"As I understand it, they (the two FERC solicitations for comments) are VERY different, and even worse.  The first FERC solicited comment response was based upon FERC's prior Order for PacifiCorp to be a co-licensee as a condition of potential License Transfer, though at the time FERC said if anyone could figure a way to indemnify PacifiCorp as a co-licensee from responsibility for any damages, that would be Hokey-Dokey with FERC (nice fellers).  However, PacifiCorp knew better, and flatly refused to do so, instead presenting FERC with an incomplete 'Agreement' with the States of CA and OR to instead have the States act as co-licensees with KRRC, thereby throwing ALL of the cost to shield PacifiCorp and 'Agreement' signatories from ANY accountability for damages caused the very public being unwillingly forced to pay for it.  On top of that, PacifiCorp and KRRC essentially DEMANDED that FERC immediately 'expedite' approval not only for License Transfer, but now License Surrender as well, setting in stone acceptance of unaccountability, inadequate funds, essentially blow and go 'value engineered' authority, and assured destruction REGARDLESS of any 'later' determined EIS.  Of course, only out of the goodness of their hearts, KRRC SUPPLIED FERC with 'their version' of an 'indexed reference' (to kindly 'spare FERC from having to receive voluminous studies') of THEIR already outdated and now empirically proven defective 'modeled science'.  Thereby, FERC could simply 'look over' that referenced list in order to approve their EIS NOW, and 'make revisions later' as they see fit during the 3 years KRRC will be simultaneously irreversibly destroying the Project reservoirs, dams, environment, public safety, economic stability, and private and public property.  Of course, since 'approval' would already be granted, any 'revisions' could ONLY happen in context conforming to both pre approved devastation and the already exhausted available funds.

 

Rex Cozzalio, Hornbrook, CA on the Klamath River