May 3, 2016


Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426


Re:       Northfield Mountain Pumped Storage Project No. 2485-063

Turners Falls Project No. 1889-081

Connecticut River Watershed Council Comments on Study Reports filed March 1, 2016

Response to April 22, 2016 letter from FirstLight to Secretary Bose;

Request that the Commission Require Compliance with the RSP;

Request that FirstLight Provide Documentation of Study Results; and

Request that studies be modified


Dear Secretary Bose,

On May 2, 2016, the Connecticut River Watershed Council, Inc. (CRWC) submitted a comment letter on several studies.  Today, we realized that our analysis of Study 3.3.6 contained an error in one paragraph.  We are therefore re-submitting our entire comment letter, with a corrected paragraph substituted for the incorrect paragraph.  The corrected paragraph begins with the following notation: [Corrected paragraph is inserted here].

The Connecticut River Watershed Council, Inc. (CRWC) 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.  We have been participating in the relicensing of the five hydropower facilities on the Connecticut River since the beginning of the process in late 2012.  We have reviewed the set of Study Reports that were posted on March 1, 2016.  CRWC attended the study report meeting held on March 16, 2016.  Don Pugh assisted us on our comments on the fisheries studies.  CRWC collaborated with the Appalachian Mountain Club (AMC) on a portion of the comments on Study 3.6.1.  Below are our comments.

Comments on FirstLight’s March 1, 2016 cover letter to Study Reports filed on that date

FirsLight submitted a process and schedule overview in their cover letter to the March 1, 2016 reports.  FL proposes to file 10 more study reports on October 14, 2016.  Their proposed schedule allows stakeholders only 4 days to look at the report before the study report meeting and a little over a month to file study disagreements and modifications.  We think the time frame between submitting the completed reports and the meetings and comment deadline should be the same as with the other study report review periods.

In the March 1, 2016 cover letter, FL proposes to use 2002 hydrology (flow) and the actual 2009 Northfield pump/generation schedule to simulate the current and proposed operations in the BSTEM model for Study 3.2.2.  CRWC inquired how those dates were chosen, and were informed that 2002 was selected for calibration of the Turners Falls pool hydraulic model and represents average conditions in the CT River near the project.  The year 2009 represents more current operations at the Northfield Project.  CRWC prefers that all studies looking at operational impacts, proposed and current, be conducted in a consistent manner using multiple years of data and the hydraulic model.

Comments on FirstLight’s April 22, 2016 letter to FERC

On March 25, 2016, CRWC sent a letter requesting information to FirstLight, and filed it with FERC.  FirstLight responded on April 22, 2016.  In some cases, FirstLight regarded CRWC’s request as consistent with 18 C.F.R. § 5.15(b), and supplied the data as requested.  In other cases, FirstLight regarded the request as being outside the scope of the FERC-approved Revised Study Plan (RSP).  Their letter stated that they will supply some information on May 30 and that CRWC needs to provide rationale before it gives out other information.

FirstLight attempts to hide the fact that it failed to gather information and conduct its studies as provided for in the Revised Study Plan (RSP) behind unfounded procedural claims.  In response to FirstLight’s March 1, 2016 study reports, and because reports lack some details indicating whether or not they were not properly conducted, CRWC asked for documentation (or lack of documentation) of study results.  18 C.F.R. § 5.15(b).  FirstLight responded by characterizing CRWC’s effort as an attempt to amend “the Commission-approved study plan.”  In some cases, it states that information will be given on May 30 — well after today’s deadline for comments.

The following comments demonstrate significant gaps and failures in several studies.  They also demonstrate that the studies are either incomplete or must be redone because of significant failures to adhere to the RSP.  See 18 C.F.R. § 5.15(a) and/or (d)(1).  The comments also explain that FirstLight’s failures lead to study results that are inaccurate and unreliable.

