February 5, 2019
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426
Via Electronic Filing
Re: Turners Falls Hydroelectric Project (FERC No. 2622) Final License Application
Dear Secretary Bose:
Pursuant to 18 CFR 16.8(d), Turners Falls Hydro, LLC (TFH) is hereby filing with the Federal Energy Regulatory Commission (Commission) and providing to resource agencies, Indian tribes, and other interested parties listed on the enclosed stakeholder distribution list its Final License Application for a Subsequent License for a Minor Water Power Project for its Turners Falls Hydroelectric Project (FERC Project No. 2622), initiating the third stage of consultation of the Traditional Licensing Process.
TFH is providing for consideration the Final License Application as follows:
• Initial Statement • Verification Statement • Exhibit A – Project Description • Exhibit E – Environmental Report • Exhibit F – Drawings of Project Works and Supporting Design Report • Exhibit G – Project Boundary • Exhibit H – Plans and Ability to Operate the Project • Attachment 1: Draft License Application Comment Response Summary
Some of the information presented in the Final License Application is considered Critical Energy Infrastructure Information (CEII), as defined by 18 CFR § 388.113(c). Such information has been removed from the public version Final License Application (Volume 1). In accordance with the Commission’s filing guidelines, all CEII is included in a separate volume (Volume 2) that has been clearly marked as "CONTAINS CRITICAL ENERGY/ELECTRIC INFRASTRUCTURE INFORMATION – DO NOT RELEASE." In addition, some information included in the Final License Application is privileged information, and has been filed in a separate volume (Volume 3) that has been marked as “CONTAINS PRIVILEGED INFORMATION – DO NOT RELEASE.”
A copy of the Volume 1 of the Final License Application has been made available on Eagle Creek’s Turners Falls Hydroelectric Project Relicensing Website at https://www.eaglecreekre.com /turners-falls-relicensing as well as at the Montague Public Library, Carnegie Library Branch
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com located at 201 Avenue "A" Turners Falls, MA 01376 during their normal business hours for public inspection and reproduction, as required by 18 CFR 4.32(b)(3)(i). In addition, pursuant to 18 CFR 4.32(b)(6), TFH will publish twice within two weeks a notice of the filing of the Final License Application in “The Montague Reporter,” a weekly published newspaper in general circulation in the county where the Turners Falls Hydroelectric Project is located.
If there are any questions concerning the enclosed, please do not hesitate to contact Mr. Michael Scarzello, Director, at (973) 998-8400 or [email protected].
Respectfully,
for
Robert A. Gates Executive Vice President Turners Falls Hydro, LLC
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Stakeholder Distribution List
FEDERAL Andrew L. Raddant David Turin Regional Environmental Officer U.S. Environmental Protection Agency U.S. Department of Interior 5 Post Office Sq, Ste. 100 408 Atlantic Ave Ste. 142 Boston, MA 02109-3946 Boston, MA 02210-2209 [email protected] [email protected]
Edward J. Markey, Senator Kevin Mendik, ESQ U.S. Senate NPS Hydro Prgm Coord 218 Russell Senate Office Bldg. U.S. National Park Service Washington, DC 20510 15 State Street 10th floor Boston, MA 02109 [email protected]
U.S. Geological Survey Melissa Grader Massachusetts-Rhode Island Dist., Wrd U.S. Fish & Wildlife Service 10 Bearfoot Rd. 103 East Plumtree Rd. Northborough, MA 01532-1528 Sunderland, MA 01375 [email protected]
Bruce Maytubby Greg Penta Regional Director New England District Eastern Regional Office US Army Corps of Engineers Bureau of Indian Affairs 696 Virginia Rd 545 Marriott Dr. Ste. 700 Concord, MA 01742-2751 Nashville, TN 37214 [email protected] [email protected]
Ken Sprankle William McDavitt Connecticut River Coordinator Environmental Specialist Connecticut River Coordinator's Office Northeast Regional Office US Fish and Wildlife Service National Marine Fisheries Service 103 East Plumtree Rd. 55 Great Republic Dr. Sunderland, MA 01375 Gloucester, MA 01930-2276 [email protected] [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com Julie Crocker U.S. Coast Guard Protected Resources Division MSO Boston National Marine Fisheries Service 447 Commercial St. 55 Great Republic Dr. Boston, MA 02109-1027 Gloucester, MA 01930 [email protected]
Office of Senator Elizabeth Warren Office of the Solicitor United States Senate U.S. Department of Interior Washington, DC 20510 1849 C Street, NW, MS 6557 Washington, DC 20240
Dr. Ted Castro-Santos William Connelly Conte Anadromous Fish Research Center Project Manager US Geological Survey Federal Energy Regulatory Commission One Migratory Way 888 First Street, N.E. PO Box 796 Washington, D.C. 20426 Turner Falls, MA 01376-0796 [email protected] [email protected]
Bjorn Lake National Marine Fisheries Service [email protected]
STATE MA Division of Energy Resources Angela M. O'Connor Hydro Section Chairmen 100 Cambridge St., Ste. 1020 Massachusetts Dept. of Public Utilities Boston, MA 02114-2533 1 South Station Boston, MA 02110 [email protected]
Attorney General Brian D. Harrington Utilities Division Deputy Regional Director 1 Ashburton Pl Fl. 19 MA Department of Environmental Protection Boston, MA 02108-1518 436 Dwight Street Springfield, MA 01103 [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Cindy Delpapa Jack Buckley Riverways Program Manager Director Massachusetts Riverways Program Massachusetts Dept. of Fisheries & Wildlife 251 Causeway St. Ste. 400 251 Causeway St Boston, MA 02114-2119 Boston, MA 02114-2104 [email protected] [email protected]
Michael Stroman Martin Suuberg, Commissioner Program Chief MA Department of Environmental Protection Massachusetts Division of Wetlands Suite 700 Suite 700 251 Causeway St 251 Causeway St Boston, MA 02114-2104 Boston, MA 02114-2104 [email protected] [email protected]
Massachusetts Division of Water Pollution Massachusetts Dept. of Public Works Control 10 Park Plz. 1 Winter St Boston, MA 02116-3933 Boston, MA 02108-4747
Bruce Carlisle, Director Dr. Caleb Slater Massachusetts Office of Coastal Zone Massachusetts Division of Fisheries and Management Wildlife 251 Causeway St. Ste. 800 1 Rabbit Hill Rd. Boston, MA 02114 Westborough, MA 05181 [email protected] [email protected]
Leo Roy Paul Jahnige Commissioner Director Greenways and Trails Program Massachusetts Department of Conservation Massachusetts Department of Conservation and Recreation and Recreation 251 Causeway St. Ste. 900 136 Damon Road Boston, MA 02114-2104 Northampton, MA 01060 [email protected] [email protected]
Robert Kubit, P.E. David Cameron Massachusetts Department of Environmental Regional Section Chief Protection Western Regional Office Division of Watershed Management Massachusetts Department of Environmental 8 New Bond Street Protection Worcester, MA 01606 436 Dwight St. [email protected] Springfield, MA 01103 [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Tim Purinton, Director Amanda Veinotte Massachusetts Division of Ecological Regulatory Review Administrator Restoration Natural Heritage & Endangered Species 251 Causeway St. Ste. 400 Program Boston, MA 02114 Massachusetts Division of Fisheries and [email protected] Wildlife 1 Rabbit Hill Rd Westborough, MA 01581 [email protected] Brona Simon Jennifer Jillson Soper State Historic Preservation Officer & Executive Land Protection Specialist Director Connecticut River Greenway State Park Massachusetts Historical Commission Headquarters/District Field Office 220 Morrissey Blvd Massachusetts Department of Conservation Boston, MA 02125-3314 and Recreation [email protected] 136 Damon Rd Northampton, MA 01060 [email protected] Matthew Beaton Office of Dam Safety Director Massachusetts Dept. of Conservation & Massachusetts Executive Office of Energy and Recreation Environmental Affairs John Augustus Hall 100 Cambridge St Ste. 900 180 Beaman St. Boston, MA 02114 West Boylston, MA 01583-1109 [email protected] [email protected]
Jesse Leddick Endangered Species Review Biologist MA Division of Fisheries and Wildlife 1 Rabbit Hill Road Westborough, MA 01581 Ph: 508-389-6386 Email: [email protected]
LOCAL Deborah Tuttle Timothy Brennan Town Clerk Executive Director Town of Greenfield Pioneer Valley Planning Commission 14 Court Sq. 60 Congress St. Greenfield, MA 01301 Springfield, MA 01104-3419 [email protected] [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Debra Bourbeau Walter Ramsey, AICP Town Clerk Town Planner & Conservation Agent Town of Montague One Avenue A 1 Avenue A Turners Falls, MA 01376 Turners Falls, MA 01376 [email protected] [email protected]
Peggy Sloan David Jensen, Inspector Director of Planning & Development Town of Montague Planning Division One Avenue A Franklin Regional Council of Governments Turners Falls, MA 01376 425 Main St [email protected] Greenfield, MA 01301 [email protected]
Kimberly Noake MacPhee, P.G., CFM Land Use & Natural Resources Planning Program Manager Franklin Regional Council of Governments 12 Olive Street, Suite 2 Greenfield, MA 01301 Email: [email protected]
TRIBAL Doug Harris Robert Longtoe Sheehan Assistant Historic Preservation Tribal Headquarters Narragansett Indian Tribe Elnu Abenaki Tribe PO Box 268 5243 VT Route 30 Charlestown, RI 02813 Jamaica, VT 05343 [email protected] [email protected]
Bettina Washington Donald Stevens Tribal Historic Preservation Officer Chief Wampanoag Tribe of Gay Head Nulhegan Abenaki Tribe 20 Black Brook Rd 158 Whiting Lane Aquinnah, MA 02535-1546 Brownington, VT 05860 [email protected] [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Cedric Cromwell Matthew Thomas, Chief Sachem Chairmen Historic Preservation Mashpee Wampanoag Tribe Narragansett Indian Tribe 483 Great Neck Road South P.O. Box 268 Mashpee, MA 02649 Charlestown, RI 02813
Sherry White Historic Preservation Officer Stockbridge-Munsee Community W13447 Camp 14 Rd Bowler, WI 54416 [email protected]
NON-GOVERNMENTAL ORGANIZATIONS Bob Nasdor Charles Olchowski Northeast Stewardship Director Chapter President American Whitewater Deerfield/Millers Chapter 65 Blueberry Hill Lane Trout Unlimited Sudbury, MA 01776 28 Smith Street [email protected] Greenfield, MA 01301 [email protected]
Ken Kimball, PhD Wade Blackwood Director of Research Executive Director Appalachian Mountain Club American Canoe Association Pinkham Notch Camp 108 Hanover St. PO Box 298 Fredericksburg, VA 22401 Gorham, NH 03581 [email protected] [email protected]
Amy Singler Andrea Donlon Associate Director Massachusetts River Steward River Restoration Program Connecticut River Watershed Council American Rivers 15 Bank Row 25 Main Street, Suite 220 Greenfield, MA 01301 Northampton, MA 01060 [email protected] [email protected]
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Kim Lutz Director Connecticut River Program The Nature Conservancy 55 Church St New Haven, CT 06510-3029 [email protected]
INTERESTED MEMBERS OF THE PUBLIC Susanne LaCosse Tim deChristopher 270 316 Log Plain Road [email protected] Turners Falls Rd Greenfield, MA 01301
Peter Golrick Jeanne Golrick [email protected] [email protected]
OTHER Edward R. Niederriter Ron Lamberston International Paper Company Chairman Corporate Office Connecticut River Atlantic Salmon Commission 6400 Poplar Ave 103 East Plumtree Rd. Memphis, TN 38197-0100 Sunderland, MA 01375
Rachel Ruppel Paul Nolan Program Manager Energy Consultant Connecticut River Joint Commissions 5515 17th Street North 10 Water St Ste. 225 Arlington, VA 22205-2722 Lebanon, NH 03766 [email protected]
Simeon Bruner Joe Lucas Cambridge Development Corporation FirstLight Power Resources 130 Prospect Street [email protected] Cambridge, MA 02139
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
