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.