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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