.”

Currently UCSWCD contributes twelve million dollars ($12,000,0000) over a rolling five-year period to this effort, of which 62% of this money is devoted to turbidity reduction restoration projects upstream of the Ashokan Reservoir.  This is a significant contribution committed to the reduction of turbid inflows to the Ashokan to protect the quality of the drinking water, which this proposal will adversely impact.

On a slightly different vein, there are some 300,000 annual visits yearly to the Ashokan Promenade along the reservoir, drawn by the beauty of the surroundings.  To be clear, not all of these visits are unique individual visitations, but include some return visitors.  Additionally, there are over 2000 registered rowboats of anglers who utilize the Ashokan for fishing purposes, and this does not include foot traffic of anglers from shore.  Plus, the newly implemented Ashokan Rail Trail (ART) has an estimated 250,000 annual visitors.  On a nice weather weekend parking space is often not available for all those who wish to use the ART.

This proposal is an economic and environmental disaster that flies in the face of all commonsense, directly and adversely impacting all those who benefit from NYC’s Ashokan Reservoir.  Pumping and release of water between two different reservoirs, varying the Ashokan’s levels will keep silt suspended in the water column causing significant, and potentially unhealthy issues with the City’s drinking water.  It will adversely impact the existing fishery, which has been an economic engine for a struggling local economy.  Plus, just the sight of the clean, majestic Ashokan Reservoir against the Catskill wild forest backdrop has brought crowds of anglers, walkers, bald-eagle watchers, nature lovers, and sight-seers who further support the local economy through purchases of gas, food, and gifts.  And this does not include the potential health and financial impacts to the nine million New Yorkers who rely upon the Ashokan Reservoir as a source of unfiltered drinking water.  This project is ill conceived with far reaching economic and environmental impacts.

For these reasons, I urge the Federal Energy Regulatory Commission to deny a permit to Premium Energy Holdings for the referenced project.
							
                                                        Sincerely,
							/s/
							Lois M. Ostapczuk

Hanson Wong, NEW YORK, NY.
I am opposed to the permitting, licensing, or construction of a hydroelectric plant in the Catskills of New York.
(1)	That region is “forever wild” under the New York State constitution
(2)	That facility and its associated transmission wires would deface the land, disrupt the wild environment, and negatively impact the lives of residents and tourists
(3)	That facility may affect the water supply system to New York City.


Hanson Wong
New York City

Amanda Dean, Houston, TX.
I grew up in the NYNJ Trail system, and I visit these trails each year. I OBJECT to building a hydroelectric facility in the Catskills, as this will irrevocably damage the surrounding preserves. I strongly OPPOSE this docket.

Markus Koelbl, West Shokan, NY.
As a resident of West Shokan and New York City I have strong objections to this application based on damage that could be done to the environment upstate as well as my drinking water downstate.

This proposal is an add on project and not a closed loop system as the report claims. I'm not sure why Premium Energy is obfuscating the fact that this is not the FERC desired closed loop project but it surely raised some red flags.

The dmage this will do to a status 1 protected NY forest is huge. I understand this technology is required for sustainable energy projects but it cannot be done in the catskill forest.

Markus Koelbl
Scientist of Water Ecology III
NYC DEP

Judith E Turkel, Olivebridge, NY.
I am a New York State licensed attorney and a 30 year resident of Olivebridge, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity.   I am writing to vigorously object to the proposal and I hereby request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams, have a devastating impact on protected wildlife and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Please do not permit this to go forward - this proposed project, if permitted will cause  permanent and irreparable  damage.

Thank you.

Catherine M Johnston, Willow, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

First, and most importantly, residents of the Catskills have lived here for centuries. However, in recent years, we've experienced a tremendous change regarding our waterways. Frequent hurricanes and heavy rainfall have led to flooding, and FEMA has re-zoned many of our homes. Our waterways are fragile. I cannot stress enough the importance of avoiding all unnecessary change that could directly change the volume of water flowing through our rivers and streams. 

Further, I support the points by SavetheCatskills:

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Cathy Johnston

Deirdre Newman, Jersey City, NJ.
Please deny the request to build a hydro electric plant at Ashokan Reservoir. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.
Thank you!

Mary Ellen Smyth, Rockaway Park, NY.
The Catskills are a State Preserve protected by the NY State Constitution.
The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails.
The road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 
The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms. 
The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience. 
This plan would increase turbidity and negatively impact NYC’s drinking water.
It would cause a significant impact on the streams, affecting fishing, boating, and swimming.
Rerouting Route 214 (a Scenic Byway) would be incredibly disruptive.
The loss of tourist dollars and business revenue would directly hurt our communities.
The plan could limit access to skiing/concerts at Hunter Mountain, Hunter, and Tannersville.

Alexander Archambault, New York, NY.



Alexander Archambault
193 Second Ave Apt. 9
New York, NY 10003

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I’m writing in opposition to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. The Ashokan Pumped Storage Project P-15056, as described, would be devastating to the environment, displace vibrant local communities, and threaten the purity of NYC’s drinking water.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Why now would this pact be breached?

The area around the proposed plan is the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. Why would we destroy this vital land? Once it’s gone, we can never get it back. 

Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Alexander Archambault

Samuel Kalb, Woodstock, NY.
My name is Sam Kalb, I come from Woodstock, NY, and I would like to express my strong opposition to Premium Energy Holdings' Ashokan Pumped Storage project. I am an ecology graduate student and as I have delved into this field of research one point I have come to again and again is how lucky I am to be from the Catskills; very few places still exist in the world like our region. Infrastructure and urban sprawl are creating widespread pest ecosystems, systems where a small number of highly reproductive species dominate due to altered ecosystem processes such as nutrient dynamics. Streams impacted by dams are at extremely high risk for such a transformation; stream ecosystems rely heavily on natural flow regimes for maintaining microhabitats for many species that keep them diverse, and the unnatural uniformity created by dams can cause many of these species to go locally extinct. Large areas of still water are highly vulnerable to eutrophication, the process of nutrient overload that leads to the dreaded "dead zones" seen in regions like Lake Erie. 

I am not a pure preservationist who holds some idealistic worldview that humans should never do anything with negative ecological consequences, nor am I akin to Edward Wilson, the ecologist pushing to preserve 50% of the world's land from human use. I am a realist. What I want to impress upon our decision makers is that the Catskills region where this dam has been proposed is one of the last of a fast disappearing type of landscape, wildland where human communities exist around healthy ecological processes. Travel the United States with an ecologist and you will see just how rare such regions are in a country where urban sprawl is becoming a dominant land cover type. The Catskills represent a future where humans can extract resources from our environment in an ecologically conscious way. A Catskills region with this dam will not have the same character we so love now, and that is a guarantee. Among the proudest parts of being a New Yorker is that our state constitution protects such lands; if our elected leaders and their appointed agents fail to respect such protections, it becomes one more failing of a broad system of powers in which many young people like me are fast losing faith. I have had some faith that our new government may break this long trend of lost faith, and I hope you will prove me right by respecting both our state constitution and the value for a biosphere where humans can live in concert with nature.

The bottom line is this: energy can be acquired from many sources, but healthy forests and streams are a phenomenon that will not long persist if those in power allow projects like this. I would consider it a deep failing to allow the mountain forests that made me who I am to be turned into just one more low-biodiversity dammed watershed.

Samuel Kalb, Woodstock, NY.
My name is Sam Kalb, I come from Woodstock, NY, and I would like to express my strong opposition to Premium Energy Holdings' Ashokan Pumped Storage project. I am an ecology graduate student and as I have delved into this field of research one point I have come to again and again is how lucky I am to be from the Catskills; very few places still exist in the world like our region. Infrastructure and urban sprawl are creating widespread pest ecosystems, systems where a small number of highly reproductive species dominate due to altered ecosystem processes such as nutrient dynamics. Streams impacted by dams are at extremely high risk for such a transformation; stream ecosystems rely heavily on natural flow regimes for maintaining microhabitats for many species that keep them diverse, and the unnatural uniformity created by dams can cause many of these species to go locally extinct. Large areas of still water are highly vulnerable to eutrophication, the process of nutrient overload that leads to the dreaded "dead zones" seen in regions like Lake Erie. 

I am not a pure preservationist who holds some idealistic worldview that humans should never do anything with negative ecological consequences, nor am I akin to Edward Wilson, the ecologist pushing to preserve 50% of the world's land from human use. I am a realist. What I want to impress upon our decision makers is that the Catskills region where this dam has been proposed is one of the last of a fast disappearing type of landscape, wildland where human communities exist around healthy ecological processes. Travel the United States with an ecologist and you will see just how rare such regions are in a country where urban sprawl is becoming a dominant land cover type. The Catskills represent a future where humans can extract resources from our environment in an ecologically conscious way. A Catskills region with this dam will not have the same character we so love now, and that is a guarantee. Among the proudest parts of being a New Yorker is that our state constitution protects such lands; if our elected leaders and their appointed agents fail to respect such protections, it becomes one more failing of a broad system of powers in which many young people like me are fast losing faith. I have had some faith that our new government may break this long trend of lost faith, and I hope you will prove me right by respecting both our state constitution and the value for a biosphere where humans can live in concert with nature.

The bottom line is this: energy can be acquired from many sources, but healthy forests and streams are a phenomenon that will not long persist if those in power allow projects like this. I would consider it a deep failing to allow the mountain forests that made me who I am to be turned into just one more low-biodiversity dammed watershed.

Other formats

Jill Singer, West Shokan, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Jill Singer

Thomas C Konrad, Stone Ridge, NY.
As a local resident who supports clean energy development as an essential part of our transition away from fossil fuels, I believe we should not immediately decide against a project such as the Ashokan pumped hydropower proposal without at least understanding both the costs and the benefits.  Premium Energy should be allowed to do its feasibility study, so that we can make a decision based on facts and evidence, and actually weigh the costs against the benefits.

Larry Federman, Palenville, NY.
    On behalf of Northern Catskills Audubon Society, the 350-member chapter of the National Audubon Society, and whose chapter territory includes the area of this proposal, I offer these comments in opposition to the proposed Ashokan Pumped Energy Storage Project, Docket P-15056.
    The proposed project is located within the Catskill Peaks Important Bird Area (IBA), identified by Audubon New York as one of the largest contiguous forest tracts in the state.  The area was given IBA designation due to the presence of high-elevation breeding bird species, such as Bicknell’s Thrush and Blackpoll Warbler, as well as home to the suite of lower-elevation forest nesting birds.  Many of these are considered species of Special Concern or Threatened in New York State, or Species of Greatest Conservation Need and include American Black Duck, Osprey, Bald Eagle, Sharp-shinned Hawk, Cooper’s Hawk, Northern Goshawk, Red-shouldered Hawk, Peregrine Falcon, American Woodcock, Olive-sided Flycatcher, Wood Thrush, Scarlet Tanager, Cerulean Warbler, Black-throated Blue Warbler, and Canada Warbler. In addition to state protections, Bald Eagle is afforded federal protection under the Bald and Golden Eagle Protection Act. The Ashokan Reservoir, as part of the IBA, is an important site for wintering waterfowl and it is unknown how water depth fluctuations from this project would affect those birds. 
    Permanent protection of this IBA is of utmost importance to protecting the aforementioned species. This project, if approved, would fragment the forest to the detriment of those species, as well as species currently not identified as in need of protections.
    We urge FERC to stop this project before much time and money are needlessly spent, given that further, detailed negative environmental effects that will certainly be identified in an EIS if the project is approved to move to the next step.

Sincerely,
Larry Federman
President, Northern Catskills Audubon Society, Inc.

Norman Baron, Olivebridge, NY.
To Whom it May Concern:

I am writing in protest of the proposed Ashokan Pumped Storage Project for which  you have received a Preliminary Permit Application.  It is inconceivable that such a project has even been suggested for our quiet, pristine country location.  The effect of such an undertaking would completely change the character of our local communities and environs.

In the Town of Olive there is currently a civil ongoing discussion about just how the town should control development.  There is no doubt in my mind that if this project is approved the citizenry of Olive will be completely united in doing all that it can to prevent the first shovelful of rural earth to be disturbed. Many citizens of the Town of Olive are still smarting from the Ashokan Dam project which flooded and destroyed Olive City and Olivebridge.  That project was completed 115 years ago, yet remains a serious bone of contention in Olive. The proposed project brings the Ashokan Dam project to the minds of the citizens of Olive, New York.  Please deny the Preliminary Permit, help us preserve our communities and environment and make unneeded what is certain to be a powerful and universal objection to the proposed Ashokan Pumped Storage Project. 

Thank you,

Norman Baron
24 Spruce Hill Road
Olivebridge, New York 12461

Emilio Pardi, Phoenicia, NY.
Emilio Pardi - Phoenicia, NY resident. emiliopardi@yahoo.com / (845) 688-2824
Re: FERC docket number P-15056-000

To Whom It May Concern, 

     I am writing to express my strong opposition to Premium Energy Holdings, LLC’s proposed Ashokan Pumped Storage Project. As a lifelong resident of Woodland Valley, in Shandaken/Phoenicia, New York, I am deeply disturbed by the idea of Premium Energy Holdings, LLC turning my home into the proposed “Woodland Reservoir.” A California-based company, despite its good intentions of promoting renewable energy, cannot be allowed to enter a New York State-protected mountain preserve for the sole purpose of providing additional energy capacities. Not only would the proposed dam and reservoir increase turbidity in the Ashokan Watershed, thus drastically reducing quality levels for NYC’s primary water supply, but it would be devastating to our local communities and economy. Such proposed reservoirs will displace hundreds of residents by flooding/raising their homes. Although my own home is in the directly affected area, I am writing on behalf of my community and neighbors, many of whom settled here decades before I was born. 

     The Woodland Valley stream, which feeds into the broader Esopus Creek and Ashokan Reservoir, is an ecologically diverse area that is home to protected species of fish, birds, plants, trees, and animals. I have spent countless days walking along its banks, swimming in its currents, and simply admiring its natural beauty. Over the past year, the Valley has been my place of respite from the ever-ravaging COVID-19 pandemic. These same qualities, stories, and uses are true of all three proposed site areas, and Premium Energy Holdings must recognize that their destruction is neither viable nor ethical. In 1885, the Catskills Forest Preserve was established by the State of New York as a primary habitat in Ulster County. Under Article XIV of the NYS constitution, the lands were provisionally said to be “forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  
     As our area developed, this environment has become increasingly fragmented and strained. No dam or hydroelectric power plant can be created in this region without disrupting, and likely causing catastrophic damage to, the natural lands. All three proposed reservoirs fall directly within Audubon’s Catskill Peaks Important Bird Area, as well as having Status 1 land protections under USGS “Gap Analysis Program.” Accordingly, the Department of Energy’s own Hydropower Vision plan states that areas with “Status 1 or 2 protections are avoided for development proposals.” To avoid the legalities of such protections, Premium Energy Holdings is touting this as a “closed-loop” project. Simply put, this is an outright lie. All projects that add an upper reservoir to an existing lower reservoir are known as “add-on” projects. 
     Finally, this is not the first time our region has been disrupted by an outside entity wishing to transform our lands into assets for the benefit of others. Construction of the Ashokan Reservoir, between 1907-1915, displaced more than 25 existing communities spread out over thousands of acres so as to create an abundant water supply for New York City. Aside from the ensuant environmental devastation and emotional trauma, the impacts of the construction are still felt today. Specifically, a decreased tax base has hindered the maintenance of public infrastructure as well as decreased the availability of public services. With the rise of Catskills tourism, prompted by events such as the Phoenicia’s Top 10 Coolest Small Towns in America ranking, our region is now home to a $1.6 billion industry that employs over 20,000 people. As of 2019, second homes generated $360 million in economic activity, and this number has skyrocketed in the past year as thousands of metropolitan homeowners relocated to the Catskills. 
     Thus, I urge FERC to strongly oppose any further considerations of this project. Premium Energy Holdings, LLC must be denied the rights to initiate any construction in the Catskills. For any additional questions, please do not hesitate to contact me. Thank you for your consideration. 

Sincerely, 
Emilio Pardi

Brian Scanlan, Wyckoff, NJ.
This project would create a concrete water storage facility at one of three places:

In Lanesville, NY  by damming Stony Clove Creek along Route 214 creating a water storage facility  of 245 acres

In Phonecia, NY by damming Woodland Valley Creek from Pantherkill Road up to Fawn Hill Lane, creating a water storage facility  of about 313 acres

In West Shokan, NY by damming Maltby Hollow Brook along Moon Haw Road, creating a water storage facility of about 226 acres

As a long-time homeowner in the region and a strong proponent of renewable energy, I am writing to express my opposition to this project. This project is massive and, if constructed, will severely damage whatever local stream is picked for the dam. As a trout fisherman, I recognize that it would significantly damage the ecology of an area that has been long been preserved by the constitution of the State of New York and local and state laws. Much of this area is pristine wilderness and its smaller streams are spawning habitat for  the native trout which are a very vital part of the natural food chain. In addition, I’m concerned (as I work frequently in New York City and use its water supply) about a negative impact on its water supply because of the connection of the project to the Ashokan Reservoir.

This is NOT a closed loop project. It’s an add-on to an existing reservoir.  This project  is not the kind of “innovation” DOE needs. If approved, it will take years to construct, and will be a net consumer of energy once in operation. It’s inherent inefficiency creates the specter of a stranded asset in the future.  The DOE ought to be investing its resources into large-scale battery storage, not this 19th Century technology.

It is vital that FERC prevent this project from moving forward.

Thank you for your time and consideration.

Jack C Pliskin, Brooklyn, NY.
I am vehemently opposed to this application made by Premium Energy Holdings.  The application and the project about which it relates contain many flaws, among the gravest being:

(A) The project's location in a state preserve protected by the state's constitution;
(B) The project would cause increased turbidity in the Ashokan watershed and negatively impact New York City's drinking water;
(C) The project would be detrimental to the local communities surrounding the project causing disruption to the local economy and displacing residents.

Respectfully submitted,
Jack Pliskin

Edward Butler, New York, NY.
The Catskills are a State Preserve protected by the NY State Constitution, to be  "forever kept wild" and not "leased, sold or exchanged, or be taken by any
corporation, public or private." Moreover, the Preserve is in an increasingly
fragmented environment. This project would increase turbidity in the Ashokan Watershed, leading to a loss of trout breeding habitat and negatively impacting New York City's drinking water. It would be detrimental to our local community by disrupting the tourist economy and displacing residents. I urge rejection of the proposal.

Kathryn F Kassner, Red Hook, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am opposed to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
As a climate activist I support clean hydroelectric power over fossil fuels.  While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. 
In addition to damaging local ecosystems this project would be damaging to the local economy that relies on tourism for revenue and jobs.  The natural beauty and opportunity for outdoor recreation draw many to the area and is enjoyed by those of us who live nearby.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see.  Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval.  This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. 
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Kathryn Kassner

Dan, Willow, NY.
This is not at all a closed loop project, and not at all what the DOE is explaining as the type of project or proposal they're interested in supporting. Not to mention, you're literally choosing sites for an add-on project in a U.S. Forest Preserve. The effort to fight this proposal even 5 years out is heated here locally, to put it mildly. 

Dan Kennedy

Jane Simmons, Mt Tremper, NY.
This proposal is shocking, outrageous and totally ill considered! And it shows NO knowledge, respect or concern for the Catskills and its people—and NYC. Clean, fresh water is the Catskills greatest resource. Which is why we have fought so hard against fracking—and won! Our tourist industry is dependent on that water, for fishing and so many other recreational activities. In addition, the Catskills has many family farms, and fresh water is crucial for livestock, cows, sheep and increasingly alpacas and horses, and of course, it is also necessary for agriculture. The Catskills are America’s first great wilderness, lost in the 19th century to other irresponsible uses, such as the destruction of the hemlock forests by the tanning industry. Due to protections, such as codifying the Catskill Park as Forever Wild in NYS law (and how does this irresponsible proposal get around THAT?), the Catskills and its waters, which were thoroughly polluted by past egregiousness, have revived. Our streams and rivers offer some of the best fly fishing, as the trout, along with many mountain critters, such as the white-tailed deer and black bear, have returned with our reforested slopes and clean water. Our waters also, and crucially,  supply drinking water to New York City, and the Ashokan Reservoir is the main reservoir whose sweet, clean waters flow to downstate. This project would put that water supply at risk!  And according to one article, the NYDEP, in addition to the Catskill towns concerned, was not even notified? And according to the same article, a Catskill town would be flooded for this? Absolutely not! That happened to too many villages to build the reservoirs. Catskillers, folks native to this area and the many downstaters now increasingly living here—and lots more have moved here due to the pandemic—simply won’t stand for this. This project would alter the hydrology of our local waters, the Esopus Creek, for starters, affect the quality of our water for recreational and drinking uses, both on a personal and commercial level, and also—and just as important—impact our wildlife, which has struggled and finally succeeded in making a comeback here. The Catskills, as anyone making such an irresponsible proposal, soon learns, are home to many committed, passionate and EFFECTIVE grass-roots environmental groups and individuals who will resist any such efforts that would result in compromising in any way our precious natural resources. My vote is a resounding NO!

Jonathan Burn, Chichester, NY.
April 3, 2021

Jonathan Burn
10 Park Road
Chichester
New York, 12416


Dear Sirs:

FERC Ref: Premium Energy Holdings: P-15056

As a resident of Chichester NY in the Catskills, not far from the Ashokan Reservoir, I have reviewed what information is currently available on the proposal by Premium Energy Holdings  (P-15056) to build a Pumped Storage Hydropower project in the Catskills Forest Preserve.  This proposal appears to be deficient in a number of crucial ways.  

Firstly, it is proposed to build this within the boundaries of the Catskill Forest Preserve.  This represents over 700,000 acres of contiguous highly preserved land, in existence for over 135 years, and considered to be in the top 1% of New York State’s forest habitats.  Importantly, as a State Forest Preserve this is considered to be Status 1 land by the USGS and, according to the Department of Energy’s Hydropower Vision report, Status 1 lands are areas to be avoided for development.  Premium Energy’s proposals demonstrate no awareness of this and in fact appear completely contradictory to the objectives of the Department of Energy.

Secondly, Premium Energy’s proposal describes the project as a Closed Loop System, which it clearly is not.  The underlying concept of the pumped storage facility uses the Ashokan Reservoir as the lower basin, and the Ashokan is a reservoir with an inflow from the Esopus creek and other surrounding water sources, and an outflow into the New York City water system.  I understand that Department of Energy is a supporter of Closed Loop projects on the basis of their reduced environment impact.  This proposal should not be considered as such, and in fact the misrepresentation on the part of Premium Energy calls into question both their capabilities and their motivations.

Lastly, and as noted above, the Ashokan forms part of the New York City water supply, and in fact is the pivotal reservoir in that system, with over 40% of New York City’s water flowing through it.  The Catskill/Delaware Watershed and the network of reservoirs and rivers it contains, represent the largest unfiltered water supply in the nation, supplying a billion gallons a day to over 9 million people.  The Ashokan provides a crucial sediment settling basin within this system, allowing sediment flowing downstream to settle in the western portion of the reservoir, where Premium Energy propose to build their Open Loop project, prior to flowing to the eastern portion of the reservoir and hence via aqueducts directly from there to New York City.  The rapid flow of water and significant water level changes inherent in a pumped storage hydropower plant would have a hugely detrimental impact on the reservoir’s primary purpose of water supply and on the turbidity of the water provided to over 9 million people.

By proposing to build this Open Loop Hydropower facility in a State Forest Preserve and the New York City Watershed, and significantly impacting a critical part of the New York City water system, Premium Energy have demonstrated a fundamental lack of understanding of the environment in which they propose to build.  This proposal should be rejected at this stage and not allowed to proceed.

Sincerely,

Jonathan Burn

Andrea Shallcross, Chichester, NY.
April 3, 2021

Andrea Shallcross
10 Park Road
Chichester
New York, 12416

FERC Ref: Premium Energy Holdings (P-15056)

Dear Sirs:

As a resident of Chichester NY, I have reviewed the proposal by Premium Energy Holdings (P-15056) to build a large dam, reservoir, turbine and tunnels (collectively “dam”) in the Catskills Forest Preserve.  

I want to draw attention to the fact that the each of the proposed sites for the dam are located on lands that, under Article XIV of the NYS Constitution, are designated to be “kept as wild forest lands.” The Article goes on to say that: “They shall not be leased, sold, exchanged or be taken by any corporation, public or private”.  Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature and then submitted to the public in a referendum. In order to avoid that, and for this plan to go forward in any manner, FERC would have to force the state of New York to condemn state land.  A case about this very matter is currently under review by the Supreme Court. [PennEast Pipeline Co. v New Jersey]. The primary issue of the case being: 

Whether the Natural Gas Act delegates to Federal Energy Regulatory Commission certificate-holders the authority to exercise the federal government’s eminent-domain power to condemn land in which a state claims an interest

In addition to the protections afforded by the state constitution, the areas slated for possible location of the dam also comprise the catchment area for the New York City water supply (supplying approximately 1 billion gallons of water a day for use by 9M New York City residents) and are within the New York City Watershed. Such a massive construction project in this area would disrupt that water supply in many significant ways.

Additionally, as a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis” Program.  According to the Department of Energy’s Hydropower Vision, Status 1 lands are areas to be avoided for development.

Considering all of the above, Premium Energy Holdings’ failure in its proposal to indicate the Status 1 designation of the land selected for development, or that all of the selected possible sites for the dam are located within the catchment area for the New York City water supply, suggests both poor research and a profound ignorance of the actual nature of the land chosen for development.  As such, it seems that allowing this project – posited as it is on such a deficient understanding of the status of the land per the State constitution – a preliminary license would be ill-advised since any actual construction in the cited areas would be subject to strong and well-founded challenges and, almost certainly, to strong legal challenges not least by the State and by New York City.  Based on the foregoing facts, I strongly contend that this project should be disallowed at the earliest opportunity.

Sincerely, 

Andrea Shallcross

MICKEY KRUEGER, New York, NY.
I am opposed to this project.  please help protect our public lands by moving this project to the vast area that does not disturb the balance of nature and the public who enjoys it.

Renee Smith, Killingworth, CT.
I am writing in opposition to Premium Energy’s proposal to build an upper reservoir to the Ashokan Reservoir in the Catskill Forest Preserve.  
I urge FERC to REJECT the application for a feasibility study for this proposed project.  The proposed locations for this project make no sense for the following reasons:

1.	First, and most important, it would be a long, expensive legal battle because the proposal is for a project inside the boundaries of the Catskill Forest Preserve.  In 1885 a law was passed by the NY State Congress which established the Catskill Forest Preserve. From the beginning this land was protected by the State constitution as ‘Forever Wild’ land, never to be subjected to development or extraction of natural resources.   ARTICLE XIV Section 1 of the Constitution begins as follows:  “The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private”.  Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.  As of 1999, more than 2000 amendments had been proposed. Only 29 made it to the referendum stage, and 20 of those passed. 

2.	This proposal is for an ADD-ON OPEN-LOOP system.  According to the Department of Energy’s own document, Pumped Storage Hydropower FAST Commissioning Technical Analysis, June 2020, “The closed-loop configuration is being favored by regulators and developers alike because it minimizes environmental impacts on watershed ecosystems and provides unconstrained flexibility to provide grid benefits.”  It also states, “Open-loop projects are often subject to lengthy environmental reviews and long-term monitoring to ensure the connection to a naturally flowing water feature produces no significant environmental impact to the local aquatic ecosystem.”

3.	The area in question qualifies as Status 1 under the USGS Gap Analysis Project.  Meaning, “An area having permanent protection from conversion of natural land cover and a mandated management plan in operation to maintain a natural state within which disturbance events (of natural type, frequency, intensity, and legacy) are allowed to proceed without interference or are mimicked through management.  Examples of Status 1: National Parks, Wilderness Areas.” It is also my understanding that the proposed sites are a Status 1 area according to the USGS Gap Analysis, and that DoE prefers to avoid projects that are on Status 1 land.

Certainly there are numerous other reasons why I personally object to this project, as I have a home in West Shokan built by my great-grandfather.  I fully understand the need for alternative energy and to get away from fossil fuels.  This is one reason why I am a strong supporter of nuclear power.  While hydro pump projects can also be an important part of the energy storage puzzle, the sites in Premium Energy’s proposal make no sense whatsoever.

Thank you for reading and acknowledging my comments.

Renee Smith

Joel Sperber, Ulster Park, NY.
I am opposed to the Ashokan Reservoir hydroelectric proposal. I, and many local residents and sportsmen argue that the proposal would negatively impact the quality of the NYC drinking water, the pristine habitat of our trout hatchery, and  natural environment. The proposal clearly does not add to the quality of life for our NYS tax-paying citizens. All around, it is an unnecessary and bad idea.

Cody Kostro, New York, NY.
This proposal would be disastrous for the community and has not been properly vetted. I urge you to
recommend that Premium Energy's proposal be rejected. 

Thank you,
Cody Kostro

Dr. Peter Mark, Oneonta, NY.
Dear Sirs and Mesdames:

	I write to submit my opposition to docket number P 150-56000, the proposal by Premium Energy of California, to construct a dam and two holding basins in the Catskill Mountains State Forest Preserve. if approved, This proposal, submitted by an out-of-state corporation that has no responsibility to the taxpayers and citizens of New York State, would impact land that is set aside by the NYS Constitution as forever wild, for the benefit of New Yorkers.
	As an historian and a naturalist writer, I have visited, written about, taught college students about, and enjoyed the Catskills for nearly 60 years. My family own two homes in the Catskills. To see an outside corp[oration come in and threaten to destroy our pristine mountain environment is unacceptable. The affected territory is Status 1 land; it should therefore fall under constitutional protection from such development.
	As the recent and ongoing public health crisis has demonstrated so clearly, we all need the wilderness even more than we had imagined. This proposal for a hydro facility would be counter to all of our heightened concerns for the environment. The project of Premium Energy must be rejected.
	Thank you for your consideration. You may write to me at: 
			
			9 Franklin Street
			Oneonta, New York 13820

		Sincerely,

		Dr. Peter A. Mark

Mary Mistler, HURLEY, NY.
Ms. Bose,  I am writing to oppose the application of Premium Energy Holdings for construction of a pumped storage facility on the Ashokan Reservoir and lands in the Ulster County Catskill region. This land is part of the Catskill Park Forest Preserve, established in 1885, and enshrined in the New York State Constitution, to be held “forever wild,” and as such, is extremely environmentally sensitive, rated as Status 1 in the USGS Gap Analysis Program. The proposed construction should therefore, according to FERC’s guidelines, be prohibited on these lands. 
Further, the application by Premium Energy is inaccurate in that the proposed project is not a “Closed Loop” system as the application indicates. The basins of the Ashokan Reservoir feed into the Esopus Creek which continues on to the Hudson River, making it an “Open Loop” or “add-on” system. 
It is also unclear how the Reservoir, part of a public water supply system, can be used in such a project. Does this water supply not belong to the taxpayers of New York? Construction of this proposed pumped storage plant, using water pumped from the Reservoir’s basin, disturbing all the sediment at bottom, would create increased turbidity in the water supply, disturbing the downstream ecology.  And during the lengthy construction period of such a large project as this, with its tunnels, reservoir and dam, there would certainly be runoff of pollutants into the watershed. These disturbances might endanger the water quality and require the City to build an enormously expensive filtration system. And it is unclear what effect the constant pumping in and out of water might have on the existing dams on the Ashokan Reservoir, constructed in 1907-1915.  A failure of these dams would be catastrophic, and impossible for any company to mitigate or remedy.
In terms of the local history, in 1907, many families lost their lands and farms in the Esopus valley and there is still lingering feeling in the residents about what was done here. Perhaps Premium Energy, based in California, is not aware of this history and does not understand that the proposal to repeat history in flooding another valley in this area would be extremely controversial. 
I am, therefore, requesting that this proposed project application be denied by the Federal Energy Regulation Commission in the interests of the people of New York. 
Thank you for your consideration.

Donald J. Brown Jr., Phoenicia, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.
While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.
In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.
As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?
Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Donald J. Brown Jr.
963 Woodland Valley Road
Phoenicia, NY 12464

Janet Siskind, Accord, NY.
I urge the commission to reject the preliminary permit application for project P-15056.  This project is ill conceived in many ways, three of which are as follows:

Legally:  the Catskill Forest Preserve is protected in perpetuity.  This project will not stand up in a court case, no matter the amount of legal fees it can afford.

Politically:  any possible turbulence of the Ashokan Reservoir or disturbance to the Catskill watershed threatens a major source of New York City’s water supply.  The protests would be massive.

Economically:  the only major industry in this region is its tourist industry.  The construction and continuing operation of this project would adversely effect the area’s natural beauty and quiet  upon which tourism is based.

Sharon Sofranko, West Shokan, NY.
I am a resident of the Town of Olive, Ulster County, New York where the Ashokan Pumped Storage Project (P-15056) by Premium Energy LC is proposed to be located. The proposed upper Wittenberg Reservoir is located on NYS constitutionally protected Forever Wild lands. In addition, the project proposes damming the Maltby Hollow Brook Stream, a protected trout spawning stream.
 
I oppose this project on these grounds and object to the insensitivity to the people of the Town of Olive who have for generations have sacrificed their land and livelihoods to protect the drinking water of NYC in the Ashokan Reservoir. This is not a project the town can viably sustain as the scope and scale of this project will detrimentally change the landscape and quality of life of our town forever.

Nancy Caigan, Woodstock, NY.
Hello-
Please reject this application for any permit due to the following important points-
The Catskills are a State Preserve protected by the NY State Constitution
It would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water
It would be detrimental to our local community by disrupting our economy and displacing residents

We the local residents strongly object to this proposal.
Thank you

Monica B Harrington, Olivebridge, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number:
P-15056-000

Dear Ms. Bose,

I am writing to comment on the application by Premium Energy Holdings for a preliminary permit to build a hydroelectric power plant in New York’s Catskill Mountains: Ashokan PSP P-15056. I urge FERC to decline this request. Sustainable energy is important to me, but this plan on the whole is not sustainable for the local environment, economy and community. The proposed project will have many negative impacts, but I will focus on three of them.

1. The proposed project area is within the protected Catskill Forest Preserve. This is Status 1 land under the USGS Gap Analysis, which – according to the DOE’s Hydropower Vision – should be avoided for development. The 700,000-acre Preserve comprises unique continuous wildlife habitat (and falls within an Audubon Important Bird Area) and pristine forest (top 1% in the region according to the New York State Forest Condition Index). The impacts of the proposed project are greater than Premium Energy is claiming, because this is not a closed-loop system as they represent, but an add-on to an open system. (This also means the proposal is not eligible for streamlined FERC approval.) Disruption of this valuable habitat must be prevented, yet the proposed project will irreparably damage the ecology of the area by causing rapid fluctuations in water levels and continuous disturbance of sediments – not to mention the additional harm caused by the construction/development processes themselves.

2. The proposed project will negatively impact tourism and those who work in the $1.6-billion industry – roughly 20,000 or 17% of jobs - in an area already hit hard by the coronavirus pandemic. Premium Energy’s project will restrict access to hiking, fishing, skiing, and other forms of recreation and decrease the natural beauty, stifling tourism in the region, which has already been reduced by the coronavirus pandemic. This could cause many local businesses to close permanently.

3. The proposed project will further damage the economy and community by eliminating homes, in addition to jobs. Adding a reservoir site in the Catskill Forest Preserve will require the seizing of homes and private property via eminent domain. These displaced residents will have a hard time securing new housing, given the shortage of housing – especially affordable housing – in Ulster County. 

We need sustainable energy, but not at the expense of sustainable environments, economies and communities. I hope Premium Energy will be able to find a suitable alternative location for their pumped storage project — where construction and operation will not destroy protected wilderness and natural resources, devastate local economies, and displace vulnerable communities.

Please understand the true impacts of Premium Energy’s proposed project and deny their preliminary permit for the Ashokan PSP P-15056.

Thank you,
Monica Harrington

Virginia Loughlin, Ossining, NY.
Dear Ms. Bose,

A a frequent traveler to the Catskills, I'm writing in response to the highly problematic proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. In addition, as one who hikes frequently in this area, I can assure you that this project would compel me to go elsewhere. When I hike, I buy meals at local bakeries, restaurants, breweries, and coffee shops. In addition, I shop at the beautiful area craft shops, bookstore, and cycling store. All these places would lose my business and those of the many hikers and outdoor enthusiasts who enjoy the natural beauty of this area.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Virginia Loughlin
Ossining, NY

Peter McKnight, West Hurley, NY.
To:

Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

There is deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. 

I'm strongly urging FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

Normally I would be encouraged by a pumped storage project to help our country’s transition to renewable energy. However the forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. 

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

The Preserve currently contains 700,000 acres of continuous wildlife habitat, and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. 

One negative effect is the alteration of the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

Further, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

It should also be pointed out that this proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. So while Premium is claiming this project to be “closed-loop”, their project actually is an “add-on,” using an existing body of water as a lower reservoir. 

I urge Premium Energy to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

And I urge you to deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Peter McKnight

Bill Faiella, Beacon, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, Bill Faiella

Sue Story, West Shokan, NY.
This proposed project is certainly going to disastrously affect the aquifers as well as drinking water. Another result will be wells drying up.

The construction will not only destroy homes, it will wipe out a good part of the local environment as well. Those residents who won't be forced to move will have to endure all the noise and disturbances involved in constructing something of this magnitude, not to mention pollution caused by the machinery and construction debris.

Olive endured the destruction of several villages by the early 20th century construction of the New York City reservoir. It's taken Olive's inhabitants a full century to adjust to having this in our midst--and it still causes inconvenience to the residents of this township.

Dangerous high voltage wires are going to be above ground in an area where we already have more than the average amount of power outages due to above-ground wiring. This construction will only serve to increase outages.

It is definitely not going to be cost effective, which means the consumer will have to make up the difference. 

It will have an adverse effect on the townships of Olive, Shandaken and Woodstock, areas already badly affected by the influx of outsiders from NYC and other downstate areas. Much of the wild land has already been wiped out by the homes built by these newcomers. 

Suggestion: Go where there is no habitation for miles and miles and stay out of the Catskills. We've been through enough because of "outsiders."

S. Chasse, Willow, NY.
To whom it may concern,

This comment is in opposition to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

The disruption resulting from both construction and implementation of this project would be harmful to the natural, protected environment and disruptive to local communities. 

As a State Forest Preserve, the Catskills are considered Status 1 land
under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own
Hydropower Vision, “areas with formal protections designated as Status 1 or 2
under the USGS Gap Analysis Program are avoided for development.”

Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any
corporation, public or private.”

To allow such a project to occur would not only harm wildlife, protected land, local residents, and tourism, it would set precedent for potential future projects of this kind. The serenity of the protected Forest Preserve was a primary reason we purchased our home in the Catskills in 2015, as so many others have done for decades.

My wife and I hope you will deny Premium Energy Holdings' request for the preliminary permit for the Ashokan Pumped Storage Project P-15056 and halt any potential for this project to occur.

Sincerely,
Scott Chasse
62 Ostrander Rd, Willow, NY

Sue Fuirst, Chappaqua, NY.
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Susan Greene Fuirst

Devon Russ, West Kill, NY.
April 2, 2021

Re:  Project Docket:  P-15056

Hello, 

I am writing to comment on the Preliminary Permit application entitled the Ashokan Pumped Storage Project.  

I live only a few miles from the proposed Stony Clove reservoir, and I am also very familiar with the proposed Wittenberg and Woodland Valley sites.

I think the project would be terribly destructive in any of these proposed sites.  

The High Peaks area of the Catskills State Park is a well-loved recreation area for many, and a rare bit of wildness within reach for day trips from some of our most densely populated cities.  It would be a shame to diminish this with an industrial project.  Hikers and skiers in the Catskills would have views interrupted by transmission towers, anglers would have streams disturbed,  and all users and residents would have our narrow valleys disrupted for years  by construction traffic and noise.

I think this proposal should be denied.  I am afraid that if Premium Energy is granted permission to invest $5m in feasibility studies, that $5m will be like a ratchet, making it that much harder to deny a permit in the future.  This proposal clearly conflicts with existing recreational and environmental use of the area, and it should be denied now. 

Thank you,
Devon Russ

Yuri Okumura, Stone Ridge, NY.
I am a property owner and resident of Stone Ridge, NY in Ulster County and New York City. I am strongly opposed to the proposed Ashokan Pumped Storage Power project for several reasons: this project (i) is an illegal project as it violates Article XIV of the New York State Constitution; (ii) will harm wildlife and preserved lands in upstate New York, which lands must be preserved for future generations; (iii) is highly likely to harm the drinking water in New York City and it is difficult to source clean drinking water for the millions of people residing ther; (iv) will harm other streams and waterways in the area with sediment, etc. (v) creates a net use of energy does not make any sense (using more than it generates);  (vi) requires building a new reservoir and dam which is damaging  as per the preceding and means that it is NOT "closed loop" and will therefore have a greater impact on the environment than Premium Energy is claiming; (vii) this area of the Catskills is close to New York City and has increasingly become a tourist area and an area sought after for its beauty and outdoor recreation, a large project like this will create blights on the land and will greatly dampen that enjoyment - note that Kingston New York, Marbletown, the Hunter/Windham area have had huge increases in property values in the last few years as more people seek affordable ways to seek recreation and/or live near metropolitan areas in pristine lands. If this project attempts to move forward it will be fought vigorously on the courts, as it should be.
Please DO NOT allow this project to move forward.

Evangeline Murphy, Earlton, NY.
The Catskills have been protected by NYS constitution to keep it wild forever. This dam will not only affect the lives of those living in NYC's drinking water (and everyone in close proximity), but it will ruin land that was intended to be spared forever. This land is home to thousands, humans and wildlife alike roam these mountains for peace and a good life. This project would ruin so many ecological systems, will end up killing wildlife, and would be taking on of the most sacred spaces in NYS and making it just another for profit. I understand that the intentions are not to do harm, but that is exactly what this project would do. I beg you not to go through with it.
Sincerely,
Someone who knows the magic of the Catskills.

Charles Gadol, Highland, NY.
My name is Charles Gadol, MD.  I reside at 555 Plutarch Rd, Highland, NY, 12528.  I am writing in opposition to the preliminary permit application of Premium Energy Holdings, LLC, docket # P-15056 for the Ashokan Pumped Storage Project in Ulster County, NY.
I am currently a staff pathologist for Westchester Medical Center working at Health Alliance in Kingston, NY, and as medical director of the laboratory at Margaretville Hospital, an acute care access hospital close to the project area.  Also, I serve on the board and as a trail maintainer for the New York New Jersey Trail Conference.  The Trail Conference is a 501(3)(c) organization of staff and volunteers which maintains and develops over 2100 miles of trails between and including New Jersey and the Catskill Mountains.  Additionally, I am co-owner of wtf racing, LLC, which organizes and directs two popular long distance trail races in the Catskills; one is a 54 mile long race from Windham to Phoenicia, and the other is a trail marathon in the Slide Mountain Wilderness Area.  These races could become impossible if dams proposed as alternatives one and two are completed.
The dam proposed as alternative #1 creating Stony Clove Reservoir would destroy residences in Lanesville and interrupt/divide Rte 214, which is the major road connecting the northern Catskills, the town of Hunter, and Rte 23A with Phoenicia, and a major east/west highway, Rte 28.  Rte 214 traverses a deep gorge in the mountains with steep slopes on either side of the roadway.  Interruption and destruction of Rte 214 would prevent access to the NYS-DEC Devil's Tombstone campground and to trails in this area, especially including the famous and popular Devil's Path.  Residents in this area routinely use Rte 214 to get to shopping in Hunter.  Hunter and Belleayre ski centers are also accessed by Rte 214.  Bypassing Rte 214 using other roads requires driving many extra miles along roads which can be closed during winter and have been recently closed due to flood damage.
The dam proposed as alternative #2 creating Woodland Reservoir would destroy numerous residences in the Woodland area, inundating and interrupting Woodland Valley Rd., a dead end road, and blocking access to additional homes and property.  Woodland Valley Rd. leads to a very popular NYS-DEC campground at its terminus.  This campground area has at least two very popular and heavily used trailheads accessing trails in the Burroughs Range as well as the Long Path hiking trail, and trails in the Giant Ledge-Panther Mountains.
Alternative #3 creating the Wittenberg Reservoir would close Moonhaw Rd, another dead end road, destroying and isolating multiple residences.  Although no official trails begin in this area, the end of Moonhaw Rd. is used for backcountry access to several high peaks which see a lot of foot traffic (Friday, Balsam Cap, Lone and Rocky Mountains).
The areas impacted by the proposed alternative dam sites, and indeed the entire Catskill area, are heavily dependent on tourism.  Tourism has increased dramatically in recent years and especially during the pandemic.  Closure of major roads and disruption of trailhead access caused by the proposed dams and reservoirs would significantly impact tourism prospects and could be a death blow to a traditionally economically depressed area.  The disruption and unsightliness caused by construction of tunnels and transmission lines would also be damaging to tourism.  Loss of homes and livelihoods for area residents would also be disastrous.
The need for increased power and generating capacity in the Hudson Valley has not been demonstrated.  This area includes lands preserved as wilderness and wild forest, a widely dispersed population with small towns and cities, some light industry, and a strong agricultural component to the local economy.  Any new energy challenges should be met by renewable energy sources according to the recently passed NY State Climate Leadership and Community Protection Act.
As described earlier, closure of either Rte 214 or Woodland Valley Rd. would be detrimental to the trail races that I operate, which are permitted by NYS-DEC, preventing travel to and access to different parts of the race courses.  This could especially present issues regarding safety and communications, as well as providing aid to participants.  These races bring several hundred people into the area annually, producing additional benefit to the local economy.
In conclusion, I urge you to deny the preliminary permit application of Premium Energy Holdings, for all the reasons I have presented.  Thank you for the opportunity to comment on this application.

