Catskill Preservation Comments


Other formats

Disclaimer: A lot of these TIF files are corrupt.

Town of Saugerties submits response to the Preliminary Permit application for the Ashokan Pumped Storage Project under P-15056.
click here to view.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Violet Streich under P-15056.
click here to view.
click here to download.
Comments of Walter F Vines under P-15056.
click here to view.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Michael Kudish under P-15056.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Dr. Adeline Basil under P-15056.
click here to download.
Comments Gayle Walsh under P-15056.
click here to download.
Comments of Joseph N. Raguzin under P-15056.
click here to view.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Mickey & Mo Winograd re the Ashokan Pumped Storage Project under P-15056.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Mountain Top Progressive re the Ashokan Reservoir Pumped Storage under P-15056.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Dakin W. Morehouse re the Ashokan Pumped Storage Project under P-15056.
click here to view.
click here to download.
Comments of Lori J. Moroso under P-15056.
click here to download.
Comments of Sandra S. Scheuar under P-15056.
click here to download.
Comments of Sara Ansari re the Ashokan Pumped Storage Project under P-15056.
click here to download.
Comments of Cynthia Moutsinas under P-15056.
click here to download.
Comments of the County of Greene, New York under P-15056.
click here to download.
Comments of Martha Steuding re the Ashokan Pumped Storage Project under P-15056.
click here to view.
click here to download.
Comments of Kareu Moller under P-15056.
click here to view.
click here to download.
Comments of Frank Romano under P-15056.
click here to view.
click here to download.
Comments of Debra Tomkowid under P-15056.
click here to view.
click here to download.
Comments of Kimberly Daley under P-15056.
click here to download.
Comments of Katherine Burger under P-15056.
click here to download.
Comments of Valerie Griffin re the Ashokan Pumped Storage under P-15056.
click here to view.
click here to download.
Comments of Mary Kelly under P-15056.
click here to download.
Comments of Barbara Prete re the Ashokan Pumped Storage under P-15056.
click here to download.

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Robert Kluthe under P-15056.
click here to download.
Comments of Vida Nathanson under P-15056.
click here to view.
click here to download.
Comments of Irina Belenkaya under P-15056.
click here to download.
Comments of Michael Koval under P-15056.
click here to download.
Comments of Leonard Lerner under P-15056.
click here to view.
click here to download.
Comments of Ellen Lerner under P-15056.
click here to download.
Comment of Stuart Felberg under P-15056.
click here to download.

Comments of Joelle Chorny under P-15056. Submission Date: 4/14/2021
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

Comments of Karena Louise Cronin under P-15056. Submission Date: 4/14/2021
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

Other formats

Disclaimer: A lot of these TIF files are corrupt.

Comments of Town of Hurley under P-15056.
click here to view.
click here to download.

Comments of Linda Yassky under P-15056. Submission Date: 4/12/2021
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.

Comments of Kevin Scisorek under P-15056. Submission Date: 4/12/2021
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.

Comments of David Kearford under P-15056. Submission Date: 4/12/2021
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

Comments of Joshua Frank under P-15056. Submission Date: 4/12/2021
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)

Comments of Juliette Mapp under P-15056. Submission Date: 4/12/2021
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

Comments of Monica Compton under P-15056. Submission Date: 4/12/2021
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.

Comments of Drew Stuart under P-15056. Submission Date: 4/12/2021
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.

Comments of Benjamin Cannon under P-15056. Submission Date: 4/12/2021
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

Comments of Steven J. Calinda under P-15056. Submission Date: 4/12/2021
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

Comments of Matthew Furlong under P-15056. Submission Date: 4/12/2021
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

Comments of Kara Borbely under P-15056. Submission Date: 4/12/2021
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

Comments of Cristine S Riedel under P-15056. Submission Date: 4/12/2021
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

Comments of Elizabeth Ryan under P-15056. Submission Date: 4/12/2021
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

Comments of Ryan Ross Smith under P-15056. Submission Date: 4/12/2021
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

Comments of Lester Burg under P-15056. Submission Date: 4/12/2021
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

Comments of Russell Martin under P-15056. Submission Date: 4/12/2021
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

Comments of Erik Marschall under P-15056. Submission Date: 4/12/2021
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.

