Photo courtesy of Al Braden
Hydropower Relicensing
5 hydroelectric facilities on the Connecticut River are in the process of relicensing, and the public comment period for FERC (the Federal Energy Regulatory Commission) has closed on May 22nd, 2024. This process is not complete until new licenses are in place, which means there is still more to do. We're moving on to the next phase of the relicensing - state level 401 water quality certifications!
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Connecticut River Conservancy has been involved in the relicensing process for over a decade with the aim of getting the best possible outcome for our rivers, wildlife, and communities. Read on for all the details.
Hydroelectric facilities use a public trust resource – your river – to produce power.
In exchange for this privilege and to mitigate for impacts of the dams, FERC (the Federal Energy Regulatory Commission) requires that hydropower operators provide direct benefits to the public and be protective of the ecological health of the river. The license serves as a public contract that we revisit periodically to examine the impact of the facility on our public trust resource.
Sign Up for Hydro Email Updates​
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We have a hydropower-specific email list to notify you as milestones happen or new resources become available. If you're not already on it, take a moment to sign up here and then return to this page.
Five Hydro Facilities Now!
The heart of the Connecticut River’s next 50 years.
Since late 2012, five hydroelectric facilities in the heart of the Connecticut River have been in the process of renewing their operating licenses in a process known as relicensing. The licenses for two facilities in northern MA and three dams in southern VT and NH will endure for the next 30-50 years and impact more than 175 miles of the Connecticut River. It’s critical that we all speak up NOW in this once-in-a-lifetime opportunity to influence these operating licenses.
The three dams at Wilder, Bellows Falls and Vernon in New Hampshire and Vermont are owned by Great River Hydro (formerly TransCanada), a subsidiary of Hydro-Québec whose sole shareholder is the Government of Quebec. The two Massachusetts facilities, Turners Falls Dam and Northfield Mountain Pump Storage Project, are now separate LLCs under FirstLight Power Services LLC, owned by PSP Investments, one of Canada’s largest pension investment managers.
The Federal Energy Regulatory Commission (FERC) last issued licenses for these facilities over forty years ago and all five licenses initially expired
in April, 2018.
Comments by local communities, the states, individuals, and other stakeholders provide a rare opportunity to improve the health of our river. The current relicensing process for these five hydropower facilities will dramatically affect the health of the river and watershed for generations to come. Anyone with thoughts or concerns can comment at any time and those comments become part of the official record for that project. You can see instructions below to formally submit comments to the Federal Energy Regulatory Commission (FERC), however the deadline for this has now passed on May 22nd, 2024.
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CRC River Stewards Kathy Urffer (VT), Kate Buckman (NH), and Nina Gordon-Kirsch (MA) are participating in all the formal proceedings related to this relicensing effort. They review reports, prepare CRC comments, and are working to engage the public in the process. They are glad to answer any of your questions or speak to your group about the relicensing.
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Both Great River Hydro and FirstLight submitted amended final license applications (AFLAs) in December 2020. And on February 22nd, 2024, FERC released a public notice indicating that the Turner’s Falls, Northfield Mountain, Vernon, Bellows Falls, and Wilder hydroelectric project applications have been accepted and are ready for environmental analysis. Link on the project name to see their respective notice. This opened a 60-day comment period through April 22nd, which was then further extended to May 22nd. It also starts the Clean Water Act Section 401 water quality certification clock and gives the companies 60 days to file an application with the state to apply for a water quality certificate.
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Next Steps:
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This process is not complete until new licenses are in place, which means there is still more to do. We're moving on to the next phase of the relicensing - state level 401 water quality certifications! Read more about the 401 Water Quality Certification here.
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A Public Trust Resource
Refers to the public trust doctrine that recognizes the public right to many natural resources including "the air, running water, the sea and it's shore." The doctrine requires a state to hold in trust designated resources for the benefit of the people, regardless or private property ownership.
