A February 25, 1993 filing before the Federal Energy Regulatory Commission by the Maine Bureau of Parks and Recreation states that by 1990 the alterations in Sebago Lake water levels made by S.D. Warren beginning in 1987 had toppled large trees and substantially eroded and reduced the width of Songo Beach at Sebago Lake State Park. This official filing states in part:

"Lake water levels in recent years, particularly after 1986, have been higher for longer periods of time in the summer and fall (Attachment #3). We believe this had three effects on the state park day-use area: a loss of beach width from the historic 25 foot to 30 foot to the recent 5 foot to 10 foot (Attachment #4); erosion of the shoreline and undercutting and loss of shoreline trees (Attachment #5); and loss of sand volume as water levels have not been low enough during the summer and fall to permit progradation of beach sand ....

"It is the Bureau's belief that a substantial departure from the lake water level management of the 80 year period has occurred resulting in substantial alterations to use of project lands in the period from 1987 to present and occurs under S.D. Warren's management from 1987 to 1990 and under the Maine Department of Environmental Protection's recommendations of 1991 and 1992.

"S.D. Warren spokesmen have indicated at public meetings that summer and fall levels were raised in 1987 to benefit two users of project lands and waters: private marina and boating interests which experienced reduced activity during the previous drought season, and the Company itself which could store summer and fall water to generate and sell more power in the winter under recently increased winter rates. However benign its intent, this decision ignored other users of project lands and waters with adverse effects such as beach loss and erosion. Moreover, the Company's decision granted a primacy to private marina and boating interests in the recreational use of the lake which neither existed nor was proposed in the application which the Company submitted to the Bureau for review in 1979."

A letter dated February 20, 1992 from Cindy Bastey of the Maine Bureau of Parks and Recreation states: "Recent information, together with Portland Water District historical water level records and the recollections of Bureau personnel who have worked at the park over the years provide a reasonable basis to suggest that the beaches were wider by perhaps as much as 15-25 feet in the past .... We believe the beach configuration is not the same as it was in earlier years and that a considerable amount of sand has eroded away. This is supported not only by the recollections of park employees but by photographs of the area in question." [emphasis in original]

A letter dated November 3, 1994 from Maine Bureau of Parks and Recreation director Herbert Hartman to Mr. William Foley of S.D. Warren states: "That BPR has lost a substantial amount of beach at Songo Beach at Sebago Lake State Park has been acknowledged by a number sources identified in our original presentation to you. We believe a water level management plan which closely mirrors the historic lake level conditions under which the beach was maintained for many years will be the least costly form of mitigation of beach loss."