Elizabeth Scott, Stone Ridge, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Matt Kobussen, Phoenicia, NY.
In Reference to: FERC Project and Subdocket Number: P-15056:000

My wife and I moved to the Woodland Valley as full-time residents in March 2020. The pandemic brought added challenges to living in New York City and we found ourselves with limited options to turn.


We bought our cabin in the protected Catskill Forest Preserve a year earlier to enjoy one of the most natural, ecologically significant areas in all of New York State. Its historical significance to trout fishing, fresh natural water and camping all create an ecosystem that is both a wonderful place to live, but it also attracts a growing number of tourists from throughout New York and surrounding states to the Woodland Valley area.


Since moving permanently to the area, it’s become even more clear how important the tourism is to maintaining local businesses and creating jobs. People travel from hours away to explore the trail heads accessible from the Woodland Valley campground, which was developed in the 1930s and is one of New York’s oldest camp sites. More than 5,000 people each year come to this area for the natural beauty and hiking trail experience, which then leads them to the surrounding businesses, restaurants, coffee shops, hotels, gift and apparel stores, and more.


As a $1.6 billion dollar industry in the Catskill region, it creates close to 9,000 jobs in the Ulster County area alone. Unemployment rates are also on the decline with more people fleeing New York City for space and more time outdoors. In April 2020, at the very beginning of the pandemic and a pivotal point in the year for tourism uptick, the unemployment rate rose to 14.6% - up from 4.2% just two months prior. Since then, the unemployment rate has fallen to 6.8% in February 2021. With the introduction of this power plant and the decrease in accessible trails, fishing and other outdoor activities, unemployment rates can only spike again.


While we understand that new developments of all types may support the public good—the proposed pumped-storage hydro plant in Woodland Valley brings vastly more negative consequences than benefits.


More specifically, my wife and I appreciate the global energy transition taking place and renewable power is an important component of lessening our dependence on fossil fuels. But this hydro plant is not in line with the preference of the Department of Energy and it would require more energy to operate than it would ultimately create from pumping water to the upper reservoir and back down again. This effectively feels like a greenwashing exercise or ‘energy arbitrage’ approach whereby Premium Energy would be spending cheap power to make expensive power.


Premium Energy, despite knowing the inefficiencies of its project, would be uprooting protected forests and fresh-water habitats to build a large dam, reservoir, turbines and tunnels. These developments would upend the Woodland Valley and local communities.

 
Equally important to the challenged economics of this project is the fact that it would wreak irreparable damage on the ecology of this protected forest area that thousands of business owners and visitors rely on. The Woodland Valley’s businesses and tourism, and its natural environment of fish, animals and plants—are all interdependent. The more people that come to this area to experience its streams and trails helps reinforce the significance of forest preservation and, in turn, helps maintain a constant flow of tourism to this area’s businesses.

 
Please honor the protected Catskills forest and stop this proposal from moving forward.

 
From:

Matt and Kate Kobussen
817 Woodland Valley Road
Phoenicia, NY 12464

Molly Hyde, Florida, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I grew up in the Catskill Mountains and many of my earliest memories revolve around the Ashokan Reservoir. Although I live about an hour away now, I still go back to the area whenever I can to visit the forever wild lands that are so important to me. Therefore, I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Molly Hyde

Jessica Karr, Woodstock, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000 

Dear Ms. Bose,

I learned recently from my friends in Olive that there is a plan to build a hydroelectric power plant nearby. This news stunned me. The Catskills has become a land very dear to my community and myself and has been a refuge over the last couple of years.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process.

It is critical that we stop and consider the unintended consequences that will come about with this “transition.”

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. 

Sincerely,
Jessica Karr

Robert Funicello, Mamaroneck, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.Docket number P-15056-000

Dear Ms. Bose,I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristine protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Robert Funicello
206 Fenimore Road
Mamaroneck, NY 10543

Tara Sarath, New York, NY.
Dear Federal Energy Regulatory Commission, 

I am a NY resident and avid admirer of the Catskills and would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and I ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  


All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”


The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 


In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats.  Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.


I and the community understand the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 

Thank you for your time, 

Sincerely,
Tara

Gilbert Hsiao, Olivebridge, NY.
Gilbert Hsiao
20 Beaver Lake Road
Olivebridge, NY  12461

FERC Project/subdocket P-15056-000


I am writing to share some facts pertaining to why Premium Energy’s proposal for a hydroelectric dam in any of the three locations(Olive, Woodland, and Lanesville, NY) proposed in the Catskill Forest Preserve should not go forward.

First, all the locations proposed are located on protected land that is designated Status 1 by the United States Geological Society under the USGS Gap Analysis program, which provides “permanent protection from conversion of natural land cover and mandated management plan to maintain a natural state.” (see https://www.usgs.gov/core-science-systems/science-analytics-and-synthesis/gap/science/pad-us-data-overview?qt-science_center_objects=0#qt-science_center_objects)

Second, even if the proposed land did not have Status 1, Premium seems to be trying to take shortcuts by misrepresenting the nature of the project. It is calling their project a closed loop system, with limited environmental impact, and high in desirability by entities such as DOE, while in actuality it is an add on system, adding on to the Esopus Creek or the Ashokan Reservoir. The artificial raising and lowering of water levels of the creek would have an adverse impact on the ecologically rich and fragile Esopus. The Ashokan Reservoir itself is fed by the Esopus. Both provide almost half of the drinking water to the 8.5 million residents of New York City.

Robert Cornett, Mount Tremper, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings (PEH) to build a hydroelectric power plant in the Catskill Forest Preserve area of New York state. This project would be absolutely devastating to the environment, disruptive to local communities and have high risk to the purity of NY City’s drinking water.  I along with many other individuals, organizations and town councils in this area urge you to decline PEH’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. There has been a thorough review of the PEH proposal by environmental and energy consultants who have confirmed that this is not a suitable location for a pumped storage facility.

The proposal is in violation of Article XIV of the NY State Constitution which has guaranteed that the Catskill Forest Preserve “shall be forever kept as wild forest lands and shall not be leased, sold or exchanged, or be taken by any corporation, public or private. The project would cause significant destruction to the forest and lands around the proposed sites and environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. A Pumped storage facility will wreak havoc on nearby stream ecology and land habitats. It will affect wildlife and alter sediment regimes in connected tributaries including the Esopus Creek, near my property which  feeds into the Ashokan Reservoir which supplies over 40% of NY City’s water supply and is a vital trout breeding stream. Water fluctuations caused by this project would increase turbidity within the Ashokan Reservoir and its watershed threatening the water supply to NY City and causing issues in nearby communities.

Any of the proposed upper reservoir sites in the PEH proposal would also be damaging to local communities and property owners due to the seizing of homes and property via eminent domain. This will be a repeat of the devastating displacement of people and communities 100 years ago when the Ashokan was constructed.

Due to these serious environmental and community impacts It would be totally reckless of FERC to approve this preliminary permit request.  PEH should be directed to look for more suitable and less destructive locations for this kind of project.

Sincerely,

Robert Cornett
1298 Wittenberg Road
Mt. Tremper, NY 12457
rcornett@maine.rr.com
Phone: 207-838-2168

John Eastridge, brooklyn, NY.
John Eastridge
118 Eagle St. apt 2, Brooklyn, NY 11222

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

There is a wealth of evidence from around the world showing the waterfall of devastation that follows from ill-conceived hydro-electric works. To sell off our dwindling natural resources to unaccountable for-profit enterprise in the face of this wealth of evidence would suggest collusion between corporate greed and elected officials whose duty it is to protect our planet and our future. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

John Eastridge

montine e jordan, west shokan, NY.
I am a resident of West Shokan in the Town of Olive in Ulster County, NY.
A preliminary permit application (The Ashokan Pumped Storage Project) is now before FERC (the Federal Energy Regulatory Commission. This proposal includes building a large dammed reservoir in a New York State forest, an underground hydropower plant in West Shokan, and high voltage transmission lines running from Olive to the Town of Ulster. If allowed to proceed, this project will have materially  detrimental impact on our community.

I am opposed to The Ashokan Pumped Storage Project for three reasons:

1. The Premium Energy proposal is not the kind of green energy project that the Department of Energy (DoE) wants:
• Premium Energy is proposing an open-looped pumped-storage hydropower project where the lower reservoir will be continuously connected to a naturally flowing upper reservoir. Closed-loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval.
• Turbidity will prove a significant issue, as a 'lack' of this problem is the one reason the Ashokan reservoir does not require a filtration plant (as do NYC's other reservoirs).  This project threatens to force NYC to undergo the substantial investment of a new filtration plant, given the turbidity this project threatens to introduce.
• Premium Energy is claiming this to be “closed-loop.” It is not. Projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects. That is what this project is.  Premium Energy is not being honest in its declarations.
• “Initial construction impacts” for open-loop projects are lower, but “operational impacts are still likely to be higher than for a closed-loop project because the add-on project’s lower reservoir is still continuously connected to, and may affect, the natural flowing water feature that was dammed for its original construction.” (Source: DoE: “A Comparison of the Env. Effects of Open-Loop and Closed-Loop Pumped Storage Hydropower.” April 2020)

2. There’s a substantial negative impact on highly preserved land:
• Premium Energy appears to be completely unaware that they are proposing a project in an extremely protected state preserve, a Status 1 area according to the USGS Gap Analysis.  Change in the State Forest Preserve is rare:
o Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum.
o As of 1999, more than 2,000 amendments have been proposed. Only 29 made it to the referendum stage; of those, 20 passed. (Source: The Catskill Park: Inside the Blue Line)
• The Catskills Forest Preserve was created in 1885 in Ulster County. As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the DoE’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
• Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
• The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index.
• All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: see https://www.audubon.org/important-bird-areas/catskills-peaks-area.
• This area is protected for a reason.  It should not be disturbed.

3. There is a significant negative Impact on stream ecology
o Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats.
o Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the New York City water supply.
o A valuable trout breeding habitat will be lost.

As a resident in this impacted area, I urge you to intervene to stop this Ashokan Pumped Storage Project.  Its harm is incalculable.

Thank you,

Montine Jordan
34 Turner Road
West Shokan, NY 12494

Lisa Gizzarelli-Drago, Ulster Park, NY.
Dear Ms. Bose,

I am writing to urge you to decline this proposal. While renewal energy storage is important, this is NOT the appropriate location.  

This land is part of the Catskill Forest Preserve and is deemed forever wild in the NYS constitution.  There is so little forever protected land left; it is imperative to keep it protected.  This alone, should be reason enough to not allow this project to be approved here.

This project will greatly affect the ecology of the streams that feed these proposed reservoirs.  The increased turbidity and highly fluctuating water levels from pumped storage will cause the trout population to decline and likely disappear.  Trout rely on cold/deep, clear water to survive.  Their habitat will be ruined and this will affect the entire food web.  Trout fishing is also a major source of income for the towns along the Esopus Creek.  This would devastate a major part of their economy.      

This project proposes to use the Ashokan Reservoir as its lower basin.  This is drinking water for NYC residents.  Pumped storage will increase the turbidity in the reservoir, making it impossible to remain the largest unfiltered reservoir in the country.  This is irresponsible and reckless to allow this to happen to such a vital resource for the largest urban population in the US.  

Renewable energy solutions should work in harmony with the environment.  They should not decrease the quality of an ecosystem. This project is claiming to be a 'closed loop' project, when actually, it is an add-on project. This add-on project is proposing to use an existing drinking water reservoir for the nation's largest city as its lower basin.  This is a high risk project that will be detrimental to this vital resource and to the ecology of the area.  Premium Energy Holding, LLC is lying about this being a 'closed loop' project to get a quick approval.  They are NOT to be trusted.   

I hope you carefully take these points into consideration and do NOT allow this proposal to move forward.  Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Thank you,
Lisa Gizzarelli-Drago

Lisa Starger, Mt. Tremper, NY.

Kimberly D. Bose
FERC
888 First St. NE Room 1A
Washington, D.C. 20426

Dear Ms. Bose,

While I am a fervent supporter of projects that contribute to our transition to renewable energy and reduce our reliance on fossil fuels, there are multiple reasons why Premium Energy Holdings Ashokan Pumped Storage Project is the wrong project in the wrong place.

While closed-loop projects are considered to have less environmental impact and are eligible for streamlined FERC approval, this project is not, as Premium has erroneously represented it, a closed-loop project but, in fact, an add-on project which is subject to a higher level of scrutiny.

In addition, all of Premium’s proposed reservoir sites are in the Catskills Forest Preserve. Under the New York State constitution these lands “shall be forever kept as wild...not leased, sold, exchanged, or be taken by any corporation...” Under the Dept. of Energy’s own guidelines, Status 1 land, as the Preserve has been designated by them, should be “avoided for development.” Our wild lands are our children’s irreplaceable heritage and the protection of the purity of our waterways. Damage done by development cannot be undone.

It is known that the rapid fluctuations of water resulting from this project will wreak havoc on both aquatic and land habitats, alter the sediment regime in the Esopus aggravating an already problematic turbidity problem, affect New York City’s water supply, and destroy priceless trout breeding habitat.

Alternate energy technologies are rapidly being developed and improved but Premium Energy’s planned project is ill conceived and attains nowhere near the efficiency desirable in a sustainable energy source because of its need to use energy to make energy. It is destined to become, in time, another costly white elephant blighting the landscape like the decommissioned nuclear power plants that, not so long ago, also seemed like a good idea.

Sincerely,
Lisa Starger
1298 Wittenberg Rd.
Mt. Tremper, NY 12457

Adam Chodkowski, Highland, NY.
I oppose this project as a nearby resident and supporter of nature conservation. This project is not suitable for this part of the Catskills, including that the Ashokan Reservoir is critical to supplying drinking water for nine million residents of New York City, and that it would have a negative environmental impact on several wild trout streams and the trout in the Ashokan Reservoir itself.

Taylor Spitzer, Brooklyn, NY.
Taylor Spitzer
118 Eagle St #2
Brooklyn, NY 11222


To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I urge the FERC to reject the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 should be shut down immediately as it will be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

As a frequent visitor to the beautiful Catskill Mountain area, and drinker of the water provided to Brooklyn via the Ashokan Reservoir I am vehemently opposed to this project. Under Article XIV of the NYS Constitution, it is clearly guaranteed that the Catskill Forest Preserve lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 

We look to you and all our elected officials to uphold the constitution and protect public land, especially against private interest groups and corporations. The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Furthermore, should the project be approved - pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. 

It would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. 

Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Taylor Spitzer

Kevin Boyer, West Shokan, NY.
My name is Kevin Boyer and I have been educating myself about the specifics of the “Ashokan Pumped Storage Project,” proposed by Premium Energy – FERC project number P-15056-000 – which I strongly oppose.  

As a resident of the immediate area that would be affected, I’ve quickly learned several key things. A proposal and project such as this has huge legal ramifications at many levels, knowing that New York State’s objection to such development will cause this to be tied up in legal wrangling for many years. This highly preserved land has been so since 1885, when the NYS Constitution declared this 700K acres of continuous wildlife habitat of Catskills forest be “forever kept as wild.” As a State Forest Preserve the Catskills are considered Status 1 land under the USGS Gap Analysis Program – and the DEP has said land areas designated as Status 1 or 2 will be “avoided for development.” This alone should be enough to halt this proposal immediately.  However, if this proposal did in fact get any traction, it would have to be passed by a constitutional amendment by the NYS Constitution, voted on by two consecutive sessions in state legislature and then submitted to the public for referendum. I’ve learned that this is really difficult to do – and Premium Energy seems to be completely unware they are proposing a project in such a protected environment.  (As you likely know, since 1999 there have been 2000 proposals and only 20 have passed.) 

These highly preserved state lands are kept so for many important ecological reasons, perhaps most notably the important bird and fish wildlife habitats that would be lost if such a project were to move forward. The surrounding Catskill’s area and Ashokan Reservoir make up the largest unfiltered drinking supply in the nation – is that not important?  A hydroelectric plant will impact the water’s turbidity and increase stream sediment that runs into the reservoir – affecting the water’s purity and in essence altering a clean source that currently provides 40% of New York City’s drinking water (feeding 9.5 million people). 

Equally as important to note, this proposal by Premium Energy is not factual. This proposal is NOT for a closed-loop project, it is an add-on project since an upper reservoir would be added on to a lower reservoir – so this proposal is, in fact, deficient and untrue. Premium Energy does not deserve the special consideration FERC may give to closed-loop projects. 

The scope of such a project will literally be life altering for both humans and animals that would be displaced, not to mention the impact it would have on the local tourism economy, which continues to grow, reliant on the natural beauty of this region. In 2019 Ulster County represented over 40% of that market. 

There are countless reasons this is a bad idea and I will continue to research and fight to stop this proposal from going further.  This proposed project cannot happen. 

Thank you.
Kevin Boyer

Andrea Stanley, Chichester, NY.
docket number P-15056-000

I am a resident and homeowner in Chichester NY, Ulster County. I am unequivocally opposed to the proposed hydropower project currently under review by FERC (docket number P-15056).

We moved this area in 2007 primarily because of its astounding beauty and the fact that at our doorstep are all the amazing flora and fauna of the Catskills forest. 

While I am in support of renewable and sustainable energy sources and recognize that sometimes there is a “greater good” with some energy projects-- this is not one of them. 

 The proposed project would have a detrimental effect on the ecology of the Catskills Forest Preserve (established in 1885) and on the wellbeing of the flora and fauna in this habitat, including the Ashokan Reservoir and larger New York City Watershed system.
Premium Energy Holding’s claim that it will build an “enclosed loop” system is false; closer study indicates their proposal is actually an “open loop” system. The environmental and aquatic impact of such an open loop system would be significant and damaging. 
The company also falsely states that the project will take place outside the boundaries of the protected Catskills Preserve. Closer study indicates that its proposed sites are actually located squarely within the Catskills Forest Preserve. This area is protected under Article XIV of the New York State Constitution, which deems the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Constitutional amendment is required for any change in the management of State Forest Preserves. This process involves both state legislative approval and a public referendum; it is otherwise unlawful and unconstitutional. 
As a State Forest Preserve the Catskills are considered Status 1 land under the USGS Gap Analysis Program. The US Department of Energy’s own Hydropower Vision report states that, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
I believe the protected status of the Catskills Forest Preserve; the misleading nature of Premium Energy Holding’s proposal; and the Department of Energy’s mandate to avoid Status 1 land are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit. 

Sincerely,

Andrea Stanley

chauncey upson, chichester, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

My name is Chauncey Upson, and I own 158 acres of land in silver hollow, chichester ny.  i am one of the largest private contiguous land owners in ulster county and vote and pay taxes here.  I have been here for over 20 years.   my land is right next to one of the 3 sites from this flawed proposed project (stony clove).  

As a land owner, with warner creek in my property, i have had extensive interactions with the DEP over stream maintenance over the past 2 decades. my thoughts below are intimately informed by interactions with the DEP and ultimately management of the catskills watershed creek on my own land.      

these creeks up here are high velocity creeks, at steep gradients.   that means they transport immense amounts of sediment.   stony clove creek for example is the steepest gradient creek in ALL of the catskills mountains.   this project is counter to basic logic.  

this means that ANY impoundment (i.e. dam) of this creek will bring with it rock, sand,  silt and other sediment build up.   this will require constant (and costly) regular dredging and removal of debris.   something which your plan does  not foresee in its viability study.   if this dredging process is not regularly undertaken, then the dam will eventually breach, thereby subjecting the entire downstream portions of stony clove to damaging floods.

this is basic science.   the maintenance of the dam you propose alone would make it uneconomic.  

i am leaving aside the other catastrophic negative impacts to the local economy (loss of road access, loss of wild life, hiking, impact on water quality for the NYC water shed, etc).  i am purely talking about the severe flaws in the basis premise for this project.  

food for thought:   since the DEP has been taking data from stony clove:   the floods are way under estimated.   this valley can not take more water.   IRENE was supposed to be a one in 100 year story.   it was the record in the past 23 years of data taken by DEP.   but the Grinch storm of 2020 was "only" a 1 in 10 year storm, and look at the damage done.   these creek beds can not take MORE water.  

the proposal from Premier will lead to water levels rising by some 5 feet when fully in use.   this is WAY above levels of peak flooding that we have seen in past, which has destroyed homes, roads, wildlife and ecology, and infrastructure alike.   all to the detriment of the NYC watershed drinking water.  

this project will not work.   ANY dam project in the catskills will not work.   this is the forever wild protected watershed of the 20m people in the NYC metropolitan region.  

i expect in short order the full power and voice of both the DEC and the DEP to further convince you of the special considerations needed in this region vis a vis the NYC watershed.  

please listen to this basic scientific logic and deny any feasibility study to build a pumped storage facility in this region.  
 
thanks,

chauncey j. upson
silver hollow
chichester ny

Cathy McNamara, Woodstock, NY.
 We must ask people to use less energy not at the cost of our natural resources, wildlife and townships. This is not wanted here and goes against what makes upstate NY do precious. We already feed water to the NYC and get little back for it. Enough is enough! I and many of my friends are totally against this proposal and will fight it to the end. Thank you for your ear. Cathy McNamara Woodstock NY

marilyn fogliano, Shokan, NY.
 As a resident of the town of Olive one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Thank You,
Marilyn Fogliano

Vincent fogliano, Shokan, NY.
 As a resident of the town of Olive one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Thank You,
Vincent Fogliano

Marianne Berry, Olivebridge, NY.
I am writing to urge FERC to reject the proposal (Docket # 15056-0000) submitted by Premium Energy for a pumped-storage hydroplant to be constructed in the Catskill Forest Preserve.

 While the goal of increasing the use of renewable energy is an important one, constructing a pumped storage plant and dam within this highly preserved and legally protected forestland and watershed is manifestly contrary to the public good. 

    The Department of Energy has publicly stated that “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

    Premium Energy’s proposal is flawed in that it purports to describe a closed-loop system, whereas it is clearly an add-on utilizing, as its lower reservoir, the Ashokan reservoir, itself an engineering marvel of enormous historical and economic significance. 

    Because of the importance of the Ashokan Reservoir and the surrounding forest preserve, it is legally protected by Article XIV of the New York State Constitution: “shall be forever kept as wild forest lands, [and] shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  The Ashokan reservoir was built, almost exactly a century ago, by means of eminent domain and the displacement of an entire community of towns and farms. This constitutional promise of protection must be kept. 

    There is widespread community opposition to this plan, among not only residents but also visitors to the Preserve, many of them from New York City and other urban areas who value the chance to enjoy unspoiled wilderness within a few hours’ drive. Community groups and organizations across the political spectrum are united in their determination to protect this preserve, as their State Constitution has promised them it would. 

I urge the commission to consider these and other reasons raised by public commentary and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Thank you, 

Marianne Berry

Fred Robin, Chappaqua, NY.
I am writing concerning the proposal for the Ashokan Reservoir pumped storage project. I am a member of Croton Watershed Chapter of the national conservation organization Trout Unlimited.  There are 625 members of the Croton Watershed chapter who live in the Hudson Valley area in NY State.  Although we do not live in Ulster County, NY, many of us travel to Ulster to fly fish for trout in the Esopus Creek and other Catskill streams.  When we travel to fish the Esopus, we purchase food and lodging in the nearby towns in Ulster.  Right now tourism generates more than $600 million dollars and 15% of jobs in Ulster County and fishing/outdoor recreation contributes a large share to the tourism dollars and jobs.  The pumped storage project by pumping and releasing the turbid water from and into the Ashokan and mixing the normally stratified layers of cooler and warmer water has the potential to make the Esopus Creek, a turbid warmer water stream that would destroy the trout fishery.  This would be a serious detriment to those of us who travel from out of the area to fish in the Esopus and would have large impact on the recreational tourist spend and jobs maintained  in the area. Furthermore, pumped storage is not an efficient way of green energy generation because it is a net consumer of energy. Our Trout Unlimited Chapter joins with the others who have expressed the opinion that this project should not be approved because of its detrimental impact on outdoor sports recreation/tourism that generates dollars and jobs for the region from individuals in and traveling to the region from elsewhere in NY.  When local economies are already staggering from the effects of COVID, a project like this that will destroy a major local recreational tourist business should not be allowed to go forward.   Sincerely,  Fred Robin, Croton Watershed Chapter, Trout Unlimited

Ronald S. Friedman, Delmar, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Ron Friedman

william Shubert, Bronx, NY.
Dear Ms. Bose,
I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
William Shubert

ginger perowsky, ny, NY.
Dear Federal Energy Regulatory Commission, 

I have friends and family who are members of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 



A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  



All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 



Yet, this is what is being proposed by Premium Energy. 



The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”



The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 



In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.



Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 



I ask that you deny this permit based on these essential points. 



Thank you. 

Sincerely,
Ginger Perowsky

Karen Goodman, Lake Hill, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jay Bloomfield, PhD, PE, Voorheesville, NY.
I'm am the retired Director of Water Research of the NYS Department of Environmental Conservation. In that capacity I worked on establishing the NYC Watershed Filtration Avoidance under the Federal Safe Drinking Water Act. The FAD was recently extended for ten years in 2017. It is my professional opinion that the FAD would need to be renegotiated with USEPA before even preliminary work on this project could proceed. I suggest that FERC consult with EPA and delay any preliminary investigations undertaken as part of this project.

Sara Villard, Mount Tremper, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

My name is Sara Villard and I am a resident and small business owner in this area.  I’m appalled at the idea residents here should have to worry about eminent domain for this project. The tourism here is also essential to most people in the area. The upheaval and devastation of the general population in 2020 and beyond the pandemic has been enough for the people of the Catskills to endure.  Now we should worry about the devastation of our natural resources, land, and our homes and businesses?  

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Sara Villard

Lorelei Voelker, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Kai Hillmann, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, wildlife, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank You
Respectfully, 
Kai Hillmann

Katie Goldman Macdonald, NEW YORK, NY.
Katie Goldman Macdonald24 Bennett Ave 46A, New York, NY 10033

To:Kimberly D. BoseFederal Energy Regulatory Commission888 First St. NE, Room 1AWashington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 because of the huge risk it poses to the environment and NYC’s drinking water.


Pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. It would be a travesty to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.
-Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”
-The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index.

Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down.
-This can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people.
-Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.


Premium Energy’s proposal would be deeply damaging to local communities.
-Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County.
-Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond. The Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs will be disrupted by this project.


Premium's proposal does not even represent the kind of innovation that the Department of Energy wants to see.
-Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir.
-This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. We cannot trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval.

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.


Sincerely,
Katie Goldman Macdonald

Erica Gruen, NYC, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Erica Gruen

David Severance, Stamford, CT.
I'm writing to say this preliminary permit should NOT be approved. The Forever Wilds clause means these lands should remain untouched in perpetuity. As a long-time fisherman throughout the Catskills, my family has treasured the pristine lands that have been gifted to us by past generations and we owe it to future ones to keep them that way.

Submission Description: (doc-less) Motion to Intervene of Sandra Friedel under P-15056-000.

Submission Date:        4/4/2021 1:57:46 PM

Filed Date:             4/5/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               sandyseacape1@gmail.com                                                          

Basis for Intervening:
April 3, 2021
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission 888 First Street, NE, Room 1A, Washington, DC 20426


Re: Docket P-15056-000
MOTION TO INTERVENE of Sandra E. Friedel for the Premium Energy Holdings, LLC, Project No. 15056


Dear Secretary Bose,

This correspondence is in direct response to the Federal Energy Regulatory Commission (FERC) proposed Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA. Sandra E. Friedel is filing a motion to be an intervener and meets the requirements of 18 CFR 385.214 of the Commission’s regulations to be granted full party status.

The basis for intervening is due to the proposed location of the project (Wittenberg Reservoir) would mean that I would lose my home and access to my property. Therefore, I have substantial interest in the matter. I reside on 65 Friedel Drive that is directly off Moonhaw Road, West Shokan, NY 12494.

Sandra E. Friedel respectfully requests that the Federal Energy Regulatory Commission grant this motion
to intervene.

Respectfully,

Sandra E. Friedel
PO Box 33
65 Friedel Drive
West Shokan, NY 12494

Mac Huelster, Catskill, NY.
Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Mac Huelster
Catskill NY

Emma Wyman, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Joshua Bryant, Woodstock, NY.
As a resident of Woodstock NY (one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity,) I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Grace Patschke, Shokan, NY.
To: Federal Energy Regulatory Commission (FERC)

From: Grace Patschke, 41 Hanzel Rd., Shokan, NY 12481
            (845) 657-9547           gmpatschke@gmail.com

Date: March 27, 2021

Re: Ashokan Pumped Storage Project

I am officially registering my comments and concerns with the Federal Energy Regulatory Commission FERC with regard to the Ashokan Pumped Storage Project. I have been a resident of Olive for the past 24 years. I was blind sighted by the proposed Ashokan Pumped Storage Project. I have huge concerns with this project proceeding in this beautiful and eco sensitive location. This project would be unquestionably detrimental to this area. The following is a partial list of how this area, its residents, wildlife and environment would be compromised:
 
Environment: This beautiful area has seen a surge in the once endangered Bald Eagle, as well as recent sightings of the Red Crossed Bill. In addition to these beautiful birds there are a huge number of land and aquatic animals that would be gravely impacted by this project. Destroying forests for this project would impact wildlife. Creating dams would impact fish, all forms of aquatic life as well as destroying forests, pastures, fields and streams, and all forms of plant and animal life that exist in those natural environments. How will fish migrate between all the reservoirs unharmed? The level of the environmental impact is astronomical. And the damage done could never be reversed.

Well water: People in this area have well water. This type of massive construction both above and below ground can have a catastrophic negative impact on local well water. Just the recent construction on Rt. 28 has turned the Ashokan Reservoir brown for months. Often, sediments and toxins are not visible and could cause harm to those drinking the water as well as the surrounding wildlife. When our neighbor dug their own well on new construction, our well water turned brown for months.
Will this construction impact the water table? Could wells run dry? And what contaminants will be introduced into the water supply? It is not worth the risk to thousands of residences.

Homeowners: Those families that would be displaced by this project would face incredible and possibly insurmountable difficulties. Even if the families are reimbursed for their homes. The unique recent surge of people from New York City relocating to our area, due to COVID, is larger than any we have ever experienced. Homes have hugely increased in their selling price. People purchasing homes are paying with cash, driving the real estate market up. Availability of homes to purchase is very low if nonexistent in the most desired areas. The people having to relocate would not be able to find compatible homes in this market, leaving them at a huge loss both financially and emotionally.

Would solar or wind be more economically viable?

How much co2 and methane is projected to be produced?

Will a warning system be in place in case of a dam collapse?

https://qz.com/797380/reservoirs-methane-emissions-climate-change/



This beautiful area is a natural treasure and moving ahead with the Ashokan Pumped Storage Project will destroy its beauty, permanently scar the environment as well as have devastating impacts on the people, animals, and plant life that exist here on these precious lands. I stand firmly against this project!

Dana Chaifetz, chichester, NY.
Dana Chaifetz  Docket Number P-15056-000

April 

Dear Ms Bose,

I implore FERC to reject the request for a preliminary permit for the Ashokan Pumped Storage Project P-15056.. This project is wrong and immoral for so many reasons. 
This is a danger to the NY water supply .It will displace residents and tourists. 
This land is protected by the constitution and is legally preserved to be forever wild.
The land is used and enjoyed by many and contributes to the quality of life for residents and tourists. It would be terribly destructive and damaging to the environment and equally as disruptive and damaging to our local communities. 

In short, this project has no place here. It must be built elsewhere. 
Please, do what’s right and do not allow this terrible project to ruin what we have preserved here-  truly sacred land.

Sincerely ,
Dana Chaifetz

Calandra Cruickshank, Big Indian, NY.
Calandra Cruickshank 
58 Hatchery Hollow Rd.
Big Indian, NY 12410
calandralila@gmail.com

Regarding: Docket Number P-15056-000

To Whom It May Concern:

I write to formally submit that I am against Premium Energy Holdings, LLC’s proposed Ashokan Pumped Storage Project. 

The 700,000 acre Catskills Forest Preserve was created in 1885 in Ulster County. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” This project would clearly go against this intent and simultaneously endanger forest around the proposed sites that ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. 

All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Sanctuary. As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Additionally, according to The Catskill Park: Inside the Blue Line, changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. 

As someone who lives on a former trout hatchery in the Catskills, established by my great-great-grandfather, I also am concerned about the impacts on stream ecology. Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and a critical part of the NYC water supply. Valuable trout breeding habitat would be lost and there could be significant impacts to the NYC water supply. According to the DEP, this area provides 40% of NYC’s water, a water supply that provides 1 billion gallons a day to 9.5 million people. 

In summary, this project does not represent the innovation that the Department of Energy would want. I urge you to stand against this project and shut it down. 

Sincerely, 
Calandra Cruickshank

Shona Hurst, Ridgewood, NY.
As a resident of NYC, and as someone who studies the history of NYC's drinking water watershed, I strongly oppose the development of the pumped storage project at Ashokan Reservoir. This project will undeniably compromise the health and quality of the water supply of NYC and the other upstate towns that rely on the water from the Catskill water system. The current restrictions on development within the Catskills are there for a reason, to protect the water. Energy and electricity can be found and produced in other ways and means, but water —and especially water of the quality that is in the watershed— cannot be so easily found. Since the late 1800s water stewards have fought to find and maintain clean drinking water for NYC, why should this project compromise decades of work.

Sincerely,

Shona Hurst

Bonita Meadow, Woodstock, NY.
I reside near the Ashoka Reservoir and recreate on the protected lands around it. I vigorously object to the proposed power project near the reservoir, which I believe will damage local lands and water supplies. The request for a permit to build dams and a turbine plant near the reservoir should be denied.

Suki Maltby-Duggan, Brooklyn, NY.
As a lifelong resident of the Catskills who grew up directly on the Ashokan Reservoir, I'm devastated by the potential of the environmental and social havoc this project will have on the Catskills. For a company not based in the area, they can't don't have any notion of the importance of the Catskills and the Forever Wild environment. We CANNOT allow special interest groups to invade our towns and land with the clear intention to destroy the precious land which has been protected for so long and needs to be preserved for future generations. We cannot allow our communities to be destroyed.

Thank you,
Suki Maltby-Duggan

Gretchen Hildebran, Ulster Park, NY.
Dear Federal Energy Regulatory Commission, 
I am a resident of the Hudson Valley and Catskills area and would like to register my opposition to a project under your consideration, Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. I ask that this permit be denied based the concerns that follow, along with additional information which is being provided from Interveners and other concerned citizens. 
First, Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices and reliability. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy for a project that would deeply disrupt the Forever Wild areas as well as protected species.

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage but cannot depend upon the deceptive information provided by Premium Energy for this project. In addition, the proposed locations for this project are in the habitat of threatened species, Forever Wild areas and Status 1 protected land. 

I ask that you deny this permit based on these essential points. 

Thank you for your consideration of these concerns as you review the permits for this project.

Sincerely,
Gretchen Hildebran

Anne Miller, Mount Tremper, NY.
Dear Ms. Bose, 

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water. 

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country. 

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone. 

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond. 

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. 

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Sincerely, 
Anne Marie Miller

Seth Townsend, Phoenicia, NY.
Docket number P-15056-000
My family and I are directly impacted by the proposal, and are strongly opposed to it (both as primary residents in Phoenicia, and as property owners in NYC).  We have carefully reviewed the proposal and have the following concerns with the proposal: 
1)	Environmental
a.	Negative impact on wildlife (fish, birds, deer, bobcats, bears, etc) 
b.	Disruption of underground oil, propane, gas tanks (locations may not be known or these may be inadequately permitted).  The proposal would directly lead to risk of these flooding the supply
c.	Previous industrial sites that are in the flood zone and not documented 
d.	Water quality in NYC – increased risk to requiring filtration which would make the proposal economically non-viable
2)	Merits of the proposal 
a.	Not sufficient detail to understand approach or merits of proposal; risks are not defined, and not captured in the proposal 
b.	Mathematical errors in their proposal are either intentional or careless – the proposal should be submitted and be internally consistent and accurate 
c.	Risk of drought increased (surface areas of reservoir and moving water daily would significantly reduce the water available in the reservoir) – it is not a closed system.  This significantly increases risk of a water outage and has direct impacts on other reservoirs 
d.	Team is not qualified to execute on this type of project – inadequate track record of execution for projects of this magnitude
e.	Inadequate reserve funds available – similar proposals have required 10-20x of the project cost held in cash in a reserve fund to ensure requirements met and no damages
f.	Better proposals elsewhere (e.g., lithium battery) that are more cost effective, efficient; old technology is used for the proposal – this is not efficient and not effective 
g.	Proposal should include DEC / DEP / Ulster County Healthy and Safety representatives to oversee all activity (in person monitoring)  
h.	Property value has significantly increased in last 5 years (~2x value) and this is not accounted for in financial calculations of value 
3)	Legality of the approach 
a.	Violation of 10th Amendment in US constitution and NY state constitution 
b.	California company without alien company registration in NYS or Ulster County 
c.	Federal laws violation including Endangered Species Act and FEMA regulations
d.	State Laws violation including Fish & Wildlife and DEC / DEP regulations  
e.	Ulster County lacks legal authority to grant local permit and exposes both members of the community and individuals who sign permits to civil and criminal penalties 
f.	This is not in the public interest due to the inefficiency in the approach and other more favorable options – local and federal tax incentives cannot be used to justify a seizure of property that is not in the community interest 
4)	Impact on the community
a.	Impact of data requests / research on the Town Hall staff and inability to meet other requests for permitting (lack of town resources) 
b.	Impact to fishing / hunting / camping which is currently used in the area 
c.	History of disrupted / displaced individuals – there are not adequate housing supplies available in the area to support displaced families (and also not available construction workers to build new houses) 
d.	Graves in the local area that would be disturbed  
e.	The impacted community extends well beyond the flood zone and will impact erosion along the waterway as well ad impact community / property value and potential uses 
f.	Additional risk to COVID exposure by the community, which is in violation of current CDC guidelines as these are non-essential business activities

Danielle Campisi, Saugerties, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am appalled by this project which clearly does not take into consideration its devastating affect in our world.  In a time when such lands are now scientifically proven to be connected to the health of humanity and with so many folks taking flight up this way, this project must be halted immediately.

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Danielle Campisi

Conor Nolan, Providence, RI.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Conor Nolan

Eileen DeSanna, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Thank you.

Valentine Tugel, Hudson, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Valentine

Laura Lennon, Brooklyn, NY.
RE: FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA.


Hello,
I'm reaching out to express my disapproval of the proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. Our preserved land would be negatively impacted, along with private property owners who are already facing extreme uncertainty during the COVID pandemic and potentially negative consequences to NYC's main water source. Not to mention, tourism in the area could suffer as people like me are dismayed by the development disrupting one of my most favorite areas near the Ashokan Reservoir.

Please do not let this proposal, or others like it, go forward.

Thank you

philip john anderson, Boiceville, NY.
# 1  As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Anne Lutwak, Kingston, NY.

To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Anne Lutwak

Zachary Sklar, Olivebridge, NY.
I live within 1 mile of the Ashokan Reservoir. I oppose this ill-conceived, reckless proposal. While its intention may be noble, its implementation on the ground, or under it, would be disastrous for the environment, for New York City's water supply, and for the locals like myself who live nearby. The Ashokan Reservoir is a beautiful, protected part of our town and a major source of clean water for New York City. This proposal would violate our state's constitution which protects our reservoir. It would have a terrible impact on the lives of those of us who live nearby. And it would endanger the purity of the water that New York City relies on. I believe in alternative source of energy that do not rely on fossil fuels. However, this is not a good alternative. Please respect our protected lands and water and reject this proposal. Thank you, Zachary Sklar

Leslie Fleischman, HIGH FALLS, NY.
I am writing to oppose the proposed Ashokan Pumped Storage Facility submitted by Premium Energy Holdings. Docket #P-15056:000.

Pumped storage is a flawed solution that uses more power than it stores,  is expensive, and damages the area’s ecology with the rapid changes in water level in the upper reservoir. 

The project is proposed within the Catskills Forest Preserve, with impacts on formally protected and ecologically valuable land. The U.S. Department of Energy itself has recognized that development on such lands should be avoided. 

The movement of water in pumped storage can affect the sediment regime and stream ecology. This is of heightened concern, since excessive sediment is already a major issue affecting the Ashokan Reservoir and the quality of NYC’s unfiltered drinking water. The project would likely affect the 9.5 million residents of New York City and many Hudson Valley communities that rely on its drinking water. It also has significant implications on the health of the Esopus Creek and the communities on its banks, and to the communities that draw drinking water from the Hudson River.

Given the areas appeal to tourism due to its pristine wilderness areas it seems counter to rational thought to allow such destruction to our area that would not appear to create excess power to alleviate the need for energy, instead wasting our valuable natural resources for little assistance in energy needs. There are better ways to create clean energy without trading our Catskill Forest Preserve for another manmade plant that will affect everything for miles around it. This is not the time to take apart more of nature but more the time to learn to live in harmony with nature and live within the perfect balance rather than destroy it. 

The Ashokan Reservoir, NYC watershed, and the Catskill Forest Preserve are not the right place for a pumped storage project.

I sincerely hope that these comments will be taken into consideration as we are the people who live here and enjoy the natural resources provided by the Catskill Forest Preserve. 

Thank you for your consideration,
Leslie Fleischman
High Falls NY 12440

Hilary Nihlen, Scotts Valley, CA.
Hilary Nihlen 
5610 Scotts Valley Drive 
Scotts Valley, CA 95066 

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval? 

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Hilary Nihlen

Doug Peltzman, Shokan, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Douglas Peltzman

Ericca A Gandolfo, Shandaken, NY.
To: Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.
Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Ericca Gandolfo

Walter Auch, Greenwich, CT.
Dear Ms. Bose,

I urge FERC to decline the Premium Energy Holdings request for a preliminary permit for the Ashokan Pumped Storage Project P-15056 as it would be devastating to the environment, highly disruptive to the local communities and risky for the purity of NYC's drinking water.

Sincerely ans Respectfully,

Walter Auch
Greenwich, CT
(203)-355-1416
E-Mail: skipauch@netscape.net

Andrew Konzelmann, Woodland Park, NJ.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Ms. Bose,

Please help keep the Catskills as wild as they currently are. You have a great power yielded unto you by your position and title, and I implore and beg you to please keep the Catskill Forest forever wild. 

Notwithstanding the fact that the NY State Constitution bans the sale of land and removal and sale of trees but from a fundamental level of common sense, the proposal would strip the land and its people of the one commonality they all share, a deep and abiding passion for the Catskill Forest.

It would be irresponsible and downright negligent if the proposed dam by Premium Energy Holdings is allowed to pass. It would destroy the very character of the “Preserve.” This beautiful land would no  longer be preserved - it would be exploited.

One pocket of land here, another patch of land there, another few hundred acres here. This is a slippery slope that will hurt the land, it’s communities, nature itself, and benefit a company 3,000 miles away.

I urge you to please keep these lands forever wild, and forever beautiful.


Best,

Andrew Konzelmann
3500 Club Aspirant
Woodland Park, NJ
973-647-8705

Maegan Butler, New York, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,
Maegan Butler

Eva Armour, Cambridge, MA.
Dear Federal Energy Regulatory Commission,

I am writing in solidarity with the Catskills community opposing the proposal from Premium Energy: FERC project and sub- docket number: P-15056. 

While there is a need for clean energy and pumped storage, I share the concern that these proposed locations are in the habitat of threatened species, Forever Wild areas and Status 1 protected land.

A site where the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Yet, this is what is being proposed by Premium Energy.

As a frequent visitor to this community, and in solidarity with those living there, I ask that you deny this permit based on these points.

