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A recent study about “forever chemicals” in freshwater fish has made national headlines, reporting that eating just one freshwater fish a year is equal to a month of drinking water contaminated with chemicals linked to cancer and other adverse health effects. The study from Environmental Working Group showed that locally caught freshwater fish across the United States are likely a significant source of exposure to PFAS and other perfluorinated compounds to people who consume them. Given our strong connection with the Connecticut River and tributaries, we thought we’d take a closer look at the data along with other local research to see what conclusions we can draw from this about the waterways in New England. For those who want the quick takeaway, our general assessment is that PFAS are an issue in the Connecticut River watershed just as they are across the country. States are working on monitoring and regulating PFAS and issuing consumption advisories (such as this factsheet and this advisory in NH) or monitoring plans when appropriate (such as this plan in VT). Consuming freshwater fish from local waters can be a source of PFAS exposure but it is just one among many ways we can and are exposed to PFAS every day. What is PFAS? PFAS is short for per- and polyfluoroalkyl substances and refers to a group of over 4000 human-made chemicals found in everyday household products such as nonstick pans, food packaging, waterproof jackets, and carpets, as well as personal care items such as shampoo and shaving cream, and even industrial materials such as aqueous film forming foam used to fight fires at military bases and commercial airports. One subclass of PFAS, perflourooctane sulfinates (PFOS), are often the focus of exposure due to their widespread use and persistence in the environment. PFAS compounds are useful because they are designed to be resistant to breakdown and impart stain and water-resistant properties to products. Unfortunately, they continue to resist breakdown and become “forever chemicals,” persisting in the environment for decades. They can bioaccumulate (accumulate in tissues) and biomagnify (increase in concentration as you move up the food chain) in living organisms resulting in negative health effects, including cancer. For these reasons and more, they are a serious contaminant that is a global problem. The New Study: First, a summary of the key takeaways from the new Environmental Working Group study: Researchers reviewed data from over 500 samples of fish fillets collected under various other studies in the US. Freshwater fish data came from two different US EPA monitoring initiatives analyzed in 2013-2015. One of these studies targeted fish from the Great Lakes region, which should be noted, is home to several industrial producers of PFAS; Great Lakes fish had a higher concentration of PFAS than more generally across the US. The study concluded that consuming freshwater fish caught in the US can significantly increase PFOS concentration in the human bloodstream, compared to exposure from drinking water alone. They point out that this is an environmental injustice that affects communities that depend on freshwater fishing for sustenance and for traditional cultural practices, which often includes poor, underserved, or BIPOC communities which may be subject to additional environmental health hazards as well. One thing that is important to understand about PFAS both locally and nationally is that this is an emerging area of science. There is, unfortunately, a lot that scientists don’t fully know or understand yet about PFAS, how they move through the environment, and the full effects of chronic exposure on humans, wildlife, and the environment. Even analytical methods for accurately measuring the different PFAS compounds are still being developed and refined. If you are concerned about PFAS, it will be important to keep up as new science emerges and puts what is understood currently into context. For example, there are no federally agreed upon standards in the US for exposure to PFAS through water, eating, or household use yet. The research needed to set these standards is still being done. Individual states have enacted drinking water standards and have issued fish consumption advisories where they feel it is appropriate, but these will likely be adjusted as our knowledge regarding the environmental health effects of PFAS increases. Falls in the Connecticut River below Second Connecticut Lake, Pittsburg, NH. Photo by Al Braden. Westfield River at Chesterfield Gorge, MA. Photo by Diana Chaplin. Skyline and Connecticut River at Springfield, MA. Photo by Al Braden. PFAS in the Connecticut River Watershed While this research is helpful in looking at the issue on a national scale, let’s turn to other studies done closer to home. We reviewed the information available from our four watershed states (VT, NH, MA, and CT). Unfortunately, PFAS are found everywhere that scientists go looking for them – groundwater, surface water, fish, animals, humans, etc. Testing for PFAS is incredibly expensive and challenging. Because PFAS are used in many household and laboratory products, extra care is needed to ensure there is no contamination during the sampling and analysis compared to other things that might be tested for. Even with these challenges, all four states have their own testing programs for water, fish, and more. Here’s a look at how each state is approaching PFAS in their surface waters: Vermont released a surface water monitoring report in 2021 and is expected to go through the rulemaking process to issue water quality standards in 2024. New Hampshire added PFAS monitoring to their surface water monitoring in 2017 and developed a plan to create water quality standards in 2019. Massachusetts funded a study along with the United States Geological Survey (USGS) which focused on known point sources in the eastern portion of the state but included some sites in the Connecticut River watershed. Connecticut is developing a mapping tool to identify potential PFAS sources and guide future monitoring efforts in the states’ waters. What About PFAS in Fish? There are varying levels of PFAS in local fish depending on their environmental exposure and location on the food chain. Fish in water bodies located near point sources of pollution will have higher tissue PFAS concentrations than those caught in water bodies that are subject to background contamination. Some states (like NH and CT) have analyzed fish tissues in areas of known increased environmental contamination and issued consumption advisories for specific rivers and lakes.  Currently, there is a fish consumption advisory for fish caught in the Hockanum River, a tributary to the Connecticut River in Connecticut. There was previously a similar advisory on the Farmington River, another tributary in Connecticut, after an aqueous film firefighting foam spill in 2019; this advisory was lifted in 2020 after testing showed reduced PFAS concentrations in Farmington River fish. More advisories may be issued as states are able to include more water bodies in their testing programs. The suggestions for avoiding excessive exposure to PFAS from fish that are caught from local rivers and lakes are similar to those for avoiding other environmental contaminants that biomagnify such as mercury: Eat low on the food chain, vary fishing spots, and respect local fishing advisories. Fish that live in waters that have lower levels of PFAS contamination will have lower PFAS concentrations in their tissues. Because PFAS are so pervasive, the only way to avoid exposure from consuming locally caught fish is to practice catch and release. That said, PFAS are everywhere in our current world and will continue to be. Every day products like food packaging and waterproof clothing that contain PFAS continue to be manufactured and used nearly ubiquitously throughout the world. The unfortunate and scary truth is that we are exposed to PFAS in many ways every day, not just by consuming freshwater fish. Exposure to PFAS will only truly be addressed by discontinuing use of PFAS compounds globally, however, PFAS that are already present in our environment will continue to persist. Connecticut River PFAS Conclusion: While it is concerning to see viral headlines about the levels of PFAS in our nation’s fish, it is a reminder that these forever chemicals are a clear and present health threat in our modern world. It is a complex issue with a lot of different moving parts. Officials in our watershed states and national agencies are working hard to assess the current levels of PFAS in our waters, soils, fish, and more to set rules and regulations that will help keep folks safer. Ultimately, this is the best thing we can do to address this national issue and stop PFAS from entering the environment in the first place. What CRC is Doing to Clean Up Our Rivers CRC is aware of and following research and data collection efforts regarding pollution and contaminants in our watershed, from e. coli to excess nutrients to chemicals like PFAS. We work with state and local governments, industries, and other non-profits to address issues as appropriate. For example, one of the roles of our River Stewards in each state is to comment on discharge permits through the National Pollutant Discharge Elimination System (NPDES). Anyone discharging a potential pollutant into a body of water must go through the NPDES permitting process, including a comment period. These permits now include regulations for discharging PFAS along with the other pollutants that they regulate. Our River Stewards review these permit applications and submit comments to help ensure that our rivers are protected. We regularly share all CRC comments via our News Updates. Because of the difficulty and expense required to sample and analyze for PFAS, it is unlikely that CRC will start its own PFAS monitoring program. We will, however, continue to watch and engage with the studies being done by state and federal agencies about PFAS in the Connecticut River watershed, advocate for meaningful policy change at every opportunity, and educate the public. Please reach out if you have additional questions and we can connect you with the appropriate agency official for your state if we cannot answer them. _______________ Written by Ryan O’Donell, Monitoring Program Manager at Connecticut River Conservancy Editorial support from Kate Buckman, River Steward in NH, and Diana Chaplin, Communications Director Sign up for email updates to get stories like this in your inbox

