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.
ACTION
Today, Greening Greenfield is asking 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.
While the DEP has agreed to hold 2 public hearings, there have been no details announced, and we want to make sure there is ample opportunity for everyone concerned with any aspect of this project to have their voices heard.
After FirstLight applies for the WQC, which we anticipate will be some time in mid to late 2022, 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.
If you've already written a basic letter, and you have time, please also consider requesting
- EEA/DEP host a recorded public information session prior to the hearings, to explain the process to all who are interested;
- EEA create and update a dedicated website to help the public understand and track the progress;
- EEA widely advertise these events and resources; and
- That MEPA be fully involved in the relicensing process, especially as the original license pre-dates the entire 401 process.
WHAT COMES NEXT IN THE PROCESS
See Water Quality Certificate graphic of steps
(Click this link, then scroll down)
WRITE YOUR LETTER NOW
Sample letter to EEA for you to copy and modify.
Send copies to
- Governor Charlie Baker, state of Massachusetts
- Commissioner Martin Suuberg, MassDEP
- Members of the Western MA congressional delegation and their staffers - at least your own elected officials
If you are mentioning the desire to have MEPA invoked, (click, then scroll down to "MEPA") include
- Director Tori Kim, MA Environmental Policy Act Office
Public Official's, names, email addresses, & postal addresses
MORE LETTERS TO SEE WHAT OTHERS HAVE EMPHASIZED
- Sample letter 2020 from Western MA legislative delegation to EEA/DEP/Gov
- Sample letter from Peg Hall to EEA/DEP/Gov/MEPA
- Sample letter from Nancy Hazard to EEA/DEP/Gov
Or short and sweet, but cc'd to about 30 people
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