FirstLight’s argument that a party must seek to amend the RSP to require FirstLight’s adherance to the RSP is nothing but misdirection.  One does not have to amend the RSP to require that FirstLight comply with it.  Further, FirstLight’s failures to gather information and conduct studies in accordance with the study plan and schedule amount to its unilateral and improper amendment of the RSP in violation of the Integrated Licensing Process (ILP).  See 18 C.F.R. § 5.15(c).

CRWC requests that the Commission assure the propriety of FirstLight’s studies by requiring that FirstLight conform to the RSP.  18 C.F.R. § 5.15(a).  The Commission has the authority to do so regardless of whether a participant seeks to amend the study plan or modify a study.

CRWC also requests that the Commission require FirstLight to fully comply with CRWC’s request that it provide documentation of study results.  18 C.F.R. § 5.15(b).

CRWC requests that the particular studies listed below to address the issues raised in these comments.  18 C.F.R. § 5.15(d)(1).  The bases for these requests are set forth in the following comments.

3.2.1 Water Quality Monitoring Study

Table 3.3-1 indicates that the temperature and DO logger at Site 7, at the Turners Falls boat barrier, was installed at a depth of 12 feet.  That is deeper than all the other sites, making it difficult to compare with the other sites.  Comparatively, TransCanada, for Study 6, installed loggers at 1 m depth, “mid-depth” and 1 m from the bottom of the river.  TC Study 6 was able to conclude in Section 6.0 that, “In addition, an indirect effect of the impoundments was the surface warming and very weak stratification at the forebay (06-W-01, 06-BF-01, 06-V-01) and middle impoundments stations (06-W-02, 06-BF-02, 06-V-02).  The periods of mild surface warming and weak stratification occurred during short periods when the weather was fairly calm and temperatures were hot.”  The FirstLight study was not conducted in a way that would evaluate surface warming of the impoundment as a project effect.  Moreover, the impoundment location had the deepest logger.

TransCanada’s Study 6 identified a high temperature-low flow period and looked at results closely during this period.  Study 6 also summarized results by month at each site (max, min, mean, and median).  FirstLight’s study 3.2.1 did not do this, which would have been useful.

FirstLight’s loggers did not identify water quality problems in the bypass region.  It would have been impossible to place loggers in sections that become dry during the season, and CRWC thinks there are locations in the bypass that violate water quality standards for temperature during parts of the summer due to partial or complete dewatering.

3.3.4 Evaluate Upstream Passage of American Eel at the Turners Falls Project

Section 4.1 Eel Monitoring. 

Low collection of eels at the Cabot ladder may have been caused by high velocities at the Cabot entrance limiting the eel’s ability to enter the ladder.  Both entrances are the same width.  The spillway entrance was set to provide a 1-foot differential (125 cfs).  The Cabot ladder also was set for a 1-foot differential but that required significantly more flow (~300 cfs) with a commensurate increase in velocity over the entrance weir.  This increased velocity may have hindered eels entering the fishway.

Section 4.2 Environmental and Operational Conditions

The report states that there is no correlation between river flow, as measured at the Montague USGS gage, and the rate of eel collections.  There is no information provided as to the means of calculating the rate of eel collections or the period of time of collection that is used for the evaluation.

A correlation between discharge at Montague and the rate of eel captures is invalid, as most of the eels collected (88%) were at the spillway ladder and 87% of the time when eels were captured at the spillway ladder, there was only minimum flow (125 cfs) in the bypass reach.  Eels in the bypass reach are not affected by river flow as measured at the Montague gage, but by generation at Station #1 and spill.

The report also states that, “Data suggests that spill at the Turners Falls Dam does not affect collection rate at the traps.”  There is limited data to assess the effect of spill on eel captures at the spillway trap, where spill affects collections, but what data there are points to the opposite conclusion.  During the period of trapping, there was spill from July 10 to 13 (mean 1,245 cfs), July 22 (1,058 cfs), and beginning on October 1st and lasting (except for one day) for the entire month.   During the initial period of spill, 119 eels were collected at the spillway trap.  A large number of eels was collected around June 22, but without daily collections it is impossible to determine if eels came into the ladder before, after, or during spill.  For the month of October, only 10 eels were collected after the start of significant spill (Oct. 2), and those eels could have already been in the ladder prior to spill.  Although eels may be able to enter the spillway ladder when spill is around 1,000 cubic feet per second (cfs), it is likely that spill greater than several thousand cfs prohibits eels from entering the spillway ladder as spill plunges into the bypass at the spillway ladders entrance, creating turbulent conditions with a large amount of entrained air.