March 29, 2021 Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: CRC comments on the Fiske Mill hydroelectric project (P-8615) Preliminary Application Document and study requests Dear Secretary Bose, The Connecticut River Conservancy (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.  The interests and goals represented by CRC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of ecologically sound hydroelectric projects in the Connecticut River watershed. CRC attended the Joint Agency and Public meeting on January 29, 2021 and has reviewed the Pre-Application Document for Exemption from Licensing, dated November 25, 2020. Please consider our comments and requests for studies below. General Comments The PAD states that Power Pool LLC is in “good standing.”[1] Based on a quick search of the NH Secretary of State website this does not appear to be correct.[2] CRC assumes that this is probably the result of a minor infraction, but it should be corrected. The applicant provides a paragraph on page 21 describing indigenous use of the river.  The link to the reference at https://www.des.nh.gov/organization/divisions/water/wmb/rivers/ash_river.htm is not working.  Can Fiske Mill provide the correct link?  Was this description meant to be in the Fisheries section or should it have been placed under Historic Properties? The PAD states that, “there is no formal project boundary associated with this minor project”[3] yet there is an Exhibit G providing a map of the project boundary.  Additionally, the applicant suggests that the impoundment extends upstream approximately 1,800 feet, but the Exhibit G boundary map reflects a distance of approximately 1,500 feet.  Please clarify the extent of the impoundment and the ecological or project related justification that defines the upper end of the impoundment. The PAD states that, “Total flow capacity of the turbines, including the proposed fifth turbine, at the Fiske Mill site (910 cfs) is exceeded 23 percent of the time.”[4] This seems to have been taken from the previously amended application to increase electrical generation to 910 cfs – as opposed to an anticipated total flow capacity of 884 cfs as proposed in the current application.  This percent exceedance should be corrected. In the PAD, the applicant references only the following water quality data, “Water quality parameters measured in August 1989, by the New Hampshire Water Quality Division in the project area indicated that DO was 9 mg/l and pH was 7 standard units.”[5] This was clearly copied from the 1990 amended license information and is too old to be of use.  A quick search of the NH DES website shows that NH Department of Environmental Services and the Ashuelot River Local Advisory Committee have been testing the water quality adjacent to Fiske Mill for many parameters in the intervening years.  While we note that the 2019 sampling results from the NH Volunteer River Assessment Program is included as Attachment A, the PAD should provide more comprehensive information about water quality data that has been collected above and below the project site. Timing of Studies in Relation to Needed Repairs Fiske Mill has been operating significantly under its nameplate capacity for several years due to the collapse of one of the penstocks.  It is not clear from the Notice of Intent or PAD when Fiske Mill intends to fix the penstock and upgrade the turbines and how studies would be timed in relation to this repair work. CRC contends that due to the need to make these repairs, any habitat, water quality, flow, entrainment and impingement, and fish passage studies should be delayed until after the repairs are done to have reliable results.  Any studies done under the current circumstances are not properly reflective of how the facility will be operating when returned to a fully operating condition. Economic Considerations Of additional concern is the economics of limited revenue because of reduced generation combined with expenses related to project repairs and additional expenses that will occur as part of the relicensing process. CRC is concerned about the current limited electricity generated by this facility and whether the cost to the ecosystem is currently justified.  Potential increases in electrical generation may justify some minor ecological impacts, but CRC has concerns about the feasibility of completing repairs and facility upgrades in addition to the cost to carry out relicensing studies while the facility is generating limited revenue.  The exemption for this facility should only be issued if it can be clearly shown that the project is economically viable in the face of these significant obstacles. Section 10(c) of the FPA requires licensees to ‘‘maintain the project works in a condition of repair adequate for… the efficient operation of said works in the development and transmission of power, . . . make all necessary renewals and replacements, . . . establish and maintain adequate depreciation reserves for such purposes…’’[6] Additionally, based on significant dam safety issues, FERC has recently issued a “Notice of Inquiry: Financial Assurance Measures for Hydroelectric Projects” (NOI – Jan. 26, 2021) which states, “In rare cases, the Commission has also included a requirement to file a financial assurance plan. The financial assurance article requires licensees to submit a plan that identifies the costs of project facilities that would be removed, secured in-place, or otherwise modified to ensure public safety, as well as other measures needed to protect environmental resources, in the event the licensee cannot complete project construction [emphasis added] or is unable to operate the project once construction is complete. After approval of the financial assurance plan and before beginning ground disturbing activities, the licensee must obtain a bond or equivalent financial instrument to ensure the licensee has the economic means to implement the plan. The licensee is also required to file annual reports to document that the bond or equivalent financial instrument remains in effect for the ensuing year.”[7] Further the NOI states, “Commission has seen increasing numbers of projects that are nonoperational or out of compliance with their license conditions, where licensees have stated that they cannot afford to operate or maintain the projects or implement required environmental or safety measures. Commission staff regularly works with these licensees to bring these projects back into operation or compliance, but only with mixed success.”[8] Given the growing concern over the financial stability and the aging of our hydro-power assets, and the complexity of extensive repairs needed at the Fiske Mill project in the midst of a relicensing process, CRC requests that a Cost Benefit Analysis of Continued Generation in Relation to Ecosystem and Repair Costs study be done to ascertain if the electric generation currently provided by the Fiske Mill Hydro-power facility is justified when balanced against habitat costs, whether the repairs and capital improvements are feasible, and whether expected generation would provide a return on investment that would maintain the viability of the project. This study may be combined with a decommissioning study to identify the cost of decommissioning the project if upgrades are not economically feasible. See requested Study 1 in Attachment A. Recreational Resources The applicant states that based on a letter from FERC dated October 3, 1997 the licensee was exempted from filing the Form 80 because there were no recreational facilities associated with the project.  The decision to waive requirement of the Form 80 twenty years ago does not waive the examination of recreational needs under this relicensing process.  Since then, FERC has stopped requiring the Form 80 altogether.  That action does not imply a complete waiver of any recreational requirements for mitigation through a relicensing process. 18 CFR Part 2s § 2.7 requires licensees to: “(1) acquire lands to assure optimum development of the recreational resources afforded by the project; (2) develop suitable public recreational facilities with adequate public access, considering the needs of physically handicapped persons in the design of facilities and access; (3) coordinate efforts with other agencies in the development of recreation areas and facilities; (4) provide for planning, operation, and maintenance of these facilities; and (5) inform the public of opportunities for recreation at licensed projects.”[9] The PAD states that, “the river segment below the project to its confluence with the Connecticut River is rural in nature. The area above the Project’s impoundment ,i.e. the former site of the McGoldrick dam and upstream are used for personal boating…”[10] Since the last relicensing of this project portage trails have been developed at two upstream dams and the McGoldrick and Winchester dams have been removed.  The Ashuelot River has become a nationally recognized river for whitewater recreation with Class II to Class IV whitewater reaches in the 13 miles above Fiske Mill Dam. Below the Fiske Mill dam there is another 1.6 miles until the confluence with the Connecticut River. Currently there is no portage trail around Fiske Mill Dam and it remains an impediment to on-water navigation. The Fiske Mill Dam is in the center of downtown Hinsdale, with parking and easy access to the downstream section for fishing. The PAD also provides information about the 21-mile long Ashuelot River Recreation Trial which runs adjacent to the river and project. While there may be constraints to providing recreational enhancements directly on the Fiske Mill site, the presence of the dam nevertheless provides an obstacle to navigation and this impact to recreation should be mitigated for under the new license.  CRC asserts that mitigation of project impacts is not limited by the project boundary.  The project boundary is set to identify where the impacts of the operation are. If needed, the project boundary can be adjusted to accommodate mitigation requirements. In addition, other relicensing processes have provided recreational enhancements off-site as mitigation for project impacts. [11] CRC reiterates that waiving the requirement to provide a Form 80 under a previous license is not related to the consideration of mitigating for impacts to recreation under a relicensing process. CRC would expect Fiske Mill to provide some mitigation in exchange for obstacle to recreation and to identify the most appropriate mitigation effort, Fiske Mill should conduct a Recreation Survey/ Assessment. Please see requested Study 2 in Attachment A. Fish and Fisheries Habitat Five separate hydro-electric facilities on the Connecticut River are currently undergoing relicensing (P-1889 Turners Falls Dam, P-2485 Northfield Mountain Pump Storage Facility, P-1904 Vernon, P-1855 Bellows Falls, and P-1892 Wilder), two of which, P-1889 and P-2485, are downstream of the confluence of the Ashuelot River with the Connecticut.  All these facilities will be changing operations and enhancing up and downstream fish passage over the coming few years. The Fiske Mill project is the first obstacle on the Ashuelot River for the upstream migration of important Connecticut River migratory fish. According to the NH Wildlife Action Plan[12], the Ashuelot River is important for the restoration of American Shad and American Eel.  