BELLOWS FALLS — The Federal Energy Regulatory Commission (FERC) has filed a notice of intent and pre-application document for five hydroelectric projects on the Connecticut River, including ones in Bellows Falls and Vernon, beginning the first phase of a regulatory process that will reach its final conclusions in 2018.
The filing will bring to the table a number of regional, state, and federal government agencies, as well as an array of nonprofit conservation, wildlife, and advocacy groups, to weigh in on the process.
The last dam relicensing - a 5{1/2}-year process - occurred around 40 years ago, said Connecticut River Watershed Council (CRWC) river steward Andrea Donlon.
According to Donlon, hydropower facilities have to undergo an integrated licensing process (ILP) through the FERC every 30-50 years, a complex process that energy companies and environmental activists alike will track with what she characterized as “a mind-numbing flow chart.”
Donlon, 44, said she was “just being born” when Northfield Mountain Pumped Storage Hydroelectric, a massive facility on the Connecticut River, was under construction. The facility began generating electricity in 1972.
“All these licenses date from either late '60s or early 70s,” Donlon said.
The organization existed at the time, she said, but over the past four decades, issues have come to the fore that no one considered during the last licensing round.
The CRWC, based in Greenfield, Mass., has assumed responsibility of the 11,000-square-mile, four-state waterway. Its work is centered around protection of the “water - the river, its tributaries, lakes, fish; and the land, plants, and creatures connected to that water,” according to the nonprofit's website.
It sees itself as the hub of a wheel connected to many spokes: the many entities whom CRWC staff hope to bring to the table with data and information.
The CRWC hopes to coalesce this data and bring it to the FERC for consideration at various stages of the long regulatory process. FERC is supposed to be the “balancer of environmental and power generation conflicts,” said river steward David Deen of Putney.
Environmental site reviews in October provided those with a stake in the projects' pending relicensing an opportunity to view the hydroelectric facilities and surrounding areas.
These non-governmental organizations (NGOs) are beginning to seek public input as well as gather scientific data.
Some of the two states' NGOs wanting in on the process are the Connecticut River Watershed Council, Appalachian Mountain Club, Connecticut River Joint Commissions, Trout Unlimited, White River Partnership, Southeast Vermont Watersheds Association, Black River Action Team, Conservation Law Foundation, the Nature Conservancy, New England FLOW, and the Sierra Club.
In Vermont and New Hampshire alone the Windham Regional Planning and Development Commission, Southern Windsor County Regional Planning Commission, Upper Valley Lake Sunapee Regional Planning Commission, and the Southwest Region Planning Commission are involved in the process.
Other government agencies involved in the four-state (Vermont, New Hampshire, Massachusetts, and Connecticut) process are the Vermont Fish and Wildlife Department, Vermont Department of Environmental Conservation, New Hampshire Fish and Game Department, New Hampshire Department of Environmental Services, Massachusetts Department of Fish and Game, and Massachusetts Department of Environmental Protection.
On the federal level, the U.S. Fish and Wildlife Service and, potentially, the U.S. Environmental Protection Agency will participate in the process.
The National Oceanic and Atmospheric Administration's National Marine Fisheries Service will become involved in the Turners Falls relicensing based on the issue of the endangered shortnose sturgeon, whose spawning grounds are a mile away from the Turners Falls Dam.
Organizations work together
Donlon is responsible for oversight of the Northfield Mountain and Turners Falls Hydroelectric projects in Massachusetts, both owned by First Light Power Resources. She works closely with Deen, her counterpart who is responsible for oversight of the Wilder Dam Hydroelectric in Wilder, Bellows Falls Hydroelectric, and Vernon Dam Hydroelectric, all TransCanada properties.
“David and I are both trying to organize the NGOs and individuals who are interested in relicensing and have started to meet and go over what our objectives are in the relicensing process,” Donlon said, calling the process “a collaboration of entities.”
“Resource agencies and NGOs recognize that we will have a more effective voice if we figure out what our interests are and try to have a well-thought-out list of objectives,” she said.
Donlon predicted “a long series of negotiations because the power companies certainly keep economics in mind, and they know that they will have to [be] more protective of the river” now.
Collaboration between entities that have desires for protecting river and species is key, “in order to impact the ability to float ideas,” Donlon emphasized.
Deen said his relicensing experience with the 15 Mile Falls Project in Grafton County, N.H. and Caledonia County, Vt., taught him “that NGOs have different individual issues, but the only way to move those individual issues is to do it as a single voice.”
“We are trying to get the discussion started about what our objectives are for when this 5{1/2}-year effort is over,” Deen continued. “If we can reach some level of agreement now, we know where we are headed so that we don't get lost during those 5{1/2} years.”
Environmental concerns
CRWC staff cite potential issues with the upper-river dams in Vernon, Bellows Falls, and Wilder and their effect on the Connecticut River: shore erosion, invasive species, recreation, reach, minimum flow, water temperature, and dissolved-oxygen levels, which have not been checked in 40 years.
Another concern is draw down, the amount of water removed from a reservoir to generate electricity. If a facility removes too much water during spawning, the process can expose the nests where fish and other non-mobile aquatic species have laid their eggs. The eggs die.
Donlon and Dean are also eyeing ramping rates: how fast the water level below a dam rises or falls at the start and end of a generating period.
If the water rises too fast, aquatic organisms can be swept away. Once the water is high, fish and other organisms begin to explore the newly wetted areas; if the water level drops too fast, they can be stranded and die.
One of the issues of concern at the Bellows Falls facility: “There is not really any water in the riverbed next to the canal,” Donlon explained. “They are not required to put water there. People will be looking at whether they should.”
“The fact that there is no minimum flow in the bypass reach [canal] reflects the state of environmental concern at the time the license was issued in 1979,” Deen said.
“I know that FERC will be asked to require some level of minimum flow so there is a wetted and livable area downstream of the dam. I don't think TransCanada will be happy about any such request because spilled water is not able to generate electricity,” he continued.
A complex system
For four years, the Nature Conservancy has been working with 70 partners to develop a flow model of the whole Connecticut River watershed.
The project will let “all parties involved have the knowledge, opportunity and say in how the watershed could be managed,” said Emily Boedecker, deputy state director of the worldwide conservation organization's Vermont chapter in Montpelier.
“We are talking about a complex system,” Boedecker continued. “We bring a level of science into the relicensing [through an understanding of] the way a river influences all natural communities within a flow.”
“We're looking at the best possible outcome for people and nature,” Boedecker said.
“We've all had a real wakeup call during [Tropical Storm] Irene that it's important to understand how an entire river system works,” she said.
Boedecker described the relicensing as a “once-in-a-lifetime chance or ability to influence the river for the next 50 years.”
“We want the best available information, and we need to work collaboratively,” she said.