You should generally ask FERC to include a “No Project Alternative” as an action alternative in its NEPA analysis. Since the status quo, including the original license for a project, is the environmental baseline for such analysis (see American Rivers v. FERC, 201 F.3d 1186, 1195 (9th Cir. 1999)), this action alternative permits FERC and the parties to evaluate future conditions without the project. This assists to segregate the project from other facilities and activities which affect natural resource values in the watershed. Where you have no actual interest in pursuing decommissioning as the licensing decision, you should clearly state that your request for the action alternative is solely intended to assure that FERC understands the project's contribution to existing conditions, so that mitigation is proportional to that contribution. Clarity about your intent is very important, since FERC and the licensee otherwise will view this request as a camel's nose in the tent (namely, as your effort to compel them to develop the record for decommissioning as the actual relicensing decision).

You may decide to advocate some form of decommissioning as the relicensing decision, in circumstances where you believe the resulting restoration of natural resource values is the best or only method to comply with Section 10(a) and other applicable law, bearing in mind that it will also result in loss of generation capacity. This is a fight that you should not start unless you have a very substantial basis in evidence and law - for example, because the project has marginal economic value for the licensee, or where the project cannot comply with water quality standards no matter what the mitigation. Bear in mind that a request for decommissioning as the relicensing decision will start a fight not just with an unwilling licensee, but also with the owners of any residential or commercial facilities around the reservoir. For more information about dam removal and strategies for achieving removal, go to http://www.americanrivers.org/.