This is our February 2023 update on all things hydropower!
First a Refresher:
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. Our voices – your voice – will make a difference in achieving a healthy and flourishing river.
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!
In this update:
FirstLight Power updates
Great River Hydro updates
What you can do!
Updates on FirstLight Power Facilities in MA: Turners Falls Dam & Northfield Mountain Pumped Storage
To recap where we are
Since our last update in August, CRC has continued to advocate for a license that ensures safe and effective fish passage, provides recreational access for a diversity of river users, protects habitat, and minimizes erosion caused by FirstLight operations.
In early 2022 FirstLight submitted recreation and whitewater Agreements in Principle (AIPs). CRC supports several recreation improvements included in the recreation and whitewater AIPs, including the addition of new trails, camping sites, pocket parks and boating access as well as white water releases for paddlers.
FirstLight also submitted a fish and flows AIP and indicated to FERC that the final settlement agreement for fish and flows was being circulated for signatures. CRC did not sign onto this AIP because of our concerns that it does not provide timely fish passage, it does not adequately protect juvenile fish from getting pulled into Northfield Mountain’s reservoir, and it does not provide enough water to support aquatic life below the dam. You can read more about this and about the recreation agreement in our last update.
What’s happening now (and into March)
FirstLight rang in the New Year by blowing through yet another deadline to submit a final settlement agreement, which they had previously committed to filing by June 2022, then December 2022, and now have indicated they will file by March 2023. In response to FirstLight’s request for an extension, the Federal Energy Regulatory Commission (FERC) issued a letter on January 4, 2023 indicating that they will delay the Ready for Environmental Analysis (REA) notice until May 31, 2023. This is five years after their previous license has expired. However, FERC is also now requiring FirstLight to submit biweekly updates on settlement discussions until March 31. You can receive these biweekly updates by subscribing to the FERC Docket here for Northfield Mountain Pumped Storage Project (P-2485) and Turners Falls Dam (P-1889).
To read FirstLight’s first biweekly update on settlement progress, filed January 27, 2023, click here.
What’s next? In March we’ll provide another update on the next steps in the process and how our voices – your voice – will make a difference in achieving a healthy and flourishing river.
Great River Hydro Facilities in VT & NH: Wilder, Bellows Falls, and Vernon Dams
The surprising (ish) news…
Large hydroelectric facilities are frequently bought and sold as assets in larger energy portfolios. In October 2022, Great River Hydro (including all of their hydro facilities on the Deerfield and Connecticut Rivers) were sold to HQI US Holding, a subsidiary of Canadian energy utility Hydro-Québec.
Just to provide some perspective, here is a timeline of previous owners of the Wilder, Bellows Fall, and Vernon facilities:
New England Power Association (NEPA) (~1926-1947)
New England Electric System (NEES) (~1947 to late 1990s).
US Gen of New England (late 1990s to 2005)
TransCanada (2005 to 2017)
ArcLight Capital Partners (2017 to 2022)
Hydro- Québec (2022 to ….)
You may remember that Hydro-Québec has been trying for decades to export the electricity generated in their massive Canadian facilities into the New England States through large transmission line projects that they have been attempting to get built, namely:
Northern Pass, which was blocked in NH;
the New England Clean Energy Connect (NECEC), currently being challenged in Maine;
Champlain-Hudson Power Express, with transmission lines that would be buried under Lake Champlain and the Hudson River;
and the New England Clean Power Link, which would go under Lake Champlain and down to Ludlow, VT to be connected to existing transmission lines.
And now they own many of the hydro facilities on the Connecticut and Deerfield Rivers, thereby having a business presence in VT, NH, and MA.
CRC does not believe this purchase will affect the current relicensing of the Wilder, Bellows Falls, and Vernon dams, but it certainly means that the parent company has much deeper pockets and can afford to provide more comprehensive mitigation for impacts to our river from these dams – on a shorter timeline. CRC will be keeping this in mind as we continue to engage and prepare our comments.
To recap where we are
Great River Hydro proposed an alternative operational scenario – consisting of less peaking and more water flowing through the river – that 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 that the license will be in effect.
CRC was concerned with information lacking in the AFLA so we submitted comments to FERC on January 28, 2021.
After a year of negotiations, Great River Hydro (GRH) filed a Fish Passage Settlement agreement on August 2, 2022, which provides some positive aspects, such as opening fish 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 diversion dam originally designed to support upstream passage of salmon. The Atlantic salmon restoration program ended more than five years ago. Removal of this dam will benefit river habitat and recreation. Unfortunately, GRH is trying to avoid paying for the removal of this structure. And they are seeking to delay implementation of fish passage improvements for up to 16 years after their new license.
Additionally, 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 continued land erosion after operational changes are implemented. FERC will be required to consider the cumulative impact of the hydro-relicensing under their Environmental Analysis. This means FERC needs to have complete information regarding the scope of what will be provided for mitigation under the new license.
The Great River Hydro (GRH) relicensing process continues to be delayed by FirstLight’s settlement discussions and delays in the regulatory timeframe. Based on previous conversations with FERC staff, CRC’s understanding is that FERC wants to have all five projects go through the final commenting and Environmental Impact Statement process together.
We expect an opportunity to comment on the Amended Final License Application (AFLA) for the Great River Hydro projects after May 2023.
We will keep you informed and let you know next steps as they evolve. Stay tuned!
We – and the health of the river for the next 30 to 50 years – need you to stay involved! CRC continues to keep tabs on and be involved in the relicensing process. There are a few things you can do right now to keep this conversation alive:
Let your legislators know you are paying attention and care about this process.
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!
Get Ready to Comment! If FERC sticks to the plan, 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.
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:
You can learn more about the details of the Great River Hydro application by viewing our January 13, 2021 LiveStream virtual presentation:
Video that covers some of our concerns about riverbank erosion:
Video that covers some of our concerns about recreation: