Hollis Select Board Transparency Archive

PH7PR19MB5895E6B64AE591FD0196872BB3ED2

memo on Brookfield

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• Renee Lewis <[email protected]>

To

• Jim Boutin ([email protected]) <[email protected]>
• Terry Walters <[email protected]>
• Paul Mattor <[email protected]>
• Richard Morin <[email protected]>
• Dan Yarumian <[email protected]>
• Mark Woodruff <[email protected]>

Date

Wed, Jun 24, 2026 · 6:09 p.m. ET

• Brookfield_Renewable_US_Disposals_with_Locations_2015-2025 (4).docxOpen original

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  Brookfield Renewable US Asset Disposals — Ledger with Locations, 2015–2025 US-located disposals, including orphaned / non-core sales. Locations are as named in filings and contemporaneous reporting; “not disclosed” means the company did not specify states or sites. Compiled June 2026. ◆ HYDRO SPOTLIGHT — IDENTIFIED The two large hydro portfolios both resolve to the same asset: Smoky Mountain (formerly Tapoco) — four dams (Cheoah, Santeetlah, Calderwood, Chilhowee) on the Little Tennessee and Cheoah Rivers across east Tennessee and western North Carolina, FERC Project No. 2169. Brookfield bought it from Alcoa for $600M in 2012, sold 50% to Argo Infrastructure Partners in 2023, and sold the remaining 50% across 2025–early 2026 to fully exit. “Non-core” reflects portfolio fit, not asset quality: Smoky signed a 10-year TVA offtake (2024) and supports a $435M private placement (2025). The 30 MW plant (2024) remains unidentified by state. None was sold at a loss.

