February 7, 2013
I have reviewed the Application for Authoriziation of Non-Project Use on behalf of the Connecticut River Watershed Council. The Holyoke Canal system seems well-suited as a demonstration area for the testing of innovative small hydropower technologies. CRC concurs with the application, with the following comments:
1) We have read and support the letter submitted by Mass. Division of Fisheries and Wildlife.
2) Could courtesy copies of the information sent to resources agencies and the Massachusetts SHPO be sent to the NGO members of the CCT, or could there be postings on the HG&E website describing each project?
3) The information HG&E obtains about each project (shown in Step 1 of Exhibit A) should include the following:
* flow levels needed for testing of each product, and confirmation that these flows are compatible with Holyoke’s Comprehensive Canal Operations and Flow Plan.
* location of equipment showing known mussel locations
4) Step 2 of the process outlined in Appendix A provides a 30-day agency comment period, and if no comments are received, HG&E assumes no opposition or concern. While CRC understands that HG&E does not want to hold up projects by lack of agency attention to filings, we still recognize that there are field seasons and periods of time that agency staff are very busy. The next 5.5 years with the relicensing of the 5 upstream hydropower facilities on the CT River will have very busy periods. HG&E should consider a 30-day review period, followed by a reminder and wait for 15 days if agency staff indicate a desire for additional review time.
Thanks, AndreaAndrea Donlon, River Steward CONNECTICUT RIVER WATERSHED COUNCIL, INC. 15 Bank Row Greenfield MA 01301 Phone: (413)772-2020 x. 205 Fax: (413)772-2090