Comments of Katie Peterson under P-15056. Submission Date: 4/12/2021
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

Comments of Stephen Nash-Webber under P-15056. Submission Date: 4/12/2021
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

Comments of Linda Yassky under P-15056. Submission Date: 4/12/2021
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

Comments of Linda Yassky under P-15056. Submission Date: 4/12/2021
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

Comments of Stephen Sanchez under P-15056. Submission Date: 4/12/2021
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

Comments of Josh Olsen under P-15056. Submission Date: 4/12/2021
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.

Comments of Jason Kachadourian under P-15056. Submission Date: 4/12/2021
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

Comments of Christina Pisarik under P-15056. Submission Date: 4/12/2021
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

Comments of Jennifer Ascosi under P-15056. Submission Date: 4/12/2021
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.

Comments of Blake DeLanney under under P-15056. Submission Date: 4/12/2021
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.

Comments of Fara Warner under P-15056. Submission Date: 4/12/2021
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

Comments of Michael Segura under P-15056. Submission Date: 4/12/2021
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.

Comments of Arden Sherman under P-15056. Submission Date: 4/12/2021
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

Comments of Miriam Marschall under P-15056. Submission Date: 4/12/2021
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.

Comments of Caleb Thomas Frank iunder P-15056. Submission Date: 4/12/2021
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

Comments of Yuki Asada under P-15056. Submission Date: 4/12/2021
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

Comments of Anne-Marie Johansson under P-15056. Submission Date: 4/12/2021
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

Comments of Aaron N. Berger under P-15056. Submission Date: 4/12/2021
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.

Comments of Jessica Swarbrick under P-15056. Submission Date: 4/12/2021
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.

Comments of John Hutchins under P-15056. Submission Date: 4/12/2021
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

Comments of Soniya Munshi under P-15056. Submission Date: 4/12/2021
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.

Comments of Lauren Elliott under P-15056. Submission Date: 4/12/2021
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

Comments of Daniel Case under P-15056. Submission Date: 4/12/2021
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.

Comments of Susan Barnett under P-15056. Submission Date: 4/12/2021
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.

Comments of James M Hoffman under P-15056. Submission Date: 4/12/2021
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.

Comments of Correy McGlyn under P-15056. Submission Date: 4/12/2021
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

Comments of Christopher Parris-Lamb under P-15056. Submission Date: 4/12/2021
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

Comments of Madeline Wilson under P-15056. Submission Date: 4/12/2021
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.

Comments of Elaine Oswald under P-15056. Submission Date: 4/12/2021
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.

Comments of Eric A. Goldstein under P-15056. Submission Date: 4/12/2021
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

Comments of Aaron Anaya under P-15056. Submission Date: 4/12/2021
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.

Comments of Edward S Vickers under P-15056. Submission Date: 4/13/2021
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.

Comments of Heather Hammond under P-15056. Submission Date: 4/13/2021
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.

Comments of Anna Compton under P-15056. Submission Date: 4/13/2021
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.

Other formats

Motion to Intervene of Damascus Citizens for Sustainability, Inc. under P-15056.
click here to view.
Motion to Intervene of Coalition of Watershed Towns c/o Delaware County Department of Watershed Affairs under P-15056.
click here to view.
Comments of Coalition of Watershed Towns under P-15056.
click here to view.

Disclaimer: A lot of these TIF files are corrupt.

Comments of B. Jean Runz under P-15056.
click here to view.
click here to download.
Comments of Rosemary L. Anderson under P-15056.
click here to download.
Comments of Irene Koval under P-15056.
click here to download.
Comments of Boris Belenky under P-15056.
click here to download.
Comments of Larry Brown under P-15056.
click here to download.
Comments of Kevin Boyer under P-15056.
click here to download.
Comments of Holley George-Warren under P-15056.
click here to download.
Comments of Sue Ann and Michael J Bronds under P-15056.
click here to download.
Comments of Donna Elberg under P-15056.
click here to view.
click here to download.
Comments of Linda Sobel under P-15056.
click here to view.
click here to download.
Comments of Gary and Linda Scheruger under P-15056.
click here to download.
Comments of Diane DiMartino under P-15056.
click here to download.
Comments of Vincent H. Biondo under P-15056.
click here to download.
Comments of Astrid Nordness re the Ashokan Pumped Storage Project under P-15056.
click here to download.

