Why does FERC want comments on a form nobody fills out unless a dam closes?

The form that appears when a project ends

A hydropower license from FERC can last decades. When the owner decides to stop — maybe the turbine is shot, the economics collapsed, or a flood took the dam — they file FERC-510. That application triggers a public notice, an environmental review, and eventually an order that spells out what must be cleaned up, removed, or left in place. The form itself is short. The consequences are not.

How the burden math works

FERC estimates ten licensees a year will file. Each spends about eighty hours assembling the data: project maps, safety inspections, environmental studies, consultation records. At one hundred two dollars an hour — the agency's own FY 2026 fully loaded rate — that comes to eight thousand one hundred sixty dollars per filing. Eight hundred hours total across the country. Eighty-one thousand six hundred dollars total. The numbers are precise because the Paperwork Reduction Act demands them. They do not include legal fees, consultant reports, or the months of back-and-forth that often follow.

The burden table assumes one response per respondent per year. Reality sometimes delivers zero for years, then three in one month. The eighty-hour figure is an average. A complex site with sediment contamination and endangered species can run far higher.

What the comment window actually covers

Remarks are invited on four points: whether the collection is necessary, whether the hour estimates are realistic, whether the form could be clearer, and whether technology could cut the workload. FERC is not proposing changes. The agency is required to ask anyway. Comments are due October 30, 2026. They go to DataClearance@FERC.gov with docket number IC26-42-000 and collection number FERC-510 in the subject line. Paper mail works too, sent to the Secretary at 888 First Street NE, Washington, DC 20426.

Who files and why it matters

Only non-federal licensees — private companies, municipalities, irrigation districts — use FERC-510. A surrender order can require dam removal, fish passage restoration, or long-term monitoring. The application is the first time the Commission sees the full picture of what the owner plans to leave behind. If the form misses something, the review stalls. If the owner underestimates cleanup, the public bears the risk. The current version has been in place since the last renewal. No one has suggested a shorter path.

Where the process stops being paperwork

The notice does not say how many licenses are currently active, how many are idle, or how many owners are quietly preparing to file. It does not list recent surrenders or their outcomes. The form does not change. The conditions on the ground do.