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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