CRC and CRSEC Comments on Northfield Mountain application for temporary license amendment

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

In re: )
FirstLight Hydro Generating Company) Northfield Mountain Pumped Storage Project, No. 2485-065
COMMENTS
OF THE
CONNECTICUT RIVER WATERSHED COUNCIL, INC.
AND THE
CONNECTICUT RIVER STREAMBANK EROSION COMMITTEE OF THE FRANKLIN REGIONAL PLANNING BOARD, ACTING UNDER THE AUTHORITY OF THE FRANKLIN REGIONAL COUNCIL OF GOVERNMENTS
IN THE ABOVE APPLICATION
FOR TEMPORARY AMENDMENT OF LICENSE
The Connecticut River Watershed Council, Inc. and the Connecticut River Streambank Erosion Committee of the Franklin Regional Planning Board, acting under the authority of the Franklin Regional Council of Governments (herein the “Intervenors”) submitted a motion to intervene and comments to the above referenced application for temporary amendment of license dated October 3, 2014. On October 10, FirstLight Hydro Generating Company filed an “Answer of FirstLight Hydro Company to Motion to Intervene and Comments” (“Answer”). FirstLight did not object to CRC and CRSEC’s intervention, but responded to comments by the Intervenors and an opposition to a condition proposed by the Intervenors. The Intervenors herein are submitting brief additional comments.
I. Comments
1. FirstLight writes in its Answer on page 3, “FirstLight does not believe the current reservoir elevation limits are needed for any engineering, environmental, or any other reason.” This is an astonishing claim made at any point, but particularly during the current relicensing. Assertions such as these made in the record give us pause and cast a significant cloud on our ability to believe that FirstLight is looking for unbiased information regarding the current and future operation of their facilities .
The Intervenors are concerned that the operation of Northfield Mountain under its current license parameters has environmental effects including riverbank stability and fish entrainment. Utilizing additional storage capacity, as requested in the temporary amendment, means potentially longer pumping and generating times for the entire 4-month period. Therefore, the requested amendment has the potential to increase the environmental impacts about which the Intervenors are concerned. FirstLight has provided no evidence, and has done no studies to our knowledge, regarding its effects during the temporary amendment. FirstLight’s Exhibit E in their August 8, 2014 Application for Temporary Amendment of License notes on page 9 that the range of water level fluctuations on a given day will increase minimally under the temporary amendment. FirstLight believes this “may have a marginal effect on streambank erosion.” Exhibit E section E.3.1.1 provides no information on the numbers or species of resident fish that may be in the vicinity of Northfield Mountain in the winter. As we noted previously, relicensing studies are underway to look at these concerns further.
2. FirstLight bases its assertions about water level fluctuations using a model to compare a “baseline” vs. conditions under the temporary amendment, yet there is no way to evaluate the assertions or the baseline assumptions. FirstLight used December 1, 2001 to March 31, 2002 flows in the HEC-ResSim model because that time period represents low flow conditions. “Baseline” pumping and generating were based on actual hourly pumping and generating for December 1, 2008 to March 31, 2009, a different year than the HEC-ResDim used, and for which no flow data or climate information were provided as background information. FirstLight provided no information why the winter of 2008-2009 was selected or how representative of “baseline” that winter was. Page 5 of Exhibit E says that the GDF Suez Energy North America Commercial Group provided feedback how they would have operated the Northfield Mountain Pumped Storage Project if the upper reservoir storage capacity during the winter 2008-2009 period had been available. No information on the assumptions the Commercial Group made to estimate the market bids was provided. There are several wholesale electricity markets in New England (see ISO-NE’s 2013 “Overview of New England’s Wholesale Electricity Markets and Market Oversight”—online at www.iso-ne.com/pubs/spcl_rpts/2013/markets_overview_051513_final.pdf), and it is unclear which markets the Commercial Group used in their model assumptions presented in Exhibit E. Additionally, FirstLight’s application at page 4 implies that ISO-New England faces different reliability challenges this winter than in previous years, and ISO-New England has agreed. We therefore have no way of evaluating how the “baseline” winter 2008-2009 relates to the potential operation of Northfield Mountain this winter.
3. In our Motion to Intervene, we did not oppose a temporary amendment with limitations. If storing more water, and therefore having more “fuel” on site, for the entire season provides more reliability to the electrical grid, we are not opposed. We still maintain that permission for using additional water than currently allowed via license parameters to lengthen generation time be triggered only by a real reliability issue faced by ISO-NE.

DATED this 30th day of October 2014, on behalf of the organizations we represent.

Signed,

LINDA DUNLAVY
Linda Dunlavy, Executive Director
Franklin Regional Council of Governments
12 Olive Street, Suite 2
Greenfield MA 01301

ANDREW FISK
Andrew Fisk, Executive Director
Connecticut River Watershed Council, Inc.
15 Bank Row
Greenfield MA 01301

Date: October 30, 2014

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the Comments submitted by the Intervenors, upon each person designated on the attached service list. Dated this 30th day of October, 2014.

Signature:

Andrea Donlon
Connecticut River Watershed Council
15 Bank Row
Greenfield MA 01301
Telephone: (413) 772-2020 x. 205
E-mail: adonlon@ctriver.org
On behalf of the Intervenors:

Connecticut River Streambank Erosion Committee of the Franklin Regional Planning Board, Acting under the authority of the Franklin Regional Council of Governments
Connecticut River Watershed Council, Inc.,
SERVICE LIST
FirstLight Hydro Generating Company
John Howard, Director FERC compliance
Northfield Mountain Station
99 Millers Falls Road
Northfield MA 01360

Julia S. Wood
Van Ness Feldman, LLP
1050 Thomas Jefferson St., NW
Washington DC 2007
(202) 298-1938

U.S. Fish and Wildlife Service (USFWS)
John Warner, Ecological Services
N.E. Fish and Wildlife Office
70 Commercial Street, Suite 300
Concord NH 03301-5087
(603) 271-2541

Connecticut River Atlantic Salmon Commission
Kenneth Sprankle
U.S. Fish and Wildlife Service
103 East Plumtree Road
Sunderland MA 01375
(413) 548-9138 x. 121

U.S. Army Corps of Engineers
John C. Sargent
U.S. Army Corps of Engineers
New England District
696 Virginia Road
Concord, MA 01742
(978)318-8026-

Massachusetts Department of Environmental Protection
David Foulis
MA DEP Western Regional Office
436 Dwight Street
Springfield MA 01103
(413) 784-1100

Robert Kubit
MA DEP Central Regional Office
627 Main Street
Worcester, MA 01608
(508) 767-2854

Massachusetts Division of Fisheries and Wildlife
Caleb Slater, PhD., Anadromous Fish Coordinator
MA DFW
1 Rabbit Hill Road
Westborough, MA 01581
(508) 389-6331

ISO New England Inc.
Peter Brandien, Vice President, System Operations
ISO New England Inc.
One Sullivan Road
Holyoke, MA 01040
(413) 535-4000