3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects

CRWC requested information from FirstLight on launch locations and times for all field work in this study by letter dated March 28, 2016.  FirstLight’s response dated April 22, 2016 indicated that FirstLight will be making this information public on May 30.  Our information request was based on a desire to review that the study was conducted as provided for in the approved study plan (18 CFR §5.15(a), (b) and (d)(1)).  Until we get this information, we are unable to evaluate whether the study methods were done according to the study plan, and this may impact some of the results and conclusions in this study.

The Revised Study Plan (RSP) dated August 14, 2013 stated in Task 3 that in the Turners Falls impoundment, “…Upstream surveys will target areas of suitable aquatic habitat for shad spawning based on HSI curves.” A revised, track-changes version of this study plan was circulated to stakeholders on April 8, 2015.  The April 8 track-changes version did not show this wording being deleted, but the resulting draft and final version dated April 29, 2015 did not specify that suitable habitat will be identified using HSI curves.  CRWC, and perhaps other stakeholders, did not realize this step was being eliminated.   Certainly, it would have been useful for determining launching locations and timing in a 20-mile stretch of river for which little was known with regard to shad spawning.

4.2.1 Downstream Reach

The report notes that for safety reasons, physical parameters were generally recorded while the boat was tied off at the shore.  Consequently, measurements such as velocity do not represent those where the fish were spawning and this should be noted in the report.

4.3.1 Spawning Activity

The mean counts of splashes before and after unit changes include counts from the first survey on June 9th when generation did not change.  This is not appropriate in an evaluation of the effect of unit change.

FL used a negative binomial model to assert that there was no change in the number of splash counts; this test is not appropriate for comparing “before” and “after” pairs.  The Wilcoxon signed-rank test is more appropriate, because it applies to two-sample designs involving repeated measures, matched pairs, or “before” and “after” measures.  It is a non-parametric test that does not require the samples to have a normal distribution and whose greatest application is for paired sample testing (Zar, 1984).  At the 0.01 level of significance, the Wilcoxon signed-rank test refutes the null hypothesis that there is no difference between the number of splashes before and after operation changes (13 counts, excludes June 9 & 22).  Our conclusion is that operation changes negatively impact spawning.

For eleven of thirteen tests, there was a reduction in the number of splashes after the unit change.  The average reduction of the thirteen splash counts was 22%.

[Corrected paragraph is inserted here] The USGS Montague gage discharge readings for the before and after times for the splash samples (Table 4.2.1-1 data and USGS downloaded 15 min data are similar) do not show the change in MW’s/discharge stated in Table 4.3-1.  Each Cabot unit’s hydraulic capacity is 2,280 cfs.  For the thirteen readings where a change in unit operation is listed, six show a change in discharge opposite of the listed generation change (5/26 twice, 5/27, 6/9 to 6/10, 6/10 to 6/11, & 6/17 to 6/18), one had no change in discharge for a decrease of two units (6/16), five had changes averaging 224 cfs and only one had a change that approximated the listed unit change (5/28, 1,530 cfs). The Deerfield River gage near West Deerfield (#01170000) showed no significant change in discharge during any of the periods of splash count sampling, and as such did not influence the Montague gage. Changes in generation should be readily apparent at the Montague gage due to its close proximity to Cabot station. That the flow did not change as noted in Table 4.3-1 is of serious concern for the accuracy of the study and calls into question any conclusions. As such, this study should be repeated or data need to be corrected (consistent with 18 CFR §5.15(d)(1) and (2)).

Reference cited.  Zar, Jerrold H. Biostatistical Analysis. Englewood Cliffs, New Jersey: Prentice-Hall, Inc., 1984.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

We regard the results for this study showing flow reversals 5 km upstream and downstream of the Northfield Mountain tailrace as having implications for recreational use of the river as well as having potential impacts on migrating fish.  The eddying action shown in the Appendix B velocity vector maps may also have uses for interpreting patterns of erosion along the river banks in the study area.

The water level logger data for this study was not presented in graphical form.  The Initial Study Report for this study showed the water level logger data in Figure #3 for May 21 to July 16, 2014.  This graph does not seem to match the logger data given to us in Excel form.  The Study 3.3.9 report should present the logger data month by month for stakeholders to be able to review.

3.3.10 Assess Operational Impacts on Emergence of State-Listed Odonates in the Connecticut River

This study was completed in a way that vastly differed from the FERC-approved revised study plan.  We point out the following key deviations.

  1. Page 3-28 of the RSP states, “To some extent, a thorough review of existing information will provide adequate biological information for an impact assessment using the hydraulic model, but field observations are planned to fill critical knowledge gaps by conducting surveys in both the Turners Falls Impoundment and downstream from the Turners Falls Dam.” The purpose of the field work was to fill in data gaps.  However, the Study Report only looked at the gap areas, and did not assess project operations on the Turners Falls impoundment using the existing data as was implied in the RSP.
  2. Task 1 was to be a review of existing information, and “the life history and ecology of these species and species groups will be summarized.” The first paragraph in section 4.1 of the report gives a slight mention of some existing information, but in no way was the existing information summarized.  And for some reason, a study conducted in 2011 by Biodrawversity as part of a Massachusetts Department of Environmental Protection (MassDEP) Administrative Consent Order against FirstLight for the 2010 sediment dumping incident was never even mentioned.
  3. Task 5 was to be a water fluctuation impact assessment using the hydraulic model. No such impact assessment was done using the hydraulic model.
  4. The FERC study plan determination dated February 21, 2014 stated, “As such, we recommend FirstLight use the quantitative data collected under study 3.1.2, such as frequency, amplitude, and speed of boat wakes when evaluating effects on odonate emergence. We estimate that the cost of including this data in the odonate analysis would be approximately $2,000.”  The resulting report in section 2.2.3 says merely, “Boat traffic was extremely light at all sites on all dates, and no disturbance from boat wakes was ever observed.  Thus, this parameter is not discussed further in this report.”  Given that the field work was largely done below the Turners Falls dam, in a section that gets almost no motor boat traffic (it’s the only section of the Connecticut River in Massachusetts that is actually regulated as a no-wake zone), it’s not surprising that no disturbance was observed.  However, that is not what FERC asked for.  The Turners Falls impoundment gets much boat traffic, enough that the erosion study is looking at it as one of the causes of erosion.  The analysis should still be done.

CRWC contacted Dr. Kirsten Martin and we attach the brief letter we received back from her.

CRWC recommendation:  We request a modification to the study report under 18 CFR §5.15(d)(1)FirstLight should re-write the entire Study Report, using the new and existing data along with the hydraulic study and the boat wake study results, to assess the impact of existing and potential operations on odonates.  Dr. Martin’s letter hints that some of the methodology in the RSP may not have been sufficient to analyze project effects, but CRWC is not qualified to assess this.

3.3.18 (Addendum) Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms

The Addendum includes a count of 766 fish identified in stranding events during the canal drawdown.

The revised RSP submitted as Appendix to ISR for 3.3.18 said that in Task 1, “A field crew of experienced biologists will systematically traverse each of the zones in a meander survey fashion recording observations of estimated number of each species encountered.”  Despite our numerous requests, neither the Study Report nor the Addendum describes a meander survey taking place.  A search for the word “meander” turns up nothing.  We conclude that the pictures shown in the addendum represent a random indication of strandings.  We conclude that the study was not conducted according to the RSP (18 CFR §5.15(d)(1)), but instead of requesting a modification to the study, we are going to make the assumption that stranding numbers are much higher than reported.  This will be reflected in our desire for real PM&E measures to be suggested for canal draining activities in the future license.