CRC’s desired outcomes and priority areas where we are actively advocating for change include:
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Safe, timely, and effective upstream and downstream fish passage
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Operational changes at the dams to minimize both upstream and downstream surface water fluctuations to reduce bank erosion and impacts to rare and threatened species
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Healthy aquatic habitat for river critters
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Seasonally appropriate minimum flows in the river channel
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Ecologically compatible and accessible recreational facilities
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Protection and interpretation of historic and archeological resources
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Equal consideration of Indigenous People’s traditional cultural properties
Hydro Relicensing and the 401 Water Quality Certification:
States & Federal Have a Parallel Process
All hydroelectric facilities must also apply for and receive within 12 months a Water Quality Certification (WQC) from the state that that facility is located in.
Anything the states require in this certificate will automatically be included in the final FERC license.
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Great River Hydro and FirstLight applied for their 401 WQ Certifications in April 2024, so the states will use the next year to conduct public information sessions, issue a draft WQ Certification, and then will hold a formal public comment period to receive comments on the draft.
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You can learn more about this process in each state here:
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CRC has also made dedicated brochures for each state, which you can find here for Vermont, New Hampshire, and Massachusetts.
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Public comments submitted to the state during this process can have a positive impact on the long-term benefits for the river!
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CRC's comments on the application for MA 401 WQC (submitted on 6/3/24) can be found here.
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We have a hydropower-specific email list to notify you as milestones happen or new resources become available. If you're not already on it, take a moment to sign up here.
401 Water Quality Certification
This refers to the Section 401 of the Clean Water Act (CWA) in which a federal agency (in this case the Federal Energy Regulatory Commission - FERC) may not issue a license to hydro facilities for a discharge from the hydro plant into public waters unless the state or authorized tribe issues a Section 401 water quality certification verifying that the discharge will comply with existing water quality requirements, or waives the certification requirement.
The LiveStream below with CRC's Director of Policy and Advocacy, Kathy Urffer, was recorded prior to the now open comment period, the Fish Passage Settlement Agreement, and the sale of Great River Hydro to HydroQuebec, however the key details remain accurate and it describes the proposed operational change agreed to in 2020.
Full License Applications submitted to the Federal Energy Regulatory Commission (FERC):
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Great River Hydro: Open “80-Amended-Final-License-Applications-AFLA” folder. Most information is in “Exhibit E.” CRC was concerned with information lacking in the AFLA so we submitted comments to FERC in January 2021.
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FirstLight: Executive Summary Table ES-1 shows inflated cost amounts that include a hidden expected energy revenue loss, whereas Exhibit D for the two facilities show lower costs. Otherwise, the Executive Summary is a concise summary of what the application package includes. CRC was concerned with information lacking in the AFLA so we submitted comments to FERC in January 2021.
Stay informed! Subscribe to the FERC docket using the project number (eg. Northfield Mountain Pump Station is P-2485) so you receive updates whenever comments are filed, or FERC issues a determination.
Research! Search the FERC eLibrary using the project number (eg. Northfield Mountain Pump Station is P-2485) for previously submitted comments, issuance, and documents.
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CRC and Appalachian Mountain Club’s recreation recommendations submitted to FERC.
Recordings: CRC has been holding a number of virtual events to share information and answer questions. Visit CRC’s YouTube channel to see all past recordings.
Background: Hydropower in the Connecticut River Watershed
River
A large natural stream of water flowing into a channel.
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Dams undo many of the very features that distinguish a river ecosystem, such as:
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Variations in flow rate, river bottom sediments, and movement of soil and rocks.
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Migratory fish runs that bring economic opportunity, sustenance, and nutrients inland.
All power generation has impacts on the environment. Hydropower has large impacts on a river. The Connecticut River watershed has dozens of active hydropower dams and two pumped storage projects that are regulated by the Federal Energy Regulatory Commission (FERC). Their individual and cumulative impacts to our rivers are massive.
The Connecticut River is one of the most extensively dammed rivers in the nation. CRC has advocated for removing dams in our watershed that no longer serve a purpose. Thus far, we have aimed to minimize the impacts of operating hydropower dams rather than removal. However, we evaluate each facility on a case by case basis.
