The promise of hydrokinetic turbines is in their ability to produce clean, sustainable energy that takes advantage of the river’s current (run of river). But because this is the first installation of this type of turbine, there are questions about their effect on wildlife and the surrounding area that need to be addressed. During the licensing process, FERC received comments from a variety of agencies including the Department of the Interior, Minnesota Pollution Control Agency, the Fish and Wildlife Service, the Army Corps of Engineers, Trout Unlimited, American Rivers, and others about specific aspects of the project.
National Park Service Concerns
The National Park Service has several concerns about the hydrokinetics array currently being installed below Lock/Dam 2 at Hastings.
First, potential impacts on wildlife are completely unknown, since this technology has never been tested in a river.
- Impacts on fish are a particular concern, since fish tend to congregate in the tailwaters of dams—especially in early spring just before they spawn. Large numbers of walleye and sauger are particularly vulnerable because they concentrate just below the dam. Studies of fish impacts proposed by the applicant may not be adequate to assess true impacts, especially cumulative impacts over time. Impacts may multiply if other hydrokinetic arrays are deployed as expected.
- Mussel impacts are unknown, but of concern. One federally endangered species is found in the area and several state-listed species are known to be in the general area of the kinetic array. Because of high current velocities right below the dam there may be few mussels directly impacted, but we may never know for sure since the applicant doesn’t plan to do a mussel survey. The applicant promises to move any mussels it finds—but it’s hard to find mussels when you’re not looking, and mussels won’t survive moving them in winter.
- Impacts to diving birds are also unknown, but if the turbine entrains many fish the site will become a magnet for birds in the middle of one of the continent’s most important flyways for migratory birds.
Second, impacts on recreational boating are not addressed. The emergency removal plan suggests the barge containing the turbine will be pulled up on shore at the Hastings Public Water Access site just downriver. It is not clear how long or frequently this action would close the public access, which is the only free public boat ramp on the river in the area.
While the hydrokinetic array is in place below the dam it is unlikely to interfere with recreational boating, since it will be placed within the 300-foot exclusion zone on the downstream side of the dam. This is an area that is unsafe for boating. If the hydrokinetic array is expanded downriver, however, which is part of the applicant’s future plans, it will expand into an area popular with anglers and the potential for conflict increases significantly.
Third, the speed by which this application process has moved means that several deadlines have already passed without required agency consultation.
- Operating Plan: An Operating Plan must be submitted to the Corps of Engineers 60 days prior to the start of construction and a Memorandum of Agreement must be signed with the Corps prior to start-up. Neither had been approved as of December 17, even though construction had clearly begun by December 10.
- Hydrokinetic Array Safety Plan: Before preparing this plan, the applicant must consult with the Corps of Engineers, U.S. Fish and Wildlife Service, National Park Service and Minnesota DNR. After preparing a draft plan, the agencies will have a minimum 10-day review/comment period. The plan must be finalized 20 days prior to starting construction or operation. Required consultation never occurred; a draft plan was submitted to the agencies December 22, well after construction began. Considering the significance of a possible breakaway just upstream of the Highway 61 bridge at Hastings, this safety plan is not something that should be rushed.
- Hydrokinetic array removal plan: Similarly, this plan must be prepared after consultation with state and federal agencies, but that consultation never occurred. The agencies have 15 days to review a draft plan starting December 16. The plan must be finalized prior to startup.
When the license was issued, the following conditions were placed on the City of Hastings in order for the license to be valid:
- The hydroturbines must operate in a strict run of river mode.
- The city needs to monitor water quality at two locations; one between the hydroturbines and the existing facility and one downstream from the hydroturbines. Water quality monitoring will continue for three years after installation.
- A study must be completed to determine fish mortality. The study must include data concerning injury caused by the turbines themselves and predation rates just downstream from the turbines. Once the study is completed, the city will work with the MPCA, the Minnesota Department of Natural Resources and the U.S. Fish and Wildlife Service to recommend changes if harm to the fishery is identified.
- A bird monitoring plan must be developed to describe bird presence in the tailrace. The plan must include seasonal effects and migration surveys.
- If mussels are found in the immediate area, they will be relocated in cooperation with the U.S. Fish and Wildlife Service.
- Zebra mussel monitoring will take place at the site, and a plan will be devised with control procedures to ensure zebra mussels are not spread to other waters.
- Safety and interpretive signage will be developed and installed nearby.
Other conditions regarding engineering, construction and compliance issues were published and can be found in the full document.
Hydrokinetics Compatibility Letter (Deputy Secretary, DOI)