March 14, 2012

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

Re:    COMMENTS
Application for a Preliminary Permit, FERC #13273-001
Proposed Canton Hydroelectric Project
Farmington River, Hartford County, CT

Dear Secretary Bose,

This responds to your public notice, dated January 19, 2012, regarding the application for preliminary permit for the Canton Hydroelectric Project, located on the Farmington River in Hartford County, Connecticut. Thank you for the opportunity to provide comment on this project, which would potentially involve the Upper and Lower Collinsville Dams on the Farmington River. I am submitting these comments on behalf of the Connecticut River Watershed Council (CRC), a nonprofit organization established in 1952 to advocate for the sustainable use of the Connecticut River throughout the entire four-state watershed that is home to more than 2.5 million people. We work to conserve, protect and restore water quality and quantity, habitat and recreational access within the Connecticut River watershed.

The Farmington River is a beautiful and important tributary to the Connecticut River system, and we greatly value its role as a cold water fishery. CRC supports the development and operation of hydropower facilities that can minimize and mitigate impacts to aquatic ecosystems as well as generate clean sources of electricity. The CRC takes particular interest in any new hydropower project that may significantly impact aquatic habitat, fish passage and/ or recreation. Of importance to us when reviewing the pre-feasibility study prepared by GZA GeoEnvironmnetal, Inc. were the following:

1) the specific additional data needed to gauge anticipated changes to wetlands
2) FERC’s EA recommendation of preserving vegetation below the new water line in the Lower impoundment
3) the need for field surveys to be conducted to follow-up on the possible presence of listed state threatened species and species of special concern
4) consultations necessary to assess impacts to wildlife and to stipulate appropriate construction windows
5) BMPs for sedimentation and erosion control must be employed and proper handling must be performed in the event that contaminated sediment is found at the project
6) mitigatory measures needed to control flow fluctuations
7) recommended pre and post-water quality studies for effects on dissolved oxygen and temperature.

We strongly encourage early initiated and continued collaboration with appropriate agencies and community groups to assess project impacts to wildlife and recreation so that choices may be made in the preliminary and planning phases that minimize negative impacts and maximize potential benefits for all parties.

We are supportive of all the comments submitted and recommendations made by the USF&WS. We believe the details they have given about fish and wildlife, cultural and recreational considerations are very worth paying attention to. The comments point to the need for consideration of freshwater mussels and for fish passage plans to account for all migratory fish species presently under management goals, not just Atlantic salmon. This kind of holistic thinking is critical to the sustainability of diverse ecosystems. The Council is very supportive of work by the CT DEEP to create biological criteria for all our waters. This important work will contribute to scientifically robust water quality criteria that ensure that the many millions of dollars we are investing are targeted precisely and money is allocated as efficiently as possible. This particular project may have significant effects on the ecosystem but if planned with holistic thinking and consideration that healthful waters support diverse aquatic life, those effects may be minimized.

We are especially supportive of the recommendation to carefully consider the findings of the GZA prefeasibility study, particularly the finding that development of just the Upper Dam yields the best output per financial investment. This course of action seems to lead to win-win situation in which the Town could maximize its generation at the Upper Dam while providing safe and adequate fish passage and the Lower Dam could be removed, thus providing migratory habitat, enhancing connectivity and potentially mitigating some of the effects of development at the Upper Dam. The two Collinsville Dams were among all the dams ranked by the Nature Conservancy’s Dam Prioritization model, which seeks to identify which dam removals would provide the most benefit by looking at factors such as connectivity and migratory fish habitat created. The model placed the two Collinsville Dams in the top 10% bin for all dams in the 11 northeastern states.

Given the high resource values of the Farmington River and the high priority scores assigned to these two dams, it is very important that fish passage requirements for any new hydropower facility be based on 2012 standards and experience. If pending legislation does allow for a transfer of the Summit License as a cost savings measure, the resource agencies should be free to utilize fish passage conditions of 2012 standards and not be bound to employ the old license’s 1990 standards.

We look forward to staying involved as this project progresses and would value communication with the town and interested stakeholders. I work out of Middletown, CT and can be reached via email: jtalbot@ctriver.org or telephone: 860.704.0057.

Thank you for your time, consideration and stewardship of our water resources.

Sincerely,

Jacqueline Talbot, Lower River Steward
Connecticut River Watershed Council
deKoven House, 27 Washington Street, Middletown, CT 06457
860.704.0057  jtalbot@ctriver.org