  Year Asset &amp; capacity Location (as disclosed / identified) Buyer Gain / loss &amp; notes 2015 Wind facility — 102 MW California Third party (not named in filing) Gain $53M ($12M net). BEP held 22%. 2016 — none identified — — Acquisition year (Isagen; Holtwood/Pennsylvania hydro). 2017 — none identified — — Acquired 51% of TerraForm Power. 2018 — none identified — — Raised TerraForm stake to 65%. 2019 — none identified — — Disposals were Europe / Asia / South Africa. 2020 Wind portfolio — 852 MW (40% interest) United States (states not disclosed; TerraForm-era assets) Not disclosed in filing FFO impact $15M, 760 GWh. Blended w/ Ireland. 2021 Wind portfolio — 391 MW (4 farms) California (Alta Wind VIII 150 MW, Windstar 120 MW, Coram 22 MW) + New Hampshire (Granite 99 MW) NextEra Energy Partners Mature onshore wind; ~2x invested capital. 2022 — none in US — (US held-for-sale building up) — Year&apos;s disposals were Asia solar (19 MW). 2023 Q1 ◆ HYDRO — 378 MW Smoky Mountain (78% interest) TN &amp; NC — Cheoah, Santeetlah, Calderwood, Chilhowee dams (Little Tennessee / Cheoah Rivers; FERC P-2169) Argo Infrastructure Partners (50%) + Brookfield Corp affiliates (28%) Deconsolidated. BEP kept 22%, no proceeds. 2023 Q2 Wind assets (acquired 2022) United States (not further specified) Not disclosed Quick resale of recently acquired wind. 2024 Q2 ◆ HYDRO — 30 MW asset United States (single plant; state not disclosed) 3rd party + institutional partners Gain $29M ($6M net). Sold above book. 2024 Q2 Battery storage — 60 MW United States (state not disclosed) 3rd party + institutional partners Gain $5M ($2M net). 2024 Wind — 845 MW (partial; Shepherds Flat) Oregon (repowered onshore wind) Institutional buyer (50% across 2024–25) One of largest US wind repowerings. 2025–26 ◆ HYDRO — 403 MW Smoky Mountain, remaining 50% TN &amp; NC — same four dams as 2023 (full exit of the system) 3rd party (25%) + BAM-managed fund (25%) “Non-core” = portfolio fit, not quality. TVA PPA + $435M financing in place. 2025 Distributed generation — 700 MW United States (multi-site; Luminace-related) 3rd party (47%) + BAM-managed fund (53%) Part of majority Luminace exit. 2025 Solar portfolio — 833 MWdc (613 MWac) United States (sites not disclosed) Not disclosed Agreed subsequent to Q3 2025. 2025 Solar — Deriva platform United States (sites not disclosed) Not disclosed ~$400M ($70M net). Closed Q1 2026. 2025–26 Wind &amp; solar — ~2,300 MW (two-thirds) United States (dev-platform-built; sites not disclosed) Buyer consortium (framework w/ recurring sales) Closes H1 2026; +$1.5B future framework. Amber rows (◆) = hydro disposals. “BAM-managed fund” = a private fund managed by Brookfield Asset Management (an affiliate); such partial sales are stated to be at the same value agreed with the unaffiliated third party. Ranges reflect figures refined between quarterly filings. Notes on location disclosure A key finding for your geographic focus: Brookfield discloses asset location only sparingly in its own filings. The disposal notes almost always read simply “in the U.S.” without naming states, rivers, or plants. Where precise locations appear in this ledger, they generally come from the buyer’s disclosure or trade-press coverage, not Brookfield’s. The standout example is the 2021 sale to NextEra, which named all four wind farms and their states. Where locations are firmly established 2021 — 391 MW wind to NextEra Energy Partners ($733M): Alta Wind VIII (150 MW), Windstar (120 MW) and Coram (22 MW) in California, plus Granite (99 MW) in New Hampshire. This is the most geographically precise US disposal on record. 2024–25 — the 845 MW Shepherds Flat wind sits in Oregon. 2015 — the 102 MW wind facility is in California. Where location was recovered through triangulation The two large hydro portfolios (2023 and 2025) were disclosed by Brookfield only as “in the U.S.,” but both were identified as Smoky Mountain by cross-referencing the buyer (Argo Infrastructure Partners), the offtaker (a 2024 TVA power-purchase agreement that named all four dams), the lenders (a 2025 $435M private placement), and a sister Brookfield fund’s holdings table that lists “U.S. Hydro (Smoky Mountain).” The capacity figure (377–403 MW) was the thread tying the vague filing to the named asset. The 30 MW plant (2024), the 2020 wind, and the 2025 solar/DG portfolios remain unspecified as to site — those would need the same buyer-or-FERC reconstruction. Geographic pattern that emerges US wind disposals cluster on the West Coast / mountain-West (California, Oregon) with one Northeast outlier (New Hampshire). The identified hydro disposals both sit in the Tennessee Valley / western Carolinas (the Smoky Mountain four-dam system) — a cluster somewhat apart from Brookfield’s larger Northeastern, New York and Maine hydro concentrations, which is the most likely reason it carried the “non-core” label. FERC license surrenders &amp; decommissioning by Brookfield entities Separate from sales, you asked which Brookfield Renewable entities have not renewed a FERC license or moved to decommission a plant. These are concentrated in Maine and are matters of relicensing conflict rather than asset sales. The clearest cases: ▸ Bar Mills (FERC No. 2194), Saco River, Hollis, Maine — Brookfield White Pine Hydro filed a notice of intent to surrender the license on Nov 30, 2020, the first step toward decommissioning. The units had not run for three years; a surrender application and decommissioning plan (partial dam breach) followed. This is the most clear-cut voluntary surrender — driven by an inoperable, uneconomic-to-repair plant. ▸ Ellsworth Project (Union River &amp; Graham Lake dams), Maine — operated by Black Bear Hydro Partners. Its last license expired in 2017; it has run on annual temporary licenses since. Maine DEP denied the required water-quality certification (2020, and a draft denial again in 2025), and the company has said removal of the Ellsworth and Graham dams “may be an unfortunate but necessary outcome.” Not yet surrendered, but relicensing is in serious jeopardy — a possible forced (non-voluntary) decommissioning. ▸ Lower Kennebec dams — Shawmut (FERC No. 2322), Lockwood, Hydro-Kennebec, Weston, Maine — operated by Brookfield White Pine Hydro, Merimil LP and Hydro Kennebec LLC. State agencies (Maine DMR, NMFS) and a 2020 Kennebec River Management Plan amendment have pushed to remove these four dams over endangered-fish concerns; Maine DEP denied water-quality certification for Shawmut’s relicensing. Brookfield has litigated to block removal (including a D.C. Circuit case and an injunction against Maine DMR). Contested and unresolved — relicensing opposed, removal not yet ordered. Focus risk: Bar Mills retained powerhouse &amp; the municipal abandonment problem The Bar Mills surrender carries a specific long-tail risk worth isolating. BWPH is not fully removing the project. Per its own plan, it will retain the powerhouse (1956 structure; original project 1919) “for operational purposes, such as materials and equipment storage and office space,” and will leave a portion of the spillway and the entire eastern half of the dam in place. The powerhouse will not be demolished; no soil testing is proposed around it for that reason. The mechanism that creates the risk: per BWPH’s own FAQ, “once the surrender application has been approved by FERC, there is no longer a FERC project boundary.” When surrender is granted, FERC’s safety and financial jurisdiction ends entirely. The retained powerhouse, spillway remnant and water-retaining structures become ordinary private real estate under state/local authority only. There is no FERC decommissioning bond, no federally-mandated maintenance trust, and no federal obligation that runs with the land to a future owner. BWPH’s maintenance duty binds BWPH under the FERC-approved decommissioning plan — it is not clearly a perpetual covenant enforceable against a downstream purchaser after federal jurisdiction terminates. So the scenario of concern is real: if BWPH (or a successor Brookfield entity) later sells or abandons the parcel to a thinly-capitalized buyer that cannot fund upkeep or removal of an aging, partially-breached dam and powerhouse, the residual liability could fall to the municipality. Enforceability would depend entirely on state dam-safety law and whatever deed covenants exist — not on FERC. The retained structures are not liability-free. The un-removed eastern dam sits adjacent to the Rogers Fibre Mill EPA Superfund site, and its concrete foundation is itself a water-retaining structure FERC required inside the project boundary. Decommissioning also affects municipal infrastructure (the Canal Road dry hydrant, which BWPH proposes to relocate in consultation with Hollis). Geographic nuance: the exposure is split between two towns. The retained powerhouse and BWPH-owned access road, parking and canal lands are on the Hollis side; the un-removed eastern dam portion and the adjacent Superfund parcel are owned by the Town of Buxton. Hollis’s exposure centers on the powerhouse and western structures BWPH retains; Buxton carries parallel exposure on the eastern remnant on its own land. A small town’s inability to absorb future maintenance or removal cost applies to both, and is not addressed by any federal financial-assurance mechanism in the surrender process. Potential mitigations a stakeholder could pursue (not legal advice): request, during the open FERC surrender docket, that the decommissioning order condition approval on (a) a funded maintenance/removal escrow or surety that survives transfer, (b) recorded deed covenants binding successors-in-interest to maintain or remove the retained structures, and (c) a state dam-safety registration that names a financially-responsible party. These are the kinds of conditions that, if not imposed before surrender is granted, become very difficult to attach afterward — because FERC jurisdiction will have ended. Is the Hollis fear precedented? Comparable cases The concern — an aging dam/powerhouse passing to an owner without the balance sheet to maintain or remove it, ultimately landing on the public — is a documented failure mode, not speculation. The enabling structure is the single-purpose LLC holding one hazardous structure with no parent guarantee. Key precedents: ▸ Cheboygan, Michigan (closest analog). A hydro powerhouse adjoining a shuttered tissue factory passed through a series of private owners to a thinly-capitalized LLC (Hom Paper XI). The powerhouse went offline after a 2023 fire; by 2025–26 FERC had ordered the owner to restore it or surrender its licensing exemption, but the owner won repeated extensions while trying to sell to another small entity (HydroMine). During this limbo the high-hazard dam nearly overtopped in a flood. Ownership was split between the state (which owns the 1922 dam) and the private LLC (the powerhouse) — structurally identical to a town/Brookfield split. ▸ Boyce Hydro / Edenville Dam, Michigan. The canonical case: an under-capitalized owner repeatedly stalled on FERC-ordered safety upgrades, then the dam failed catastrophically in 2020, flooding Midland. A Michigan dam-safety official linked Cheboygan, Boyce (Tittabawassee) and Renewable