On this LEARN MORE page scroll down to find:
- Key Players/Agencies
- MA input into Federal (FERC) license
- MA Water Quality Certificate process graphic
- Pumped Storage and its Role in the Grid
- Links to Other Information Sources and Documents
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KEY PLAYERS / AGENCIES
The owner/operator of all the hydro facilities we are watching. Despite the impression one could receive from their website, their parent company is Canadian. These facilities are estimated to bring in revenue of up to $140 million/year as recently as 2019. They have applied to the FERC for a federal power license to continue operations of existing facilities.
At the federal level, the Federal Energy Regulatory Commission (FERC*) is where most efforts have focused to date. Karl Meyer's blog and his letters in the Greenfield Recorder have explained how to look up information about their records on this project, and how to add your own comments to the public record. We have gathered this information about how to contact FERC here.
At the state level, the Executive Office of Energy and Environmental Affairs, EEA, houses a number of state agencies, including the Department of Environmental Protection. Under Section 401 of the federal Clean Water Act "a federal agency may not issue a permit or license to conduct any activity that may result in any discharge into waters of the United States unless a Section 401 water quality certification (WQC) is issued, or certification is waived. States and authorized tribes where the discharge would originate are generally responsible for issuing water quality certifications." In Massachusetts, the DEP is the entity that will issue the WQC.
We know this is confusing. An analogy for how to think about this relationship is in this MyTurn.
Massachusetts legislative delegation for CT River communities
Our State Senators and Representatives are currently meeting weekly with EEA to track progress and pass on our comments and concerns. Thank them for their hard work! They have shared with us: their August 2020 joint delegation letter to EEA/DEP & the Governor, about the re-licensing, and their Shared Concerns document, currently the March 9, 2022 version, where they list issues they are tracking (note this version was before the new Fish and Flow AIP was issued).
There is a potential parallel state track under which the projects might be reviewed, which is the Massachusetts Environmental Policy Act, or MEPA. The MEPA Office like the MassDEP, is under the Energy & Environmental Affairs (EEA) umbrella. Its purpose includes requiring state agencies, such as the MassDEP, to study the environmental consequences of their actions. See MEPA purpose & intent.
On July 6, 2012, FirstLight applied to the MEPA Office for an "Advisory Opinion" about whether "the upcoming licensing of the Northfield Mountain and Turners Falls Projects by the Federal Energy Regulatory Commission (FERC) subjects either project to" MEPA jurisdiction. That document, though old, is very helpful in understanding the exact language of the pieces of the projects, and the originally projected timeline. In it, FirstLight essentially argues that they will not be making enough changes to their existing practices allowed under the then-current license to make them subject to MEPA review. Or if they do make changes that major, it will only be because the FERC makes them, so MEPA shouldn't get involved until after FERC checks in. A week later, the MEPA Office agreed, granting them the Advisory Opinion that MEPA review was not necessary.
However, that decision is currently under review and could be revised by the current MEPA Director, who has not stated definitively yet whether or not they agree with this prior opinion, as of January 4, 2022.
Some of us feel that letters to the MEPA Office, encouraging their immediate involvement could be helpful. MEPA has a strong interest in having parties explore alternatives, and with the climate crisis and the potential 40-50-year license, we think some things will change during that time frame.
Ready to TAKE ACTION? Go Here
MA INPUT INTO FEDERAL (FERC) LICENSE
FirstLight has already submitted its initial application to the FERC. (Executive Summary of December 2020 application.) FERC has asked for additional information and has asked clarifying questions, and we are able to submit comments to the FERC right now. Also, FirstLight has requested that FERC not proceed yet with issuing a "Ready for Environmental Analysis" determination, so that Settlement Talks could take place. Although FERC has not formally responded to that request, the Settlement Talks have been going on for some time, and will probably conclude some time in 2022.
What are Settlement Talks?