Before the Federal Energy Regulatory Commission
FINAL Application for Subsequent License for a Minor Water Power Project 5 Megawatts or Less
Turners Falls Hydroelectric Project (No. 2622)
Volume 1 of 3: Public
Initial Statement Verification Statement Exhibit A – Project Description Exhibit E – Environmental Report Exhibit F – Project Drawings and Supporting Design Report Exhibit G – Project Boundary Exhibit H – Plans and Ability to Operate the Project
February 2019 Turners Falls Hydroelectric Project (No. 2622) INITIAL STATEMENT
INITIAL STATEMENT PER 18 CFR § 4.51
Draft Application for Subsequent License for a Minor Water Power Project 5 Megawatts or Less 1. Turners Falls Hydro, LLC (the Applicant), a wholly owned subsidiary of Eagle Creek Renewable Energy, LLC (Eagle Creek), applies to the Federal Energy Regulatory Commission (Commission or FERC) for a subsequent license for the existing Turners Falls Hydroelectric Project (Project), FERC Project Number 2622, as described in the attached Exhibits. The current license for the Turners Falls Hydroelectric Project was issued on June 29, 1990, and expires on February 28, 2021. 2. The location of the Project is:
State: Massachusetts County: Franklin Townships: Montague Stream: Turners Falls Power Canal, Connecticut River
3. The exact name, address, and telephone number of the Applicant are:
Turners Falls Hydro, LLC 116 N. State Street P.O. Box 167 Neshkoro, WI 54960 920-293-4628
4. The exact name, address, and telephone number of each person authorized to act as agent for the Applicant in this application are:
Robert Gates Michael Scarzello Vice President Director Eagle Creek Renewable Energy, LLC Eagle Creek Renewable Energy, LLC 65 Madison Avenue, Suite 500 65 Madison Avenue, Suite 500 Morristown, NJ 07960 Morristown, NJ 07960 [email protected] [email protected] (973) 998-8400 (973) 998-8400
5. The Applicant is a domestic corporation and is not claiming preference under section 7(a) of the Federal Power Act, 16 USC 800. 6. (i) The statutory or regulatory requirements of the Commonwealth of Massachusetts that affect the Project as it exists with respect to bed and banks and the appropriate, diversion, and use of water for power purposes, and with respect to the right to engage in the business of developing, transmitting, and distributing power and in any other business necessary to accomplish the purpose of the license under the Federal Power Act are: • Chapter 253, Massachusetts General Laws-Mills, Dams, and Reservoirs. Provides authority to use existing water mills and mill dams • Chapter 91, Massachusetts General Laws-Waterways. Regulates use of waterways within the Commonwealth of Massachusetts • Chapter 21G, Massachusetts General Laws-Water Management Act. Regulates water withdrawals and 401 Water Quality Certifications, which are issued pursuant to the Massachusetts Department
i Turners Falls Hydroelectric Project (No. 2622) INITIAL STATEMENT
of Environmental Protection’s delegated authority under the Federal Clean Water Act, PL 92-500, §401, as amended. (ii) The steps which the applicant has taken or plans to take to comply with the regulations cited above are: • With the exception of the §401 Water Quality Certification, the Applicant believes that it has all approvals, licenses, permits, and exemptions that are necessary to continue operating the existing waterpower facility. A request for §401 Water Quality Certification will be submitted to the Massachusetts Department of Environmental Protection concurrent with the submittal of this Application. Since this is an application for relicensing of an existing waterpower project and the Applicant does not propose any alteration of the existing waterpower facility, new construction, or significant change in operation of the existing waterpower facility, the Applicant expects to continue to operate the facility pursuant to approvals, licenses, permits, and exemptions already in effect. 7. Brief project description: (i) Proposed installed generating capacity is 937 kW (ii) Check appropriate box
existing dam unconstructed dam
existing dam, major modified project (see §4.30(b)(14))
8. Lands of the United States affected (shown on Exhibit G)
(Name) (Acres) (i) National Forest 0
(ii) Indian Reservation 0
(iii) Public Lands Under Jurisdiction of 0
(iv) Other 0
(v) Total U.S. Lands 0
Check appropriate box:
Surveyed land Unsurveyed land
9. The Project is an existing operating hydroelectric project. No new construction or major project modifications are proposed.
ii Turners Falls Hydroelectric Project (No. 2622) INITIAL STATEMENT
ADDITIONAL INFORMATION REQUIRED BY 18 CFR § 4.32
1. Identify every person, citizen, association of citizens, domestic corporation, municipality, or state that has or intends to obtain and will maintain any proprietary right necessary to construct, operation or maintain the project: Turners Falls Hydro, LLC, a subsidiary of Eagle Creek Renewable Energy, LLC, currently owns and will continue to maintain all proprietary rights necessary to construct, operate, and maintain the Project. 2. Identify (providing names and mailing addresses): (i) Every county in which any part of the project and any Federal facilities that would be used by the project would be located: The Franklin Regional Council of Governments 12 Olive Street, Suite 2 Greenfield, Massachusetts 01301 (ii) Every city, town, or similar political subdivision: i. In which any part of the Project, and any Federal facility that would be used by the project, would be located; or
Town of Greenfield Town of Montague 14 Court Street 1 Avenue A Greenfield, MA 01354 Montague, MA 01376
ii. That has a population of 5,000 or more people (2010 U.S. Census data) and is located within 15 miles of the project dam.
Town of Amherst Town of Greenfield 4 Boltwood Avenue 14 Court Street Amherst, MA 01002 Greenfield, MA 01301 (population 37,819) (population 17,456)
Town of Athol Town of Montague 584 Main Street, Suite 10 1 Avenue A Athol, MA 01331 Turners Falls, MA 01376 (population 11,584) (population 8,437)
Town of Orange Town of Hadley 6 Prospect Street 100 Middle Street Orange, MA 01364 Hadley, MA 01035 (population 7,839) (population 5,250)
Town of Deerfield Town of Brattleboro 8 Conway Street 230 Main Street, Suite 108 South Deerfield, MA 01373 Brattleboro, VT 05301 (population 5,125) (population 12,043)
iii Turners Falls Hydroelectric Project (No. 2622) INITIAL STATEMENT
(iii) Every irrigation district, drainage district or similar special purpose political subdivision (A) in which any part of the project is located, and any Federal facility that is or is proposed to be used by the project is located, or (B) that owns, operates, maintains, or uses any project facility or any Federal facility that is or is proposed to be used by the project: There is no irrigation district, drainage district, or similar special purpose political subdivision in which any part of the Project is located or that owns, operates, maintains, or uses any project facility. (iv) Every other political subdivision in the general area of the project that there is reason to believe would likely be interested in, or affected by, the application. There is no other political subdivision in the general area of the Project that there is reason to believe would be likely to be interested in, or affected by, this notification. (v) All Indian tribes that may be affected by the Project. Mashpee Wampanoag Indian Tribe 483 Great Neck Road Mashpee, MA 02649 Wampanoag Tribe of Gay Head (Aquinnah) 20 Black Brook Road Aquinnah, MA 02535-1546 Nipmuc Nation 25 Main Street South Grafton, MA 01560 3. Notification (i) The Applicant has made a good faith effort to give notification by certified mail of the filing of the application to: (A) Every property owner of record of any interest in the property within the bounds of the Project, or in the case of the Project without a specific boundary, each such owner of property which would underlie or be adjacent to any Project works, including any impoundments; and (B) The entities identified in paragraph (2) above, as well as any other federal, state, municipal or other local government agencies that there is reason to believe would likely be interested in or affected by the application. 4. PURPA Benefits The Applicant is seeking any PURPA benefits in association with the relicensing of the Project.
iv
TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
FINAL APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT A – PROJECT DESCRIPTION Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
TABLE OF CONTENTS
1 Turners Falls Project Description ...... 1 1.1 Generators ...... 1 1.2 Turbines ...... 1 1.3 Existing and Proposed Project Operations ...... 1 1.4 Average Annual Energy Production ...... 2 1.5 Estimated Gross Head ...... 2 1.6 Impoundment ...... 2 1.7 Flow Data ...... 2 1.8 Project Structures ...... 2 1.8.1 Intake Facility ...... 2 1.8.2 Penstock ...... 2 1.8.3 Powerhouse ...... 2 1.8.4 Tailrace ...... 3 1.8.5 Transmission Line ...... 3 1.8.6 Appurtenances ...... 3 1.9 Estimated Project Cost ...... 3 1.10 Estimated Capital Cost and Estimated Annual Operations and Maintenance Cost of Each Proposed Environmental Measure ...... 3 2 Project Purpose ...... 3 3 Project Licensing Costs ...... 3 4 Peak and Off-Peak Power Values ...... 3 5 Change in Project Generation ...... 3 6 Project Value ...... 4 7 Annual Operations and Maintenance Costs ...... 4 8 Single-Line Electrical Diagram ...... 4 9 Safe Management, Operation, and Maintenance of the Project ...... 4
i Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
LIST OF FIGURES
Figure 1-1. Project location...... 5 Figure 1.8-1. Project structures...... 6 Figure 8-1. Turners Falls Hydroelectric Project single-line diagram...... 7
ii Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
1 TURNERS FALLS PROJECT DESCRIPTION
The 937-kilowatt (kW) Turners Falls Hydroelectric Project (Project, or Turners Falls) is located on the Turners Falls Power Canal, Connecticut River, in Franklin County, Massachusetts, in the Town of Montague, Massachusetts (Figure 1-1). The Turners Falls Power Canal is in the unincorporated Village of Turners Falls, Massachusetts, within the Town of Montague, Massachusetts. The Turners Falls Power Canal is 2.1 miles in length and empties into the Connecticut River about 2.0 miles downstream of the Project. The Power Canal is owned and operated by FirstLight Hydro Generating Company (FirstLight) as a part of their Turners Falls Hydroelectric Project (Federal Energy Regulatory Commission [FERC] Project No. 1889). The Power Canal begins at a gatehouse at the upstream end of the Power Canal adjacent to the Turners Falls Dam, also owned and operated by FirstLight. Situated on the Power Canal are three hydroelectric generating stations: Turners Fall Hydro (FERC Project No. 2622), Station No. 1 (FERC Project No. 1889), and Cabot Station (FERC Project No. 1889). Station No. 1 and Cabot Station are downstream of the Project.
1.1 Generators The Project powerhouse contains one generating unit with a capacity of 937 kW. Information on the single generating unit is provided below. • 937-kW General Electric Alternating Current Generator • 314 amperes • 0.75 power factor • 2,300 volts full load
1.2 Turbines The powerhouse also contains one vertical Francis turbine unit with a total hydraulic capacity of 289 cubic feet per second (cfs) at 225 revolutions per minute, 1,340 horsepower at approximately 44 feet of head. The turbine has a runner diameter of 38.5 inches. The turbine has an operating range of approximately 60 cfs to the maximum hydraulic capacity of 289 cfs. Flow through the turbine is manually regulated by wickets gates. Headgates within the Project intake facility (see section 1.81 Intake Facilities below) are manually opened fully for operation, or closed for unit outage and/or repair.
