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Motion to Intervene and Comments of CRC and FRCOG on Northfield Mtn Temporary Amendment Application

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Motion to Intervene and Comments of CRC and FRCOG on Northfield Mtn Temporary Amendment Application

UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

 

In re:                                                  )

FirstLight Hydro Generating Company                     )       Northfield Mountain Pumped Storage Project, No. 2485-076

 

 

MOTION TO INTERVENE AND COMMENTS

OF THE

CONNECTICUT RIVER CONSERVANCY AND THE

FRANKLIN REGIONAL COUNCIL OF GOVERNMENTS

IN THE ABOVE APPLICATION

FOR TEMPORARY AMENDMENT OF MINIMUM AND MAXIMUM RESERVOIR ELEVATION REQUIREMENT

 

The Connecticut River Watershed Council, Inc., now doing business as the Connecticut River Conservancy (CRC), and the Franklin Regional Council of Governments (FRCOG) hereby move for leave to intervene to the above referenced application for amendment of license filed by FirstLight Hydro Generating Company on September 11, 2017, pursuant to the Notice dated September 28, 2017, published by the Commission and Rule 214 of the Commission’s Rules of Practice, 18 C.F.R. § 385.214 and related authority and orders.  This Motion to Intervene clearly states CRC’s and FRCOG’s position and specifies the bases for its position.  The facts below demonstrate that CRC and its members and FRCOG and its member towns have interests that are directly affected by this proceeding.  CRC’s and FRCOG’s intervention is also in the public interest.

  1. Statement of Interest

CRC is a nonprofit watershed organization that has an interest in protecting environmental values that directly and indirectly support the state, regional, and local economies and quality of life in the Project area.  The FRCOG is a political subdivision of the Commonwealth of Massachusetts is and the Regional Planning Agency (RPA) for Franklin County, Massachusetts.  The Connecticut River and the rich agricultural soils of the surrounding valley bottom are the resources that define this region of Massachusetts, Vermont, and New Hampshire.  The ecological and cultural importance of the Connecticut River was recognized by the federal government in the 1990’s when the river was designated an American Heritage River, and the watershed a National Fish and Wildlife Refuge, and most recently in 2012 as the first National Blueway by former Secretary of Interior Ken Salazar.

The Connecticut River provides water-related recreational opportunities for swimming, boating and fishing, as well as drawing both residents and tourists who enjoy walking, bicycling, hiking, camping, and nature observation along its banks.  Within the reach of the Connecticut River known as the Turners Falls pool, FirstLight Hydro Generating Company (“FirstLight”) operates popular campsites, picnic sites, and a tour boat in the project area.  The Commonwealth of Massachusetts operates two state-owned boat launches in the reach.

CRC’s and the FRCOG’s interests include the prime agricultural and recreational lands and economy of the valley; the improvement of water quality; enhancing aquatic and related terrestrial habitat; protecting and restoring the several threatened and endangered plant and animal species of the valley; preserving wetlands, undeveloped shore lands, and the many significant archaeological, cultural, and historical sites of the valley; and enhancing the aesthetics of the region.  These interests are not adequately represented by other parties to this proceeding.  CRC members and residents of FRCOG member towns live and work along the areas of the river affected by the Project, and regularly use, and continue to use the areas of the River and River valley affected by the Project, including the River itself, its fishery, lands on the River’s banks, and State and Applicant-owned or operated boat launches, and all of the other above-mentioned resources and amenities.

As noted in FirstLight’s Application for Temporary Amendment of License dated December 11, 2017 (“Application”) on page 4, the licensee has applied for temporary amendments multiple times since 2001.  FirstLight’s application did not mention that FERC’s orders granted varying levels of use of the expanded capacity.  Prior to the winter of 2014-2015, temporary amendments to the license authorized changes to the minimum and maximum reservoir elevation requirement only under certain emergency operating conditions as determined by ISO-NE.  For example, the licensee’s application to the winter of 2005-2006 temporary license amendment requested permission to use increased operational flexibility whenever ISO-NE declared an Energy Emergency under Operating Procedure (OP) No. 21 (Action during an Energy Emergency), OP No. 4 (Action During a Capacity Deficiency), or OP No. 7 (Action in an Emergency).  During the winters of 2014-2015 and 2015-2016, FirstLight was allowed full use of the extra capacity during the amendment period.   Last winter (2016-2017), FERC’s order issued January 6, 2017 required FirstLight to maintain the upper reservoir between elevations of 1,004.5 and 947 feet msl during normal operations, allowing use of additional storage, between 947 and 920 feet msl, “in response to ISO-NE discretionary actions taken during emergency operations to meet applicable NPCC and NERC reliability standards.”   The licensed operating range of the upper reservoir is typically between 1,000.5 feet and 938 feet msl.

The current application requests use of the expanded upper reservoir for the full amendment period, with no restrictions, as was done during the winters of 2014-2015 and 2015-2016.  Operations that are detrimental and exacerbate existing erosion problems should be reserved solely for emergencies.  Further, any operational changes should be to remedy erosion issues, not make them worse.

  1. Description of CRC and FRCOG

The Connecticut River Watershed Council, Inc., doing business as the Connecticut River Conservancy (CRC), is a nonprofit citizen group that was established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed.  CRC’s members use and are concerned about the area of the Connecticut River affected by the presence and operation of the Northfield Pumped Storage Project (FERC Project No. 2485) and the Turners Falls Project (FERC Project No. 1889).

The Franklin Regional Council of Governments (FRCOG) is the Regional Planning Agency (RPA) for Franklin County, Massachusetts.  The governing body of our organization has representatives from all 26 communities, the Franklin Regional Planning Board, and two regionally elected officials.  As the RPA for Franklin County, we provide land use, natural resource, economic development and transportation planning services to our communities and the region.  In addition, we provide extensive GIS database development, mapping, and analysis services and are an affiliate of the Massachusetts State Data Center.

For almost three decades, FRCOG and its Connecticut River Streambank Erosion Committee (CRSEC) have been actively involved with stakeholders concerned about the ongoing and extensive erosion in the Turners Falls Power Pool.  The FRCOG’s CRSEC was recognized by FERC in 1999 as an Ad Hoc Committee that would work with the utility to develop and implement bioengineering bank stabilization projects.   The Connecticut River bisects Franklin County and is a major economic, recreational and environmental resource for the residents of our member towns.

CRC is a member of CRSEC, and as a member of the committee, has worked with the FRCOG and the owners of the Project to address erosion in the Turners Falls pool, including development of bioengineering river bank stabilization projects that are part of the Erosion Control Plan ordered and approved by the FERC.  CRC and FRCOG advocate for the protection of water quality and habitat on the river, as well as the environmentally-responsible use of the river.  As such, CRC and FRCOG have been an active stakeholders participating in the ongoing relicensing of Northfield Mountain, Turners Falls Dam, Vernon Dam (No. 1904), Bellows Falls Dam (No. 1855), and Wilder Dam (No. 1892).  CRC was an intervenor in the relicensing of Holyoke Dam (FERC No. 2004), Canaan Dam (No. 7528), and Fifteen Mile Falls (No. 2077) projects on the Connecticut River, and is currently also involved in the relicensing of Bear Swamp Pumped Storage Project and Fife Brook Dam (P-2669) on the Deerfield River.


 

III. CRC and FRCOG’s Participation is in the Public Interest

CRC and its members, and FRCOG and its member towns, use the Connecticut River between the Turners Falls Dam and Vernon Dam for recreation, transportation, fishing, and irrigation; own land along its banks, and farm this land; fund town services using property taxes that include land along the river; and are therefore affected by project operations.  Many acres of riparian lands, including state identified Prime Farmlands have been conserved using Federal and state tax funded land conservation programs, such as the Agricultural Preservation Restriction Program.  However, these lands are actively eroding into the river.  FRCOG has been awarded over $700,000 in funding from the US EPA and the MassDEP 319 Nonpoint Source Pollution Program to help fund innovative bank stabilization measures and monitor successes and failures along the Connecticut River upstream of the Turners Falls Dam.  See www.restoreconnriver.org.   The integrity of these projects is threatened by increases in the magnitude and frequency of pool elevations because the measures were designed with specific water elevations in mind.

No other parties to this proceeding represent our interests.  FERC has authority over the operations of this facility and can act to minimize impacts from operations, such as riverbank erosion.

