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Connecticut River Conservancy’s Hydropower Relicensing Comments to FERC

Closeup of Bellows Falls dam on the Connecticut River
Bellows Falls dam by Al Braden

After a 12-year process in the relicensing of 5 hydroelectric facilities on the Connecticut River, and the past several months of advocacy related to encouraging public comments for FERC (Federal Energy Regulatory Commission – the agency charged with issuing new licenses), we have arrived at a new milestone. The public comment period with FERC is now closed, and we want to extend a heartfelt thanks to all those who submitted your stories and experiences with the Connecticut River. There were hundreds of comments submitted and the outpouring of community support has been tremendous! 

Connecticut River Conservancy’s River Stewards Kathy Urffer, Kate Buckman, and Nina Gordon-Kirsch have submitted detailed comments to FERC to speak on behalf of our rivers.


You can download and read our full comments for Great River Hydro (Vernon, Wilder, and Bellows Falls dams) and FirstLight (Turners Falls dam and the Northfield Mountain Pumped Storage Station). 

In summary, our priorities asked FERC and these facilities to: 

  • Take responsibility for the erosion caused by the operation of the facilities 

  • Implement erosion control plans to reduce bank erosion, stabilize banks, and compensate landowners for loss of land 

  • Undertake long term monitoring and assessment of changes in how sediment moves in the river over the next license 

  • Institute comprehensive improvements to recreation access and state of the art ADA compliant recreation amenities along the entire 175 miles of river 

  • Adhere to the shortest possible licensing term (30 years is better than 50) 

  • Initiate immediate upgrades to fish ladders under a shorter timeline than proposed to protect American shad, American eel, Sea lamprey and Shortnose sturgeon 

  • Develop protective land management plans, which include management of terrestrial and aquatic invasive species, and improvements to habitat and riparian buffers 

  • Educate about and protect indigenous cultural resources related to the river 


In addition, CRC filed interventions for both FirstLight and Great River Hydro to have legal standing in the FERC process, so that we can file for rehearing, and appeal the license if it is inadequate. 

What’s next? 

This process is not complete until new licenses are in place, which means there is still more to do. We're moving on to the next phase of the relicensing - state level 401 water quality certifications!  

Massachusetts, Vermont, and New Hampshire have all received applications for a water quality certification (WQC) from either FirstLight or Great River Hydro. The state has jurisdiction to ensure the hydro operations comply with state water quality statutes, and this is the process to ensure that they do. The final WQC will be accepted by FERC for inclusion into the license with no modifications. 


The entire 401 certification process takes about a year, but there are opportunities to comment and various deadlines throughout that time span.  


For more information, visit Mass DEP's webpage dedicated to the FirstLight 401 WQC process (first open comment period ends June 3rd!), or Vermont DEC’s page and NH DES’s page dedicated to the process for Great River Hydro. 


CRC will hold informational sessions in VT and NH during the summer to educate the public and encourage further participation, and we will continue to share news and milestones throughout this process.  




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