1.3 Existing and Proposed Project Operations The Project currently uses waters of the Turners Falls Power Canal for hydroelectric generation. The Project has first-priority right to the water in the canal, and the existing license authorizes Turners Falls to continually operate the Project. Currently, the Project is operated either on or off pursuant to an off- license Water Use Agreement (dated January 1, 1998 as amended May 14, 2003) between Turners Falls and FirstLight Hydro Generating Company (FirstLight). The water use agreement dictates that Turners Falls will generate only when flows within the Turners Falls Power Canal are greater than 15,000 cfs and the needs of FirstLight’s Station No. 1 and Cabot Station hydroelectric developments are met (FERC Project No. 1889). Turners Falls currently manually operates the Project when indicated by FirstLight. FirstLight indicates Turners Fall may start and stop generation by telephoning the operator, who manually turns on and off the Project. Monitoring equipment at the Project consists of a call-out device that alerts the operator if there is a problem at the Project. The operator also maintains a station log book, which includes information and conditions that affect operations.
1 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
Turners Falls proposes to continue operating the Project as currently licensed during the next license term, with the flexibility to operate up to continuously or to operate under the current or a modified water use agreement between Turners Falls and FirstLight.
1.4 Average Annual Energy Production The average annual energy production (2011 – 2015) for the Project is 1,512,009 kWh with the water use agreement between Turners Falls and FirstLight. Average annual energy production operating continuously is estimated at 7,755,000 kWh.
1.5 Estimated Gross Head The estimated gross head for the Project is 44 feet.
1.6 Impoundment The Project has no dam or impoundment. The Project is situated on and uses the waters of the Turners Falls Power Canal for hydroelectric generation. The Turners Falls Power Canal is owned and operated by FirstLight for their Turners Falls Hydroelectric Project (FERC No 1889). Therefore, Turners Falls does not control flow or storage within the Turners Falls Power Canal.
1.7 Flow Data The Project has a hydraulic capacity of 289 cfs. The Turners Falls Power Canal has a design flow capacity of 18,000 cfs. At the point of diversion, the Turners Falls Dam, which is owned and operated by FirstLight, has a drainage area of 7,163 square miles, and the average annual flow of the Connecticut River Dam is 14,049 cfs (FirstLight, 2016a).
1.8 Project Structures The Turners Falls Project consists of intake facilities, penstock, powerhouse, tailrace, and appurtenant facilities. Figure 1.8-1 shows the location of the Project features.
1.8.1 Intake Facility The Project intake facility consists of a canal entrance, trashrack, and manually operated rack-and-pinion gates (i.e., headgates). Water from the Turners Falls Power Canal is delivered to the Project through a 12- foot-high by 20-foot-wide canal entrance that is oriented parallel to the direction of flow. Set back about 10 feet from the canal entrance is a 22-foot-high by 20-foot-wide trashrack with 1.5-inch clear spacing between the vertical bars. Behind the trashrack are two rack-and-pinion slide gates that are manually operated.
1.8.2 Penstock Water passes from the intake facility into an 8.5-foot-diameter, 50-foot-long underground steel penstock to the Project’s single vertical Francis turbine.
1.8.3 Powerhouse The Project powerhouse is a four-story building with a footprint of 3,847 square feet. The Powerhouse contains the Project’s single generator and turbine.
2 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
1.8.4 Tailrace After passing through the Project turbine, water passes into a 50-foot flume that extends underneath the adjacent mill complex and is discharged into an excavated and walled tailrace channel that measures about 80 feet long by 10 feet wide and empties back into the Connecticut River.
1.8.5 Transmission Line The Project has an approximate 1,000-foot-long, 13.8 kV transmission line.
1.8.6 Appurtenances Appurtenances at the Project include switches and other electrical equipment needed to safely operate the Project.
1.9 Estimated Project Cost The Applicant does not have any records of the original Project construction costs.
1.10 Estimated Capital Cost and Estimated Annual Operations and Maintenance Cost of Each Proposed Environmental Measure
Estimate Annual Proposed Environmental Measure Estimated Capital Cost Operations and Maintenance Cost
Trashrack with ¾-inch clear spacing1 $75,000 $5,500 1. Does not include annual cost of lost generation.
2 PROJECT PURPOSE
Power generated by the Project is sold into the power grid. The Project provides valuable socioeconomic benefits for the region, and renewable power generation from the Project helps offset reliance on non- renewable fossil fuel sources.
3 PROJECT LICENSING COSTS
The estimated cost to develop the license application is $103,000.
4 PEAK AND OFF-PEAK POWER VALUES
In accordance with 18 CFR 4.61(c)(4), the Project is currently, and will continue to be, operated in run- of-river mode. Therefore, providing peak and off-peak power values is not applicable.
5 CHANGE IN PROJECT GENERATION
Turners Falls is not proposing changes to Project operations as currently licensed, with the flexibility to operate up to continuously or to operate under the current or a modified water use agreement between Turners Falls and FirstLight.
3 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
6 PROJECT VALUE
The undepreciated net investment, or book value of the Project, is being filed as privileged information.
7 ANNUAL OPERATIONS AND MAINTENANCE COSTS
In 2018 dollars, the average annual operations and maintenance costs is estimated to be $195,000 will be presented in the Final License Application.
8 SINGLE-LINE ELECTRICAL DIAGRAM
A detailed single-line electrical diagram is included as Figure 8-1 to this Exhibit. Note: this drawing is considered Critical Energy Infrastructure Information pursuant to the Commission’s regulations and will be removed from publicly available copies of the application.
9 SAFE MANAGEMENT, OPERATION, AND MAINTENANCE OF THE PROJECT
The Applicant has safely managed, operated, and maintained the Project throughout the existing license term. These same practices will be continued under the subsequent license, subject to any new terms and conditions contained therein.
4 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
Figure 1-1. Project location.
5 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
Figure 1.8-1. Project structures.
6 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT A – PROJECT DESCRIPTION
These drawings are considered Critical Energy Infrastructure Information [CEII] and have been removed from this document. Figure 8-1. Turners Falls Hydroelectric Project single-line diagram.
7 TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
FINAL APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT E - ENVIRONMENTAL REPORT Turners Falls Hydroelectric Project (No. 2622) EXHIBIT E – ENVIRONMENTAL REPORT
TABLE OF CONTENTS
1 General Description of Project Locale ...... 1 1.1 Topography ...... 1 1.2 Bedrock Geology ...... 1 1.3 Surficial Geology and Soils ...... 1 1.4 Vegetative Cover ...... 2 1.5 Climate ...... 2 1.6 Population Size and Density ...... 2 1.7 Regional Socioeconomics ...... 2 2 Water Resources ...... 6 2.1 Water Quantity ...... 6 2.2 Water Use ...... 6 2.3 Water Quality ...... 6 2.3.1 Water Quality Standards ...... 6 2.3.2 Water Quality Assessment and Impairments...... 7 2.3.3 Historical and Existing Water Quality Data ...... 7 2.4 Environmental Impacts on Water Resources ...... 8 2.5 Proposed Measures to Enhance, Protect, or Mitigate Effects on Water Resources ...... 8 3 Aquatic and Fisheries Resources ...... 25 3.1 Aquatic Habitat ...... 25 3.2 Fisheries ...... 25 3.2.1 Fish Community ...... 25 3.2.2 Migratory Species ...... 25 3.2.3 Fish Passage ...... 28 3.3 Freshwater Mussels ...... 28 3.4 Fisheries Resources Study Requests and Results...... 28 3.5 Environmental Impacts on Aquatic and Fisheries Resources ...... 29 3.5.1 Aquatic Habitat ...... 29 3.5.2 Resident Fish ...... 29 3.5.3 Migratory Species ...... 30 3.5.4 Freshwater Mussels ...... 32 3.6 Proposed Measures to Enhance, Protect, or Mitigate Effects on Aquatic and Fisheries Resources ...... 32 3.7 Coastal Zone Management Act ...... 32 4 Wildlife and Botanical Resources ...... 44 4.1 Environmental Impacts on Wildlife and Botanical Resources ...... 44 4.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Wildlife and Botanical Resources ...... 44 5 Wetlands, Riparian, and Littoral Habitat ...... 45 5.1 Environmental Impacts on Wetland, Riparian, and Littoral Habitat ...... 45
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5.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Wetland, Riparian, and Littoral Habitat Resources ...... 45 6 Rare, Threatened, and Endangered Species ...... 47 6.1 Environmental Impacts on Rare, Threatened, and Endangered Species ...... 49 6.2 Proposed Measures for Enhancement of Rare, Threatened, and Endangered Species ...... 50 7 Historical and Archaeological Resources ...... 51 7.1 Environmental Impacts on Historical and Archaeological Resources ...... 51 7.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Historical and Archaeological Resources ...... 51 8 Recreation Resources ...... 53 8.1 Environmental Impacts on Recreation Resources ...... 53 8.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Recreational Resources ...... 53 9 Land Use and Aesthetic Resources ...... 55 9.1 Land Use ...... 55 9.2 Aesthetic Resources ...... 55 9.3 Environmental Impacts on Land Use and Aesthetic Resources ...... 55 9.4 Proposed Measures to Enhance, Protect, or Mitigate Effects on Land Use and Aesthetic Resources ...... 55 10 Compliance with Commission-Recognized Comprehensive Plans ...... 59 10.1 Relevant Comprehensive Waterway and Resource Management Plans ...... 59 11 Responsiveness Summary ...... 61 12 References 62
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LIST OF TABLES
Table 1.5-1. Climate of the Project area.1 ...... 3 Table 2.1.1-1. Estimated mean and median monthly and annual Connecticut River flow at the Turners Falls Dam...... 9 Table 2.1.2-1. Water users of the Turners Falls Power Canal...... 10 Table 2.3.1-1. Applicable surface water standards for Class B Warm Water Fisheries designated waters of the Connecticut River in the vicinity of the Project...... 11 Table 2.3.3-1 Minimum, maximum, and average water temperature and dissolved oxygen within the Turners Falls Power Canal and Connecticut River bypassed reach during the spring, summer, and fall of 2015...... 12 Table 3.2.1-1. Fish species and abundance sampled in the lower Turners Falls Power Canal during the 2014 canal drawdown...... 33 Table 3.2.1-1. Fish species and abundance sampled in the Connecticut River bypassed reach in September 2015...... 34 Table 3.3-1. Project existing trashrack configuration...... 35 Table 3.3-2. Conceptual trashrack configuration with ¾-inch clear spacing...... 36
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LIST OF FIGURES
