If you are new to these issues or need more background information,

please start here instead.

 

RELICENSING PROCESS

Although the Federal Energy Regulatory Commission (FERC*) is the overarching licensing authority for FirstLight's application for a Federal Power Act (hydro) license, FirstLight also must apply to Massachusetts for a Water Quality Certificate (WQC) (as authorized by Section 401 of the federal Clean Water Act) that will then be incorporated into the license issued by the FERC.

This means that whatever "conditions" MA puts in the WQC WILL be included in the FERC license, and FirstLight MUST adhere to them. 

This is our best opportunity to make a real difference.

PRIOR ACTION

In January 2022, Greening Greenfield asked you to write to the Secretary of the EEA* (Executive Office of Energy and Environmental Affairs) requesting that MassDEP (one of the 6 Departments under EEA, plus 14 other entities):

  • hold robust public hearings on FirstLight's application for a Water Quality Certificate. 

They have agreed!  Good work everyone!  See DEP's new web page.

  • EEA/DEP host a recorded public information session prior to the hearings, to explain the process to all who are interested;

They have at least partially agreed.  There will be such a session.  We don't know if it will be recorded.  See DEP's new web page.

  • EEA create and update a dedicated website to help the public understand and track the progress;

They have agreed!  This is excellent news.  See DEP's new web page.

  • EEA widely advertise these events and resources; and

Remains to be seen.  We only found out that the new DEP web page existed because our legislative delegation was kind enough to tell us. And we don't know what plans DEP has for advertising the public meetings, but they have NOT yet set up a way to be added to a mailing list. We think DEP can do better.

  • That MEPA be fully involved in the relicensing process, especially as the original license pre-dates the entire 401 process.

We have heard nothing since June, so can only guess no decision has been made?

After FirstLight applies for the WQC, which could be any time now, it will be time to tell EEA / MassDEP what we want to see in that certificate, and ways in which we support or disagree with the provisions proposed in FirstLight's application.  But TODAY, our simple ask is to make sure we will all have the opportunity to make those comments about the river and the license.  In addition to written comments, we feel public hearings are critical to having our voices heard, and this is a new opportunity to do that.  The FORMAL PUBLIC COMMENT PERIOD will still probably only be 20 days, per regulation (possibly part of the Trump era changes in the process of being fixed, but not final until spring 2023).


CURRENT ACTION

  • Thank everyone for what they've done so far - this includes our legislators, but especially DEP;
  • Ask DEP to start compiling an email list through which to notify folks when meeting dates are set;
  • Ask DEP to add your name to such a list
  • Encourage them to record the public information session and all meetings, making them available through their web page;
  • Encourage them to widely advertise the existence of the new web page and when public meetings will be held;
  • Include Director Tori Kim and continue to urge MEPA involvement;
  • Don't send them testimony yet, since it won't be recorded, but start thinking about or preparing testimony to submit, or questions to ask, when the public comment period begins.  That will be the time for specifics, and it might be a very brief window.


WHAT COMES NEXT IN THE PROCESS                

See Water Quality Certificate graphic of steps                                                   TF dam Impound ment area
                     (Click this link, then scroll down)                                         

 

WRITE YOUR LETTER NOW

Sample letter to DEP/EEA for you to copy and modify.

Send copies to:

  • Governor Charlie Baker, state of Massachusetts;
  • Commissioner Martin Suuberg, MassDEP;
  • Director Tori Kim, MA Environmental Policy Act Office (requesting to have MEPA invoked, (click, then scroll down to "MEPA");
  • Members of the Western MA congressional delegation and their staffers - at least your own elected officials.

Public Official's, names, email addresses, & postal addresses

 

EARLIER LETTERS TO SEE WHAT OTHERS HAVE EMPHASIZED

 

See also

 


 
*ACRONYMS 

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

 

 "Never doubt that a small group of thoughtful, committed citizens can change the world; indeed, it's the only thing that ever has."

Margaret Mead

 

© 2018 Greening Greenfield • c/o 34 Pierce St, Greenfield, MA 01301 • 603-477-3527 • Contact Us: info@greeninggreenfieldma.org