December 2020 – Hydroelectric Relicensing Update

Good news – Amended Final License Applications for five FirstLight and Great River Hydro facilities on the Connecticut River have been submitted to FERC.

The next 6 – 8 months are critical to determine the final outcome for our rivers. These licenses will endure for the next 30-50 years and impact hundreds of miles of the Connecticut River. FirstLight, owner of the Turners Falls Dam and Northfield Mountain Pumped Storage in MA, released their final applications Friday, December 4 and Great River Hydro, owner of the Wilder, Bellows Falls, and Vernon Dams in VT and NH, released their applications on Monday, December 7.

The Amended Final License Applications (AFLA) are long and have many different components. Below are CRC’s take on the broader elements of the AFLAs, including links for more details.

Remember: Andrea and Kathy are available to update your local town board or interested group on the relicensing process and CRC’s concerns about the river. It is important that all parties re-engage as we come into this final stretch of this once-in-a-lifetime relicensing process.

Facilities in MA, Owned by FirstLight

CRC is pleased that FirstLight is addressing what science has told us for years by proposing to build a Holyoke-style fish lift at the Turners Falls dam to improve decades of inadequate fish passage. And they will be putting more water (amount varies by season) into the river channel below the dam. Additionally, slower fluctuations in turbine operations may allow more “natural” river flows to protect endangered and threatened species.

CRC is disappointed that FirstLight offers nothing to minimize or fix erosion that has been a huge issue since Northfield Mountain Pumped Storage began operating in 1972. FirstLight is proposing to use additional water in the upper reservoir, and they propose no changes to the 9-ft variation allowance in the river levels in the Turners Falls impoundment.

While the company will maintain existing recreational offerings, they propose only meager additions of three paddling put-ins and a renovation of an access spot (Poplar Street) that has needed work for the past 20 years. FirstLight has also proposed a series of whitewater releases at the Turners Falls Dam. CRC expects and the public deserves for the company invest significantly in resources for recreation patterns through 2070.

FirstLight continues to downplay the amount of revenue they make and highlight expected losses in generation or costs to build enhancements, many of which are the cost of doing business, like dredging the upper reservoir and moving the Riverview boat dock to accommodate the proposed Northfield barrier net.

Get more details at a virtual event on January 27.

Hydropower in MA: Do rivers need water & fish need elevators? REGISTER

Facilities in VT / NH, Owned by Great River Hydro

CRC was invited to participate in a productive discussion with Great River Hydro and other stakeholders about potential alternative operations. This collaboration yielded positive results for the river including operational changes that reduce peaking and will allow the river inflow into the facilities to equal the outflow, thereby returning the river to a much more natural flow at the three facilities much of the time. This change is expected to improve aquatic habitat for all aquatic life, particularly rare and endangered species; maintain minimum flow requirements to support resources and uses downstream during low flow conditions; and provide a more stable water level above the dams, which should reduce erosion on properties and shorelands in the impoundment areas.

While CRC is pleased with Great River Hydro’s willingness to collaborate transparently and effectively on this significant change to operations, CRC expects and the public deserves more comprehensive enhancements for recreational and cultural considerations in the license, safe and effective fish passage, as well as monitoring to ensure that operational changes will indeed reduce erosion issues in the upper end of the Wilder impoundment.

Get more details at a virtual event on January 13.

Hydropower in NH & VT: Three dams, two states, one better deal for rivers REGISTER

Next Steps

On December 15 and 16 the Federal Energy Regulatory Commission (FERC) posted a procedural schedule which indicates that they will be collecting additional information between January and May, and we can expect a notice that the application will be ready for environmental analysis sometime after May, 2021. This gives us time to fully analyze and understand the application and prepare to file comments and interventions between May and July.

CRC encourages the public to get involved in this once-in-a-lifetime opportunity to influence these operating licenses. More details to come about when and how you can join CRC to speak up over the coming months. Get in touch with Andrea (MA) or Kathy (NH & VT) to learn more.

Meanwhile, CRC plans to intervene and will submit extensive formal comments on these applications to address issues such as minimum flows at Turners Falls, upstream and downstream fish passage, recreational access and resources for river communities and the public, historic and native cultural sites, and advocating for ongoing streambank monitoring and mitigation funds to address erosion.

Additional Resources

Full License Applications submitted to the Federal Energy Regulatory Commission (FERC):

• Great River Hydro: https://www.greatriverhydro-relicensing.com/overview/documents/ Open “Final Licensing Application” folder. Most information is in “Exhibit E.”
• FirstLight: http://www.northfieldrelicensing.com/Pages/Documents2020.aspx Executive Summary Table ES-1 shows inflated cost amounts that include a hidden expected energy revenue loss, whereas Exhibit D for the two facilities show lower costs. Otherwise, the Executive Summary is a concise summary of what the application package includes.

CRC and Appalachian Mountain Club’s recreation recommendations submitted to FERC: https://elibrary.ferc.gov/eLibrary/idmws/file_list.asp?accession_num=20190730-5077

Great River Hydro’s Deerfield River Project applies for Low Impact Re-certification

The Deerfield River Project in Vermont and Massachusetts is up for recertification by the Low Impact Hydro Institute. Comments from the public as to whether the project meets the LIHI Handbook standards are due by January 29, 2021. CRC often comments on LIHI certification, and we plan to submit comments by the deadline. Additional information is available online.