World Energy (Au Train) as the same pattern — owners that stall on FERC orders, then declare bankruptcy amid a safety crisis. ▸ Morrow Dam, Michigan (STS Hydropower / Eagle Creek). A single-purpose LLC owned the dam and surrounding land; a mismanaged reservoir drawdown sent hundreds of thousands of cubic yards of sediment ~30 miles down the Kalamazoo River, at the head of a PCB Superfund site. Demonstrates the thinly-capitalized-entity-plus-contaminated-neighbor profile — the same combination present at Bar Mills (retained powerhouse adjacent to the Rogers Fibre Mill Superfund site). Industry backdrop: a 2020 survey found ~30% of hydro dam owners are considering decommissioning rather than relicensing, with economics the primary driver. Many FERC-regulated dams are old, uneconomical and have become liabilities — so the volume of aging structures changing hands is rising. Does Brookfield itself show this pattern? No completed case of Brookfield abandoning a surrendered structure to a municipality was found. But three Brookfield-specific patterns make the Hollis concern credible rather than far-fetched: 1. It uses the exact spin-out structure now. In the 2025 sale of four lower Kennebec dams to The Nature Conservancy ($168M), Brookfield asked FERC to transfer each dam’s license to newly created Brookfield-owned holding companies as a step to facilitate the sale. Spinning dams slated for disposal into single-purpose holding entities is precisely the structure that worries Hollis. The Kennebec buyer (a well-funded conservancy forming the Kennebec River Restoration Trust) is strong — but the same structure with a weaker buyer is how a Cheboygan happens. 2. It sheds these assets explicitly to escape cost. Brookfield told Maine regulators the Kennebec sale was motivated by an “increasingly complex, expensive and uncertain regulatory landscape,” calling required fish passage “prohibitively expensive” and “arguably unattainable.” Cost-avoidance is the stated disposal motive — consistent with holding a non-productive powerhouse only until offloading is convenient. 3. It has minimized obligations on an uneconomic asset before. In New York, Brookfield suspended payments to the Hudson River–Black River Regulating District for the head the Conklingville Dam provides to its E.J. West plant — cutting that revenue ~97% — triggering demand letters and a FERC dispute. A live example of Brookfield minimizing financial obligations when a hydro asset’s economics turn. Counterweight (in fairness): in the Kennebec deal Brookfield agreed to keep maintaining all four facilities under long-term operating agreements through the multi-year decommissioning — i.e. retaining responsibility through transition rather than dumping it. And unlike a Boyce Hydro, Brookfield has a real balance sheet and significant reputational exposure in Maine (it generates ~87–90% of the state’s hydropower). Its hundreds-of-entities structure cuts both ways: it could isolate liability in a shell, but Brookfield also has assets and standing that a failed micro-operator never did. Bottom line: the feared outcome is a documented industry failure mode (Cheboygan, Boyce/Edenville, Morrow), it is enabled by the single-purpose-LLC structure Brookfield is actively using (Kennebec), and Brookfield has shown willingness to shed uneconomic hydro obligations. What is absent is a completed Brookfield abandonment-to-a-town. That argues for a preventive posture: secure transfer-surviving financial assurance in the Bar Mills surrender order now, while FERC still has jurisdiction — not after it ends. Honesty caveat: this list is built from Brookfield’s project websites, the Federal Register, FERC court-case pages, and Maine news coverage — not from a complete docket-by-docket sweep of FERC eLibrary, which my tools can’t fully query. It captures the prominent, publicly reported Maine cases; there may be smaller surrenders (e.g. minor exemptions or sub-1-MW projects) elsewhere in Brookfield’s ~38-dam Maine fleet or other states that aren’t surfaced here. A definitive list would require a direct FERC eLibrary search on each Brookfield licensee entity (Brookfield White Pine Hydro, Black Bear Hydro Partners, Merimil, Hydro Kennebec, Erie Boulevard Hydropower, and others). Confirmation status Hydro identifications (Smoky Mountain) are confirmed across buyer, offtaker, lender and Brookfield-fund sources. Wind locations for 2015, 2021 and Shepherds Flat are confirmed. “Not disclosed / not identified” entries reflect genuine absence of public detail. The FERC decommissioning cases are confirmed as reported but the list is not guaranteed exhaustive (see caveat above). Sources: Brookfield Renewable / BEPC annual reports and Form 6-K interim reports 2015–2025 (SEC EDGAR; bep.brookfield.com); NextEra Energy Partners, Argo Infrastructure Partners, TVA and Brookfield Infrastructure Income Fund disclosures; trade press (Renewables Now, IPE Real Assets, Daily Energy Insider); FERC (federalregister.gov, ferc.gov, MBR/eTariff guidance, court-case pages) and the Bar Mills project site (barmills.brookfieldusprojects.com — FAQ, Draft/Final Study Plans, FERC No. 2194); comparative cases from Bridge Michigan and Detroit News (Cheboygan), American Rivers Practitioner’s Guide to Hydropower Dam Removal, Michigan AG filings (Morrow Dam), The Nature Conservancy and Central Maine / Bangor Daily News (Kennebec sale), and HRBRRD (Conklingville / E.J. West); plus Maine municipal and news sources (Town of Hollis, Town of Buxton, Ellsworth American, Mainebiz, Portland Press Herald, NewsCenter Maine). Informational summary, not legal or investment advice.