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August 2022 – Hydroelectric Relicensing Update

Home|Projects|Hydro Power|August 2022 – Hydroelectric Relicensing Update

August 2022 – Hydroelectric Relicensing Update

August 27th, 2022|Tags: Great River Hydro, hydro, Hydro Power|

August 2022: Hydropower Updates

Contents:

  • FirstLight Power updates
  • Great River Hydro updates
  • What you can do!

Need a refresh about why you are getting this email? Scroll down for the scoop!

Remember: CRC River Stewards Kathy Urffer and Kelsey Wentling are available to update your local town board or interested group on the relicensing process and CRC’s concerns about the river. It is vital that community members stay engaged as we come into this final stretch of a once-in-a-lifetime relicensing process!

Updates on FirstLight Power Facilities in MA

Turners Falls Dam & Northfield Mountain Pumped Storage

The good news first!

You may recall from our last update that FirstLight Power has filed settlement agreements to address recreation, fish passage, and river flows.

Some of the new recreation improvements that we are excited about include an improved ADA-accessible dock at Northfield, the addition of trails on conserved land, mountain biking trails, camping sites, pocket parks, conservation of climbing ledges, new boat access on the Miller’s River at Cabot Camp and at Unity Park in Turners Falls, and a walkable portage around the Turners Falls dam. These would all be in place within 5 years of the license being re-issued.

In addition to the recreation improvements, whitewater boating releases will provide recreational whitewater flows for many weekends between July and October.  CRC was not involved directly in the whitewater negotiations, but we do support it.

CRC has been a voice bringing community needs for access to a healthy river to the negotiations table, and we aren’t done yet!  These improvements happened because CRC and other stakeholders pushed FirstLight Power to the table.  This collaborative work demonstrates again that public engagement gets results!

These agreements have proposed some good changes in how river flows will occur to better support migratory fish and minimize impacts to other critters that live in the river and around the riverbanks.  But that’s not nearly good enough…

Because there is also not-good news:

FirstLight Power is proposing unnecessarily lengthy timeframes to install a barrier net at Northfield Mountain and fish passage projects.

Waiting until 2033 for a new fish lift is too long! 

NOTHING has been agreed upon to address impacts from Northfield Mountain beyond a minimally helpful barrier net (not to be operational until 2031!) and a payout to mitigate for the decades of impacts to young fish.

In fact, this agreement allows FirstLight to use a larger operating range in the upper reservoir which will increase negative impacts on erosion and fish habitat.

There is nothing in place to prevent FirstLight from dewatering parts of Barton Cove.  Last summer, excessive pumping at Northfield Mountain left boats stranded.

And last but not least, the flow in the river for most of the year is still too low to meet state water quality standards and support healthy aquatic life and recreation in the river.

These shortcomings mean that any license issued will be in violation of the Clean Water Act.  We brought our concerns to the MA Executive Office of Energy and Environmental Affairs and we filed this correspondence with FERC, urging them to move the process forward. You can read our letters and the response from FirstLight here. 

Here is what we know: The now years-long delay in the relicensing process and in the negotiation of agreements are not good enough for the river, the fish, the watershed, and the community. However, the delay has been “good for business” in one notable way: in helping FirstLight Power generate more money with limited accountability.

A few things to keep in mind:

  • The river is a public resource and is vital to all of us.
  • First Light Power is an important community partner.
  • Local, state, and federal folks are working hard to ensure a smart, equitable, and sustainable relicensing process.
  • FirstLight Power can afford to do this work and the profits they have generated in these staggering delays can offset any revenue impacts of changes proposed for a healthy river and watershed. FirstLight Power’s owner is PSP Investments, a multi-national, sophisticated investment firm cognizant of anticipated costs for healthy use of resources – and of utilizing delay tactics for their benefit.

What’s next? 

With their update to the Federal Energy Regulatory Commission (FERC), FirstLight Power has won yet another delay by indicating that it will file a final, comprehensive settlement agreement by December 2022.  Although we want it to happen now, FERC will likely wait until after that settlement agreement to issue its formal “REA” (Ready for Environmental Analysis) document, which establishes the next set of relicensing deadlines.  Once the “REA” is issued, the state will be involved in evaluating the application and settlement agreements (through the 401-water quality certificate).

This time-consuming process is long overdue for resolution.  Our voices – your voice –  will make a difference in a healthy and flourishing river.  What does that mean? Scroll down for how to stay involved.

If you want to dig in directly:

12/4/2020: FirstLight Amended Final License Application

2/28/22 – “Agreement in Principle” Whitewater Boating Releases and Recreation Improvements

3/18/2022: “Agreement in Principle” Fish Passage and Flows

8/19/2022: CRC concerns about the settlement process

Great River Hydro Facilities in VT & NH

Wilder, Bellows Falls, and Vernon Dams

Great River Hydro (GRH) proposed an alternative operational scenario – consisting of less peaking and more water flowing through the river, which will be much better for the river, but they offered little else in the Amended Final License Applications (AFLA) filed in December of 2020 for protection, enhancement, and mitigation for our communities over the next 30 to 50 years.  CRC was concerned with information lacking in the AFLA so we submitted comments to FERC on January 28. In response to a FERC request, GRH submitted some spreadsheets that contain what they will spend for mitigation at each facility in March of 2021.