CRC as the Connecticut River Watershed Council, Inc., intervened and/or submitted comments to FERC for other amendment applications to use the expanded reservoir in 2001, 2005, 2006, 2007, 2014, 2015, and 2016.  FRCOG has done the same, often in the same filing as CRC, with the exception of 2016.  The public interest served by CRC and FRCOG relative to the River and Project operations is also described in sections I and II, above, and further detailed below.

  1. Statement of Position and Comments on Application for Temporary Amendment of License

There is a long history of riverbank erosion associated with Northfield Mountain pumped storage project ever since Turners Falls Dam was raised and operation of Northfield Mountain began in 1972.  As stated above, CRC and FRCOG have been active members of the CRSEC, which has worked with the applicant for many years on erosion control projects in support of the Erosion Control Plan, required by the FERC in 1999 per the conditions of FirstLight’s license based on the documented loss of valuable farmland and private property.

CRC and FRCOG are aware of ongoing concerns about grid reliability in New England during periods of high demand in the winters.  We support increasing the reliability and storage capacity of the New England grid, but not at the expense of avoidable environmental harm.  FirstLight has argued in its Application on page 5 that the proposed amendment is in the public interest because it will provide ISO-New England (ISO-NE) with additional operational flexibility without adverse environmental impacts.  On October 18, 2017 ISO-NE submitted to FERC a letter supportive of the temporary license amendment.

CRC and FRCOG disagree that the proposed license amendment would have no adverse environmental impacts.

Project operations and expanded operations pose an ongoing threat to bank stability

We are concerned with the undermining of banks at the toe of the slope, which begins the cycle of erosion.  The daily difference between the maximum and minimum pool elevation, a change in the average elevation of the pool, and the duration and speed of elevation change in the pool height are all factors that can contribute to a notching at the toe of the slope, sometimes acting in concert with other influences such as ice in the winter and natural high flow events.

FirstLight continues to cite the Environmental Report submitted in support of its 2014-2015 temporary amendment application to assert that the timing, rate, magnitude, and frequency of water elevation fluctuations in the upper reservoir and impoundment were “not materially different” compared to baseline conditions.  CRC continues to disagree, for reasons described in our motion to intervene dated November 21, 2016.

FirstLight says that their findings have been “further affirmed” by environmental analyses and field data filed in compliance with the Commission’s order granting the 2014-2015 and 2015-2016 temporary amendments.  CRC’s Motion to Intervene dated November 21, 2016 described numerous deficiencies with the “analysis” and field data, leading to what we viewed as erroneous conclusions.  We continue to believe that the information provided by FirstLight in these reports failed to affirm their findings.

FirstLight states on page 11 of its Application that it has completed its relicensing study No. 3.1.2, Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability, including an addendum filed on April 3, 2017, evaluating the impact of increasing the useable storage volume of the upper reservoir on streambank erosion in the impoundment.  The addendum concluded that increasing the useable storage volume of the upper reservoir resulted in no impact on streambank erosion in the impoundment when comparing the expanded use scenario to baseline conditions.  Because of this, FirstLight argues on page 12, “Now that the relicensing studies are complete, there is no longer any basis for restricting a temporary amendment to ISO-NE emergencies.”  FirstLight then says it understands that FERC has not completed its comprehensive review of the relicensing and does not believe that an approval from FERC would prejudge the relicensing outcome.  Just because FirstLight’s study concluded that its operations have very little impact on bank erosion doesn’t make it true.  CRC hired a peer reviewer to look at Study 3.1.2, not the addendum, who found numerous problems and flawed reasoning (see CRWC comment letter dated December 15, 2016).

Throughout each step of the Integrated Licensing Process, FRCOG has filed detailed comments with FERC that describe our concerns with the Study Plans and Study Reports for the two studies specifically related to river bank erosion:  Study 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability and Study 3.1.1, the 2103 Full River Reconnaissance.  On December 15, 2016, FRCOG filed a comment letter with FERC that lists our concerns with the Final Study Report 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability filed by FirstLight on October 15, 2016.  FirstLight concluded that [h]ydropower operations have limited to no impact on bank erosion in the TFI.”[1] (TFI is the Turners Falls Impoundment).  This statement strains credulity and is contrary to decades of stakeholder and landowner observations and filings with FERC as well as the findings of both the 1979 Army Corps of Engineers’ study and the 2007 Field Geology Services report.[2]

While FERC has said in its study plan determination dated February 17, 2017 that it has enough information to complete its technical review, FERC has not necessarily completed such a review.