3.3.20 Ichthyoplankton Entrainment Assessment at the Northfield Mountain Project

CRWC requested information from FirstLight on pumping information by letter dated March 28, 2016.  FirstLight’s response dated April 22, 2016 indicated that FirstLight will be making this information public on May 30.  We regard our request as being consistent with a request for documentation of study results under 18 CFR §5.15(b).  Until we get this information, we are unable to evaluate some of the results and conclusions in this study.   CRWC may choose to file additional comments after May 30.

The study results are not conclusive or determinant for three reasons:

  1. The start of the study was well after the initiation of spawning. Ten thousand shad passed the Gatehouse fishway on May 13.  Entrainment surveying did not begin until May 28, fifteen days later.
  2. The number of pumps evaluated was not evenly distributed during the period of the study. To evaluate the effect of pumping, the number of pumps tested (1 to 4) should have been tested equally through the period to account for unequal availability of eggs/larvae.
  3. River flow was not accounted for in the analysis. The assumption in the report is that density is independent of the number of pumps, which is not the case.  The effect of pumping is determined by the volume of water passing the project.  Study report 3.3.9 Appendix B Vectors (2D Model of Northfield Intake/Tailrace and CT River above and below) shows how the number of pumps can affect river flows.  With low river flow, water from below the French King Bridge up to the Northfield intake along with all water from above the intake can be pumped into the upper reservoir, whereas with high flow and the same number of pumps a portion of flow passes the project.

An evaluation of flow at the USGS Montague gage show that for the months of May through July (1980 to 2014) four pumps (15,200 cfs) exceeds river flow 66.9% of the time whereas one pump exceeds river flow only 9.0% of the time.  The interaction of the number of pumps and river flow must be considered in any analysis of entrainment.

The report did not relate entrainment in 2015 to the “normal’ year of pumping, or river flow.  If 2015 was a high water year and pumping was normal, it would be anticipated that in a normal year entrainment would be greater.  Likewise if 2015 was a low water year with higher than normal pumping, it would be anticipated that entrainment in a normal year would be lower.  Without relating 2015 to project operations and river flow, the effect of entrainment cannot be understood.  Our March 28, 2016 request for pumping information and Vernon discharge for the previous 10 years was consistent with the study objectives.  We agree that this information was not specifically called for in the RSP dated October 16, 2014, but the study should be designed to evaluate impacts for more than one particular year that may or may not be representative of the future license conditions.  See also CRWC’s comments above on the March 1, 2016 cover letter.

In section 5.0, a more complete description of the calculation of adult equivalents is needed, including an analysis of variability.


3.6.1 Recreation Use/User Contact Survey

Accuracy of User Estimates

One of the study objectives was to determine the amount of recreation use at the Turners Falls and Northfield Mountain recreation sites.  In Study Report 3.6.1, FirstLight has estimated total recreation use to be 152,769 recreation days in 2014.  Comparatively, TransCanada estimated recreation use in their Study 30, calculating annual use for the Wilder study area to be 234,400; Bellows Falls 312,531; and Vernon 72,388.  Section 4.7.1 states that the user surveys indicate that the large majority of visitors to the Project live within 25 miles of the Project.  TransCanada’s study 30 also concluded that, “the overwhelming majority of visitors to the recreation facilities originate their trips from the towns immediately adjacent to the Projects.”  Parts of Hampshire County, including Northampton, are within 25 miles of the Project.  Though Hampshire County was not considered to be part of the projection of project recreation days, the area around the Turners Falls and Northfield Mountain projects has a larger population than surrounding most if not all of the TransCanada sites.  The estimated yearly use in Study 3.6.1 either indicates that the estimates are too low, or that the facilities are not drawing the kinds of recreational users that are possible for a region of this population.

