December 22, 2014

Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

Re: CRWC comments on the Great Falls hydroelectric project

FERC Project NO. 2839 Preliminary Application Document.

Dear Secretary Bose:

Statement of Interest

The Connecticut River Watershed Council is a nonprofit membership organization that has an interest in protecting environmental values that directly and indirectly support the state, regional and local economies and quality of life in the Project area.

The interests and goals represented by CRWC 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.

Following are the comments from CRWC on the Great Falls hydroelectric project FERC Project NO. 2839 Preliminary Application Document.

4.1 Existing Project Facilities Although, not immediately part of this section, while on site it was clear that there is a lot of deferred maintenance that needs to be undertaken at the facility. The turbine and supporting equipment seemed to be in fine shape albeit old. But the exterior of buildings and the dam and canal structure are in need of significant repair based on observation.

4.4 Existing Project Operations The PAD says that the operator adjusts turbine settings to ensure run of river but the operator is not present at all times. The approach used by the operator is to eye ball the reservoir level and adjust from that observation. Some approach of automatic monitoring and adjustment should be a license condition to assure run of river operations 24/7.

Section 5.2.10 Water Quality Monitoring – The PAD describes periodic but ad hoc water quality monitoring in the Passumpsic River Watershed, but no water quality data exists within the project area. At a minimum, dissolved oxygen and temperature should be evaluated for compliance with Vermont Water Quality Standards.

4.4.2 Low and High Water Operations While we were on site we were told that the bypass gate had not been used in “a while.” It was not made clear how long a while was in this case. This leaves one with the question of how minimum flow is maintained during low flow periods (August – October according to the flow duration curves) when water does not flow over the dam. Fish Species and Habitats There has not been a full fish assemblage study done at the site ever according to the PAD and on-site discussion. Some species have been studied but it is unknown if some species are even present. Once the species are established it is important to note that resident species migrate from spawning to rearing habitats up and down river. Resident salmonids actively migrate during the spring and fall. Downstream passage for resident salmonids would allow fish to seek the best available habitat and food resources. Resident fish should be able return to tributaries upstream of the project to spawn.

5.7.3 Recreation Access to the river for fishing, swimming or canoeing is difficult since the gate at the top of the hill is closed unless there is a LED staff person on site. A closed gate makes access difficult and the warning sign on the gate is discouraging of using the property to gain access to the river. Using the opportunity of an open gate because staff is on-site with a vehicle is unsure since a recreational user would not know for sure when the staff person will leave and lock them behind the gate.

CRWC thanks FERC for the opportunity to comment on the Great Falls hydroelectric project.


David Deen Upper Valley River Steward