December 22, 2014

Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

 

Re: CRWC study requests for 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 throughout the four state watershed and 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 studies that CRWC requests be undertaken as part of the relicensing of the Great Falls hydroelectric project FERC Project NO. 2839. These requests are based on the PAD information and the on the site visit.

Physical plant review study

  1. Goals and Objectives

The goal of the study is to determine the eventual overall cost of bringing the facility up to top physical condition as the project is applying for a 30-year license renewal.

  1. Resource Management Goals

The safe and responsible operation of the facility in the interests of the public safety and protection of all riverine species is the point of the FERC relicensing process.

  1. Public Interest Considerations

Public safety and aquatic habitat are clear public interest considerations. If equipment and structures do not work as planned the project could become a danger to people and the environment.

  1. Existing Information

I am sure that there are some existing evaluations of the facility but none was presented in the PAD nor through conversation during the on-site visit.

  1. Project Nexus

This is a study request of the project itself and its long term viability. If FERC and the project operator are to even consider the removal option both need to know what the physical plant costs would be into the future under a new license.

  1. Proposed Methodology

Standard facility and structure evaluations are done all the time so it should be no problem for a study of this kind to be done by the consulting engineering firm working for the project applicant.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

Automation of the Great Falls facility study

  1. Goals and Objectives

The PAD states and during the onsite visit is was stated again that the facility operator uses personal judgment to set the turbine flow level when there is an operator on site. The goal of the study is to determine the cost to insure compliance as a run of river facility.

  1. Resource Management Goals

The Passumpsic River is classified by the state of Vermont as a Class B water and cold water fish habitat. The study would establish costs to meet the basic run of river requirement that will help the facility meet the Class B standard.

  1. Public Interest Considerations

High quality Class B waters are a central goal of the VT Water Quality Standards (WQS) in the interest of a high quality of life for Vermont residents and visitors.

  1. Existing Information

There is no information presented as part of the PAD but similar operations throughout NE use automated systems for flow control and the study would fill in that information void.

  1. Project Nexus

As a likely license condition compliance with a run of river requirement is central to the relicensing of this facility.

  1. Proposed Methodology

Simple contact through Vermont League of Cities and Towns, professional engineering associations or through the professional association of hydroelectric operators should provide more than enough information to complete the study.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

Water Quality Monitoring Study

  1. Goals and Objectives

The goal and objective is to determine if the project affects the water quality in the area of the project so does or does not meet the VT WQS.

  1. Resource Management Goals

To make sure that the project does not affect the water quality in the immediate area of the project so that water flowing through the project meet the WQS for dissolved oxygen and temperature.

  1. Public Interest Considerations

Meeting the WQS is a legal requirement for any activity that creates a discharge to the waters of the state. It is also an important consideration in the use of the waters by the public.

  1. Existing Information

There is only sporadic ad hoc water quality testing throughout the watershed and there in no testing that has been done at the facility.

  1. Project Nexus

The project impounds 1 mile of river that would otherwise be free-flowing. The results of the operations of the project must conform to WQS. This study would determine if there were mitigation steps necessary should the project receive a license renewal.

  1. Proposed Methodology

Standard testing on a regular schedule through the year is an approach used in many water quality determinations.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

Fish Species Assemblage Study

  1. Goals and Objectives

The goal and objective of the study is to determine the makeup of the fish assemblage in the river near the facility.

  1. Resource Management Goals

It is necessary to know the makeup of the full fish population in order to make the water quality mitigation positively affect the fish species present in the project area.

  1. Public Interest Considerations

A healthy wild fish population is in the best interests of the river and the Vermont residents and visitors who value a healthy river.

  1. Existing Information

According to the PAD there has not been a fish assemblage study done on the reach of river affected by the project.

  1. Project Nexus

The project affects the quality of the habitat and the potential for migration of fish present in the river consequently the project affects the makeup of the fish species present.

  1. Proposed Methodology

Assessing a river for the fish species present is a known methodology.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

Fish Passage Study

  1. Goals and Objectives

The goal and objective of the study is to determine the cost to install up and down stream passage at the Great Falls dam.

  1. Resource Management Goals

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.

  1. Public Interest Considerations

A healthy and wild population of fish is in the best interests of the river and the people of Vermont. Knowing the cost of passage compared to the economic viability of the facility is necessary information if FERC is to meet its responsibility to balance power production with protection of the environment.

  1. Existing Information

According to the PAD there has been no study of the possible costs of fish passage done at this site since the applicant did not feel one was warranted because there are no anadromous fish present in the watershed. This approach limits the focus too narrowly and ignores the need of resident populations of fish.

  1. Project Nexus

If the dam were not present then fish would have access to up and down stream passage.

  1. Proposed Methodology

Estimating costs for installation of fish passage is a known methodology as fish passage studies are a normal part of FERC licensing applications.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

Recreation Access Study

  1. Goals and Objectives

The goal and objective of the study is to determine what access to the river Vermonters and visitors feel would be appropriate at the facility.

  1. Resource Management Goals

The access to the river at the facility is limited at best. Determining the interest of area residents, their guests and visitors to the area would want is an important consideration. Recreation is a major economic activity in the area and rivers are a big part of that attraction.

  1. Public Interest Considerations

Public use of a public trust resource is at the heart of the FERC review. FERC will need the information of a recreation study to establish conditions for the facility in the new license.

  1. Existing Information

There is little or no existing information about what the wider community wants in terms of access to the river near the facility.

  1. Project Nexus

The project uses a public trust resource to generate value for a limited number of people in the nearby community. The river should be open as much as possible to all Vermonters and visitors.

  1. Proposed Methodology

A survey of sporting and river user groups (fishers, canoeists, swimmers) would provide guidance for FERC in terms of what conditions might apply to the new license.

  1. Level of Effort and Cost

The level of effort and cost will be determined by the methodology that is ultimately used, but is expected to be comparable to that of similar FERC projects of this size.

CRWC thanks FERC for the opportunity to suggest these studies.

Sincerely

David L Deen Upper Valley River Steward