Thank you for your time,

Sincerely,
Eva Armour

Catherine E James, Woodstock, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

This is an ill-thought out, environmentally devastating and totally inappropriate project that will impact local people and wildlife.

Susan J McClellan, Barnet, VT.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

As a frequent visitor to the Catskill Mountains, I'm writing to object to the flawed and dishonest proposal by Premium Energy Holdings to build a hydroelectric power plant there. I strongly urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. 

Premium Energy is lying: Their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Premium claims that this project is “closed-loop.” But it is actually an “add-on,” using an existing body of water as a lower reservoir. This is extremely risky, especially when the lower reservoir is a vital source of drinking water for New York. We cannot trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval.

The long-protected forests, streams, and wildlife of Catskill Forest Preserve must not be endangered. Article XIV of the NYS Constitution clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” It would be criminal to destroy this sacred and wonderfully preserved land, a habitat for countless important and endangered species. And this flawed project would set a horrible precedent, dooming protected lands across the country.

On a personal note, I am deeply saddened because I am planning to buy a home in the Catskills to retire to in the next year or so. But I would not want to see what the region looks like if such a devastating project is allowed to go through. The damage would be enormous to the natural environment (supposedly protected for eternity!) as well as to tourism, jobs, and many unique communities. Not to mention that 100 years ago, the region already endured something much like this. Valleys were flooded, homes and entire towns destroyed and relocated, and livelihoods ruined. It is NOT OK to do this again, especially when the company is lying – seriously  misrepresenting their plan simply to gain a preliminary permit. Then they have their foot in the door and endanger what is "forever protected."

Premium Energy should look for a more suitable location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources. Transition to renewable green-energy sources must not come at the cost of environmental and community devastation.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Susan McClellan

Joshua Howard, Mahwah, NJ.
Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314), the New York-New Jersey Trail Conference (Trail Conference), a non-profit organization incorporated in the state of New York with its primary office in Mahwah, New Jersey, hereby petitions the Federal Energy Regulatory Commission to grant it full party status in the above captioned proceeding. 

The person to whom communications should be addressed and to whom service should be made is as follows:

Joshua Howard, Executive Director
jhoward@nynjtc.org
845-304-2782

600 Ramapo Valley Road
Mahwah, NJ 07430

As grounds for this Motion, the Trail Conference, a 501(c)(3) non-profit organization, has a vital and unique interest in the Preliminary Permit application submitted to the Commission by Premium Energy Holdings for the Ashokan Pumped Storage Project (P-15056). 

The Trail Conference is recognized as an advocate for the Catskill region, working with more than 80 member organizations and a combined membership of almost 100,000 concerned trail users, citizens, and strategic partners to ensure the integrity and quality of trail-based recreation. That includes the protection of the natural areas surrounding the trails in the Forever Wild lands of the Catskill Forest Preserve in Ulster County, N.Y.

The Trail Conference has a signed Volunteer Stewardship Agreement with the New York State Department of Environmental Conservation that authorizes a stewardship program between the Commissioner and our organization for the purpose of preserving, maintaining, or enhancing a state-owned natural resource or portion thereof in accordance with the policies of the Department. Additionally, our agreement permits the Trail Conference, whenever possible, to educate others using the trail(s) on how to hike safely, encouraging them to value open spaces and to treat the land wisely. This proposal contradicts that charge.

The proposed dam, reservoir, powerhouse, pipeline, and subsequent powerlines will significantly and permanently damage the viewshed and trail user experience from multiple hiking trails, including the most popular trails in the Slide Mountain Wilderness and the 360-mile Long Path, which transects the Forest Preserve and connects New York City to the Mohwak River and eventually to the Adirondack Forest Preserve. The pristine scenery of the area is a prime reason for the popularity of the trail network in the Forest Preserve. 

Additionally, the road closures in the proposed pumped storage project eliminate vital access points to popular hiking destinations and recreational resources. By interrupting Route 214, access to the Devil's Path, Diamond Notch, and Becker Hollow trails are disrupted, as well as the Devil's Tombstone Campground. By interrupting/obliterating Woodland Valley Road, access to the Burroughs Range, Long Path, and Giant Ledge-Panther Mountain trails are affected, and the Woodland Valley campground is cut off. The elimination of these trailheads will force increased usage in other areas of the Forest Preserve and magnify the negative ecological impacts that we have observed over the past 12 months due to unprecedented visitation on these trails during the pandemic. 

The impacts to these already overwhelmed trailheads and destinations have been identified as a critical issue by Governor Andrew Cuomo and the New York State Department of Environmental Conservation’s Commissioner Basil Seggos. As a result, the Catskill Advisory Group was formed. This group, which the Trail Conference serves on, is charged with creating recommendations and actionable steps to safeguard the Catskills for sustainable recreation. This project would further exacerbate the goals and charge of the Catskill Advisory Group.

The proposed project would also have negative impacts to the natural areas surrounding the trails we are charged with maintaining and protecting. The required powerline right of ways will cross different ecosystems and fragment habitat, lead to the clearing of sensitive vegetation, and create pathways for the spread of invasive species. There is also unnecessary risk of the introduction of invasive species into the Forest Preserve during construction of these facilities, as cited in a Pennsylvania State University study of gas drilling platforms.

The lands and waterways that support the native flora and fauna that are synonymous with the Forest Preserve would be irreversibly damaged and affected by the construction of new dams and reservoirs; the noise pollution from the operation of the facilities would additionally produce undesirable impacts on the trail user experience.

Accordingly, the Trail Conference has a substantial interest in this matter. No other party represents the Trail Conference’s interests, and no other party reasonably could do so. Neither disruption to the proceedings nor any additional burden to any party will result from the granting of this Motion. Considering the concerns mentioned above, the Trail Conference respectfully petitions for intervention.

Jane Casey-Meyer, Secaucus, NJ.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,

Jane Casey-Meyer

Carol Chappell, High Falls, NY.
To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC’s drinking water.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy’s proposal is not a closed-loop system as they claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy’s proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain—a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project’s effect on the Catskills’ growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be “closed-loop” rather than being honest about what their project actually is: an “add-on,” using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation’s largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project—one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely, CAROL CHAPPELL

Other formats

Ashokan Pumped Energy Storage Comments – First Step 3-31-21

On behalf of Northern Catskills Audubon Society, the 350-member chapter
of the National Audubon Society, and whose chapter territory includes
the area of this proposal, I offer these comments in opposition to the
proposed Ashokan Pumped Energy Storage Project, Docket P-15056.

The proposed project is located within the Catskill Peaks Important Bird
Area (IBA), identified by Audubon New York as one of the largest
contiguous forest tracts in the state. The area was given IBA
designation due to the presence of high-elevation breeding bird species,
such as Bicknell’s Thrush and Blackpoll Warbler, as well as home to the
suite of lower-elevation forest nesting birds. Many of these are
considered species of Special Concern or Threatened in New York State,
or Species of Greatest Conservation Need and include American Black
Duck, Osprey, Bald Eagle, Sharp-shinned Hawk, Cooper’s Hawk, Northern
Goshawk, Red-shouldered Hawk, Peregrine Falcon, American Woodcock,
Olive-sided Flycatcher, Wood Thrush, Scarlet Tanager, Cerulean Warbler,
Black-throated Blue Warbler, and Canada Warbler. In addition to state
protections, Bald Eagle is afforded federal protection under the Bald
and Golden Eagle Protection Act. The Ashokan Reservoir, as part of the
IBA, is an important site for wintering waterfowl and it is unknown how
water depth fluctuations from this project would affect those birds.

Permanent protection of this IBA is of utmost importance to protecting
the aforementioned species. This project, if approved, would fragment
the forest to the detriment of those species, as well as species
currently not identified as in need of protections.

We urge FERC to stop this project before much time and money are
needlessly spent, given that further, detailed negative environmental
effects that will certainly be identified in an EIS if the project is
approved to move to the next step.

Sincerely,

Larry Federman

President, Northern Catskills Audubon Society, Inc.

Nathaniel Gillespie

Woodland Valley Farm, LLC/ Woodland Valley Woods, LLC

624 Woodland Valley Road

Phoenicia, NY 12464

April 4, 2021

RE: MOTION TO INTERVENE ON PROJECT # 15056-000, ASHOKAN PUMPED STORAGE
PROJECT

Dear FERC,

I am filing a motion to intervene for proposed project #15056, Ashokan
Pumped Storage Project. I co-own 9.1 acres of property at 624 Woodland
Valley Rd (24.8.1.11), and am a member of Woodland Valley Woods, LLC, 20
acres in size, and Woodland Valley Farm, LLC, approximately 105 acres in
size, which would be inundated by the proposed reservoir in Woodland
Valley associated with the proposed Ashokan Pumped Storage Project.

Our family has owned and lived on this property since 1835, making me a
seventh-generation owner of land that would have to be taken away by
imminent domain to be buried forever under water. The property includes
a homestead constructed in 1865 following the conclusion of the Civil
War and an original barn built in that era. We have a gravesite on the
property, and numerous family heirlooms from generations of family who
were born on, who served the military during the Civil War, the First
World War and World War II, who worked, and who died on this property.
Our family has invested significant time in collaboration with NYC DEP
to serve as good stewards of the property in its important role in
contributing clean drinking water downstream to New York residents,
including the sale of a 97-acre conservation easement to NYC DEP in 2014
that sacrificed our right to further subdivide and develop much of the
property in perpetuity to help ensure watershed protection. We adopted a
Forest Management Stewardship plan through NYC DEP in 2014 and entered
the Woodland Valley Woods, LLC property into the National Tree Farm
System to ensure best management practices and long-term sustainable
management ensures water quality, wildlife and timber conservation for
future generations. Our family is involved in important American
Chestnut restoration with the New York Chapter of the American Chestnut
Society on the property. I, as well as my family, would therefore be
impacted financially, physically, and on a very real level, spiritually,
from the proposed project #15056.

Not only is this property invaluable to me and my family, the proposed
reservoir construction and operation would generate unacceptable risk to
New York City DEP’s unfiltered water supply downstream in the Ashokan
Reservoir via numerous short-term and long-term impacts. The property
currently serves an important role in maintaining the unfiltered water
supply for New York City Department of Environmental Protection (NYC
DEP) via its contribution to the high- water quality currently found in
Woodland Valley Creek, its floodplains, and several tributaries and
wetlands located on the property. The proposed reservoir and pumped
storage operation would literally destroy all of these important
hydrological resources. Construction of the reservoir dam, associated
blasting for the dam and connecting underground tunnel, land clearing
and clearcutting to remove standing vegetation beneath the reservoir
pool, and roadbuilding to replace many miles of Woodland Valley Road
would all cause significant fine sediment, turbidity and water quality
impacts to Woodland Creek, Esopus Creek and the Ashokan Reservoir for
many years. But the major water quality impacts would not be limited to
the 5 or more years of construction and disturbance: the daily
fluctuation of the proposed Woodland Valley Reservoir to serve the
pumped storage needs would erode and resuspend fine sediment and
colloidal clay found in numerous naturally-occurring glacial lacustrine
clay deposits throughout the stream, floodplain and valley. The
underlying geology therefore would contribute turbidity to Esopus Creek
and the Ashokan reservoir potentially on a daily basis, causing great
impact and unacceptable risk to New York City’s drinking water supply to
over 9 million people.

The Woodland Creek serves as an important and valued recreational
resource in its current state for me and my family as well. The Woodland
Creek is a storied wild trout fishery, and provides very significant
spawning and rearing habitat for wild brook, brown and rainbow trout
which migrate annually from the Ashokan Reservoir and the Esopus Creek
to use these fertile headwaters to spawn. The proposed reservoir would
eliminate the current fishery within more than 3 miles of Woodland
Creek, it would forever sever the vital connection of more than 13 miles
of coldwater habitat used by trout in the Esopus Creek/Ashokan Reservoir
causing significant impact to this recreationally valuable fishery. If
the proposed project is permitted to be constructed, it would also
degrade the Esopus Creek fishery downstream from altered water
temperature, sediment regime and water quality impacts from the proposed
reservoir construction and operation. Due to the potential negative
effects of the proposed pumped storage reservoir on the Woodland Creek,
Esopus Creek and Ashokan Reservoir and their cherished wild trout
fishery, I am filing as an intervenor as well.

Sincerely,

Nathaniel Gillespie

3 April 2021

Ashokan Pumped Storage Project

Docket Number P-15056

I, Salomon Weir, in my capacity as president of the Chichester Property
Owners Association, file this Motion to Intervene in this proceeding.

Salomon Weir, president

Chichester Property Owners Association (CPOA)

796 New York State Route 214, Chichester, Ulster County, NY 12416

845-688-0293

Cpoaevents@gmail.com

We will be directly impacted by the project’s effect on our streamside
property and recreational use of the Stony Creek, New York State Route
214, the Esopus Creek, and the Ashokan Reservoir in Ulster County, which
provides 40% of the unfiltered drinking water for New York City.

Therefore, I, Salomon Weir, president of CPOA, respectfully request that
the Commission grant our Motion to Intervene as a party with full rights
to participate in all further proceedings.

Respectfully submitted on 04/03/2021

Salomon Weir, president

Chichester Property Owners Association (CPOA)

796 New York State Route 214

Chichester, Ulster County, NY 12416

Neal G Brownell, Olivebridge, NY.
This comment is in regard to the Ashokan Pumped Storage Project. I am opposed to it - stop it at all costs.

Ellen Carter, Phoenicia, NY.
I am vehemently opposed to the project Premium Energy wishes to undertake in the towns of Shandaken and Olive. 

While I understand that energy storage is a critical issue for our region, the Catskills are not the proper location for such a project, and I question the appropriateness of this particular technology. According to my research, the Department of Energy stated in 2013, in a study covering pumped storage technology, that “no energy future was found to bring quantifiable revenues sufficient to cover estimated costs of plant construction.”

My understanding of the technology is that the upper reservoir would be subject to frequent water level changes, a disaster for the rainbow trout fishery that preserves wildlife and forms an important part of the local tourist economy.

This environmentally sensitive area would be adversely impacted by the flooding of valleys. Please do not allow this project to go forward.

Thanks for listening.

craig comperatore, shandaken, NY.
this project goes against everything the NYS land rights constitution protects and endangers wild life, NYC water, local water, and local tourist that enjoys the remote undisturbed forest. I do not support any project that would forever alter and endanger what little open areas we have left.

Linda Mae Wilson-Brownell, Olivebridge, NY.
This is in regard to the Ashokan Pumped Storage Project. I am opposed to it. Please stop it at all costs.

George Esposito, Phoenicia, NY.
George & Karen Esposito, Phoenicia, NY 
Docket No. P-15056 -000  Ashokan Pumped Storage Project

The proposed project by Premium Energy, a California Co, to use the pristine land which is part of the Catskill Forest Preserve and the Ashokan reservoir that is highly protected as part of NYC’s drinking water is nothing but greedy and preposterous. We have owned our second home in Woodland Valley Phoenicia NY, one of the areas directly affected by this proposal for over 30 years. We raised our children and grandchildren to love, respect and always protect the natural wildlife and its abundant nature, as well as the wild streams that flow into the Ashokan and NYC’s drinking water. The proposal infringes on lands that are deemed to be “forever kept as wild forest land” and part of that land also includes the Woodland Valley Campground, est. in the 1930’s one of the oldest in NY and a major tourist attraction. If allowed to go forward the project will also negatively impact tourism which generates significant revenue for the local economy.  There are so many reasons why we passionately object to this irrational project. A project that was submitted to FERC as a “closed loop” project which from what we have learned appears to be quite the contrary.  Please do everything in your power to decline this project as it will ultimately desecrate one of the Catskills most scenic tourist areas with tremendous dams, transmission lines, turbines and tunnels, to possibly store enough energy to supply a small number of homes in the event current grid is overtaxed. The massive costs of this project coupled with the destruction to the ecosystem, drinking water, businesses, people’s lives, livelihoods and wellbeing, is not quantifiable nor well thought out. 
While renewal energy may be important in today’s world surely Premium Energy of Ca could seek out more suitable sites across the country that are barren or rural where a project of this nature would not have a detrimental effect on vital trout waters, an existing community, or clean drinking water.

Mary Huhn, WEST SHOKAN, NY.

I am a resident of West Shokan, a hamlet in the town of Olive, New York. 

West Shokan, as well as the very road I live on, Moonhaw Road, is one of the towns being proposed by Premium Energy Holdings as a site for a 300-foot dam, giant reservoir, turbine, and 50-foot tunnels for use in pumped storage and generation of electricity. There will also be unsightly transmission towers up and down many roads, the mountain and valleys, and along the Ashokan Reservoir, which supplies drinking water 40% of water to New York City. A power plant would be built right next to the Ashokan reservoir. 
 
I reject this proposal, object to this proposal and downright am horrified by this proposal, which would negatively impact the environment, destroy communities, upend the homes of many wild creatures great and small. The construction would permanently damage the rivers and streams, and the power plant would disrupt the flow to and increase the turbidity of the Ashokan Reservoir, destroy mountains, as well as the quiet beauty of the Catskills, where people have been coming for centuries for respite. I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. Whoever is reading this, please do everything you and your FERC colleagues can do to stop this proposal from going one step further. Thank you, Mary Huhn

Theresa Delozier, Shokan, NY.
     



    April 1, 2021

    Kimberly D Bose, Secretary
    Federal Energy Regulatory Commission
    888 First ST, NE
    Washington DC,    20426

Re:  Premiere Energy's proposition inside the Catskill Park, NY


Dear Secretary Bose:

    I am absolutely shocked that there is even a proposal for an energy project to be constructed inside the Catskill Park in Ulster County NY.  The land proposed for this project is within the “forever wild” forest lands created by New York State in 1885.  According to the NYS constitution  this land can not “be leased, sold, or exchanged, or taken by any corporation public or private.”  Any change to this must be made through constitutional amendment.  This proposal should not even be considered.

Also this project will impact the NYC watershed.  The city receives 40% of its water from the watershed with one of its most important reservoir just miles from the proposed project.  When you live in the watershed putting in a septic system is highly regulated by NYC DEP.  How can something this big and disruptive be considered under these circumstances?

This area of western Ulster County is highly dependent on tourism.  People come here for the pristine beauty of the Catskills as well as to fish in the premiere trout fishing stream, the Esopus.  If this project were to move forward the rapid water fluctuations that would occur would destroy the habitat and breeding grounds of trout.  This project would be a blight on that pristine beauty.

While the town of Olive, where this proposed project would be primarily located, is currently trying to come up with more environmentally friendly ways of supplying energy for our town this proposal is not.  The claim that this is a closed loop project is false.  The plan to have “add on” projects means it is not a closed loop therefore far more detrimental to our environment, in our town, our home.  I can  not believe that this is a project that the Department of Energy would approve as being in line with caring for the environment.

We moved here 40 years ago to live in the mountains and in the Catskill Park.  We do not want to see the beauty of our town, our home destroyed by a company trying to sneak its way into our county.   I hope that you will consider that our current administration ran on caring for the environment and that you will see that this project would jeopardize the forever wild environment of the Catskill Park in Ulster County, town of Olive NY.
 
Sincerely,

Rebecca L Flanagan, BROOKLYN, NY.
I am writing to protest the proposed Pump Storage Hydroelectric Plant that would do irreparable damage to the Catskill Forest Preserve and surrounding areas. I am extremely concerned about the impact that this proposal would have on these highly preserved forests, the wildlife and ecosystems therein. Green energy is important and infrastructure always involves trade-offs between individual and public interests, but this proposal does not seem to offer the kind of innovation that would best serve the public in the long term. FERC should deny Premium Energy Holding’s application for a preliminary permit, and consider other locations. This proposal is likely to damage local lands, roads, and streams and cause
increased turbidity in waters serving as an unfiltered drinking water source for
nine million people in New York City. Please do everything in your power to stop this from moving forward. Thank you.

Richard Lipfert, West Shokan, NY.
To Whom It May Concern,
I’m vehemently opposed to project P-15056-000 for the following reasons,
1. The desecration of the natural habitat and wildlife in the path of the proposed reservoir and power lines.
2. The possibility of water wells that can be effected.
3. The effects that this project on the Ashokan Reservoir will have on New York City’s main clean water supply.
4. Damage and changes of town roads that will effect travel due to heavy construction vehicles while construction could last anywhere from 7 to 10 years.
5. This project will stifle tourism and local businesses while removing properties from the current tax base.
6. My wife and I built our home 52 years ago and we raised our children here while tending to the acreage raising farm animals and growing vegetables and being what we considered good stewards of the land. Now in our so called “Golden years” we find ourselves in the position that our home will be uninhabitable due to the proposed 2 power lines/ towers going directly over the rooftop of our house. At the age of 78 we will be uprooted and forced to start a new life God knows where. I would not wish this on anyone! 
Please consider these and many other negative aspects that this project will have on our protected lands.
 
Respectfully 
Richard Lipfert, 52 Brodhead Rd, West Shokan, NY 12494
richlipfert@gmail.com

Roni Natov, Chichester, NY.
I am a resident of Chichester, NY in Ulster County.  I have been a part of the Chichester community all my 78 years; my mother and grandmother have been a part of the community their lives.  Although they are both gone now, my grandmother was one of the first up here and my son and grandchildren are also a part of the community. I am writing to oppose the granting of a preliminary permit to Premium Energy Holdings. While I support our nation’s transition to renewable energy, I believe the Catskills region is not the right location for such a project with significant impacts to state preserved forest land, streams, species, and the New York City water supply. Much of the harm is unlawful and in violation of the New York State Constitution. Further, Premium Energy does not provide the kind of innovation sought by the Department of Energy as its proposal is deficient and misleading. Premium Energy’s claim that it will build a closed loop-system is false.  Closer study indicates their proposal is actually an open loop system, an add-on project where an upper reservoir would be added to an already existing lower reservoir connected to a natural water source.  As you know, the environmental and aquatic impact of such an open loop system would be significant and damaging. 

The company also falsely states that the project will take place outside the boundaries of the protected Catskills Preserve. Closer study indicates that its proposed sites are actually located squarely within the Catskills Forest Preserve (established 1885). This area is protected under Article XIV of the New York State Constitution, which deems the lands shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. Any changes in the management of State Forest Preserves have to be passed by constitutional amendment, which involves both state legislative approval and a public referendum. Otherwise, it is unlawful and unconstitutional.  Consider also the fact that, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. According to the US Department of Energy’s own Hydropower Vision report, areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.

I believe the protected status of the Catskills Forest Preserve; the misleading nature of Premium Energy’s proposal; and DoE’s mandate to avoid Status 1 land are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.
Sincerely,
Roni Natov

James Burkly, Phoenicia, NY.
I am strongly opposed to the Proposed Pump Storage Hydroelectric Plant in the Catskill Mountains.
My family and I have escaped to the Catskills from NYC and NJ for the past 80 years. The area has been mostly untouched by any major development for most of that time period.
It is still a beautiful area where nature still thrives now as it has for centuries.  This plant would bring environmental devastation.

I currently own a home on the Esopus Creek in Phoenicia.
I understand renewable energy is important but the plan is not good for the Catskills, an area that must be left alone for the reasons I will share below:

According to Article XIV of the NYS Constitution, the lands "shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private".  This proposal violates Article XIV.

The impact on stream ecology from the pumped water would wreak havoc on valuable trout breeding in addition to properties like mine that are on the Esopus Creek.

This project would also pose risks to the NYC water supply which cost billions of dollars of investment; $1.7 billion since the 1990s alone.

This project would also have a major impact on the Catskills tourism economy. Tourism is integral to the NYS economy.  Tourism generated 17% of employment in the Catskills in 2019. It is a $1.6 billion industry in the region, supporting roughly 20,000 jobs. Ulster County represents 43% of that market.  And second homes generate $360 million in economic activity of which none want their land taken away due to "eminent domain". 

Thank you for letting me voice my opinion.

If you would like to contact me directly, please feel free.

Respectfully,


James Burkly
5 Hummingbird Lane
Phoenicia, NY 12464

Joey Carey, Glenford, NY.
Kimberly D. Bose
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A
Washington, D.C. 20426.

Docket number P-15056-000

Dear Ms. Bose,

I am writing in response to the deeply flawed proposal by Premium Energy Holdings to build a hydroelectric power plant in New York's Catskill Mountains. I urge FERC to decline their request for a preliminary permit for the Ashokan Pumped Storage Project P-15056, as it would be devastating to the environment, highly disruptive to local communities, and risky for the purity of NYC's drinking water.

While there's no doubt that pumped storage and new hydroelectric projects will play a key role in our country's transition to renewable energy, the pristinely protected forests, streams, and wildlife of Catskill Forest Preserve must not be sacrificed in the process. Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands "shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private." The Preserve currently contains 700,000 acres of continuous wildlife habitat (very rare in our increasingly fragmented environment), and the forest around the proposed sites ranks among the top 1% of forest habitats region-wide, according to the New York State Forest Condition Index. It would be a true crime to destroy this sacred and wonderfully preserved land, and would set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic and land habitats, because within a pumped storage system, the upper reservoir is subject to rapid fluctuations as the water is pumped up and down. In addition to affecting wildlife, this can alter the sediment regime in connected tributaries, which has a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the sediment regime in the Esopus Creek, which is one of the Catskills' most vital trout breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which supplies 40% of NYC's water supply, serving 1 billion gallons of water a day to 9.5 million people. Plus, Premium Energy's proposal is not a closed-loop system as they claim-it is in fact an "add-on," and the water fluctuations would no doubt increase turbidity within the Ashokan and its watershed. Taking all this into account, it would be reckless to allow a project to proceed that would threaten such a valuable asset as the Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium Energy's proposal would be deeply damaging to local communities. Any conceivable upper reservoir site in the Catskill Forest Preserve would require the seizing of homes and private property via eminent domain-a process that already displaced thousands when the Ashokan was constructed 100 years ago. Residents displaced by the Ashokan Pumped Storage Project would likely have a hard time securing new housing, as there is currently a housing shortage in Ulster County, and for homes that are available, prices are through the roof. Beyond the problem of community displacement, there is also the proposed project's effect on the Catskills' growing tourism economy, which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion industry, supporting roughly 20,000 jobs. Premium Energy's project would limit access to hiking, fishing, and other forms of recreation in the Catskills, decrease the area's natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and Tannersville, and otherwise dampen tourism in the region, negatively affecting businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy's Ashokan Pumped Storage Project, it must be pointed out that their proposal does not even represent the kind of innovation that the Department of Energy wants to see. Closed-loop pumped storage projects have smaller environmental impacts than those that make use of existing watersheds, and are thus eligible for streamlined FERC approval. This is why Premium is claiming this project to be "closed-loop" rather than being honest about what their project actually is: an "add-on," using an existing body of water as a lower reservoir. This kind of project carries with it significantly higher risks, even when the lower reservoir is not a vital source of drinking water for our nation's largest city. How can we trust a company that would lie in their proposal simply for the advantage of being fast-tracked for approval?

Our country's transition to renewable, green-energy sources must not come at the cost of environmental and community devastation. I hope Premium Energy will be able to find a suitable alternative location for a pumped storage project-one where the construction and operation will not destroy protected wilderness, displace vulnerable communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy's proposal for a preliminary permit for the Ashokan Pumped Storage Project P-15056.

Sincerely,


Joey Carey

Blaine Hoekstra, Wayne, NJ.
Please be advised that this application should be rejected on the merits of the fact it is mislabeled as an application for a closed loop hydroelectric system which it is not. It is an “add-on” hydroelectric system. 
This system is also being proposed to be located in a highly environmentally sensitive area that is designated wild and restricted   Class one environmental sensitive area not to be developed for any purpose.

Victoria Klose, Lagrangeville, NY.
RE: docket P-15056-000


Dear Secretary Bose,

Please do everything in your power to STOP Premium Energy Holding’s proposal for the Ashokan Pumped Storage Project.

It is illogical, not to mention incredibly stupid, to use more energy to pump water up to a storage area than one would get when it is released downhill. 

It is immoral to destroy the homes and lives of countless people, fauna and flora in order to create this storage area. It is immoral to violate the Catskill Forest preserve. It is incredibly stupid to build a three-hundred-foot dam in an era when dams are known to cause more harm than good. It is incredibly stupid not to anticipate a catastrophe from a burst dam, which would wreak havoc for years.

This proposal is NOT great brains at work. This proposal is an ecological nightmare. STOP THIS PROPOSAL.

Lynn Schauwecker, Phoenicia, NY.
Lynn Schauwecker
66 Fawn Hill Road
Phoenicia, NY 12464

To:
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A
Washington, D.C. 20426.
Docket number P-15056-000

Dear Ms. Bose,

I am writing as I deeply concerned about the proposal by Premium Energy Holdings to
build a hydroelectric power plant in New York’s Catskill Mountains. I urge FERC to
decline their request for a preliminary permit for the Ashokan Pumped Storage Project
P-15056, as it would be devastating to the environment, ecology, highly disruptive to local
communities, and risky for the purity of NYC’s drinking water.

Both my residence and work (Menla Mountain Retreat) are located in Woodland Valley, New York. It would be  devastating to the protected forests, streams, wildlife, and the environment of the Catskill Forest Preserve if a dam was placed in this area.

While there’s no doubt that pumped storage and new hydroelectric projects will play a key role in our country’s transition to renewable energy, wild life preserves, ecology, protection of drinking water, communities and businesses must not be sacrificed in the process.

Under Article XIV of the NYS Constitution, it is clearly guaranteed that these lands “shall
be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be
taken by any corporation, public or private.” The Preserve currently contains 700,000
acres of continuous wildlife habitat (very rare in our increasingly fragmented
environment), and the forest around the proposed sites ranks among the top 1% of
forest habitats region-wide, according to the New York State Forest Condition Index. It
would be a true crime to destroy this sacred and wonderfully preserved land, and would
set a doomed precedent for protected lands across the country.

Even once construction is complete, there would be further environmental devastation
due to the interconnectedness of the Ashokan watershed and its tributaries. Pumped
storage is notorious for wreaking havoc on nearby stream ecology and on both aquatic
and land habitats, because within a pumped storage system, the upper reservoir is
subject to rapid fluctuations as the water is pumped up and down. In addition to
affecting wildlife, this can alter the sediment regime in connected tributaries, which has
a cascading effect. The Ashokan Pumped Storage Project would ultimately affect the
sediment regime in the Esopus Creek, which is one of the Catskills’ most vital trout
breeding waters, and one of the key creeks feeding into the Ashokan Reservoir, which
supplies 40% of NYC’s water supply, serving 1 billion gallons of water a day to 9.5
million people. Plus, Premium Energy’s proposal is not a closed-loop system as they
claim—it is in fact an “add-on,” and the water fluctuations would no doubt increase
turbidity within the Ashokan and its watershed. Taking all this into account, it would be
reckless to allow a project to proceed that would threaten such a valuable asset as the
Ashokan Reservoir, which is the largest unfiltered water supply in the nation, and
represents over $1.7 billion of investments since the 1990s alone.

In addition to its negative effects on the environment and water supply, Premium
Energy’s proposal would be deeply damaging to local communities. Any conceivable
upper reservoir site in the Catskill Forest Preserve would require the seizing of homes
and private property via eminent domain—a process that already displaced thousands
when the Ashokan was constructed 100 years ago. Residents displaced by the
Ashokan Pumped Storage Project would likely have a hard time securing new housing,
as there is currently a housing shortage in Ulster County, and for homes that are
available, prices are through the roof. Beyond the problem of community displacement,
there is also the proposed project’s effect on the Catskills’ growing tourism economy,
which generated 17% of employment in the Catskill region in 2019, and is a $1.6 billion
industry, supporting roughly 20,000 jobs. Premium Energy’s project would limit access
to hiking, fishing, and other forms of recreation in the Catskills, decrease the area’s
natural beauty, cut off access to skiing and concerts at Hunter Mountain, Hunter, and
Tannersville, and otherwise dampen tourism in the region, negatively affecting
businesses in Ulster County and beyond.

As a last point to make in opposition to Premium Energy’s Ashokan Pumped Storage
Project, it must be pointed out that their proposal does not even represent the kind of
innovation that the Department of Energy wants to see. Closed-loop pumped storage
projects have smaller environmental impacts than those that make use of existing
watersheds, and are thus eligible for streamlined FERC approval. This is why Premium
is claiming this project to be “closed-loop” rather than being honest about what their
project actually is: an “add-on,” using an existing body of water as a lower reservoir.
This kind of project carries with it significantly higher risks, even when the lower
reservoir is not a vital source of drinking water for our nation’s largest city. How can we
trust a company that would lie in their proposal simply for the advantage of being
fast-tracked for approval?

Our country’s transition to renewable, green-energy sources must not come at the cost
of environmental and community devastation. I hope Premium Energy will be able to
find a suitable alternative location for a pumped storage project—one where the
construction and operation will not destroy protected wilderness, displace vulnerable
communities, and threaten incredibly important natural resources.

Please do the right thing and deny Premium Energy’s proposal for a preliminary permit
for the Ashokan Pumped Storage Project P-15056.
Sincerely,
Lynn Schauwecker

Barbara Shapiro, Shokan, NY.
The Catskill Forest Preserve has been protected by the NY State Constitution since 1885. Designated Status One Land, the Dept. of Energy respects this land as requiring strict protection against development.

The Ashokan Pump Storage Project would be in violation of the NY State Constitution, increasing turbidity in NYC drinking water (approximately 1 billion gallons for 9.5 million persons daily), scarring the Ashokan Watershed area, disrupting our tourism economy, and displacing area residents for a second time.

Article XIV of the NYS Constitution specifically states that these forested lands "shall be forever kept as wild...". And that they "shall not be leased, sold, or exchanged, or be taken by any corporation, public or private." 

As a pristine 700,000 acres of continuous wildlife habitat, the forested area ranks among the top 1% of such habitats region-wide. The Catskill's own State Forest Preserve is considered Status One Land under the USGS "Gap Analysis Program". Areas considered Status One, with formal protections under the Dept. of Energy "Hydropower Vision" are specified as to be avoided for development. 

This proposed Ashokan Pump Storage Project is an unacceptable project for the intended area. As this proposal has been earmarked by Premium of California to be a "Closed-Loop" system - which given the existence of the connected Esopus River it most certainly would not be, but rather an "Add-on" - their proposal should not even be considered.

Thank you for your careful consideration,  

Barbara J. Shapiro
6 Croswell Manor Drive, Shokan, NY 12481

Brendon Shapiro, Shokan, NY.
The Catskill Forest Preserve has been protected by the NY State Constitution since 1885. Designated Status One Land, the Dept. of Energy respects this land as requiring strict protection against development. I was born and raised in the area, and it is a truly special and unique part of the country that holds great value in so many ways.

The Ashokan Pump Storage Project would be in violation of the NY State Constitution, increasing turbidity in NYC drinking water (approximately 1 billion gallons for 9.5 million persons daily), scarring the Ashokan Watershed area, disrupting our tourism economy, and displacing area residents for a second time.

Article XIV of the NYS Constitution specifically states that these forested lands "shall be forever kept as wild...". And that they "shall not be leased, sold, or exchanged, or be taken by any corporation, public or private." 

As a pristine 700,000 acres of continuous wildlife habitat, the forested area ranks among the top 1% of such habitats region-wide. The Catskill's own State Forest Preserve is considered Status One Land under the USGS "Gap Analysis Program".  Areas considered Status One, with formal protections under the Dept. of Energy "Hydropower Vision" are specified as to be avoided for development. 

This proposed Ashokan Pump Storage Project is an unacceptable project for the intended area.  As this proposal has been earmarked by Premium of California to be a "Closed-Loop" system - which given the existence of the connected Esopus River it most certainly would not be, but rather an "Add-on" - their proposal should not even be considered.

Thank you for your time,

Brendon Shapiro

Kim Lipfert, West Shokan, NY.
To Whom It May Concern, 

I wish to voice my opposition to the proposal put forth by Premium Energy Holdings to build a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. Although I agree that sustainable and renewable energy is important, I strongly oppose Project P-15056-000. I believe the Catskill Mountains is not the right place for such an intrusive project, and would have a long-term devastating impact on the environment and community. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams that are part of a Status 1 State Forest Preserve, and cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 

In addition, a long-term project of this kind, with a constant flow of heavy construction vehicles and road restrictions, would deter much relied upon tourism, and cause road congestion for many years for the community.

And lastly, a project of this kind with a massive power line path would cause many homes of established residents to be vacated and possibly leveled. This displacement of families, including my own, who have built and maintained their homesteads over many years, respecting and preserving the surrounding environment, would be absolutely devastating.

In conclusion, I believe the project would be better suited in a location that:

1. Is not a Status 1 State Forest Preserve.
2. An area where an “Add On” reservoir does not pose a serious risk to one of the largest reservoirs providing pristine drinking water to NYC residents, and local wells.
3. Is situated in an area that is not populated by a community of long-term, established residents, who rely on a healthy tourism economy. 


Please do everything in your power to prevent this proposal from moving forward.

Respectfully,

Kim Lipfert
52 Brodhead Rd
West Shokan, NY 12494

Miles T Naughton, West Shokan, NY.
To Whom It May Concern, 

I am writing in response to the proposal by Premium Energy Holdings to build a pumped storage plant at the Ashokan Reservoir in New York’s Catskill Mountains. 

First of all, I do understand the need for energy storage and that pumped storage can be the preferred option if a proper location is found. A location using a closed-loop system where it would have minimal impact on the environment, wildlife, and communities involved. 

Premium Energy’s open-loop proposal seems to have overlooked these criteria. The three sites they proposed for this project are located in an area that is a delicate balance of highly preserved lands, rich wildlife, and diverse watershed communities.

This project would have severe impacts on highly preserved forests and lands. The Catskill Forest Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index.

As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private. 

The proposed project would wreak havoc on stream ecology and vital trout habitat. Maltby Hollow Brook has some of the highest quality water in the region coming directly form the highest peaks in the Catskills. This area provides suburb spawning grounds for brown, rainbow, and brook trout. The proposed dam would cause rapid fluctuations of water flow which is needed to maintain a healthy ecosystem. Furthermore, a slow-moving or still reservoir would heat up, resulting in abnormal temperature fluctuations which can lead to algal blooms and decreased oxygen levels. Today it is estimated that less than 9% of the areas that historically supported brook trout are intact. 
Native brook trout, which require the highest quality waters, currently thrive in Maltby Hollow brook. Altering the stream ecology here would make this area forever uninhabitable to brook, and all other species of trout. 

New York City has one of the largest and complex unfiltered water systems in the country. Ashokan Reservoir provides 40% of this water. The streams affected in this proposal all provide class A water from the higher peaks and forests down to the Ashokan Reservoir. Diverting water through an open pumped storage system would upset the natural filtration of water coming into the reservoir and likely increase turbidity which would have a negative impact on water quality. Currently, NYC meets its water needs through watershed management and water quality preservation. If NYC were to lose its ability to use unfiltered water due to loss of water quality, the estimated cost to operate a filtration system could exceed one million dollars per day. 

Furthermore, this proposal would have an extreme impact on the watershed communities affected. All three sites would put sections of each community underwater. This includes infrastructure, roads, historic sites, and some of the most pristine homes, estates, and private lands in the region. The remaining sections of each community would be transitioned into a vast flood zone. At time when global warming is making the weather more extreme and the streams flashier and more erratic. 

I think it would be in Prime Energy’s best interest to first do some basic research on a proposed site instead of hastily picking spots from a topo map from thousands of miles away. Prime Energy’s proposal is ill-conceived and unacceptable, and it is my hope that FERC will reject this proposal. 

Thank you for your time.

Sincerely,


Miles T. Naughton

Kim Lipfert, West Shokan, NY.
To Whom It May Concern, 

I wish to voice my opposition to the proposal put forth by Premium Energy Holdings to build a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. Although I agree that sustainable and renewable energy is important, I strongly oppose Project P-15056-000. I believe the Catskill Mountains is not the right place for such an intrusive project, and would have a long-term devastating impact on the environment and community. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams that are part of a Status 1 State Forest Preserve, and cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 

In addition, a long-term project of this kind, with a constant flow of heavy construction vehicles and road restrictions, would deter much relied upon tourism, and cause road congestion for many years for the community.

And lastly, a project of this kind with a massive power line path would cause many homes of established residents to be vacated and possibly leveled. This displacement of families, including my own, who have built and maintained their homesteads over many years, respecting and preserving the surrounding environment, would be absolutely devastating.

In conclusion, I believe the project would be better suited in a location that:

1. Is not a Status 1 State Forest Preserve.
2. An area where an “Add On” reservoir does not pose a serious risk to one of the largest reservoirs providing pristine drinking water to NYC residents, and local wells.
3. Is situated in an area that is not populated by a community of long-term, established residents, who rely on a healthy tourism economy. 


Please do everything in your power to prevent this proposal from moving forward.

Respectfully,

Kim Lipfert
52 Brodhead Rd
West Shokan, NY 12494

Regina Lipfert, West Shokan, NY.
To Whom It May Concern,

I am writing to voice my objection to Project P-15056-000.

I have been a resident of the town of Olive for 52 years and I am very concerned about the negative effects that this project will have on such a pristine area which is currently protected by the New York State constitution.

These are my concerns:

1. The negative effects on the New York City water supply and local wells.
2. The destruction of wildlife habitat and forestry.
3. The decline of tourism in this area that would directly affect our local community and businesses.
4. Many residents will be displaced including my family due to the proposed power lines that will directly run over my property and home.

In closing, I want to emphasize my commitment to preserve the natural environment of the Catskills Park and respectfully ask you to deny any permit applications related to this project.

Respectfully,
 
Regina Lipfert
52 Brodhead Rd
West Shokan, NY 12494

Gina Giuliano, CASTLETON ON HUDSON, NY.
I grew up in West Shokan, where my maternal ancestors lived since 1792. I currently have a house in Olivebridge. The Ashokan Reservoir is beautiful; it is also the evocative watery grave of Old West Shokan and nine other hamlets in the Towns of Olive and Hurley. Recently nearby “new” Boiceville was carelessly  partially erased due to flood mitigation. The latest lunacy, the Ashokan Pumped Storage Project, is not needed and is a threat to the public. It would be unsightly. This project is far too much of a risk to a precious resource: drinking water. It was conceived of by secretive opportunistic entrepreneurs from distant states with no appreciation of nor respect for the culture, historic, and ecological significance of the area. West Shokan and the Ashokan are sensitive environmentally. The Catskills have been abused enough; please do not allow it to happen again.

Alex Marshall, Olivebridge, NY.
It’s an admirable idea to improve sustainable energy   storage and reduce cost. The proposal in question raises several issues — cost,immediate Impact on local communities and long-term amenity.

No cost estimate is included in the proposal, but on the face of it, the amount and nature  of construction must be considerable.

Extensive construction in a remote area — much of it designated wilderness — will cause considerable upheaval to local residents, and reduce attraction to tourists.  The Catskill Park is unique in its unspoiled nature and its accessibility to East Coast population centers.

The final form of the project is unclear, but at the very least there will be new building and transmission lines. The impact on the unique character of the Catskill Park will be permanent. 

Finally, with the best will in the world, there will be some impact on the Ashokan Reservoir, the major supply of water to New York City.   

For these reasons I oppose the proposal 

Regards 

Alex Marshall

Submission Description: (doc-less) Motion to Intervene of Mary Huhn under P-15056-000.

Submission Date:        4/2/2021 4:33:26 PM

Filed Date:             4/2/2021 4:33:26 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               maryhuhn@mac.com                         maryhuhn@mac.com                        

Basis for Intervening:
Motion to Intervene

Motion to Intervene of Premium Energy's Ashokan Pumped Storage Project

I live at 55 Moonhaw Road in West Shokan NY 12494 and will be directly impacted by this project, which will negatively impact the Catskills' environment, wildlife and communities. 

Thank you
Mary Huhn

Other formats

2 April 2021

Ashokan Pumped Storage Project

Docket Number P-15056

I, Salomon Weir, file this Motion to Intervene in this proceeding.

Salomon Weir

106 Stony Clove Lane, Chichester, Ulster County, NY 12416

845-688-7395

salzweir@gmail.com

I will be directly impacted by the project’s effect on the Stony Creek,
New York State Route 214, the Esopus Creek, and the Ashokan Reservoir in
Ulster County, which provides 40% of the unfiltered drinking water for
New York City.

Therefore, I Salomon Weir, respectfully request that the Commission
grant my Motion to Intervene as a party with full rights to participate
in all further proceedings.

Respectfully submitted on 04/02/2021

Salomon Weir

106 Stony Clove Lane

Chichester, Ulster County, NY 12416

Chase Kruppo, Fleischmanns, NY.
There is no doubt the kind of pumped storage energy systems like that proposed in this application have value in advancing the expansion of renewable energy in the region. 

