Letter: Relicensing Northfield Pump Station And Turners Falls Dam Will Harm Connecticut River

The following letter was sent to the Federal Energy Regulatory Commission on May 19, 2023.

re: Proposed Relicensing of the Turners Falls Hydroelectric Project (FERC No. 1889) and Northfield Mountain Pumped Storage Project (FERC No. 2485)

We are writing to oppose the above-referenced settlement agreement and proposed relicensing.

FirstLight Power is seeking 50-year license renewals for the Northfield Pump Station and Turners Falls Dam that it owns and operates on the Connecticut River. These are both antiquated facilities that would never be newly licensed today.  It makes no sense to grant FirstLight 50-year licenses for these facilities in the context of current knowledge about:

• The ecological needs of the Connecticut River in order to support successful fish life and biodiversity

• The impacts of global warming, which are worsened by high-impact dams like the Turners Falls Dam, due to algae growth

• The rapidly changing needs of the region, making a 50-year license for these antiquated and destructive facilities reckless at this time.

FirstLight’s Northfield Pump Station causes tremendous ecological harm to the Connecticut River, effectively using many miles of the river as a lower reservoir at Barton’s Cove, pumping huge amounts of water to an upper reservoir, killing all aquatic life that is sucked up with the water, and then discharging the water for profit, causing water levels at Barton Cove to dramatically rise and fall. If this project were newly proposed today, FirstLight would be required to make a closed loop system with an actual reservoir. The level of daily harm caused by FirstLight’s pumping operations far exceeds what a river can possibly sustain and remain ecologically viable.  FirstLight itself has acknowledged that fish, eggs, and larvae that get sucked up into its pipes have “no expectation of survival.”  Moreover, FirstLight is positioning to increase the amount of water pumped from the river at least three-fold, which would significantly increase the tremendous damage this facility causes. 

No justification exists for relicensing the Northfield Pump Station. This facility does not generate power; it runs at a net loss of energy daily. Massachusetts has no current energy storage crisis; and even if energy storage needs jump dramatically in the future, the ecological harm done by this facility is far too great to justify its potential storage value. The Northfield Pump Station should not be relicensed.

The Turners Falls Dam license should similarly not be renewed unless the company is required to make much faster and more dramatic improvements to its operations. There is no excuse for a new fish lift to take nine years to complete, as FirstLight has proposed.  The proposed timeline for completion of the fish lift is motivated purely by FirstLight’s greed; prioritizing profits over the desperately challenged health of our lifeblood river.  FirstLight has plenty of money to dramatically improve the Turners Falls Dam immediately; there is no excuse for a nine year delay.

Moreover, FirstLight proposes to release far too little water over the Turners Falls Dam – nowhere near the amount required to maintain the fish and other aquatic life that are dependent on the water for their survival.  Once again, FirstLight is prioritizing its profits over our river; this must not be allowed.

It is hugely significant that the Connecticut River Conservancy (CRC), an extremely reasonable party to the negotiations, refused to sign the settlement agreement.  CRC is asking for only the most minimal requirements to protect the fish and aquatic life of the river.

With respect to the specifics of the proposal –

• The barrier net that FirstLight has proposed to reduce fish intake to the Northfield Pump Station, is untested technology that may have little success. The negotiated settlement allows the trial of this net to drag on for more than a decade. Given FirstLight’s acknowledgment that fish, eggs, and larvae sucked up into its pipes have no expectation of survival, it is unacceptable that FirstLight be given another ten years of this 100% death rate while they play around to see if their net works at all.

• Erosion concerns were not addressed at all in the settlement. The Northfield operations cause significant erosion damage to the Connecticut River – some riverfront property owners have lost 40 feet of frontage to this erosion, not to mention the damage this has caused to the river ecosystem. But FirstLight ignores this issue entirely; they address only increases in erosion, nothing about the need ameliorate erosion their operations already cause.

• FirstLight also ignores the destruction of fish, eggs, and larvae from their operations, only mentioning “protected, threatened, or endangered species.” In other words, FirstLight refuses to address and wants us to ignore the lion’s share of the harm they cause to the Connecticut River on a daily basis.   
  
• The proposal does not require remediation. FirstLight should be required to properly remediate the harm their facilities have already done and continue to do, including the need to stabilize riverbanks, repair areas that have already eroded, and present a clear plan for how future monitoring and solving of negative impacts will be carried out. FirstLight’s written materials indicate repeatedly their reckless disregard for the local ecology of the river and the watershed, and their refusal to take any steps unless forced to do so. It would be a grave mistake for licensing to proceed with any expectation of good faith on the company’s part; requirements must be made explicit and must be enforced.
  
• The proposal also does not mention decommissioning requirements.  FirstLight should be required to post decommissioning bonds for both of their facilities now, while the company is viable, so that local communities and the State are not left with financial responsibility for this at a later date. Requiring FirstLight to post decommissioning bonds is fiscally prudent and critical for the residents and taxpayers of Massachusetts.
  
• The proposal does nothing to address FirstLight’s history as a chronic violator of laws and regulations. For example, FirstLight had a very serious oil leak into the river a year ago that they promised would never be repeated, but then another oil leak occurred this year.  FirstLight should be required to pay the State of Massachusetts for the cost of monitoring their compliance with applicable law and enforcement of any transgressions.
  
  We invite readers to sign on to these comments at – FirstLight Power petition.  Please also visit the Connecticut River Conservancy website for information about how to submit comments to FERC on the relicensing – Microsoft Word – CRC FERC Comment Guide.doc (ctriver.org)
  
  Lundy Bancroft
  Sarah Matthews

Lundy Bancroft and Sarah Matthews are members of Western Massachusetts Rights of Nature