This temporary amendment proceeding is not the forum to fully critique Study 3.1.2 or its addendum.  That forum exists in the relicensing proceedings, and could be done in response to a completed Draft License Application that includes full analysis of the licensee of all its relicensing studies (FirstLight’s DLA was filed December 5, 2015), prior to the completion of study 3.1.2 and its addendum.  In the meantime, Article 20 of FirstLight’s current license continues to be in effect and FirstLight is responsible for minimizing bank erosion.[3]


 

New information has become available that may change conclusion of no aquatic species impact

In its Application on page 8, FirstLight describes a comprehensive Exhibit E – Environmental Report that was prepared to support its request for temporary amendment for the 2014-2015 period.  FirstLight’s Application says that this Environmental Report is incorporated by reference into the 2017-2018 amendment request.  Exhibit E Section E.3.1 discusses migratory and resident fish, and mentions that federally endangered shortnose sturgeon are known to be in the project area, but present downstream of the Turners Falls Dam.  Section E.3.2 concluded, “The minor changes in the flow regime and water elevations of the temporary amendment coupled with the time of year, will not adversely affect wildlife, botanical or RTE [rare, threatened, or endangered] species in the NMPS Project area.”  On October 25, 2017, NOAA Fisheries posted an announcement online about a federally endangered shortnose sturgeon caught by a local fisherman just downstream of the Vernon Dam (see https://content.govdelivery.com/accounts/USNOAAFISHERIES/bulletins/1bfbea5), and therefore upstream of the Turners Falls Dam.   As far as CRC and FRCOG knows, NOAA has not made any conclusions beyond announcing this documented case.

CRC and FRCOG is making note of this observation in that it now seems possible that project operations could impact shortnose sturgeon.  CRC’s Executive Director sits on the Connecticut River Atlantic Salmon Commission (CRASC) as a member of the public from Massachusetts.  CRASC is committed to restoration of anadromous and catadromous fish populations in the Connecticut River.  CRC was an intervenor in the Holyoke Dam (P-2004) license, and as a member of the Cooperative Consultation Team, CRC spent 10 years attending meetings and reviewing studies and drawings and plans to construct safe and effective upstream and downstream shortnose sturgeon passage at the Holyoke Dam.  Construction for this project was completed in time for the 2016 fish passage season.   CRC has an interest in the restoration of this species, and therefore would also want to make sure that project operations do not result in negative impacts to shortnose sturgeon or other migratory fish species.  At this time, we can not make any conclusions about impacts related to this species, but until further evaluation is done, it seems prudent to limit expanded use of the upper reservoir.

Grid reliability can be bolstered without full unrestricted of an expanded upper reservoir

During normal operations, FirstLight reserves some of its water stored in the upper reservoir for capacity.  This capacity can always be used in an emergency to supply electricity to the grid, even without the need of a temporary amendment.  Moreover, during the winter of 2016-2017, FirstLight was allowed to fill its upper reservoir to the requested new upper limit of 1004.5 ft msl and was in a position to deliver extra capacity when needed by ISO New England.  According to ISO New England’s post-winter 2016-2017 review (available online at https://www.iso-ne.com/static-assets/documents/2017/06/2017-06-27-egoc-a2-0-post-winter-2016-17-review.pdf), there were no OP-4 events, and there were three MLCC2 (Master/Local Control Center Procedure No. 2) events, one of which occurred prior to FERC’s order amending license dated January 6, 2017.  CRC received no reports from FirstLight indicating use of additional storage, as required in Section (D) of FERC’s order.  Therefore, we are under the impression that the additional capacity was never used for generation last winter.  FirstLight, in its Application, made no mention of its operations during the winter of 2016-2017.