Figure 1-1. Location of the Turners Falls Hydroelectric Project...... 4 Figure 1.3-1. Soils of the Project area...... 5 Figure 2.1-1. Connecticut River annual flow duration curve at Turners Falls Dam, January 1941 to December 2014...... 13 Figure 2.1-2. Connecticut River January, February, and March flow duration curves at Turners Falls Dam, January 1941 to December 2014...... 14 Figure 2.1-3. Connecticut River April, May, and June flow duration curves at Turners Falls Dam, January 1941 to December 2014...... 15 Figure 2.1-4. Connecticut River July, August, and September flow duration curves at Turners Falls Dam, January 1941 to December 2014...... 16 Figure 2.1-5. Connecticut River October, November, and December flow duration curves at Turners Falls Dam, January 1941 to December 2014...... 17 Figure 2.1-6. Annual flow duration curve for the Turners Falls Power Canal (hourly 2000-2009)...... 18 Figure 2.1-7. January, February, and March flow duration curves for the Turners Falls Power Canal (hourly 2000-2009)...... 19 Figure 2.1-8. April, May, and June flow duration curves for the Turners Falls Power Canal (hourly 2000-2009)...... 20 Figure 2.1-9. July, August, and September flow duration curves for the Turners Falls Power Canal (hourly 2000-2009)...... 21 Figure 2.1-10. October, November, and December flow duration curves for the Turners Falls Power Canal (hourly 2000-2009)...... 22 Figure 2.2-1. Location of Turners Falls Power Canal water users...... 23 Figure 2.3.3-1. Location of FirstLight (2016) water quality monitoring stations in relation to the Project...... 24 Figure 3.1-1. Turners Falls Power Canal in a watered state at the Project intake...... 37 Figure 3.1-2. Turners Falls Power Canal in a de-watered state at the Project intake...... 38 Figure 3.1-3. Turners Falls Power Canal in a de-watered state just upstream of the Project intake looking upstream...... 39 Figure 3.1-4. The Connecticut River bypassed reach downstream of the Project tailrace...... 40 Figure 3.1-5. The Connecticut River bypassed reach downstream of the Project tailrace looking upstream...... 41 Figure 3.1-6. The Connecticut River bypassed reach downstream of the Project tailrace looking downstream...... 42 Figure 5.0-1. Wetlands in the Project area...... 46 Figure 7.0-1. Location of the Strathmore Mill Complex...... 52 Figure 8.0-1. Recreation facilities and opportunities near the Project...... 54 Figure 9.2-1. View of the Project from the Turners Falls Road Bridge...... 56 Figure 9.2-2. View of the Project from Canal Street...... 57 Figure 9.2-3. View of the Connecticut River bypassed reach downstream of the tailrace when the Project is generating...... 58
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ACRONYMS AND ABBREVIATIONS
°C degrees Celsius °F degrees Fahrenheit % percent § section of a statute such as 18 C.F.R. § 5.6 (c) CFR Code of Federal Regulations cfs cubic feet per second CMR Code of Massachusetts Regulations DO dissolved oxygen EPA U.S. Environmental Protection Agency FERC or Commission Federal Energy Regulatory Commission FPA Federal Power Act FWS U.S. Fish and Wildlife Service fps feet per second IPaC (FWS) Information for Planning and Consultation KPC Keith Paper Company kVA kilovolt-ampere kW kilowatt kWh kilowatt-hour MassDCR Massachusetts Department of Conservation and Recreation MassDEP Massachusetts Department of Environmental Protection MassDHHS Massachusetts Department of Health and Human Services ml milliliter mg/L milligram(s) per liter NAVD88 North American Vertical Datum of 1988 NWI National Wetlands Inventory PCB polychlorinated biphenyl RTE rare, threatened, or endangered SCORP Statewide Comprehensive Outdoor Recreation Plan TFH Turners Falls Hydro, LLC TMDL total maximum daily load USDA U.S. Department of Agriculture USGS U.S. Geological Survey
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1 GENERAL DESCRIPTION OF PROJECT LOCALE
The Turners Falls Hydroelectric Project (Project, or TFH) is located on the Turners Falls Power Canal (Power Canal), which is situated adjacent to the Connecticut River, in the Town of Montague, Franklin County, Massachusetts (Figure 1-1). The Project lies within the Connecticut River basin, which covers approximately 11,250 square miles. The Connecticut River is the largest river in New England and generally flows north to south. The Connecticut River begins in the Connecticut Lakes region near the U.S.-Canada border and flows approximately 410 miles south to Long Island Sound. The Power Canal is owned and operated by FirstLight Hydro Generating Company (FirstLight) as a part of their Turners Falls Hydroelectric Project (Federal Energy Regulatory Commission [FERC] Project No. 1889). The Power Canal begins at a gatehouse at the upstream end of the Power Canal adjacent to the Turners Falls Dam, also owned and operated by FirstLight. At the Turners Falls Dam the drainage area of the basin is approximately 7,160 square miles. The Power Canal is approximately 2.1 miles long and ranges in width from 40 feet at the upstream end near the Project to 300 feet at the downstream end. Situated on the Power Canal are three hydroelectric generating stations: Turners Fall Hydro (FERC Project No. 2622), Station No. 1 (FERC Project No. 1889), and Cabot Station (FERC Project No. 1889). Two other water users withdraw water from the Power Canal: the Southworth Company (Paperlogic) and the U.S. Geological Survey (United States Geological Survey [USGS] Conte Anadromous Fish Laboratory). Land use in the Connecticut River watershed is approximately 77% forested, 9% agricultural, 7% wetlands, and 7% developed. Land use is generally rural agrarian and undeveloped at the headwaters in northern Vermont and New Hampshire, transitioning to densely populated urban areas in the south-central river valley in Connecticut (FirstLight, 2016a). Land use in the general area of the Project is predominantly industrial and water.
1.1 Topography The Project is located in the New England Upland section of the New England physiographic Province in Massachusetts, and the Connecticut River Valley is the dominant feature in the section. The topography of the Connecticut River Valley is mostly level to rolling, with some higher hills (FirstLight, 2016a). The Connecticut River Valley in the vicinity of the Project is generally narrow, rising sharply from approximately 120 feet to 300 feet NAVD88 over 0.1 miles along the river right bank. Along the river’s left bank within the village of Turners Falls elevations gradually rise from approximately 120 feet to 300 feet NAVD88 over 0.5 miles.
1.2 Bedrock Geology The bedrock geology of the Project, including the Power Canal, is entirely Mesozoic basin sedimentary rock of the Mount Toby Formation. Bedrock of the Mount Toby Formation are reddish brown to pale red arkosic sandstone, gray sandstone, gray siltstone, and black shale interpreted as an ancient lake bed formed during the lower Jurassic period (USGS, n.d.).
1.3 Surficial Geology and Soils Surficial geology of the Project area is exposed bedrock and a thin layer of artificial fill, as the Project is situated in an existing mill building constructed on a man-made berm between the Connecticut River and the Power Canal. Soil of the Project area consists entirely of the Udorthents-Urban land complex (Figure 1.3-1). Urdorthents-Urban land complexes consist of moderately well-drained to excessively well-drained soils that have been disturbed by cutting and filling, and covered by buildings or pavement (USDA, n.d.). Slopes of Udorthents soils can be very steep, but the Urban complex usually has a slopes of 0 to 5%.
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Typical of Urdorthents-Urban land complexes are eroded areas without vegetation. The area of the Project is almost entirely building with bedrock banks with little vegetation; therefore, erosion is negligible.
1.4 Vegetative Cover The Project is located within the Connecticut River Valley ecoregion. This ecoregion is mostly urban and built up but also has croplands, pasture, and oak-hickory and maple-beech-birch forest in higher elevations (MassAudubon, 2018). In the vicinity of the Project the land cover is entirely urban and built up with little vegetative cover. The limited vegetative cover occurs near the tailrace along the shoreline of the Connecticut River bypassed reach. This area has flood-tolerant species, such as alders and willow, intermingled with a variety of sedges and forbs.
1.5 Climate The climate in the Project area is a humid continental climate with warm summers and cold winters. This climate type is found over large areas of land masses in the temperate regions of the mid-latitudes where there is a zone of conflict between polar and tropical air masses. The humid continental climate is marked by variable weather patterns and a relatively large seasonal temperature variability. The highest air temperature of the area is approximately 95°F and ranges from 89 to 101°F. The lowest air temperature of the area is approximately -7°F and ranges from -17 to 6°F. The average annual air temperature is 48°F. Both precipitation and snowfall average 48 inches (Table 1.5-1).
1.6 Population Size and Density The Project is located within the unincorporated village of Turners Falls in the Town of Montague, Franklin County, Massachusetts. According to the U.S. Census Bureau (U.S. Census, 2010a, 2010b), the population of Turners Falls and Montague, MA, were 4,470 and 8,437, respectively. The population of Franklin County is 71,372 (U.S. Census, 2010c). Turners Falls and Montague, Massachusetts, have an area of approximately 2.3 and 31.5 square miles, respectively. Therefore, the population density of Turners Falls is 1,944 persons per square mile, and the population density of the Town of Montague is 268 persons per square mile.
1.7 Regional Socioeconomics In Franklin County, approximately 59,500 of people 16 years or older are employed. The per capita and median household income are $31,689 and $56,347, respectively. Approximately 11.3% of all people in Franklin County live at or below the federal poverty level (U.S. Census Bureau, n.d.). Some of the larger employers in the Project vicinity include the Greenfield Community College (Greenfield, MA), Yankee Candle (Whately, MA), Cooley Dickinson Hospital (Northampton, MA), Smith College (Northampton, MA), and the University of Massachusetts Amherst (Amherst, MA) (FirstLight, 2016a).
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Table 1.5-1. Climate of the Project area.1
Annual Annual Annual Annual Total Annual Total Average Air Maximum Air Minimum Air Statistic Precipitation Snowfall Temperature Temperature Temperature (inches) (inches) (°F) (°F) (°F)
Mean 48.0 48.0 48 94.6 -7.4
Maximum 61.4 71.9 51.3 101.0 6.0
Minimum 35.6 19.8 42.8 89.0 -17.0
1. Data presented for January 2000 through June 2018. Source: NOAA (2018)
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Figure 1-1. Location of the Turners Falls Hydroelectric Project.
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Figure 1.3-1. Soils of the Project area.
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2 WATER RESOURCES
2.1 Water Quantity The Project is situated on the Turners Falls Power Canal. The Power Canal is owned and operated by FirstLight as a part of their Turners Falls Hydroelectric Project (FERC Project No. 1889). The Power Canal receives waters from the Connecticut River via FirstLight’s Gatehouse adjacent to their Turners Falls Dam at the head of the Power Canal (Figure 1.1). The drainage area at the dam is approximately 7,163 square miles (FirstLight, 2016a). Table 2.1.1-1 presents the estimated mean and median Connecticut River flow at the Turners Falls Dam, and Figures 2.1-1 to 2.1-5 present annual and monthly flow duration curves for Connecticut River flows at the Turners Falls Dam. The Power Canal is approximately 2.1 miles in length and ranges in width from 120 feet near the upstream end to approximately 920 feet near the downstream end. Under normal operations the Power Canal has an elevation of 173.5 feet and varies in depth from approximately 17 feet near the upstream end to 30 feet at the downstream end. The design hydraulic capacity of the canal is approximately 18,000 cubic feet per second (cfs) (FirstLight, 2016a). Monthly median flows through the Power Canal range from 3,000 to 16,000 cfs. Figures 2.1-6 through 2.1-10 provide annual and monthly Power Canal flow duration curves. The Power Canal bypasses a 2.1-mile stretch of the Connecticut River — from the base of Turners Falls Dam to the tailrace of FirstLight’s Cabot Station at the end of the Power Canal. The existing FERC license for FirstLight’s Turners Falls Hydroelectric Project (FERC No. 1889) requires FirstLight to provide a minimum flow to the bypassed portion of the Connecticut River. The minimum flow requirement is specified in Article 34 and consists of a continuous minimum flow of 200 cfs to be maintained in the bypassed reach starting on May 1, and increases to 400 cfs when annual fish passage at the Turners Falls Project begins. The minimum flow is released through a bascule gate at the Turners Falls Dam. The 400-cfs continuous minimum flow is provided through July 15, unless the upstream fish passage season has concluded early, in which case the 400-cfs flow is reduced to 120 cfs to protect shortnose sturgeon. The 120-cfs continuous minimum flow is maintained in the bypassed reach from the date the fishways are closed (or by July 16) until the river water temperature drops below 7°C, which typically occurs around November 15 (FirstLight, 2016a). TFH has no minimum flow requirements for the project.
