Friends of Sebago Lake
P.O. Box 445, Casco, ME 04015 · www.friendsofsebago.org
May 19, 2003
Ms. Magalie Salas, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C. 20426
RE: Eel Weir Dam Project (FERC No. 2984)
Dear Ms. Salas,
On February 14, 2003 the Commission sent S.D. Warren, the Applicant for
the above mentioned project, an Additional Information Request (AIR) . This
AIR stated in part:
"In its letter to the Commission, filed November 15, 2002, Friends
of Sebago Lake (FOSL) referenced a study done by Ritzi for S.D. Warren in
1984. FOSL states that the study showed 'an increasing number of high flow
events as well as increasing flow volumes,' as recorded at Cumberland Mills
in Westbrook, Maine. FOSL requests that staff consider the need to increase
the storage capacity of the Eel Weir dam, particularly during the 10- or
25-year storm events. In order for us to evaluate the storage capacity issue
and any potential effects of operating and maintaining Sebago Lake at a
lower level, please provide the following: (A) A copy of the 1984 Ritzi
study mentioned above ...."
Friends of Sebago Lake (FOSL) has recently learned the study referenced
in the Commission's above AIR was conducted by Kleinschmidt & Dutting,
consulting engineers for the S.D. Warren Company. This December 1984 study
is titled Analysis of Dam Failure at Eel Weir Dam, S.D. Warren Company,
Westbrook, Maine. File: 23-18-90-00-07. FOSL believes this study was filed
with the Commission by S.D. Warren as part of its 1985 Emergency Action
Plan for the Eel Weir dam, accession number 8504040166. An original and
eight copies of pertinent excerpts of this Kleinschmidt & Dutting study
are enclosed for Commission staff review.
Information pertinent to the Commission's February 14, 2003 AIR is found
on page 2 of the Kleinschmidt & Dutting study, which states: "The
drainage area downstream of the lake [Sebago] is unregulated and can be
characterized as gently rolling coastal plain. Much of the area is forested,
however, and is experiencing increasing development. Flood flows recorded
at the Cumberland Mills in Westbrook show an increasing number of high flow
events, as well as increasing flow volumes which may be attributed to urbanization
of the area. Sebago Lake has a surface area of 45 square miles and, because
of its large storage capacity, effectively attenuates flood flows from its
contributing watershed. During flood events downstream of the dam, outflows
from the lake can be minimized, if required, to reduce the downstream flood
flows."
FOSL believes the study's conclusions support Commission staff's interest
in analyzing the potential benefit of lower annual lake levels at Sebago
Lake to attenuate the impact of flood events in the Presumpscot River basin.
According to the Kleinschmidt and Dutting study, an outflow at the Eel Weir
Dam of 12,000 cfs would lower lake levels by approximately one foot after
29 hours. They estimated the outflow of Eel Weir Dam at a 500-year flood
event to be 10,000 cfs. These findings suggest that maintenance of lake
levels well below the crest of the Eel Weir Dam spillway would be useful
to attenuate a large-scale flood event in the Presumpscot River basin by
reducing the contributing effect of Sebago Lake outflows to unregulated
flood flows from Presumpscot River tributaries below the Eel Weir Dam.
FOSL wishes to correct the Applicant's April 14, 2003 AIR response (AIR
7, pp. 2-3) which states, "It is well documented that flood issues
on the Presumpscot River come from the unregulated drainage area downstream
of Sebago Lake .... However, even during the 250-year flood event in 1996,
the lake rose only approximately three feet and no excessive flow releases
were necessary."
This statement implies that during the October 1996 flood event, peak flows
in the watershed above the Eel Weir Dam were equivalent to that of a 250-year
flood. This is not true, according to the study titled Flood of October
1996 in Southern Maine. U.S. Dept. of the Interior and U.S. Geological Survey,
Water Resources Investigation Report 97-4189. This study report is included
in the Applicant's April 14, 2003 AIR response to the Commission as Appendix
Seven (AIR 7). Data in this study indicates that peak flows entering Sebago
Lake during the October 1996 flood event were equivalent to less than that
of a 10-year flood.
During the October 1996 flood event, extreme precipitation was largely confined
to the Presumpscot River watershed below Sebago Lake, as illustrated in
the study at p. 19, Figure 10. The study shows that during the 1996 flood
event, peak flows at two tributaries feeding Sebago Lake did not exceed
a 10 year flood occurence. The study at p. 18, Table 2, shows that during
the 1996 flood, flows at the Crooked River in Casco and Naples were 2,810
cfs, approximating a 4-year flood, and flows at Stony Brook in Sebago were
106 cfs, approximating a 7-year flood. As such, the 1996 flood event does
not -- as the Applicant asserts -- represent the ability of the existing
Sebago lake level management plan to attenuate a 25-, 50-, 100-year or greater
flood event occuring within the Sebago Lake watershed above the Eel Weir
Dam.
There is no evidence to support the Applicant's assertion that, "It
is well documented that flood issues on the Presumpscot River come from
the unregulated drainage area downstream of Sebago Lake." It is entirely
possible a precipitation event of the magnitude observed in the watershed
below the Eel Weir Dam in October, 1996 could occur in the watershed above
the Eel Weir dam in the future. Maintenance of lake levels at Sebago Lake
well below the spillway crest of the Eel Weir dam would greatly assist efforts
to attenuate lake outflows during such a flood event.
