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On this LEARN MORE page scroll down to find:

  • MA Water Quality Certificate process graphic
  • Key Players/Agencies 
  • Pumped Storage and its Role in the Grid
  • Links to Other Information Sources and Documents
  • Acronyms 

Certificate process graphic draft3 PDF


FirstLight Power

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.



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.



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 MA DEP, is under the Energy & Environmental Affairs (EEA) umbrella.  Its purpose includes requiring state agencies, such as the MA DEP, 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.


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PUMPED STORAGE AND ITS ROLE IN THE GRIDTF dam sunny day 2 test resized

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 relicensing.)

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".


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.




The Connecticut River Conservancy hydro pages

Karl Meyer's Blog

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


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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

GG - Greening Greenfield

MEPA - Massachusetts Environmental Policy Act

REA - Ready for Environmental Analysis

TF - Turners Falls

WQC - Water Quality Certificate


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John Muir


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