Comments of Laurie Winnie under P-15056. Submission Date: 4/9/2021
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

Comments of Harrison Molmed under P-15056. Submission Date: 4/9/2021
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

Comments of Barbel Eggers under P-15056. Submission Date: 4/9/2021
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.

Comments of peter himberger under P-15056. Submission Date: 4/9/2021
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

Comments of Johnny Simon under P-15056. Submission Date: 4/9/2021
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

Comments of Kelly Stefanski under P-15056. Submission Date: 4/9/2021
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

Comments of Sara Babyatsky under P-15056. Submission Date: 4/9/2021
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

Comments of Sara Ansari under P-15056. Submission Date: 4/9/2021
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

Comments of Jane Smiley under P-15056. Submission Date: 4/9/2021
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.

Comments of Woodstock Land Conservancy N/A under P-15056. Submission Date: 4/9/2021
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

Comments of JOHN b KOCH under P-15056. Submission Date: 4/9/2021
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

Comments of Michael Boyer under P-15056. Submission Date: 4/9/2021
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

Comments of Rachel Hunt under P-15056. Submission Date: 4/9/2021
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.

Comments of Elinor Stapylton under P-15056. Submission Date: 4/9/2021
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

Comments of Edward Ripley-Duggan under P-15056. Submission Date: 4/9/2021
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.

Comments of Gail Mallimson under P-15056. Submission Date: 4/9/2021
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

Comments of Jane Levenson under P-15056. Submission Date: 4/9/2021
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

Comments of Suzanne Thorpe under P-15056. Submission Date: 4/9/2021
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

Comments of Tatiana Alexa under P-15056. Submission Date: 4/9/2021
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

Comments of Andrew Lemonier under P-15056. Submission Date: 4/9/2021
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.

Comments of Julia Rose under P-15056. Submission Date: 4/9/2021
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

Comments of Maya Raffaele under P-15056. Submission Date: 4/9/2021
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

Comments of chris condon under P-15056. Submission Date: 4/9/2021
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

Comments of Margery Schab under P-15056. Submission Date: 4/9/2021
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.

Comments of Marilee Talman under P-15056. Submission Date: 4/9/2021
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.

Comments of Jessica Rose under P-15056. Submission Date: 4/9/2021
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

Comments of Adriane Hectus under P-15056. Submission Date: 4/10/2021
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

Comments of Stan Mashov under P-15056. Submission Date: 4/10/2021
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

Comments of Kelly Sinclair under P-15056. Submission Date: 4/10/2021
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

Comments of michael blitz under P-15056. Submission Date: 4/10/2021
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

Comments of Judith Capurso under P-15056. Submission Date: 4/10/2021
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

Comments of Alice Bierhorst under P-15056. Submission Date: 4/10/2021
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

Comments of Kathryn Bradley Chernis under P-15056. Submission Date: 4/10/2021
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.

Comments of Heather Gierloff under P-15056. Submission Date: 4/10/2021
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.

Comments of Mary Sheridan under P-15056. Submission Date: 4/10/2021
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

Comments of Ricarda O'Conner under P-15056. Submission Date: 4/10/2021
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

Comments of Michael Ottavi under P-15056. Submission Date: 4/10/2021
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

Comments of Cliff Rabuffo under P-15056. Submission Date: 4/10/2021
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

Comments of Luke Schwartz under P-15056. Submission Date: 4/10/2021
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.

Comments of Aliza under P-15056. Submission Date: 4/10/2021
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.

Comments of Mary J Reiss under P-15056. Submission Date: 4/10/2021
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

Comments of Melissa Kawecki under P-15056. Submission Date: 4/10/2021
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.

Comments of Hendrik Uyttendaele under P-15056. Submission Date: 4/10/2021
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.

Comments of Joan Hall under P-15056. Submission Date: 4/10/2021
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

Comments of Daniel Prousline under P-15056. Submission Date: 4/10/2021
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!

Comments of Cynthia Russak under P-15056. Submission Date: 4/10/2021
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.

