Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426

Re: CRC comments on North Hartland Project (P-2816-050) and Clay Hill Transmission Line Project (P-12766-007) Scoping Document 1 (SD1)

Dear Secretary Bose,

The Connecticut River Watershed Council, Inc. (CRWC), now doing business as 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 a hydroelectric project in the Connecticut River watershed.

CRC provides the following comments on the North Hartland Scoping Document 1 dated May, 2020.

4.1.2 Geographic Scope

The scoping document indicates that the geographic scope would be limited to the Ottaquechee River from headwater to confluence of the Connecticut River and that the operation of the North Hartland Project, in combination with the other dams… could affect migratory fish species.[1]  As advocates for the Connecticut River, we are well aware that the migratory fish that use the river are cumulatively being affected by all of the dams that serve as obstacles from the Long Island Sound to the headwaters of various tributaries in the Connecticut River watershed.  Given this, the geographic scope considered should include the entire length of the Connecticut River to the headwaters of the Ottaquechee River.

4.2.4 Threatened and Endangered Species

Based on the lack of an asterisk in this section, the Scoping document indicates that effects of continued operation and maintenance of the North Hartland Project would not [emphasis added] be analyzed for both cumulative and site-specific effects on the federally endangered dwarf wedgemussel.[2] The dwarf wedgemussel is reliant on host fish such as the tessellated darter (Etheostoma olmstedii), johnny darter (Etheostoma nigrum), mottled sculpin (Cottus cognatus), and slimy sculpin (Cottus cognatus) to complete their development and disperse to additional habitat areas.  Both the Vermont[3] and New Hampshire Wildlife Action Plans[4] indicate that dams and altered hydrology have impacted these and other threatened freshwater mussels. Since this mussel is native to the entire Connecticut River watershed, CRC argues that the Environmental Analysis for the North Hartland project should consider cumulative effects of project operation on this species.

4.2.5 Recreation, Land Use, and Aesthetic Resources

Similarly, the scoping document indicates[5] that effects of continued operation and maintenance of the North Hartland Project on recreational use will not [emphasis added] be analyzed for both cumulative and site-specific effects. The North Hartland dam is one of many dams on the Ottaquechee River impeding recreational use by paddlers and people tubing on the river.  Additionally, it serves as a barrier to the free movement of resident fish, thereby impacting angling. CRC requests that because of this the consideration of recreational use be analyzed for cumulative impact in addition to site specific considerations.

In addition to the comments provided above, 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 appreciate the opportunity to provide comments.  I can be reached at kurffer@ctriver.org or (802) 258-0413.

Sincerely,

Kathy Urffer
River Steward

CC:

Andrew Locke, Essex Hydro Associates, LLC
Jeff Crocker, Vermont DEC
Eric Davis, Vermont DEC
Betsy Simard, Vermont DEC
Hannah Harris, VT Fish and Wildlife
Melissa Grader, US Fish and Wildlife Service
jmccaffrey@publicpower.org
glinka@sover.net

[1] Scoping Document 1, North Hartland Project No. 2816-050. Clay Hill Road Line 66 Transmission Project No. 12766-007. Vermont. Federal Energy Regulatory Commission, Office of Energy Projects, Division of Hydropower Licensing, Washington, D.C. May 2020. Page 14.

[2] Ibid. Page 15-16.

[3] Vermont’s Wildlife Action Plan. 2015.  Accessed at: https://vtfishandwildlife.com/about-us/budget-and-planning/wildlife-action-plan June 26, 2020.

[4] New Hampshire Wildlife Action Plan. 2015 Revised Edition. Accessed at: https://www.wildlife.state.nh.us/wildlife/wap.html on June 26, 2020.

[5] Scoping Document 1, North Hartland Project No. 2816-050. Clay Hill Road Line 66 Transmission Project No. 12766-007. Vermont. Federal Energy Regulatory Commission, Office of Energy Projects, Division of Hydropower Licensing, Washington, D.C. May 2020. Page 15-16.