FirstLight states in its Application on pages 4 and 5 that the increased operating flexibility of an expanded upper reservoir limit would “enhance the reliability of the New England Bulk Power Supply System while providing the capability to displace operation of fossil-fueled electric generation facilities and reduce greenhouse gas emissions.”  Perhaps Northfield Mountain is technically “capable” of displacing fossil-fuel generation and reducing greenhouse gas emissions, but that certainly won’t be happening this winter, for two primary reasons: 1) for every kilowatt hour of power generated by Northfield Mountain, the facility must use 34% more power to pump water to the upper reservoir,[4] and 2) the ISO-NE grid is not equipped for the winter of 2017-2018 to provide renewable power for Northfield Mountain’s pumping operations.[5]  While we agree that Northfield Mountain has the potential to offer grid reliability, and that might be of high value, operation of Northfield Mountain increases total use of fossil fuels at the present time.  In fact, if peak demands periods can be supplied by generation elsewhere, the best use of Northfield Mountain from a greenhouse gas emission standpoint would be to have Northfield Mountain’s upper reservoir poised at full capacity and then not operate until if and when grid reliability is threatened.  In that scenario, FirstLight would continue to be paid for capacity, and environmental impacts would truly be negligible.

 

 

  1. Recommendations
  2. FERC should deny FirstLight’s application as requested.
  3. If approved, FERC should approve as provided in FERC’s order dated January 6, 2017, (B) through (E).
  4. If the temporary license amendment is approved and the extra capacity is used during the winter, FERC should require that FirstLight submit the report that FirstLight has committed to preparing on page 13 of its Application. We request that the report follow requirements described in sections (D) and (E) of FERC’s order dated December 16, 2015 approving the temporary amendment for the winter of 2015-2016, with the following additional requirements to ensure that the data is useful to stakeholders and supports FirstLight’s findings and conclusions.
  5. Data presented on the cross-sections should include the time periods of the previous temporary amendments granted to the Licensee (2001, 2005, 2006, 2014-2015, 2015-2016, 2016-2017 – stipulating how many times in each year the extra capacity was used, and noting if any of the units were out) and bank morphology during “typical” or non-temporary amendment winters (2002-2004; 2007-2013).
  6. Cross-section diagrams should show the water elevation at the time of the survey and shown on the cross-sections. These data have likely been collected by FirstLight during past surveys and should be shown on the cross-sections for previous years.
  7. Water elevation ranges should also be shown on the transect graphs as follows: the “typical” range of elevations during operations that cover flows during which the river is controlled by operations (less than 15,938 cfs, which is 72% of the time[6]).  Optional lines of higher flows can be provided if desired by the company, such as 25,000, 50,000 and 75,000 cfs.

 

  1. Service and Communication

Service of process and all other communications concerning this motion and the above-referenced project should be made to:

Andrea Donlon

Connecticut River Conservancy

15 Bank Row

Greenfield MA 01301

VII.  Conclusion

The temporary license amendment should be denied.  However, we do not object to an approval with restrictions equivalent to last year’s temporary amendment.  CRC and FRCOG believe that continued operation of Northfield Mountain, and any scenario that involves moving additional water in and out of the Connecticut River, comes at a price for the riverbanks.  Grid reliability can be enhanced under the restrictions similar to those imposed last winter.

We respectfully request that the Commission allow CRC and FRCOG to become parties to this proceeding.

DATED this 27th day of October, 2017, on behalf of the Connecticut River Conservancy and the Franklin Regional Council of Governments.

Signed,

 

 

 

 

___________________________________________

ANDREW FISK

Executive Director

Connecticut River Conservancy

15 Bank Row

Greenfield MA 01301

 

 

 

 

 

____________________________________________

BILL PERLMAN

Chair, Executive Committee

Franklin Reginal Council of Governments

12 Olive Street, Suite 2

Greenfield, MA  01301

CERTIFICATE OF SERVICE

 

I hereby certify that I have this day served the foregoing document, the Motion to Intervene for Project 2485, the Northfield Mountain Pumped Storage Project, submitted by CRC and FRCOG, upon each person designated on the attached service list.  Dated this 27th day of October, 2017.