Comments of Janice Kachadourian under P-15056. Submission Date: 4/10/2021
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

Comments of Michael Callejo under P-15056. Submission Date: 4/10/2021
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

Comments of James Pellitteri under P-15056. Submission Date: 4/10/2021
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

Comments of Junice J Santa Ana under P-15056. Submission Date: 4/10/2021
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

Comments of Ben Perowsky under P-15056. Submission Date: 4/10/2021
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

Comments of Sarah Mitchell under P-15056. Submission Date: 4/10/2021
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

Comments of Michael Rosenthal under P-15056. Submission Date: 4/10/2021
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

Comments of John Boston under P-15056. Submission Date: 4/10/2021
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

Comments of R Benaducci under P-15056. Submission Date: 4/10/2021
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

Comments of Maret Panzenbeck under P-15056. Submission Date: 4/10/2021
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.

Comments of Sabina D. Tannenbaum under P-15056. Submission Date: 4/10/2021
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)

Comments of Paul Fusco under P-15056. Submission Date: 4/10/2021
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

Comments of Jenny under P-15056. Submission Date: 4/10/2021
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.

Comments of Galina Rodionov under P-15056. Submission Date: 4/10/2021
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

Comments of Sandra Au under P-15056. Submission Date: 4/10/2021
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

Comments of Jennifer Charles under P-15056. Submission Date: 4/10/2021
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

Comments of Ina Kozel under P-15056. Submission Date: 4/10/2021
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

Comments of Anatoly Y Rodionov under P-15056. Submission Date: 4/10/2021
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.

Comments of K.A. Risio-Smith under P-15056. Submission Date: 4/10/2021
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.

Comments of Sydney under P-15056. Submission Date: 4/10/2021
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.

Comments of Steven Parisio under P-15056. Submission Date: 4/10/2021
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.

Comments of Francesca Esmay under P-15056. Submission Date: 4/10/2021
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

Comments of Justin Lamarche under P-15056. Submission Date: 4/10/2021
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.

Comments of Thomas Smith under P-15056. Submission Date: 4/10/2021
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.

Comments of Barbara klippert under P-15056. Submission Date: 4/10/2021
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

Comments of Gillian Luongo under P-15056. Submission Date: 4/10/2021
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

Comments of Dawn S Peters under P-15056. Submission Date: 4/10/2021
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

Comments of Caryn Carter under P-15056. Submission Date: 4/10/2021
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

Comments of Mickey & Mo Winograd under P-15056. Submission Date: 4/10/2021
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

Comments of Jim Sofranko under P-15056. Submission Date: 4/10/2021
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

Comments of Eileen M Gumport under P-15056. Submission Date: 4/10/2021
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

Comments of Shea Fink under P-15056. Submission Date: 4/10/2021
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.

Comments of Dette Flies under P-15056. Submission Date: 4/10/2021
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

Comments of Mozelle Dayan under P-15056. Submission Date: 4/10/2021
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

Comments of GIANROBERT C. S. WOOTTON under P-15056. Submission Date: 4/10/2021
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

Comments of Kevin Young under P-15056. Submission Date: 4/10/2021
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

Comments of John Buckler Seiberling under P-15056. Submission Date: 4/10/2021
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

Comments of Robert Selkowitz under P-15056. Submission Date: 4/10/2021
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

Comments of Kathleen R Anderson under P-15056. Submission Date: 4/10/2021
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.

Comments of Elizabeth Gumport under P-15056. Submission Date: 4/10/2021
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

Comments of Amanda Lees under P-15056. Submission Date: 4/10/2021
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

Comments of Marilyn Manning under P-15056. Submission Date: 4/10/2021
Marilyn Manning, Phoenicia, NY.
I'M AGAINST IT!

Comments of Peter Laciano under P-15056. Submission Date: 4/10/2021
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.

Comments of Nicole Cawley under P-15056. Submission Date: 4/10/2021
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

Comments of Beyl Peter under P-15056. Submission Date: 4/10/2021
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

Comments of katharine s holmes under P-15056. Submission Date: 4/10/2021
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

Comments of Cathy Capozzi under P-15056. Submission Date: 4/10/2021
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

Comments of Emily Darrow under P-15056. Submission Date: 4/10/2021
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

Comments of John Draper under P-15056. Submission Date: 4/10/2021
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.

