November 13, 2015


Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426


Re:      Northfield Mountain Pumped Storage Project No. 2485-063

Turners Falls Project No. 1889-081

Comments on the Updated Study Report (USR) dated September 14, 2015

Joint Comments from the Connecticut River Watershed Council and the Appalachian Mountain Club on completed recreation studies submitted as part of the USR


Dear Secretary Bose,

The Connecticut River Watershed Council, Inc. (CRC) is a nonprofit membership organization established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed. The interests and goals represented by CRC include improving water quality; enhancing habitat for fish and other aquatic biota; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety. We have been participating in the relicensing of the five hydropower facilities on the Connecticut River since the beginning of the process in late 2012.

Since 1876, the Appalachian Mountain Club (AMC) has promoted the protection, enjoyment, and understanding of the mountains, forests, waters, and trails of the Appalachian region. The AMC is the largest conservation and recreation organization in the Northeast with more than 90,000 members, many of whom live within three hours of the Connecticut River and would enjoy this section as a day-long or longer trip or as a self-propelled boating opportunity.

CRC and AMC are jointly submitting comments on several recreation study reports that have been completed as part of this relicensing process. These completed studies were included as part of the September 14, 2015 Updated Study Report (USR) package, and were discussed at the USR meetings held on September 29 and 30, 2015. Both organizations attended the USR meetings.

Our comments follow below.

3.6.1 Recreation Use/User Survey

As part of a variance to Study 3.1.2, FirstLight collected boat wave data and took photos of boats at 3 locations in the impoundment during the summer of 2015.

CRC-AMC request: CRC and AMC recommend that boat data from the boat wake study, such as total boat numbers for the season at each location and possible seasonal peak use numbers (max number in a day and what day that was, etc.) be incorporated into the report for Study 3.6.1. If there is information about motorized vs. non-motorized boat numbers, that would also be useful information.

3.6.2 Addendum to the Recreational Facilities Inventory and Assessment

The updated maps and survey forms appear to be done more thoroughly.

Our only comment is that we are baffled why the form for site 25, the Poplar Street Access says this is an “informal” site. The Poplar Street Access is owned by FirstLight and is the “formal” put-in location for the portage around the Turners Falls Dam. It is also the only access location between the Turners Falls dam and the Sunderland Bridge.

3.6.3 Whitewater Boating Evaluation

This is a completed study.

CRC observed the controlled flow runs on Saturday, July 19 and Monday, July 20, 2014; AMC observed on Sunday and Monday. We observed the put-in, the first set of rapids from the Gill-Montague Bridge, the rapids at the Rock Dam, and the take-out at Poplar Street. In general, the management of the study was very good. Several of the conclusions in the report, however, do not follow from the study.

The Executive Summary for the Study 3.6.3 Report oddly concluded that, “Demand for boating in the bypass reach appears to be tempered by the numerous other boating opportunities that occur within close proximity of the Turners Falls Project.” We point out that no question tackled the issue of demand. Question #10 in the Comparative Flow Evaluation Form asked participants to score other rivers in comparison to Turners Falls bypass. This question does not address demand in any way; it just asks for a comparison between two rivers on a variety of features.

Ratings for the Turners Falls bypass were generally quite strong, within the region. CRC reviewed answers in the raw data sheets for the Comparative Flow Evaluation Form question #9. Our tally of numbers of people responding in each category is shown in the table below. Results, summarized in Table 1 below, show that 80% of participants thought that the Turners Falls bypass was average or better compared to other rivers within a one-hour drive. And, even more compellingly, 40% of participants thought that the Turners Falls bypass was either better than average, excellent, or among the very best compared to other rivers within a one-hour drive. Participants also rated the Turners Falls bypass favorably compared to other rivers in Massachusetts and other rivers in the northeast. To us, this indicates the bypass reach would provide an outdoor recreation opportunity to whitewater paddlers if whitewater flows and better access were offered.

Table 1. Summary of responses to Question 9 in the Comparative Flow Evaluation Form

The factors cited in the report as influencing a perceived lack of interest in the Turners Falls bypass appear to be erroneous. Page 5-1 in the Conclusions states, “Factors suggested by the boaters based on their survey responses that may affect the overall appeal of the bypass reach for boating included the relatively short length of the boating run (2.7 miles), the urban setting, and the lack of information about when spills are occurring or expected to occur.”

Tables 4.2-4 through 4.2-9 in the Study Report indicate the length of the run was generally acceptable for all users, except cataraft users who thought it only “neutral” for the 2,500 cfs flow level, so the report’s statement about the length of the run seems to be wrong. None of the questions asked about the urban setting. CRC analyzed question 4 in the Comparative Flow Evaluation Form, and numbers of responses are shown in Table 2 below. Opinions varied, but in general the factors that are most important to paddlers are availability and size of features, a thrilling experience, and safety. Moderately important were driving distance, accessibility, crowding, and water quality. Things that are least important are weather, water temperature, and shuttle availability. Attractive scenery is close behind in not being terribly important. On the other hand, a few of the participants in the 2,500 cfs level wrote comments like, “Beautiful river” and “Beautiful scenic valley,” presumably because at the lower flows they weren’t as challenged by the whitewater features and had more time to look around. The statements about the urban setting of the Turners Falls bypass seem unfounded and inaccurate. The lack of information on flows noted in the conclusions as a reason for lack of interest in the byapass can easily be remedied by making the calculation that estimates bypass flows more readily available, or a website with actual information could be created, and of course, a set of release flows could be established at some time.

Table 2. Summary of responses to Question 4 in the Comparative Flow Evaluation Form

 Features and # of responses Not at all important Slightly important Moderately important Very important Extremely important
Availability of features 0 0 5 21 16
Size/difficulty of features 0 0 13 24 5
Driving distance to river 3 11 23 4 2
Accessibility 0 8 25 6 2
Shuttle availability 17 11 8 2 2
Crowding 3 16 18 2 1
Weather 15 17 9 1 0
Water temperature 15 17 8 2 0
Attractive scenery 3 20 13 5 1
Water quality 2 6 21 8 3
Thrilling experience 0 6 10 17 9
Safe trip 1 1 9 13 18


Some observations CRC and AMC saw from the report and the survey responses were as follows:

  • The study showed that test flows ranging between 2,500 and 13,000 cfs resulted in boatable flows for most types of users.
  • Those who paddled the test flows generally felt the Turners Falls bypass reach was about as good or better than other locations nearby and in the region, but it is not likely to become a whitewater destination of national renown.
  • The Connecticut River in the Turners Falls bypass has the potential to offer “big water” whitewater opportunities, something that is lacking elsewhere in the region, which some people feel would be valuable (see question 11 responses from the Comparative Flow Evaluation Form).
  • The Turners Falls bypass would be a good teaching river or place to practice paddling (see question 11 responses from the Comparative Flow Evaluation Form).
  • Improvements would need to be made to a put-in at the upstream end of the run downstream of Turners Falls dam, the take-out at Poplar Street, and access at No. 1 station and at the Rock Dam.

3.6.4 Assessment of Day Use and Overnight Facilities Associated with Non-motorized Boats

This is a completed study.

Overall comments

Page 3-389 of the Revised Study Plan (RSP) for Study 3.6.4 stated, “Data from the Recreation Use/User Contact Survey will be reviewed to assess the need for new or improved facilities to accommodate non-motorized boating use at the Projects.” This does not appear to have been done.

CRC-AMC request: FirstLight review the user surveys and incorporate any relevant information that might help inform the need for new or improved boating facilities.

Access sites

The study concludes that no new access sites are needed. CRC and AMC believe there are some flaws in the report that lead to this conclusion.

