July 28, 2014

John S. Howard
Director, FERC Hydro Compliance
FirstLight Power Resources/GDF Suez
Northfield Mountain Station
99 Millers Falls Road
Northfield, MA 01360

Re: Temporary license amendment for winter 2014-2015

Dear John,

The Connecticut River Watershed Council (CRWC) reviewed FirstLight Hydro Generating Company’s Draft Application for a Temporary Amendment of License for the Northfield Mountain Pumped Storage Project (NMPS). We appreciate the opportunity to comment on this prior to your submission to FERC. The application requests authorization for a temporary change in the water surface elevation limits for the NMPS Upper Reservoir for the period December 1, 2014 through March 31, 2015. CRWC submitted comments and intervened in previous temporary amendments in 2001, 2005, and 2006, along with a permanent amendment application that was later withdrawn in 2007. Below are CRWC’s comments on this current proposal.

Previous temporary amendments were made based on a specific request from ISO-NE and the changes were authorized only under certain emergency operating conditions as determined by ISO-NE. The requested change as drafted does not ask for the change under limited emergency conditions, but for the entire period December 1, 2014 to March 31, 2015. Moreover, the purported need to provide ISO-NE with additional resources to deal with a potential shortage of energy is vague and potentially unjustified.

In an email from ISO New England Customer Support dated July 16, 2014, they stated, “We anticipate having adequate resources to meet demand over the winter and while fuel availability is always a concern we have implemented a winter reliability program again this year to mitigate against such risks. That is currently filed with FERC and can be found at the link below in two parts. Winter 2014-15 Reliability Program (Part 1 and 2 of 2) http://www.iso-ne.com/regulatory/ferc/filings/2014/jul/index.html.” A review of this report indicates no requests regarding NMPS, hydropower, or pumped storage facilities specifically. The introduction to the report summarizes the plan as follows, “The Winter Reliability Program is intended to maintain reliability through fuel adequacy by creating incentives for dual fuel resource capability and participation, offsetting the carrying costs of unused firm fuel purchased by generators, and providing compensation for demand response services.” It appears that FirstLight is responding to market incentives that will help provide electricity during the winter, and be financially beneficial to the company.

Erosion Impacts
Figures E 1.0-13 through E 1.0-16 show Turners Falls impoundment elevations for baseline vs. temporary amendment conditions during December, January, February, and March. The figures indicate that the daily minimum pool elevation will often be lower during the temporary amendment conditions than during baseline conditions. Based on our experience attending Streambank Erosion Committee meetings, visual observation of the river, and review of the 2007 Field Report, when the toe of the bank is lowered, this can contribute to notching and undercutting, thereby exacerbating erosion of riverbanks in the Turners Falls pool.

Entrainment Impacts.
Currently the entrainment impact of the NMPS facility during the winter is not well understood, which the pending appeal by USFWS regarding the sufficiency of FirstLight’s proposed entrainment study well illustrates. Theoretically, the relicensing entrainment study (or studies) will shed better light on this subject. So until such time as we have a much better understanding of the entrainment impacts of NMPS, it seems inappropriate to request additional pumping capacity.

As a general matter, it is problematic to request a license amendment in the middle of the relicensing process, particularly to have FERC make decisions about environmental impacts of a proposed operating scenario that may (or may not) influence the proceedings while we are in the process of gathering new and important information about your facility’s impact on the river.

Given the potential impacts on erosion and entrainment, the fact that the facility is in the middle of relicensing, and the lack of compelling need for the additional electricity, the temporary amendment application seems unjustified and untimely.

Thank you for the opportunity to provide input on the draft temporary amendment. As ever, we are happy to talk on this directly if that is helpful.

Sincerely,

Andrea F. Donlon
River Steward