In some areas, such as Cabot Woods, where a stairway was removed to reduce recreational use of that area, or Poplar Street access site, where the site has been inadequate and allowed to deteriorate for years, or Cabot Camp, which has a building that was formerly used by the public but now is closed to the public, degradation/use restriction no doubt reduces demand.  The current minimum flow requirements in the bypass section of the river also reduces recreational demand.

CRWC tried to evaluate whether or not the estimated user numbers at popular recreation sites were accurate.  We reviewed parts of TransCanada’s Study 30.  The estimate for the Governor Hunt Recreation Area and Boat launch (including fish ladder) site for yearly recreational use by TransCanada is 30,561 (see Table 4.1-2 of Study 30).  This estimate was made using a traffic counter and average group size.  This site is just downstream of the Vernon Dam and is owned and operated by TransCanada. According to Study 30’s Section 3.3.5, “The most common recreation activities at this site are swimming from shore and sunbathing along the sandy beach, fishing from shore, picnicking, car-top boat launching, and motorboat launching and visiting the fish viewing window when the fish ladder is operating.”  Comparatively, FirstLight’s estimated annual use for the Governor Hunt Boat Launch/Picnic Area was 1,812, an order of magnitude lower than TransCanada’s estimate (see Table 4.1.3-1 of Study 3.6.1).  Table 4.1.3-2 estimates that recreational use at this site was 53% motor boating, 15% non-motor boating, 12% fishing, and 19% “unidentified.”  Picnicking and fishway viewing got 0%.  Swimming was not a category that FirstLight evaluated at any site, but may be part of the “unidentified” numbers.  CRWC views the differences in the information collected about this site to be large, and requests that FERC attempt to evaluate whether each company in fact followed their respective RSP or if the methodology in the RSPs were flawed (particularly for FirstLight’s sties that were assessed only by spot counts).

Next in CRWC’s evaluation of estimated user numbers, CRWC requested and received traffic counter data used in the study from FirstLight.  We looked at three of the popular recreation sites, summed the traffic counter data, and compared that to FirstLight’s estimated annual use for these sites.  See the table below.  We did not evaluate counts at  Cabot Woods because there were two entries for that site and we didn’t know what that meant (in addition, we weren’t sure how they subtracted out vehicles coming in and out of the Conte Fish Lab).  We also did not look at the Poplar Street boat launch counter numbers because we believe the counter was put in the wrong location, and did not actually count all vehicles coming in and out of the site.

CRWC comparison of Traffic Counter data vs. estimated annual use

Site Estimated Annual Use (2014) in Table 4.1.3-2 FirstLight Traffic Counter totals 5/23-11/14/2014 CRWC estimated vehicle counts CRWC Comments
Pauchaug Boat Launch 9,630 70,253 11,708 [a] Our conservatively estimated # of vehicles exceeds FL’s annual estimate of the site recreation use.
Boat Tour and Riverview Picnic Area 13,651 32,239 [c] 8,059 [b] Table 4.1.3-1 estimates winter use at this site is 17%, and traffic counter was removed 1 month into fall which gets 21% of use, so FirstLight must have estimated additional numbers.
State Boat Launch (at Barton Cove) 15,126 97,482 16,247 [a] Our conservatively estimated # of vehicles exceeds FL’s annual estimate of the site recreation use.
[a] – We divided the total counts by 6.  This assumes every vehicle has 2 axles and a trailer with one axle (this would underestimate the count, since cartop use does not involve a trailer), which each trigger the counter once on the way in and once on the way out.  Assumes there is only one person in the vehicle, which is a low estimate.

[b] – We divided the total counts by 4.  This assumes every vehicle has 2 axles, which each trigger the counter once on the way in and once on the way out.  Assumes there is only one person in the vehicle, which is a low estimate.

[c] – Traffic counter was pulled from the site on 10/20/14.