GRH and fisheries biologists from VT Fish and Wildlife, NH Fish and Game, and the US Fish and Wildlife Service have spent the last year negotiating a settlement to address improvements for fish passage at Wilder, Bellows Falls and Vernon dams, which they filed with FERC on August 2, 2022. The settlement provides some positive aspects, such as opening the ladders earlier in the spring to accommodate the migration of resident species, setting clear performance measures to evaluate upstream and downstream passage for American shad, and a detailed process to develop effective downstream passage (thereby reducing mortality and injury to American shad and American eel as they attempt to migrate through the turbines).

An important improvement to the river at Bellows Falls would be the removal of a dam in the river right below the hydropower dam. Removing this diversion dam – designed to support upstream passage of salmon – will benefit river habitat and recreation.  Unfortunately, GRH is trying to avoid paying for the removal of this structure.  And they are seeking delay implementation of fish passage improvements for up to 16 years after their new license

Since this is a formal settlement, FERC has established a comment period.  If you would like to comment on the GRH fish passage settlement, you have until September 2 to file comments! (contact Kathy – scroll to bottom – with questions!)

Additionally, while this fish passage agreement is a milestone, there absolutely needs to be more information provided to address recreation and  indigenous concerns regarding traditional cultural properties. There is also a need for GRH to be proactive and responsive to landowner’s concerns for the potential of operational changes not successfully slowing continued land erosion along the river.

If you want to dig in directly:

12/7/2020: Great River Hydro Amended Final License Application

8/2/2022: Great River Hydro Fish Passage Settlement Agreement (comments due on this by Sept. 2!)

You’ve read this far.

Wonder what YOU can do?

We – and the health of the river for the next 30 to 50 years – need you to stay involved!

There are a few things you can do right now to keep this conversation alive:

  • Submit comments on the Great River Hydro Fish Passage settlement by September 2! (Scroll down for Kathy’s contact info!) 
  • Write to Secretary Card and MA DEP telling them you’ve had enough of FightLight’s delay tactics and ask them to take a seat at the table to negotiate a better deal NOW!
  • Let your legislators know you are paying attention and care about this process.
    • Vermont
    • New Hampshire
    • Massachusetts
  • Do the same with your local selectboards, conservation commissions, and recreation boards.
  • Talk it up – let your community know what’s going on and share why this tangled process matters for all of us.
  • Write a letter to the editor – keep letting the media know hydro relicensing is important to follow.
  • Forward this newsletter to someone who would be glad to learn more.
  • Reach out!: CRC River Stewards Kelsey and Kathy are available to update your local town board or interested group on the relicensing process and CRC’s concerns about the river. It is important that all parties re-engage as we come into this final stretch of this once-in-a-lifetime relicensing process!

It seems likely that FERC will wait to move forward until further settlement discussions have been completed by December. FERC will be required to consider the cumulative impact of the hydro-relicensing under their Environmental Impact Analysis. This means FERC needs to have complete information regarding the scope of what will be provided for mitigation under the new license.

We are looking forward to the official public comment stage, where you can voice your concerns directly about the final application. Once the process has arrived at that stage, CRC will let you know. Check out our Watchdogging Hydropower page for more info.

Need a refresh about why you are getting this email?

Five hydropower facilities along the Connecticut River are up for relicensing. The next license will last for 30-50 years and will impact hundreds of miles of the Connecticut River. FirstLight Power, owner of the Turners Falls Dam and Northfield Mountain Pumped Storage in MA, and Great River Hydro, owner of the Wilder, Bellows Falls, and Vernon Dams in VT and NH continue to negotiate – and delay – the relicensing. Remember: our voices – your voice – will make a difference in achieving a healthy and flourishing river.

Additional Resources

Full License Applications submitted to the Federal Energy Regulatory Commission (FERC) in December 2020:

  • Great River Hydro: Open “80 – Amended Final License Application” folder. Most information is in “Exhibit E.”
  • FirstLight Power: The Executive Summary is a concise summary of what the application package includes, although CRC believes the total costs associated with their proposed environmental measures are inflated. (NOTE: Ongoing settlement negotiations may result in different proposed measures than those initially submitted.)

You can learn more about the details of the FirstLight Power application by viewing our January 27, 2021 LiveStream virtual presentation:

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You can learn more about the details of the Great River Hydro application by viewing our January 13, 2021 LiveStream virtual presentation:

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Video that covers some of our concerns about riverbank erosion:

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Video that covers some of our concerns about recreation:

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If you have any questions or comments, please be in touch:

Kathy Urffer

 

VT & NH River Steward

kurffer@ctriver.org

802-258-0413

Kelsey Wentling

 

MA River Steward

kwentling@ctriver.org

413-772-2020 x216

15 Bank Row  |  Greenfield, MA 01301

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