On page 4-25 of the report, FirstLight lists among the “formal” river access sites within the Project boundary includes Cabot Camp Access Area (RM 16.2). We had not been aware of this location as a formal access site, and CRC’s “Connecticut River Boating Guide” does not list it. The study report cites the AMC guide as listing it as an access site. This is not really the case. The AMC Guide states that under certain flows, water in the area of Cabot Camp becomes turbulent, and at those flows, paddlers might want to get out at the bridge on the Millers River near its confluence with the Connecticut River (this is the area of Cabot Camp). Even the inventory forms for Study 3.6.2 do not consider this site to be an access – in the box for “boat launch” it says “N” for No. The drawing for the site in Study 3.6.2 Addendum correctly shows a beach area that could be access, but there is no defined route from the car parking area to this beach location.

The Riverview Picnic Area is also listed as an access point. CRC’s Boating Guide states, “The main dock must be kept clear for the Quinnetukut II, but boaters and paddlers may use the dock for brief stops to load and unload. The dock is inaccessible directly by car and can only be reached on foot from a parking area 100 yards away.” Again, the inventory forms for the Addendum to Study 3.6.2 do not consider this site to be an access – in the box for “boat launch” it says “N” for No. To us, this isn’t a full-service access site, given that the main purpose is for launching the Quinnetukut II. If these two sites are to be considered formal access sites, then some changes and upgrades to the sites would be needed. We also note that the FirstLight-operated access sites have a more limited season. Riverview is open Memorial Day to Columbus Day, and the Barton Cove canoe and kayak rental access is open Memorial Day to Labor Day weekends. The paddling and boating season can start earlier and end much later.

The Study Report 3.6.4 indicates that water trail access spacing varies widely across the country, ranging from 4 to 10 miles between access points. In the 21.3-mile Turners Falls impoundment, there are access points at the start and end of this segment. In the middle, there is only one motor boat-accessible site at the Pauchaug Brook state boat ramp 6.5 miles downstream of the Vernon Dam, and possibly two for cartop access if you count the Riverview Picnic area. Pauchaug Brook state ramp is problematic when Northfield Mountain has drawn the river levels down, and the site frequently fills with silt and requires maintenance. Downstream of the Turners Falls Dam, the 9-mile section between the Poplar Street access and Sunderland Boat ramp has no additional access sites, and the Poplar Street carry-in access is treacherous to get in and the parking is very limited.   In addition, as the report notes in the final bullet on page 4-1, all of the municipal open space plans for Northfield, Gill, Montague, and Sunderland highlight an interest and need for improving public access to the Connecticut River for recreational activities. To us, this indicates a documented need for additional access sites, despite the study’s conclusion.

CRC-AMC comment. Municipal open space and recreation plans indicate a real need for additional access sites. The conclusion in the report that the number of access sites is sufficient is erroneous and misleading. However, there are locations and opportunities to add to the number of access sites.

Campsites within the Study Area

FirstLight provides the only official campsites along the Massachusetts stretch of the Connecticut River. The Appalachian Mountain Club is in the process of establishing more sites, so that statistic will change soon. Nevertheless, there is a need for more campsites to allow for people to go on multi-day trips along the Connecticut River, which is what the Connecticut River Paddler’s Trail partners are trying to accomplish.

Page 4-22 of report indicates that spacing guidelines for campsites varies considerably, from 3-15 miles. There are three potential camping locations in the 21.3-mile Turners Falls impoundment, and no camping locations in the 9-mile section between Poplar Street and the Sunderland Bridge. There are also no campsites in the ~3-mile long segment of the river downstream of the Turners Falls dam upstream of Poplar Street. We believe there is a need for additional camping locations, especially when the individual campsites at Barton Cove are not available after Labor Day. September is an ideal time of year to go on a multi-day trip, and the availability of camping locations is limited to Barton Cove for this entire 33-mile stretch of river.