The issue is that this is not the place in which to site a project that has legal and environmental implications that span local, county, city, and state governments. The most glaring oversight is that this project inevitably disturbs over 100 years of sediment since the Ashokan reservoir was built in 1915.

The construction is one phase of development that impacts water quality in the reservoir. The continuous daily pumping and discharge of water between any new upper holding reservoir and the Ashokan assures that turbidity is permanently elevated in one of the most sensitive trout fisheries in the Catskill Forest Preserve. 

Not least of all, affecting drinking water quality for the 9 million customers in New York City, as 40% of its unfiltered drinking water passes through the Ashokan reservoir. The City of New York does not have the capital to construct a filtration system, having for decades relied on the undisturbed nature of the Catskills region to provide that water. It is the largest unfiltered water system in the world.

I write my comment as a farmer and agritourism operator just west of the proposed site. In recent years major bridge construction along the Route 28 corridor served as an impediment to tourists accessing the interior of the Catskill mountains. When guests visit from afar, the last thing they want is to sit in traffic or take long detours to reach their destination for a weekend or holiday trip. The construction of a new dam and proposed infrastructure inevitably places a burden on the local tourist economies. The damage to local tourist economies isn't off-set in the long-run by the temporary construction jobs that are created.

Lastly, this is not a closed-loop project. It's an add-on project. The Esopus River flows into and out of the Ashokan Reservoir before meeting the Hudson River. This project directly interacts with a unfiltered public water source. As it is within a State Forest Preserve, the Catskills are designated Status 1 land under USGS “Gap Analysis Program.” The Dept of Energy's own materials on hydropower indicate that development of Status 1 or 2 lands should be avoided.

Changes to land management in the State Forest Preserves must be passed by
constitutional amendment, voted on by two consecutive sessions in the state
legislature, then submitted to the public in a referendum.

This is the right project in the wrong place. It's not a simple not-in-my-backyard situation, it seems as if this permit proposal was submitted without any contextual understanding of what water source Premium Energy Holdings wants to use or the land that will be required to implement the project.

Please deny the application for this project.

Rebecca Van Kollenburg, PURLING, NY.
As an avid hiker in the Catskills and resident, the project would be devastating to our forever wild landscapes in the Catskills, as well as to the water supply of our down state neighbors in New York. Protection of our nation's public lands are integral to the fabric of American identity, and this proposal undermines the New York State Constitution.

Kristen Edwards, Ulster Park, NY.
Dear Federal Energy Regulatory Commission, 

I am part of the Catskills community and would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook is where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats. Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 

Thank you for your time, 

Sincerely,
Kristen Edwards

Jasmine Jordaan, West Shokan, NY.
Dear FERC Representative,

 

I am writing in my capacity as a concerned property owner in one of the potential dam sites as well as an attorney who has worked for several years for the New York City Department of Environmental Protection working on protecting the watershed through their land acquisition program. The first point that jumps out at me is the huge turbidity threat that this project poses to the New York City drinking water which Services more than 9 million people. Although I see the benefits of hydroelectric power, it is not feasible in our location due to the interests of New York City and the implications of this project interfering with the Environmental Protection Agency's Grant of consent for the NYC Filtration Avoidance Program. So not only is there a City issue here there is an interference with a federal agency's consent. Granting this permit will result in years of litigation with New York City as well as several federal agencies and state agencies. Aside from this monumental hurdle to this project there is several other huge implications such as the fact that the Catskill Park is one of the only national areas with more than 700,000 acres in continuous protection by the state as well as the city (due to the land acquisition program). This protection has been in effect for over 100 years and has resulted in animal and stream habitats that would be directly affected by this project. This project appears to not only create a huge dam but also to require high voltage electric lines to be put in place through protected lands. This is yet one more issue with this project. Also, in reviewing the application there are several misrepresentations a glaring one being that the company is describing this as a closed loop system which is not correct. Ashokan reservoir has the Esopus running into it which clearly is not a closed loop system. From participating in several meetings concerning this project it appears that there is tremendous opposition to this and I hope that you take all these comments into consideration and not Grant this initial permit which will save many hours of taxpayers money since this will trigger tremendous amount of litigation. I'm surprised that this California company has made an application which takes on the entire New York City water supply system. Thank you for your attention to this, Jasmine Jordaan

Parihan Rahman-Porras, Hurley, NY.
Hello,

I am very concerned about this proposed hydro-electric power plant from Premium Energy LLC and I vehemently oppose it. By allowing this to be built you will destroy highly preserved forests, wildlife, and stream ecology. The project would increase turbidity and pollution in the protected Ashokan Reservoir, which supplies 40% of NYC’s drinking water. Private property would be taken by eminent domain—a process that has ALREADY displaced thousands in this area when the Ashokan Reservoir was built.
 The Catskills are a State Preserve protected by the NY State Constitution and this proposal is in violation of it. We will take this to the rest of the NYS government  to voice our concern as this proposed plant is illegal and should not move forward.

Tricia Bard, Fleischmanns, NY.
I am writing today, as a concerned Catskills property owner, about a CA company, Premium Energy Holdings recent proposal to FREC, regarding creating a pumped storage hydroelectric plant, using the Ashokan Reservoir.

Despite the fact that I strongly support clean/ renewable energy initiatives, I oppose this move for 2 primary reasons:

(1)  This project will significantly impact homes and communities, local infrastructure, water quality, and natural habitats on public and private lands.  Recreational use of the land, tourism and local economies would also be impacted. 

(2) This plan was submitted without input from NYCDEP, NYS’s Dept of Environmental Conservation, or from local leaders or stakeholders.  

I firmly believe that this project should not move forward. 

Sincerely,

Tricia Bard

Jacqueline Lovelock, Shokan, NY.
As a resident in the area, I object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application. 
This proposal would cause irreversible harm to the area, residents and wildlife. And is not acceptable.

Greg Farley, Catskill, NY.
I oppose the dam being proposed in Ulster county NY. It will threaten protected lands water and local towns and neighborhoods tourism fishing and much more.

Joan Hall, Phoenicia, NY.
I live in Woodland Clove. I treasure the wildlife here and love trout fishing in the Esopus. Premium Energy's Proposal would disrupt the ecology in this area. I would harm the economy from tourism, as people come from many places to fish and enjoy the Catskills. The Catskills are a State Preserve protected by the NY State Constitution. I urge you to stop this project immediately.
Thank you.
     Joan Hall

camran hartman, Lake Placid, NY.
To Whom it may Concern,
​FERC Project No. 15056-000, Ashokan Pumped Storage Project, submitted by Premium Energy Holdings LLC, Walnut, CA goes directly against New York State Constitution. “ The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold, or taken by any corporation, public or private, nor shall the timber thereon be sold, removed, or destroyed.” – Article XIV, New York State Constitution.  
Reasons to say “NO” to the proposed dam.
- The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index
- As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
- Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the NYC water supply
- The largest unfiltered water supply in the nation, built at the cost of displacing 25 communities
The American people have been stepped on too many times, please do not hurt our mountains any further.
Sincerely,
Camran Hartman

Kathleen Kuhlman, New York, NY.
This is a very bad idea. Please ensure that New York City is involved in responding to this terrible proposal. In addition to the severe environmental impact to a beautiful wild state-protected area, the ultimate consequences to the water system of the greater New York City area would be profound. It was also very sneaky of the company to make this proposal without informing highly interested parties such as New York City Department of Environmental Protection, not to mention state and local government entities. It is an indication that this company has a severe lack of principles and trustworthiness. Please deny the proposal.

Emily McKenna, Elmore, VT.
In re: P-15056-000, and as someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Eric J. Della Vedova, Boiceville, NY.
To whom is may concern:

I am writing to voice my extreme concern about Premium Energy Holdings, LLC Ashokan PSP's application for preliminary permit for document (docket number P-15056-000). I believe this proposed project would be very detrimental for the environment, the community, and Ulster County's economy. 

Specific concerns include:

1: The Catskills are a State Preserve protected by the NY State Constitution, and this would disrupt this protected land
2: The project would increase turbidity in the Ashokan Watershed and negatively impact NYC’s drinking water
3: The project would be detrimental to our local community by disrupting our economy and displacing residents
4: The destruction of our natural beauty would negatively impact tourism, an important source of positive economic impact for Ulster County

Please do not allow this proposal to move forward.

With kind regards,

Eric J. Della Vedova

Mark Lerner, KINGSTON, NY.
This project will be a disaster on many levels

The Catskills Forest Preserve are meant to be forever kept as wild
forest lands.

The forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index.

There will be terrible impacts on local stream ecology and impacts to the NYC water supply

There will be large impacts on our local tourism economy.

Judith Maguire, Roxbury, NY.
This proposal is shocking, outrageous and totally ill considered! And it shows NO knowledge, respect or concern for the Catskills and its people—and NYC. Clean, fresh water is the Catskills greatest resource. Which is why we have fought so hard against fracking—and won! Our tourist industry is dependent on that water, for fishing and so many other recreational activities. In addition, the Catskills has many family farms, and fresh water is crucial for livestock, cows, sheep and increasingly alpacas and horses, and of course, it is also necessary for agriculture. The Catskills are America’s first great wilderness, lost in the 19th century to other irresponsible uses, such as the destruction of the hemlock forests by the tanning industry. Due to protections, such as codifying the Catskill Park as Forever Wild in NYS law (and how does this irresponsible proposal get around THAT?), the Catskills and its waters, which were thoroughly polluted by past egregiousness, have revived. Our streams and rivers offer some of the best fly fishing, as the trout, along with many mountain critters, such as the white-tailed deer and black bear, have returned with our reforested slopes and clean water. Our waters also, and crucially,  supply drinking water to New York City, and the Ashokan Reservoir is the main reservoir whose sweet, clean waters flow to downstate. This project would put that water supply at risk!  And according to one article, the NYDEP, in addition to the Catskill towns concerned, was not even notified? And according to the same article, a Catskill town would be flooded for this? Absolutely not! That happened to too many villages to build the reservoirs. Catskillers, folks native to this area and the many downstaters now increasingly living here—and lots more have moved here due to the pandemic—simply won’t stand for this. This project would alter the hydrology of our local waters, the Esopus Creek, for starters, affect the quality of our water for recreational and drinking uses, both on a personal and commercial level, and also—and just as important—impact our wildlife, which has struggled and finally succeeded in making a comeback here. The Catskills, as anyone making such an irresponsible proposal, soon learns, are home to many committed, passionate and EFFECTIVE grass-roots environmental groups and individuals who will resist any such efforts that would result in compromising in any way our precious natural resources. My vote is a resounding NO!

Other formats

Jenn Wexler, Brooklyn, NY.
March 30, 2021

Kimberly D. Bose 
Federal Energy Regulatory Commission 
888 First St. NE, Room 1A 
Washington, D.C. 20426. 

Docket number P-15056-000 


Ms. Bose,

I’m writing regarding Premium Energy Holdings of California’s proposal to build a hydroelectric power plant at the Ashokan Reservoir in New York’s Catskill Mountains, including a 300-acre reservoir at one of three sites and a tunnel to bring the water to the east shore of the upper basin of the Ashokan Reservoir. The three sites are Chichester, Woodland Valley, and the Moonhaw valley in the hamlet of West Shokan, Town of Olive. My comments focus on Moonhaw and West Shokan.  

This construction would impact state land, and as a designated Wilderness Area of the New York State Forest Preserve, the upper reaches of Moonhaw valley are protected from development, per Article XIV of the New York State Constitution.

Also building in these areas would have a devastating impact on tourism in the Catskills, which is integral to the NYS economy, generating 17% of employment in the region in 2019 and providing about 20K jobs, with Ulster County representing 43% of that market and second homes in the area creating $360 million in economic activity.  

Moonhaw is also a community with many homes, valued up to $2.5 million each. This thriving community would be decimated by this construction.

I strongly urge you to recommend that Premium Energy’s proposal be rejected.

Sincerely,

Jenn Wexler

Douglas Kerr, Schenectady, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings of Southern California as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for millions of people in both Upstate New York and New York City. If this project moves forward, the company would be tearing into the valleys in the towns of Olive and Shandaken, leveling several hamlets in the process. Please do everything in your power to prevent this proposal from moving forward.

Michael Dean, Lanesville, NY.
The company seeking the permit have shown zero concern for the people, community and land that the project would impact.  Their assurances that the project would only be undertaken with approval of the community are entirely hollow, evidenced by the complete lack of due diligence done before dropping proposed reservoir sites onto a map.  The applicant clearly did not make even the most basic effort to understand the areas they propose to investigate.  Had they done so, they would have easily realized that their proposal would encroach on legally protected forever wild lands and displace entire hamlets and residential areas.

Rather than requiring the community to go on high alert and rush to defend itself against a poorly though out proposal, perhaps the better path would be for the applicant to construct a proposal that is not completely devoid of basic knowledge, insight on or concern for the local region.  Then having demonstrated that basic level of due diligence, the community could with sufficient time and information, thoughtfully consider and respond taking all the pros and cons into account.

Until then, I ask the FERC to say NO and our elected officials and community to vigorously defend against this proposal.

Melissa A. Rabuffo, Chichester, NY.
Project Docket:  P-15056
Melissa Rabuffo, Chichester, N.Y.

As a resident of Chichester, NY in Ulster County, I am writing to oppose the granting of a preliminary permit to Premium Energy Holdings.  I agree and support the national initiative to increase and transition to renewable energy. It is a necessary goal and objective nationally, as well as worldwide.  I am in support of reducing our dependence on fossil fuels and reducing the effects of climate change, but this proposal is not the right plan and it does not reflect the right kind of initiative which the Department of Energy should approve.   

This portion of the Catskill region, and all three proposed sites, are not the right location for this project due to its incredible impact to state preserved forest land, streams, and the New York City Water Supply.  It is also unlawful and in direct violation of the New York State Constitution and puts in question using public land for private gain. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Any changes to the land management in the State Forest Preserve must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, and then submitted to the public in a referendum.  For that reason alone, this proposal misunderstands or does not take into account the logistical issues of such a project. 

The proposal itself is full of inaccuracies and lack of diligence which makes one suspect the Premium’s ability and basic understanding of scope to engage in this endeavor. The proposal claims that it is a closed-loop system, yet it is connecting to the Ashokan Reservoir. The Esopus Creek and other streams connect to the Ashokan Reservoir so in effect this is an open-loop system.  The Department of Energy encourages the use of close-loop systems, but not open-loop systems.  In addition, Premium Energy did not inform the various stakeholders and communities that could be impacted for comment. 

As the largest national preserve closest to New York City, as well as supplying 40% of its drinking water, the amount of protest and concern would be overwhelming. There are also legitimate concerns about how this open-loop system would impact turbidity and water quality for over 9 million residents in New York City.  

Environmentally, the Catskills Forest Preserve created in 1885 in Ulster County and is 700,00 acres of continuous wildlife habitat in an increasing fragmented environment.  The proposed reservoir falls within the Audubon Catskill Peaks Important Bird Area.  As a State Forest Preserve, the Catskills are considered Status 1 under the USGS “Gap Analysis Program”.  According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

As it stands, there is strong opposition from all represented parties locally including townships, conservation groups, business owners, as well as an involved and invested residents and visitors.   Phoenicia, which is the largest town in this area,  is one of the most popular tourist attractions in the Catskill Mountains.  Phoenicia is rated as one of the Top Ten Small Towns in America (Budget Travel Magazine). It also has been ranked as the #1 destination outside of NYC.  The amount of people who are moving to or trying to live her full time in the last year is astounding.  The local and regional resistance to taking land from existing home owners or potential homeowners would be a political nightmare and a public relations disaster for Premium.  

Historically, this is an area which was flooded 100 years ago to create the Ashokan Reservoir and displaced 22 townships.  There continues to be historical trauma and outrage in this area which is significant to this day.  Our area is filled with brown signs along our roads declaring Former Site of West Shokan, Olivebridge, Ashokan, and Shokan, as well as towns which no longer exist such as Brown’s Station.   The residents and those who love the Catskills would vehemently oppose this happening again in this area. 

Due to the Catskill Forest being a protected preserve protected by the NY State Constitution, the misleading and inaccuracies of the Premium Energy proposal, the direct threat to NY City drinking water and environmental impact, and strong public opposition, are all key reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.


Project Docket:  P-15056

Bushra Rehman, West Shokan, NY.
Dear Federal Energy Regulatory Commission, 

I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056:000. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 
First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

I live on Moonhaw Road, one of the locations under consideration. The end of our road, where one of the storage facilities is being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 
In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats.  Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 
I ask that you deny this permit based on these essential points. 

Thank you for your time, 

Sincerely,
Bushra Rehman

Tibet House US / dba Menla Mountain Retreat, Phoenicia, NY.
As a non-profit business in one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, we vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

We are a tourist attraction, and this unsightly project would negatively impact tourism in our town. Also, years ago we did a large study on the local ecology in our valley, and our property and surrounding area are home to several endangered species of birds (including the eastern hellbender and the Bicknell's Thrush), a rare sanctuary to hundreds of species of lichen, in addition to providing habitats for rabbits, foxes, deer, turkeys, coyotes, fisher cats, bears, and even mountain lions, among other species.

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams, disrupt the local ecosystem, and cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Michael Burbank & Lynn Schauwecker
Co-Directors, Menla Mountain Retreat

Dave Binck, Olivebridge, NY.
This project would have unacceptable ecological, economic and quality of life impacts on the community in which I live and work. I along with my family strongly object to this project and the devastation it will bring. This project puts our environment, drinking water and livelihood at risk. Strongly oppose.

Victoria Lopez, New City, NY.
Dear Federal Energy Regulatory Commission, 

I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

Yet, this is what is being proposed by Premium Energy. 

The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats.  Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 

Thank you for your time, 

Sincerely,
Victoria Lopez

Anna, NYC, NY.
Dear Federal Energy Regulatory Commission, 
I am part of the Catskills community that would like to bring awareness to a pending proposal from Premium Energy: FERC project and sub- docket number: P-15056. Premium Energy is has applied for a preliminary permit to conduct studies on building a pumped storage plant utilizing the Ashokan reservoir. This project raises environmental concerns and we ask that this permit be denied based on information in this letter along with additional information which is being provided from Interveners and concerned citizens. 

First, it is essential to note that Premium Energy is misrepresenting this project by describing it as a closed loop project. According to hydro power experts in the area, this is not a closed loop project. It is an add-on project which will have much more of a detrimental environmental impact than a closed loop project. This misinformation used to push the project forward is deeply troubling to the community and raises concern over Premium Energies practices. 

A site where the storage facilities are being proposed is designated Forever Wild. Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  

All the sites in this proposal are within the Catskills, which is designated as Status 1 land. According to the Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 
Yet, this is what is being proposed by Premium Energy. 
The Protected Three Birds Orchid currently at the end of Maltby Hollow Creek and both sides of the upper Dry Brook where one storage facility is being proposed. These sites are registered in the Biological and Conservation Database for North America. All proposed sites in this project are noted by the Audubon society as a “Catskills Peaks Important Bird Area.”

The sites in this project are foraging habitats for NY-threatened northern long-eared bat and habitat for NY-Species of Greatest Conservation Need, black-throated blue warbler, scarlet tanager, and wood thrush, as well as NY-Special Concern raptors Cooper’s hawk, red-shouldered hawk, and sharp-shinned hawk. It is also habitat for NY-Special Concern eastern hognose snake and NY-Threatened timber rattlesnake. 

In addition, Maltby Hollow Creek, Wittenberg Brook and the Esopus are trout waters and trout spawning habitat. Pumped storage upper reservoirs are subject to rapid fluctuations of water which can wreak havoc on aquatic and land habitats.  Sediment in tributaries to the Esopus will alter the sediment in the Esopus, one of the Catskills’ most vital trout waters. Valuable trout breeding habitat will be lost.

Our community understands the need for clean energy and for pumped storage. However, these proposed locations are in the habitat of threatened species. Forever Wild areas and  Status 1 protected land. 

I ask that you deny this permit based on these essential points. 
Thank you for your time, 
Sincerely, Anna

Submission Description: (doc-less) Motion to Intervene of Theodore Gordon Flyfishers, Inc. under P-15056-000.

Submission Date:        3/31/2021 1:11:54 PM

Filed Date:             3/31/2021 1:11:54 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Theodore Gordon Flyfishers, Inc.         stevelieb123@gmail.com                                                           

Basis for Intervening:
Theodore Gordon Flyfisher, Inc, (TGF) is a not-for-profit angling organization committed to stream and river protection and the preservation of wild trout populations in the Catskills.  If approved, the proposed project will impact the quality of the water of the Esopus and its tributaries.  TGF moves to be made an Intervenor in these proceedings to represent its members, who have a vital interest in the protection of these rivers and streams.  TGF’s members are avid anglers that live in the Northeast and frequently fish in the Esopus and its tributaries.

Since its founding in 1963, TGF’s singular mission has been to preserve the habitat of wild trout populations, including the native brook trout in New York State.  The locations of any of the three dams proposed for the project will eliminate or severely restrict the flow of water in a tributary to the Esopus river.  Each of those tributaries provide critical spawning habitat for wild and nativized trout, including native brook trout.  Reducing spawning habitat will impact the population of wild trout in the river system and degrade the quality of the river system that TGF members use for recreation.  

TGF members are intimately familiar with the condition of these streams.  Many of them have spent a lifetime fishing these waters. On behalf of its members, TGF successfully sued the City of New York under the Clean Water Act to require the City to monitor and reduce turbidity of water the city released into the Esopus.  See Catskill Mountains Chapter of Trout Unlimited, Inc. v. City of New York, 451 F.3d 77, 62 ERC 1737 (2d Cir. 2006).  Through its continued efforts to advocate for the protection of the Esopus, TGF’s directors and members have gained a deep understanding of the river system and can provide a unique perspective to the proceedings.   

TGF works hard to keep its members informed of conservation issues that effect the cold-water fisheries around the Northeast, including the Esopus watershed.  For over twenty years TGF has kept its members informed about important conservation issues in the region through the publication of its newsletter, Gordon’s Quill https://www.tgf.org/publications.  The TGF board receives feedback from its members and remains informed of their concerns.  Granting this petition to have TGF added as a party to these proceedings will allow TGF to represent the interest of its members related to this project. 

Neither disruption to the proceedings nor any additional burden to any party will result from the granting of this Motion.

Submission Description: (doc-less) Motion to Intervene of Woodland Community Association under P-15056-000.

Submission Date:        3/31/2021 1:20:00 PM

Filed Date:             3/31/2021 1:20:00 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Woodland Community Association           woodlandvalleymail@gmail.com                                                     

Basis for Intervening:
Woodland Community Association
PO Box 509, Phoenicia, NY 12464

Motion to Intervene: Project P-15056
Application for Preliminary Permit 
Premium Energy Holdings, LLC 
Ashokan Pumped Storage Project

Ms Kimberly Bose, Secretary							3/28/21
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC
20426

Dear Secretary Bose,
Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314) the Woodland Community Association, the only organization representing home and property owners in the hamlet of Woodland Valley in the Town of Shandaken, Ulster County New York, hereby petitions the Federal Energy Regulatory Commission to grant it intervener status in the above proceeding. 

All communications should be addressed to:

Bethany Saltman
President 
Woodland Community Association
PO Box 509 
Phoenicia, NY
12464
woodlandvalleymail@gmail.com

Basis for Intervening: 
The Woodland Community Association represents the home and property owners of Woodland Valley who have an interest in the Preliminary Permit application submitted to the Commission by Premium Energy for the Ashokan Pumped Storage Project (P-15056). The proposed reservoir in Woodland Valley would either flood, or cut off access to, almost all of 200+ homes in Woodland Valley. Accordingly, the Woodland Valley residents have a primary and vital interest in this matter. We seek to become a party to this proceeding to insure that the interests of the residents are properly represented. 

Neither disruption to the proceedings nor any additional burden to any party will result from the granting of this Motion. In light of the foregoing, the Woodland Community Association respectfully petitions for intervener status. 


Bethany Saltman
President 
Woodland Community Association

Russell Higgins, Lanesville, NY.
Proposed site is inappropriate for pumped storage and will not efficiently use funds to provide maximum peak storage capacity.

Pumped storage projects usually use ‘cleaned’ / lined reservoirs on vacant land, like Blenheim – Gilboa, to ensure water quality.  Proposed reservoirs would be created in heavily occupied areas including abandoned & lost septic systems, congregate & private dumps, lead & asbestos in most buildings.  Areas are covered in dense forest.  Remediation necessary for removing and disposing of contamination would be very costly.

Pumped storage projects rely on NATRUAL elevation differences, low bermed reservoirs to minimize costs & transport of massive quantities of concrete & reinforcing for high dams with far less requirements for in depth foundations, as well as far less problems with silt, debris, & and other contaminated construction run off. 

Bedrock depth varies up to and over 500 feet in place.  Soil column contains strata’s of artesian springs, voids, quick sands, clays, rock etc. This needs removal, shoring, dewatering to blast foundations into bedrock.  Anything less risks dams failure which would kill thousands living clustered along stream banks & render the Ashokan Reservoir providing water for 10 million, contaminated, useless

Interrupting aquifers that travel along valley bottoms, wells for all buildings down stream are at risk, failure will require yet more property acquisition.

Construction of MASSIVE dams will require MASSIVE amounts of trucked in material over a SINGLE TWO LANE ROAD.  Such loading will beat the highways to rubble & will probably wear out all but the 2 main highway bridges.  HUNDREDS of trucks a day will spew mammoth amounts of pollution to the many buildings close to the roads.  Vibrations will lead to damage to many.

Areas are fully occupied with homes lining roads.  Roads in subject areas are critical access roads to other areas with limited access. Electrical power to subject valleys is from one end only and this project would leave stranded all properties not flooded from both power and access requiring their acquisition also.

Proposed dams are inappropriate for pumped storage projects ESPECIALLY as part of a municipal water supply system for over 10 million people, as they will CERTIANLY lead to extensive construction contamination followed by even more contamination from reservoirs filled with remains of if not actual hundreds of thousands of trees, asphalt highways, drives etc.  Acquisition costs alone will exceed ½ billion dollars unless owners are paid LESS than what they’ll need to buy homes in the area, close to family, friends and jobs. Remediation of constructed environment will cost hundreds of millions including digging up dozens of acres of abandoned dumps along with the soil sewerage and garbage wastes percolated into.  Tens of millions will be needed for the removal of trees and other bio mass and stabilization of the bared forest floors to prevent their quick erosion from creating an ecological disaster.  The project will also need to reimburse NYS tens of millions for repeated road reconstruction and bridge replacements as it’s hundreds of trucks a day destroy them.  The project will need to reimburse tens of millions more to hundreds, thousands of property owners from vibration damage to homes often yards from roads, & to businesses for loss of income from truck, fume, and dust choked roads and hundreds of millions for tourism businesses for permanent reduction of business.

Furthermore, the proposal to site the generation facility in massive caverns deep under ground with miles of associated access, air, and water tunnels up to 50 feet wide, through loose fills saturated with water to solid bedrock will create the most expensive generator building in the US.  As being located and connected to and BELOW the level of the Ashokan Reservoir any failure of dewatering pumps will risk the contamination of the reservoir with tons of lubricants & chemicals needed to maintain generators & building, along with leachate from plastics and chemicals embedded in the generator building itself.  

These issues, along with the work being performed in the most costly construction market in the US, subject to approval by NYS and NYC Building Codes as well as NYS and NYC DEP regulations and approval PLUS Federal Oversight to ensure water quality remains unaffected by the work or operations will be the most expensive hydro power project every attempted in the US and no doubt the most expensive pumped storage project in the world.

For the BILLIONS it would take to realize this projects full potential similar capacity of liquified compressed air off peak storage as is being installed on remote islands could be located nearest power hungry areas, thus saving on transmission system costs and transmission losses.

The application is a virtual cut and paste of prior applications down to facility size, power house location, and the most dubious and vague construction methodologies.

The applicant has also been reported to have made ignorant if not misleading statements, indicating the firm is working at the request of PSEG Long Island to provide peak power for LI.  All transmission lines feeding NYC & LI are maxed out on peak days.  The very time the energy would be most needed, the facility would need to sit idle.  (Ashokan-Plant_Hudson-Valley-One.pdf (shandaken-ny.com))  The applicant also states that as engineer they have no interest in the project, despite 5 million dollar cost of report nearly DOUBLING yearly billing.

The above indicates an inability of applicant to perform to a minimum standard of veracity care and due diligence VITAL in the construction of SIGNIFICANT dams and infrastructure, inability of same to design facility to produce power at economical price to consumers, and inability to care for the water supply of over 10 million people, and should require the immediate rejection of this application.

Morgan Lyle, Brooklyn, NY.
I write to ask the Commission to reject P-15056, the proposal by Premium Energy Holdings to construct a pumped storage facility in the Esopus Creek watershed in New York.

As a resident of New York City, I find the potential for damage to the city’s drinking water supply completely unacceptable. As a native of Ulster County, I am appalled by the idea of burying any of the three communities and locales cited in the proposal, each of which I have visited whenever possible throughout my lifetime. And as an avid angler, I can scarcely believe that anyone in the 21st century would suggest destroying the habitats of heritage-strain brook trout and wild, self-sustaining rainbow trout. The project would be very damaging to the outdoor recreation industry that is so important to the area.

I am a strong supporter of renewable energy, but this proposal is a terrible idea. Again, I ask you to reject it.

Morgan Lyle

Steve Golden, Olivebridge, NY.
On behalf of Golden Woodlands, LLC, I urge FERC to decline Premium Energy Holding’s request for a preliminary permit for the Ashokan Pumped Storage Project P-15056. My family has been a landowner in Olivebridge, NY since 1950, and the third generation of our family currently lives on our property.  Golden Woodlands, LLC, the land holding entity for the family is adamantly opposed to the highly destructive proposal submitted to FERC by Premium Energy Holdings.  We will collaborate with others opposing this project until it is defeated, no matter how long it takes.  We have very deep roots in the community and will actively oppose this proposal which will drastically impact the area’s ecology, landscape, economy, and detrimentally impact the NYC water supply.

The Town of Olive is the wrong place for a project of this type.  The community, which still harbors some resentment from its relocation due to the construction of Ashokan Reservoir has contributed substantially to the public welfare of the State and region.  Bound by forever wild lands of NYS Department of Environmental Conservation in the Catskill Forest Preserve, and highly protected lands within the NYC Department of Environmental Protection Watershed, its resource base is already limited and cannot afford to be severed by an additional reservoir and lengthy transmission lands.  

A project of this type should only be located closer to a population center and existing transmission facilities, so as to more efficiently utilize the energy savings created.
It appears that the transmission lines for this proposal will cross property owned by Golden Woodlands.  We guarantee the applicant will have to use eminent domain to acquire any of our holdings and we will fight at each step of the process placing every legal obstacle in the way.  Several of our neighbors have all agreed to make a concerted effort to challenge any access to the property along the route shown on the preliminary map.

We will insist that the applicant submit a full environmental impact statement and analysis of alternatives sites considered.  It is also our understanding that the reservoir sites and transmission lines identified potentially impact species of special concern including both plants and animals and that the US Fish and Wildlife Service needs to thoroughly investigate all potential impacts in the entire watershed.  

The Ashokan Reservoir is a engineering achievement of extraordinary national historic and cultural value and is eligible for listing on the National Register of Historic sites and merits protection of its entire infrastructure including the quarries and roads which were used in its construction.  A detailed historical survey must be completed for planning to proceed.  

Finally, the economy of the southern Catskills will be drastically impacted by a project of this magnitude, and a comprehensive assessment of its economic impact is essential.  It is likely that the negative impact on the region’s value as a world class fishery, its historically notable landscapes painted by the Hudson River School of Painters, and written of by notable early conservationists like John Burroughs, the popular Catskill hiking trails in the area, and extraordinary opportunities on and off-road biking must be accounted for.  It seems likely that far more value will be lost than that created by the pump storage project.

Please stop this project and decline a preliminary permit now rather than create the long-term disruption and cost it will inevitable create with very uncertain outcome.  Simply this is the wrong place for this type of project.

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Suzanne Keusch, Chichester, NY.
March 29, 2021

FERC Docket # P-15056

I own a home on Stony Clove Lane in Chichester, NY.  I am writing in opposition to the granting of a preliminary permit, now under consideration, to Premium Energy Holdings (FERC Docket # P-15056.

The company claims that the project will take place outside the boundaries of the Catskills Forest Preserve.  But a study of the proposed sites shows that they are within the Preserve - which was established in 1885 by the New York State Constitution.  A constitutional amendment would be required to change the use of lands meant to be kept forever as wild lands.

The company also claims that this would be a closed loop system - but a review reveals that it would be an open loop system which would affect the Stony Clove and Woodland Valley Creeks.  It would also negatively affect the Ashokan Reservoir, proposed as the lower reservoir and the source of 40% of New York City’s drinking water, with turbidity due to fluctuations of pumped water.

I understand, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program and therefore are to be avoided for development.   Damage will be done to wildlife habitat, including protected species.

For all the above reasons I urge you to deny Premium Energy Holdings a preliminary permit.

Sincerely yours,

Suzanne Keusch
124 Stony Clove Lane
Chichester, NY 12416

Ralph Legnini, West Shokan, NY.
RE: The Ashokan Pumped Storage Project

We all know time goes on and takes technology with it. But one has to weigh the positive and negative impact of technology on those who it interacts with.

Do we want to flood areas of our community where folks lived and have lived for decades? No!
Do we want to relocate families? No!
Do we want high voltage power lines running right past our house? No!

What are the positives of this plan? That Central Hudson can generate more electricity during the off peak hours to use during peak time? That the company involved putting this all together can make a lot of money doing it?

What are the negatives? Many, many families will be impacted. Their entire lives will have to change. Their serene existence in the Hudson Valley, in the Catskill Mountains will be disrupted. Many will be exposed to the - not disproven - health effects of power lines. Property values will go down for all near those lines. 

We don’t want it.

Virginia Workstus, Olivebridge, NY.
Virginia Workstus
47 Tongorekill Rd.
Olivebridge, NY 12461

Re: FERC project proposal by Premium Energy Holdings 
subdocket # P-15056-000


I have lived full time in Olivebridge, NY for the past 20 years. I want to share my opinion to the proposal by Premium Energy Holdings to build a large dam, reservoir, turbine and tunnels for use in pumped storage and generation of electricity. I oppose this proposed project.

This proposed project is intrusive and will negatively impact the ecology of the Catskill Forrest Preserve, which is protected by the New York State Constitution.  This project is likely to uproot area residents, damage or relocate local roads, damage local lands and streams and cause increased turbidity in waters which are a part of the watershed serving New York City’s unfiltered drinking water system.

This project will be a net consumer of energy, meaning that cheap power will be spent to make more expensive power.  This is short sighted and does not support responsible development of green energy production, which I do support. 

The Ashokan watershed has endured and continues to endure environmental stress.  The local ecosystem faces ongoing challenges to its health.  Pumped storage systems such as the one proposed creates rapid water level fluctuations of the upper reservoir.  These “wreak havoc on ecologically rich areas where terrestrial and fresh water ecosystems overlap.”  

I understand that infrastructure projects like this one often involves trade-offs between the negative impacts and positive good.  The Catskill Preserve and surrounding wilderness areas support the local economies of area towns and individuals.  The current New York City reservoir system sacrificed 33 towns, displacing thousands of residents.  Many area communities such as Olivebridge continue to struggle to survive and depend on tourist dollars.  This proposed project will stress already stressed communities.

This area is not the best suited place to build this proposed system.  Please work to prevent this proposal from moving forward.  Thank you.


Source: Electric Power Research Institute: “Quantifying the Value of Hydropower in the Electric Grid”; Yale 360: “For Storing Electricity, Utilities are turning to Pumped Storage”; DoE HVR

Amna Akbar, Columbus, OH.
I am a regular visitor to the area and have organized multiple events nearby. I am writing to voice my opposition to the destruction of Moonhaw road. This is important preservation land that should be left alone without destroying the ecosystem further. Thank you.

Krishna Fitzpatrick, West Shokan, NY.
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Room 1A
Washington, DC 20426

March 30, 2021

Dear Ms. Bose,

This letter is concerning docket #P-15056-000.

I am writing to express my support for renewable energy, but my opposition to this plan in particular. Premium Energy (PE) has clearly given little to no consideration to the area that they are proposing to build this hydropower dam. 

There are a number of flaws in PE’s proposal. The first being that PE is calling the Ashokan Pumped Storage plan a “closed-loop” system. This is blatantly false. The proposed upper reservoir would rely on the lower reservoir (the current Ashokan reservoir) as a water source. This makes the plan patently an “open-loop” plan.

Number two. The Ashokan reservoir, which PE’s proposed plan will rely heavily on, is an integral and majority resource in NYC’s water supply. The Ashokan provides around 40% of the water supply to New York City’s over 9 million residents. Allowing PE’s plan to go forward would mean increased turbidity and sediment to the Ashokan, not to mention possible risk to overall supply. As climate change continues to affect our world, it’s impossible to know whether the levels of the Ashokan will remain stable in the coming years. 

Thirdly, tt seems with willful ignorance, that Premium Energy has chosen one of this region’s largest continuous wildlife preserves, under the protection of the New York Constitution, as the locale for a hydroplant designed to supply backup power.The sites in question are home to numerous under-threat and endangered species, including the:

	•	Cooper’s hawk
	•	Red-shouldered hawk
	•	Sharp-shinned hawk
	•	Eastern hognose snake
	•	Timber rattlesnake


Premium Energy’s proposal claims the hydroplant would generate 2,800 mega watts of power, but would require 2,000 mw of that power just to operate the plant itself. This equation does not make a strong case for the sacrifice of hundreds of acres of protected wildlife habitat to be wiped out.

I thank you in advance for considering the above points. Again, renewable energy is an important part of our future, and one that I value. However, this plan from Premium Energy is not sound, and should not be allowed to move forward.


Sincerely,

Krishna Fitzpatrick
137 Whispell Road
West Shokan, NY 
12494

Kate Potters, Highmount, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

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John Navarro, Bearsville, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Kelvin Perez, shokan, NY.
The proposed Ashokan pump storage project will cause severe environmental damage directly and indirectly to the area. It will contaminate wells and the surrounding underground water table, due to the chemicals and processes in excavation. It will also damage and affect plant and animal  species that live in a protected area. It would also affect the quality of the drinking water the is supply to NY city.  We request that you do not grant the preliminary permit to this project.

Lynne M Bailey, Hurley, NY.
As someone who recreates on, and lives very near to, the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. It will also have multiple adverse effects, beyond the actual construction areas that we cannot foresee. What kind of wide disturbances will be produced? The vibrations and noise this equipment could produce would also travel long distances underground even further disrupting the environment. So much is at stake. We can't replace one kind of bad system with another one that could destroy the drinking water of 9 million people and cause irreparable harm to the ecosystems it connects with. Spare us this nightmare. It would ruin the entire area, and cause untold economic as well as environmental loss.

I urge you do do everything in your power to prevent this proposal from moving forward.

Eric Booth Miller, High Falls, NY.
I am opposed to the project plan in docket P-15056.  This is the wrong kind of plan for my home area. While I am supportive of alternative energy projects, and recognize that trade-offs are almost always part of energy advancement, this plan has so little energy gain it is not worth the costs and risks. The areas that would be impacted are highly preserved land, and there will be devastating impact to preserved land and streams. Preservation has been hard won over many years, and this plan will undo those gains in a number of areas.  Also, we are going to see a parade of legal ramifications and entanglements emerge if this plan moves forward; I will join them and encourage my neighbors to join them, because they are justified in challenging this wrong approach by Premium Energy. This project impacts wildlife, local tourism and historical preservation, including for Native American history.  The Catskills Preserve in my county of Ulster has been working for over 135 years, and under Article XIV of the New York State Constitution the wording states that the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  As a State Forest Preserve, the Catskills hold Status 1 land designation under USGS “Gap Analysis Program.” According to the Department. of Energy’s own Hydropower Vision: “Areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”

Please stop this ill-conceived boondoggle--the downsides far outweigh the proposed advantages.

Nicole Ryan, Saugerties, NY.
 As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Matthew Ryan, Saugerties, NY.
 As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Bradley Johnsmeyer, Rosendale, NY.
This proposal seems to have major issues that would not only impact the water quality, but the health of the Catskill ecosystem at large around the Ashokan reservoir. 

The well-being of the people in the area, the ability for New Yorkers to be able to enjoy our forests and watershed, without an ill-conceived idea that could destroy our trout fishery, the drinking water, and the on-going tourism in our county, should be paramount. 

Please reject this proposal.

George Kraemer, Shokan, NY.
My name is George Kraemer (52 Old Farm Road, Shokan, NY 12481), and I submit here my comments on the pumped storage hydro plant proposed for locations adjacent to the Ashokan Reservoir (FERC project number P-15056, sub-docket number P-15056:000).

I understand and applaud the commitment to transitioning from fossil fuels to renewable energy sources as a strategy for reducing greenhouse gas emissions.  However, the proposed pumped storage project has numerous negatives, based on location and environmental impact.  These negatives far outweigh the benefits gained by the project.  

Pumped storage reservoirs are environmentally detrimental.  The recently discovered phenomenon of methane emission from anoxic bottom sediments negates much of the switch from fossil fuel combustion to renewable sources.  Methane has ca. 25-times the potential for global warming of carbon dioxide. 

The Department of Energy’s Mission Innovation initiative has as its mission the research and development of clean energy.  Pumped storage is a net consumer of energy.  It is also relatively inefficient, requiring massive volumes of pumped water to store significant energy.  An environmentally better alternative is demand side management of electricity demand to reduce the need for pumped storage.  Pumped storage fails to be either innovative or clean.  

Ecologically, the rapid fluctuations of the water level in pumped storage prevent the development of a diverse, functional community.  Additionally, seasonal discharges of excess water from the proposed upper reservoir will seriously alter the hydraulics of the local creeks, incising stream beds and removing finer sediments and substrates, resulting in loss of biological integrity; the creeks will no longer be functioning parts of the biological landscape, but rather simply canals to release unneeded water.  These sediments will be transported into the Ashokan Reservoir, degrading the water quality of a major (40%) supplier of drinking water to New York City.  

New York State has long recognized the value of conserving wild lands, having the strongest “forever wild” clause of any state’s Constitution.  This 1894 clause directs that state-owned Catskill lands “shall be forever kept as wild forest lands.  They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.”  Whether New York State legislators of 125 years ago knew it or not, conservation of undisturbed wild land is key to the ecological integrity of the whole; many forest fragments do not add up to the same ecological entity as an intact forest.

Summarized succinctly, while the grid may need additional energy storage, and pumped storage is one means of achieving that, the proposed locations simply poor choices.

Ana Silva, West Shokan, NY.
I’m an Olive resident who is worried about the pumped storage hydro proposed. I’m worried about impacts on the beautiful wilderness of the Catskills, the related tourist economy which benefits my direct neighbors, and the impacts on the NYC water supply, where I also live. The Catskills forest preserve, designated as status 1 or 2 should be preserved.  Thank you.

Josh Dorman, West Shokan, NY.
Concerning docket P-15056:000
  I’m writing in opposition to the proposal for a pumped storage hydro project in the Catskills Forest Preserve. As a resident of West Shokan and also as a consumer of New York City drinking water, I believe this is not an appropriate choice of site. Having seen parts of the proposal, it strikes me that your company has not considered many of the essential aspects of this region that make it a terrible location. 
  Under the NYS constitution, Article XIV, the Catskills forests “shall not be leased, sold or exchanged, or be taken by any corporation, public or private”. Indeed, this area is pristine Status 1 preserve. It shall be forever kept as wild forest lands”.
  Aside from the huge disruption to and destruction of ecosystems, small roadways and homes and impact on local tourism, the potential for silty runoff into the NYC water system is cause enough for this project to be moved elsewhere. Please let us keep the Catskills as pristine forest lands. 
   Thank you. 
Josh Dorman
36 Lang Rd 
West Shokan, NY 12494

Samuel Redfield, West Shokan, NY.
To whom it may concern, 

As a long time residents of West Shokan in Olive New York, We strongly object to the proposed hydroelectric plant, penstock and pumped storage reservoir proposed for our area. We feel that the proposed project would be destructive to our community and fundamentally change our way of life. It's construction would be disruptive and the associated infrastructure would scar the land in an otherwise pristine landscape that is enjoyed by residents and visitors alike. 

Please consider using another location for the proposed project! 

Sam Redfield
482 Watson Hollow Rd 
West Shokan, NY 12494

Julie Fogliano, West Shokan, NY.
As a resident of West Shokan/ Olive that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.  Thank you so much.

Susanna Nicholson, Shokan, NY.
This comment is written by a full time resident of the reservoir area on 3/31/21.  I’m Susanna Nicholson, at 170 Chase Rd. Shokan NY 12481.