Comments of Dianna Brindle under P-15056. Submission Date: 4/10/2021
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

Comments of Quinn Holmes under P-15056. Submission Date: 4/10/2021
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,

Comments of Walker holmes under P-15056. Submission Date: 4/10/2021
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

Comments of Sally Smith-Raymond under P-15056. Submission Date: 4/10/2021
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

Comments of MICHAEL MOSS under P-15056. Submission Date: 4/10/2021
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

Comments of Judith Moss under P-15056. Submission Date: 4/10/2021
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

Comments of Daria Skripka under P-15056. Submission Date: 4/10/2021
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

Comments of Judith Coutinho under P-15056. Submission Date: 4/10/2021
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

Comments of Teresa Falkowski under P-15056. Submission Date: 4/10/2021
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

Comments of 47 Hoffman st under P-15056. Submission Date: 4/10/2021
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

Comments of David E Seitz under P-15056. Submission Date: 4/10/2021
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

Comments of Rebecca Riklin under P-15056. Submission Date: 4/10/2021
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

Comments of Claudine brenner under P-15056. Submission Date: 4/10/2021
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."

Comments of Andrey Zhukov-Khovanskiy under P-15056. Submission Date: 4/10/2021
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

Comments of Vivian Welton under P-15056. Submission Date: 4/10/2021
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

Comments of Elziabeth Earle under P-15056. Submission Date: 4/11/2021
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.

Comments of Alison Maltby-Duggan under P-15056. Submission Date: 4/11/2021
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

Comments of Janine Connell under P-15056. Submission Date: 4/11/2021
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

Comments of Janine Connell under P-15056. Submission Date: 4/11/2021
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

Comments of Michael pezzolla under P-15056. Submission Date: 4/11/2021
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

Comments of Ralph Schimmenti under P-15056. Submission Date: 4/11/2021
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

Comments of Alexandria Rabuffo under P-15056. Submission Date: 4/11/2021
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

Comments of Lindsay Stanislau under P-15056. Submission Date: 4/11/2021
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.

Comments of Jennifer Christie under P-15056. Submission Date: 4/11/2021
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.

Comments of Arthur Christie under P-15056. Submission Date: 4/11/2021
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.

Comments of Megan Brenn-White under P-15056. Submission Date: 4/11/2021
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

Comments of Robert Howe under P-15056. Submission Date: 4/11/2021
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

Comments of Robert Brown under P-15056. Submission Date: 4/11/2021
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

Comments of Laura Tofte under P-15056. Submission Date: 4/11/2021
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

Comments of Cynthia Thomas under P-15056. Submission Date: 4/11/2021
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

Comments of Catherine Yoon under P-15056. Submission Date: 4/11/2021
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

Comments of Mark Mann under P-15056. Submission Date: 4/11/2021
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

Comments of Morgan Miller under P-15056. Submission Date: 4/11/2021
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

Comments of Simon Mortimer under P-15056. Submission Date: 4/11/2021
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

Comments of Bonnie Valentines under P-15056. Submission Date: 4/11/2021
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

Comments of Joel I Shapiro under P-15056. Submission Date: 4/11/2021
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.

Comments of Tina DiVello under P-15056. Submission Date: 4/11/2021
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

Comments of Dashall Vazquez under P-15056. Submission Date: 4/11/2021
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!

Comments of katherine mcmillan under P-15056. Submission Date: 4/11/2021
katherine mcmillan, High Falls, NY.
ADAMANTLY OPPOSED TO THE WALNUT ENERGY PROPOSAL. PLEASE DO NOT LET THIS HAPPEN.

Comments of Douglas Gillespie under P-15056. Submission Date: 4/11/2021
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

Comments of Ty Stallard under P-15056. Submission Date: 4/11/2021
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

Comments of Lynn Luong under P-15056. Submission Date: 4/11/2021
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.

Comments of Walter Alexander under P-15056. Submission Date: 4/11/2021
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.

Comments of Barbara Blumenthal under P-15056. Submission Date: 4/11/2021
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

Comments of Maria muller under P-15056. Submission Date: 4/11/2021
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

Comments of Amie Green under P-15056. Submission Date: 4/11/2021
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

Comments of Alexandra Schmidbauer under P-15056. Submission Date: 4/11/2021
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

Comments of Brian Powers under P-15056. Submission Date: 4/11/2021
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

Comments of Carol Monteleoni under P-15056. Submission Date: 4/11/2021
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

Comments of Marlene Castro under P-15056. Submission Date: 4/11/2021
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.