The report on page 4-3 states that camping on Kidd’s Island is no longer permitted at the request of the Town of Northfield Board of Health due to concerns over sewage handling by campers. FirstLight owns Kidd’s Island, and the island was formerly made available only to members of the Franklin County Boat Club. It is true that there were no facilities for human waste, and this was a problem. However, a member of the Northfield Open Space Committee recently attended a Northfield Board of Health meeting and discussed camping on Kidd’s Island. The board is open to the idea of a composting toilet on the island, and members recall telling the Boating Club to go to the MA Department of Environmental Protection for guidance on establishing a privy. The Northfield Board of Health never heard back from the Club, so it appears that the statement that camping was shut down at the request of the Board of Health is not accurate. CRC and AMC’s position is that Kidd’s Island should be considered as a potential spot for boat-access camping — with proper sanitation — and that this could be made available to all, not just members of a club. AMC is currently going through the process of getting a privy permitted in Whately, MA along the Connecticut River, so the issue of establishing a privy on Kidd’s Island should not be considered a barrier.

Portage around Turners Falls Dam

One of the purposes of the study was to evaluate “the feasibility of alternate walkable canoe portages.” The report on pages 4-26 through 4-27 describes a single option: a 3.08-mile walkable trail that uses the exact same take-out and put-in locations. This is not what we were asking for in our study request. We were looking for alternate take-out and put in locations that would just be around the dam. For example, take out at Unity Park and walk around the dam and put in on river left where the whitewater paddlers put in. This would work if a) minimum flows were increased, and b) enough water was in the bypass channel that canoes and kayaks could get over all sections without too much technical expertise.

The Revised Study Plan for study 3.6.4 said that in Task 2, field work will include, “A review of potential canoe portage trails and potential put-in improvements will also be conducted in the field along with flows at potential put-in locations. FirstLight will observe water flows and depths in the by-pass to determine navigability by non-motorized boats.” This does not seem to have happened. Moreover, in response to CRC’s comment that stakeholders be involved in this process, the FERC Study Plan Determination dated September 13, 2013 specified that FirstLight consult with stakeholders throughout Task One and Task Two phases of this study.” As far as we know, although CRC and AMC were invited to participate in the boat tour that looked at access and camping locations, stakeholders had no part in any discussion of alternative portage routes, new put-in locations for the portage, or an evaluation of flows in the by-pass for the purpose of navigability (this would be different from the Whitewater study).

We will note that the participants who filled out the Single Flow Evaluation Form for the lowest test flow, 2,500 cfs, in the Whitewater Study, typically reported that the bypass channel was Class I or II waters that could be navigated by a novice or a beginner. There is an alternate route to the Rock Dam feature, and so if the minimum flow in the bypass channel was increased, it is possible this section of river would be runnable to most paddlers. In that case, a shorter portage route around the dam would be desirable. We also understand that the Town of Montague recently acquired a property downstream of the dam, and we believe this site could be explored as a possible put-in in the future.

We also find it strange that the report only includes a single year portage data—2014– on page 4-24. It would be helpful to have more years of data. We also include as Attachment 1 an article from the October 1, 2015 edition of the Montague Reporter about a paddler who attempted to walk the portage route after being unable to reach FirstLight for pickup. A concerned citizen contacted CRC and forwarded CRC a letter to the editor she wrote in response to this article in the Montague Reporter. It includes another citizen perspective in the condition of the Poplar Street access (for more on this, see our comments below).

CRC-AMC request: FirstLight do an actual evaluation of various options for a walkable (i.e., less than a mile) portage route as required in the study plan.

Poplar Street access

The Poplar Street access site has long been problematic. Getting a boat down the steep and eroded bank is treacherous and is difficult for anyone less than able-bodied. See the letter to the editor in Attachment 1 for comments on getting a boat up the bank at this site. The parking capacity is minimal (listed as 4 sites in Table 4.3-2, but page 4-16 of the Addendum to Study 3.6.2 says 16 parking spaces), and nearby landowners are understandably not happy when their land is used for access because of easier slope.   Many respondents in the whitewater boating evaluations noted that improvements to Poplar Street would be needed to expand usage of that area.