The Applicant's statement that in October 1996, Sebago Lake rose three feet
in response to a less than 10-year flood event in the watershed above the
Eel Weir Dam further demonstrates the value of lower lake levels to provide
sufficient storage capacity in Sebago Lake to attenuate downstream flooding.
Had the October 1996 flood event occurred earlier in the season, when lake
levels are kept much higher than in late fall, the Applicant's ability to
attenuate flood flows at the Eel Weir dam would have been significantly
diminished.
Lastly, we wish to provide the Commission with new historical information
which refutes the Applicant's assertion at AIR 7, p. 4, that, "The
fishery of Sebago Lake could be negatively affected by reduced lake levels.
Effects could include reduced access to tributaries for smelt spawning,
and possibly for other species."
A petition of residents of the Crooked River, dated 1800, describes a very
healthy native salmon fishery in Sebago Lake, with salmon as large as seventeen
pounds. This document proves that when Sebago Lake was undammed, unregulated
and had lake levels much lower than today, the lake's native fisheries were
far healthier than today. Since native rainbow smelt in Sebago Lake are
the principal forage of its native lake-dwelling Atlantic salmon, this historic
document shows that prior to damming and lake level increases, Sebago Lake
and its tributary streams provided spawning opportunities for rainbow smelt
sufficient to sustain a native salmon population of far greater quality
than known today.
The petition reads:
"Petition of inhabitants of Crooked River -- 1800
To Honorable the Senate and the House of Representatives of the Commonwealth
of Massachusetts, in General Court assembled:
The petition of the subscribers inhabiting near Crooked river humbly showeth
that in said river is a kind of trouts of an uncommon size, weighing from
three to fourteen pounds. Some have been caught which weighed seventeen
pounds. These fish run up the river in the months of September and October,
but are scarce at all other times of the year. They have been, and might
continue to be, very beneficial to all who inhabit near said river, which
runs from a pond in Oxford, near Bethel southerly line; from thence it runs
through said Oxford and through Waterford, a part of Norway and Phillip's
Gore, Otisfield, and a part of Raymondtown into a gore between Raymondton
and Flintston, where it falls into Songo River and with it into the Great
Sebago pond. These fish have for several years been prevented from passing
up said river by wares built wholly across the water by inhabitants near
the mouth thereof, and as there is no law to prevent them, they not only
boast of having availed themselves for all the benefit of the fish in years
past, but declare they are determined to do it in future, to the great injury
of the other inhabitants above them, who have (or ought to have) equal right
to the benefit of the fish. We therefore humbly request your Honours to
take the case into your consideration, and to make a law for preventing
the obstruction of these fish in said river and its connections in the months
of September and October, and as in duty bound will ever pray."
Petition signed by Asael Foster and 28 others.
Source: Maine Fisheries Commissioners Report for the Year 1884. Maine Public
Documents, 1884, Vol. 1. Maine State Archives, Augusta, Maine.
Sincerely,
Douglas Watts
Friends of Sebago Lake
CC: Service List
Friends of Sebago Lake
P.O. Box 445, Casco, ME 04015 · www.friendsofsebago.org
June 16, 2003
Ms. Magalie Salas, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C. 20426
RE: Eel Weir Dam Project (FERC No. 2984)
Dear Ms. Salas,
On February 14, 2003 the Commission sent S.D. Warren, the Applicant for
the above mentioned project, an Additional Information Request (AIR) .
Friends of Sebago Lake (FOSL) has recently found correspondence from S.D.
Warren to the Commission dating from 1989 regarding the flood prevention
capabilities of the Eel Weir Dam. An original and eight copies of this
correspondence are enclosed. This information appears to be pertinent to
the Commission's February 14, 2003 AIR regarding the flood storage capabilities
of the Eel Weir Dam.
In this correspondence, S.D. Warren states of the Potential Maximum Precipitation
(PMP) estimated for Sebago Lake:
"The PMP determined for Eel Weir is 18.45 inches of rain in a 24 hour
storm. Never, in the recorded history of this region, has this figure been
approached."
According to the study titled Flood of October 1996 in Southern Maine.
U.S. Dept. of the Interior and U.S. Geological Survey, Water Resources Investigation
Report 97-4189, up to 19.19 inches of rain fell on the region just below
the Eel Weir Dam on October 20-22, 1996.
Regarding what S.D. Warren should do at the Eel Weir Dam if a large flood
occurs, the company asks the Commission in its letter: "With this amount
of water, the decision must be made -- whom do we want to flood? Should
we try to hold the entire PMF in Sebago Lake and inundate the majority of
camp and home owners around the lake, or should we pass the PMF flow down
stream and flood the down stream camp and home owners?"
The issues raised by S.D. Warren in this letter affirm our organization's
belief that a lower lake level at the Eel Weir Dam would be very helpful
to reduce such flooding and associated property damage.
Sincerely,
Douglas Watts
for Friends of Sebago Lake
CC: Service List
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