Our area is a recreational jewel, an absolutely essential animal habitat.  Shokan also features a critical resource for the security and health of our state:  the Ashokan Reservoir, serving millions of NY State residents with clean, beautiful mountain water.

The assaults on natural habitat and water quality have never had more serious consequences than now, a time when water is truly an endangered resource nationwide.  Siting two powerhouses on the reservoir threatens our clean water, especially as the heat index already rises annually with climate change, and aquatic plant growth increases with CO2.  

Let’s pause here to remind ourselves that NY State has committed to renewable energy growth *with restrictions* as part of “Governor Cuomo’s Nation-Leading Climate Agenda”: “[projects will be] … responsibly permitted, bolster the state’s economy, and deliver health, environmental, and economic benefits to all New Yorkers.”  And I would like to draw your attention to one of the signal responsibilities of the Renewable Energy Siting Office:

“[to] achieve a net conservation benefit to any impacted endangered and threatened species.”

That is simply not possible with this project: the destruction of numerous woodland habitats through demolition and dams, the loss of recreational revenue and natural beauty, and the changing temperatures, pH, and soil content in important wetlands and estuaries downstream of the proposed dams and powerhouse.  The health and environmental aspects could not be worse.  If anyone imagines this enhances the quality of water arriving to NYC, I’d like to see the evidence.

Our future energy needs will be more efficiently met with other sources. I think we should wait to see what the Biden infrastructure plan offers our state in terms of federal funding for renewables such as solar and wind.  Our county has proven especially hospitable to solar projects, and those would be more consistent with existing land use patterns.

Also:

Why have we banned fracking in NY if we’re going to allow this Rube-Goldberg, comically-complex scheme of new reservoirs, dams, and powerhouses, privately run by out-of-state speculators?  

Given the complexity of this project, the environmental impact review process alone will run the state into the millions, or it will be shortchanged to expedite matters, with profound costs to the quality of life in Ulster and downstate counties.  There will be an extraordinary amount of litigation … all for an obviously inefficient project with catastrophic implications for NY State wildlife and forest.  

The required deforestation also seems ill-timed given our state’s priorities on climate change.

The Catskills are one of the things that make life in NY with its high taxes and demanding regulatory structures, really worthwhile for ALL of us.   Don’t ruin it.

Nivo Rovedo, Lagrangeville, NY.
My comment is in regards to the project known to FERC by docket number P-15056, the Ashokan Reservoir pumped storage project. Premium Energy Holdings 
(PEH) has requested a permit from the Federal Energy Regulatory Commission (FERC) to study a pumped storage project on New York City’s Ashokan Reservoir. As a resident nearby the Catskill region,  I am against permitting this. My reason has to do with the location of this proposal and the significant adverse impacts it would have on water quality, the environment, and local Ulster County economy to name but a few effects. I am generally very much in favor of renewable energy storage projects, but this one is ill-conceived and can do incredible damage to the water supply of many towns, including New York City, and to the  environment.
  PEH requested the FERC permit without consulting with New York City (NYC); NYC’s Department of Environmental Protection had no prior knowledge of this proposal. This is crucially important because millions of people depend on the Ashokan Reservoir for drinking water, in New York City and many communities north of the city. We cannot afford to damage this precious, essential resource in any way! I feel that PEH, being a California based developer, is not familiar with how crucial and sensitive this body of water is to the region.
   As part of NYC’s water supply system, the Ashokan meets approximately forty percent of the City’s water needs, plus supplies water for some twenty communities as it travels south.  This water is currently unfiltered. The Ashokanis the oldest of NYC’s six Catskill water supply impoundments and the second largest.  But it is the only NYC Catskill reservoir that was constructed with two separate basins, an east and west basin.  The upper, or west basin, was constructed to serve as a settling basin allowing the periodic turbid reservoir inflows to settle out.  Since the reservoir’s construction in 1915, over one hundred years of sedimentation have settled in the west basin, where Premium Energy Holdings seeks to construct its pumped storage facility.The pumping and releasing of water from and into the Ashokan would potentially keep water turbid, thus negatively affecting its drinking quality, if not filtered.
   Additionally, the action of the pumped storage project would disrupt the reservoir’s thermocline. The Ashokan currently is a two-story reservoir that stratifies into a warm layer top and cold-water bottom during part of the year.  As such, it supports a healthy population of wild rainbow and brown trout.  Rainbow trout, which the Esopus Creek is best known for, are sight feeders that fed on zooplankton.  Zooplankton require clear water to thrive.  Thus, operation of a pumped storage project could create a constant turbid state, adversely impacting both zooplankton and the rainbow trout population.  And loss of the cold-water regime would further negatively impact the reservoir’s trout population. 
   For decades the Ashokan Reservoir-Esopus Creek connection of spawning rainbows and browns, running out of the reservoir, upstream into the Esopus to reproduce, has been much written about and heartily pursued.  In fact, the Esopus Creek wild trout fishery is dependent upon spawning trout from NYC’s Ashokan Reservoir.  Under a recently revised NYS Trout Management Plan the NYS Department of Environmental Conservation (DEC) recognized the significance of the Esopus Creek trout fishery, classifying the river as Wild-Quality AND all its tributaries as Wild, that is to say, there is more than adequate spawning of wild trout to maintain these fisheries.  These are classifications very few NYS streams attain, and a recognition of the intrinsic value of these waters.If allowed to proceed, the proposed project would impact the watershed trout fishery: the Ashokan, Esopus, and tributaries where trout spawn.
   In addition, a major issue is that portions of the upper reservoirs would be constructed on NYS Forest Preserve lands; this would be a direct violation of the NYS Constitution.  While all of the aforementioned are environmental impacts, they are also economic impacts to Ulster County.  Much of the Ulster County economy is recreation based, with angling an important contributor.  Additionally, communities along the Esopus Creek, downstream of NYC’s Ashokan Reservoir have long since raised concerns about turbid discharges from the water supply.  These concerns can only be exacerbated if this project goes forward.
    Clearly this project is an ill-convinced idea by a west-coast based company with little knowledge, nor care, to impacts caused to the water quality, environment, economy, history, and general well-being of people living in the general area of this proposed endeavor.
     Please reject this permit request for all the reasons above.
    Thank you.
Nivo Rovedo

Lynne Sherbondy, West Shokan, NY.
I am a resident of West Shokan in the Town of Olive in Ulster County, NY.

The preliminary permit application, entitled The Ashokan Pumped Storage Project, currently before the Federal Energy Regulatory Commission (FERC)includes building a large dammed reservoir in a New York State forest, an underground hydropower plant in West Shokan, and high voltage transmission lines running from Olive to the Town of Ulster. If allowed to proceed, this project will have enormous detrimental impact on our community. 

I am opposed to The Ashokan Pumped Storage Project for three reasons:

1. The Premium Energy proposal is not the kind of innovation the Department of Energy (DoE) wants.
   • Premium Energy is proposing an open-looped pumped-storage hydropower project where the lower reservoir will be continuously connected to a naturally flowing upper reservoir. Closed-loop projects are considered to have smaller environmental impact and are thus eligible for streamlined FERC approval. 
   • Premium Energy is claiming this to be a “closed-loop.” It is not. Projects where an upper reservoir is added to an existing lower reservoir are known as “add-on” projects. That is what this project is. Premium Energy is lying. 
   • “Initial construction impacts” for open-loop projects are lower, but “operational impacts are still likely to be higher than for a closed-loop project because the add-on project’s lower reservoir is still continuously connected to, and may affect, the natural flowing water feature that was dammed for its original construction.” (Source: DoE: “A Comparison of the Env. Effects of Open-Loop and Closed-Loop Pumped Storage Hydropower.” April 2020)

2. Impact on highly preserved land
   • The Catskills Forest Preserve was created in 1885 in Ulster County. As a State Forest Preserve, the Catskills are considered Status 1 land under USGS “Gap Analysis Program.” According to the DoE’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
     o Under Article XIV of the NYS Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” 
     o The Preserve is 700,000 acres of continuous wildlife habitat in an increasingly fragmented environment; the forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. 
     o All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: see https:// www.audubon.org/important-bird-areas/catskills-peaks-area. 
   • Premium Energy appears to be completely unaware that they are proposing a project in an extremely protected state preserve, a Status 1 area according to the USGS Gap Analysis. Change in the State Forest Preserve is rare:
      o Changes to land management in the State Forest Preserves must be passed by constitutional amendment, voted on by two consecutive sessions in the state legislature, then submitted to the public in a referendum. 
      o As of 1999, more than 2,000 amendments have been proposed. Only 29 made it to the referendum stage; of those, 20 passed. 
      o Source: The Catskill Park: Inside the Blue Line 

3. Impact on stream ecology 
   • Pumped storage upper reservoirs are subject to rapid fluctuations of water which wreak havoc on both aquatic and land habitats. 
   • Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills’ most vital trout waters and part of the New York City water supply.
   • A valuable trout breeding habitat will be lost. 

Thank you for your time.

Leslie Sharpe, Walton, NY.
proposal is shocking, outrageous and totally ill considered! And it shows NO knowledge, respect or concern for the Catskills and its people—and NYC. Clean, fresh water is the Catskills greatest resource. Which is why we have fought so hard against fracking—and won! Our tourist industry is dependent on that water, for fishing and so many other recreational activities. In addition, the Catskills has many family farms, and fresh water is crucial for livestock, cows, sheep and increasingly horses, and of course, it is also necessary for agriculture. The Catskills are America’s first great wilderness, lost in the 19th century to other irresponsible uses, such as the destruction of the hemlock forests by the tanning industry. Due to protections, such as codifying the Catskill Park as Forever Wild in NYS law (and how does this irresponsible proposal get around THAT?), the Catskills and its waters, which were thoroughly polluted by past egregiousness, have revived. Our streams and rivers offer some of the best fly fishing, as the trout, along with many mountain critters, such as the white-tailed deer and black bear, have returned with our reforested slopes and clean water.. Our waters also, and crucially,  supply drinking water to New York City, and the Ashokan Reservoir is the main reservoir whose sweet, clean waters flow to downstate. This project would put that water supply at risk!  And according to one article, the DEP, in addition to the Catskill towns concerned, was not even notified? And according to the same article, a Catskill town would be flooded for this? Absolutely not! That happened to too many villages to build the reservoirs. Catskillers, folks native to this area and the many downstaters now increasingly living here—and lots more have moved here due to the pandemic—simply won’t stand for this. This project would alter the hydrology of our local waters, the Esopus Creek, for starters, affect the quality of our water for recreational and drinking uses, both on a personal and commercial level, and also—and just as important—impact our wildlife, which has struggled and finally succeeded in making a comeback here. The Catskills, as anyone making such an irresponsible proposal, soon learns, are home to many committed, passionate and EFFECTIVE grass-roots environmental groups and individuals who will resist any such efforts that would result in compromising in any way our precious natural resources. My vote is a resounding NO!
Leslie T. Sharpe, author of The Quarry Fox and Other Critters of the Wild Catskills, was named one of Fifty Stewards of the Catskills by the Catskill Center for Conservation and Development in 2019.

John Chazik, Woodstock, NY.
My family and I moved up here from New Jersey approximately 9 years ago as we saw firsthand the destruction of land and waterways that was so obvious from Energy Companies such as Southern California called Premium Energies.  My family and I object to this underground hydroelectric plant adjacent to the Ashokan Reservoir or for that matter any land or waterway in the Catskill Region.  The Great People of the Catskills do not need this not do want any Energy Company being intrusive onto our land and communities that we here in the Catskills hold so dear.
Again, The Chazik Family stands firm as being vehemently opposed to this or for that matter any hydroelectric plant in our communities.

Edmund Earle, Olivebridge, NY.
I was disturbed to learn of the recently proposed hydroelectric overhaul of the region by Premium Energy Holdings. Residents of the Catskills are keenly aware of our area's past exploitation, and to have a company propose continuing that tradition is the antithesis of what we stand for.

I am also fully aware of how easy it would be for these concerns to be dismissed as knee-jerk, or based on an incomplete understanding of the project. So instead I'll approach it with the objective question: would such a project produce more good or more harm? 


From what information is available, the good seems pretty minimal: 

-Premium Energy Holdings employs and shareholders will see a benefit.
-Such projects can contribute to reducing our overall dependence on fossil fuels. (However any climate-change gains may be undercut by the energy and resources required for production and operation.)


Meanwhile the harm caused by such a project seems far greater:

-Permanent alteration and destruction of the regions water systems.  I've seen first-hand how even year-to-year changes in rainfall have had drastic impacts on our local streams, ponds, rivers, and overall watershed: recurring summer dry spells have meant even existing reservoirs have been dangerously low, as has the water table we rely on for our home wells. This is the time for us to be working to preserve our water sources, not altering them further. As others have brought up, this issue affect not just the Catskills region but New York City itself, which relies on our existing reservoirs for its water supply.

-Displacement of and negative impact on the region's peoples. This project will inevitably lead to people's homes being destroyed. This is something we have been through before with the construction of the existing Ashokan reservoir, a time we do not look back on fondly. In addition such a project will affect every resident's ability to travel, as well as potentially damage the tourism industry that sustain towns from Woodstock to Phonecia to Hunter. 

-Massive losses to and displacement of wildlife. The Catskills are a unique oasis for flora and fauna that are otherwise struggling from climate change and human development. As mentioned before, it wasn't too long ago that most this area was clear-cut. Thanks to state protections our natural areas are finally beginning to return to their former glory- to the benefit of us all. To flood these areas and cut down acres of forest for powerlines and pipelines would be to undo all that progress.  

So it is for all these reasons that I believe a project of this nature would objectively be a detriment to the region, and I hope that Premium Energy Holdings will take this into consideration going forward.


Edmund Earle
60 Weber Ln
Olivebridge, NY 12461
917-710-4054

Cheryl Spada, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Aaron Greenbaum, Maplewood, NJ.
To Whom It May Concern,

I am contacting you in regards to the Ashokan Reservoir Power Plant proposal (P-15056). This proposal was developed by the private electric company Premium Energy, based in California, and involves the construction of a for-profit hydroelectric dam in Olive, Woodland, or Lanesville. The proposed dam would reach up to 300 feet and connect to the Ashokan Reservoir by a tunnel drilled under public and private land. This dam would be problematic for numerous reasons.

The dam would need to flood at least 200 acres to construct a new reservoir, which would negatively impact the ecology of the Catskills Forest Preserve, which is protected by the NY State Constitution. This would reduce the amount of recreational area available for hikers, and it would also endangered several threatened species.  Moreover, the dam would reduce the quality of New York City’s drinking water, as well as negatively affect the streams that locals and tourists use for fishing, boating, and swimming. Due to the damage the dam will inflict on the local area, tourism would decrease, and many of the nearby towns rely on tourist dollars for their revenue, which would hurt their communities.

My family owns a summer cabin that has stood for several generations. If the dam is built, it would directly impact the property.

Please help me and others stop the Ashokan Reservoir Power Plant proposal.

Thank you for your time.

Sincerely,

Aaron Greenbaum

Submission Description: (doc-less) Motion to Intervene of Stacey M Holt under P-15056-000.

Submission Date:        3/27/2021 7:54:44 PM

Filed Date:             3/29/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               brassica@thevegetablegardener.net                                                

Basis for Intervening:
Motion to intervene of Stacey M. Holt for the Ashokan Pumped Storage Project as a concerned citizen who lives in the area.  

PO Box 544
Bearsville, NY 12409

845 688 2644

Submission Description: (doc-less) Motion to Intervene of Larry T Fessenden under P-15056-000.

Submission Date:        3/28/2021 6:01:53 PM

Filed Date:             3/29/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               larry@glasseyepix.com                                                            

Basis for Intervening:
To Whom it may Concern:

This is to request Intervener status on the hydro-electric power station and dam project proposed by Premium Energy, a California Company that seeks to build a reservoir less than a mile from our home in a protected area of the Catskill Mountains that will devastate the residential area, destroy the habitat of wildlife and endangered species, transform the local community with power lines, water tunnels and a power station, and which will threaten the Ashokan reservoir that supplies drinking water to 9 million residents in New York City. 

Larry Fessenden
Rebecca Underwood
FERC ID #F647125

Submission Description: (doc-less) Motion to Intervene of Lee S Wecker under P-15056-000.
As a tax paying home owner with properties in the hamlets of Chichester, Allaben and Phoenicia, within the town of Shandaken, I and my properties will be directly impacted by the proposed Pumped Storage Project. I request intervener status.

 

Submission Date:        3/28/2021 6:16:39 PM

Filed Date:             3/29/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               lwecker@yahoo.com                                                                

Basis for Intervening:

As a tax paying home owner with properties in the hamlets of Chichester, Allaben and Phoenicia, within the town of Shandaken, I and my properties will be directly impacted by the proposed Pumped Storage Project P-15056. I request intervener status.

Linda M Barash, Olivebridge, NY.
This is a comment regarding the proposed Ashokan Pump Station. The proposal from Premier Energy is neglectful of the sensitive nature of the proposed site. Most specifically our reservoir water which will be turbid,  will wreck havoc on our environment- fauna and flora, high power transmission lines will be near homes and can be detrimental to health especially the young and elderly, and will effect tourism. 
Furthermore, Catskill Forest Preserve. 1885 states lands in this status 1 area are to be avoided for development.
Therefore, this project should not be under consideration.
Lind Barash

verena u. shapiro, Olivebridge, NY.
re: FERC project sub docket # P-15056:000 "Ashokan Pumped Storage Project"

To whom it may concern: 

I would like to express my concern in regard to the above proposed project since all three possible locations would impact highly preserved land and stream ecology of the Catskill Forest Preserve.

Under the USGS "Gap Analysis Program" the Catskill Forest Preserve is considered Status 1 land. According to DOE's own Hydropower Vision "areas with formal protections designated as Status 1 or 2 under the USGS program are to be avoided for development".

Furthermore, the Catskill Forest Preserve is protected by the NYS constitution. Any changes to land management would require a constitutional amendment, to be voted on and passed by two consecutive sessions and then submitted to the public in a referendum.

Thirdly, Premium Energy is proposing this project to FERC as a "closed loop project", a type of project the DOE supports. The above project is not a closed, but an open loop project since it involves the Ashokan Reservoir as the lower basin. which has the Esopus River running into it and out of it.

Sincerely,
Verena Shapiro
302 Acorn Hill Road
Olivebridge, NY 12461

Traci A Parks, Chichester, NY.
I live in Chichester, NY, near one of the proposed sites Premium Energy Holdings is considering for an upper reservoir that would connect to the Ashokan. After reading the proposal, and based on my knowledge of the area, I urge you to deny PEH a preliminary permit to conduct studies on a proposed pumped storage plant. The Catskill Forest Preserve is not the right place for this project, and this for-profit company’s proposal threatens to do more environmental and economic damage than it sets out to solve.
 
All three of the sites under consideration in Premium Energy’s proposal are within the Catskill State Park, which is protected from development by the NYS Constitution unless amended otherwise. These three sites also fall within Audubon’s Catskill Peaks Important Bird Areas. Further, the Catskills are considered Status 1 land under the United States Geological Survey’s “Gap Analysis Program.” According to the Department of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.”
 
Pumped storage upper reservoirs are subject to rapid fluctuations of water which threaten both aquatic and land habitats. Altering the sediment regime in tributaries to the Esopus will alter the sediment regime in the Esopus, one of the Catskills most vital trout waters and part of New York City's water supply. Disrupting the local ecology and subjecting our local waters to cooling and evaporation are not the kinds of trade-offs we can afford. Nor is the potential to seriously harm New York City’s water supply.
 
Please deny Premium Energy Holdings a preliminary permit so that local experts can work toward genuine solutions to our energy needs.
 
Sincerely,
 
Traci Parks

David Pillard, Shandaken, NY.
     As a resident of Shandaken and the owner of a business in Phoenicia I am writing to voice my strong opposition to granting a preliminary permit to Premium Energy Holdings. I acknowledge and support the pursuit of renewable energy projects, but the Catskills is uniquely ill suited for the Premium Energy hydropower endeavor.
     Why is it "uniquely" ill suited?
     Premium Energy is proposing a project in the Catskills Forest Preserve - land under Article XIV of the NYS constitution that "shall be forever kept wild forest...shall not be leased, sold or exchanged, or be taken by any corporation, public or private." Altering the land management for this project to move forward in the State Forest Preserve would require a state constitutional amendment, voted on by two consecutive sessions in the state legislature then submission to the public in a referendum. Such amendments rarely pass.
     The Department of Energy's "Hydropower Vision" recommends that land with formal protection designated as Status 1 or 2 under the USGS Gap Analysis Program be avoided for development. As a State Forest Preserve the Catskills do fall into the Status 1 land designation.
     The Esopus Creek, one of the East Coast's most vital trout waters, will be adversely affected by the increased turbidity of the project causing irreparable damage to trout breeding grounds. The pristine Esopus Creek network is fragile and will never recover from such a massive disturbance to its delicate ecology.
     And let's use common sense. Let's use our nation's economic resources sensibly to make good choices in developing renewable energy resources. Think of the millions of dollars that will need to be spent by the parties involved for this project to move forward:
     - the associated costs of amending the state constitution.
     - the review process expenses incurred by the New York State agencies 
       in assessing the project's negative environmental impact.
     - the litigation expenses New York City will incur in reviewing and 
       fighting this proposal since it will so grossly endanger its water 
       quality.
     Wouldn't all this money be better used for a project that is better suited to succeed and have solid prospects for coming to fruition? This is not an issue of "we don't want this project here." It's an issue of recognizing the disqualifying circumstances situating this project specifically in the Catskills  that make it prohibitive.

Other formats

Anthony Walters, Olivebridge, NY.
Please stop this proposal. We don't want this to happen. No power lines. It will destroy are reservoir. Stop this right NOW!!!

Anthony Walters, Olivebridge, NY.
Please stop this proposal. We don't want this to happen. No power lines. It will destroy are reservoir. Stop this right NOW!!!

Anthony Walters, Olivebridge, NY.
Please stop this proposal. We don't want this to happen. No power lines. It will destroy are reservoir. Stop this right NOW!!!

Anthony Walters, Olivebridge, NY.
Please stop this proposal. We don't want this to happen. No power lines. It will destroy are reservoir. Stop this right NOW!!!

Maria Pozoga, Big Indian, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. docket number P-15056-000

Zachary Chapman, Boiceville, NY.
This proposal lacks in grounding or merit to it's proposed location. I'm not sure if Premium Energy Holdings, LLC is simply throwing darts at a map right now, as that's the only possible way anybody could think a project like this would belong in this location:

1. On a general note power production is not a concern for the area to be met. We have issues as any rural area does with outages, but those are all from storms that disrupt the infrastructure, never from demand outpacing supply.
2. In order to build any of the proposals it would not simply mean imminent domain problems for residents and land owners but also getting land from the State of New York who holds land in all of the proposed areas, so they would be taking public land at the expense of every single resident in the state.
3. The Esopus Creek has just been given designation as a river of Wild-Quality by New York Department of Conservation.

This is pretty clearly a plow to fund a feasibility study for somebody to profit, but to never intend on pursing, because anybody in the area can tell you it's not feasible.

Jenni Cawein, Lexington/West Kill, NY.
The proposed project is out of scale to the area and not energy efficient. Moreover, each of the alternatives would potentially encroach on sensitive ecosystems, including Catskill Park/New York State forever wild lands.  We are all for renewable and sustainable energy.  But this project does not fit well here.

Our region is packed full of headwater streams and waterfalls that would lend themselves well to small hydro projects.  Why in the world would you want to pump water upstream to create a massive closed loop system?  This would be highly inefficient and totally unnecessary.  There are so many opportunities to work with the natural hydraulic corridors here. So why would anyone want to work against them?  Makes little sense – is it just to have a massive project that is not wanted by the locals here?  Exploring smaller scale projects would be so much smarter, and not infringe nearly as much on the beautiful ecosystem we have here.  Larger pumped power storage systems can be useful, but not here.

The future will be in energy efficiency, but this is not efficient.  Not only is there an obviously huge waste of energy in this proposed concept, but energy is also wasted as soon as it enters the grid.  It has been suggested that the pumping energy might be supplied by solar panels during the day. Where would you put those?  Raze our forever wild forest lands?  Or maybe you could construct them miles away and transmit the energy through transmission lines, wasting even more energy.

There are much better solutions to solving our energy challenges, so please don’t go down this short-sighted road.  We need to think further out into the future.  And while a massive concrete uphill holding reservoir is not a good long-term answer, it does have the potential to create long term and possibly permanent damage here.

Thank you for reading my comments.

Joel E. Cohen, West Shokan, NY.
FROM:
Joel E. Cohen
50 Bitterman Road
West Shokan, NY 12494
TO: 
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE Room 1A
Washington, D.C. 20426
https://ferconline.ferc.gov/QuickComment.aspx
DATE: 2021-03-26
RE:
FERC project and subdocket number: P-15056:000
Preliminary Permit for the Ashokan Pumped Storage Project
The proposal before you, "Premium Energy Holdings’ First Amendment for Preliminary Permit for the Ashokan Pumped Storage Project, FERC Project No. 15056-000," Document Accession #: 20210201-5022 Filed Date: 02/01/2021, suffers fatal deficiencies. Granting the urgent need for more renewable energy in New York State and nationally, this application for a preliminary permit should be rejected at the outset because the proposed sites are not the right places for this project.
The proposal states falsely on p. 5 that "The location of the proposed project is: State or territory: New York, Counties: Ulster County" and again falsely on p. 7 that "Every county in which any part of the project, and any Federal facilities that would be used by the project, would be located. Ulster County." In fact, Exhibit 3, page 21, shows clearly that the proposed Stony Clove Reservoir and Dam along Route 214 are approximately 1 mile into Green County in the hamlet of Lanesville.
The proposal states falsely in Exhibit 1 on p. 11: "The proposed Ashokan Pumped Storage Project would operate in a closed loop. Aside from evaporation and percolation losses, the project’s water would stay within the system." The Ashokan Reservoir, the proposed lower reservoir, is part of a flowing water system, fed from above by the Schoharie Reservoir, Esopus Creek, and smaller tributaries, and flowing downstream into Esopus Creek and the water-supply system of New York City (NYC). The Schoharie and Ashokan Reservoirs provide approximately 40% of the daily water supply of NYC's 9 million inhabitants. The water that would flush at high pressure (594-914 feet of head claimed in the proposal) and high velocity from any of the proposed upper reservoirs into the depth of the Ashokan Reservoir upper (western) basin would stir up a century's worth of sediment, add its own sediment, and commingle with the outflow to both NYC and Esopus Creek downstream. This is NOT a closed-loop system. It is an add-on project for open-loop pumped-storage hydropower because the proposed project’s lower reservoir, Ashokan Reservoir, is still continuously connected to, and may affect, the natural flowing water feature that was dammed to construct the Ashokan Reservoir.
The proposal states on p. 13 that approximately 15,800 acre-ft of water would be used for pumping or generating 800 MW over 12 hours of continuous output. The proposal also states on p. 13 that the Ashokan Reservoir has "around 382,358 acre-ft of storage capacity. Also, additional water volume at Ashokan reservoir would be discharged through the Esopus Creek (southeast basin)." That last sentence contradicts the proposal's earlier claim on p. 11 that this is a closed-loop system. But more importantly, the Ashokan Reservoir is divided by a spillway into a western basin upstream and an eastern basin downstream. Water is released from upstream to downstream. Therefore the western basin would take the full impact of the proposed 15,800 acre-ft of water. According to Adam Bosch at the NYC Department of Environmental Proection, the western basin has a surface area of 3,106 acres and a storage volume of 143,700 acre-ft when full.  So the daily rise and fall of the western basin would be 5.09 ft = 15800 ÷ 3106 and the 15,800 acre-ft pumped in each 12-hour power cycle would be 11% = 15,800 ÷ 143,700 of the western basin volume.  Every 9 days the entire volume of the western basin could turn over, assuming the western basin were full throughout. Most of the time, the western basin is far from full, so total turnover of the western basin would happen faster and the surface level fluctuation would be more extreme than 5 feet. Such mixing could not fail to perturb in disastrous ways the ecology within the Ashokan Reservoir, the ecologically rich areas where terrestrial and freshwater ecosystems overlap (as a result of the 5-foot surface water elevation fluctuation), and the quality of the water supplied to NYC.
The three sites proposed for the upper reservoir would cause major damage to highly preserved land in the Catskills Forest Preserve created in 1885 in Ulster County. Under Article XIV of the New York State Constitution, the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” As a State Forest Preserve, the Catskills are considered Status 2 land under the USGS “Gap Analysis Program.” According to the U.S. Dept. of Energy’s own Hydropower Vision, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development." The forest around the proposed sites ranks among the top 1% of forest habitats region-wide according to the New York State Forest Condition Index. All proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area: see https:// www.audubon.org/important-bird-areas/catskills-peaks-area. The proposed project would destroy these irreplaceable natural areas, undermine the attractiveness of the area for tourism, weaken the local economy, pollute downstream, and possibly wreck one of NYC's major capital assets, its water supply system.
In conclusion, granting the urgent need for more renewable energy in New York State and nationally, this preliminary permit application should be rejected at the outset, because the Ashokan Reservoir and surrounding forests and mountains are not the right place for this project.
Joel E. Cohen, Ph.D., Dr.P.H. (public health)
Professor and Head
Laboratory of Populations
Rockefeller University & Columbia University
1230 York Avenue, Box 20
New York, NY 10065-6399 USA

Other formats

Suzanne Wind, Saugerties, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

 

I do understand and appreciate the need to create more truly renewable energy sources. We cannot allow typical NIMBY concerns to block all projects. 

 

However, this proposal is truly deficient, would cause massive and irreparable harm to protected lands and to people, and should be denied on its merits. The proposed sites in the Catskills region are on Status 1 land, and the Department of Energy has clearly stated that Status 1 or 2 land must be avoided for any development. The proposed project will cause severe ecological damage, particularly on streams resulting in increased turbidity and sediment in water that serve as an unfiltered drinking water source and blocking the natural spawning areas of trout and other wildlife.

 

Furthermore, the proposed project is not a true ‘closed loop” energy source and is not the type of innovation that is being sought; it could even result in a net loss of energy given its reliance on traditional pumping to higher elevations. 

 

Thank you for the opportunity to comment. I respectfully ask that you prevent this proposal from moving forward.

Leo J Warren, Shokan, NY.
The Ashokan Reservoir Power Plant Proposal is not beneficial for this area or community. I am a town of Olive resident I grew up in Shandaken.  I am a property owner as well as a business owner in this area. This proposal is not displaying any benefit to this community. Only negative effects for the people and profits for a company that isn't based in New York.  It is a California based company coming into upstate New York to make money and destroy our community and lands. Coming into the area and acting like it is ok to relocate families in a time where people cannot find homes to live. This demonstrates the lack of care for our community. Hiding under the umbrella of renewable energy is unacceptable and creating a false vision of what it will do for our community. I am against this proposal. During the town board presentation a question was asked what's in it for the community the company representative replied it is renewable energy. They are not looking out for us the residents of this community they are looking out for their bottom line. One of the reasons we all live here is because of the community and lands. Allowing an organization to destroy our lands and potentially remove families from our community is unacceptable.

Mary M Schroeder, Lanesville, NY.
I am a resident of Lanesville NY, one of the towns that is being proposed by Premium Energy Holdings as a site for a new dam and reservoir.  I am requesting the Federal Energy Regulatory commission deny Premium Energy Holdings a preliminary permit.  The project would destroy our life here.  The community here, our land and house would be destroyed.  Our neighbors would all lose their houses and our way of life here would come to an end. In addition to the destruction of this historic community, the trails, streams and woods would be obliterated.  And how in the world would this be a good idea for the drinking water of New York City?

Kaseb Smith-Allgire, SHOKAN, NY.
Its hard to ignore the devastating impacts on the natural environment that this pumped-storage power plant will have. For one thing, as this PowerPoint is more than happy to inform us, the building of an upper-level reservoir will "wreak havoc on both aquatic and land habitats" but also "[destroy] valuable trout breeding habitat" (slide 26, Strand). As a matter of fact, the only benefits to building this plant that are ever outlined have little to no impact on the local residents surrounding the reservoir. The only benefits to this project are economical, and they only economically benefit New York City and the companies who are building it. 

I implore concerned individuals, activists, and anybody living around here to read that PowerPoint and ask yourself "what will this do for me?" The answer is, quite simply, nothing. 

My concern with this project is that the negative environmental and economic impacts of it will be bared only by the local people, and that this is yet another frightening example of a government overstepping their boundaries to make up for a lack of adequately and sustainably designed city infrastructure. The PowerPoint provided on the Town of Olive website does nothing to dissuade me from that.

Abby Heijnen, Olivebridge, NY.
Abby Heijnen
186 Sheldon Hill Road
Olivebridge, NY 12461

FERC
ferconline.ferc.gov/QuickComment.aspx


Re: Preliminary Permit Application
Proposed Ashokan Pumped Storage Project and Ashokan Reservoir-Power Plant Proposal
495209905


3/25/2021


To whom it may concern,

This letter is to register my vigorous opposition to the above proposed Permit and project!
This proposal includes an inappropriate siting of  a large dammed reservoir in a NYS forest, an underground hydro plant in West Shokan and high voltage transmission lines running from Olive to the town of Ulster. ALL IN THE CATSKILL STATE PARK and surrounding area. 

The idea of this project in a pristine natural environment, where tourism is a major source of income for our communities, is absolutely unacceptable!

This California company is arbitrarily choosing sites all over the country for investment, without regard to the impact on our community.

The town of Olive has already suffered a loss of income from the building of the Ashokan reservoir and we, as residents, are required to comply with strict and extra costly regulations in order to keep New York City's water supply fresh and clean.

Though I am a supporter of clean energy, there must be consideration for appropriate locations.

Please deny them this permit and keep them, and anyone else, from building projects that would desecrate our natural environment.


Sincerely,


Abby Heijnen

Pierre Heijnen, OLIVEBRIDGE, NY.
Pierre Heijnen
186 Sheldon Hill Road
Olivebridge, NY 12461

FERC
ferconline.ferc.gov/QuickComment.aspx


Re: Preliminary Permit Application
Proposed Ashokan Pumped Storage Project and Ashokan Reservoir-Power Plant Proposal
495209905


3/25/2021


To whom it may concern,

This letter is to register my vigorous opposition to the above proposed Permit and project!
This proposal includes an inappropriate siting of  a large dammed reservoir in a NYS forest, an underground hydro plant in West Shokan and high voltage transmission lines running from Olive to the town of Ulster. ALL IN THE CATSKILL STATE PARK and surrounding area. 

The idea of this project in a pristine natural environment, where tourism is a major source of income for our communities, is absolutely unacceptable!

This California company is arbitrarily choosing sites all over the country for investment, without regard to the impact on our community.

The town of Olive has already suffered a loss of income from the building of the Ashokan reservoir and we, as residents, are required to comply with strict and extra costly regulations in order to keep New York City's water supply fresh and clean.

Though I am a supporter of clean energy, there must be consideration for appropriate locations.

Please deny them this permit and keep them, and anyone else, from building projects that would desecrate our natural environment.


Sincerely,


Pierre Heijnen

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Susan Thomas, West Shokan, NY.
I live in West Shokan, NY. I’m curious to know what started the interest in the Ashokan Pumped Storage Project. I would like to see the Environmental Impact Statements (EIS) and State Environmental Quality Review Act (SEQRA) reports. There are several bald eagle nesting sites located along the Ashokan reservoir and in the areas for the 3 proposed reservoirs, what will be done to protect them and other wildlife? Why are  the transmission lines running on the southern side of the Ashokan Reservoir, instead of along NYS Route 28 on the northern side? Why do the proposed facilities need to be located 200-300 feet below ground level? Will the building of this effect the well water systems of local residents? How much noise, traffic disruption, dust, etc. can we expect from the construction of this? Since this will be underground, how much blasting will there be? Or will mining equipment be used used and if so, what type will be brought in? Will local labor be used or is this a private out-of-state company’s labor force? Once it’s built, who owns it and maintains it?

Benjamin Obler, Olivebridge, NY.
March 23, 2021

To Whom It May Concern:

As a resident of Olive, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I VIGOROUSLY OBJECT to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 

Please do everything in your power to prevent this proposal from moving forward.

Thank you.

Benjamin Obler
86 Brown Road
Olivebridge, NY 12461

Stephanie Gindele, Chichester, NY.
The community that exists in the stony Clove and Woodland  Valleys and in Olive / Shokan will raise hell and WILL NOT LET THIS HAPPEN. Take the project somewhere else and save the trouble. 

We will protect our rivers and streams from PROFIT DRIVEN EXPLOTATION which will destroy not only our life styles and primary sources of joy but WILDLIFE that exists in a balanced ecosystem ONLY HERE because of the undisrupted natural expanse that is the Catskills.  

This project is NOT SUITED for the Catskills in anyway and FERC and Premium Energy Holdings can take it somewhere else where it will benefit the people. We DON'T NEED OR WANT IT HERE AND WONT ALLOW IT TO HAPPEN.

Protus A Mayunga, Chichester, NY.
I think this is a very unfair, unacceptable idea. I live here and swim in the river almost every day of every summer. It would make it extremely dangerous and risky to swim in it if at any time a huge rush of water could come sweeping down and take a human with it. If you do this these rivers, and streams won't be very accesible to the people that live here. Please take everything into consideration before you do this.

Mandana Boushee, Phoenicia, NY.
To whom it may concern :

I am writing to you as a concerned Woodland Valley resident, who is against the proposed  underground hydroelectric power plant at the Ashokan Reservoir by the company Premium Energy Holdings LLC.

The  proposed locations for the new reservoirs would mean taking away private property from people and in one case – for the prospective WoodlandReservoir – involve flooding an entire community, Woodland Valley, which is the community that I live in. Additionally, this proposed plant poses potential issues with town infrastructure, individual wells, regional infrastructure as related to the electric grid, and environmental sensitivities.

We do not want this plant coming to our beautiful and protected environment here in the Catskill Mountain Region!

With respect,
Mandana Boushee

Christopher Edelson, maplewood, NJ.
The plant would utilize electricity to pump water to the upper reservoir.  This is inefficient and hardly innovation.  The public deserves a higher standard for an energy project.

The area is used for recreation.   The disruption of construction and the lasting impact on the natural resources in the area would have unforeseen economic impact.

Construction, ongoing operation, and potential accidents would have devastating impact on the aquatic environment in the immediate and surrounding areas.  This is totally unacceptable considering the history of the aquatic environment and its economic potential. 

The proposed area is on Status 1 land and would require legislative effort at the state level to move forward.

Danielle M Bliss, Shokan, NY.
I don't want this in my community. The last thing we need are cancer causing high voltage transmission lines running anywhere near my house, where I hike or near any of the schools. This will bring a lot of damage to protected forests and wildlife. This area is home to many eagles and birds of prey. I did not buy a home in Shokan to be near a destructive power plant. And I would love to know why a company from California is the one proposing this. It sounds like even local environmental agencies were not notified of this proposal.

Sean ODWYER, Kingston, NY.
To whom it concerns:

I am writing about Premium Energy’s proposal for a hydroelectric plant in the Catskills. I live next to the Catskills and know the area well, as I hike in there every week. I know all three proposed locations. I am shocked at the choices, as they are all manifestly unsuitable for a project of this kind. 

Premium Energy’s proposal seems haphazard and sloppy and quickly put together without any real knowledge of the area, of the obvious impacts this project will have on this major tourism area, or of the laws that apply to these projects and the Catskill Park.

1. The Catskill Park is constitutionally protected as “forever wild" and is highy preserved Status 1 Land. The Department of Energy has said that Status 1 or 2 must be avoided for development. Premium Energy seem unaware that their project will require an amendment to the State Constitution which protects the Catskill Park. 

2. This region is where fly fishing began in the United States and this project threatens to destroy that valuable legacy with sediment build-up which will decimate local trout habitat.

3. This project not kind of innovation DoE is looking for. This is not a true “closed loop” project. Premium Energy’s proposal is deficient. It does not deserve the streamlined application process.

Thank you for your consideration of these points.

Sean O’Dwyer

Submission Description: Motion to Intervene of Dawn S Peters under P-15056-000.
As a taxpaying resident in an impacted community, Chichester, the Pumped Storage Project will impact environmental resources and state constitutionally protected land I have a stakeholder interest.

Submission Date:        3/24/2021 1:13:14 PM

Filed Date:             3/24/2021 1:13:14 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               ashlynericca@aol.com                                                             

Basis for Intervening:
Motion to Intervene of Dawn Peters for the Premium Energy Holdings, LLC, 
Project No. P-15056

As a resident in an impacted community and as a taxpayer in that community, Chichester in Ulster County, the State of New York, the Ashokan Pumped Storage Project will undoubtedly impact environmental resources and state constitutionally protected public land that I have a stakeholder interest in as a contributing taxpayer. 

The proposed Stoney Clove dam, located in Lanesville, would be approximately 1.25 miles north of my home and Stoney Clove Creek streamside property. This CEMENT BARRIER would be 2,600 feet in length and 212 feet high. EFFECTIVELY CHOKING the Stoney Clove Creek and altering the streambank and aquatic habitat of any plant or animal living in this cold water stream.

In light of the uncertainties of global warming, NO FEASIBILITY STUDY NOR COMPUTER MODELLING can predict the added consequences of a construction site and eventual dam, tunnels, high tension wires, turbines, etc., on the delicate balance of nature we have here in the Catskill Forest Preserve. 

Forests act as a filter. This natural filter keeps NYC's unfiltered drinking water system clean by preventing the runoff of chemicals and soil into waterways and eventually the upper Ashokan Reservoir, which already holds years of silt, sediment, etc. Locally, the dam would undoubtedly impact the area's water table, wells, MY WELL, stream turbidity, and ultimately, it would have to affect NYC's drinking water quality. Stoney Clove Creek, a source of life and sustenance, would inevitably be forever changed. 

I, Dawn Peters, respectfully request that the Commission grant my Motion to Intervene as a party with full rights to participate in all further proceedings. 

Respectfully submitted,
Dawn Peters
2 Stoney Clove Lane
Chichester, NY 12416

Louis and Carol Mauriello, Chichester, NY.
We understand the fact that the government has requirements to take appropriate action(s) for our future electric needs, and we understand the government’s thoughts that green energy style so-called renewable energy sources are considered the future.

The following are our concerns with this project’s three proposed locations:
•	Lanesville – This site is the farthest equating to the causing the most environmental damage running the pipeline through Phoenicia, Chichester, and Stoney Clove. It also involves the longest run of pipeline, which will make it the most expensive to operate insofar as the energy required to pump water from the Ashokan Reservoir to the Upper Reservoir, negating any expected financial gain in electricity.
•	Woodland Valley - Though Woodland Valley is much closer, by half the distance of Lanesville, it posses a very similar environmental damage issue, plus seems to eliminate access to the State campground and hiking trails which are a major attraction and revenue generator for the area.
•	Both the Lanesville and the Woodland Valley sites would require the pipeline extend through the Route 28 Corridor causing more environmental damage, raise the costs of pumping the water, and will further negate any expected financial gain in electricity.
•	MoonHaw Road – This site seems the best possible choice. It would involve the least amount of environmental damage and the least amount of pipeline, which would decrease the costs of pumping water, though I haven’t seen any data on at what length pumping becomes financially worthwhile.
•	All three locations would require further environmental damage for the power lines and connections to the grid the project requires.

We are also concerned about the overall environmental impact of this project and how it will affect the Ashokan Reservoir’s ecosystem as well as the ecosystems of the Esopus and other creeks, all of which need extensive study before a decision like this should be considered. Plus, the government needs to study the possible impact this could have on the downstate needs of NYC residents as it will have an impact on their drinking water supply. Furthermore, the entire Catskill Park Forest Preserve, of which this project falls within, could be drastically affected and will require extensive study to determine the impacts.

As stated in the bullets above, pumping water from the Ashokan Reservoir to another reservoir, by design, can only consume more energy than it creates, and we question where the energy to perform all that pumping is coming from as it sounds like it will require more fossil fuel utilization, not less.

As a last point, we understand that the concern over whether green energy investments reduce the costs of electricity to its citizens aren’t always a determining factor in government decisions, but this project goes beyond that consideration as, previously stated, it would all take place within the Blue Line of the Catskill Park Forest Preserve and be devastating to the ecosystem. As such, this project seems more appropriate for State land along the Hudson river where connecting to grid infrastructure would be much easier, cause less damage to the environment, and be part of a hydro ecosystem that is much more robust than the Esopus feed to the Ashokan reservoir will ever be.

In closing, we thank you for your consideration of our concerns and comments.