Additionally, the US Fish and Wildlife Service and CRC have both surveyed and found an abundant number of active sea lamprey nests in the Lower Ashuelot River. CRC supports any studies that may be requested by resource agencies to evaluate effectiveness of upstream and downstream passage for American Shad and American Eel, spawning habitat assessments in the project area for sea lamprey and American shad, freshwater mussel surveys, and studies to assess the presence of tesselated darter (Etheostoma olmstedi), Johnny darter (E. nigrum), and mottled sculpin (Cottus bairdi), as host fish for mussels. It is important that studies done for the Fiske Mill project be comprehensive and properly scoped to anticipate potential changes to flows in the Connecticut River, expected upgrades to fish passage and subsequent changes to the number of migratory fish accessing the lower Ashuelot River for spawning habitat. We appreciate the opportunity to provide comments. I can be reached at kurffer@ctriver.org or (802) 258-0413. Sincerely, Kathy Urffer River Steward CC: Cameron McLeod, Fiske Mill Hydro Paul Nolan Gregg Comstock, NH DES Matthew Carpenter, NH Fish and Game Melissa Grader, USF&WS William McDavitt, NOAA Barbara Skuly, Ashuelot River Local Advisory Committee Rich Holschuh, Atowi Hinsdale Conservation Commission ATTACHMENT A: STUDY REQUESTS Requested Study 1:  Cost Benefit Analysis of Continued Generation in Relation to Ecosystem and Repair Costs Conduct a study of the economic analysis of the return on investment and limited electricity generated by this facility and whether the costs to the ecosystem are justified by this current limited generation and expected capital costs and feasibility of expected repairs and upgrades.  Methodology could include a Return on Investment (ROI) of capital costs of needed repairs and generation capacity increases; potential increases to recreational economy of adjacent towns with an un-obstructed river; potential economics of ecosystem benefits of an un-obstructed river; develop a cost estimate for decommissioning if expected repairs and turbine upgrades are not financially feasible; as well as other economic considerations. Goals and Objectives To determine if the ROI for project repairs and upgrades are feasible and reasonable to justify ecological impacts from a continued license; To determine if project generation is justified in relation to the impact to the river; To determine economic impact of this facility as obstacle to recreation; Develop a cost estimate of decommissioning to consider this as an alternative to relicensing. Resource Management Goals Cost/benefit analysis of impacts to river and whether local and natural resource impacts are justified by limited generation. Noted that requester is not an agency or Indian tribe. Public Interest FERC Licensing Guidance indicates that economic studies should address: sources of economic information assumed such as fuel costs, escalation rates, growth rates in peak demand, and existing and planned generating resources; feasibility of financing a proposed project modification based upon the size of the economic benefits and the forecasted project revenues; estimate of the net present value of the project; capital and operations and maintenance costs of project modifications and all proposed protection, mitigation, and enhancement measures; and an estimate of the cost to prepare the license application 18 CFR 4.41(e)(9); 18 CFR 4.51(e)(9); 18 CFR 4.61(c)(9). Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued.  As indicated in the FERC Policy Statement on Project Decommissioning at Relicensing, “The more likely scenario is one in which the Commission is required to condition a new power license with environmental mitigation measures, and the licensee is unwilling to accept the license tendered. The licensee may prefer to take the project out of business, because the costs of doing business have become too high. There is no merit to the suggestion by some industry commenters that a condition in a power license is per se unreasonable if, as a result of imposing the condition, the project is no longer economically viable. The statute calls for a balancing of various development and nondevelopment interests, and those commenters’ position would elevate power and other development interests far above the environmental concerns. It would mean that severe environmental damage would have to be accepted in order to protect even a very marginal hydropower project. The Commission does not read the Federal Power Act to compel such a result.”[13] Existing Information Existing cost of road infrastructure issues should be accessible by contacting adjacent towns.  Similar sized dams have been removed in Vermont in recent years and those costs are accessible through the VT DEC and NGOs. Nexus to Project Operations and Effects The Federal Power Act requires the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. Given the current marginal generation at this facility, it is in the best interest of the public to have a clear economic analysis of the feasibility of increases to electrical generation as compared project impacts in order to weigh the benefits of this limited generation against impacts to the waterway and surrounding communities. Methodology Consistent with Accepted Practice The proposed study would be conducted by developing an environmental cost benefit analysis to consider habitat and societal costs and compare these costs and impacts to the ROI of capital improvements to increase generation. This is an accepted methodology for this type of study. Level of Effort/Cost, and Why Alternative Studies will not suffice Cost for this study is estimated to be low.  Conducting this study at the outset of relicensing will help Fiske Mill to clarify whether continued investment in this facility is warranted. Requested Study 2:  Recreation Survey/Assessment Conduct a study of the recreational boating, fishing, and birding opportunities at the dam, as well as upstream and downstream of the dam to determine if changes or improvements can be made to enhance recreational opportunities.  Methodology should include using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of the neighboring towns to assess recreation use and needs at the project.  The applicant should coordinate information gathering with the Town of Hinsdale Planning Department and Department of Parks and Recreation as to useful recreational enhancements that could result through a partnership. The study should also include an assessment of possible enhancements of ADA compliant fishing access in the project area. Goals and Objectives To determine if project operations impact recreational opportunities; To determine current use of project area for recreation; Assess if there are modifications to the project or additional off-site enhancements which could improve fishing, birding, boating, or other recreational opportunities. Resource Management Goals Enhancement of recreational opportunities associated with the presence and operation of the project, including the dam, impoundment and tailwater areas. Noted that requester is not an agency or Indian tribe. Public Interest Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued.  As indicated in the FERC guidance for Recreation Development at Licensed Hydropower Projects,“On December 27, 1965, FERC issued Order No. 313, which amended the General Policy and Interpretations section of the Commission’s regulations (18 CFR Part 2) to ensure that the ultimate development of recreation resources at all projects is consistent with area recreational needs.  Specifically, 18 CFR Part 2 was amended to include § 2.7, which requires licensees to: (1) acquire lands to assure optimum development of the recreational resources afforded by the project; (2) develop suitable public recreational facilities with adequate public access, considering the needs of physically handicapped persons in the design of facilities and access; (3) coordinate efforts with other agencies in the development of recreation areas and facilities; (4) provide for planning, operation, and maintenance of these facilities; and (5) inform the public of opportunities for recreation at licensed projects.”[14] Existing Information Fiske Mill obtained an exemption from the requirement to file a Form 80 in 1997. In 2019, the requirement to file Form 80s, which provided some information as to recreational amenities at and investment of hydro power facilities was eliminated as a result of a rule change by the FERC.  In the ensuing 24 years since 1997, numerous changes have occurred to the river and recreational use patterns, including the removal of several dams, creation of upstream portages, and the identification of the Ashuelot River as a white water destination.  Since the licensee is applying for a license exemption,  this will likely be the only opportunity to consider recreational use over the remaining life of this project. Nexus to Project Operations and Effects Boaters, anglers, and other recreational users are impeded from access to their public trust waters by hydro-electric dams.  Changes in hydraulic conditions and habitat in the river impacts their ability to use the resources, affects catch rates and species for fish, and creates safety concerns. Methodology Consistent with Accepted Practice The proposed study would be conducted by using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of Hinsdale and neighboring towns to collect feedback on perceptions of access to the area, use patterns and local needs.  This is an accepted methodology for this type of study. Level of Effort/Cost, and Why Alternative Studies will not suffice Cost for this study is estimated to be low.  This study would provide the current baseline regarding recreational use and would provide insight into the need for and type of potential enhancements. [1] Pre-Application Document for Exemption from Licensing. Fiske Hydro, Inc. Orange, MA. November 25, 2020. Page 3. [2] New Hampshire Department of State. Accessed at https://quickstart.sos.nh.gov/online/BusinessInquire/BusinessInformation?businessID=420884 on March 26, 2021. [3] Pre-Application Document for Exemption from Licensing. Fiske Hydro, Inc. Orange, MA. November 25, 2020. Page 25. [4] Pre-Application Document for Exemption from Licensing. Fiske Hydro, Inc. Orange, MA. November 25, 2020. Page 27. [5] Ibid. Page 18. [6] 16 U.S.C. 803(a). [7] Notice of Inquiry: Financial Assurance Measures for Hydroelectric Projects” (Jan. 26, 2021) [8] Ibid. [9] 18 CFR § 2.7 – Recreational development at licensed projects. [10] Pre-Application Document for Exemption from Licensing. Fiske Hydro, Inc. Orange, MA. November 25, 2020. Page 9. [11] See City of Seattle, Washington, 26 FERC ¶ 61406, 61906 (1984) where FERC required off project site recreation facilities. [12] New Hampshire Fish and Game. NH Wildlife Action Plan. 2015 Revised Edition. Accessed at: https://www.wildlife.state.nh.us/wildlife/wap.html [13] Project Decommissioning at Relicensing; Policy Statement (December 14, 1994), 18 C.F.R. § 2.24, 60 Fed. Reg. 339 (January 4, 1995), FERC Stats. & Regs. Preambles 1991-1996 ¶ 31,011. [14] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 1.