2.2 Water Use Four entities use waters of the Power Canal, including TFH. Table 2.1.2-1 lists the Power Canal water users from upstream to downstream, and Figure 2.2-1 shows the location of the water users. TFH has indentured water rights to waters of the Power Canal. Since September 28, 1951, a water use agreement between FirstLight and TFH (or their predecessors) has been in place. The water use agreement dictates that TFH can operate when Connecticut River flows as measured at the Turners Falls Dam exceed 15,000 cfs and operating needs of FirstLight Station No. 1 and Cabot Station have been met. When operating, TFH uses 289 cfs for hydroelectric generation and does not fluctuate its water use. Paperlogic also has a similar agreement with FirstLight, and the USGS also has an agreement with FirstLight, but their water use is minimal (FirstLight, 2016a).
2.3 Water Quality
2.3.1 Water Quality Standards Massachusetts Surface Water Quality Standards (314 CMR 4.00) defines the Connecticut River in the vicinity of the Project (Turners Falls Dam to Holyoke Dam) as a Class B, warm water fishery with
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combined sewer over flows (Massachusetts Department of Environmental Protection [MassDEP], 2013).1 Class B waters are designated as a habitat for fish, other aquatic life, and wildlife, including their reproduction, migration, growth, and other critical functions; and for primary and secondary contact recreation. They can be suitable as a source of public water supply after suitable treatment. Class B waters are also suitable for irrigation and other agricultural uses and for compatible industrial cooling and process uses (MassDEP, 2013). Applicable water quality standards for the reach of the Connecticut River that encompasses the Project are listed in Table 2.3.1-1.
2.3.2 Water Quality Assessment and Impairments Every two years the MassDEP submits to the Environmental Protection Agency (EPA) a document called the “Integrated List” to comply with sections 303(d) and 305(b) of the Clean Water Act. The most recent Integrated list is the “Massachusetts Year 2016 Integrated List of Waters” (MassDEP, 2016). MassDEP divides waterbodies of the Commonwealth into segments for the purpose of determining water quality uses and impairments. The waterbody segment that encompasses the Project is MA34-03, which extends 3.7 miles from the Turners Falls Dam to the Connecticut River and Deerfield River confluence. MassDEP lists this segment of the Connecticut River as impaired (Category 5-Waters Requiring a total maximum daily load [TMDL]) because of Escherichia coli, polychlorinated biphenyl (PCB) in fish tissue, and total suspended solids (MassDEP, 2016). MassDEP (2016) also lists the river segment as impaired because of “low flow alterations” and “other flow regime alterations;” however, a TMDL is not required for these impairments. The concern of elevated PCB levels in fish tissue is addressed by the Massachusetts Department of Health and Human Services fish consumption advisory for the entire length of the Connecticut River within Massachusetts, from Northfield to Longmeadow, Massachusetts (Massachusetts Department of Health and Human Services [MassDHHS], 2017). MassDEP plans to address the issue of elevation bacteria levels (Escherichia coli) by preparing, as resources allow, a watershed-wide bacteria TMDL for the Connecticut River basin (MassDEP, 2016). MassDEP has not prepared a schedule of when the TMDL will be completed and provided to the EPA for approval.
2.3.3 Historical and Existing Water Quality Data FirstLight (2016a) presents a detailed summary of the historical water quality data collected in the vicinity of the Project. The summary includes a discussion of extensive, historical water quality sampling of the Connecticut River conducted by MassDEP in 2003, Connecticut River Watershed Council volunteer monitoring, USGS water quality monitoring, a Long Island Sound TMDL Study, and an EPA Connecticut River Fish Tissue Contaminant Study. Existing and recent water quality for the Project area was collected as a part of the FERC-approved relicensing study plan for FirstLight’s Turners Falls Hydroelectric Project (FERC No. 1889) in 2015 (FirstLight, 2013; FERC, 2014). The purpose of the water quality study was to document baseline water quality conditions including water temperature, dissolved oxygen (DO), and other water quality parameters upstream and downstream of the FirstLight’s Turners Falls (FERC No. 1889) and Northfield Mountain (FERC No. 2485) hydroelectric projects. The study included 18 monitoring stations with one monitoring station within the Power Canal and two within the bypassed reach (Figure 2.3.3-1). The data collected at the three stations consisted of continuously recorded (every 15 minutes) water temperature and DO.
1 The Holyoke Dam is the next downstream dam on the Connecticut River and is located about 36 miles downstream of the Turners Falls Dam in the City of Holyoke, Massachusetts.
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Table 2.3.3-1 provides summary statistics for the continuous water temperature and dissolved oxygen monitoring within the Power Canal and bypassed reach. Maximum water temperatures of the Project area reached 27.4°C, and the lowest DO level measured in the Project area was 6.1 mg/L. FirstLight (2016b) also observed that in the bypassed reach and Power Canal, water temperature and DO level exhibit natural diurnal fluctuations. Collectively, these data indicate that waters of the Connecticut River are consistent with Massachusetts State Surface Water Quality Standards for water temperature and DO.
2.4 Environmental Impacts on Water Resources Existing water quality data indicate that waters of the Project area are consistent with state surface water quality standards under current project operations, which include the flexibility to continuously operate. Because no changes in project operation as currently licensed are proposed, there would be no adverse effects on water resources during the next license term
2.5 Proposed Measures to Enhance, Protect, or Mitigate Effects on Water Resources Because there would no adverse effects on water resources, TFH is not proposing any PME measures related to water resources.
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Table 2.1.1-1. Estimated mean and median monthly and annual Connecticut River flow at the Turners Falls Dam.
Month Mean Flow (cfs) Median Flow (cfs)
January 10,242 7,963
February 9,682 7,711
March 18,514 13,200
April 34,713 30,238
May 19,680 17,316
June 11,887 8,900
July 8,432 4,965
August 7,549 4,147
September 6,267 4,059
October 11,710 6,058
November 13,810 9,845
December 14,793 9,613
Annual 14,079 8,489
Source: FirstLight (2016a) Exhibit E Table 3.3.2.1.1-4 as modified by TFH.
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Table 2.1.2-1. Water users of the Turners Falls Power Canal.
Approximate Hydraulic FERC User Entity Capacity (cfs) Project No.
Turners Falls Turners Falls Hydro, LLC 289 2622 Hydroelectric Project
Paperlogic Southworth Paper 113 Not Applicable
Station No. 1 FirstLight 2,210 1889
USGS Conte Anadromous USGS Variable Not Applicable Fish Laboratory
Cabot Station FirstLight 13,728 1889
Source: FirstLight (2016a) Exhibit A Table 1.4-1 as modified by TFH.
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Table 2.3.1-1. Applicable surface water standards for Class B Warm Water Fisheries designated waters of the Connecticut River in the vicinity of the Project.
Parameter Class B Warm Water Fishery Surface Water Quality Standards
Dissolved Oxygen Not less than 5.0 mg/l in warm water fisheries. Where natural background conditions are lower, DO shall not be less than natural background conditions. Natural seasonal and daily variations that are necessary to protect existing and designated uses shall be maintained.
Water Temperature Shall not exceed 83°F (28.3°C) in warm water fisheries. The rise in temperature caused by a discharge shall not exceed 5°F (2.8°C) in rivers and streams designated as warm water fisheries (based on the minimum expected flow for the month). Natural seasonal and daily variations that are necessary to protect existing and designated uses shall be maintained. There shall be no changes from natural background conditions that would impair any use assigned to this Class, including those conditions necessary to protect normal species diversity, successful migration, reproductive functions, or growth of aquatic organisms. pH Shall be in the range of 6.5 through 8.3 standard units and not more than 0.5 units outside of the natural background range. There shall be no change from natural background conditions that would impair any use assigned to this Class.
Bacteria The geometric mean of all E. coli samples taken within the most recent six months shall not exceed 126 colonies per 100 ml typically based on a minimum of five samples, and no single sample shall exceed 235 colonies per 100 ml; alternatively, the geometric mean of all enterococci samples taken within the most recent six months shall not exceed 33 colonies per 100 ml typically based on a minimum of five samples, and no single sample shall exceed 61 colonies per 100 ml.
Solids Shall be free from floating, suspended, and settleable solids in concentrations and combinations that would impair any use assigned to this Class, that would cause aesthetically objectionable conditions, or that would impair the benthic biota or degrade the chemical composition of the bottom.
Color and Shall be free from color and turbidity in concentrations or combinations that are Turbidity aesthetically objectionable or would impair any use assigned to this Class
Oil and Grease Shall be free from oil, grease, and petrochemicals that produce a visible film on the surface of the water, impart an oily taste to the water, or an oily or other undesirable taste to the edible portions of aquatic life, coat the banks or bottom of the water course, or are deleterious or become toxic to aquatic life.
Taste and Odor None in such concentrations or combinations that are aesthetically objectionable, that would impair any use assigned to this Class, or that would cause tainting or undesirable flavors in the edible portions of aquatic life.
Source: MassDEP (2013) as modified by TFH.
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Table 2.3.3-1 Minimum, maximum, and average water temperature and dissolved oxygen within the Turners Falls Power Canal and Connecticut River bypassed reach during the spring, summer, and fall of 2015.
Connecticut River Bypassed Reach Power Canal Statistic Site 8 Site 9 Site 10 Upstream of Station No. 1 Rawson Island Power Canal
Water Temperature (°C)
Maximum 27.4 27.4 26.7
Minimum 0.9 1.0 0.9
Average 17.0 17.0 17.3
Dissolved Oxygen (mg/L)
Maximum 16.1 11.6 10.9
Minimum 6.1 6.9 6.4
Average 9.4 8.9 8.6
Dissolved Oxygen (percent saturation)
Maximum 181.3 128.5 111.2
Minimum 71.9 78.9 78.7
Average 106.9 101.0 98.7
Source: FirstLight (2016a) Relicensing Study 3.2.1 Study Report, Table 3.3-1 as modified by TFH.
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Source: FirstLight (2016a) Figure 2.1-1. Connecticut River annual flow duration curve at Turners Falls Dam, January 1941 to December 2014.
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Source: FirstLight (2016a) Figure 2.1-2. Connecticut River January, February, and March flow duration curves at Turners Falls Dam, January 1941 to December 2014.
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Source: FirstLight (2016a) Figure 2.1-3. Connecticut River April, May, and June flow duration curves at Turners Falls Dam, January 1941 to December 2014.
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Source: FirstLight (2016a) Figure 2.1-4. Connecticut River July, August, and September flow duration curves at Turners Falls Dam, January 1941 to December 2014.
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Source: FirstLight (2016a) Figure 2.1-5. Connecticut River October, November, and December flow duration curves at Turners Falls Dam, January 1941 to December 2014.
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Source: FirstLight Power Resources (2012) Figure 2.1-6. Annual flow duration curve for the Turners Falls Power Canal (hourly 2000-2009).
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Source: FirstLight Power Resources (2012) Figure 2.1-7. January, February, and March flow duration curves for the Turners Falls Power Canal (hourly 2000-2009).
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Source: FirstLight Power Resources (2012) Figure 2.1-8. April, May, and June flow duration curves for the Turners Falls Power Canal (hourly 2000-2009).
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Source: FirstLight Power Resources (2012) Figure 2.1-9. July, August, and September flow duration curves for the Turners Falls Power Canal (hourly 2000-2009).
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Source: FirstLight Power Resources (2012) Figure 2.1-10. October, November, and December flow duration curves for the Turners Falls Power Canal (hourly 2000-2009).
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Figure 2.2-1. Location of Turners Falls Power Canal water users.
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Figure 2.3.3-1. Location of FirstLight (2016) water quality monitoring stations in relation to the Project.
