Update: FERC issued a “study plan determination” on February 6, 2023 approving Green Mountain Power’s revised study plan with recommended modifications. These recommended modifications include some of the aspects addressed in the comments submitted by CRC. We are pleased to see this result!

CRC submitted the following comments to FERC regarding Green Mountain Power’s revised study plan as part of the relicensing process for the Glen Hydro Facility on the Mascoma River in West Lebanon, NH.

January 24, 2023

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Room 1A
Washington, D.C. 20426

Via E-Filing

Re: CRC comments on the Glen Road Hydro (P- 8405-023) Revised Study Plan

Dear Secretary Bose,

The Connecticut River Conservancy (CRC), is a nonprofit citizen group established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed.  The interests and goals represented by CRC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of hydroelectric projects in the Connecticut River watershed.

CRC received the Revised Study Plan (RSP) for the Glen Hydroelectric Project (FERC project number 8405) submitted by  Green Mountain Power (GMP) on January 9, 2023 and has reviewed said plan. We were pleased to see the inclusion of modified recreation and whitewater boating assessments in the RSP and thank GMP for their responses to our and other stakeholder comments regarding the proposed studies. We would like to request additional detail and clarification on the Recreation Assessment plan proposed in the RSP.

Specifically, Green Mountain Power indicated in Table 1.2-1 that “GMP’s modifications to the proposed CRC study request include handling aesthetics as previously proposed under the Bypass Reach Minimum Flow Study”. However, GMP also indicated in response to multiple comments by the NH Department of Environmental Services and US Fish and Wildlife, both requesting additional test flows for the minimum flow study, that GMP intends to only conduct a single test flow at 40cfs and model the other flow conditions unless ZOP issues are observed at the minimum flow. Neither the recreation study nor the minimum flow study descriptions indicate how the 40cfs flows condition will be utilized to evaluate aesthetics. It is our understanding that typical aesthetic studies involve multiple human participants who score a range of flow conditions for aesthetics based on how the different flows look, sound, and make them feel while observing them in person. We would request that GMP provide additional information indicating how the photos and flows under the bypass reach minimum flow study will fulfill an aesthetic evaluation, particularly if only one flow condition is utilized.

In section 5.3.1, Task 2, it would be helpful to see an example of the “standard form” that GMP intends to use.

Additionally, we request that GMP provide better justification for not including users of Riverside Park in the online recreation survey as is indicated under Task 3 in the section 5.3.1 study description. Given that GMP also states that this Park provides “direct public access to Project lands and waters” (section 5.3.1 background and existing information) and that the penstock runs directly underneath the park, we feel that this park should be included in the user survey outreach. We agree with GMP that an online user survey will likely garner larger participation than in-person intercept surveys. However, we feel that intentionally not targeting users of one of the larger formal recreation sites which meets the criteria of providing access to or abutting Project lands and waters will diminish the strength of the study and request that the exclusion of Riverside Park from the online user survey be reconsidered. We appreciate GMP’s willingness to provide the link to the online survey to stakeholders for distribution and also request that this and other comments regarding access, limitations on survey users per site, etc. included in the comments in Table 1.2-1 also be included in the individual study plan proposal.

CRC will defer to the expertise of NH DES and US F&W regarding additional considerations for the water quality and fishery resource revised study plans. We thank Green Mountain Power for their consideration of and response to our past comments regarding recreation studies in and around the Project area and would be happy to engage in further discussion as these plans move forward. I can be reached at kbuckman@ctriver.org or (603) 931-2448.

Sincerely,

Dr. Kate Buckman

River Steward, Connecticut River Conservancy