Comments of Jess Bird under P-15056. Submission Date: 4/11/2021
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

Comments of Val Zlatev under P-15056. Submission Date: 4/11/2021
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.

Comments of Lemuel Amaral under P-15056. Submission Date: 4/11/2021
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

Comments of Nancy N Parisio under P-15056. Submission Date: 4/11/2021
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

Comments of Dorothy Solomon under P-15056. Submission Date: 4/11/2021
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

Comments of Leslie Cagan under P-15056. Submission Date: 4/11/2021
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

Comments of Jeffrey Potent under P-15056. Submission Date: 4/11/2021
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.

Comments of John H Moore under P-15056. Submission Date: 4/11/2021
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/

Comments of Sid Davidowitz under P-15056. Submission Date: 4/11/2021
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.

Comments of Daniel W Morgan under P-15056. Submission Date: 4/11/2021
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

Comments of Nick Frattaroli under P-15056. Submission Date: 4/11/2021
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.

Comments of Noah Kagan under P-15056. Submission Date: 4/11/2021
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

Comments of corey adams under P-15056. Submission Date: 4/11/2021
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

Comments of Patrick Dimilia under P-15056. Submission Date: 4/11/2021
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

Comments of Michael Rosenman under P-15056. Submission Date: 4/11/2021
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

Comments of Sondra Wolferman under P-15056. Submission Date: 4/11/2021
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.

Comments of Anne E Glausen under P-15056. Submission Date: 4/11/2021
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.

Comments of Michael Wong under P-15056. Submission Date: 4/11/2021
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

Comments of Todd Green under P-15056. Submission Date: 4/11/2021
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

Comments of Lynnette under P-15056. Submission Date: 4/11/2021
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

Comments of Steve Cunningham under P-15056. Submission Date: 4/11/2021
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

Comments of Jeannette Estruth under P-15056. Submission Date: 4/11/2021
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

Comments of Robert Munk under P-15056. Submission Date: 4/11/2021
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

Comments of Jacqueline Lyons under P-15056. Submission Date: 4/11/2021
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

Comments of Jonathan Basker under P-15056. Submission Date: 4/11/2021
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

Comments of Wendy Wolfenson under P-15056. Submission Date: 4/11/2021
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

Comments of Irene Jessica Upson under P-15056. Submission Date: 4/11/2021
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

Comments of Betsy Cowden under P-15056. Submission Date: 4/11/2021
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.

Comments of Nicholas Arbatsky under P-15056. Submission Date: 4/11/2021
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.

Comments of Laura Giles under P-15056. Submission Date: 4/11/2021
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

Comments of Leanne Avery under P-15056. Submission Date: 4/11/2021
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.

Comments of Anne Kohlhagen under P-15056. Submission Date: 4/11/2021
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

Comments of Catherine White under P-15056. Submission Date: 4/11/2021
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

Comments of Angel Molina under P-15056. Submission Date: 4/11/2021
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

Comments of Catherine White under P-15056. Submission Date: 4/11/2021
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

Comments of Daniel Melnick under P-15056. Submission Date: 4/11/2021
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

Comments of Adrienne Larys under P-15056. Submission Date: 4/11/2021
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.

Comments of Pamela Moulton under P-15056. Submission Date: 4/11/2021
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

Comments of Hiroko Sakurazawa under P-15056. Submission Date: 4/11/2021
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.

Comments of Jeffrey C Schwartz under P-15056. Submission Date: 4/11/2021
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

Comments of Judith Hannon under P-15056. Submission Date: 4/11/2021
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.

Comments of Peggy E Reynolds under P-15056. Submission Date: 4/11/2021
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

Comments of Josh A Massicot under P-15056. Submission Date: 4/11/2021
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.

Comments of Elizabeth Ristow under P-15056. Submission Date: 4/11/2021
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.

Comments of Sam S Spata under P-15056. Submission Date: 4/11/2021
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.

Comments of Alexander Miller under P-15056. Submission Date: 4/11/2021
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

Comments of Thomas Parker under P-15056. Submission Date: 4/11/2021
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

Comments of Ellen Helman under P-15056. Submission Date: 4/11/2021
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

Comments of Donad Sandor under P-15056. Submission Date: 4/11/2021
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

Comments of Elizabeth Sandor under P-15056. Submission Date: 4/11/2021
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

Comments of Michael Taffet under P-15056. Submission Date: 4/11/2021 (Erroneously filed)

Comments of Barbara Becker under P-15056. Submission Date: 4/11/2021
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

Comments of Philip Monteleoni under P-15056. Submission Date: 4/11/2021
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!