Interested Parties (FirstLight, federal and state agencies, non-profits, local towns) who were willing to sign a non-disclosure agreement have been invited into "the room where it happens" to try to hash out details of what any new license might look like. Greening Greenfield is not involved in these talks. These talks are to negotiate detailed terms regarding flow and erosion controls; fish protections, habitat, and migration patterns; protections for other aquatic life and riparian habitat; recreational provisions; and probably more. They are private talks in order to allow the players the space and ability to understand each other's positions. We don't know those details, and Greening Greenfield is not the right entity to ask.
It is the goal of these Settlement Talks to improve FirstLight's hydro applications. Although in theory they could result in a signed agreement, we have been advised that MassDEP does not plan to sign anything before the public process has even begun.
MassDEP is not a signatory, as stated above. Nor is the FERC. The parties who are, now have their hands somewhat tied. Those of us who are not, may try to make improvements. A downside of MassDEP not participating in Settlement Talks is that they have not been able to push for some studies that are needed to make the final document well-informed. Our congressional delegation is expected to relay some of this to DEP.
The Public Process
When the Settlement Talks have done as much as they can, FirstLight will make whatever changes they want to their application (Amended Final License Application, AFLA), and when the FERC is ready, FERC will issue a "notice of acceptance and Ready for Environmental Analysis" (REA). At that point, FirstLight will file an application with MassDEP for a Water Quality Certificate (WQC) under Section 401 of the federal Clean Water Act, sometimes called "a 401".
As mentioned before, it would be legal for MassDEP to throw one notice in the paper, accept written comments on the 401 for 20 days, and move on. We do not want this to be any kind of rubber stamp process. Work over the last few years is making progress toward enabling MA to use its power. This is where we all come in.
Ready to TAKE ACTION? Go Here
PUMPED STORAGE AND ITS ROLE IN THE GRID
What is Pumped Storage?
A pumped storage facility is a means of storing energy in the form of water that has been pumped to an upper reservoir. This water can be released when needed to run turbines to generate electricity. This much is good, because it makes clean, hydroelectric power that can be generated when needed, acting like a giant battery.
However, all energy storage systems lose energy during the process, and pumped storage facilities are no exception. They take more energy to pump water to the top than they generate when the water comes back down. About 20 - 30% of the energy is lost.
Although that sounds intuitively like a bad idea, there are times when this storage capacity is worth it (more below). They pump water up when electric demand is low (mostly at night when electric prices are cheaper), and let it out when there is peak demand (and prices are higher, like a summer afternoon when the whole world wants to run air conditioners).
How is the Northfield Mountain Pumped Storage Facility different than most?
All pumped storage systems need an upper and a lower reservoir. Northfield Mountain has an upper reservoir, where the top of the mountain was dug out to make a lake. However, instead of a human-made lake for the lower reservoir, Northfield Mountain / FirstLight uses the Connecticut River that has been backed up for miles by the Turners Falls Dam. This is called the "impoundment area" and it goes upstream from the dam, through Barton Cove, all the way to the dam at the Vernon VT hydro project. (Great River Hydro owns that facility, also up for FERC re-licensing.)
So why / how is that a problem?
Greening Greenfield believes the issues with the Northfield Mountain Pumped Storage facility fall into 2 basic categories:
- Fossil Fuel Used: The fact that the energy used to pump water up comes from the MA utility grid, the majority of which is generated from fossil fuels at this time. Thus the produced hydro energy should not be claimed to be "clean, renewable energy".
- Environmental Impact on the River: There are numerous environmental impacts that result from using the Connecticut River as a lower reservoir. These include issues of flow - too much and too little - causing erosion and allowing a nearly dry riverbed; and the effects on aquatic life of all sorts, including, but certainly not limited to adult fish.
Greening Greenfield will continue to advocate for changes to the operation that halt this ongoing destruction and repair damage already done. GG also supports improved recreational opportunities, and increased sensitivity to the cultural history of the area and the past and current relationships of native populations with the river.
So why would anybody want Northfield Mountain at all, besides the owners to make money?
It is true that Northfield Mountain facility was originally built to complement the Vermont Yankee nuclear power plant operation. Since nuclear facilities do not start and stop their operations, but keep running and generating electricity even when the demand is low, the excess power at night was used to pump water to the top of Northfield Mountain. Vermont Yankee is now closed.