Study omits one key use of the Project Area: swimming

Table 4.1.3-2 includes project-wide use of the sites.  The most popular activity identified in this table was walking, hiking, and jogging.  The second most popular was “unidentified recreation activity.”  CRWC believes that the goal of the study (to determine the amount of recreational use and demand) cannot be met when the FirstLight surveys have apparently missed one or more major recreational uses.  CRWC suggests one of the major categories is “swimming.”  Swimming was not listed as a recreational use category in the calibration count sheets, and therefore swimming could not be noted down when observed by personnel conducting the spot count.  According to Table 4.2-3, recreation survey respondents did indicate that they were swimming at the sites – 19 indicated that this was the primary activity, and a total of 93 indicated that they swam during their visit (surprisingly, 22 indicated doing so in the winter).  The Town of Montague has indicated that the lack of river access for swimming is a key interest area for their residents.  FirstLight’s failure to include swimming in Section 4.1.2 and 4.1.3 in the report does not mean that swimming doesn’t occur and there is no demand for it, despite FirstLight’s wish for it to go away.

For example, page 4-3 of the report states that the most popular activities at Cabot Camps were fishing (26%) and walking/hiking/jogging (19%).  Actually, the most popular activity was “unidentified” at 39%, according to Table 4.1.3-2.  This site has a nice gentle entry into the water and is used for swimming.

Potential error

At the Station No. 1 fishing access site, cross country skiing is listed as 14% of the activities at this site in Table .  This appears to be an error.  The calibraton count spreadsheet shows no cross country skiing at this location.  This is not a practical activity at the site.  It also estimates biking at this site to be 21% of the use.  We reviewed the spot count record for this site, and on April 27, 2014, the spot counts indicated that 5 people biked to the site.  We do not agree that the means of transportation to the site indicates the recreational use AT the site.

Assessing User Demand

One of the study objectives was to determine the amount of recreation use and demand at the Turners Falls and Northfield Mountain recreation sites.  Unfortunately, FirstLight only interviewed people who came to the facilities, which indicates that something about that facility appealed to them.  They refused to interview people who did not show up because they found the facility faulty and went elsewhere.  In contrast, the surveys done on the upper dams by TransCanada included contact with people who did not use the TransCanada facilities.

Survey of Connecticut River Watershed Council and Appalachian Mountain Club members

In an effort to gather additional information who may not use the facilities and/or who use them infrequently, CRWC and AMC developed an online survey using the TransCanada user survey as a starting point.  We posted our survey on Survey Monkey and notified all CRWC members and the AMC members who lived within 30 miles of the Projects.  In total we got 321 responses from CRWC and AMC members.  Since they are members of the organizations, they are either biased toward an affection for the river or someone who is engaged with the outdoors already.  Based on the zip code responses, our respondents lived in the following places: 137 from western MA from Agawam to Northfield and in the watershed, 16 central and eastern MA, 1 who splits time between western MA and VT, 54 NH inside watershed, 5 NH outside watershed, 57 VT inside watershed, 1 VT outside watershed, 8 CT inside watershed, and 1 outside state (Texas).

Of our survey respondents, 72% regularly visit the sections of the Connecticut River under relicensing or Northfield Mountain and 27.7% do not.  Of those who don’t regularly visit this region, 34% said they prefer other areas with better opportunities and 52.9% cited other reasons.  Of the 55 people who responded to the question about the kinds of recreational facilities and activities that would make them more likely to recreate on the Connecticut River included, the most popular answer was better and easier access sites and launch facilities for canoes and kayaks, and trails for hiking, biking, and birdwatching.

Our survey asked respondents if they had ever portaged around the Wilder, Bellows Falls, Vernon, and/or Turners Falls Dams.  Of the 158 people who responded to this question, we got 32 descriptions of the experience.  Several of those responses indicated that the Poplar Street access was too steep and was not easily accessible.  One respondent indicated a desire for access upstream of the Sunderland Bridge, but an inability to use the steep access at Poplar Street.  Other responses pointed at portage length and there was a general comment about not being able to find the put-in and take-out points for any portages.

