March 2, 2015

Honorable Kimberly D. Bose Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426

Re: Wilder Project No. 1892-028
Bellows Falls Project No. 1855-048
Vernon Project No. 1904-076

Re: CRC COMMENTS on TransCanada’s Request for Extension of License Term

Dear Secretary Bose,

The Connecticut River Watershed Council, Inc. (CRC) is a nonprofit citizen group established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed. We have been participating in the relicensing of the five hydropower facilities on the Connecticut River as a stakeholder organization since the beginning of the current ILP process in late 2012.

CRC reviewed TransCanada’s request to extend their license term for the Wilder, Bellows Falls, and Vernon projects, dated January 16, 2015. TransCanada requests a one-year extension to “maintain the integrity of the Integrated License Process (ILP) pre-filing process in light of the delay in conducting necessary studies caused by the closure of Vermont Yankee and the statutory deadline for submitting new license applications two years before the license expires.” CRC agrees that, given the situation, a one-year extension would allow for a more logical schedule, with study results being reviewed prior to a license application submitted by TransCanada. We also think it makes sense to keep the five-hydropower facilities on the same relicensing schedule, since many of the issues and studies are intertwined.

We support TransCanada’s license extension request as long as FERC is able to keep all five hydropower facilities on the same ILP schedule, including those owned by FirstLight. We appreciate the opportunity to provide comments.


David Deen Andrea Donlon
Upper Valley River Steward Massachusetts River Steward