HOWEVER, the transition away from fossil fuels to renewable sources such as solar and wind energy requires energy storage. Wind doesn't always blow at the same rate, and solar power varies depending on time of day, year and weather conditions. But people use electricity regardless of those facts.
Storage could be from batteries, but existing batteries use toxic materials and healthier possibilities are not available at scale yet. Northfield Mountain can store a LOT of energy. FirstLight's website says it is the largest energy storage facility in New England. Several of the offshore wind facilities off Cape Cod that are under construction or under consideration have partnered with FirstLight. They have to show the ability to produce consistently for the grid. Without Northfield Mountain, we probably won't be able to get the wind power we need to transition away from fossil fuels. That doesn't mean we want the Northfield Mountain facility operating in the way it has been.
If we don't have storage such as this, then we'll need more fossil fuel peaker plants like this gas one proposed to be built, brand new, in Peabody, MA. (5.33 minute video).
One other side note: Northfield Mountain can make money by NOT making electricity, too. They get paid to have the ability (a full upper reservoir) to generate electricity in case more traditional sources run into trouble from storms, equipment failure, etc. FirstLight relies on Northfield Mountain to restart the electric grid if the grid goes down. This is called a "black start".
$$ TWO OTHER NOTES ON MONEY $$
1. Some of us are requesting that if MassDEP grants a WQC, they make one of the Conditions a requirement that FirstLight set up a decommissioning fund. Some day – sooner or later – the day will come when the dam or generating stations or pumped storage facility isn't cost-effective. While it is, they are making money and are going to want to run it. When it is not, by definition, it will not be a good time to convince the owners to put forth the large amounts of money to remove structures and restore a free-flowing river. Require the money to be set aside now. When it is de-licensed, there is much less ability for government to keep an owner from walking away and leaving us holding the bag.
2. Some of us are also requesting that while the facilities are operating, under the principle that the responsible party should pay, that FirstLight be required to pay MassDEP an annual fee sufficient to cover MassDEP's costs of inspection of the facilities and enforcement of any issues that may arise. An understaffed, publicly-financed agency cannot keep up with all of its oversight functions while only utilizing taxpayer dollars. Private, for-profit facilities should not be allowed to overwhelm staff who have other duties beyond this oversight.
Greening Greenfield is currently focusing on the PROCESS of relicensing.
Consult other sources for more information about the technical aspects of river flow, erosion, fish habitat, recreation, and more.
LINKS TO OTHER INFORMATION SOURCES AND DOCUMENTS
If you can make time for only one webinar describing the whole interconnected River issues and licensing process, we highly recommend CRC's one-hour webinar below. PLEASE NOTE: Timelines have changed, and ongoing settlement negotiations may result in different proposed measures than those submitted in December 2020 in the Amended Final License Application that were summarized in the video. LiveStream Season 2, Episode 2, Hydropower in MA
Older documents are at Northfield-Relicensing.com (Good luck)
(Don't forget that this is what's currently public, but there will surely be amendments made as a result of the Settlement Talks.)
AIP - Agreement in Principle
AFLA - Amended Final License Application
CRC - Connecticut River Conservancy
DEP or MassDEP - Massachusetts Department of Environmental Protection
EEA / EOEEA - Executive Office of Energy and Environmental Affairs
EIS - Environmental Impact Statement
FERC - Federal Energy Regulatory Commission
FL - FirstLight Power
FLA - Final License Application
FPA - Federal Power Act
GG - Greening Greenfield
ISO-NE - Independent Systems Operator - New England
MEPA - Massachusetts Environmental Policy Act
NRF - Naturally Routed Flow
PM&E - Protection, Mitigation, & Enhancement
REA - Ready for Environmental Analysis
TF - Turners Falls
USGS - United States Geological Survey (usually used in FirstLight documents for USGS "gage" or "gage flow")
WQC - Water Quality Certificate
Ready to TAKE ACTION? Go Here
"When we try to pick out anything by itself, we find it hitched to everything else in the Universe."