CRWC is a leading river advocate in the Federal Energy Regulatory Commission (FERC) process to regulate hydropower facilities in the Connecticut River basin. In exchange for the privilege of damming our rivers, a private hydropower operator must provide direct benefits to the public and the river. These benefits may include recreational facilities, better fish passage and reducing damage to healthy river habitats. CRWC has, since our founding in 1952, worked to see that hydro projects meet the federal and state laws that require a balancing of public good and private interests.
When licenses come up for renewal, we begin our homework years in advance. Working with other river guardians, we examine proposed operations for each facility. Our formal comments offer our own proposals to ensure balance between hydro operations and protections/improvements for the river. We use solid scientific and technical information to negotiate the best deal for our rivers – and our presence does make a difference.
There are dozens of FERC-regulated hydropower projects on the mainstem Connecticut River and its tributaries. Some dams are quite large, producing thousands of megawatts of electricity. Their individual and cumulative river impacts are also huge. These dams affect flows and water levels from the headwaters region, 410 miles from Long Island Sound, to the Holyoke Dam, 86 miles from the Sound. Hydro dams run our appliances, but dams disconnect rivers and block the movement of migratory and resident fish and other aquatic animals. They create reservoirs where people boat and swim but reservoirs are settings that warm rivers, impede natural river flows and encourage the accumulation of sediment, burying important river bottom habitat.
Being an advocate for the river during relicensing of these facilities is vital because FERC issues these licenses for 30 to 50 years. These licenses lock-in minimum flow requirements, impoundment levels, fish passage and operating regimes for generations to come.
Five Connecticut River facilities up for new licenses
Beginning in the fall of 2012, FERC began the relicensing procedure for five hydroelectric facilities in northern MA and southern VT that produce over 30% of hydropower generation in New England. Together they affect more than 175 miles of the Connecticut River. FERC last issued licenses for these facilities between the late 1960s and 1980s and all expire in 2018.
The five hydro projects include dams at Wilder, Bellows Falls and Vernon in Vermont, owned by TransCanada which also owns hydropower facilities in northern Vermont and on the Deerfield River. The MA facilities up for renewal are the Turners Falls Dam and the Northfield Mountain Pump Storage Project, owned by FirstLight Power, a subsidiary of GDF Suez. Both companies are multinational corporations with their headquarters located in foreign countries.
In March of 2013, CRWC submitted over 300 pages of comments and study requests to FERC for additional information CRWC felt was needed to make sound decisions about license renewal. These comments focused on how to improve the ecological health of the river and recreational opportunities for the public, including:
- Increasing investments in recreational and educational opportunities for river users with improved fishing and boating access, safe and walkable portage facilities, more and better maintained campsites, and migratory fish viewing facilities that support educational programs and are ADA accessible.
- Minimizing riverbank erosion by moderating river flow and reservoir fluctuations at all facilities with a special emphasis on exploring the option of a closed-loop system at the Northfield Mountain Pump Storage Project in Massachusetts.
- Investigating how to improve aquatic species habitat. Important factors to consider include efficient and successful fish passage, minimum river flows to support fish habitat and impacts of these dams on the migration of American shad, American eel, dwarf wedgemussel, host fish species, and endangered shortnose sturgeon.
TransCanada and FirstLight submitted proposed study plans in April, 2013. This important early stage of the relicensing process aimed at filling in research gaps that will help participants like CRWC negotiate license requirements. CRWC reviewed the proposed studies in detail, attended dozens of technical meetings related to all of the proposed studies, and submitted detailed letters on the updated and revised study plans in 2013 and through the spring of 2014.
CRWC pushed for better erosion studies, more water level loggers, better recreational user surveys, more rigorous studies of the impacts of redirected flows, impact of canal drawdowns, among other concerns. FERC ruled on the study plans in the fall 2013 and winter 2014, requiring the companies to make several changes based in part on CRWC’s comments.
TransCanada and FirstLight will conduct their field studies in 2014 and 2015, and will file their draft license application at the end of 2015. CRWC river stewards Andrea Donlon (MA) and David Deen (Upper Valley) are participating in all the formal proceedings. They will take the lead in the review and analysis of the reports that come out of the field studies and preparation of CRWC comments. They are working to engage the public in the process. Get in touch if you would like to participate!
Past work to improve hydropower
The 15-Mile Falls Project is a series of dams near Littleton, NH — the Moore, Comerford and McIndoes Falls dams. These impoundments represent the largest single hydroelectric generating complex of dams in New England, affecting levels and flows from the Connecticut Lakes to the dam at Wilder, VT. CRWC is a signatory to the 2001 landmark agreement guaranteeing increased river flows. The agreement established permanent easement protection on 9,200 watershed acres and created a $15 million Mitigation and Enhancement Fund.
The Holyoke Dam is the lowermost dam on the River, controlling migratory fish access to 85% of the spawning habitat in the Connecticut River basin for American shad, blueback herring, shortnose sturgeon, and other species. In 1999, CRWC helped win increased habitat flows in the bypass reach below Holyoke Dam as well as improvements in fish passage and the 401 Water Quality Certificate in the new license.
The Canaan Dam is located in Stewartstown, NH and Canaan, VT. This 275 foot-long dam and hydro facility backs-up a 4,000 foot pond on the Connecticut River. During the 2009 relicensing, CRWC and Trout Unlimited successfully requested that Vermont include a condition in their 401 Water Quality Certificate that the dam owner would need to install fish passage at the request of the state. Although appealed by the dam owner to the VT Environmental Court, the condition remains in the VT 401 Certification and thereby is a condition of the FERC license.