In the Spring of 2005, Northeast Utilities (prior owner of Turners Falls Dam and Northfield Mountain) hired the Conway School of Landscape Design to design an improved access and parking area. The design was never implemented and this study gives no mention to the document. We include the cover page and final design of this project as Attachment 2, which we obtained from the Conway School of Landscape Design. There is universal agreement that improvements are needed to this access point, or an alternative access location is needed.

The RSP for study 3.6.4 said that in Task 1, “The Licensee will review the existing information regarding the Poplar Street Put-in and develop potential improvements to the site which may be implemented when and if it is determined that improvements are needed. Information will be field verified and updated as appropriate as part of Task 2.” The report has accomplished this with as little effort as possible, saying only (page 4-21), “The slope to the shoreline at this site is steep and the portage trail to the shoreline is unimproved. Reduced gradient, improved footing, and clearance to allow for portaging 16 foot (minimum) long boats would improve conditions at this site for non-motorized boat access.”

CRC-AMC request: FirstLight complete the Task 1 and Task 2 work described in the RSP that has been omitted.

3.6.7 Recreation Study at Northfield Mountain, Including Assessment of Sufficiency of Trails for Shared Use

This is a completed study.

The Northfield Mountain Tour and Trail Center is a valuable resource in the area, providing recreational opportunities as well as environmental and educational opportunities to the public. The report indicates that visitors are generally satisfied with their experiences at Northfield Mountain, and most feel that the amenities and attributes are either good or excellent. Visitors most seem to value the beauty, scenery, and opportunity to observe nature. We offer the following comments on the report.

Table 4.1-1 describes all the activities and programs held between Fall 2014 – Summer 2015. The study summarized user surveys for the period of January to December 2014. We aren’t sure why those two time periods didn’t match up.

Participation in environmental programs is shown for the time period 1986-2014, although it appears that 1996-2001 and 2007-2009 participation numbers are missing. The number of environmental programs offered is provided for the years 2002-2014, excluding 2003. Participation in the Quinnetucket II is shown for 1985-2014. Participation in fishway tours are shown for 1988 through 2014.  Trail use and numbers of skiers/snowshoers are given for the years 2005 and 2010-2014. It would be good to have seen this information for the entire period given for other programs, such as 1986-2014. Without knowing, for example, how many environmental programs were offered between the years 1986 and 2001, it is difficult to evaluate the trends in participation numbers.

Figure 4.1.4-2 shows a downward trend in participation in the riverboat tours between 1985 and 2014. Table 4.1.4-1 lists the impacts to QII Riverboat Operations, giving various reasons for the decline in ridership. CRC has a brochure from 2006 that shows public cruises were offered between Wednesdays and Sundays from June 21 to October 15, with groups and charter cruises beginning in early June on Saturdays. See Attachment 3 for a copy of this brochure. This schedule was the same in 2007. By 2009, the boat ran only on Fridays, Saturdays, and Sundays; Wednesday and Thursdays had been eliminated. Cutting off 2/5 of the days is not mentioned anywhere in the Table 4.1.2-1, and currently the FirstLight website lists the riverboat cruise schedule going from July to mid October (, which is a shorter season than what had previously been offered (nothing in June now).   The decision to reduce the number of cruises per season is not explained, or even mentioned, in the report. The assertion in the Conclusion section on page 5-1 that declines are “not a result of reduced program offerings, which have remained constant or decreased slightly since 2001” doesn’t seem to be entirely true.

CRC-AMC request: If available, provide environmental program offerings and trail use data for the period 1986-2014. Amend Table 4.1.2-1 or create new table showing how many days of cruises were offered over the years vs. numbers of participants.


CRC and AMC appreciate the opportunity to provide comments on the USR.


Andrea Donlon

Massachusetts River Steward

Connecticut River Watershed Council


Kristen Sykes

Director Conservation Strategies

Appalachian Mountain Club


Norman Sims

Appalachian Mountain Club