Dams on the main stem of the Connecticut River alter flows and water levels on more than 324 miles of the river’s 410 mile total length, from the headwaters region all the way down to Holyoke Dam 86 miles upstream from Long Island Sound. They block the movement of migratory and resident fish and other aquatic animals. The dams turn New England’s longest river into a series of warm water reservoirs. They impede natural river flows and cause the accumulation of sediment behind the dams, burying important river bottom habitat. Paddlers have to portage around the dams to continue traveling on the river. Historical uses and artifacts along the river are changed or submerged. It is important to remember the companies aren’t just managing their facilities, nor merely impacting just the water “at” the dams or nearby habitat. Through their presence and operations, hydro facilities manage the whole river.
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Most hydropower facilities have a Federal Energy Regulatory Commission (FERC) license with a term of 40-50 years. When these operating licenses come up for renewal during the relicensing process, it is our once-in-a-lifetime opportunity to change how these hydro facilities affect our rivers. With such lengthy terms, the licenses lock-in impacts to the river for generations to come. Therefore, advocating for the river during relicensing is critical! It is a chance to improve access, habitat, and the river’s overall health as an ecosystem. Working with state and federal agencies, municipalities, nonprofits, and local residents, CRC examines the impacts of each facility’s operations on our local waterways and submits formal comments to ensure a balance between hydro operations and protection of the river.
It is important for the public and municipalities to submit comments to make sure that local concerns and desires are voiced during the relicensing process and are responded to as part of the new license. The Federal Energy Regulatory Commission (FERC) is interested in maintaining these energy facilities and they are in constant communication with the companies in the course of their relationship as regulators. FERC needs to hear from the public in order to understand and balance local ecological and public access concerns with power production
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To submit comments on a particular dam or hydro project you first need to know the Federal Energy Regulatory Commission (FERC) project number. There are many hydroelectric projects in the watershed. Click on the project in the map below to get more details. Comments can be in response to a particular filing or can be a complaint about project operations, safety, or recreation issues in the project areas. You can see comment examples and a way to see all submitted comments here.
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Project numbers for the five large hydro facilities on the main stem Connecticut River undergoing relicensing now:
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Wilder Dam, P-1892-030
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Bellows Falls Dam, P-1855-050
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Vernon Dam, P-1904-078
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Northfield Mountain Pumped Storage Project, P-2485-071
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Turners Falls Dam, P-1889-085
There are two options for submitting comments to FERC:
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For a comment up to 6,000 characters, you can submit an e-comment. This DOES NOT require creating an account with FERC.
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For a longer comment, or to post a comment on your letterhead, you will need to eRegister with FERC to create an account, and then eFile.
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Please see our Comment Guide for extended comment details. Comments submitted so far can also be found here.
Tributary Facilities Undergoing Relicensing
P-10934 Sugar River II; Newport, NH on the Sugar River
P-9648 Fellows Dam, P-9649 Lovejoy, P-9650 Gilman and P-7888 Comtu Fall; Springfield, VT on the Black River
P-8615 Fiske Mill; Hinsdale, NH on the Ashuelot River
P-7887 Minnewawa Brook; Marlborough, NH on the Ashuelot River
P-7883 Weston; Groveton, NH on the Upper Ammonoosuc River
P-2490 Taftsville; Woodstock, VT on the Ottauquechee River
P-2489 Cavendish; Cavendish, VT on the Black River
P-2816 North Hartland; Hartland, VT on the Ottauquechee River
P-2839 Great Falls; Lyndonville, VT on the Passumpsic River
P-5261 Newbury; Newbury, VT on the Wells River
P-2392 Gilman; Lunenberg, VT and Dalton, NH on the Connecticut River
P-2669 Bear Swamp; Rowe and Florida, MA on the Deerfield River
For questions about hydropower relicensing, contact the following:
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Kathy Urffer for Vermont: kurffer at ctriver.org | 802-258-0413
Kate Buckman for New Hampshire: kbuckman at ctriver.org | 603-931-2448
Nina Gordon-Kirsch for Massachusetts: ngordonkirsch at ctriver.org | 413-772-2020 ext. 216