Date: 1/3/2004
From: Harold W. Tomlinson
Re: Comments on the Hudson River Flow Regulation Benefit Study Final Report, July 2003
I am writing this letter to point out inconsistencies in the reapportionment analysis presented in the "Hudson River Flow Regulation Benefit Study Final Report" dated July 2003, written by Gomez and Sullivan Engineers, PC. The inconsistencies result in a gross overestimate of the benefit to lake recreation and real estate values as compared to hydroelectric power. I believe these inconsistencies need to be corrected before any decisions regarding district policy are based on this study.
To perform a fair reapportionment analysis of the benefits derived by regulating the Sacandaga River, the same assumptions need to be applied to all beneficiaries. Unfortunately, the base assumptions made for the hydroelectric power analysis are not the same as the assumptions made for lake recreation and real estate values.
As stated on page (4) of the report, hydroelectric power generation was analyzed under two scenarios, "the first scenario reflected the operational conditions set forth in the settlement agreement for the Upper Hudson/Sacandaga River Offer of Settlement Agreement. The second scenario reflected run-of-river operation at Great Sacandaga Lake." However, the run-of-river scenario assumes the Conklingville dam exists. If the Conklingville dam did not exist, there would be no power generation at the Sacandaga power plant, as can be seen from the equation on page (5) of the report.
P=Q* Hnet* G sys/11.8
Where:
P= Power (kW)
Q= Turbine Discharge (cfs)
Hnet= Net Head (ft), which is equals the headwater minus tailwater minus headlosses
G sys= Station Efficiency (%)
11.8= Constant for English/Metric conversion
Without the dam, Hnet would be nearly zero since no headwater would be available, and power generation would be unfeasible.
However, the benefit analysis for lake recreation and real estate was done under a different set of scenarios. As stated on page (3) of the report, "the increased real estate benefits derived from the Great Sacandaga Lake would be the difference between current property values and property values without the reservoir." Property values without the reservoir assumes the Conklingville dam does not exist. But the dam, and the resulting Sacandaga Lake do exist.
The fact is, flow regulation of the Hudson River via the Conklingville dam is of no benefit to lake recreation and the property owners around the Sacandaga Lake unless it provides consistency in the lake level. Lake level, not flow rate, is the benefit. Since the Upper Hudson/Sacandaga River Offer of Settlement Agreement is designed to keep lake levels higher during September and October, the incremental benefit for lake recreation and property values should be based on these months, not the whole year. However, poor regulation of lake level can negate even this benefit, as demonstrated by the shore damage created by the extremely high lake levels in 2003.
As stated in the report, "Title 21 of Article 15 of the New York State Environmental Conservation Law requires that the cost of operation of the District's reservoirs be apportioned upon any public corporation or parcel of real estate benefited." Since the cost of operation of the Conklingville dam does not include building the dam, the benefit analysis should be based on the benefit and cost related to regulating river flow, not whether the lake exists or not. Under this assumption, the benefit to lake recreation and property values would be a small percentage of that presented in the report (no more than 2/12), and may be less since fall recreation levels are much lower than those during the summer months.
I hope the regulating district revises the benefit analysis based on this input.
Sincerely,
H. W. Tomlinson