January 27, 2021 Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Turners Falls Project No. 1889 Northfield Mountain Pumped Storage Project No. 2485 Objection to Deficient Amended Final License Application and Request for Additional Information Dear Secretary Bose, The Connecticut River Conservancy (CRC) is a nonprofit citizen group that was established in 1952 as the Connecticut River Watershed Council, Inc. (CRWC) to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed. CRWC, now as CRC, has been participating in the relicensing of the Turners Falls and Northfield Mountain Pumped Storage Projects since the process began. CRC has been reviewing the Amended Final License Application (AFLA) for the above-referenced projects submitted to FERC on December 4, 2020. This letter includes our initial identification of deficiencies and requests for additional information based on our review of the AFLA. We note that, because the original Draft License Application dated December 5, 2015 and the Final License Application (FLA) dated April 29, 2016 were completed prior to the relicensing studies being complete, stakeholders have been deprived of the opportunity to comment on a draft set of Protection, Mitigation, and Enhancement measures (PM&Es).  The existence of an AFLA is not contemplated in the Integrated Licensing Process (ILP). The AFLA is deficient and should be rejected.  18 C.F.R. § 5.20.  Additional information should be required. 18 C.F.R. § 5.21 and ILP generally. The AFLA and the shortcomings leading to and compounded by the AFLA result from First Light’s patently defective Draft License Application submitted in 2015. The continued deficiencies compound and add to previously identified ILP failures that deprive agency and public comment and undermine the ILP. Rather than fine-tuning already-vetted mitigation measures, the vetting of mitigation measures that should have started prior to filing the DLA, may just be starting now. Our request for additional information follows. Costs and financing Clarification needed between costs shown in the Executive Summary Table ES-1 and the Exhibit D Tables 4.5-1 for both projects. Table ES-1 itemizes FirstLight’s proposed PM&E measures.  This Table ES-1 includes a “total cost” which Footnote 1 defines as energy revenue loss, capital cost, periodic costs, and operation and maintenance costs over a 50-year duration.  Table 4.5-1 in Exhibit D for both the Turners Falls and Northfield Mountain Pumped Storage Projects includes these same PM&E projects, broken down by project.  Table 4.5-1 has separate columns showing the total capital cost over 50 years, the total periodic capital cost over 50 years, the total O&M costs over 50 years and the average annual cost for each of the 50 years, all in 2019 dollars.  CRC requests more information from FirstLight on the differences between these two tables.  It appears that the only difference is the energy revenue loss, but it is unclear what assumptions went into the derivation of the estimates.  For example, Table ES-1 lists a total cost for the improvements to the existing river access location at Poplar Street at $1,573,000.  Table 4.5-1 lists this same facility as costing $286,000 in capital costs and $328,000 in O&M costs over 50 years, for a total of $614,000.  We are seeking an explanation of the basis for the estimate of $959,000 in revenue loss to build and maintain the Poplar Street facility.  Similarly, the installation of the ultrasound array in the Cabot Station tailrace has a $11.62M total cost in ES-1 but a $6M total cost (adding up 3 columns) in Table 4.5-1 in Exhibit D, and CRC is requesting information on the assumptions that account for a $5.6M loss in energy revenue over 50 years in relation to the ultrasound array installation and maintenance.  CRC requests this information for all of the PM&E measures listed in the tables. 18 CFR §5.18(b)5(ii)E states that “If a protection, mitigation, and enhancement measure reduces the amount or value of the project’s developmental resources, the applicant must estimate the reduction.” Does Table ES-1 consider a reduced value of the project, or only reduced energy revenue loss? Have costs to dismantle existing fish passage structures been built into any of the costs presented in the AFLA? Better understanding of operation and maintenance activities and budget desired Exhibit D for the Turners Falls Project estimates capital costs of $2M/year, and operation and maintenance costs of $4.3M/year.  Table 4.5-1 of Exhibit D shows the capital costs and the operation and maintenance costs of proposed PM&E measures.  CRC requests that FirstLight break down capital and/or O&M costs from Exhibit D to include large categories of maintenance activities (aside from the PM&E measures), such as the following:  cost of running and maintaining recreation facilities, cost of annual canal drawdown and maintenance, etc. Exhibit D for the Northfield Mountain Project estimates capital costs of $8.22M/year, and operation and maintenance costs of $24.9M/year (CRC notes that this figure was listed as $11.02M in the 2016 Final License Application).  Table 4.5-1 of Exhibit D shows the capital costs and the operation and maintenance costs of proposed PM&E measures. CRC requests that FirstLight break down capital and/or O&M costs from Exhibit D to include large categories of maintenance activities (aside from the PM&E measures), such as the following:  cost of running and maintaining recreation facilities, project lands maintenance/real estate, power equipment maintenance, etc., and CRC recommends that FirstLight remove the periodic dredging of the upper reservoir intake channel that is shown in Table 4.5-1 and include it as a category under O&M because it is not a PM&E measure.  CRC is curious how the O&M budget is more than doubling since the FLA was filed in 2016 because there are two notable things being proposed to be eliminated, as follows: Section 3.3.1.4.1 of Exhibit E on page E-74 of the AFLA states that FirstLight is not proposing any PM&Es related to erosion. Under their current license, FirstLight has been expending O&M money on riverbank restoration projects.  FirstLight should explain what their budget has been under the existing license, and how that money will be spent under the new license. FirstLight, on page E-532, states that it is discontinuing the rental of cross-country ski equipment in part because of “high overhead costs.” It is not clear what those costs are, and if money may be shifted to some other recreation activity or if FirstLight is lowering their overall budget for recreational offerings. CRC requests information from FirstLight on maintenance dredging of Barton Cove to maintain navigation and reservoir storage for Northfield Mountain.  During the scoping phase of the relicensing, the siltation of Barton Cove was identified as an issue currently affecting navigation to various boat access locations within the Cove.  Although Section 3.3.1.2 of the AFLA on page E-72 mentions that cross-sections in Barton Cove showed net deposition, there is no assessment of net volume accumulation of sediment in Barton Cove, or in areas of Barton Cove.  CRC requests information from FirstLight as to the expected rate of siltation and at what point it may impact (or has impacted) the storage capacity of Northfield Mountain’s lower reservoir or the operation of Turners Falls dam and gatehouse, and at what point they anticipate needing to dredge Barton Cove over the next 50 years to either maintain navigation or for operational reasons. Additional revenues for the Project should be estimated Annual revenues from recreational facility programs (rentals, tickets, etc.), nonproject use of project land including the solar energy facility and re-imbursement by private uses of camps and private clubs should be included in Exhibit D, just as expenses not specifically tied to energy generation, such as taxes, were included.  After all, these revenues occur because of the project’s existence and operation. Operational changes to Great River Hydro’s facilities upstream should now be modeled In the AFLA submitted by Great River Hydro on December 7, 2020, they propose to operate the Wilder, Bellows Falls, and Vernon Projects “fundamentally different” than current operation.  In FirstLight’s AFLA in Section 3.3.2.1.1.1, FirstLight requests certain information about Great River Hydro’s operations.  CRC requests that FirstLight provide commentary and/or model runs on how Great River Hydro’s proposed operation, if implemented, would impact the operation of the Turners Falls Project, and possibly Northfield Mountain.  As part of this request, CRC specifically requests how flows below the Turners Falls Dam and Cabot Station may or may not change from current/proposed operations, given the proposed Great River Hydro operations. Explanation of PM&E measures not adopted is deficient The ILP regulations at 18 CFR §5.18(b)5(ii)C require that if an applicant does not adopt a preliminary environmental measure proposed by a resource agency, Indian tribe, or member of the public, it must include its reasons, based on project-specific information. CRC notes again that normally this would take place in a FLA after stakeholders have proposed preliminary measures in comments on a DLA. FirstLight was required to submit their DLA and FLA before the relicensing studies were complete, and now FERC has required an Amended Final License Application with no comment period, further denying the public the opportunity to comment on still deficient PM&E measures and plans. FirstLight’s AFLA has only a list of commenters on their DLA, but no part of Exhibit E reflects stakeholder input, either through comments on the DLA or otherwise. Though FirstLight conducted settlement negotiations with stakeholders, including CRC, for two years, those discussions focused only on flows and fish passage before they ended. More information is needed on why the following measures were not adopted: FirstLight in Exhibit C on page C-3 for the Turners Falls Project says that it considered but eliminated installing a minimum flow turbine. What assumptions were made as to size and amount of water and costs of installing? On June 8, 2018, CRC filed with FERC a request for a full alternatives analysis to mitigate the environmental effects of Northfield Mountain. CRC suggested an analysis of full or partial closed loop, a retrofit to adjustable speed units, widening the tailrace, and a request for thinking of other alternatives not contemplated by CRC. FirstLight has only described building a lower reservoir for Northfield Mountain as an alternative identified but not adopted in Section 2.3 in Exhibit E. This is insufficient. CRC’s comments on FirstLight’s DLA dated March 1, 2016 contained a series of recreation recommendations. FirstLight’s FLA included a Draft Recreation Management Plan with no response to specific comments on the DLA.  On July 30, 2019, CRC filed with FERC a detailed set of additional recreation recommendations put together by CRC and the Appalachian Mountain Club (AMC).  The AFLA does not contain a reason for not adopting many of these proposed PM&E’s.  Somehow, FirstLight has gone from a deficient Draft Recreation Management Plan in 2016 to a Final Plan in 2020, with no consideration or response to comments received. Information lacking on flows and river levels needed for paddling and boat navigation Section 3.3.6.2 in Exhibit E lacks an analysis of navigability in and out of all current and proposed river access locations based on the proposed flows and operations, both in the Turners Falls impoundment and below the Turners Falls Dam (especially under the proposed minimum flows at the new put-in below the dam, 650 and 500 cfs, for August and September 1 to November 30, respectfully).  And, if average river elevations in the Turners Falls Impoundment (TFI) will be changed under proposed increase upper reservoir capacity as it has under temporary amendment conditions in the past, that information needs to be highlighted in the AFLA and included in this requested analysis. Having no comment period on a true draft license application undermines the ILP FirstLight’s continuing failures compound the issues identified in CRC’s March 1, 2016 comments and further undermine the ILP.  A critical part of the ILP was to better allow for public input and response, and to front-load this input.  Now that the studies are in, and FirstLight has proposed PM&E’s that the public can react to, these are being offered as “final” elements of their application. This wholly circumvents the required public input and undermines the ILP. Indeed, FirstLight has made no attempt to respond to some of the recommendations that have been submitted since the DLA and the present.  FERC staff have said that there are plenty of opportunities for public comment later in the process, but that has yet to happen and does not excuse clear ILP violations. CRC requests FERC to require significant additional information and clarification of the details and a formal public comment period before it deems the application complete. FERC must do so without additional delays to this long-delayed relicensing process. I can be reached at adonlon@ctriver.org or (413) 772-2020 x.205. Sincerely, Andrea F. Donlon River Steward ATTACHMENT: CRWC’s 2016 comments on the Draft License Application See CRC’s Comments on First Light’s DLA (Mar. 1, 2016).  CRC reasserts those comments and incorporates them as part of these comments.

