Comments of American Whitewater and California Sportfishing Protection Alliance on FERC's Notice of Proposed Rulemaking concerning the application of categorical exclusions under the National Environmental Policy Act under RM26-7.

Summary: American Whitewater and the California Sportfishing Protection Alliance oppose the proposed Categorical Exclusion for hydropower license terminations or revocations. They argue that exempting these actions from NEPA review fails to consider decommissioning alternatives, prevents the Commission from making informed public interest determinations, and creates a negative incentive for orderly project surrender.