Survey respondents indicated they found the following amenities important if they were made available:  parking areas, road access to recreation areas, toilets, trash receptacles, tent campsites, boat access for canoes and kayaks, picnic sites, swimming/beach access, scenic views, wildlife viewing and nature trails, hiking trails, and biking trails.

Of the 227 people who answered the question, 73.6% said fluctuating river levels on the Connecticut River have not affected their recreation experience and 23.8% said that river fluctuations have negatively affected their recreation experience.  This answer has not been split out by project.  Out of 60 people, 51.7% said they would prefer a smaller amount or range of fluctuation of river level and 41.7% said they would prefer more gradual or slower fluctuations.

CRWC will post the SurveyMonkey results and raw data as a separate filing for all projects later this week.

Additional CRWC observations

Study 3.5.1, the baseline inventory of wetland habitat, shows the daily changes in elevation at transects in the study area based on the hydraulic model.  Table 4.3-10 of that report shows that at Transect 4, which is downstream of the confluence of the Deerfield River near the railroad bridge, the daily change in elevation for the months of June, July, August, and September are 4.0 feet or greater 29%, 36%, 42%, and 38% of the time, respectively.  This is the area of most dramatic river fluctuation, and we believe that it impacts recreation use of the river downstream of Cabot.  The Recreation Use/User Contact Survey did not survey river users downstream of the project area, and we continue to believe this is an oversight.

3.6.5 Land Use Inventory

FirstLight regarded an information request we sent FirstLight on March 25, 2016 requesting FirstLight ownership of recreation lands as outside the scope of the study.  We disagree and believe it is consistent with 18 CFR §5.15(a).  One of the study objectives was to, “Identify current land use controls on lands within the Projects’ boundaries and on lands abutting the Projects’ boundaries up to 200 feet.”  One key land use control on lands within Project boundaries is land ownership.  Unfortunately, the report does not identify ownership and other controls such as FirstLight’s flowage rights within the Project boundaries.  FirstLight does not own all of the lands within the project boundaries.  FirstLight ownership of lands within 200 feet of the Project boundaries is identified in Figure 4.4-1, but nothing indicates ownership within the boundaries.


In our comments on the updated Proposed Study Plan sent to FERC on July 15, 2013, CRWC wrote, “One of the maps should show land uses with lands owned or flowage rights owned by FirstLight clearly identified.”  Without knowing ownership of the land, it will be impossible for stakeholders to suggest and discuss anything with regard to land uses in a revised draft license application.


Section 4.4 of the report states that, “FirstLight has an established FERC-approved Permit Program through which it administers non-project uses of Project lands including lands it owns in fee, or in which it has an interest.”  FirstLight’s April 22, 2016 response to CRWC’s information request admitted elements of this Permit Program were not FERC-approved.  CRWC will comment on other aspects of this Permit Program at a later time.

We make note of Table 4.2-2 that indicates only 0.4% of land within the Projects’ Boundaries are conserved for recreation.  It looks like all of the land on Northfield Mountain, as well as all the other recreation land we know to be owned by FirstLight has no conservation protections on it.

CRWC inquired with the Town of Greenfield planning department about ownership of land along the bypass section on the Greenfield side of the river.  See attached map.  We received this map shortly before filing this letter with FERC, and have not been able to determine if Figure 4.2-1 Map 8 is lacking any information about conservation land.  We recommend FirstLight look at the attached map, and confirm land use ownership, if it hasn’t already.

CRWC request:  CRWC requests that FirstLight provide information on land it has ownership or any other control over, and the land use associated with those lands, in an addendum to Study 3.6.5.  See 18 CFR §5.15(a).

We appreciate the opportunity to provide comments on the studies submitted on March 1, 2016.


Andrea Donlon

River Steward



Letter from Dr. Kirsten Martin

Land ownership information along CT River in Greenfield

Note:  AMC-CRWC Survey results not included in this posting; to be filed later this week separately