Greenfield, MA — This year, the Connecticut River Conservancy (CRC) is aiming to complete nine river restoration projects across all four Connecticut River states – NH, VT, MA & CT. These projects will restore natural river flow, improve wildlife habitat, and protect clean water. They will also pump more than $2 million into local economies and local businesses like plant nurseries, tree planting crews, construction crews, engineering and design firms, and more. CRC’s river restoration projects include: Streambank stabilization with large wood in Lisbon, NH; Dam removal and culvert upgrade already complete in Perkinsville, VT; Dam removal at Magic Mountain in Londonderry, VT; Habitat improvements with large wood additions in Windham, VT; Two berm removals reconnecting the Green River to its floodplain in VT; Streambank stabilization with large wood in Colrain, MA; Streambank stabilization & culvert upgrade in Colrain, MA; Living shoreline in Fenwick, CT. “We always say that a healthy environment and healthy economy go hand in hand, and it couldn’t be any more true right now,” says Ron Rhodes, River Steward for CRC. “We’re thrilled that our river restoration work can help boost the local economies during these difficult times. And we are proud of the partnerships we have been able to forge over the past decade that have resulted in nearly 350 miles of stream being restored and opened to fish passage.” David Sagan, Private Lands Biologist with the US Fish & Wildlife Service notes, “Each time we remove an old dam, replace a bridge or culvert in the Connecticut River watershed, it has far-reaching benefits to the wildlife and people that depend on it. We are pleased to be a part of the team helping to remove a dam.” “NorthWoods is proud to work alongside the Connecticut River Conservancy to help our local rivers,” said Meghann Carter, Conservation Science Director at NorthWoods Stewardship Center. "We are so glad for this opportunity to get back out into the field." In addition to these nine river restoration projects, CRC and partners planted more than 6,400 trees this past spring and has 13 more tree planting projects lined up for this fall. Ben Machin, Partner and Forester at Redstart, noted that “we greatly appreciate the chance to work with CRC to get these important restoration projects completed. Nothing expresses hopefulness like planting trees and shrubs.” Since 1952, Connecticut River Conservancy has been the voice for the Connecticut River watershed, from source to sea. They collaborate with partners across four states to protect and advocate for your rivers and educate and engage communities. They bring people together to prevent pollution, improve habitat, and promote enjoyment of your river and its tributary streams. Healthy rivers support healthy economies. To learn more about CRC, or to make a contribution to help protect your rivers, visit ctriver.org.

John Greenan, P.E. Green Mountain Power Corporation 2152 Post Road Rutland, VT  05701 Re: CRC comments on the Cavendish (P-2489) Preliminary Application Document and Study Plan Requests Dear Mr. Greenan, The Connecticut River Watershed Council, Inc. (CRWC), now doing business as the Connecticut River Conservancy (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.  The interests and goals represented by CRC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of hydroelectric projects in the Connecticut River watershed. CRC attended the Joint Agency and Public meeting via phone on February 6, 2019 and has reviewed the Cavendish hydro-electric facility Pre-Application Document October, 2019. Please consider our comments on the PAD and requested studies below. 4.4 Current and Proposed Project Operations The PAD states, that “For the protection of this bypass reach, the Project provides a continuous minimum flow of 10 cfs, or inflow, whichever is less.”[1] CRC understands that the minimum flow of 10 cfs in the bypass reach had been established due to the presence of bryophyte communities in the Cavendish Gorge during the last relicensing. This flow was established to protect the population of Scapania umbrosa that was present.  The PAD goes on to state that, “at the conclusion of the post license study period, Scapania umbrosa populations in Cavendish Gorge had disappeared.”[2] It seems logical that an analysis be done to ascertain what bryophytes communities are still present and whether a 10 cfs minimum flow is still appropriate in the bypass reach. CRC supports any additional analysis to establish an appropriate minimum flow that would support riverine habitat downstream of the project. 6.6.6 Freshwater Mussels The PAD states that, “The State of Vermont has 17 native species of freshwater mussels…”[3] but it does not indicate that 10 out of the 17 are considered endangered or threatened in the state.[4]  CRC thinks it prudent that GMP do a mussel survey in the project area to consider project effects on our mussel populations. CRC defers to the expertise of the VT State Fish and Game or the United States Fish and Wildlife Service as to the design and oversight of this study. 7.2.7 Recreation and Land Use The FERC guidance for recreation at hydropower projects states, “Licensees must also keep in mind that the demand for recreation is not static; it is an evolving process. Periodic review of a project’s consistency with recreation demands is required to ensure that the public need for recreational opportunity is being met by existing and proposed facilities.”[5]  All hydropower facilities have been required to file a “Form 80” with FERC every 6 years, and all were on the same filing schedule (recent filings are from 2015, 2009, and 2003). In 2019, this requirement was eliminated as a result of a recent rule change by the FERC. Therefore, there will not be any future Form 80 filings. Given that the only opportunity to consider recreational use now occurs during the relicensing process, CRC supports a recreation study.  Additionally, CRC encourages GMP to develop a Recreation Plan with a commitment to update this every 10 years over the course of the coming license in case additional opportunities for recreational improvements arise.  See Requested Study 1 in Attachment A. In addition to the comments provided above, please note that CRC supports comments submitted by the natural resource agencies, including but not limited to the Vermont Fish and Wildlife Department (VT F&W), VT Department of Environmental Conservation (VT DEC), and the U.S. Fish and Wildlife Service (USFWS). We are very grateful for Green Mountain Power’s sustainable leadership and encourage them to use this opportunity to increase their commitment to the environment.  We appreciate the opportunity to provide comments.  I can be reached at kurffer@ctriver.org or (802) 258-0413. Sincerely, Kathy Urffer River Steward Encl: Attachment A: Study Requests CC: FERC, e-file Jason Lisai, GMP John Tedesco, GMP Katie Sellers, Kleinschmidt Associates Jeff Crocker, VT DEC Eric Davis, VT DEC Betsy Simard, VT DEC Lael Will, VT F&W Courtney Buckley, VT F&W Hannah Harris, VT F&W Melissa Grader, US FWS ATTACHMENT A: STUDY REQUESTS Requested Study 1:  Recreation Survey Conduct a study of the recreational boating, fishing, and birding opportunities at the dam, as well as upstream and downstream of the dam to determine if changes or improvements can be made to enhance recreational opportunities.  Methodology should include using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of the neighboring towns to assess recreation use and needs at the project.  The study should also include an assessment of use of ADA compliant fishing access from the parking lot and walking paths available in the project area. Goals and Objectives To determine if project operations impact recreational opportunities; To determine current use of project area for recreation; Assess if there are operational, structural or other modifications to the project which could improve fishing, birding, or other recreational opportunities. Resource Management Goals Enhancement of recreational opportunities associated with the presence and operation of the project, including the dam, reservoir and tailwater areas. Noted that requester is not an agency or Indian tribe. Public Interest Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued.  As indicated in the FERC guidance for Recreation Development at Licensed Hydropower Projects, “On December 27, 1965, FERC issued Order No. 313, which amended the General Policy and Interpretations section of the Commission’s regulations (18 CFR Part 2) to ensure that the ultimate development of recreation resources at all projects is consistent with area recreational needs.  Specifically, 18 CFR Part 2 was amended to include § 2.7, which requires licensees to: (1) acquire lands to assure optimum development of the recreational resources afforded by the project; (2) develop suitable public recreational facilities with adequate public access, considering the needs of physically handicapped persons in the design of facilities and access; (3) coordinate efforts with other agencies in the development of recreation areas and facilities; (4) provide for planning, operation, and maintenance of these facilities; and (5) inform the public of opportunities for recreation at licensed projects.”[6] Existing Information GMP provided filing of Form 80 reports in 2003, 2009, and 2015. All hydropower facilities have been required to file a “Form 80” with FERC every 6 years, and all were on the same filing schedule. In 2019, this requirement was eliminated as a result of a rule change by the FERC. Therefore, there will not be any future Form 80 filings. This relicensing process will be the only opportunity to consider recreational use over the course of the coming license period. Nexus to Project Operations and Effects Boaters, anglers, and other recreational users are impeded from access to their public trust waters by hydro-electric dams.  Changes in hydraulic conditions and habitat in the river impacts their ability to use the resources, affects catch rates and species for fish, and creates safety concerns. Methodology Consistent with Accepted Practice The proposed study would be conducted by using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of neighboring towns to collect feedback on perceptions of access to the area, use patterns and local needs.  This is an accepted methodology for this type of study. Level of Effort/Cost, and Why Alternative Studies will not suffice Cost for this study is estimated to be low.  This study would provide the current baseline regarding recreational use and would provide insight into the need for and type of potential enhancements. [1] Pre-Application Document. Cavendish Hydroelectric Project. (FERC No. 2489). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. October 2019. Page 4-12. [2] Ibid. Page 6-26. [3] Pre-Application Document. Cavendish Hydroelectric Project. (FERC No. 2489). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. October 2019. Page 6-32. [4] Vermont Agency of Natural Resources. Fish and Wildlife Department. Endangered and Threatened Species.  Accessed at: https://vtfishandwildlife.com/conserve/conservation-planning/endangered-and-threatened-species. April 5, 2020. [5] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 14 [6] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 1.

John Greenan, P.E. Green Mountain Power Corporation 2152 Post Road Rutland, VT  05701 Re: CRC comments on the Taftsville (P-2490) Preliminary Application Document and Study Plan Requests Dear Mr. Greenan, The Connecticut River Watershed Council, Inc. (CRWC), now doing business as the Connecticut River Conservancy (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.  The interests and goals represented by CRC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of hydroelectric projects in the Connecticut River watershed. CRC attended the Joint Agency and Public meeting on December 10, 2019 and has reviewed the Taftsville hydro-electric facility Pre-Application Document August 28, 2019. Please consider our comments on the PAD and requested studies below. 4.4 Current and Proposed Project Operations CRC understands that the change to run of river and a minimum flow of 15 cfs had been established voluntarily by the previous owner before the last relicensing. It is unclear if this is based on any scientific analysis of appropriate flows for the river. CRC supports any additional analysis to establish an appropriate minimum flow that would support riverine habitat downstream of the project. Additionally, the PAD states that the “18 inch flashboards are removed prior to winter and reinstalled in late spring.”[1] During the site meeting Green Mountain Power (GMP) staff indicated that the flashboard are allowed to break over the winter, generally in February and then are repaired in the spring. CRC notes this in case there are impoundment surface water elevation considerations that may be affected by this course of action. 4.5.3 Average Annual Energy and Dependable Capacity Table 2 from the PAD providing net generation by month[2] may be incorrect. The Total column is actually the average over the 12 months of each year, not the total generation for that year. If one takes an average of the total generation over the four years presented, the average annual generation is actually 1.0252. CRC is curious about the return on investment and limited electricity generated by this facility and whether the cost to the ecosystem is justified by this limited generation. The PAD states that, “there are no dams upstream of the Taftsville Project”[3] and that the “Lower Ottaquechee River (Kedron Brook to confluence) is listed as a priority water for remediation and enhancement projects.” [4] Based on this, ecosystem restoration in this stretch of the river seems to be a high priority. Given the Given Green Mountain Power’s role as the only utility in the nation to be designation a Certified B-Corp, the standards and expectations of that certification compel the company, “That all business ought to be conducted as if people and place mattered, and that, through their products, practices, and profits, businesses should aspire to do no harm and benefit all.”[5] Additionally, New England in general is trending toward declining electricity demand.  According to GMP’s 2018 Integrated Resource Plan, “Sales of baseload energy in Vermont have declined to levels last seen fifteen years ago.”[6] As the holder of multiple hydro assets, GMP is in the unique position to consider balancing the costs and benefits of its facilities across its assets in order to make choices to prioritize the most effective and efficient facilities while allowing possible decommissioning of some facilities to protect or enhance our resources. To that end, CRC requests that an ecosystem cost/generation benefit study to ascertain if the electric generation provided by the Taftsville Hydro-power facility is justified when balanced against habitat, recreational and municipal costs.  This may be combined with a decommissioning study to identify the cost of decommissioning the project in anticipation of revenue changes. See requested Study 1 in Attachment A. 6.3.2 Aquatic Habitat The PAD states that, “During July, August and September, river flow is usually less than the minimum capacity of the turbine unit (110 cfs); consequently, during these months the Licensee does not usually operate the Taftsville project.”[7]  Yet, Table 4-2 Taftsville Net Generation by Month[8] shows generation amounts for June, July, August and September in every year between 2014 and 2018 except for August of 2016. Additionally, this statement indicates that the minimum capacity of the turbine unit is 110 cfs, but during the site meeting it was suggested the minimum capacity was 95 cfs. Can this be clarified? 6.8.1 Existing Recreation Opportunities and Use at the Project While we understand that there may be some recreational opportunity at the facility itself, the presence of the dam nevertheless impedes access by anglers, boaters and other recreation users to freely access or paddle through on the river. The FERC guidance for recreation at hydropower projects states, “Licensees must also keep in mind that the demand for recreation is not static; it is an evolving process. Periodic review of a project’s consistency with recreation demands is required to ensure that the public need for recreational opportunity is being met by existing and proposed facilities.”[9]  The PAD indicates that “GMP reported estimated recreation use… in the 2003, 2009, and 2015 FERC Form 80 Licensed Hydropower Development Recreation Reports.”[10] All hydropower facilities have been required to file a “Form 80” with FERC every 6 years, and all were on the same filing schedule (recent filings are from 2015, 2009, and 2003). In 2019, this requirement was eliminated as a result of a recent rule change by the FERC. Therefore, there will not be any future Form 80 filings. Given that the timing of this relicensing falls in line with what would have been a normal Form 80 reporting period, and this now will be the only opportunity to consider recreational use over the course of the coming license period, CRC supports a recreation study.  Additionally, CRC encourages GMP to make a commitment to develop a Recreation Plan with a commitment to update this every 10 years over the course of the coming license in case additional opportunities for recreational improvements arise.  See Requested Study 2 in Attachment A. 6.8.5 National Rivers Inventory and National Wild and Scenic River System The PAD states that the section of the “Ottaquechee from the headwaters to Woodstock is listed on the NRI…”[11]  What it doesn’t state is that the uppermost point of this is only approximately 12,000 feet upstream from the Taftsville impoundment.  One might argue that the reach of river containing the Taftsville dam is not on the NRI because of the presence of the dam itself.  The fact that this project is essentially adjacent to an NRI segment advances the argument that GMP should study the cost benefits of generation at this facility. 6.9.2 Land Use and Management within the Project Vicinity In Figure 4-1, The Project Location Map[12] one notices that Old River Road to the north and east, and Woodstock Road, or VT Rte 4 to the south and west are adjacent to the project boundary on both sides of the impoundment. It is CRC’s understanding from personal communication that there are ongoing issues with ice coming up onto those roads from the impoundment.  This is a yearly expense that the adjacent towns of Woodstock, Pomfret, and Hartford have to bear possibly due to sediment levels in the impoundment.  Town residents have reported that they feel that the dam is influencing that stretch of river with sediment backup and ice jams.[13] 6.11.4 History of the Project The PAD indicates that the facility, “suffered serious damage due to flooding caused by Tropical Storm Irene.  The river overflowed the west bank upstream from the dam and descended past the landward side of the headworks and connecting floodwall to enter the powerhouse.” [14] We understand from the site visit that as a result of this GMP has reconstructed the power house to protect it in future floods, but given the shallowness of the impoundment, and increased flooding due to climate change, we can expect this to reoccur.  The study request for cost/ benefit analysis should include some consideration of future flooding on the towns. 7.2.6.2 Proposed Studies CRC supports the proposal by GMP to conduct a freshwater mussel survey.[15]  CRC defers to the expertise of the United States Fish and Wildlife Service as to the design and oversight of this study. In addition to the comments provided above, please note that CRC supports comments submitted by the natural resource agencies, including but not limited to the Vermont Fish and Wildlife Department (VT F&W), VT Department of Environmental Conservation (VT DEC), and the U.S. Fish and Wildlife Service (USFWS). We are very grateful for Green Mountain Power’s sustainable leadership and encourage them to use this opportunity to increase their commitment to the environment. We appreciate the opportunity to provide comments. I can be reached at kurffer@ctriver.org or (802) 258-0413. Sincerely, Kathy Urffer River Steward Encl: Attachment A: Study Requests CC: FERC, e-file Jason Lisai, GMP John Tedesco, GMP Katie Sellers, Kleinschmidt Associates Jeff Crocker, VT DEC Eric Davis, VT DEC Betsy Simard, VT DEC Lael Will, VT F&W Melissa Grader, US FWS ATTACHMENT A: STUDY REQUESTS Requested Study 1:  Cost Benefit Analysis of Continued Generation in Relation to Ecosystem and Municipal Costs Conduct a study of the economic analysis of the return on investment and limited electricity generated by this facility and whether the costs to the ecosystem and adjacent municipalities are justified by this limited generation.  Methodology could include analyzing costs to neighboring towns of flooding and ice impacts on Old River Road and Rte 4; analyzing potential increases to recreational economy of adjacent towns with an un-obstructed river; develop a cost estimate for decommissioning; as well as other economic considerations. Goals and Objectives To determine if project generation is justified in relation to the impact to the river and financial cost to neighboring municipalities; To determine economic impact of this facility as obstacle to recreation; To determine economic impact of habitat loss and sedimentation behind the dam; Develop a cost estimate of decommissioning to consider this as an alternative to relicensing. Resource Management Goals Cost/benefit analysis of impacts to river and whether local and natural resource impacts are justified by limited generation. Noted that requester is not an agency or Indian tribe. Public Interest Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued.  As indicated in the FERC Policy Statement on Project Decommissioning at Relicensing, “The more likely scenario is one in which the Commission is required to condition a new power license with environmental mitigation measures, and the licensee is unwilling to accept the license tendered. The licensee may prefer to take the project out of business, because the costs of doing business have become too high. There is no merit to the suggestion by some industry commenters that a condition in a power license is per se unreasonable if, as a result of imposing the condition, the project is no longer economically viable. The statute calls for a balancing of various development and nondevelopment interests, and those commenters’ position would elevate power and other development interests far above the environmental concerns. It would mean that severe environmental damage would have to be accepted in order to protect even a very marginal hydropower project. The Commission does not read the Federal Power Act to compel such a result.”[16] Existing Information Existing cost of road infrastructure issues should be accessible by contacting adjacent towns.  