Comments of Ruth Rich under P-15056. Submission Date: 4/11/2021
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

Comments of Sabrina B Taylor under P-15056. Submission Date: 4/11/2021
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

Comments of Linda Werner under P-15056. Submission Date: 4/11/2021
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

Comments of Brian Sandor under P-15056. Submission Date: 4/11/2021
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

Comments of Jeffrey Martin under P-15056. Submission Date: 4/11/2021
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

Comments of Natira Silva under P-15056. Submission Date: 4/11/2021
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

Comments of Gayle Panzenbeck under P-15056. Submission Date: 4/11/2021
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!

Comments of Laura Endres under P-15056. Submission Date: 4/11/2021
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

Comments of Sierra Flach under P-15056. Submission Date: 4/11/2021
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

Comments of Maddy Culpepper under P-15056. Submission Date: 4/11/2021
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

Comments of Esther Normann-Riosc under P-15056. Submission Date: 4/11/2021
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

Comments of Michelle Tuorto-Collins under P-15056. Submission Date: 4/11/2021
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.

Comments of Michael Taffet under P-15056. Submission Date: 4/11/2021
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

Comments of Martha M Porter under P-15056. Submission Date: 4/11/2021
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

Comments of Devon Kasarjian under P-15056. Submission Date: 4/11/2021
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.

Comments of Jenna Pethybridge under P-15056. Submission Date: 4/11/2021
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

Comments of Jordan Tsao under P-15056. Submission Date: 4/11/2021
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

Comments of David I Reiner under P-15056. Submission Date: 4/11/2021
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.

Comments of Zelma Livingston under P-15056. Submission Date: 4/11/2021
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

Comments of Jim Rich under P-15056. Submission Date: 4/11/2021
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

Comments of Ruth Ann Gyure under P-15056. Submission Date: 4/11/2021
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.

Comments of Amanda Insall under P-15056. Submission Date: 4/11/2021
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

Comments of Augusta Gillespie under P-15056. Submission Date: 4/11/2021
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

Comments of Jason Campe under P-15056. Submission Date: 4/11/2021
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

Comments of Natalie Parker under P-15056. Submission Date: 4/11/2021
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!

Comments of Karl Steinbrenner under P-15056. Submission Date: 4/11/2021
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

Comments of Constance Kieltyka under P-15056. Submission Date: 4/11/2021
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

Comments of Michelle Friedel under P-15056. Submission Date: 4/11/2021
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

Comments of Roger & Judith Morris under P-15056. Submission Date: 4/11/2021
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.

Comments of Sita Anderson under P-15056. Submission Date: 4/11/2021
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

Comments of Curtis Troeger under P-15056. Submission Date: 4/11/2021
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.

Comments of Gary under P-15056. Submission Date: 4/11/2021
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.

Comments of Sara Muskulus under P-15056. Submission Date: 4/11/2021
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

Comments of John F Krenek under P-15056. Submission Date: 4/11/2021
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!!!

Comments of Nicole Mihatov under P-15056. Submission Date: 4/11/2021
Nicole Mihatov, Nanuet, NY.
This project must be rejected. It will bring too much harm to the Catskills

Comments of Robert Marschall under P-15056. Submission Date: 4/11/2021
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.

Comments of Michael L Rusilas under P-15056. Submission Date: 4/11/2021
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.

Comments of Bethany Saltman under P-15056. Submission Date: 4/11/2021
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

Comments of Kimberly Standerwick under P-15056. Submission Date: 4/11/2021
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

Comments of Doreen Arnesen under P-15056. Submission Date: 4/11/2021
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

Comments of Rebecca A Anwar under P-15056. Submission Date: 4/11/2021
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.

Comments of Holli Silver under P-15056. Submission Date: 4/11/2021
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

Comments of James Borbely under P-15056. Submission Date: 4/11/2021
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.

Comments of Damian Amitin under P-15056. Submission Date: 4/11/2021
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

Comments of Susan Hereth under P-15056. Submission Date: 4/11/2021
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.