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3 AQUATIC AND FISHERIES RESOURCES
3.1 Aquatic Habitat Aquatic habitat of the Project area is limited to the Power Canal immediately upstream of the Project intake and the bypassed reach immediately downstream of the Project tailrace. Figures 3.1-1 to 3.1-3 are pictures of the Power Canal upstream of the Project intake in watered and dewatered states. The Power Canal in the vicinity of the Project intake is approximately 17 feet in depth, has mostly scoured bedrock ledge with some boulder and larger cobble-sized substrate, and has high water velocity. Figures 3.1-4 to 3.1-6 are pictures of the Project tailrace and the Connecticut River bypassed reach. The bypassed reach has a low gradient (approximately 0.3%); it contains mostly bedrock, boulder, cobble, and gravel substrates; and it is primarily composed of pool mesohabitat, followed by riffle and backwater types (FirstLight, 2016a). In the immediate vicinity of the Project the bypassed reach is pool habitat with cobble substrate (FirstLight, 2016a). The bypassed reach has a minimum flow requirement as discussed in section 2.1. FirstLight is responsible for providing the minimum flow in the bypassed reach, and TFH has no minimum flow requirements under its existing license.
3.2 Fisheries
3.2.1 Fish Community The fish community of the Project area is considered a warm water fishery and consists of resident and migratory species. Fish sampling of the Power Canal and bypassed reach was performed by FirstLight as a part of the Turners Falls Hydroelectric Project (FERC No. 1889) relicensing effort and is summarized below. Power Canal In 2014, during the annual Power Canal drawdown at the end of September and the first week of October, FirstLight surveyed the lower Power Canal for stranded fish and sampled hydrologically connected pools using backpack electrofishing and seining (FirstLight, 2015b). Table 3.2.1-1 presents the fish species observed and their relative abundance during two sampling events. Overall, 22 species were collected, which included 19 resident species and 3 diadromous species (American shad, American eel, and sea lamprey). The three most common species present were spottail shiner, American shad, and the tessellated darter. All the American shad individuals were emigrating juveniles. Bypassed Reach In September 2015, FirstLight performed boat electrofishing in the bypassed reach at four locations from the Turners Falls Dam downstream 1.9 river miles to a natural geologic feature known as Rock Dam; two locations were sampled upstream and downstream of FirstLight’s Station No. 1 (FirstLight, 2015b). Table 3.2.1-2 presents the results of FirstLight boat electrofishing sampling of the bypassed reach. In total, 269 individuals were collected, with smallmouth bass the most common species, accounting for 62.5% of the catch, followed by American eel and bluegill, which accounted for 9.7% and 8.2% of the catch, respectively.
3.2.2 Migratory Species In the vicinity of the Project, the Connecticut River supports several migratory species, both anadromous and catadromous species, which include American shad, blueback herring, sea lamprey, and American eel.
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American Shad American shad are a large anadromous herring and migrate into the lower Connecticut River during late March or April, reaching the Project area in late April or early to mid-May as they move upstream to spawn. In 2017, an estimated 48,727 adult American shad successfully passed upstream of the Turners Falls Dam (U.S. Fish and Wildlife Service [FWS], 2017). American Shad tend to spawn in areas dominated by runs and glides, 3 to 18 feet deep. They have been observed to spawn over a variety of substrates but prefer sand and gravel bottom (Stier and Crance, 1985). This type of habitat most closely corresponds to the runs and glides occurring downstream of FirstLight’s Cabot Station, but it is very limited in the bypassed reach and Power Canal. As a part of FirstLight’s Study No. 3.3.6, Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects, American shad were observed to spawn within a pool of the bypassed reach 1.5 miles downstream of the Project and in the Power Canal approximately 1.0 miles downstream of the Project where the Power Canal begins to widen (FirstLight, 2016a). Tracking of adult American shad through the Power Canal was performed by FirstLight as a part of Turners Falls Hydroelectric Project (FERC No. 1889) relicensing effort (FirstLight, 2016c, 2017a). FirstLight used radio-telemetry to monitor shad passage through the Power Canal at five locations. Two of the locations encompassed the Project, at the Power Canal Gatehouse entrance at the head of the canal, and 1,200 feet downstream of the Power Canal Gatehouse, at the bridge immediately downstream of the Project. FirstLight estimated that 92% of American shad migrating upstream that arrive at the station immediately downstream of the Project successfully pass by the Project and are subsequently detected at the Power Canal Gatehouse (FirstLight, 2017a). In addition, FirstLight estimated that 100% of adult American shad that emigrate through the Power Canal also successfully passed by the Project (FirstLight, 2017a). FirstLight also tracked American shad attempting migration through the bypassed reach. They determined that the median travel time for shad to move through the bypassed reach and reach the Turners Falls Dam spillway was 1.18 days and that Rock Dam was a significant impediment to American shad upstream movement within the bypassed reach (FirstLight, 2017, 2016a). When flows in the bypassed reach increased, shad movement through the bypassed reach appeared to increase, with peak movement occurring when flows in the bypassed reach were around 4,000 cfs (FirstLight, 2017a). Juvenile shad in the vicinity of the Project emigrate during mid-summer through late fall (FirstLight, 2016d). FirstLight performed a study in which juvenile shad were tagged and tracked through the Power Canal from August 1 through mid-November as a part of their Turners Falls Hydroelectric Project (FERC No. 1889) relicensing effort (FirstLight, 2016d). FirstLight concluded that the likelihood of juvenile shad passage survival through the Power Canal would likely be greater than passage over the Turners Falls Dam. In addition, of 183 tagged juvenile shad that were released into the Turners Falls impoundment, 16 were determined to enter the Power Canal. Four of the 16 were subsequently determined to move downstream of the Gatehouse through the Power Canal. Of the four, all passed and were detected downstream of the Project (FirstLight, 2016d). This would indicate that juvenile shad passage downstream through the Power Canal is likely unaffected by the Project. It is important to note, however, that FirstLight determined that tagged juvenile shad exhibited high mortality, tag loss, and atypical swimming behavior (FirstLight, 2016d). As a result, FirstLight is considering repeating the study in 2019 and is presently exploring options that would prevent juvenile shad from emigrating through the Power Canal, ameliorating any effect Project operations would have on juvenile shad (FirstLight, 2018). Blueback Herring Blueback herring is an anadromous herring but smaller than American shad. Blueback herring enter the Project area about the same time as American shad but in significantly fewer numbers. In fact, in 2017, only 875 blueback herring passed Holyoke Dam and zero passed Turners Falls Dam; few blueback herring have been recorded in the Project area since the 1990s (FWS, 2017; FirstLight, 2016a). Blueback
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Herring broadcast spawn on hard substrate in swift-flowing tributaries of the lower Connecticut River. Presumably, some spawning also occurs in the mainstem Connecticut River, where swift-flowing habitats with hard substrate are available (Hartel et al., 2002). Most of the suitable spawning habitat for blueback herring is located downstream of FirstLight’s Cabot station, with some suitable areas in the bypassed reach and below Turners Falls Dam (FirstLight, 2016a). Juvenile blueback herring emigrate from the Connecticut River in the fall, slightly earlier than American shad. Sea Lamprey The sea lamprey is an anadromous species that spawns in the Connecticut River and its tributaries in the spring in shallow areas of moderate current with gravel, sand, and cobble substrate. Pre-spawning adults create depressions in the substrate called redds by carrying larger rocks out of the nest area and by sweeping smaller particles out using rapid body movements. The female then deposits eggs, fertilized by the male. Additional redd construction and spawning may continue for up to 3.5 days; however, adults usually die shortly after spawning. After hatching and subsequent to the larval stage, sea lamprey mature into what are called ammocoetes. The ammocoetes then burrow into soft sediments and filter feed. Sea lamprey remain as ammocoetes for up to seven years before metamorphosing into transformers, the migration life stage which is similar to the adult form and migrating to the sea. In 2017, 21,526 sea lamprey passed Holyoke Dam and 9,257 reached and passed the Turners Falls Dam. Furthermore, in 2015, First Light tagged and tracked sea lamprey through the Project area to assess sea lamprey spawning and map their spawning habitat (FirstLight, 2016g). Data collected from this study indicated that sea lamprey are able to successfully pass by the Project and spawn near the Fall River confluence within the bypassed reach (0.5 miles upstream of the Project tailrace), and at locations upstream of Turners Falls Dam. FirstLight did not document spawning near the Project tailrace or within the Power Canal, but ammocoetes were collected in the lower Power Canal near FirstLight’s Cabot station during the 2014 Power Canal drawdown (FirstLight, 2015b). American eel The American eel is a catadromous species whose young enter into estuarine or freshwater environments to grow and mature and then emigrate to the ocean to spawn. American eel spawn in a location in the Atlantic Ocean known as the Sargasso Sea. Young eels eventually move into coastal areas and actively swim into estuaries and/or farther inland into freshwater streams and rivers during the spring. These young eels are called glass eels because of their small, transparent appearance. Once the glass eels develop pigmentation, they are referred to as elvers until they gain the yellow cast typical of eels. These young eels remain in freshwater environments typically for five to as much as 20 years until they mature. At maturation, the species undergoes another color change to the silver eel phase and migrates downstream, usually at night during fall. In the Project area young eels typically arrive during the late spring and early summer, with most of the upstream migration occurring in July (FirstLight, 2015a). Mature eels emigrate through and out of the Project area at night during the fall. In 2014, FirstLight conducted nighttime surveys every one to two weeks beginning in June and ending in October to observe the presence/absence of young eels migrating through the Project area (FirstLight, 2015a). This survey was a part of a study to evaluate upstream eel passage for the relicensing of FirstLight’s Turners Falls Hydroelectric Project (FERC No. 1889). The survey area included FirstLight’s Cabot Station, USGS Conte Lab, FirstLight’s Station No. 1, Turners Falls Dam Spillway, the Turners Falls Dam, and the Project’s tailrace. Results of the survey indicated that eels were observed at FirstLight’s Cabot Station and the Turners Falls Dam Spillway fishway but not at the Project tailrace (FirstLight, 2015a). In 2015 and 2016, A DIDSON camera was used to monitor the downstream migration of adult silver phase American eel in the Turners Falls Power Canal between August 1 and November 15. Eel passed sporadically throughout the study period during both years, peaking in early August during 2015 and mid-
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October during 2016. FirstLight estimated that a total of 2,382 and 2,273 silver eel passed through the canal during 2015 and 2016, respectively (FirstLight, 2017b). In addition, a total of 134 and 165 silver eels were tagged with radio telemetry tags and released in the Connecticut River upstream of the Turners Falls and Vernon Dams, respectively (FirstLight, 2017b).2 Radio telemetry tracking of the eels indicated that a total of 87 tagged fish entered the Turners Falls Power Canal, and 83% (72 fish) that entered the Power Canal escaped via the Cabot Powerhouse, 8% (7 fish) escaped via the downstream bypass adjacent to the Cabot Powerhouse, 3% (3 fish) escaped via Station 1 Powerhouse, and the remaining 5 fish were detected downstream of the project but had undetermined passage routes (FirstLight, 2017b). Therefore, FirstLight concluded that all of the tagged silver eels that entered the Power Canal escaped. (FirstLight, 2017b). By extension, all silver eels that entered the Power Canal successfully bypassed the Project. Tracking of eel through the Project area indicates that emigrating silver eel were much more likely to move at night, and especially during rain events. Passage through the Power Canal typically took 0 to 6 hours (FirstLight, 2017b). Shortnose Sturgeon Shortnose sturgeon is a federally listed endangered species that is known to occur in the vicinity of the Connecticut River bypassed reach and typically inhabits slow-moving riverine waters or near-shore marine waters and periodically migrates into faster moving fresh water areas to spawn. Because the Shortnose sturgeon is a federally list species, shortnose sturgeon is discussed in Section 7.0, Rare, Threatened, and Endangered Species.
