In December 2019 Northern States Power submitted their Notice of Intent and Preliminary Application Document to relicense both the Saxon Falls and Superior Falls Hydroelectric Projects. These two projects regulate flows on the West Branch Montreal and Montreal Canyon. Both of these runs are enjoyed by paddlers from across the Midwest and offer opportunities that are unique to the region.

American Whitewater will be filing formal comments and a study request within the next week requesting an evaluation of flow needs for whitewater boating and adequacy of accommodations for public access to the river. At this stage in the process we are highlighting issues for study and identifying information needs. Advocacy for specific mitigation measures will come later in the process but prior to issuance of a new license that is anticipated in December 2024.

As we prepare comments we have identified a few issues to study:

1) We have an interest in better understanding instream flow needs for recreation on the Montreal Canyon and West Branch Montreal. The hydropower projects have limited storage capacity but we know there are occasional releases and drawdowns from Gile Foliage. In their application, the utility states they are not planning any studies specific to recreation. We will request an instream flow study of whitewater recreation for both the Montreal Canyon and West Branch Montreal and an evaluation of opportunities to provide flows for recreation or otherwise provide forecast information and/or notification of anticipated releases or drawdown from Gile Flowage.

2) The Saxon Falls Tailwater Access is known for the long set of stairs used to enter the Montreal Canyon below the Saxon Falls Powerhouse. In their application the utility states that "no new recreation facilities or improvements are being proposed." We plan to ask for an evaluation of potential improvements to the access into the canyon.

3) The Superior Falls Canoe Take-out is used as the take-out for those who run the Montreal Canyon. Currently parking is only available for two vehicles. We will request an evaluation of the adequacy of this parking and consideration of any other potential improvements to the site. 

4) Currently flow information is provided through a phone and a recording. We plan to request access to real-time flow information through a standard API that will allow integration of flow data with paddling websites and apps such as those maintained by American Whitewater. 

At this stage in the process it is helpful to have paddlers weigh in expressing their interest in whitewater boating in the Montreal Canyon or West Branch Montreal. These comments need not be long but are used to identify issues requiring further study. If 10 paddlers write in expressing interest in whitewater boating that can help us make the case that whitewater recreation needs more attention and needs to be considered in a future license that could last 30 to 50 years.

Your comment could include the following elements:

* Introduce yourself and your personal connection to the Montreal River.

* Describe any unique attributes of the Montreal River that you believe justify studies of whitewater recreation.

* Make a request for what you want studied. Here is some sample text: "as FERC considers study needs for relicensing of the Saxon Falls and Superior Falls Hydroelectric Project I am requesting a study of instream flow needs for whitewater recreation, an evaluation of public access needs, and options for providing improved access to real-time flow information."

Comments in the coming week will be most helpful, but you can share your perspective with FERC at any time in the process. We anticipate that studies will be completed over the next two years at which point the utility will develop their formal license application. There will be additional opportunities to comment on their proposal and any additional mitigation measures we feel are warranted.

You have a couple options to comment:

1) You can file a Quick Comment of 6000 characters or less. To do this you fill out a form at <https://ferconline.ferc.gov/QuickComment.aspx> with your name, address, and email. Once you fill out the form, you will receive an email with a unique link to the form to submit your comment. On the form you will need to enter a docket number: type in "P-2587-000" and hit select, and then type "P-2610-000" and hit select. You will now be submitting comments for the two related projects and you can begin typing (or copy and paste) your comments into the text box.

2) You can eFile which allows you to upload a document (e.g. Word or PDF) with your comments. For this option you need to create an account on the FERC website at <https://ferconline.ferc.gov/LogIn.aspx> and log on and select eFiling to submit documents electronically. You will need to selecting a few options for your filing starting by selecting "General," then "Comment (on Filing, Environ, Report, or Tech Conf)," and then "Comment." On the next screen you will need to select the Docket. Type in "P-2587-000" to search and then select it. Then type in "P-2610-000" to search and then select it. Once you have both Superior Falls and Saxon Falls selected, hit Next. You can now select your file and give it a Description like "Comments of YOUR NAME" regarding whitewater recreation at the Saxon Falls and Superior Falls Hydroelectric Projects." One other feature you can take advantage of if you register with FERC online is you can follow along with the project, see what everyone else files, and get notification of upcoming opportunities to comment or provide input. To do this, go to eSubscription <https://ferconline.ferc.gov/eSubscription.aspx> and "Add New Subscription" using the docket numbers above.