Respectfully,

Louis and Carol Mauriello

Robert Croissant, Shokan, NY.
This community has been devastated by NYC and Ulster County for the betterment of other people for decades now, it is time to stop this and allow us to live our life in peace...it is enough, do not do this...

christopher diamond, East Jewett, NY.
Hello. I am a resident of Jewett NY (northern Catskills) and Brooklyn NY. I am writing to voice my opposition to this proposal. I initially started researching this project because I'm interested in pumped storage as a critical component of our clean energy future, and I would normally vocally support such a project to combat the NIMBY attitude. But I cannot support this project for a number of reasons. 
Primarily, this project would attempt to take state land within the Blue Line of the Catskills State Park which has been designated as forever wild. (I don't understand the legal mechanisms by which they could take this land without a state-wide referendum in addition to a vote by two consecutive sessions of our state legislature.) 
Secondly, this project would undoubtedly increase turbidity in the Ashokan Reservoir. Turbidity is already a big issue for the NYC Department of Environmental Protection, the city's water department.
This is the right project but in the WRONG location.
I truly support pumped-storage projects. (I work in environmental sustainability and climate resilience so I understand the issues.) But this is not the right location. Other projects that  (1) do not rely on protected state lands and (2) do not threaten the NYC drinking water system should be considered. If such a project comes forward, I will gladly support it in opposition to the NIMBY movement.
-Chris

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William McKnight Sr., West Hurley, NY.
To whom it may concern,
As a local resident who walks, hikes, and enjoys fishing in the upper and lower Esopus creek as well as in the Ashokan reservoir, it seems hard to believe FERC would even propose such a disastrous project and flood even more homes and properties in the Catskills. It is very clear that this proposed project would displace residents, destroy natural habitat, and create an unwelcome ecological disaster within the Catskill watershed. The “power plant” as designed would warm the waters of the Ashokan Reservoir to the extent that the trout population would dwindle, and the habitat would be severely harmed.
I vigorously oppose this proposed project and request that the Federal Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. This proposed project is massive, intrusive, and if constructed will likely render our beautiful area with irreparable damage and cause turbidity in waters that serve as unfiltered water to millions of people in New York City. Please deny the permit request and tell the applicant this is not the right location for this proposed project.

Scott H See, KINGSTON, NY.
I live on and own property directly on the proposed 500 kv AC T/L. How will you be able to proceed with any structures if no residents are willing to allow you to build on their land? I am also greatly concerned about the dams having an effect on the resevoir and resevoir ecosystem. So you want to build a hydro electric station with the same reservoir you supply all of NYC's water? That sounds kinda dangerous if anything were to go wrong in any stages of the project as well as during operation. The Ashokan reservoir is a beautiful place and the surrounding areas are amazing yet your proposing to destroy some of it for more power? Most the residents out here want solar so this would benefit whom? I for one am against any kind of development within the area, ESPECIALLY within my own immediate area. My fiancee and I purposely bought this house and property specifically to get away from the grid without being off it completely. The last thing we want is ANY kind of power lines or structures anywhere within eyesight...

Laura Rosenthal, Northampton, MA.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Ben DeRosa, Chichester, NY.
FERC Project and Sub-docket Number: P-15056:000 

To Whom It May Concern,

I am a resident of Chichester, NY (Ulster County), and I am writing against the granting of a preliminary permit to Premium Energy Holdings – their proposal is both misleading and deficient.

I am a citizen who cares deeply about reducing our country’s reliance on fossil fuels. I believe we ought to transition to renewable energy, and there are many good things to be said for hydropower. However, the Catskills area is not the right place for this kind of project. The damage that would be done to state preserved forest land, waterways, and wildlife is immeasurable.

Importantly, Premium Energy Holdings’ proposal is misleading and deficient: While the company says it won’t touch the Catskills Forest Preserve, its actual plan locates the project right in the heart of the Catskills Preserve, which is 700,000 acres of land protected by Article XIV of the New York State Constitution. The Article states these lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” If the company wants to change the land management of the State Forest Preserve, a constitutional amendment is required, one that is voted on twice by the NY state legislature and submitted to the public in a referendum. 

In a hydropower project, the fluctuations of pumped water would increase the turbidity of the New York City water supply (the Catskills water supply provides 40% of New York City’s drinking water). Perhaps more importantly, it would wreak havoc on land and aquatic habitats. All of the natural streams that would be affected are vital trout waters, and important trout spawning grounds would be destroyed.

The Catskills Forest Preserve is 700,000 contiguous acres of wildlife habitat. Premium Energy’s proposed reservoirs fall within Audubon’s Catskill Peaks Important Bird Area and on land that is home to many protected species: 

•	“threatened species” such as the northern long-eared bat; 
•	“species of greatest conservation need” such as the black-throated blue warbler, scarlet tanager, and wood thrush; 
•	“species of special concern” such as Cooper’s hawk, red-shouldered hawk, sharp-shinned hawk, Eastern hognose snake, and timber rattlesnake. 

Premium Energy Holdings’ proposal is also misleading in that it is described as a closed-loop system when it is clearly presented as an open-loop design.  Both the Stony Clove and Woodland Valley upper reservoir designs involve and affect the free-flowing Stony Clove and Woodland Valley Creeks.  I live on the Stony Clove and know that, since 1995, the Stony Clove has received funding from the NYC DEP Stream Management Program, the US Army Corps of Engineers under the Watershed Environmental Assistance Program, and NYS Department of Environmental Conservation (http://www.catskillstreams.org/stonyclovesmp.html).  This significant investment in time, money, and resources has greatly improved turbidity / water quality and and the health of the Creek’s ecology.

The damage that this proposed project would inflict on the ecology of state protected land is immense and unimaginable. I urge you to protect our natural resources and deny Premium Energy Holdings a preliminary permit.

Sincerely,

Ben DeRosa
111 Stony Clove Lane
Chichester, NY 12416

Robert T. Krause, Olivebridge, NY.
 Please require Premium Energy to, at the very least, resubmit their application for the Ashokan Pumped Storage Project. As I'm sure you're aware, their proposal is not a closed loop system, as represented, and as I'm sure you're also aware, there are numerous other factual errors in their application. It goes without saying that such an enormous project should have meticulous planning and attention to detail prior to submission.
 This project, if ultimatly allowed to go forward (at any level) would have a negative impact of such magnitude effecting countless entities, that the result will be immediate and continuous pushback and never ending litigation. In my opinion, it will become increasingly obvious that Premium Energy didn't spend the time  and effort necessarty for proper proposal of such a plan and its location.
This is simply not the place for this project. I believe this will become increasingly obvious, to the extent this plan is allowed to go forward. I am also  of the belief, based on my experience of 45 years as a trial attorney and from what I've seen thus far here (both from Premium Energy's initial application and the resulting reaction to same in the short time it's been public) that ultimately this project will not go forward in this location. How much time and money end up wasted remains to be seen.
Respectfully submitted,
Robert T. Krause, Esq.

Rollin Hill, Shokan, NY.
I have concerns about the impacts of the proposed dams that are part of the Ashokan Pumped Storage Project.  I see no information concerning the impacts of a dam on the fish in the stream that will be dammed nor any indications that the dam will be designed to not impact local fisheries.  Also, I have seen indications that the increased inflow to the Ashokan Reservoir will cause increased turbidity.  The turbidity of the water in the reservoir is already a cause for concern as it impacts the lower Esopus Creek. 
 
Our area is known for outdoor activities, especially trout fishing.  Any damage to the environment, especially to the streams, will have impacts on the ecology and the economy of the region.  Once any damage is caused by construction such as with dams, it is difficult to recover from.  The impacts need to be fully assessed and discussed before any permitting is allowed.

Jennifer Vallance, Shokan, NY.
I value the environment and hope to seek out renewable energy sources but do not think this is in the best interest of the Town.  I raised a few concerns with FERC re: the impact on the quality of the water and the surrounding land.  Each member, all from different departments, indicated that “can be a concern”.  If they feel that way, then it is of deep concern to me as I’m sure it must be to the millions of people who live in NYC (as this is the main source of their water supply).

In addition, the proposal of additional, yet smaller, reservoirs bothers me for the simple fact that we already have several flood zones in the area and have gone to great time and expense to avoid the potential for flooding.  Over time and with the potential for erosion mentioned in several of FERC’s studies, I can only see this as a problematic area that will need to be addressed down the line.

Additionally, the State has gone to great expense to provide the Rail Trail which draws great crowds during all four seasons of the year.  Offering hiking, biking, etc. and the observation of many species of birds and other animals (some nearing extinction or on the wildlife protection list).  A project such as this will surely be a disruption to them in their natural habitat.

I think most people agree we all want to preserve the planet we share but it is hard to justify doing it this way when the health of many may suffer, the natural habitat may disappear and all that is beautiful about this area will be torn apart in the process.

Everest Schmidt, Shokan, NY.
I write as a resident of Olive that I am concerned about the proposed placement of the hydro electric dam and power plant. From my understanding, this project will have a significant negative environmental and ecological effect on lands, at least partially, protected by New York’s Constitution. See Article XIV, Section 1, of the New York Constitution (“The lands of the state, now owned or hereafter acquired, constituting the forest preserve as now fixed by law, shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private, nor shall the timber thereon be sold, removed or destroyed.”) How many trees will be decimated in these beautiful Catskills mountains to string high voltage power lines and the bulldozing for a reservoir.

What remains of the wild must be protected. The natural beauty of these mountains draws  thousands of visitors from all over the world to these small communities, thus helping sustain our small businesses. Any kind of massive construction project, such as the proposed plan, should be looked at with strict scrutiny. 

This application should be denied.

Marisa Ann Perez Rogers, Shokan, NY.
We live in the Town of Olive, Village of Shokan, We greatly oppose this Hydro electric plant construction project in the town of Olive.  We recreate often and regularly throughout the area, this would be devastating to our scenic way of life as well as a detriment to wildlife and surrounding habitats.
please decline their proposal for this power plant.  
thank you!

Katherine O'Sullivan, New York, NY.


As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Abigail Muro, Durham, CT.
The following is written by a 10-year-old adversary to the pumped hydro project proposal.

The scent of trees drifts through the air. The Esopus Stream is making its way through the rocks. In my opinion the dam should not be built that will drown Woodland Valley and flood this stream. The dam should not be built because it is home to many plants and animals, people live there, the water won’t be the prettiest, there is a lot of history, and it uses more energy than it creates.         

First off, Woodland Valley is home to many plants and animals. Their homes would be destroyed and they would most likely die. Most of Woodland Valley's natural beauties are because of them. This makes Woodland Valley the perfect destination for wildlife lovers. As you can see Woodland Valley is home to many plants and animals.

My second reason is that people live there. They would have to move out of their houses not because they wanted to. There is even a whole colony that has made many traditions specific to that piece of land. Also would you like to have someone tell you you have to move out of your house and go somewhere else? To sum it up people live there and you would be wrecking their homes and properties.

Third, the water isn’t the prettiest. It isn’t the blue waters of Hawaii. The mountains are the Valley’s prettiest aspect. Sure water is fun but why bring more of it to a perfectly fine creek. To conclude the water isn’t the prettiest. 

Lastly, it is going to use more energy than it creates. First, it is just a silly idea if you have to drown places just to take energy and produce less than you took. Secondly, energy is not a toy, you are supposed to treasure it and not use it irresponsibly. Also, there are other environmental friendly options to produce energy that don’t involve a dam and water. In conclusion this way of making electricity is a bad idea because it is going to use more energy than it is going to create.

As you can see the dam should not be built. Not only is Woodland Valley home to many examples of wildlife, but there are many people who call it home, the water won’t be the prettiest, there is a lot of history, and it is going to use more energy than it creates. So call the building of the dam off and save the valley.

Julia Muro, Durham, CT.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Richard Kirgan, West Hurley, NY.
Pumped Storage Electrical Generating Systems consume MORE electricity than they produce.  It takes more energy to pump water to the upper reservoir than is produced when the water flows back downhill.  The advantage to pumped storage is that the electricity costs less to move the water uphill because that happens typically at night when electricity demand is low.  The electricity produced when the water flows down is more valuable because that happens when electrical demand is high. Pumped storage can be a net producer of electricity only if a stream or river adds water to the upper reservoir.

The advantage to pumped storage besides the economics for the electric company is that it is more reliable since wind or sunlight are not factors like in "green" generating systems.

To build a pumped storage system would require dams, reservoirs and tunnels.  The disruption and habitat loss, as well as monetary cost, is not justified.

Marisa Beauchemin, Providence, RI.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Other formats

Delia Kulukundis, Phoenicia, NY.
I am writing to oppose the Ashokan Hydroelectric pumped storage facility that Premium Energy Holdings has proposed in the Catskill region of New York (P-15056-000). 

I volunteer with the New York - New Jersey Trail Conference to maintain one of the trails accessed from the Woodland Valley Campground within the Catskill Forest Preserve, in an area that would be flooded by the proposed upper reservoir of this project. Our public campgrounds, trails, and streams are some of the most popular in the Catskill Forest Preserve, and attract people from all walks of life, including anglers, endurance athletes, thru-hikers on the Long Path, young families, and people simply looking for a change of scenery from urban life. New York State parks, trails, campgrounds, and historic sites saw a record 78 million visits in 2020, surpassing the previous record set in 2019 [1]. Our public lands were ever more important during a year of grief and isolation, and public campgrounds are a vital resource in the movement to make outdoor recreation more welcoming to people of color and other marginalized groups. Flooding Woodland Valley to create an upper reservoir for open-loop pumped hydropower energy storage would destroy this beloved resource.

In all three of the proposed locations, creating an upper reservoir by flooding the valley would destroy homes and communities, remove access to our public lands, and destroy the livelihoods of people who work adjacent to tourism in the region. The alternative site for the reservoir in Lanesville would destroy the recreational resources of the Devil’s Tombstone Campground and the fly fishing along Stony Clove. The proposed site in West Shokan would also destroy a residential center and a popular trailhead at the end of Moonhaw Road. 

All three of the proposed locations would encroach on the boundaries of the Catskill Forest Preserve, land that is designated by the New York State Constitution as “forever wild.” Encroaching on the forest preserve is difficult, as it should be: it requires a state constitutional amendment, two consecutive votes in state legislature, and a referendum. I urge you to reject this project swiftly, and not waste the time of your own agency and that of our state agencies tasked with protecting our public lands. 

[1] https://www.governor.ny.gov/news/governor-cuomo-announces-historic-78-million-visits-state-parks-2020

K. Clark, New York, NY.
I am a NYC resident and I am very concerned this project would affect the drinking water for me and 9 million neighbors.  Our water supply is not an experiment.  
As a NY State resident, I am concerned that this project is being proposed by an out of state corporation seeking to make a profit, without taking into consideration the lives and health and homes of NYS and NYC residents.
While I understand, and applaud, an effort to inquire into green energy solutions, that cannot come at the cost of tainting our water supply.  
Please do not approve this project.

Mitchell B Langbert, West Shokan, NY.
Dear Governor Cuomo:

There is a proposal, which is part of the Premium Energy Proposal,  to build a new, 225-acre reservoir and dam running 1/2 mile long in West Shokan.    Much of the construction would be underground, but it’s unclear to me whether there would be blasting and depredation of the visual environment were the dam to be approved. The environment here is the chief reason my late wife and I moved here 24 years ago. 
 
I received a flyer from a local group with whom I usually have few dealings, so the actual impact of the project is unclear to me. I note that property values here have soared in recent months, and the question needs to be asked whether the destructive effects on real estate values and the environment (the project abuts hiking trails and state campgrounds) will equal the economic gain from additional electricity.  Houses here that were worth $150,000 two years ago are now worth $400,000. The demand for outdoor recreation has also soared.
 
The city has a history, which goes back 120 years, of pursuing projects of benefit to the city without concern for costs to the Town of Olive.   I doubt that the costs have been accurately assessed, nor is it clear what the environmental damage will be, nor is it clear that the funds will be available to complete a long-term project.
 
Sincerely
 

Mitchell Langbert
H: 845-657-8460

Warren Davis, Olivebridge, NY.
I have lived in the Ashokan Reservoir area for over 40 years. While I have seen many changes, there is one feature that endures.  The Ashokan Reservoir remains a spectacular natural habitat for many species - while some are endangered all of them matter.  Most important, the habitat endures as a natural haven only a hundred miles from one of the world’s great metropolitan areas; and is a symbol to our commitment to the environment. This habitat then goes on to effortlessly provide clean, quality, pure water to that city of 9 plus million.  While Pumped Storage facilities offer promise and while it is an emerging technology, the Ashokan Reservoir is the wrong site for this.This will be a massive project and will disrupt and destroy this very valuable habitat, regardless of the assurances anyone can provide.  I voice my opposition to this project.

Hunter West, Huntingdon Valley, PA.
The Proposed Hydroelectric Plant at the Ashokan Reservoir is a poorly thought out attempt at producing sustainable energy. Premium Energy have not provided
enough information on this project to warrant hand waving of any part of their
proposal. To create an inefficient hydroelectric plant that must pump water uphill to yield energy in the first place is a poor plan. On top of this, building on status 1 land is just inviting a legal battle that could end up delaying this project for a long time. If the state of New York wants to get sustainable energy to its citizens right away, then why try to take land that will require an amendment to the New York State constitution, which protects the Catskills. With Joe Biden now president, there is a solid chance that nuclear power plants in the state of New York will have the funding to reopen sometime in the next four years. In addition to this, wind and solar can easily be substituted with a much smaller environmental impacts on one of New York's greatest treasures. The untouched Catskills region is the primary reason that I, as a citizen of the Commonwealth of Pennsylvania, visit and spend money in the state of New York. Please take time to solicit more reasonable and thought out sustainable energy proposals before rushing into any attempts to fundamentally alter the Catskills region.
Thank you very much for taking the time to read my comment,
Hunter  West

Peter A McAndrews, Goshen, NY.
This proposal is almost laughable.  All of the proposed sites are status 1 land which should be avoided per DOE.  Further, any development in this area would require an amendment to the NYS Constitution.  The region in question has already suffered due to the extensive network of NYC drinking water reservoirs.  Further, this are is used extensively for recreational pursuits, including hiking, camping, fishing and hunting.  In a state as densely populated as NY, eliminating land suitable for such activities should always be a last resort.

Phoebe Jones, Philadelphia, PA.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE
Room 1A
Washington, D.C. 20426

Dear Kimberly D. Bose,

I am writing to express my strong opposition to Premium Energy Holdings’ plan to build a hydroelectric plant in the Ashokan Reservoir region of Ulster County.

As my husband, in-laws, and several members of our extended family have indicated in their own comments, our family has owned a house in Woodland Valley for more than 75 years. The house and the valley it sits in are a family heirloom. While we own the house, the valley and its natural and beauty are accessible to all and are widely utilized. The state campground at the end of Woodland Valley Road, which would become inaccessible if Premium Energy Holdings’ plan comes to fruition, is an affordable way for the public to enjoy the idyllic mountain air, water, hiking, and fishing in Woodland Valley. It attracts thousands of visitors annually who bring with them a significant positive economic impact on the surrounding communities and the businesses that call those communities home. Without those visitors and the others who rent houses in the valley, these businesses and the economy of Phoenicia and the surrounding communities would suffer tremendously. They depend on tourism for their survival, and the tourism is dependent on the area’s natural beauty. 

Even conducting a study on the feasibility of such a short-sighted project would cause serious harm to the environment and natural beauty of the region. Building the temporary roads mentioned in Premium Energy Holdings’ filing will create air, noise, and water pollution and damage the environment.

Premium Energy Holdings’ proposal to use eminent domain to seize privately owned land is inappropriate. They are a private, for-profit entity asking the state to use a provision intended for the public good of all citizens in order to increase their own private profit. Moreover, nearly 75% of the power generated by the proposed plant will go toward running the plant, leaving very little to supplement the existing power grid.

Even if there is a gain in terms of cheaper or additional energy, which seems far-fetched based on the proposal, that gain would be vastly outweighed by the economic cost of acquiring the privately-owned land, the negative economic impact on the surrounding communities, the negative environmental impact of destroying the natural flow of the Woodland Valley Creek, and the destruction and loss of one of the most beautiful and peaceful places in all of the United States: Woodland Valley, New York.

For these reasons, I urge the FERC to stop the wasteful, unnecessary destruction of Woodland Valley before it begins. Deny Premium Energy Holdings’ proposal before it ruins the quality of life, livelihoods, and well-being of the people of the region and the land itself.

Sincerely,

Phoebe Jones

Drew Boggess, Shokan, NY.
Comments concerning FERC Project No. P-15056-000

I am asking FERC to deny the application for a preliminary permit for the Ashokan pumped storage project submitted by Premium Energy Holdings on January 29, 2021.  This project application has many severe technical errors in  it.  I will only address a couple of them in this comment.  It is difficult to determine if the applicant is out-and-out lying, or is incompetent, or simply failed to adequately do proper research for this application.

First, on page 11 of the application, the applicant says the system they are proposing is a closed-loop system.  This is blatantly wrong.  The Ashokan reservoir was built approximately 115 years ago and provides drinking water to New York City.  The Esopus creek flows into the western basin of the reservoir along with several small to meadium streams.  The Esopus creek then flows out of the eastern basin of the reservoir.  Approximately 40% of New York City’s clean drinking water flows through the Ashokan reservoir.  So, the system they are proposing is actually an open-loop system.  And as you know, DoE encourages the use of closed-loop systems for pumped storage, not open-loop systems.

 Second, on page 13, 2. A, the applicant indicates the pumping of 15.800 acre-ft would cause the reservoir surface variation of 2 ft based on a reservoir surface area of 8300 acres.  Again, the applicant didn’t do their homework, because they failed to understand how the Ashokan reservoir works.  The Ashokan reservoir has two distinct basins with a dividing weir between them.  The Western basin (this is the basin the applicant indicates pumping will occur) is designed as a settling basin to reduce turbidly in the water before flowing into the eastern basin and on to New York City.  So, water flows from the western basin to the eastern basin and cannot flow in the opposite direction.  Therefore, when calculating the variation of the surface level you must use the surface area of the western basin which is 3106 acres at full capacity.  When pumping 15,800 acre-ft the surface level variation of the western basin would be 5.09 ft.   Also, the western basin has a volume of 143,700 acre-ft when full, which means every day the pump storage system would be pumping about 11% of the western basin volume at full capacity.   These numbers only get worse when the western basin is not full, which is most of the time.

If the applicant can make these serious technical errors at this level of preliminary concept, how can they possibly be trusted to design a system without major flaws?

William Thompson, Northampton, MA, MA.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Doris Cheng, Chichester, NY.
As a resident of Chichester, NY in Ulster County, I am writing to oppose the granting of a preliminary permit to Premium Energy Holdings. While I support our nation’s transition to renewable energy and recognize the many benefits of hydropower, I believe the Catskills region is not the right location for such a project given significant impacts to state preserved forest land, streams, species, and the New York City water supply. Much of the harm would be unlawful and in violation of the New York State Constitution. Additionally, Premium Energy does not provide the kind of innovation sought by the Department of Energy given that its proposal is deficient and misleading. 

Premium Energy’s claim that it will build a “closed loop” system is false; closer study indicates their proposal is actually an “open loop” system, an “add on” project where an upper reservoir would be added to an already existing lower reservoir connected to a natural water source. As you know, the environmental and aquatic impact of such an open loop system would be significant and damaging. 

The company also falsely states that the project will take place outside the boundaries of the protected Catskills Preserve. Closer study indicates that its proposed sites are actually located squarely within the Catskills Forest Preserve (established 1885). This area is protected under Article XIV of the New York State Constitution, which deems the lands “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” Any change in the management of State Forest Preserves have to be passed by constitutional amendment, which involves both state legislative approval and a public referendum. Otherwise, it is unlawful and unconstitutional.

Consider also the fact that, as a State Forest Preserve, the Catskills are considered Status 1 land under the USGS Gap Analysis Program. According the US Department of Energy’s own Hydropower Vision report, “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” 

I believe the protected status of the Catskills Forest Preserve; the misleading nature of Premium Energy’s proposal; and DoE’s mandate to avoid Status 1 land are all reasons to disqualify Premium Energy Holdings from receiving a preliminary permit.

Sincerely,

Doris Cheng

Ben Kilgust, Oakland, CA.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Justine Hookes, Bearsville, NY.
As someone who lives near to and visits the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that FERC deny the application for a preliminary permit. The proposed project is massive, terribly invasive, and if constructed, likely to damage local lands, roads, and streams, causing increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. I wholeheartedly support alternative and renewable energy sources, but this project is not the right one for this region. Please do everything in your power to prevent this proposal from moving forward. Many thanks for your time and consideration.

Kathryn Kassner, Red Hook, NY.
The Premium Energy Holding’s proposed Ashokan hydroelectric project does is not well suited for the Catskills and the Ashokan reservoir.  Nine million NYC residents depend upon the reservoir for their drinking water.  It is not something that should be put in jeopardy.  The project would also be disruptive to local ecosystems.  The beauty of the Catskills brings many of us to the area to recreate and contributes to the economy in the region.  Just last week it was announced that the Catskills Park would receive funds for maintaining it as the treasured resource that it is.  Please reject the application for a preliminary permit.

Karen Charman, Shandaken, NY.
Dear FERC,

I have been a full-time resident in Shandaken, NY for the last 21 years, and I am writing to respectfully express my strong opposition to Premium Energy’s proposal to build a pumped storage hydropower plant in our area. I understand the need to move away from fossil fuels to counter global warming and am an ardent proponent of clean, renewable energy. However, the proposed project is totally inappropriate for this area for numerous reasons, a few of which I will mention below.

Premium Energy proposes to build its project in the middle of New York City’s watershed, the Catskill Park and Forest Preserve—priceless public resources. Ninety percent of New York City’s water comes from the Catskill/Delaware ¬¬¬water system, the largest unfiltered water supply in the country, providing 1 billion gallons a day to 9.5 million people. The Ashokan Reservoir, which Premium Energy is proposing to use as its lower reservoir, provides about 40 percent of the city’s daily drinking water. The pumped storage project proposes to build an upper reservoir, in one of three places: along the Stony Clove in Lanesville, along Woodland Valley Stream in Phoenicia, or in Olive by flooding homes on Moonhaw Road. The Ashokan already has problems with silt buildup. Pumping water back and forth from these upper reservoirs would add to the turbidity of the Ashokan, degrading the quality of New York City’s drinking water.

Pumped storage projects are also known to damage stream ecology, with negative impacts on both aquatic and land habitats. Water from an upper reservoir either on the Stony Clove or in Woodland Valley would travel back to the Ashokan Reservoir via the Esopus Creek. The Esopus is a major trout habitat and world class trout fishing stream that attracts fly fishermen from all over the world. Degradation or loss of trout habitat in the Esopus would also cause economic harm to our area.
 
The Catskills Forest Preserve is designated in Article XIV of the New York State Constitution as lands that “shall be forever kept as wild forest lands. They shall not be leased, sold or exchanged, or be taken by any corporation, public or private.” The U.S. Dept. of Energy’s own Hydropower Vision states that “areas with formal protections designated as Status 1 or 2 under the USGS Gap Analysis Program are avoided for development.” Since the Catskills are a State Forest Preserve, the land that makes up the Forest Preserve is classified as Status 1 land under the USGS Gap Analysis Program. Therefore, the entire Catskill Forest Preserve must be removed from consideration of Premier Energy’s proposed pumped storage hydropower project.

Thank you for your consideration.

Respectfully submitted,
Karen Charman

Lauren Kelley, Portland, OR.
As a former New Yorker who owned a home about eight miles from the Ashokan Reservoir and hopes to live near there again soon, I am shocked and disappointed at the thoughtlessness of the proposal by Premium Energy Holdings. I have hiked and swam in the Woodland Valley, and attended a square dance (SERIOUSLY, a square dance) at a wonderful gathering place for a group of homes that have been owned by families for a hundred years.  Energy creation by flooding areas that are protected, vital, and carefully enjoyed is not a solution. I object to this proposal's shortsightedness, environmental destruction, construction impact, and risk to the area's watershed (not to mention to the residents of NYC who drink this water). Please do everything in your power to prevent this proposal from moving forward.

Allan Goldhammer, Kingston, NY.
The proposed pumped storage project is not the best way to provide storage capacity. 

The project is within Catskill State Park.  This is a scenic resource. Residents of the Hudson Valley are very aware of the Storm King pumped storage proposal, which was defeated. Resistance is already gathering.

Other technologies exist to fill this need. Edison battery (nickel-iron) storage was recently put forward as an alternative to an unsuccessful local gas fired peak power plant proposal.  These larger batteries are safer than lithium batteries, so a facility can be the same size as a lithium storage facility which requires spacing of units for fire safety. Several Edison battery storage buildings could be sited around the electrical grid to provide this capacity, even though their energy storage density is not as large as a pumped storage facility. 

Pumped storage reservoirs are not viable living habitats, as they are drained when used, and the contents fed through turbines.  The remaining biomass would be deposited into a drinking water reservoir to decay.   The Ashokan reservoir already has faced water quality problems, which require watershed management regulations, and is now facing sediment management trouble in the lower Esopus. 

https://en.wikipedia.org/wiki/Scenic_Hudson_Preservation_Conference_v._Federal_Power_Commission
https://en.wikipedia.org/wiki/Nickel-iron_battery

Submission Description: (doc-less) Motion to Intervene of Rokhsareh Angha under P-15056-000.

Submission Date:        3/22/2021 10:53:48 AM

Filed Date:             3/22/2021 10:53:48 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               Roxy.angha@gmail.com                                                             

Basis for Intervening:
Motion to Intervene of Rokhsareh Angha for the Premium Energy Holdings, LLC, Project No. 15056-000

All communications, pleadings, and orders with respect to this proceeding should be sent to the following individual:

Rokhsareh Angha
165 East 32nd Street
Apt 12G
New York, NY 10016

I, Rokhsareh Angha, own property, including land and physical residence, within one of the proposed building sites included in the Premium Energy Holdings, LLC Project No. 15056-000. As such, I am seeking a Motion to Intervene. 

The proposed building site, Alternative 3, Wittenberg Reservoir, is located where my residence and my entire property exists. I would no longer be able to use any part of my property or residence if this project were approved at the proposed building site, Alternative 3, Wittenberg Reservoir. The address of my property located within the proposed building site is:

325 Moonhaw Rd.
West Shokan, NY 10016

I have important information and perspectives to bring to this process, consideration of which will serve the public interest.

Wherefore, I, Rokhsareh Angha, respectfully requests that the Commission to grant my Motion to Intervene as a party with full rights to participate in all further proceedings.

Respectfully submitted,

Rokhsareh Angha
325 Moonhaw Rd.
West Shokan, NY 10016

Submission Description: (doc-less) Motion to Intervene of David Traub under P-15056-000.

Submission Date:        3/22/2021 10:46:04 AM

Filed Date:             3/22/2021 10:46:04 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               dmtraub@gmail.com                                                                

Basis for Intervening:
Motion to Intervene of David Traub for the Premium Energy Holdings, LLC, Project No. 15056-000

All communications, pleadings, and orders with respect to this proceeding should be sent to the following individual:

David Traub
165 East 32nd Street
Apt 12G
New York, NY 10016

I, David Traub, own property, including land and physical residence, within one of the proposed building sites included in the Premium Energy Holdings, LLC Project No. 15056-000. As such, I am seeking a Motion to Intervene. 

The proposed building site, Alternative 3, Wittenberg Reservoir, is located where my residence and my entire property exists. I would no longer be able to use any part of my property or residence if this project were approved at the proposed building site, Alternative 3, Wittenberg Reservoir. The address of my property located within the proposed building site is:

325 Moonhaw Rd.
West Shokan, NY 10016

I have important information and perspectives to bring to this process, consideration of which will serve the public interest.

Wherefore, I, David Traub, respectfully requests that the Commission to grant my Motion to Intervene as a party with full rights to participate in all further proceedings.

Respectfully submitted,

David Traub
325 Moonhaw Rd.
West Shokan, NY 10016

David Sandman, West Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

I do understand and appreciate the need to create more truly renewable energy sources. We cannot allow typical NIMBY concerns to block all projects. 

However, this proposal is truly deficient, would cause massive and irreparable harm to protected lands and to people, and should be denied on its merits. The proposed sites in the Catskills region are on Status 1 land, and the Department of Energy has clearly stated that Status 1 or 2 land must be avoided for any development. The proposed project will cause severe ecological damage, particularly on streams resulting in increased turbidity and sediment in water that serve as an unfiltered drinking water source and blocking the natural spawning areas of trout and other wildlife.

Furthermore, the proposed project is not a true ‘closed loop” energy source and is not the type of innovation that is being sought; it could even result in a net loss of energy given its reliance on traditional pumping to higher elevations. 

Thank you for the opportunity to comment. I respectfully ask that you prevent this proposal from moving forward.

Kriston Ryan, PHOENICIA, NY.
Please STOP THIS! 
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Please and thank you! 

This project is not a fit for this area, please do not force this upon our small towns and beautiful outdoors.

Rebecca Lamoreaux, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Carole Huppert, West Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 
 
I do understand and appreciate the need to create more truly renewable energy sources. We cannot allow typical NIMBY concerns to block all projects. 
 
However, this proposal is truly deficient, would cause massive and irreparable harm to protected lands and to people, and should be denied on its merits. The proposed sites in the Catskills region are on Status 1 land, and the Department of Energy has clearly stated that Status 1 or 2 land must be avoided for any development. The proposed project will cause severe ecological damage, particularly on streams resulting in increased turbidity and sediment in water that serve as an unfiltered drinking water source and blocking the natural spawning areas of trout and other wildlife.
 
Furthermore, the proposed project is not a true ‘closed loop” energy source and is not the type of innovation that is being sought; it could even result in a net loss of energy given its reliance on traditional pumping to higher elevations. 
 
Thank you for the opportunity to comment. I respectfully ask that you prevent this proposal from moving forward.

Submission Description: (doc-less) Motion to Intervene of Daniel W Morgan and Willa Koerner under P-15056-000.

Submission Date:        3/22/2021 3:36:43 PM

Filed Date:             3/22/2021 3:36:43 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               themorgantown@gmail.com                                                          
Individual                               willa.koerner@gmail.com                                                          

Basis for Intervening:
Dear Secretary Bose:

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314) Daniel Morgan and Willa Koerner hereby petition the Federal Energy Regulatory Commission to grant them full party status in the above-captioned proceeding (Premium Energy Holdings, LLC Project No. 15056-000). The persons to whom communications should be addressed and to whom service should be made are as follows:

Daniel Morgan & Willa Koerner
304 Moonhaw Rd, 
West Shokan, NY, 12494

As grounds for this motion, we submit the following: 

Daniel Morgan and Willa Koerner live within the geographic area of the proposed dam (Wittenberg / Alternative 3) and seek to become a party to this proceeding. Were the dam and the reservoir to be built, they would lose their primary residence, and their entire property, including a historic 100-year-old cabin and guest house. 

Daniel Morgan & Willa Koerner

Francis Fallon, Shokan, NY.
I believe the proposed project to be too large and disruptive for the Catskill Park and New York City Reservoir system.

I'm hoping to see Green Energy proposals for the region that take into account that this is a protected park and therefore a valuable resource.

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Eric Ansanelli, Hunter, NY.
Hello,

There appear to be material errors in an Amendment filed to this docket dated January 21, 2021; the amendment is identified with a document accession number: "20210201-5022" for FERC project number 15056. In the aforementioned document section titled "ADDITIONAL INFORMATION REQUIRED BY 18 C.F.R. § 4.32(a)" it is stated: "Every city, town or similar local political subdivision:
(A) In which any part of the project, and any Federal facilities that would be used by the project, would be located" and DOES NOT go on to identify the county, town, or locality of Lanesville, NY, located in the Town of Hunter in Greene County, where the same document proposes a 245-acre reservoir and associated dam.

The wetted footprint of the proposed reservoir, shown later in Exhibit 3 of the same document, would include a small rural town center and the sole arterial road (NY-214) that provides access to the residents of the Stony Clove valley, including my business. To the extent of my knowledge, neither the residents of the directly affected and adjacent areas nor the leadership at the town and county level have been informed of this proposal. 

This reservoir would require the removal or destruction of currently-occupied homes and places of business and it would have direct adverse impact on my business. The community members have not been given their due as stakeholders.

Sincerely,

Eric Ansanelli

Cindy Flamenhaft, West Hurley, NY.
This is a massive project that is being proposed in a quiet, residential area which is being over-run with corporations looking to cash in on the beautiful lands and natural resources. It is obviously a concern to local residents. Unfortunately, due to poor planning, tonight’s meeting was set up on a platform that could only accommodate 100 participants. Many tried to join but could not. Therefore, additional public forums should be created.

Maxine Davidowitz, West Shokan, NY.
I have learned that your company has proposed a feasibility study for a pumped storage facility in the Ashokan reservoir region and I must strenuously object. The region you are considering bringing this to is a State Forest Preserve with the highest possible protective status (Status One) as designated by the USGS. You should have been aware of that from the outset, and so I wonder at the potential for other flaws in your proposal. The region is one of the rarest preserves in New York State of natural forest, with protected wildlife, flora and fauna. This is a rural area with small narrow roads, as well, and any construction through this region would be completely unfeasable. I have very deep concerns about this destructive proposal, and I will make my opinion known to all parties involved.

Natalie Korniloff, Boiceville, NY.
It is ridiculous that a company from another state is proposing something that the community hasn't asked for or needs.  My understanding is that the facility itself will generate 2800 MW but only 800MW go to the community, which I assume we will have to pay for via our electric bill.  My other understanding is that the other 2000MW will be used to run the facility. What is our community to gain??  There will be a huge disruption to the community and ecology of the area. For what?  It can be assumed that this intruding company will somehow make a profit on the back of our community.  Essentially:  How dare they..??

Skye Owens, Chichester, NY.
The areas where these proposed sites exist are all on private land meaning the destroying of property and revenue driving activities for our towns and local businesses.
We rely on tourism dollars in the Catskills such as hiking, snow sports, hunting, fishing, fly fishing, geo studies, educational camps, and scenic byways like 214 through Lanesville.
Please reconsider this project on NY STATE LAND, not private property.

Oksana Nichols, Olivebridge, NY.
Hi, my name is Oksana Nichols. I have 
Been a full time resident at 2303 State Rt 28A, Olivebridge, NY 12461 for the past 17 years. This is one of the most unique places in NYS. Besides being beautiful in any time of the year, its home to some protected species, like timber rattle snakes, bold eagles, eastern hognose snake, bog orchid. Many local creeks and brooks are both trout waters and trout spawning habitats. The Ashokan pumped storage project / FERC project # P-15056 is deficient since it is not a closed loop project, as it involves addition of another reservoir, this project is deceitful and potentially comes in direct conflict with The US Constitution, as the area proposed for the development in FERC project # P-15056 is part of Catskills Forrest Preserve, created by Constitution in 1885. The Ashokan pumped water storage project will increase the turbidity of the water, thus decreasing the quality of the drinking water NYS wide, and affecting trout natural environment. Please, do not allow FERC project # P-15056 go any further and do not grant preliminary license.

Amy Barkow, Phoenicia, NY.
As a part-time resident of the Woodland Valley in Phoenicia, NY (one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity), I categorically object to the proposal and request that the Federal Energy Regulatory Commission do everything in its power to deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, expensive and unnecessary. If allowed to proceed, it will destroy or cause longterm damage to local lands, streams and native wildlife, require massive road and infrastructural reconstruction and cause increased turbidity in waters serving as an unfiltered drinking water source for more than nine million people in New York City. I strongly oppose this proposal and urge the FERC to do everything in your power to prevent this proposal from moving forward.​

Amy Barkow

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Jim Nickel, Phoenicia, NY.
/Users/owner/Desktop/Premium Energy Holdings in Catskill.pages

Christina Muro, Durham, CT.
As someone who recreates and whose family owns a home on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sean Mahoney, Tannersville, NY.
As a resident of the Town of Hunter, I would like to make it known that there has been no official communication between this project and its owners and our local municipality. From what i can tell from the proposal, this project would eliminate a large portion of the Hamlet of Lanesville within the Town of Hunter. We have numerous residents that would be impacted by this development, as well as a State Highway 214 which appears would have to be moved.

At this time, I ask that the local municipality the Town of Hunter be notified and brought into the fold of what is being proposed within our Town Borders. We want full transparency and facts presented on All of the impacts that this project would bring to our Town. 

Thank you,

Sean Mahoney

John T Witter, New Paltz, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

John T Witter, New Paltz, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

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Nancy Golladay, Phoenicia, NY.
We own a home in one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. This project would take place less than 2 miles from our Woodland Valley property. We need constant access to this house, as, being senior citizens, we shelter there during COVID spikes in the greater NY area. I strongly object to the proposal. It defies common sense. I ask that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. Their proposed for-profit project is likely to damage local homes, roads, bridges, and streams in the area, plus denying local merchants and workers their much-needed seasonal income from tourism, skiing, and sport fishing. The increased turbidity in waters will also threaten the unfiltered drinking water source for 9,000,000+ residents of New York City. Therefore, the project benefits no one in NY State except its investors, if any such exist outside of PEH's California-based business. Please do everything possible to stop this ill-conceived proposal now.

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A statement regarding Docket # P-15056—Ashokan Pumped Storage plan.

As a resident of Woodland Valley, one of the locations being proposed by
Premium Energy Holdings of California as a site for a large reservoir,
for use in pumped storage and generation of electricity_,_ I vigorously
object to the proposal and request that the Federal Energy Regulatory
Commission deny Premium Energy Holding’s application for a preliminary
permit.

In addition to dispossessing hundreds of homeowners, this reservoir
would inundate and flood the valley’s current water way--Woodland Brook,
a trout stream and tributary to the Esopus Creek. It is a special and
beautiful stream.

John Burroughs, the 19^(th) century naturalist and author, wrote of
discovering the brook for the first time:

But the prettiest thing was the stream soliloquizing in such musical
tones there amid the moss-covered rocks and boulders. How clean it
looked, what purity! Civilization corrupts the streams as it corrupts
the Indian; only in such remote woods can you now see a brook in all its
original freshness and beauty. Only the sea and the mountain forest
brook are pure; all between is contaminated more or less by the work of
man. An ideal trout brook was this, now hurrying, now loitering, now
deepening around a great boulder, now gliding evenly over a pavement of
green-gray stone and pebbles; no sediment or stain of any kind, but
white and sparkling as snow-water, and nearly as cool. Indeed, the water
of all this Catskill region is the best in the world. For the first few
days, one feels as if he could almost live on the water alone.; he
cannot drink enough of it. In this particular it is indeed the good
bible land, “a land of brooks of water, of fountains and depths that
spring out of valleys and hills.”

The brook is the particular reason many of the valley’s homeowners chose
to live there. And when it comes their time to die, rather than be
consigned to a cemetery, their emotional attachment is such that they
prefer to have their ashes joined with the brook.

I make no apology for waxing poetic about my boyhood stream. It would be
a sin, a travesty, to permit an energy company to decimate Woodland
Brook. What follows will give you a further idea of how I feel on the
subject.

Thank you.

J. Michael O’Neil

WOODLAND BROOK

Thoughts of the brook consume me.

There’s early spring, when the water runs

Fast and blue and the shadblow blooms pure white

All along the valley corridor.

My father directs me to use a quill Gordon.

Iron Fraudator hatches while the last

Thin snow falls.

Grandpa was right.

Life is not all skittles and beer.

Even on a bright Memorial Day,

You can find evidence of Winter’s

Harsh directive.

The stench of rotting flesh hits us

Like a wall, as we crash through

Sinewy brush, lugging heavy buckets

Of stocking trout.

The doe’s body was hidden in deep water,

Until this sudden dry spell.

Lately she has become the uncontested property,

Of recalcitrant valley dogs and buzzflies.

In summer the brook dwindles to a crystalline trickle,

Under a demanding sun, grasshoppers bask

In the hot dust and fiddle beneath the black-eyed suzies.

Cautious trout maintain themselves in the shade

Of willows and smooth children’s jumping rocks

They wait for nighttime when they will fill with

Brash courage and feed in a frenzy on top.

Take your rod and visit them then.

To Hell with the cocktail hour.

Cold wet autumn, when the slate drakes hatch

Leaving their skinhusks behind like gossamer souvenirs of their

First life. As May flies, they flutter off through the rain

To begin their brief climactic last-life.

There is the Grandparent’s pool,

Where we laid my parents’ ashes,

First his in his year of death, then her’s.

Angler’s ashes in the waters they loved.

The brook holds them and venerates them,

As do we.

J. Michael O’Neil

Jack Laroux, Lanesville, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward!

Hilary Lander, SAUGERTIES, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Angel Fonseca, Kingston, NY.
I’m totally against the new plant that has been presented for ashokan reservoir!!!

Jennifer Ogg, Kingston, NY.
I am a resident of Olivebridge, however our mailing address is Kingston. We live very close to the Ashokan reservoir with my parents and young daughter. We stand in opposition of the proposal for the pumped-storage hydroelectricity plant. We fear the ecological and environmental impact it will have on the area as well as the displacement of residents in the area. We strongly urge you to reject their proposal for the sake of humanity. Thank you.

Franke Ogg Deborah, Olivebridge, NY.
NO NO NO to this project.  It has way too much environmental impact  on humans, the environment, the animals, the water for the yield that is expected.  Please don’t ruin our beautiful town!

Mary Schneller, Hurley, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Thank you, 
Mary Schneller
MSchneller1028@gmail.com

Barbara L Valocore, Olivebridge, NY.
To Whom it May Concern,

RE: Docket P-15056

     As a resident of Olive for 27 years whose property is on both sides of the Mettacahonts Creek, I realize the fragility of our precious eco- system and strongly oppose this unnecessary hydro project. The amount of digging and construction in the fragile area proposed would permanently dislodge wildlife, the flora and fauna and countless other forms of life.  
   The Catskills are rich with many smaller streams that are part of the Hudson Valley watershed that are always running. These could easily support a host of micro hydro projects installed by individual home owners that could provide reliable electricity to the area.  
    This project is a bad idea for this area and I strongly oppose it.

Oscar Ogg, Olivebridge, NY.
As a 35 yearlong resident of Olivebridge I wish to voice my opposition to the proposal put forth by Premium Energy Holdings to build a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. This will literally wipe out several local communities as well as State Park property. I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Nathan Walker, Phoenicia, NY.
To my dear fellow human beings,

My family has been blessed with a humble home on Woodland Valley Stream for over 50 years.

Woodland Valley is a very special place, with irreplaceable value in the ecosystem, the history, and the ongoing community of the entire Hudson Valley.  Its beauty and value cannot be overstated.

We invite any associates of the PSP Ashokan Pumped Storage Project to come visit and stay with us, so that we may offer you a view of the magic that Woodland Valley offers to those who can respect it.

We open our home to you, in the hope that you will open your heart to Woodland Valley Stream.

In the time we have lived there, we have witnessed an ongoing natural reclamation of a vast ecosystem, hosting myriad stories of life and regeneration.  

This area has been torn apart again and again by human development over the last few centuries, and it deserves the chance to have time to grow back into what it could be again, without the threat of yet another usurious human endeavor poisoning and pillaging its resources.

We locals have seen the way the river naturally flushes itself on an irregular and unpredictable basis, and the unquestionable value of flooding.  Any reservoir at this elevation would most likely be a fool’s undertaking.  We have watched bridges and homes get washed away in the various moods of the stream, and we have learned to respect the power of the water’s choices in its flow.

The stream’s flooding is a phenomenon of nature, and therefore something intrinsically vital to the health of the whole area’s ecosystem.  

To install an artificial device like a dam would surely create something akin to a malignant abscess in a quiet and sacred part of nature.  
 

Please come visit us and let us show you what you can help preserve!

What about the disruption this project will surely have on the quality of the drinking water of NYC’s 18,800,000+ residents??  

NYC enjoys some of the cleanest water in the world, filtered by the very stream this project would invade.  Putting any industrial development between the Big Apple and its nourishment would potentially create havoc.  I wouldn’t envy you if your project ever affects the drinking water of those 18 million people.   

And I, personally, have spent many years in California, the source of the energy group proposing to “develop” our area.

I have seen what their reservoirs have done to the countryside out there.

I have seen where they have destroyed so much of their own ecosystems under the guise of “enlightened energy”.  Not only are their reservoirs of water unnecessary out here on the east coast, where we get rain all year long, they are also detrimental to the natural order.

With the decimation of so many fish species, with the destruction of so much riparian habitat, and with wildfires that will burn into history books, the management of water in California has not worked out well.  Now a California power company wants to bring their model here?   

No, thank you.

I invite you all to come visit us, personally, at Woodland Valley. Please come stay with my family and me*. Let us show you the deep value of this very special place.  You will leave with a brighter heart, I assure you.

After a brief visit, you will not only choose to let it be as it is, you will not want to leave.  We will show you some of the good things of what life can be about. 

With hope and gratitude,

The Walker/Halsted Clan,
1039 Woodland Valley Road
Phoenicia, NY

Please reply to:   
whileiwaswalking@hotmail.com
(917)-509-3288

Julia H Haines, Shokan, NY.
As a resident of the Hamlet of Shokan, in the town of Olivebridge, NY, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. It is incomprehensible to me that this proposal can be made without any prior notification to NY City and town of Olivebirdge officials.

Please do everything in your power to prevent this proposal from moving forward.

Michelle Spark, phoenicia, NY.
P-15056-000DOCKET (NUMBER would not come up.) Proposed Hydro electric power Plant abutting Ashokan Reservoir:
Comment is made by a Catskill resident of 30 years, whose home abuts the confluence of Esopus Creek at the Woodland Valley Stream.  I have witnessed major disruptions on the creek many times during high flow events, which include scouring of stream banks, erosion to home and property, and damage to local roads and bridges.  We all have deep respect for the power of water in a storm event. These streams and valleys have taken water flows for thousands of years, and as such have evolved to a high degree of inter-related dependency. Any major change to these streams will have impacts that cannot be estimated and are not worth the risk to the delicate eco-balance that Catskill and NYS residents have determined to preserve by state law over 100 years ago.
Several points about the plan occur to me: It doesn’t look like a “closed” loop plan but looks to be an “open” loop plan, so I am suggesting that be correctly identified to get the correct name in place. I wonder why there was such a major mis- approbation ?
That being said, in regards to putting a reservoir in the Woodland Valley end, or anywhere located in this watershed region,  I have witnessed the deep micro-environmental interdependence of rain, streams, flooding, habitat with animal and human.  These dependencies have evolved in a protective way ever since the Catskill State Forest Preserve was designated protected “wild” by the NYS laws.  To change that would require a citizen amendment, and most would not agree to that- as all who come here place great value on the size of this precious forest, and nature of this protection.
The nature of rain fall, on deep valley streams made of glacial clay is one of delicate balance. 
The continuity and amount of water that empties into the Esopus, cannot be discounted, and are home and habitat to mallards, salamanders, mink, and turtle and frogs.  These creatures are the pillars of the forest floor and need protection from disrupted surfaces of ther ground in the forest. Massive rain fall runs quickly off the steep sides as creeks rise fast and furious.  Just as quickly going down.  a large area unforested such as a reservoir could disrupt the cloud eco-system and rain fall we are so dependent on.

The amount of disruption will cause more erosion on stream banks, disturbance to habitat for animals, and trout, and threaten human structures of homes, roads and bridges.  Turbidity in the water occurs any time water levels exceed the norm, and therefore impact 9 million in NYC.  Water quality is also of import to local residents who depend on clean water to drink.  Turbidity is of a great concern and is easily stirred up.
I believe this proposed project will have enormous impact on the above relationships causing major change in the balancing of the eco systems involved. 

Cycles of seasons have their own specific times of threat- snow melt, spring run off, dry conditions, and drought.  All these situations cause flooding, fire risk, depletion of food sources for animals and birds, and threat to the stream ecology.  Any large intrusion such as a new reservoir put in the basin between two major mountains and an underground channel will bring about unwanted change such as:
species dislocation, fragmenting of forest canopy thus making it difficult for some bird species to thrive such as wood thrush scarlet tanager.  NYS Audubon designated the Catskills as a mature quality forest, and any fragmentation would destroy that.
Possible opportunities for invasive species to come in could occur with a large reservoir or channel tunneling. This proposed project would invite breaking up one of the most highly preserved un- interrupted forest preserves in NYS and on the Eastern coast.

Eco tourism via outdoor natural recreation like hiking, fishing, and camping has contributed to the local economy. The grand scale of this project is beyond the intimate nature of this economy and will have a negative impact on the local permanent residential economy. When residents need to turn to destruction for economic survival due to loss of tourism, that could be consider a causal effect of such a proposal such as this one. Iurge the complete review of this project especially concerning water quality, fish and bird habitat, and weconomic impacts.
Thank you,
Michelle Spark

Paula Dutcher, Shokan, NY.
As a resident of Olive, I strictly oppose the granting of the permit to Premier Energy Holdings in the case of approving a feasibility study to build a dam and powerhouse in the area. The proposed construction by Premier Energy Holdings will displace and disrupt local residents and destroy the beautiful and thriving natural environment. Furthermore, Turbidity and contaminants will likely taint the drinking water of the millions of residents of New York City, which is provided by the Ashokan Reservoir - the area under scope by Premier Energy Holdings. Please do not approve this permit application.

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Matthew, Phoenicia, NY.
     Hello, I am vehemently opposed to this  project. The impact this would have on these mountains and waters is heartbreaking to consider. I have chosen to live here and  raise my children here because of the access to good water. This project would directly threaten our well being. It is deeply irresponsible and completely unnecessary to be drilling through and constructing on these beautiful life giving mountains. As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I will fight this project tooth and nail. Please do everything in your power to prevent this proposal from moving forward.

Thank you - Matthew O’Neill

elizabeth lawrence, west hurley, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Ann Feddersen, Boiceville, NY.
This project would be a great error. This site and area are pristine woodland and villages. We don’t want any hydro- electric project in this area or anywhere nearby. Plus this is in the New York City watershed. No contamination here.   Perhaps work could be done with a existing electric plants. Do NOT build, tunnel, or cut trees here.

Susan Perrin, Olivebridge, NY.
As a resident of Olive, a town that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I VIGOROUSLY OBJECT to the proposal and request that the Federal Energy Regulatory Commission DENY Premium Energy Holding’s application for a preliminary permit. 
The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. We live here and our land should not be sold for destructive purposes and to profit a company with no ties to this area other than to extract resources. 
PLEASE do everything in your power to prevent this proposal from moving forward.
Thank you.
Regards,
Susan Perrin

John Kurowski, Pine Hill, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Tiffany Barringer, West Shokan, NY.

Hey you, 

In regards to Docket Number P-15056-000, I, Tiffany Barringer, of the hamlet of West Shokan, strongly oppose.

I invite you to take a moment. Let your mind wander to a place nearby that you go to often that brings you peace. Could be your porch, backyard, the woods, a park, the desert, vacation area, anywhere. These spaces exist, everywhere, whether you are in California or New York City. You have one too. Imagine yourself there. Relive the moments, the memories, the feelings. You are happy. Truly happy. 

Now imagine a stranger sneaking in- and destroying it. The very place you love, the memories stored deep in your mind, in your soul. The one place you feel truly happy. 
Gone.  
Now what do you feel?

There are some things that money cannot buy.

Please, I ask that you, whoever you are, take the time to personally reach out and get to know the local people of the area you have plans to affect. This is our home. I truly believe that if we work together, then there is hope that we can all find a way to make everyone happy. 

Feel free to start with me. My e-mail is Tifferz728@gmail.com and I would love to chat anytime. I look forward to hearing from you.  

Thanks.

Nicole Knapp, Kerhonkson, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Karen Lee, Chichester, NY.
I have recently become a full time resident of Chichester, NY, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.  The Catskills is an area of pristine beauty and every effort needs to be taken to preserve what nature has provided to us for generations to come.  It would be an environmental tragedy beyond proportion if a project such as the above project was to proceed.  I absolutely oppose this project.

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Anne Hemenway, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Please save our precious land and water and wildlife.

John Wilson, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Miriam Melnick, Phoenicia, NY.
I live in Woodland Valley, Phoenicia, which is a region that would be flooded and unlivable if this project moves forward. My family has lived here for thirty years and looks forward to loving here for decades more! 

 As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Julie Parisi, Woodstock, NY.
I strongly urge you to deny the permit to Premium Energy Holdings LLC. 

As someone who has lived in Ulster County for my entire life and who spends time walking on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I strongly object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

If this project moves forward, the company would be tearing into the valleys in the towns of Olive and Shandaken, leveling several hamlets, as well as damming streams to create reservoirs. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. It would be extremely harmful to local wildlife as well as the fish and other living creatures in the streams. Please do everything in your power to prevent this proposal from moving forward. 
Thank you.

Anna Craycroft, Bearsville, NY.
I vehemently oppose this permit application and the unnecessary and irreparable environmental damage that it would cause to study the area, not to mention further unnecessary damage - without any local benefit of energy production - if the plan were to eventually go through.

Brett Barry, Chichester, NY.
To whom it may concern: As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams, with increased turbidity in waters serving as the unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Thank you very much, Brett Barry

Donna Cinelli, West Hurley, NY.
As a resident of West Hurley, NY which adjoins the lands of the Ashokan Resevoir that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I strenuously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit (docket #P-15056-000). The area is valued for the natural beauty of its protected woods and streams and infringes on land and water resources managed by the DEP. The proposed project is massive, intrusive, and if constructed, will damage the local economy and character, including lands, roads, streams, and cause increased turbidity in water serving as an unfiltered drinking water source for 9,000,000 people in New York City. 

The location is extremely unsuitable for such a project and I respectfully request that you prevent this proposal from moving forward.

Eve Fox, Woodstock, NY.
Dear FERC,
I'm writing to express my concern about this proposal which would dramatically impact the area in which I live both economically and environmentally. Although I whole heartedly support clean, renewable energy sources this project as roughly outlined does not appear to take into account our existing communities residents, economies or environment, to say nothing of its potential impact on the drinking water provided by the Ashokan Reservoir which accounts for roughly 40% of the drinking water supply of New York City.

Our area has already suffered a great deal to create the Ashokan Reservoir which has left bitter memories for residents of areas that were flooded to make way for this project that benefits New York City.

However, we have also come to appreciate the beauty and recreational (and economic) opportunities created by the Ashokan Reservoir including the new and very popular Ashokan Rail Trail that opened late in 2019 to much local acclaim. Businesses have begun to pop up near its access points and we welcome it as a fitting addition that amplifies our area's reputation for conservation and natural beauty. Although I would be happy to see hydropower utilized, in general, my understanding of this proposal seems like something our region will have to fight. And fight we will... As part of the successful grassroots effort to defeat Niagara Bottling's attempt to privatize water from the nearby Cooper Lake Reservoir in Woodstock a few years ago, I have no doubt that we can scuttle this project.

I encourage you to find other, more suitable locations (ideally using firms that are based in this region and have a strong understanding of potential locations) for a project of this scale.

Sincerely,
Eve Fox

Laura Nordstrom, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. Additionally, our area relies on the beauty of the Catskills not only for our recreation, but our economy. People come here from all over the state, country and world to visit the Catskills. If we allow this natural beauty to be destroyed, our restaurants, ski areas, hotels, small businesses and more will suffer. This plan directly aims to level some towns, but it could also effectively level the entire area with this economic loss. This is our land. These are our mountains and valleys. This is our home.

Cynthia Gleason, Woodstock, NY.
docket number P-15056-000
These lands and waters are sacred to myself and many others!
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you for listening,
Cynthia Gleason

Sara Driver, New York, NY.
As someone a person who enjoys and recreates on the protected lands near the Ashokan Reservoir and the precious Catskill lands of New York State. This proposed  invasion by Premium Energy Holdings is a disaster.. I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. It is not only an environment disaster but a human disaster - destroying communities.. 

Thank you for your attention.
Sara Driver
Stone Ridge NY.12484

Jacqueline Lieske, Cottekill, NY.
I have lived in Saugerties, Woodstock, and now Cottekill all my life. For 36 years I have found solace and joy in the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. No one locally has asked for this work to be done, no one locally wants this work to be done. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for New York City. Please do everything in your power to prevent this proposal from moving forward.

Erin von Holdt-Gilbert, Kingston, NY.
docket number P-15056-000 

As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Mark Hutchins’ Canright, Asbury, NJ.
Greetings! 
As a farmer, business owner and resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you for your time!
Take care, Mark Canright

Lois Canright, Asbury, NJ.
Hi there,
As a concerned citizen and someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you very much, Lois C.

Ellen Parker, Chichester, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Larry Brown, West Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Christian Lynch, Phoenicia, NY.
As a full-time resident of the Woodland Valley in Phoenicia, NY (one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity), I vigorously object to the proposal and request that the Federal Energy Regulatory Commission do everything in its power to deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, expensive and unnecessary.  If allowed to proceed, it will likely destroy or cause irreparable damage to local lands and streams, endanger native wildlife and possibly protected species, require massive road and infrastructural reconstruction while causing increased turbidity in waters serving as an unfiltered drinking water source for more than nine million people in New York City. I strongly oppose the trampling of personal liberty and the flagrant disrespect of private property and public lands and urge the FERC to do everything in its power to prevent this proposal from moving forward.

Laurence Kirby, Woodstock, NY.
I strongly urge that Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit for a hydroelectric project near the Ashokan Reservoir. I reside nearby and frequently use the lands near the reservoir for recreation. A large, intrusive industrial project in the neighborhood would severely affect the quality of life in the area and would be sure to result in pollution and environmental degradation in an area prized for its beauty and cleanness. In turn this could adversely affect the economy of the region which relies on its quality of life, beauty and cleanness to attract visitors and residents. The proposed project is too large for our small rural way of life and economy. Damage to roads and runoff of polluted water would be predictable results, and the quality of new York City's drinking water would be threatened.

Michal Keeley, Fleischmanns, NY.
As someone who hikes and bikes on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I strongly oppose the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holdings' application for a preliminary permit. The proposed project is massive, intrusive and, if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters that provide an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sincerely,
Michal Keeley

Maude Rith, Etna, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Joseph DeSarle, Phoenicia, NY.
As a long-time resident of Woodland Valley in Phoenicia, NY (one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity), I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

I have lived here for 67 years and have been an advocate for maintaining the pristine quality of the land and water in our area.
The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Mary DeSarle, Phoenicia, NY.
As a long-time resident of Woodland Valley in Phoenicia, NY (one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity), I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

I have lived here for 53 years and have been an advocate for maintaining the pristine quality of the land and water in our area. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

alex panagiotopoulos, kingston, NY.
As an Ulster County resident who cares about the environment, don't want solar panels clogging up my community; I want an endless source of carbon-neutral energy that can create permanent jobs, not a revolving door of commission-based panel installation jobs. Please make sure you work as much as possible with people, and be transparent!

Robert B Warren, Phoenicia, NY.
FERC
RE: P-15056-000


March 13th, 2021

To Whom it May Concern,

As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.


Thank you,
Robert Burke Warren
187 High St
Phoenicia, NY 12464
845-901-5746

Rebecca Konjas, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Merry Chellas, Albany, NY.
I have spent summers at our homes in Woodland Valley for 80 years; members of my family have visited there since the late 1800s.  We hope to continue spending time there for many more years. 

I strongly object to the Premium Energy Holdings proposal to use our valley, Phoenicia and the Shandaken township as the site for this massive development to generate electricity.  

The plan, if implemented, will severely damage many properties, as well as the roads, creeks and streams in our area.  It will endanger wildlife in the Catskill Park.  It will create excessive turbidity and endanger New York City's drinking water supply, most of which is unfiltered when it reaches residents.  And with the threat of climate change, it is unclear how such a project would be affected.  

I completely understand that creative solutions are required to meet the need.  However, this proposal has not been thought through and examined carefully.  For example, pumping water uphill apparently takes power in excess of what is generated when the water's direction is reversed. Reservoirs actually produce methane, a process that is not well understood.  The cost is way too high for the benefit realized.

I urge you to do whatever you can to block this unfortunate proposal from proceeding further. 

Thank you.
Merry Morehouse Chellas

Semi Anne Chellas, Los Angeles, CA.
Re P-15056-000 Preliminary Permit re Ashokan

Four generations of my family have spent summers in Woodland Valley in two homes, since the 19th century, and I want to be able to bring my young children and their children there for many summers to come. I am writing to register my profound objections to the Premium Energy Holdings proposal to use our valley, Phoenicia and the Shandaken township as the site for this massive development to generate electricity.  
 
The plan, if implemented, would disrupt and damage many properties, roads, creeks and streams in our area, and endanger the wildlife in the Catskill Park. It will put a dent in tourism in the area and could foment unknown consequences as the climate change. Nine million people in New York City could be affected by endangering the water supply that springs forth from this area. 

This proposal is disingenuous and not fully transparent. For example, pumping water uphill apparently takes power in excess of what is generated when the water's direction is reversed. Reservoirs produce methane, a process that is not well understood. I understand the need for new forms of power but this is not the clean, environmentally-friendly power intended, and the damage to local economies and ecosystems far outweighs potential benefit. 
 
Please do everything in your power to prevent this proposal from go forward.

Anya Ferring, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Selina E Guendel, BOICEVILLE, NY.
Hello, 
My name is Selina and I am a Catskills native. Having grown up and still living near the shores of the Ashokan in Boiceville, I am proud of the natural wonders we have in the town of Olive. This was only recently further highlighted by the new Ashokan Rail Trail. I think it would be a grave mistake and danger to the landscape we all love and the natural beauty that supports many by brining tourism to the area, by allowing Premium Energy to move forward with their Ashokan Pumped Storage Project (docket P-15056). I hope you will consider denying the permit for a feasibility study. This Californian company should have no right to impact and profit off of the landscape without taking into account the impact on those who live and recreate here.
Thank you,
Selina

Luan Jenifer, Willow, NY.
To whom it may concern:

We are deeply concerned about this project permit  application in our community. It was not initiated but the community and appears to an opportunistic land grab by a private company based out of California. 

This permit should not be approved.

Sincerely, 
Luan Jenifer

kathy ruttenberg, Bearsville, NY.
As someone who lives and owns a large acreage in the area as well as recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

kathy Ruttenberg

Eleanor Lundeen, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

This project is an example of over-development in lands that are valued as bucolic and serving the hunting, fishing and recreational interest of millions of people who live and vacation here. 

Funds for a project such as this would be better used to change and improve current energy production plants. Funds would also be better used to improve more efficient use of energy by individual customers. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sheryl Goffman, Woodstock, NY.
As someone who lives nearby and recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Thank you,

Shery Goffman

Rochelle Katz, West Shokan, NY.
I am opposed to Premium Energy installing hydroelectric dams in the West Shokan area. In doing so, it would  compromise and environmentally disrupt the surrounding land. streams and inhabitants.

Alice Beresin, Chichestwe, NY.
Docket P-15056-000

As a resident of Chichester, NY, I am writing to express my opposition to the hydroelectric plant adjacent to the Ashoken Reservoir and request FERC to deny Premiu, Energy Holding's application for a permit. This project will call great harm to our land and water.

Sincerely,

Alice Beresin
44 Cinder Road
Chichester, NY 12416

Imre I. Beke, Stone Ridge, NY.
I am a life long resident of the Mid Hudson Valley area and I am a big fan of this project as presented thus far. I am interested in more information about it, but the idea of using underground structures to use the existing reservoir to produce green hydroponic energy is a great one and very exciting. I would love to see information on how this will be done and for the company to put out information on how the money spent for this project can be funneled into the local economy through using local resources or companies. Overall, a very interesting proposal and a very exciting one. I am in support of the project.

Mike Grundfast, Saugerties, NY.
The Ashokan Reservoir and the Esopus Creek are each special places to me, either fishing in the Esopus, walking or riding the rail trails, it is my favorite place to be.  The beauty of the entire area is amazing. I have rediscovered fly fishing, and feel grateful to have one of the best trout streams in the state so close.  The thought of disrupting the fishing and the area is heart breaking.  I understand clean energy is important, but this is not the place, there is too much at risk.

Thank you, 
Mike

Joseph Spinelli, New York, NY.
To the employees of the FERC who are reviewing this application, let me begin by thanking you for taking the time to allow the home and business owners near the Ashokan Reservoir the opportunity to opine on this matter. I am currently a resident of New York City, but I grew up about a mile from the Ashokan Reservoir, and I currently own a home and business within about a mile of it. That said, my primary income comes from my career in finance in New York City, so I am involved in the energy markets, including the power market to some degree. Although I am not an expert on the electricity market, I do have a reasonable understanding of how it functions, as well as many of the mechanisms that determine pricing. Based on that background, I can only conclude that it would be a tragedy if this project is approved, as it will likely create very little, if any, benefit for local residents. In fact, from the limited data provided regarding the project, it looks like the bulk of the electricity generated will be used to pump water back and forth by the company, and not for the benefit of consumers. Isn't it interesting that Premium Energy Holdings decided to submit this application without ever having discussed it with the State of New York, New York City, or the local residents? All this application says is that a company, with no history, understanding or contribution to the area, has figured out a way to make money off of a venture. This would be distasteful to anyone in any town, but it is particularly obnoxious given the significant amounts of taxpayer money that goes to maintaining the Ashokan Reservoir, and the surrounding land, in order to protect it as a primary source of drinking water for New York City. To the locals, the reservoir is very special, as it a magnificent place that not only benefits millions of residents as a source of drinking water, but also as a wonderful example of how conservation and recreation can work hand-in-hand to protect and celebrate our most precious of natural resources. All of that said, I am not debating the need for innovation, as it is at the core of the US economy. However, let's make innovation make sense. Let's approve projects that are necessary, can have a massively positive impact on society, and let's do so in a way that protects the environment. Why would we destroy forests, the habitats of native species, and deface one of the most beautiful tourist destinations in the entire State of New York in order to move forward with a project that will produce no significant benefit to anyone? Thank you for your time and consideration.

Theresa Widmann, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Jennifer Strickland, Wilmington, DE.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Amy Farges, CHICHESTER, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Taima Smith, Saugerties, NY.
The Ashokan Reservoir and the lands surrounding it are some of the most beautiful places on earth. It is mind boggling that anyone would consider destroying it for financial gain.  As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Maria Georgopoulos, Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Autumn Brookmire, Big Indian, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Seth S. Tannenbaum, Philadelphia, PA.
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE
Room 1A
Washington, D.C. 20426

March 14, 2021

Dear Kimberly D. Bose,

I am writing to express my overwhelming opposition to Premium Energy Holdings’ short-sighted plan to build a hydroelectric plant in the Ashokan Reservoir region of Ulster County.

As my parents and several members of my extended family have indicated in their own comments, our family has owned a house in Woodland Valley for more than 75 years. The house and the valley it sits in are a family heirloom. While we own the house, the valley and its natural and relaxing beauty are accessible to all and are widely utilized. The state campground at the end of Woodland Valley Road, which would become inaccessible if Premium Energy Holdings’ plan comes to fruition, is an affordable way for anyone to enjoy the idyllic mountain air, water, hiking, and fishing in Woodland Valley. It attracts thousands of visitors annually who bring with them a tremendous positive economic impact on the surrounding communities and the businesses that call those communities home. Without those visitors and all of the others who come to rent houses in the valley, those businesses and the economy of Phoenicia and the surrounding communities would suffer tremendously.

Even conducting a study on the feasibility of such a foolish project would cause serious harm to the environment and natural beauty of the region. Building the temporary roads mentioned in Premium Energy Holdings’ filing will create air, noise, and water pollution and damage the environment.

Premium Energy Holdings’ proposal to use eminent domain to seize privately owned land is spurious. They are a private, for-profit entity asking the state to use a provision intended for the public good of all citizens for their own private profit. Moreover, nearly 75% of the power generated by the proposed plant will go to running the plant, leaving very little to supplement the existing power grid.

Even if there is a gain in terms of cheaper or additional energy, which seems far from guaranteed given this proposal, that gain is vastly outweighed by the economic cost in acquiring the privately-owned land, by the negative economic impact on the surrounding communities, by the negative environmental impact of destroying the natural flow of the Woodland Valley Creek, and by destroying and rendering inaccessible one of the most beautiful, tranquil, peaceful places in all of the United States: Woodland Valley, New York.

I urge the FERC to stop the wasteful, unnecessary destruction of Woodland Valley before it begins. Deny Premium Energy Holdings’ proposal before it ruins the lives, liberties, and ability to pursue happiness of the people of the region.

Sincerely,
Seth S. Tannenbaum, Ph.D.

Alanna Steffen, West Lafayette, IN.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Sincerely,
Alanna Steffen

Zach Golden, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Liz de Nesnera, Olivebridge, NY.
Hello,

As a resident of one of the Town of Olive in NY State, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I VIGOROUSLY OBJECT to the proposal, and request that the Federal Energy Regulatory Commission DENY Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams. Not to mention cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 

Please do everything in your power to prevent this proposal from moving forward.

Courtney M. Williams, PhD, Peekskill, NY.
docket number P-15056-000

My name is Courtney Williams. I am a resident of Peekskill, NY, but my family has a camp in Big Indian, NY and frequent in Shandaken and the area around the Ashokan Reservoir.

I strongly object to the Premium Energy Holding's plan to flood more of the area for their project.

Shandaken has already been forever altered by the formation of the Ashokan Reservoir, displacing entire communities to flood them to serve New York City.

This community objects to this project and their wishes should be respected. 

As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

steven moore, Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. The proposal serves only to enrich Holding co at the expense of millions of residents, not to mention indigenous wildlife, of the New York State. Please do everything in your power to prevent this proposal from moving forward.

Victoria Pedersen, Stone Ridge, NY.
As someone who owns a home on the Lower Esopus and recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sincerely,
Victoria Pedersen

JENNIFER L COSTLEY, OLIVEBRIDGE, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Suzanne Giangreco, Phoenicia, NY.
s a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Elaine Fasula, Shokan, NY.
As a resident in the town of Olive for the past 22yrs. I have learned that the proposed hydroelectric project will be installed in our community.
I strongly object to this proposal as it would be an intrusive damage to our local lands, streams and ruin the drinking water source for millions of New Yorkers.
Docket number P-15056-000

Linda Michela, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.  Since my home is less than half a mile from where they propose to put one of their reservoirs, I would imagine the impact to my life would be huge, unless they plan on taking my home under eminent domain, which would be devastating to myself and my family.

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Philip Andelman, Chichester, NY.
Growing up I always dreamed of owning a home that became more than simply a place to live.  I wanted a place to create not just a lifetime of memories for myself but for generations of friends and family.  My family had traveled consistently throughout my childhood and I was always envious of those who had homes in which their parents (or grandparents!) grew up.

When I moved to the Catskills sixteen years ago, I didn’t have the means to achieve this but as I looked around at houses to rent, I was led by a realtor to Stoney Clove Lane.  She explained that a cabin was about to be available.  I couldn’t look inside now as it was occupied, but I could see the exterior. I didn’t even need to.  Simply driving up the road, a chill ran through my body and I realized I had found someplace truly magical.  I agreed to a year lease without ever stepping foot in the cabin.

Within two years I had become dear friends with my neighbors on all three sides.  Across the road was an incredible psychologist from the city who spent her weekends there. To my left, Jeremy Bernstein, born and raised in the Catskills, his father had founded the only private school in Woodstock in the early 60s.  Jeremy went on to become one of my closest friends, best man at my wedding, and eventually built my child his house (but I get ahead of myself).  To my right was Chuck Lankester, a fascinating man who worked in the UN for over forty years, helping shape global environmental policies, including the Kyoto Protocol, portions of which were penned on Stoney Clove Lane!  He had built his home from scratch singlehandedly back in the early seventies, over the course of three years, assisted on weekends by his two teenage daughters.  From cutting down trees to breaking rocks to create the foundation of the driveway, they worked tirelessly on this magical home they dubbed Chalabin: smaller than a chalet, bigger than a cabin.

As Chuck thought of retiring and moving South, I began thinking of marriage.  Before long, I had bought my neighbor’s home, my very first home purchase, and exchanged marital vows on the balcony.  Jeremy worked tirelessly to overhaul the house, and a little over a year later our son Woody was born.  As he got bigger and we started thinking of other children, Chalabin began to feel too small for us.  Jeremy helped us build a second home on the property and unwittingly I was slowly beginning to create the dream property I had yearned for my whole childhood.  

We’ve celebrated birthdays, holidays, anniversaries, and global pandemics in this home.  We've hosted celebrated writers and academics, painters, musicians, and filmmakers.  We’ve endured days without power where my son helped me melt snow to get drinking water, and we’ve installed a swimming pool for days when it’s just too darn hot to head down to the swimming hole.  We’ve made new friends on the road and kept in touch with old ones (Chuck came back last year with his wife and daughter to visit!).  

The idea that this home of mine--and this community which has thrived long before I arrived--is in peril breaks my heart.  It is so rare to find a place this magical, neighbors this loving and caring, a peaceful haven so pure.  Please, I implore you, do not mercilessly destroy this.  

Thank you very much for your understanding.  

Sincerely, 


Philip Nathan Andelman

John Smylie, Gardiner, NY.
Although I live a good deal southwest of the proposed project in Ulster County and am not a directly affected local resident, I write to voice my concerns and objections over the proposals by Premium Energy Holdings which threaten the protected lands near the Ashokan Reservoir and the lands of New York State. This is not an appropriate site for, as I understand the proposal, a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. As a person who often visits the area for its scenic and historic beauty, I strongly object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. This proposal is destructive to our communities and threatening to the role of the reservoir in providing clean drinking water for millions of people. Please take action to prevent this proposal from moving forward.

Bruce Barry, Chichester, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
#2  https://ferconline.ferc.gov/QuickComment.aspx
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Nadine Slowik, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Margaret Bachor, Shokan, NY.
P-15056-000
As a resident of the Town of Olive that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Leslie Gale Dornfeld, West Shokan - Town of Olive, NY.
I am a resident of the Town of Olive, where an application for an underground hydroelectric plant, dam, reservoir, turbine and tunnels as well as other equipment for use in pumped storage and generation of electricity has been made.  I have closely examined information that is available to me.  This proposal would substantially negatively impact my property, affect my access to my house, and negatively affect the land, local streams, and overall quality of the environment in which I live.  I do not believe these impacts could be mitigated in any way.  With construction of this massive and intrusive project, there will likely be increased turbidity in waters serving as an unfiltered drinking water source for 9 million NYC residents.  I vigorously object to this proposed project and hope that you will do everything possible to prevent it from moving forward.

Lisa Luborsky, Mount Tremper, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sarah McKenna, Mount Tremper, NY.
NYC does not need to destroy any other towns up here. People have fled NYC in droves and have come up here. This wasteful construction is not needed.  I will not sacrifice my home for this cause!

Alexander Feinberg, Saugerties, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Elsebeth Thomsen, Accord, NY.

As an Ulster County resident and someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Tobe Carey, Glenford, NY.
I strongly oppose the pumped storage system proposed for the Ashokan Reservoir/Esopus Creek area. It will negatively impact the areas in which it is proposed and as a frequent user of the Ashokan Reservoir for boating and fishing, and the Esopus Creek region for hiking and fishing it will have an undeniable negative impact on the region.

The fact that the application was made without informing local and NY City authorities of the plan before filing for permits indicates that the owners have little or no regard for the local or regional residents. I urge you to deny any permits that they have requested.

Thank you,
Tobe Carey

Kelley Parker, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Samantha citrin, West shokan, NY.
This will uproot my partner and I and the numbers of friends and neighbors who so regularity have concern for tomorrow but one thing we can count on is returning home to our houses in this beautiful, peaceful country- please do not uproot this.  The land in my town is blessed with Firever wild standings and this could also endanger the the nature and animals that are climbing their numbers back in the ecosystem.  There has to be alternatives for renewable energy and we deserve to consider all options, not have our hand forced


As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Blaine Hoekstra, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. 

Docket Number P-15056:000

Barbara Salzman, kerhonkson, NY.
Our propery is on the border between Town of Olive and Town of Rochester. We also border Catskill State Park Land.

This ill-advised and poorly planned proposal does not take into account the impact of residents in the area, displacing many and impacting public lands. While clean energy is important, the impact of this project would cause destruction of habitats as well as impact the whole water system. Residents would bear the burden that this would cause.

This permit should be denied and re-submission should require sound environmental and quality of life impact statements.

Rebecca Hoffman, Big Indian, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

I have bathed in those rivers since I was a child. I meet my neighbors down by the river. I found pollywogs in their shallows. Last year I saw a bald eagle fly over head, 20 feet from me. I have admired the wildflowers on their banks. I am teaching my nieces and nephews to love them, too. This land must remain forever wild. And develop a sustainable energy that does not destroy the environment. Please do the right thing and prevent this project.

Robin Perls-Shultis, Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Jody Bryan, Saugerties, NY.
 P-15056-000

As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Allan Hirsch, Chichester, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Linda Reznick, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Therese Baron, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

rebecca underwood, west shokan, NY.

11 Hanover Meadows
West Shokan, NY 12494
Kimberly D. Bose
Federal Energy Regulatory Commission
888 First St. NE, Room 1A

Washington, D.C. 20426. 
Docket number P-15056-000

March 10, 2021

Dear Ms. Bose, 
I am writing in response to the proposal by Premium Energy Holdings to build a hydroelectric power plant at the Ashokan Reservoir in New York’s Catskill Mountains. 
The Premium Energy Holdings project is ill conceived and unwelcome. As a 25-year resident of Moonhaw Road, one of the proposed access roads for the proposal, I can attest to the problems increasing traffic to this road would present. There is substantial pedestrian activity on our road and, with just the recent increase in FEDEX, UPS and other delivery services brought on by the pandemic, there have been many close calls between pedestrians and cars and these larger trucks. Moonhaw Road is not a wide thoroughfare. Our community will not tolerate a proposal that paints our area as sparcely-populated and defines Moonhaw Road as an “access road”.
I hope FERC will reject this proposal and get behind projects that uplift communities and give green initiatives a good name. In addition to local impact, there are several reasons why this project comes up short on an environmental impact level.
On the local level, the property values and tax revenues of the area could be severely impacted. At a time when people are becoming increasingly educated about the importance of the human impact on our natural surroundings this project will have many vocal opponents. Using terminology drawing on “imminent domain” strategies is irresponsible on the part of Premium Holdings. This community has a long history with regards to the imminent domain invoked to construct the Ashokan reservoir.
The area around the reservoir has been so jealously protected in all my years residing here: every building permit, septic system and construction project is met with scrutiny in an effort to guard against any contamination or mishap befalling the drinking water for New York City. As a community we understand the importance of our stewardship of this resource.
As for its standing as a responsible project to generate green-power, the proposal, as described is an “open-loop” project. This is not a good thing. If it moves forward, it will require the construction of an entirely new reservoir to even function and that water has to be pumped to the upper basin during non-peak hours represents the least practical and most disruptive and inefficient solution to a problem that may not even exist. Early projections by Premium Energy explain that the plant would expend 2/3rd of the energy it produces just to operate. In the process, the fossil fuels required undertake construction and the methane released from the proposed new reservoir have been left out of the proposal.  
The proposed project invites problems which would affect 9.5 million New Yorkers down-state who currently enjoy some of the best unfiltered water in the nation. As I understand it, the existing reservoir has an upper basin designed to catch sediment and keep it from the lower basin. The cycling of water to a third basin can only invite contamination from disturbed sediment. I can say from experience that the taste of New York City drinking water is absolutely affected by even subtle changes to these reservoirs as discussed in a Dec 14 article in Patch (https://patch.com/new-york/new-york-city/tap-water-tasting-funny-nyc-heres-why).
This proposal by Premium Energy Holdings, put forth without prior warning to the affected area or to the city, is not a local project grown out of a community’s needs and demands, it is proposed by a company 3000 miles away prospecting with no understanding of the area’s environmental, historical or economic circumstances.
As FERC advances projects in the interest of alternative energy independence in the days and decades to come, it should support those proposals that feel right and organic and sensible for the affected communities so the nation can get behind this essential move away from fossil fuels. 

Thank you for your time,


Beck Underwood

Pauline Palkovic, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Acacia Ludwig, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Corey McMillan, Phoenicia, NY.
Please accept this comment as my full disapproval of the this permit application.  The planned installation of a dam and reservoir in the Woodland Valley would have devastating consequences for our community.  The planned location is very near my property and would destroy the much valued Woodland Valley landscape.  It would also have many consequences to the wild fishery population of the Woodland Valley Stream that merges with the Esopus Creek nearby thus impacting recreational fishing activities and water management.

Ann Morris, Woodstock, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Please do not let this  proposed plan go through. This will destroy our beautiful environment and will decimate many many people’s lives. People who have lived here for generations, as well as people who have made this their home more recently. Not to mention destroying tourism in this part of the Catskills

Thank you, 

Ann Morris
Woodstock resident

Brent Robison, Mt Tremper, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sara McMillan, Phoenicia, NY.
As a resident of the Woodland Valley area of Shandaken, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

David R Congdon, Phoenicia, NY.
I am a resident of Woodland Valley, which is one of the hamlets under consideration by Premium Energy Holdings as a site for a large dam and reservoir.  Although I would be justified in vigorously objecting to this proposal as a resident whose home and neighborhood would be destroyed if this project is approved, my objections are far wider in scope.

I object to any expense incurred by Federal, State, County or Town governments in consideration of this bizarre and unbelievably misguided proposal.  My objections are on the grounds that it will negatively impact the natural assets that make this area of unique economic, scenic, recreational, and ecological value to New York and the entire Northeast region of the United States.  Here is a list of four assets (out of many more) which are under significant threat by this proposal:
1.  The water supply for 9 million people in the City of New York and surrounding New York counties.
2.  Breeding grounds for native trout species that provide a beneficial environment for the best fly-fishing recreation area in the eastern United States.
3.  The neighboring protected NYS DEC land designated as "forever wild" by Article XIV of the New York State Constitution, which enjoys the highest degree of protection of wild lands in any state.
4.  Local lands, roads, and streams that are a major economic asset supporting the larger Catskills community, and which will suffer irreparable damage.

As a resident whose family first moved to this area in 1810, I add my voice to all those who are calling on the FERC to do everything in its power to prevent this proposal from moving forward.

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Michael E. Spada, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Sincerely,
Michael E. Spada

carol warren, shokan, NY.

As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Other formats

DOCUMENT ACCESSION #: 20210305-5009 FILED DATE: 03/11/2021

Submission Description: (doc-less) Motion to Intervene of NATHAN
DERSHOWITZ under P-15056-000. And submission in opposition to the
instant proposal.

Submission Date:

Filed Date:

3/11/2021

Dockets
-------
P-15056-000
Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Application for Preliminary Permit for Document of Filing
Party/Contacts:

Filing Party
Other Contact (Principal)

------------ -------------------------

NATHAN DERSHOWITZ

Basis for Intervening:
NATHAN DERSHOWITZ seeks to intervene in this proceeding. He is a
landowner in Woodland Valley and if the Woodland Valley site is chosen,
he will no longer have access to his property. Accordingly, Nathan
Dershowitz has a substantial interest in this matter. No other party
represents Nathan Dershowitz, and no other party is authorized to
represent Mr. Dershowitz’s unique interests. For the foregoing reasons,
Mr. Dershowitz respectfully requests that the Federal Energy Regulatory
Commission grant this motion to intervene.

Merits objection.

As I understand the Preliminary Permit application, a private party,
Premium Energy Holding, seeks to secure the federal eminent domain power
to potentially flood a large section of Woodland Valley. The claimed
purpose is to store water to supplement energy needs. The proposal does
not make clear who would own the condemned property. More importantly,
it is unclear as to whether there will be any public benefit from this
project. The proponent is a for-profit entity and will presumably sell
the energy to the city, state or federal Government. Thus, this proposal
is not a standard creation of a reservoir, for a public use or the
public good. It is a private entities effort to make money. The project
will not create additional energy, but by arbitrage, the private company
will make money and may or may not make energy minimally cheaper for the
public. Even if sold at a cheap price the economic benefit to the public
seems disproportionately low, compared to the cost and public harm of
this project. This and other legitimate objections have and will be
raised throughout these proceedings by me and others.

I write now to raise additional constitutional objections. First,
the Fifth Amendment to the Constitution states ‘nor shall private
property be taken for public use, without just compensation.’ By its
terms, the Fifth Amendment does not authorize the taking of state land
by eminent domain. Here, the New York State Constitution Article XIV
makes certain State land forever wild. The State Constitution requires
that certain state land shall not be taken by any corporation, public or
private. To circumvent this provision is a long and timely process,
which very rarely is successful. Some State land in Woodland Valley
would be flooded by this project. The Tenth Amendment provides “[t]he
powers not delegated to the United States by the Constitution, nor
prohibited by it to the States, are reserved to the States respectively,
or to the people.” The issue of whether, even if prior Supreme Court
decisions would allow Federal eminent domain to be used over the
objection of a state for the confiscation of state land, the present
proposal is extremely suspect as a basis for exercising eminent domain
over State land now being used for the public good. The “public use”
requirement of the Fifth Amendment is hard to justify here and the State
Constitutional establishment of the public good of keeping the property
forever wild cannot be ignored. There are serious questions as to
whether the present Supreme Court of the United States would allow this
project to proceed by use of eminent domain. The present composition of
the Court will, I believe, view the Tenth Amendment as being more
significant as applied to the facts of this situation, than prior courts
did in clearer “public use” cases and will defer to the State
Constitutional assertion of the benefit of forever wild land use.