3.2.3 Fish Passage There are no fish passage facilities at the Project, but the existing license does require fish passage protection measures. Within the current license, license article 401, required the licensee to install a trashrack with bar spacing that shall not exceed 1 inch and the intake velocity shall not exceed an average of 0.68 fps, as estimated within 3 inches of the face of the trashrack. Section 3.4 Fisheries Resources Study Requests and Results below discusses the history of and existing Project trashracks. FirstLight provides volitional fish passage facilities at Cabot Station, Turners Falls Dam, and the Gatehouse using Ice Harbor and vertical slot fish ladders.
3.3 Freshwater Mussels In 2011, a freshwater mussel survey was conducted in a 3.5-mile reach from Turners Falls Dam to the confluence with the Deerfield River (2.7 of the 3.5 miles are in the bypassed reach), as well as 2.1 miles of the power canal. The objective of the survey was to assess the distribution, abundance, and habitat of freshwater mussels. The bypassed reach surveys were conducted during low flow in August, and the Power Canal survey was conducted during the September canal drawdown. Five freshwater mussel species were found, including the Eastern Elliptio, Alewife Floater, Eastern Floater, and Triangle Floater. The Eastern Elliptio was more abundant than other species. One Triangle Floater was found near the mouth of the Deerfield River. Mussels were found in a wide range of water depths, flow conditions, and substrate conditions.
3.4 Fisheries Resources Study Requests and Results In 2007, the former licensee (Swift River Hydro) replaced the installed trashracks prior to Eagle Creek’s acquisition of the Project. Through document review after acquisition, no design drawings were uncovered. As such it was unknown to TFH whether the existing trashracks were compliant with Article 401 of the current license. This issue was discussed with the resource agencies at the Joint Meeting held
2 Vernon Dam is the next dam on the Connecticut River upstream of FirstLight’s Turners Falls Dam. The Vernon Dam is owned and operated by Great River Hydro, LLC (formerly TransCanada).
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on February 7, 2017. Subsequent to the Joint Meeting the resource agencies provided Turners Falls with study request that concerned the existing trashracks. The National Marine Fisheries Services requested that TFH perform a desktop study to estimate entrainment and impingement rates, and turbine passage survival of American shad, American eel, and sea lamprey at the Project. In addition, the U.S. Fish and Wildlife Service (FWS) requested a similar study but following a phased approach. Phase 1 would be investigating existing trashrack clear spacing and intake velocity. If the velocities were determined to be less than 1.5 feet per second (fps) and the clear spacing no more than ¾ inch, then no further study would be required. If not, phase 2 would proceed with the desktop assessment as requested. Phase 3 would be for TFH to explore different protection measures to mitigate entrainment, impingement, and turbine mortality at the Project. TFH subsequently proceeded to investigate the existing trashrack dimensions and estimate the existing intake velocities. Field investigation of the existing trashrack occurred on September 21, 2017, during FirstLight’s annual Power Canal drawdown. Measurements of the existing trashrack included canal entrance opening dimensions (width, height), intake opening (width, height), trashrack dimensions (width, height), number of vertical bars, vertical bar thickness, vertical bar clear spacing, number of horizontal bars, horizontal bar thickness, horizontal bar clear spacing, number of supporting vertical beams, number of horizontal supporting beams, and horizontal supporting beam dimensions. Table 3.3-1 presents the existing trashrack configuration, and Figure 3.3-1 shows a picture of the existing trashrack. Given the existing configuration, the intake velocity was estimated to be 0.96 fps and the clear spacing averaged 1.3 inches. Rather than proceed with the Phase 2 desktop study, TFH elected to proceed to Phase 3 and conceptually design and estimate the intake velocity of a trashrack with ¾-inch spacing (Table 3.3-2). Given the existing supporting structure and overall existing trashrack dimensions (width and height), TFH estimated that a trashrack with ¾-inch clear spacing would have 214 vertical bars and have an estimated intake velocity of 1.13 fps. Because a trashrack with ¾-inch clear spacing configuration would produce an intake velocity less than 1.5 fps, TFH did not further investigate entrainment, impingement, and turbine mortality for the Project and instead is considering the installation of trashracks with ¾ inch clear spacing as discussed in section 3.5, Proposed Measures to Enhance, Protect, or Mitigate Effects on Aquatic and Fisheries Resources.
3.5 Environmental Impacts on Aquatic and Fisheries Resources
3.5.1 Aquatic Habitat Aquatic habitat in the vicinity of the Project is limited to the Power Canal immediately upstream of the Project intake, the tailrace, and a small portion of the Connecticut River bypassed reach. Water level and flow in the Power Canal are controlled and regulated by FirstLight; therefore, the Project cannot affect aquatic habitat within the Power Canal. When the Project is not operating, leakage keeps the tailrace apron wetted, as shown in Figure 3.1-4. A minimum flow in the Connecticut River bypassed reach is provided by FirstLight, and the amount of available aquatic habitat in the bypassed reach is therefore largely determined by FirstLight’s minimum flow and other releases and operation at their Turners Falls Dam. When the Project is operating, an additional 289 cfs is provided to the bypassed reach, which likely only provides a marginal increase in available aquatic habitat. Because TFH is not proposing a change in operations as currently licensed, effects on aquatic habitat during the next license terms would reflect existing conditions.
3.5.2 Resident Fish The Power Canal and Connecticut River bypassed reach in the vicinity of the Project currently support a diverse warm water fish community. Flow and water levels of the Power Canal are controlled by FirstLight, and therefore, TFH has no effect associated with flow and fluctuating water levels on the
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resident fish community in the Power Canal. When the Project is operating, resident fish could become entrained and/or impinged at the Project intake and trashrack. However, estimated intake water velocities in front of the current trashracks are low, less than 1.0 fps, which is lower than the burst swimming ability of most of the resident species in the Power Canal, meaning that fish could avoid the trashracks. In addition, the canal entrance to the Project intake is small and Canal water velocities are typically high,3 reducing the probability of resident fish entering the canal entrance and Project intake. A minimum flow in the Connecticut River bypassed reach is provided by FirstLight, and the effects to resident fish within the bypassed reach is therefore mostly influenced by FirstLight’s operation of their Turners Falls Hydroelectric Project (FERC No. 1889). When TFH is operating, an additional 289 cfs is provided to the bypassed reach, which would benefit resident fish by providing additional flow and aquatic habitat. However, the effect of the additional 289 cfs in the bypassed reach is likely marginal because the Connecticut River bypassed reach is large and the 289 cfs would have minimal effects on wetted perimeter, water surface elevations, and aquatic habitat. Because TFH is not proposing a change in operations as currently licensed, which include the flexibility to continuously operate, effects on resident fish during the next license terms would reflect existing conditions.
3.5.3 Migratory Species The Connecticut River in the vicinity of the Project supports several migratory species, both anadromous and diadromous, which include American shad, blueback herring, sea lamprey, and American eel. Possible effects on these species include entrainment and impingement at the Project intake, turbine mortality, and false attraction at the Project tailrace. American Shad FirstLight’s data on adult American shad passage within the Power Canal indicates that 92% of the adult shad that enter the Project vicinity successfully migrate upstream past the Project. Those individual adults that venture near the area of the Project intake would be able to escape entrainment and impingement because of their swimming performance relative to the estimated low intake velocity of 0.96 fps. American shad have sustained and darting swim speeds that range from approximately 3.0 to near 14 fps (Bell, 1990). Therefore, entrainment and impingement of adult American shad at the Project would be unlikely. FirstLight’s adult American shad passage data through the bypassed reach indicate that Rock Dam is a significant impediment to upstream passage, that passage is improved when flows in the bypassed reach increase (up to 4,000 cfs), and that the median passage time in the bypassed reach was 1.18 days, with the middle 50% of the tagged fish (upper and lower quartiles) taking between 0.51 to 1.96 days to pass through the bypassed reach, respectively. Similarly, the median passage time of adult shad within the Power Canal is 0.92 days with the middle 50% (upper and lower quartiles) of the tagged fish taking 0.32 to 2.26 days, respectively. Therefore, because the passage time is similar between the Power Canal and bypassed reach, there is no indication that false attraction due to operation of the Project has any substantial effect on adult shad migrating upstream through the bypassed reach. Furthermore, FirstLight is currently required to pass 400 cfs during the shad migration season. At times during the migration, TFH provides an additional 289 cfs to the bypassed, which could benefit shad migrating upstream through the bypassed reach between the Project and FirstLight’s Station No. 1, particularly by improving passage conditions at Rock Dam. Preliminary juvenile shad tracking data collected by FirstLight indicate that most juvenile shad successfully pass by the Project. Juvenile shad passage by the Project is further influenced by the high water velocity near the Project’s canal entrance and the small canal entrance opening relative to the size
3 FirstLight reports the canal near the upstream end is about 120 feet wide and 17 feet deep (see section 2.1, Water Quantity). Therefore, at Power Canals design capacity of 18,000 cfs, the water velocity would be about 8.8 fps near the Project.
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of the Power Canal. In addition, any juvenile shad that enter the Project canal entrance could escape the current intake velocity of 0.96 fps because juvenile shad have documented sustained swim speeds ranging from 1.25 to 2.5 fps (Bell, 1990). Therefore, effects of entrainment, impingement, and turbine mortality at the Project are likely to be minor because of the high canal water velocities, small canal entrance, low intake velocity relative to juvenile shad swimming ability, and FirstLight’s data indicating that most juvenile successfully pass by the Project. Furthermore, TFH understands that FirstLight is considering installing a screen at the Power Canal gatehouse that would preclude juvenile shad from entering the Power Canal during their outmigration. If such a measure becomes a license condition for FirstLight’s Turners Falls Project, any issue that pertains to juvenile shad entrainment, impingement, and turbine mortality at the Project would be mitigated. Overall, shad passage data collected by FirstLight, configuration of the Project’s canal entrance relative to flow in the Power Canal, high flow velocities within the Power Canal, and the swimming ability of American shad suggest that the Project has little effect on upstream and downstream migrating adult and juvenile American shad. Because TFH is not proposing a change in operations as currently licensed, which include the flexibility to continuously operate, effects on American shad during the next license terms would reflect existing conditions. If FirstLight is required to install a screen precluding juvenile shad from entering the Power Canal during their outmigration, the very minor effects on juvenile shad at the Project would be mitigated. Blueback Herring Very few blueback herring have been recently documented in the Project vicinity. Therefore, the Project is not expected to affect blueback herring. Sea Lamprey FirstLight’s tracking data on adult sea lamprey indicate that they are able to successfully migrate upstream and bypass the Project. Bell (1990) reported prolonged and darting swimming speeds of lamprey to range from approximately 1.0 to 7.0 fps, respectively. Any adult sea lamprey that venture into the vicinity of the Project when it is operating would be able to escape the estimated intake velocity of 0.96 fps. Therefore, entrainment, impingement, and turbine mortality of adult sea lamprey at the Project are unlikely. Larval and juvenile lamprey that move downstream to suitable rearing habitat in the lower Power Canal, or are emigrating from the Project area through the Power Canal, would very likely bypass the Project because of the high water velocity in the upper Power Canal and not become entrained into the Project because of the small canal entrance and its orientation to flow. However, any juvenile sea lamprey that swim immediately in front of the trashrack structure could become entrained because, depending on size, they may not have the swimming ability to escape the 0.96 fps intake velocity. TFH believes that this is very unlikely because there is no suitable soft-sediment habitat near the project intake that juvenile lampreys would seek to rear and grow in before emerging and emigrating. Therefore, entrainment, impingement, and turbine mortality of juvenile sea lamprey at the Project are likely minor. American Eel Night time surveys performed by FirstLight near the Project tailrace indicate that juvenile American eel do not attempt to ascend at or become delayed at the Project. Therefore, continued operation of the Project is not expected to affect juvenile American eel moving upstream through the Connecticut River bypassed reach. Juvenile eel migrating upstream through the Power Canal are expected to pass by the Project. Any juvenile eel that do venture into intake area could become entrained because their reported swimming performance of < 0.5 fps is less than the estimate intake velocity of 0.96 fps (Bell, 1990). However, entrainment of juveniles is unlikely and likely very minor because juvenile eel are strongly influenced to migrate farther upstream to seek suitable rearing habitat, which does not occur near the Project intake.