Similar sized dams have been removed in Vermont in recent years and those costs are accessible through the VT DEC and NGOs. Nexus to Project Operations and Effects The Federal Power Act requires the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued. Given the marginal generation at this facility, it is in the best interest of the public to have a clear economic analysis of project impacts in order to weigh the benefits of this limited generation against impacts to the waterway and surrounding communities. Methodology Consistent with Accepted Practice The proposed study would be conducted by developing an environmental cost benefit analysis to consider habitat and societal costs and compare these costs and impacts to the benefit of electricity generation. This is an accepted methodology for this type of study. Level of Effort/Cost, and Why Alternative Studies will not suffice Cost for this study is estimated to be low.  Conducting this study at the outset of relicensing will help GMP to clarify whether continued investment in this facility are warranted. ~~~~~~~~ Requested Study 2:  Recreation Survey Conduct a study of the recreational boating, fishing, and birding opportunities at the dam, as well as upstream and downstream of the dam to determine if changes or improvements can be made to enhance recreational opportunities.  Methodology should include using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of the neighboring towns to assess recreation use and needs at the project.  The study should also include an assessment of use of ADA compliant fishing access from the parking lot and walking paths available in the project area. Goals and Objectives To determine if project operations impact recreational opportunities; To determine current use of project area for recreation; Assess if there are operational, structural or other modifications to the project which could improve fishing, birding, or other recreational opportunities. Resource Management Goals Enhancement of recreational opportunities associated with the presence and operation of the project, including the dam, reservoir and tailwater areas. Noted that requester is not an agency or Indian tribe. Public Interest Sections 4(e) and 10(a) of the Federal Power Act require the Commission to give equal consideration to all uses of the waterway on which a project is located, and what conditions should be placed on any license that may be issued.  As indicated in the FERC guidance for Recreation Development at Licensed Hydropower Projects, “On December 27, 1965, FERC issued Order No. 313, which amended the General Policy and Interpretations section of the Commission’s regulations (18 CFR Part 2) to ensure that the ultimate development of recreation resources at all projects is consistent with area recreational needs.  Specifically, 18 CFR Part 2 was amended to include § 2.7, which requires licensees to: (1) acquire lands to assure optimum development of the recreational resources afforded by the project; (2) develop suitable public recreational facilities with adequate public access, considering the needs of physically handicapped persons in the design of facilities and access; (3) coordinate efforts with other agencies in the development of recreation areas and facilities; (4) provide for planning, operation, and maintenance of these facilities; and (5) inform the public of opportunities for recreation at licensed projects.”[17] Existing Information GMP provided filing of Form 80 reports in 2003, 2009, and 2015. All hydropower facilities have been required to file a “Form 80” with FERC every 6 years, and all were on the same filing schedule. In 2019, this requirement was eliminated as a result of a rule change by the FERC. Therefore, there will not be any future Form 80 filings. The timing of this relicensing falls in line with what would have been a normal Form 80 reporting period, and this will be the only opportunity to consider recreational use over the course of the coming license period. Nexus to Project Operations and Effects Boaters, anglers, and other recreational users are impeded from access to their public trust waters by hydro-electric dams.  Changes in hydraulic conditions and habitat in the river impacts their ability to use the resources, affects catch rates and species for fish, and creates safety concerns. Methodology Consistent with Accepted Practice The proposed study would be conducted by using on-site visitor questionnaires and a mailed and/ or emailed questionnaire to residents of neighboring towns to collect feedback on perceptions of access to the area, use patterns and local needs.  This is an accepted methodology for this type of study. Level of Effort/Cost, and Why Alternative Studies will not suffice Cost for this study is estimated to be low.  This study would provide the current baseline regarding recreational use and would provide insight into the need for and type of potential enhancements. [1] Pre-Application Document. Taftsville Hydroelectric Project. (FERC No. 2490). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. August 2019. Page 4-11. [2] Ibid. Page 4-15. [3] Ibid. Page 5-3. [4] Ibid. Page 6-9 [5] The B-Corp Declaration of Interdependence. Accessed online at: https://bcorporation.net/about-b-corps [6] Green Mountain Power. 2018 Integrated Resource Plan. Accessed online at: https://greenmountainpower.com/regulatory/2018-integrated-resource-plan/. Feb. 6, 2020. Page 4-1. [7] Pre-Application Document. Taftsville Hydroelectric Project. (FERC No. 2490). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. August 2019. Page 6-21. [8] Ibid. Page 4-15. [9] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 14. [10] Pre-Application Document. Taftsville Hydroelectric Project. (FERC No. 2490). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. August 2019. Page 6-49. [11] Ibid. Page 6-57. [12] Ibid. Page 4-2. [13] Personal communication by Kathy Urffer with local residents.  Sept. 4, 2019. [14] Pre-Application Document. Taftsville Hydroelectric Project. (FERC No. 2490). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. August 2019. Page 6-72. [15] Pre-Application Document. Taftsville Hydroelectric Project. (FERC No. 2490). Prepared for Green Mountain Power Corporation. Prepared by Kleinschmidt, Pittsfield, ME. August 2019. Page 7-7. [16] Project Decommissioning at Relicensing; Policy Statement (December 14, 1994), 18 C.F.R. § 2.24, 60 Fed. Reg. 339 (January 4, 1995), FERC Stats. & Regs. Preambles 1991-1996 ¶ 31,011. [17] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 1.

Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: CRC comments on the Gilman hydroelectric project (P-2392) Pre-Application Document and Request to use the Traditional Licensing Process Dear Secretary Bose, The Connecticut River Watershed Council, Inc. (CRWC), now doing business as the Connecticut River Conservancy (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.  The interests and goals represented by CRWC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of a hydroelectric project in the Connecticut River watershed. CRC has reviewed the Gilman hydro-electric facility Pre-Application Document (PAD) dated May 30, 2019. Please consider our comments on the PAD and request to use the Traditional Licensing Process (TLP) below. 5.6 (d)(2) – Project location, facilities, and operations. Ampersand Gilman Hydro states, “The Project impoundment at normal pond condition extends approximately 2.9 miles upstream of the dam to a point just above the confluence of the Johns River; and to a lesser extent the Gilman Dam impoundment extends up to the Route 2 Bridge in Lancaster, NH, which is approximately 10 miles away from the Gilman Dam. At normal pond condition; the maximum surface area of the impoundment from the Gilman Dam to the Johns River is approximately 130 acres, at an elevation of 833.3 feet (USGS).”[1]  Yet, the “project area” indicated in Figure 3 extends only about 400 feet upstream of the dam.  CRC would appreciate some clarity on the definition of the project area / project boundary or a correction to Figure 3. 5.6 (d)(3)(iii) – Water resources. Figure 12 of the PAD is titled, “Historical recorded flows on the Sacandaga River (1966-2016)” and the minimum, mean and maximum flow in the Figure are not the same as indicated in the narrative, quoted as, “The maximum ever recorded flow at the site was 46,500 cfs on March 20, 1936, while the minimum was 115 cfs on October 3, 1937. The mean annual flow recorded at the site over the 1966-2016 period is 3,030 cfs for the period of record.”[2] Also, the historical average is listed as 1966 to 2016. Conversely, in the source information below Figures 12 and 13 it indicates the dates are from 1956 to 2016.  Please clarify the correct information for these Figures. The PAD indicates that, “The Connecticut River is Class B waters from Groveton to Gilman Dam and Class C from Gilman to the Lunenburg town line. The Project is in a water quality limited segment.”[3]  Does this refer to Vermont or New Hampshire?  Please provide the classification and water quality requirements for both states. 5.6 (d)(3)(iv) – Fish and aquatic resources. According to § 5.6 (d)(3)(iv) – Fish and aquatic resources, the PAD should provide, “A description of the fish and other aquatic resources, including invasive species, in the Project vicinity. This section must discuss the existing fish and macroinvertebrate communities…”[4] No macroinvertebrate information was provided in the PAD.  Please indicate if there has been any macroinvertebrate sampling in the project area. 5.6 (d)(3)(v) – Wildlife and botanical resources. The PAD states, “Waterfowls use the Connecticut River basin as a part of the North Atlantic Flyway. Most of the waterfowls occurring near the Project site would therefore be transient. Very little, if any, nesting and rearing occurs in the immediate Project area.”[5] Can you provide some reference or documentation to support this statement? 5.6 (d)(3)(viii) – Recreation and land use. The PAD states that, “There is little recreational use of the Connecticut River immediately above or below the Project.” [6] What evidence does AGH point to in order to support this statement?  The Connecticut River Paddlers Trail website indicates a boat launch above and below the project area in addition to the Gilman Dam Portage primitive campsite.  There is no mention of this campsite in the PAD. The PAD indicates improvements to a boat launch site, “The boat launch upgrade, consisted of leveling and surfacing the boat launch, enlarging the parking area, installing trash cans, relocating the entrance to the boat launch site, posting signs at the boat launch to limit its use to car-top and small trailer boats, and relocating the Dalton Fire Department’s dry hydrant.”[7]  While there is a picture of the launch, there is no locator map to indicate where this boat launch is. Does this refer to the John’s River Ramp? Request to Use the Traditional Licensing Process CRC requests that Ampersand Gilman use the Integrated Licensing Process (ILP).  The formal timeframe of the ILP allows for more comprehensive public participation in the process and allows for all stakeholders to be informed equally as the process unfolds. Additionally early scoping of studies creates more comprehensive sources of information before the final license application is submitted.  Given the fact that most of the other dams on the main stem of the Connecticut River have used the ILP and that the river should be considered as an ecosystem, CRC requests the use of the ILP.  The presence of dwarf wedgemussel in and above the project area also supports the use of the ILP to coordinate appropriate Federal coordination between FERC and the U.S. Fish and Wildlife Service. We appreciate the opportunity to provide comments.  I can be reached at kurffer@ctriver.org or (802) 258-0413. Sincerely, Kathy Urffer River Steward CC: Greg Cloutier, Ampersand Gilman Hydro Amit Pinjani, Ampersand Hydro, LLC Sayad Moudachirou, Ampersand Hydro, LLC Jeff Crocker, VT DEC Eric Davis, VT DEC Gregg Comstock, NH DES Pete McHugh, VT Fish and Wildlife Jud Kratzer, VT Fish and Wildlife Peter Emerson, VT Fish and Wildlife Dianne Timmins, NH Fish and Game Melissa Grader, USFWS [1] Pre-Application Document (PAD): Gilman Hydroelectric Project No. 2392. Ampersand Gilman Hydro LP. May 30, 2019. Page 7-8. [2] Ibid. Page 20. [3] Ibid. Page 24. [4] Ibid. Page 25. [5] Ibid. Page 39. [6] Ibid. Page 48. [7] Ibid. Page 48-49.

