Does FERC still require recreation monitoring?
After the December 20, 2018 Final Rule eliminating the FERC Form 80, under what circumstances does recreation use monitoring still need to occur? This is a common question I receive from Licensees. To answer it, I refer to page 12 of the Final Rule at 20:
“… unless recreation reporting is required by a license condition – including any approved recreation plan or report or mandatory agency condition – licensees will no longer have any specific recreation use reporting obligation once the Form 80 is eliminated.”
Some recreation plans only include language about Form 80 recreation monitoring reporting. However, if the license article requiring the recreation plan did not include a requirement for recreation use monitoring or reporting, there would no longer be a need for recreation use and monitoring after elimination of the Form 80.
If you’d like to discuss this or other Federal Energy Regulatory Commission hydropower licensing related concerns, please give me a call. I am committed to providing clients informed guidance on this and future FERC developments.
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