 

Signature:

 

Andrea Donlon

Connecticut River Conservancy

15 Bank Row

Greenfield MA 01301

Telephone:  (413) 772-2020 x. 205

E-mail: adonlon@ctriver.org

 

 

SERVICE LIST

 

 

FirstLight Hydro Generating Company

Douglas Bennett

Plant General Manager – Massachusetts Hydro

Northfield Mountain Station

99 Millers Falls Road

Northfield MA 01360

 

Julia S. Wood

Van Ness Feldman, LLP

1050 Thomas Jefferson St., NW

Washington DC 2007

(202) 298-1938

 

U.S. Fish and Wildlife Service (USFWS)

John Warner, Ecological Services

N.E. Fish and Wildlife Office

70 Commercial Street, Suite 300

Concord NH 03301-5087

(603) 271-2541

 

Connecticut River Atlantic Salmon Commission

Kenneth Sprankle

U.S. Fish and Wildlife Service

103 East Plumtree Road

Sunderland MA 01375

(413) 548-9138 x. 121

 


 

NOAA National Marine Fisheries Service

Julie Crocker

ESA Fish Recovery Coordinator

Protected Resources Division

Greater Atlantic Regional Fisheries Office

National Marine Fisheries Service

55 Great Republic Drive

Gloucester, MA 01930

(978)282-8480

 

Massachusetts Department of Environmental Protection

Brian Harrington

MA DEP Western Regional Office

436 Dwight Street

Springfield MA 01103

(413) 784-1100

 

Robert Kubit

MA DEP Central Regional Office

8 New Bond St, Worcester, MA 01606

(508) 767-2854

 

Massachusetts Division of Fisheries and Wildlife

Caleb Slater, PhD., Anadromous Fish Coordinator

MA DFW

1 Rabbit Hill Road

Westborough, MA 01581

(508) 389-6331

 

Franklin Regional Council of Governments

Kimberly Noake MacPhee

12 Olive Street, Suite 2

Greenfield, MA 01301

(413) 774-3167 x130

 

ISO New England Inc.

Peter Brandien, Vice President, System Operations

ISO New England Inc.

One Sullivan Road

Holyoke, MA 01040

(413) 535-4000

[1] Page 67 of Volume 1 – Study Report 3.1.2.

[2] Simons, D.B., Andrew, J.W., Li, R.M., & Alawady, M.A. (1979). Connecticut River Streambank Erosion Study: Massachusetts, New Hampshire, and Vermont. Waltham, MA: US Army Corps of Engineers (USACE).  Field Geology Services. (2007). Fluvial geomorphology study of the Turners Falls Pool on the Connecticut River between Turners Falls, MA and Vernon, VT. Prepared for Northfield Mountain Pumped Storage Project. Farmington, ME: Field Geology Services. Field, John.  2011. Detailed Analysis of the 2008 Full River Reconnaissance of the Turners Falls Pool on the Connecticut River: Unpublished report prepared for The Landowners and Concerned Citizens for License Compliance.

[3] Article 20 from the Northfield Mountain project P-2485 license (1968) states that, “The Licensee shall be responsible for and shall minimize soil erosion and siltation on lands adjacent to the stream resulting from construction and operation of the project.  The Commission upon request, or upon its own motion, may order the Licensee to construct and maintain such preventative works to accomplish this purpose and to revegetate exposed soil surface as the Commission may find to be necessary after notice and opportunity for hearing.”

[4] On October 11, 2017, FirstLight submitted its annual “Statement of Generation of Hydropower Annual Charges.”  This letter indicated that between October 1, 2016 and September 30, 2017, Northfield generated 996,023,636 gross kilowatt hours and pumped 1,337,743,448 gross kilowatt hours, so it used 34% more power than it generated.

[5] ISO-New England’s 2017 Regional Electricity Outlook (available at  https://www.iso-ne.com/static-assets/documents/2017/02/2017_reo.pdf🙂  See especially page 29: “Wind and solar resources can offset some natural gas use, but their help is limited by still-low levels of regional installation. Additionally, wind speeds are variable and can drop during extreme cold snaps, paradoxically creating a need for natural-gas-fired generators that can ramp up and down quickly to balance fluctuations in supply or demand and maintain continuity of electricity supply. Solar energy, meanwhile, isn’t dispatchable by the ISO and doesn’t help meet peak winter demand, which happens after the sun has set. Moreover, winter conditions, with snowfall and fewer daylight hours, also dampen solar output. Extreme cold could also reduce imported Canadian hydropower through proposed new long-distance transmission lines because Canada is a winter-peaking system and may need the power itself.”

[6] Pre-Application for the Turners Falls Dam (P-1889) and Northfield Mountain Pumped Storage Project (P-2485), FirstLight Power Resources, October 30, 2012.  See page 3-25.