Similarly, using or delegating eminent domain to and for a private party
for the private party’s personal profit—when the actual benefit to the
public is so speculative—raises other constitutional issues. The public
use or benefit does not flow here from the creation of the reservoir. If
there is any public benefit it would come from the private party selling
its energy. Whether that would be a public benefit would depend on what
the parties negotiate in the future. That is too speculative and
variable a bases for asserting a public benefit. The Supreme Court’s
five-to-four decision in _Kelo v. City of New London, 545 U.S.469(2005)_
will, in my view, not be extended by the present members of the Court
for a private-to-private transfer in the present situation. Even if the
flooded property is thereafter owned by the Federal or State Government,
herein a private purpose is afoot. Justice Stevens expressly noted for
the majority that “a one-to-one transfer of property, executed outside
the confines of an integrated development plan, is not presented in this
case. While such an unusual exercise of government power would certainly
raise a suspicion that a private purpose was afoot, the hypothetical
cases posited by petitioners can be confronted if and when they arise.”
The present situation seems to present that open question. Private
property will be taken to allow another private party to make a profit
and the hoped for increase in cheap energy will be in the hands of the
second private party. Equally importantly, the four-member dissent in
_Kelo_ seems to reflect the view of the present majority of the Supreme
Court, more than does the majority opinion in _Kelo_.

My view is that the FERC should evaluate these constitutional issues
before an expensive and extensive expenditure of time and money is
wasted on a project with speculative public benefit and clearly
articulated Constitutional declared harm to public area used extensively
for the public good. Pumped storage hydro plants appear to be an
important part of our goal to use renewable energy. But the present
proposal presents a very bad set of facts upon which to proceed.

Maria Darron, Rochester, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Karen Charman, Shandaken, NY.
As a resident of Shandaken, one of the towns that is being targeted by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I strongly oppose the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit.

The proposed project is completely inappropriate in an area that happens to contain the New York City watershed and the Catskill Park, both public treasures. If constructed, the Premium Energy Holdings project will damage local lands, roads, and streams and increase turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. The construction would also likely harm the character of our rural community.

I am also very alarmed that Premium Holdings didn't notify the New York City Dept. of Environmental Protection before submitting its proposal and feel that the company's remiss does not bode well for harmonious community relations. 

Please do everything in your power to prevent this inappropriate and poorly conceived proposal from moving forward. Thank you.

David A Channon, Shandaken, NY.
Pump storage projects waste more electrcity than they use. Just to balance peaks in demand. Conservation and efficiency programs could achieve the same result without endangering the watershed and lives of millions of people. 

The fact that our federal government could force this project over our objections is why we need a new government.

As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Steve Malloy, Kingston, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you,
Steve Malloy

Jennifer Valentine, Massapequa Park, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Deborah Franklin, Hurley, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Trudy Gerlach, Wyalusing, PA.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you,
Trudy Gerlach

Judith E Fletcher, The Bronx, NY.
Docket number P-15056-000 

I write as someone who cares deeply about the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. I want to vehemently object to the proposal and request that the FERC deny Premium Energy Holding’s application for a preliminary permit. The proposed project would be huge and intrusive.  If permitted to go forward, it would be almost certain to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Mark M Giese, Racine, WI.
I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

This ill-advised proposal for massive construction adjacent to the drinking water reservoir that supplies a portion of the water for nine million people seems totally implausible. Any reasonable ideas about generating hydroelectric from the reservoir system may now become harder to discuss, and local communities, already addressing more pressing issues, are being forced to divert attention to mobilize in opposition.

Please cancel the project.

Thank you.

John Rath, Poughkeepsie, NY.
The Catskills and Ashokan Reservoir are highly valued for their aesthetic and environmental assets. As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Most importantly there are viable alternatives to produce electricity in much less harmful ways, which New York state is actively pursuing. Please do everything in your power to prevent this proposal from moving forward. If you need additional information please feel free to contact me. I look forward to your reply to my request. Thank you.

Tracy, Bronxville, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Clean energy is our future, but there is no future in clean energy that threatens drinking water!

Karen Miller, Guilderland, NY.
docket number P-15056-000
As someone who recreates on and enjoys the beauty of the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary or any permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City, not to mention destroy our wildlife and nature. It is a travesty if they are allowed to come in and destroy this area. Please do everything in your power to prevent this proposal from moving forward.

Anne Huibregtse, Wingdale, NY.
As someone who has recreated on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
 

Denise Shapiro, Selden, NY.
Hello,
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you.

Alan Bonito, Ulster Park, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Alan Bonito

Josh zaloga, Saugerties, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
No project should be constructed with out the buy in of local residents. The history of the reservoir system in this area is drought with controversy since a whole town was flooded to make it. There is on going guessing between residents and Nyc who owns the ashokan reservoir which will create even more mistrust and anger toward the project. This is not needed at any time, let alone after a pandemic and contentious political times.

Lynne Sherbondy, WEST SHOKAN, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sarah Wenk, KINGSTON, NY.
This project, coming out of nowhere, and unasked for by the community, must be stopped immediately. The Hudson Valley's natural resources are not for sale, and certainly not to a company that simply plunks their request down to the FERC without any information or warning to the surrounding region. 

Please do the right thing and stop this project now. It is unnecessary and unwanted.

Thank you,

Sarah Wenk

Elizabeth Smyth, High Falls, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

I am a lifelong resident of the Hudson Valley. I have only lately become aware of this proposed project. I am very concerned and will be following the case closely and spreading the word.

joyce grant, chichester, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. thank you. Joyce Grant

Nick Alba, Phoenicia, NY.
The proposal to flood Woodland Valley is totally preposterous.   I have been a homeowner and resident of this valley for 39 years, and there are more than 200 homes of varying sizes in this historic, picturesque setting, which is habitat to a variety of wildlife, and features a world class trout stream, and well as a NY State campground and access to the most popular trails in the Catskill Mountains which lead to many of our peaks.  
Let's not belabor this ridiculous proposal any longer, and simply withdraw the application.
Thank you.

Dawn Naccarato, Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

William lytle, West Hurley, NY.
I am writing to express my dismay with Premium Energy’s application to create a pumped hydroelectric power station and set of reservoirs in the Catskill Mountain region of New York. This project would displace hundreds if not thousands of residents, and scar the beautiful and crucial wilderness areas of the region. Born and raised outside of Woodstock New York, my life has been endlessly enriched by access to these forever wild places, and they are a core aspect of our regions economy. Also, eminent domain may be an abstract concept to most communities in America, but this area still bears scars from a period of rampant land seizure associated with the construction of the NYC reservoirs a hundred years ago. Plans of this kind touch a nerve here, and I hope that FERC will recognize the substantially negative social, economic and natural impact of these plans before considering approval. Thank you for your time, and your service to our Nation. 

Will Lytle

Nancy Fallon, Shokan, NY.
As a homeowner of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Natasha Geber, Shandaken, NY.
As a resident of Shandaken, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal. I request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Melissa Pierson, Olivebridge, NY.
I am a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity. But more than that, I am a resident of one of the ever-dwindling places on earth where a semblance of wild and natural space still exists. This is where John Burroughs, one of the most important voices in naturalism, first experienced the sanctity of what this project will destroy for all time. I vigorously, vehemently, and to my last breath object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. As the plan is currently drawn, the pipeline will run through my front yard. Thus the most valuable things I have--my home, my environment--will be taken. Please do everything in your power to prevent this proposal from moving forward.

Andrew Watts, Olivebridge, NY.
As a resident of Olive, which is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

January DeBellis, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Nicholas Formont, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Anne Carlton, Willow, NY.
Regarding Docket # P15056-000, Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056: I wish to register my objections to this project:
 
The proposal has very limited benefits (net power supply) vs the cost to the fragile, protected environment of the Catskills Park.

There would be disruption to local families and businesses. 

It was not created in cooperation with state and local government plans for use of the region

There must be other, better ways to capitalize on the flow of water through the NYC water distribution system, such as installing turbines adjacent to the aqueduct. Some parts of the aqueduct are already currently under rehabilitation. Only through consultation with the state and local authorities and utilities could these be explored.

In light of the above this proposal should be rejected based on cost/benefit, prematurity and lack of planning. Please protect the citizens of NY from this invasion and grab of property by an out-of-state private corporation.

Nian Fish, Mt. Tremper, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Catherine Sebastian, Woodstock, NY.
Re: 
P-15056.000
I vigorously object to the project proposal by Premium Energy Holdings. Premium Energy Holdings wants to create an enormous underground hydroelectric plant adjacent to the Ashokan Reservoir. If this project moves forward, the company would be tearing into the valleys in the towns of Olive and Shandaken, leveling several hamlets, as well as damming streams to create reservoirs as part of what is called “pumped storage”  - electricity to be generated using massive water transport tunnels. Tapping into any energy generated would also require massive new high power electric transmission networks. 

Premium Energy Holdings has not reached out to New York City’s Department of Environmental Protection (NYCDEP) or the local municipalities that would be impacted by the project. Transparency has not been at the forefront of this massive undertaking and environmentally detrimental project. 

P-15056-000*.

William R Colagrande, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Isabella Schwartz, Boiceville, NY.
I’m a resident of the Town of Olive and I vigorously oppose the building of an under ground hydroelectric plant. Our fragile ecosystem cannot handle more rape of our precious land. Thank you.
Isabella Schwartz

Radha Stephenson, Olivebridge, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Submission Description: (doc-less) Motion to Intervene of Robert D Drake under P-15056-000.

Submission Date:        3/11/2021 4:32:56 PM

Filed Date:             3/11/2021 4:32:56 PM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Individual                               robertdrake@foxriverholdings.com                                                 

Basis for Intervening:
In having read the Ashokan Pumped Storage Project proposal, it my sense that this project risks both the natural characteristics of this area - namely the Catskills Park protected within the New York State Constitution as "forever wild" - as well as the primary industry of this area - tourism.  

A large hydro-electric dam and accompanying reservoir would not merely push aside hundreds of citizens through the necessary eminent domain seizures, but would fundamentally alter the largest industry in the entire county.  Over $500 million is spent on tourism each year in Ulster County and the largest part of that is directly connected to the mountains and streams that make the Catskills once of the prettiest parts of the country.

While clean energy is always a laudable goal, this project does not provide a sufficient return, or sufficient environmental benefits to offset the loss of an entire town hamlet, the destruction of vast areas of forest, and corresponding destruction of a major section of the local and regional economy.

As a resident of Shandaken, New York, my home and livelihood are intimately connected to the watershed of our region.  In this capacity, I respectfully request that the Federal Energy Regulatory Commission refuse any and all permits associated with this project.

Jacqueline Kellachan, Bearsville, .
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Brian Strenge, West Hurley, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Susan Breslow, Phoenicia, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Other formats

Greg Lara, Brewster, NY.
Docket P-15056-000.

As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Nathalie JAM Andrews, West Shokan, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

sarah st jacques, Barrington, RI.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Kristin Walsh, Nyack, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Heather Crispell, OLIVEBRIDGE, NY.
As a life long resident of the town of Olive, one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City.

I am saddened to think what it would do to the wildlife that calls the protected reservoir property home, there are several nests of Bald Eagles very near the site, in fact the proposed power house would likely be in eye shot of one of the nests.  If the disruption to the town's people is not reason enough surly the danger it would pose to these protected species is.

Please do everything in your power to prevent this proposal from moving forward!!

Wayne E Sygman, Shokan, NY.
Dear Sirs,

As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Thank you.

Dr. Wayne Sygman
Shokan

Christine Saward, Summitville, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Samantha Harvey, Croton, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

James Polson, Bearsville, NY.
As a resident of Woodstock, among the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City, as well as nearby towns that rely on the affected waters for drinking.
Premium Energy is attempting to exploit publicly owned land that was set aside as "forever wild."
Please do everything in your power to prevent this proposal from moving forward.
Thank you.

Charley Trowbridge, Callicoon, NY.
Folks,

Hope this finds all well by you and all yours.

As someone who hikes and fishes on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. 

Please do everything in your power to prevent this proposal from moving forward.

Thanks for your consideration and help.

Julie Kane Brinkmann, Ulster Park, NY.

As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Sincerely,
Julie Kane Brinkmann
Climate Reality Project Leader

Denise owens, Chichester, NY.
As a Twenty Year resident of one of the CHICHESTER, NY that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously OBJECT to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 
We are surviving COVID, Unemployment, Depression, and now the threat of losing our homes when we are trying to get our lives back.  This is cruel.

The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to PREVENT and STOP THIS PROPOSAL FROM MOVING FORWARD. 


Sincerely,
Denise Owens

John Barone, Albany, NY.
As someone who works and recreates in the impacted Towns and on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, expected to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

carolyn patch, ACCORD, NY.
As someone who lives near and recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Viviane Eisenberg Mellen, Bearsville, NY.
As a long time resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.
Thank you for your consideration.

Veronica Newton, Kingston, NY.
As a resident of one of the towns that is being proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward.

Our drinking water is too rare - there are few drinking water systems as pure as these reservoirs. We have to protect them, and this project threatens them. Let's not create a crisis. Please deny all permits and stop this project.

A. Lacey, New York, NY.
Docket number P-15056-000

Hello, I grew up in this area and still love spending time on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity.

I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. 

The proposed project is massive, intrusive, and if constructed, will damage local lands, roads, and streams and will negatively impact everyone living in this area of the Catskills. 

In addition, the increased turbidity in waters serving as an unfiltered drinking water source for the nine million people in New York City will directly impact me, my family, and our greater community here in NYC. 

Please do everything in your power to prevent this proposal from moving forward, thereby protecting the environment and people, both in the Catskill Mountains and NYC.

Jill Bauerle, Brooklyn, NY.
As someone who recreates on the protected lands near the Ashokan Reservoir and the lands of New York State that are proposed by Premium Energy Holdings as a site for a large dam, reservoir, turbine, and tunnels for use in pumped storage and generation of electricity, I vigorously object to the proposal and request that the Federal Energy Regulatory Commission deny Premium Energy Holding’s application for a preliminary permit. The proposed project is massive, intrusive, and if constructed, likely to damage local lands, roads, and streams and to cause increased turbidity in waters serving as an unfiltered drinking water source for nine million people in New York City. Please do everything in your power to prevent this proposal from moving forward. 

Sincerely,

Jill Bauerle

Other formats

Douglas Boyd, Phoenicia, NY.
This is an easy decision. Woodland Valley would seem to be severely devastated by something of this nature. Under no circumstances should any company, less one from out of state, benefit from the destruction of Woodland Valley as we know it.

I vote no.

Other formats

Jill Bressler, Kerhonkson, NY.
I’m writing to express my opposition to Premium Energy’s proposal for a hydroelectric power station at the Ashokan Reservoir. I support sustainable energy. But this project and this company are the antithesis of green power. In other projects in the western United States, their plants have decimated fish species, putting them on the endangered species list. They deliberately target land that has Native American interests. The Sierra Club has opposed their projects after extensive analysis of the environmental impact has shown irreparable damage to the environment and the community. Why would we support this proposal or want it?

We live in a beautiful, pristine community. The Ashokan is central to living here. Please do not grant this company the right to destroy what we hold so dear.

Here are links to two stories about similar projects in Nevada and California.

https://thesheetnews.com/2019/06/28/pumped-action/

https://www.rgj.com/story/opinion/voices/2020/08/20/hydro-power-proposal-pyramid-lake-mirage-anthony-sampson-sr/5619615002/

Gabriella, Tillson, NY.
This site is not only a beautiful ecological site and family area, but it is the first thing you see when driving into catskill park, and is a tourist attraction from all over the Hudson valley. Not only is its image important, but tourist attraction brings in vital income for the surrounding businesses in catskill park. Constructing this hydro power facility would destroy all of these vital points of interest. In addition to have a serious hazardous impact on the surrounding ecology, it simply would not be an effective source of power. I beg you to reconsider this project, for the sake of local residents, local businesses, tourists, and the surrounding environment that is continually being threatened.

Cassidy Kristal-Cohen, High Falls, NY.
I'm a concerned situation, who has lived and grown up around the Ashokan Reservoir. I'm asking the FERC to deny the preliminary permit for Premium Energy Holdings LLC. Even preliminary testing could damage what is an essential ecological resource. Our community, NYC residents, and so many animals/plants depend on this incredible ecosystem. Let's not tamper with it. The benefits are not worth the risks. Thank you.

Mei Zheng, Lanesville, NY.
I question the credibility and qualifications of Victor M. Rojas and Premium Energy Holdings, LLC. Given the significant impact of this project on the local residents and the ecology of the Catskill Forest Preserve, this firm should have at a minimum given a courtesy notice to the key stakeholders - most notably the NYC Department of Environmental Protection and the local municipal governments affected prior to submitting a preliminary application. Premium Energy Holdings has a history of taking a hostile approach to these projects, including in Washoe County, Nevada, Inyo County, California and Walker Lake, Nevada without regard to environmental impact, tribal lands, or even basic feasibility analysis in a changing climate. This company surprises communities with these proposals under the guise of “renewable” energy without material considerations for cost-benefit analysis. There are red flags and severe deficiencies in the application itself. For example, the company states the location of the proposed project is strictly in Ulster County, NY. However, their proposed Stony Clove Reservoir is entirely located in Greene County. Victor M Rojas, a professional engineer swears in his application that the contents of the application are “true to the best of his knowledge or belief”. If he had done even a very basic level of research, he would find that material facts such as the geography upon which his application is based are untrue. This carelessness from the outset is a major red flag as to what other errors and omissions this firm would commit if the project were allowed to progress. 

The Ashokan Reservoir that Victor Rojas proposes to pump water out of serves New York City, the largest city in the United States. This is a valuable resource protected by the NYC DEP and cannot be subject to the fanciful whims and experimentation of a private for profit company on the other side of the country. In recent years, the Ashokan Reservoir has had low water levels due to drought. Pumping water out of the reservoir will further exacerbate this problem due to evaporation. 

The application states that the Ashokan Reservoir water levels will fluctuate by 2 feet during operation of this power plant. This significant water movement not only accelerates evaporation but further disturbs the marine life in the reservoir. The impact is not only limited to the fisheries in the reservoir but the entire food chain. For example, the Ashokan is home to a large population of bald eagles that have made a remarkable comeback in recent years and relies on the fisheries of the Ashokan Reservoir to thrive. This project will undoubtedly have adverse ecological consequences far and wide both during construction and operation. 

Let’s be clear, Premium Energy Holdings has no track record of completing ANY successful projects of this size and scope. Do not indulge Victor M. Rojas and his company in this exercise of pure hubris. 

Let us also not forget the findings in the report submitted to the United States Congress by the Staff of the Federal Energy Regulatory Commission in May 2017 titled “Report on the Pilot Two-Year Hydroelectric Licensing Process for Non-Powered Dams and Closed-Loop Pumped Storage Projects and Recommendations Pursuant to Section 6 of the Hydropower Regulatory Efficiency Act of 2013”. The report clearly outlines to developers the proper characteristics and approach they should take to licensing. 

In terms of design, “the project would not alter existing flow regimes or cause significant impoundment fluctuations; minimal land clearing would be required; and for projects at non-federal dams, the existing structures satisfy the Commission’s Dam Safety Guidelines.” Premium Energy Holdings is seeking to significantly alter the existing flow regimes of the Stony Clove Creek,  impound water over the major New York State highway NY-214, necessitating this highway to be rerouted, and clear hundreds of acres of land in the Catskill Forest Preserve protected as “forever wild” by Article XIV of the NYS Constitution. 

In terms of environmental characteristics, “there are few, or only minor environmental concerns, for example: there would be no significant change to water quality parameters such as dissolved oxygen concentration and temperature; the project would not significantly alter the flow regime at the project site; there would be little or no potential for project effects on migratory fish; and there would be no adverse effects on federally listed species and/or
habitat”. The sites proposed by Premium Energy Holdings have exceptional scenic, recreational, and ecological value according to the NYS DEC. Premium Energy Holdings’ proposed dam construction and up to 13+ miles of tunneling will undoubtedly have both severe immediate and residual adverse environmental consequences. 

In terms of information gathering and consultation, “stakeholders, especially agencies, are consulted early, and frequently during the term of the preliminary permit and pre-filing to identify, and reach a consensus on, appropriate environmental protection, mitigation, and enhancement (PM&E) measures that address project-related impacts. Premium Energy Holdings has made NO effort to notify nor consult the relevant stakeholders including the NYC DEP which owns the lands of the Ashokan Reservoir. 

In summary, Premium Energy Holdings has NO TRACK RECORD of successful projects of this size or scope, has failed to demonstrate the proper characteristics required of such a project, and has failed to take the proper approach to undertaking such a project. Victor Rojas and his firm has further demonstrated a lack of sufficient understanding of the sites based on deficiencies in his application and has repeated these failures in other sites around the country. Based on this, the Federal Energy Regulatory Commission should promptly deny Premium Energy Holdings’ application for a Preliminary Permit for the Ashokan Pumped Storage Project.

Sophia Sagan, Poughkeepsie, NY.
I do not support this and I do not want the resovoir  to be used as a lower pool for this project. This will harm the ecosystem and the environment that locals have worked so hard to protect. Do not approve this project.

Clare Nissen, Hurley, NY.
Hi, I live in an area near the Ashokan Reservoir and I wanted to submit a comment about the proposed pumped storage facility. Supporting renewable energy is a good thing! but I am concerned about any unintended consequences.
The surveying and construction would obviously disrupt the land and wildlife of the area, so it needs to be determined whether that will all be worth it. The project should be sustainable and efficient while not significantly disrupting the landscape, wildlife, and community of the area. The local residents should also be involved in the process, and make sure the project will benefit the local community in the long term. And if not, alternative projects should be considered. 
Thank you.

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Submission Description: (doc-less) Motion to Intervene of City of New York under P-15056-000.

Submission Date:        3/4/2021 5:07:42 PM

Filed Date:             3/5/2021 8:30:00 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
City of New York, New York               klang@couchwhite.com                                                             

Basis for Intervening:
The City of New York (“City”) seeks to intervene in this proceeding on its own behalf and on behalf of the nine million people who rely on a daily basis on the City’s water supply system.  The City owns the Ashokan Reservoir, which comprises a large part of the proposed pump storage facility and is an important component of the City’s water supply system.  The City uses the Ashokan Reservoir to supply approximately 40% of the daily water supply needs of its approximately nine million customers.  The outcome of this proceeding could have a direct and significant impact on the City’s water supply system and its ability to serve its customers’ needs.  Accordingly, the City has a substantial interest in this matter.  No other party represents the City’s interests, and no other party reasonably could do so.  The City’s participation in this proceeding is therefore essential to ensure that the interests and concerns of the City and its constituents and customers are heard by the Commission.  The City also submits that its participation will help to advance the public interest.  For the forgoing reasons, the City respectfully requests that the Federal Energy Regulatory Commission grant this motion to intervene.

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Allison Garskof, Saugerties, NY.
I am writing regarding the Premium Energy Holdings LLC Preliminary Permit Application for a Pump Storage Facility utilizing the Ashokan Reservoir. This plan, and it’s feasibility study, would do irreparable damage to our local ecological systems. The Woodstock and surrounding communities want to preserve what brought us to these areas- the beautiful natural environment of the Hudson Valley. I implore you to deny this project before it starts. The ecological health of our forests and waterways are more important to us than ever- and we will continue to fight to preserve them. Please help us protect our home. Thank you.

Sequoia, High Falls, NY.
Some studies suggest hydropower may not be as harmless to the environment as fossil fuels. If hydropower is not more effective as a power source, and even the preliminary tests to see how viable a pump is at the Ashokan reservoir will screw up the ecology here, I suggest it will be detrimental to the community, and that the local government should not allow this to happen in a place that emphasizes preservation of the land.

Wendy Simon, Margaretville, NY.
I do not believe it would be in the area's best interest to grant this permit. If approved, the proposed project would cause ecological damage to the forests, streams, and wildlife in the area.  The permit would allow for the destruction of trees and for the construction of roads, as well as the use of explosives.  In my opinion, the risks will greatly outweigh any benefit.  We need to be especially wary and careful these days where the environment is concerned.  This project will be severely detrimental.

John Mickelson, West Hurley, NY.
Given the paucity of information and (intentional?)lack of spatial specificity as to exactly what the agency's proposal is or might be, it is difficult to fully assess the potential impacts that such an outrageous and seeming poorly planed project might have (what type of idiots do they think their pitching to, to suggest that the development they propose could be done for $5mil?!!!). But intentionally disturbing the NYC water supply by such a shabby group (as evidenced by simple Google searches, showing they've earned the title of "whack-a-dam"), with such a poor reputation across the country, for attempting, willy-nilly, to insert the very same type of for-cash scam, alone seems like sufficient reason to deny any further progress of the proposal. As an earth scientist with a graduate degree and 20+ years experience, I'd immediately be greatly concerned about the potential negative impacts and disturbance of the NYC impoundments and infrastructure caused by the apparent proposed penetration of associated ground water systems and surrounding surficial and bedrock geological underpinnings. 

This apparently foreign, for-profit corporation seeking to derive shareholder benefits at the expense and great risk to the NYC DEP and millions of NYC residents must be turned back. Or at the very least be required to conduct a *full* NYS SEQRA impact assessment, accompanied by full public hearings and reviews, before being allowed one inch of forward motion.

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Robert S. Tannenbaum, Lexington, KY.
Opposition to Premium Energy’s Proposed Underground Power Station

To:  Federal Energy Regulatory Commission
From:  Robert S. Tannenbaum, 2414 Lake Park Road #2108, Lexington, KY 40502 and
				       848 Woodland Valley Road, Phoenicia, NY 12464
Re:  Docket number P-15056-000


I am unequivocally opposed to the underground power station proposed by Premium Energy of California.

I and all the other individuals or entities who might be affected have received no notice of the proposal by Premium Energy of California to create an underground power station at the Ashokan Reservoir in Ulster County, NY.  The proposal would also entail a new dam at one of three sites upstream from the reservoir and the consequent destructive flooding of an existing valley.  Our only notice is an article in the Kingston (NY) Daily Freeman ( https://www.dailyfreeman.com/news/local-news/underground-power-station-proposed-on-ashokan-reservoir-property/article_5c328780-72f0-11eb-a379-8bdd4a547ba5.htm), which notes that the City of New York Department of Environmental Protection also was never notified.

The proposed plant appears to be strikingly inefficient.  Only about 25% of the electricity it would generate (800 of the 2,800 megawatts) would be available to the grid.  The remaining 75% would be used to operate the plant.  Furthermore, there was no evidence provided that these 800 megawatts are required or that they were unavailable from other existing sources.  

I am not qualified to argue the engineering failings of the proposed plant, although they do appear to be numerous.  However, I can emphatically argue against it on practical, aesthetic, and personal grounds.

In order to create this inefficient and unnecessary plant, the article indicates that one of the possible dam sites for an “upper reservoir” is in the “Woodland Valley, near Muddy Brook Road.”   A dam at that location would destroy one of the most beautiful, historic, and peaceful streams and valleys in the Catskills.

The Woodland Valley and the Woodland Creek that created it were a favorite of the famous naturalist John Burroughs.  He often hiked there in the late nineteenth and early twentieth centuries.  He wrote about it in various of his books, most notably when telling of his climbing of Slide Mountain and then descending into the Valley.  His love of the Valley for its natural beauty was shared by many others in the nineteenth and twentieth centuries who made it their home (seasonal or year-round), including painters, musicians, and those who loved and appreciated nature.

My parents were among those who fell in love with the Valley.  More than seventy-five years ago, in 1945, they purchased one of the oldest farm houses in the Valley. We believe that it is the second oldest home still standing.  We know that our house was in existence during the Crimean War (1853-56), because newspaper clippings with dispatches from that war were used as insulation in some of the walls.  Growing up, I spent all of my summers there, wading, swimming, and fishing in the Woodland Creek.  Both of my sons and both of my grandsons also waded, swam, and fished there.  I hope that someday my great grandchildren will be able to do the same.  

However, if Premium Energy is allowed to build its dam, my dreams for my progeny and the dreams of all of my neighbors will never materialize.  Our house may be inaccessible and the Woodland Creek will be forever altered.  The Valley is a thriving community with hundreds of homes, a State Park, and hiking trails that are used by people from all over the eastern United States.  All of this will be obliterated.

In addition, destruction of the Woodland Valley would certainly have an enormous negative economic impact on the surrounding communities, especially the Village of Phoenicia, just a mile from the head of the Valley and home to a renowned annual vocal music festival.  The resultant loss of thousands of annual tourists and hikers, in addition to all of the homeowners, could be devastating to the economy of that village (and the others within a ten-mile radius) that are dependent on both local and transient business.  

I can find no possible excuse (except, perhaps, stockholder profits) for the wanton destruction of such a natural wonder as the Woodland Valley and its Creek.  The same can certainly be said for the two other suggested sites for the “upper reservoir.”  

I am in favor of making maximum use of environmentally-friendly sources of power, such as solar, wind, and hydroelectric.  However, I am never in favor of such sources if they damage or destroy natural beauty or existing communities.  For example, I am delighted that we have no huge wind turbines high on the mountains in the Catskill Park, even though they might generate a significant amount of electricity.  The tops of our mountains are to be “forever wild,” as dictated by the Constitution of New York State.  The same should be the case for our valleys.  They must never be wantonly flooded and destroyed for the sake of a (relatively) small amount of power and the profits of some non-resident stockholders.

We are facing just another example of the demolition of the environment in the name of energy.  This threat is analogous to what has happened in eastern Kentucky and West Virginia with the destruction of the mountains through mountain top removal coal mining.  What has been lost there can never be retrieved or replaced.  We must not let the same devastation occur in the valleys of the Catskills.

I urge the Commission in the strongest possible terms to reject this proposal and never let the project proceed.

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Matthew McMahon, Long Eddy, NY.
Dear FERC,

Smart renewable energy initiatives are critical to our country’s long term future stability. I support novel strategies on how we shift away from fossil fuels using hydro, wind, tidal, solar, and even nuclear to become energy independent as a country.

The Ashokan reservoir watershed is not a warranted place for a large scale hydro-battery type project. The proposal put forth by Premium Energy Holdings for the Ashokan PSP is nothing short of ludicrous to see  in 2021. Habitat, residences, history, recreation, geology will be disrupted in a NYC drinking water zone.  

From reporting on the subject,  it seems that the impacted communities and counties and even NYC were not advised that someone was paying for this study and application to take place. If this is the public rollout of this radical proposal,, what does that say about the motives of the company and funded behind it - or their ability to take on something as complex as what is being proposed. 

As a New York resident and someone who already lives down stream of the effects of the western Catskills Delaware reservoirs Please do not advance this proposal.

Matthew McMahon

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Carl Tannenbaum, Philadelphia, PA.
 Kimberly D. Bose
 Federal Energy Regulatory Commission
 888 First St. NE 
Room 1A
Washington, D.C. 20426. 

Dear Ms. Bose

This is a filing concerning docket # P-15056-000.

My family has had a home in the Woodland Valley near Phoenicia, NY for 75 years. It is one of the most beautiful places on earth. Please do not allow Premium Energy to destroy this piece of paradise with an unnecessary power plant reservoir. Let Premium Energy make (or lose) their money someplace else. The plan to make a reservoir in the Woodland Valley would not only destroy our homestead but would desecrate an area of spectacular natural beauty. It must not be allowed to happen. Do not let the bulldozers into our valley. Be proactive! Stop Premium Energy now.

Thank you.

Sincerely,

Carl & Sabina Tannenbaum
848 Woodland Valley Rd.
Phoenicia, NY 12464

Stephane Sesquin, Phoenicia, NY.
Hi,

I have a property with woodland valley creek access as part of my lot.
I object to the project of using Woodland Valley as a smaller reservoir for the Ashokan Reservoir.
I would not be able to live on my property and your project would endanger the life of animals of the state land adjacent to my property.

Please showcase that you have made a study on economical impact and natural impact of such project.

Regards,
Stephane Sesquin.

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Ira S Rubenstein, Arlington, VA.
To whom it may concern,

I OPPOSE this project. My family has owned a home on Woodland Valley for over 100 years.  Built by my Great Grandfather.  I go every summer for the past 40 years to visit.  I have seen first hand how delicate the balance is on Woodland Creek between normal and floods.  A simple search would show you the damage that was done in the last major flood.  With climate change a fact and expecting more severe weather, we should NOT be changing anything with the water around Woodland Valley.  

It is a fact that Hydro-Power plants are more damaging to the environment than Wind or Solar.   We should be looking into those solutions and not something like this.   A tunnel?  Connecting Water?  A new dam?  In an area prone to flooding?  This is a disaster in the making.   Causing damage to property and the plants and animals that live in the area.  

Do not approve this project.   It will have lasting negative impact to a beautiful natural habitat that should be protected and not destroyed.   

Thank you,

Ira Rubenstein

Elizabeth O’Grady, Phoenicia, NY.
I am adamantly opposed to the possibility of Premium Energy, a California company, installing hydroelectric dams in the Woodland Valley Phoenicia area. It is my determination to make sure that the Valley is not compromised in any manner and not exploited or destroyed for commercial or any other interests.

Roger N Strickland, Phoenicia, NY.
Daming Woodland valley to create an upper pool would disrupt more citizens than it would serve. 

As a Chemical Engineer, I am currently collecting facts to quantify the damage the upper pool would create versus the benefit of power generation. 

Our team, located in the Wool\dand Valley, will submit additional comments once we have more information.

At first glance, the proposal is reckless and poorly thought through.

Stephen Ruehle, Poughkeepsie, NY.
FERC P-15056-000 Ashokan Pumped Storage project proposed by Premium Energy Holdings

I am a landowner downstream of the proposed Stony Clove Reservoir. I have three areas of concern with this project.

First, the Stony Clove Creek has experienced four (4) 100 year floods in the past 10 years. These floods have reached a discharge rate of just under 20,000 cubic feet per second. The proposed reservoir will consist of a 212 high  2,618 foot long dam holding over 950 million cubic feet of water. Any failure of this dam will be catastrophic to the hamlets of Lanesville, Chichecter, and Phoenicia along the Stony Clove. It would also impact hamlets of Mt Tremper and Boiceville on the Esopus Creek.

Second, a 13.9 mile 34 foot diameter tunnel is proposed to connect the proposed reservoir to the power generating station. The proposal does not state how deep underground this tunnel will be placed. The tunnel corridor runs through the hamlets of Lanesville, Chichecter, Phoenicia, Mt Tremper, and Boiceville. The wells for the hunderds of properties needs to be considered. Will the tunnel cut through existing wells? Will the tunnel construction damage the aquifer that supplies these wells? What mitigation plans will protect the water supply to these properties?

Third, this project contains an unprecedented amount of construction within the New York City watershed. Not only will dams and tunnels need to be created, but also town roads and NY State Route 214 will need to be relocated to make room for the proposed reservoir. The proposal implies that the Stony Clove reservoir would be on state lands. However a closer look at the details reveals the reservoir would be located just above Lanseville on private land and that NY Route 214 would have to be relocated up the mountain onto state lands that are designate wilderness within the Catskill Park.

This project has a limited benefit for the general public. It will only generate a net 800 mw to be offered to the New York electrical grid. Yet the project imposes a large negative impact on local property owners in terms of long term flood risk and risk to drinking water supply.

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Submission Description: (doc-less) Motion to Intervene of Town of Olive under P-15056-000.

Submission Date:        2/26/2021 10:53:18 AM

Filed Date:             2/26/2021 10:53:18 AM

Dockets
-------
P-15056-000          Application for Preliminary Permit for Document of Premium Energy Holdings, LLC Ashokan PSP under P-15056.

Filing Party/Contacts:

Filing Party                             Signer (Representative)                  Other Contact (Principal)               
------------                             -----------------------                  -------------------------               
Town of Olive                            olivesupervisor@gmail.com                                                        

Basis for Intervening:
Town of Olive
Jim Sofranko, Supervisor
PO Box 180
West Shokan, NY  12494
845-657-8118 x 4
olivesupervisor@gmail.com


MOTION TO INTERVENE:  PROJECT P-15056 ASHOKAN PUMPED STORAGE PROJECT


February 26, 2021


Ms. Kimberly Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE
Washington DC 20426


Dear Secretary Bose:

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR Section 385.314) the Town of Olive, Ulster County New York hereby petitions the Federal Energy Regulatory Commission to grant it full party status in the above-captioned proceeding. The persons to whom communications should be addressed and to whom service should be made are as follows:

Town of Olive - Supervisor			Town of Olive - Deputy Supervisor
Jim Sofranko 					Drew Boggess
PO Box 180					PO Box 180
West Shokan, NY 12494			        West Shokan, NY 12494
olivesupervisor@gmail.com			dboggesstownofolive@gmail.com


As grounds for this Motion, the Town of Olive, Ulster County, New York states as follows: 

The Town of Olive has a vital interest in the Preliminary Permit application submitted to the Commission by Premium Energy for the Ashokan Pumped Storage Project (P-15056).  The Town of Olive seeks to become a party to this proceeding to ensure the public interests of our residents are adequately represented. Much of the infrastructure for the proposed project lies within the political boundaries of the town including the west basin of the Ashokan Reservoir, the proposed locations of the Ashokan Switchyard, powerhouse, and transmission lines.  
Neither disruption to the proceedings nor any additional burden to any party will result from the granting of this Motion.  In light of the foregoing, the Town of Olive respectfully petitions for intervention.


Sincerely,


Jim Sofranko



Supervisor
Town of Olive

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ann tomasino, Saugerties, NY.
I am writing regarding the Ashokan Reservoir plans to build a hydro plant.  first of all, I would not want to drink water that was residing above a hydro plant, I would imagine there are risk with this.  Secondly, these projects sometime fail and the risk to the local environment, ecological systems would be devastating as well as having no water for NYC residents.  
Im sure there must be a healthier, less toxic way of creating energy...solar, wind power as it is very windy up here.  Im sure an architect could draw up a simple plan of covering the wind power so that they don't ice up like they did in Texas.  
I personally feel as if the government just randomly makes decisions not taking all into account of the devastation if there is an accident.  I guess if you don't live here, you don't care.
Just my two cents,
Thanks,
Ann

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NEW YORK STATE COUNCIL OF TROUT UNLIMITED

  7 Helen Street

  Plattsburgh NY 12901

  21 February 2021

  wellman1985@gmail.com

MOTION TO INTERVENE: PROJECT P-15056 ASHOKAN PUMPED STORAGE PROJECT

Ms. Kimberly Bose, Secretary

Federal Energy Regulatory Commission

888 First Street NE

Washington DC 20426

Dear Secretary Bose:

Pursuant to Rule 214 of the Rules, Practices and Procedures (18 CFR
Section 385.314) the New York State Council of Trout Unlimited hereby
petitions the Federal Energy Regulatory Commission to grant it full
party status in the above -captioned proceeding. The persons to whom
communications should be addressed and to whom service should be made
are as follows:

William H. Wellman Ron Urban

7 Helen Street P O Box 815

Plattsburgh NY 12901 Port Ewen NY 12466

wellman1985@gmail.com ronsgonefishing@aol.com

Ted Hoover

22 Autumn Knoll

New Paltz NY 12561

thoover@hvc.rr.com

As grounds for this Motion, the New York State Council of Trout
Unlimited (NYSCTU) states as follows: The New York State Council of
Trout Unlimited consists of 35 Chapters and approximately 8000 members
across New York State. Trout Unlimited has a vital interest in the
preservation of America’s fisheries and their habitat. The Council is a
frequent intervener in matters of this nature and is known to provide
sound advice to all parties.

Members of the New York State Council are residents of and anglers in
the waters impacted by this proposed project. Ashokan Reservoir and its
surrounding waters are noted cold water fisheries, and Trout Unlimited
has a special interest in their preservation.

Thus, no other party can represent Trout Unlimited’s interest in this
matter.

Neither disruption to the proceedings nor any additional burden to any
party will result from the granting of this Motion. In light of the
foregoing, the New York State Council of Trout Unlimited respectfully
petitions for intervention.

Sincerely,

/s/

William H. Wellman, Hydro Chairman, New York State Council of Trout
Unlimited

Ecc: Service List

NYSCTU: Urban, Hoover, Miller, Charette

NYS DEC: Hogan

US FWS: Wiley

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UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

  ------------------------------ ------------- -----------
  Premium Energy Holdings, LLC   Project No.   15056-000
  ------------------------------ ------------- -----------

NOTICE OF PRELIMINARY PERMIT APPLICATION ACCEPTED FOR FILING AND
SOLICITING COMMENTS, MOTIONS TO INTERVENE, AND COMPETING APPLICATIONS

(February 11, 2020)

On November 19, 2020, Premium Energy Holdings, LLC, filed an application
for a preliminary permit, pursuant to section 4(f) of the Federal Power
Act (FPA), proposing to study the feasibility of the Ashokan Pumped
Storage Project to be located 14 miles west of the City of Kingston in
Ulster County, New York. The sole purpose of a preliminary permit, if
issued, is to grant the permit holder priority to file a license
application during the permit term. A preliminary permit does not
authorize the permit holder to perform any land-disturbing activities or
otherwise enter upon lands or waters owned by others without the owners’
express permission.

The proposed project would consist of the following: (1) a new
2,618-foot-long, 212-foot-high roller-compacted concrete dam for the
upper reservoir for alternative 1 (Stony Clove Reservoir) with a surface
area of 245 acres and a storage capacity 22,496 acre-feet at a surface
elevation of 1,500 feet above mean sea level (msl); (2) a new
2,736-foot-long, 232-foot-high roller-compacted concrete dam for the
upper reservoir for alternative 2 (Woodland Reservoir) with a surface
area of 313 acres and a storage capacity 26,231 acre-feet at a surface
elevation of 1,210 feet msl; (3) a new 2,527-foot-long, 304-foot-high
roller-compacted concrete dam for the upper reservoir for alternative 3
(Wittenberg Reservoir) with a surface area of 226 acres and a storage
capacity 25,558 acre-feet at a surface elevation of 1,180 feet msl; (4)
the existing Ashokan Reservoir for the lower reservoir with a surface
area of 8,300 acres and a storage capacity of 382,358 acre-feet at a
surface elevation of 585 feet msl; (5) new 13.99-mile-long tunnels,
shafts, and penstocks for alternative 1 connecting the upper and lower
reservoirs; (6) new 11.58-mile-long tunnels, shafts, and penstocks for
alternative 2 connecting the upper and lower reservoirs; (7) new
3.81-mile-long tunnels, shafts, and penstocks for alternative 3
connecting the upper and lower reservoirs; (8) a new 500-foot-long,
125-foot-wide, 150-foot-high underground reinforced-concrete powerhouse
containing five turbine-generator units with a total rated capacity of
800 megawatts; (9) a 17.3-mile-long, 230-kilovolt new transmission line
for alternatives 1 and 2 from the proposed Ashokan switchyard to the
existing Hurley avenue substation; (10) a 12.9-mile-long, 230-kilovolt
new transmission line for alternative 3 from the proposed Ashokan
switchyard to the existing Hurley avenue substation; and (11)
appurtenant facilities. The proposed project would have a maximum annual
generation of 2,700 gigawatt-hours.

Applicant Contact: Victor M. Rojas, Premium Energy Holdings, LLC, 355
South Lemon Avenue, Suite A, Walnut, CA 91789; phone: 909-595-5314.

FERC Contact: Woohee Choi; phone: (202) 502-6336.

Deadline for filing comments, motions to intervene, competing
applications (without notices of intent), or notices of intent to file
competing applications: 60 days from the issuance of this notice.
Competing applications and notices of intent must meet the requirements
of 18 CFR 4.36.

The Commission strongly encourages electronic filing. Please file
comments, motions to intervene, notices of intent, and competing
applications using the Commission’s eFiling system at
https://ferconline.ferc.gov/eFiling.aspx. Commenters can submit brief
comments up to 6,000 characters, without prior registration, using the
eComment system at https://ferconline.ferc.gov/QuickComment.aspx. You
must include your name and contact information at the end of your
comments. For assistance, please contact FERC Online Support. IN LIEU OF
ELECTRONIC FILING, you may submit a paper copy. Submissions 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. Submissions sent via any other carrier must be
addressed to: Kimberly D. Bose, Secretary, Federal Energy Regulatory
Commission, 12225 Wilkins Avenue, Rockville, Maryland 20852. THE FIRST
PAGE OF ANY FILING SHOULD INCLUDE DOCKET NUMBER P-15056-000.

More information about this project, including a copy of the
application, can be viewed or printed on the "eLibrary" link of the
Commission's website at http://www.ferc.gov/docs-filing/elibrary.asp.
Enter the docket number (P-15056) in the docket number field to access
the document. For assistance, contact FERC Online Support.

Kimberly D. Bose,

Secretary.

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