The Maryland Department of the Environment public comment period for the Conowingo Dam Water Quality Certification renewal closed on Jan 15. The MDE certification is mandatory before Exelon reapplies for federal relicensing. (They have requested a 46-year lease term without any significant changes in how they operate.) This will set a precedent for the federal relicensing process. Here are our concerns:
We own and operate commercial oyster aquaculture operations in the Upper and Middle Bay regions, respectively. Through careful record-keeping, and discussions with those most knowledgeable with the dam’s operation, we feel its openings and closures have a direct and profound effect on our businesses and the aquaculture industry, as well as the public oyster fishery.
We have witnessed severely depressed salinity levels in the Bay and its tributaries, directly after extended high-flow freshwater output from the dam. These low levels of salinity negatively affect our oyster’s survival, growth rates and flavor, as well as jeopardize our nursery and hatchery operations. In addition, the regular sediment spillovers can increase mortality, even for oysters raised off the bottom. These conditions also negatively affect the public oyster fishery, arguably to an even greater degree, given the lesser ability to control growing conditions.
These are just our small observations on how the current operation of the dam has negatively impacted our businesses. The high, late winter-summer flow levels from the dam disrupt and impact all downstream Bay species during critical annual spawning periods. Oysters, unlike other finfish and shellfish, cannot move to evade low salinity, low dissolved oxygen or sedimentation. Neither can farm operations, which are tied to leased bottom/water. Their ecological services provide a public benefit for all.
Exelon must take these concerns into account when operating the Conowingo Dam. There needs to be a more transparent opening/closure schedule. There needs to be more public input — from all relevant stakeholders — on both the schedules and rate of flow emitted.
A 46-year lease term without periodic public comment/review is also unacceptable. Without a formal public input process in place, there is less incentive for the public and those operating commercially in the Bay to become valued stakeholders. The dam is the single largest emitter of nutrient-laden freshwater from a single point-source in the Bay. With such scale, public input is essential, given the externalities it generates. And Exelon, as the largest electric holding company and largest regulated utility in the United States, owes it to the public to be beholden to more than just the bottom line.
Owner, Orchard Point Oyster Co.
Founding Partner, Hooper’s Island Oyster Co.