June 22, 2020

John Greenan, P.E.
Green Mountain Power
2154 Post Road
Rutland, VT 05701

Re: CRC comments on the Newbury hydroelectric project (P-5261) Study Reports

Dear John,
The Connecticut River Conservancy (CRC), has reviewed the Newbury hydro-electric facility 2019 Study Season Reports dated May 2020. We have no comments on the Water Quality Study Report or the Freshwater Mussel Survey.

In the cover letter, GMP indicates, “Over the course of the upcoming 2020 field season, GMP plans to complete its Bypass Reach Habitat Evaluation and Aesthetic Flow Study, Cultural Resources Assessment, and schedule a site meeting [emphasis added] to discuss potential enhancements to the Wells River Wildlife Area (owned by the Vermont Division of Fish and Wildlife) located upstream of the Newbury Dam.”

While not indicated in the cover letter, CRC also commented on the proposed study plans on June 14, 2019. As stated in that letter, CRC requested that GMP have that site meeting open to the public and that GMP do direct outreach to the local recreational community,
“Given the circumstances, CRC is not opposed to the absence of a formal recreational study but we would strongly encourage GMP to engage the local community on recreational needs. It is our understanding that in addition to the Wells River Wildlife Area, there is a public rail trail, there may be issues with the portage for boaters getting out of the river at the head of the impoundment, and there is an information kiosk owned by the town adjacent to the Wells River at 5 Railroad Street that also might benefit from some enhancements.”

Additionally, in their comments on the Proposed Study Plan dated June 14, 2019, VT DEC stated,
“… it is uncertain whether enhancing access at the nearby Fish and Wildlife Access Area will adequately address recreational needs for Wells River near the project. For example, the whitewater boating community recently informed the Agency of the annual whitewater Wells River Rumble, and specifically identified the challenges with the boat takeout at the head of the Project impoundment. Therefore, the Agency suggests that GMP identify and discuss alternative recreation enhancement opportunities, including boat access within the impoundment, with a broader group of
relevant stakeholders.”

Both VT DEC and CRC requested open meetings and engagement with public to ascertain what the local community sees as recreational needs in the project area. CRC welcomes the invitation to be involved in this process and understands the challenge that Covid 19 poses. We would still  encourage GMP to do outreach to the local community and provide a public process for recreational users to provide their perspective.

In addition to the comments provided above, please note that CRC supports comments submitted by the natural resource agencies, including but not limited to the Vermont Fish and Wildlife Department, Vermont Department of Environmental Conservation, and the U.S. Fish and Wildlife Service.

We are very grateful for Green Mountain Power’s sustainable leadership and we appreciate the opportunity to provide comments. I can be reached at kurffer@ctriver.org or (802) 258-0413.

Sincerely,

Kathy Urffer
River Steward

CC:
Jason Lisai, Green Mountain Power Corporation
John Greenan, Green Mountain Power Corporation
Katie Sellers, Kleinschmidt Associates
Jeff Crocker, VTDEC
Eric Davis, VTDEC
Betsy Simard, VTFWD
Melisa Grader, US FWS
Jud Kratzer, VTWFD
Bob Nasdor, AW
Noah Pollock, Vermont River Conservancy