Comments of John Lamberty under P-15056. Submission Date: 4/11/2021
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

Comments of Kari E. Hoyt under P-15056. Submission Date: 4/11/2021
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

Comments of Megan Offner under P-15056. Submission Date: 4/11/2021
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

Comments of Jen Brueckner under P-15056. Submission Date: 4/11/2021
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

Comments of Lauren Jordan-Amitin under P-15056. Submission Date: 4/11/2021
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

Comments of Rachel Silver under P-15056. Submission Date: 4/11/2021
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

Comments of Kenneth Lipnickey under P-15056. Submission Date: 4/11/2021
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

Comments of Lorraine DellaPenna under P-15056. Submission Date: 4/11/2021
Lorraine DellaPenna, Phoenicia, NY.
/Users/lorrainedellapenna/Documents/P15056titled.pdf/Users/lorrainedellapenna/Documents//Users/lorrainedellapenna/Documents/P15056titled.pdf

Comments of Melissa Gaginer under P-15056. Submission Date: 4/11/2021
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

Comments of Rosalind Dickinson under P-15056. Submission Date: 4/11/2021
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

Comments of Mary Ann Shepard under P-15056. Submission Date: 4/11/2021
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

Comments of Tiffany Joy Butler under P-15056. Submission Date: 4/11/2021
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

Comments of Sally Plass under P-15056. Submission Date: 4/11/2021
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)

Comments of Cynthia Purchase under P-15056. Submission Date: 4/11/2021
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

Comments of Jolie Parker under P-15056. Submission Date: 4/11/2021
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.

Comments of William Melvin under P-15056. Submission Date: 4/11/2021
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

Comments of Eleanor Waligurski under P-15056. Submission Date: 4/11/2021
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

Comments of Alexander Borbely under P-15056. Submission Date: 4/11/2021
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.

Comments of Jen Brueckner under P-15056. Submission Date: 4/11/2021
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

Comments of David Rainbird under P-15056. Submission Date: 4/11/2021
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

Comments of Jennifer Kabat under P-15056. Submission Date: 4/11/2021
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.

Comments of Richard W Brown under P-15056. Submission Date: 4/11/2021
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

Comments of Derek Stukuls under P-15056. Submission Date: 4/11/2021
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.

Comments of Melanie Kier under P-15056. Submission Date: 4/11/2021
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

Comments of James Armstrong under P-15056. Submission Date: 4/11/2021
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

Comments of Greg Clarke under P-15056. Submission Date: 4/11/2021
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!

Comments of Mark Loete under P-15056. Submission Date: 4/11/2021
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

Comments of Elise Lark under P-15056. Submission Date: 4/11/2021
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

Comments of Divyan Mistry under P-15056. Submission Date: 4/11/2021
Divyan Mistry, Denver, NY.
This project will not be good for the catskills watershed. As a resident I urge ferc to block this

Comments of Henrietta Wise under P-15056. Submission Date: 4/11/2021
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

Comments of Frank M Parslow under P-15056. Submission Date: 4/11/2021
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

Comments of Benjamin Hellman under P-15056. Submission Date: 4/11/2021
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

Comments of Madeline Mallon under P-15056. Submission Date: 4/11/2021
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

Comments of Mark Bernard under P-15056. Submission Date: 4/11/2021
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

Comments of Traci A Parks under P-15056. Submission Date: 4/11/2021
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

Comments of Sorrel Brae Ahlfeld under P-15056. Submission Date: 4/11/2021
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

Comments of Dr. Wayne Ouderkirk under P-15056. Submission Date: 4/11/2021
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

Comments of David Wargula under P-15056. Submission Date: 4/11/2021
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

Comments of Anne Devine under P-15056. Submission Date: 4/11/2021
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

Comments of Joseph Felter under P-15056. Submission Date: 4/11/2021
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.

Comments of Justin Michel under P-15056. Submission Date: 4/11/2021
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

Comments of Delia K. Adams under P-15056. Submission Date: 4/11/2021
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!

Comments of Adam Kaufman under P-15056. Submission Date: 4/11/2021
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)

Comments of James R Devens under P-15056. Submission Date: 4/11/2021
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

Comments of Cheyenne Mallo under P-15056. Submission Date: 4/11/2021
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

Comments of Tom Luciano under P-15056. Submission Date: 4/11/2021
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 bill