February 1, 2019 Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: CRC comments on the Newbury hydroelectric project (P-5261) Pre-Application Document Dear Secretary Bose, The Connecticut River Watershed Council, Inc. (CRWC), now doing business as the Connecticut River Conservancy (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.  The interests and goals represented by CRWC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of a hydroelectric project in the Connecticut River watershed. CRC has reviewed the Newbury hydro-electric facility Pre-Application Document (PAD) dated August 2018 and we attended the Joint Agency and Public meeting on December 4, 2018. Please consider our comments on the PAD below. 7.2.2 WATER RESOURCES The PAD sites water quality data based on macroinvertebrate studies from between 1992 and 2014.  The most recent data from 2014 is from two sites that are 2.1 and 4.4 miles upstream of the confluence with the Connecticut River.   As indicated in the PAD the project is located .9 miles upstream of the confluence.  The only macroinvertebrate data referenced from below the project was sampled in 1992.  Given this relative lack of information, CRC would request that the licensee further examine water quality upstream in the impoundment and downstream of the project including both water quality data and macroinvertebrate sampling. 7.2.3 AQUATIC RESOURCES CRC appreciates that Green Mountain Power continues to provide downstream fish passage.  As currently configured the downstream fish passage seems somewhat problematic in that there is a significant drop from the sluice to the pool below.  We hope the GMP will work with Vermont Agency of Natural Resources Fisheries biologists to reconfigure the downstream passage. 7.2.7 RARE, THREATENED, ENDANGERED, AND SPECIAL STATUS SPECIES Ten of the 17 native species of freshwater mussels in the state are listed as endangered or threatened.  While the reference sited by Kleinschmidt indicates that freshwater mussels “may occur” in the vicinity of the project, it is incumbent upon the licensee to make sure that our endangered species are protected. Given this, CRC would like to see some sort of freshwater mussel survey take place above and below the dam and in the bypass reach to assess the mussel population that may exist there.  This will also inform appropriate processes for drawdown for maintenance of the facility. 7.2.8 RECREATION AND LAND USE The PAD states, that because of the proximity to the Route 302 and an adjacent steep bank, the “project area is not particularly conducive to recreational activities.” Regardless of the limitations of the project area, the very nature of dams precludes certain types of recreation and access to our public waters and it is incumbent upon the licensee to have a clear understanding of recreational use and needed recreational amenities in proximity to the project area.  The FERC guidance for recreation at hydropower projects says, “Licensees must also keep in mind that the demand for recreation is not static; it is an evolving process. Periodic review of a project’s consistency with recreation demands is required to ensure that the public need for recreational opportunity is being met by existing and proposed facilities.”[1]  Given this, CRC supports some assessment of recreational opportunities in the project area to fully understand what recreation (bird watching, angling, etc.) might be taking place and whether public recreational use can be enhanced. 7.2.9 AESTHETIC RESOURCES The PAD indicates that “the 5 cfs year round [minimum] aesthetic flow…. is problematic in winter months as it turns to ice and prevents deflation of the pneumatic crest.”  While we understand that this problem needs to be explored, CRC contends that the minimum aesthetic flow be maintained, and if needed, increased to help solve the freezing issue. In addition to the comments provided above, please note that CRC supports comments submitted by the natural resource agencies, including but not limited to the Vermont Fish and Wildlife Department, Vermont Department of Environmental Conservation, and the U.S. Fish and Wildlife Service. We appreciate the opportunity to provide comments.  I can be reached at kurffer@ctriver.org or (802) 258-0413. Sincerely, Kathy Urffer River Steward CC: Jason Lisai, Green Mountain Power Corporation: Jason.Lisai@greenmountainpower.com John Greenan, Green Mountain Power Corporation: john.greenan@greenmountainpower.com Katie Sellers, Kleinschmidt Associates: Katie.sellers@kleinschmidtgroup.com [1] Recreation Development at Licensed Hydropower Projects: Division of Project Compliance and Administration, Office of Hydropower Licensing, Federal Energy Regulatory Commission, Washington DC. March 1996. Page 14.

December 22, 2014 Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: CRC comments on the Great Falls hydroelectric project FERC Project NO. 2839 Preliminary Application Document. Dear Secretary Bose: Statement of Interest The Connecticut River Watershed Council is a nonprofit membership 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 interests and goals represented by CRC include, but are not limited to, improving water quality; enhancing habitat for fish and other aquatic biota; safeguarding and improving wildlife habitat; protecting threatened and endangered species; protecting wetlands; preserving undeveloped shore lands; enhancing public recreation and promoting recreational safety; protecting aesthetic values; protecting archeological, cultural, and historical resources; fostering sustainable economic development; and maintaining the potential energy benefits of a hydroelectric project in the Connecticut River watershed. Following are the comments from CRC on the Great Falls hydroelectric project FERC Project NO. 2839 Preliminary Application Document. 4.1 Existing Project Facilities Although, not immediately part of this section, while on site it was clear that there is a lot of deferred maintenance that needs to be undertaken at the facility. The turbine and supporting equipment seemed to be in fine shape albeit old but the exterior of buildings and the dam and canal structure are in need of significant repair based on observation. 4.4 Existing Project Operations The PAD says that the operator adjusts turbine settings to ensure run of river but the operator is not present at all times. The approach used by the operator is to eye ball the reservoir level and adjust from that observation. Some approach of automatic monitoring and adjustment should be a license condition to assure run of river operations 24/7. Section 5.2.10 Water Quality Monitoring The PAD describes periodic but ad hoc water quality monitoring in the Passumpsic River Watershed, but no water quality data exists within the project area. At a minimum, dissolved oxygen and temperature should be evaluated for compliance with Vermont Water Quality Standards. 4.4.2 Low and High water operations While we were on site we were told that the bypass gate had not been used in a “while.” It was not made clear how long is a while, leaving one with the question of how is the minimum flow maintained during low flow periods (August – October according to the flow duration curves) when water does not flow over the dam. 5.3.1.1 Fish Species and Habitats There has not been a full fish assemblage study done at the site ever according to the PAD and on site discussion. Some species have been studied but it is unknown if some species are even present. Once the species are established it is important to note that resident species migrate from spawning to rearing habitats up and down river. Resident salmonids actively migrate during the spring and fall. Downstream passage for resident salmonids would allow fish to seek the best available habitat and food resources. Resident fish should be able return to tributaries upstream of the project to spawn. 5.7.3 Recreation Access to the river for fishing, swimming or canoeing is difficult since the gate at the top of the hill is closed unless there is a LED staff person on site. A closed gate makes access difficult and the warning sign on the gate is discouraging of using the property to gain access to the river. Using the opportunity of an open gate because staff is on site with a vehicle is unsure since a recreational user would not know for sure when the staff person will leave and lock them behind the gate. CRC thanks FERC for the opportunity to comment on the Great Falls hydroelectric project. Sincerely David Deen Upper Valley River Steward