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Tracking of adult outmigrating silver eels by FirstLight indicate that all eels that enter the Power Canal pass the Project intake opening and most (83%) pass downstream via FirstLight’s Cabot Station. Furthermore, Bell (1990) reported that adult eel (2 feet in length) have a darting swim speed of approximately 3 to 4 fps. Therefore, if an adult silver eel swims near the Project intake, they can overcome the Project’s 0.96 fps intake velocity and escape entrainment. Consequently, entrainment, impingement, and turbine mortality of adult American eel are likely negligible to minor. Overall, American eel passage data collected by FirstLight, configuration of the Project’s canal entrance relative to flow in the Power Canal, high flow velocities within the Power Canal, and the swimming ability of adult American eel suggest that the Project has little effect on upstream and downstream migrating adult and juvenile American eel. Because TFH is not proposing a change in operations as currently licensed, which includes the flexibility to continuously operate, effects on American eel during the next license terms would reflect existing conditions. If FirstLight is required to install a screen precluding juvenile shad from entering the Power Canal during their outmigration, it would also benefit outmigrating adult American eel and any possible effect of Project operations on adult American eel would be mitigated.
3.5.4 Freshwater Mussels FirstLight owns and operates the Power Canal and controls flow and water levels within the Power Canal. Therefore, operation of the Project has no effect on freshwater mussels within the Power Canal. Mussels within the bypassed reach are present in low densities (FirstLight Power Resources, 2012). Minimum flow within the Project bypassed reach is provided by FirstLight. When the Project is operating, an additional 289 cfs is provided to the bypassed reach, which likely only provides a marginal benefit for freshwater mussels in the form of a marginal increase in aquatic habitat. Because TFH is not proposing a change in operations as currently licensed, which include the flexibility to continuously operate, effects on freshwater mussels during the next license terms would reflect existing conditions.
3.6 Proposed Measures to Enhance, Protect, or Mitigate Effects on Aquatic and Fisheries Resources Overall effects of Project operation on aquatic habitat and fisheries resource are expected to be minor and reflect existing conditions because TFH is not proposing a change in Project operations as currently licensed, which include the flexibility to continuously operate. TFH understands that FirstLight is considering the installation of a screen at the Power Canal Gatehouse to prevent juvenile shad from emigrating through the Power Canal. This would also protect adult American eel from entering the Power Canal, mitigating any, albeit unlikely adverse effect on those species from Project operations. In the event FirstLight is not required to install a screen at the Power Canal during the next license term for the Turners Falls Hydroelectric Project (FERC No. 1889), TFH proposes to develop in consultation with the resource agencies a Trashrack Replacement Plan to replace the existing trashrack with a trashrack with ¾-inch clear spacing to mitigate entrainment, impingement, and turbine mortality of migratory species at the Project.
3.7 Coastal Zone Management Act By letter dated January, 11, 2019, TFH provided notification to the Massachusetts Office of Coastal Zone Management that TFH is seeking a consistency or non-applicability determination with the Massachusetts Coastal Zone Management Program. By letter dated January 11, 2019, the Massachusetts Coastal Program responded stating the Project does not need federal consistency review because the Project is outside the Massachusetts Coastal Zone Boundary.
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Table 3.2.1-1. Fish species and abundance sampled in the lower Turners Falls Power Canal during the 2014 canal drawdown.
Species Count Catch Per Unit Effort Common Name Scientific Name Day 1 Day 2 Day 1 Day 2 Spottail shiner Notropis hudsonius 1040 802 0.1501 0.1188 American shad Alosa sapidissima 471 608 0.0680 0.0900 Tesselated darter Etheostoma olmstedi 280 697 0.0404 0.1032 White sucker Catostomus commersonii 250 411 0.0361 0.0609 Bluegill Lepomis macrochirus 166 279 0.0240 0.0413 Smallmouth bass Micropterus dolomieu 120 72 0.0173 0.0107 Yellow perch Perca flavescens 84 136 0.0121 0.0201 Sea lamprey Petromyzon marinus 75 112 0.0108 0.0166 Brown bullhead Ameiurus nebulosus 71 105 0.0102 0.0155 Largemouth bass Micropterus salmoides 35 28 0.0051 0.0041 Rock bass Ambloplites rupestris 22 81 0.0032 0.0120 American eel Anguilla rostrata 15 9 0.0022 0.0013 Banded killifish Fundulus diaphanus 15 8 0.0022 0.0012 Fallfish Semotilus corporalis 12 10 0.0017 0.0015 Golden shiner Notemigonus crysoleucas 12 18 0.0017 0.0027 Pumpkinseed Lepomis gibbosus 9 2 0.0013 0.0003 Black crappie Pomoxis nigromaculatus 8 2 0.0012 0.0003 Channel catfish Ictalurus punctatus 4 3 0.0006 0.0004 Common carp Cyprinus carpio 2 2 0.0003 0.0003 Walleye Sander vitreus 2 10 0.0003 0.0015 White perch Morone americana 2 6 0.0003 0.0009 Common shiner Luxilus cornutus 1 0 0.0001 0.0000
Source: FirstLight, 2015b.
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Table 3.2.1-1. Fish species and abundance sampled in the Connecticut River bypassed reach in September 2015.
Catch per Unit Species Percent of Count Effort Total Catch Common Name Scientific Name (fish per hour)1 Smallmouth bass Micropterus dolomieu 168 62.5 31.72 American eel Anguilla rostrata 26 9.7 4.91
Bluegill Lepomis macrochirus 22 8.2 4.15
Pumpkinseed Lepomis gibbosus 16 5.9 3.02 White sucker Catostomus commersonii 13 4.8 2.45
Tessellated darter Etheostoma olmstedi 12 4.5 2.27
Sea lamprey Petromyzon marinus 3 1.1 0.57 Largemouth bass Micropterus salmoides 1 0.4 0.19 Yellow perch Perca flavescens 1 0.4 0.19 Spottail shiner Notropis hudsonius 1 0.4 0.19 Mimic shiner Notropis volucellus 1 0.4 0.19 Walleye Sander vitreus 1 0.4 0.19
Northern pike Esox lucius 1 0.4 0.19 Brown bullhead Ameiurus nebulosus 1 0.4 0.19 Hybrid sunfish – 1 0.4 0.19 Longnose dace Rhinichthys cataractae 1 0.4 0.19
1. Catch per unit effort was calculated following Guy et al., 2009. Total second sampled was 7,089, and total distance sampled was 2,955 meters. Source: FirstLight (2016f)
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Table 3.3-1. Project existing trashrack configuration.
Element Measured Measurement
Canal Entrance Opening 11.96 ft H x 19.83 ft W
Trashrack Dimension 21.67 ft H (22.06 ft angled) x 20.00 ft W
Number of Vertical Bars 141 Mean = 0.3703 in. (0.031 ft) Vertical Bar Thickness Range =0.250 to 0.375 in. (¼ to ⅜ in.) (0.021 to 0.031 ft) Mean = 1.2961 in. (0.108 ft) Vertical Bar Clear Spacing Range =1.125 to 1.500 in. (1⅛ to 1½ in.) (0.094 to 0.125 ft) Number of Horizontal Bars 9 Mean = 0.4609 in. (0.038 ft) Horizontal Bar Thickness Range =0.375 to 0.500 in. (⅜ to ½ in.) (0.031 to 0.042 ft Mean = 29.25 in. (2.44 ft) Horizontal Bar Clear Spacing Range =28.25 to 29.50 in. (29¼ to 29½ in.) (2.35 to 2.46 ft) Number of Vertical Support Beams 1
Number of Horizontal Support Beams 4
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Table 3.3-2. Conceptual trashrack configuration with ¾-inch clear spacing.
Element Measured Measurement Canal Entrance Opening 11.96 ft H x 19.83 ft W
Trashrack Dimension 21.67 ft H (22.06 ft angled) x 20.00 ft W
Number of Vertical Bars 2141
Vertical Bar Thickness Assumed 0.375 in. (0.03125 ft)
Vertical Bar Clear Spacing Assumed 0.75 in. (0.0625 ft)
Number of Horizontal Bars 9
Horizontal Bar Thickness Assumed 0.375 in. (0.03125 ft)
Mean = 29.25 in. (2.44 ft) Horizontal Bar Clear Spacing Range =28.25 to 29.50 in. (29¼ to 29½ in.) (2.35 to 2.46 ft)
Number of Vertical Support Beams 1
Number of Horizontal Support Beams 4
1. Calculation: Trashrack Width (ft) / (Vertical Bar Thickness (ft) + Clear Spacing (ft)) = 20 ft / (0.03125 ft + 0.0625 ft) = 214 bars.
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Figure 3.1-1. Turners Falls Power Canal in a watered state at the Project intake.
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Figure 3.1-2. Turners Falls Power Canal in a de-watered state at the Project intake.
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Figure 3.1-3. Turners Falls Power Canal in a de-watered state just upstream of the Project intake looking upstream.
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Figure 3.1-4. The Connecticut River bypassed reach downstream of the Project tailrace.
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Figure 3.1-5. The Connecticut River bypassed reach downstream of the Project tailrace looking upstream.
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Figure 3.1-6. The Connecticut River bypassed reach downstream of the Project tailrace looking downstream.
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Figure 3.3-1. Photograph of the existing trashrack.
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4 WILDLIFE AND BOTANICAL RESOURCES
The Project area is entirely within the urban Village of Turners Falls. The Project footprint is small, a part of an existing mill complex and entirely commercially developed. Very little wildlife or botanical habitat is present at the Project, and it is primarily limited to the shoreline of the Connecticut River bypassed reach near the Project tailrace. Some wildlife species that could occur near the Project include woodchuck, muskrat, beaver, rabbit, weasel, squirrel, mice, bats, opossum, and raccoon. Bird species include rock dove, mourning dove, sparrows, blue jay, water fowl (mallard, wood duck, common merganser, gulls), red-tailed hawk, owls, crow, king fisher, and the occasional osprey and bald eagle. Reptiles and amphibians that could occur near the Project include garter snakes, snapping turtles, toads, and frogs (FERC, 1990). Botanical resources at the Project include flood-tolerant species, such as alders and willows, intermingled with a variety of sedges and forbes. FirstLight (2016i) performed a baseline botanical survey within the Connecticut River bypassed reach as a part of the relicensing studied for the Turners Falls Hydroelectric Project (FERC No. 1889). FirstLight identified silky dogwood, sandbar willow, sandbar cherry, dogbane, and beggarticks in the bypassed reach. FirstLight also determined that the invasive oriental bittersweet is also present near the Project (FirstLight, 2016i). Rare, threatened, and endangered (RTE) wildlife and botanical species are discussed in section 6, Rare, Threatened, and Endangered Species.
4.1 Environmental Impacts on Wildlife and Botanical Resources TFH is not proposing to change current operations as currently licensed, which includes the flexibility to continuously operate.. There is little wildlife and botanical habitat at the Project aside from the bypassed reach shoreline at and adjacent to the Project tailrace. The wildlife and botanical habitat are typical species that would occur in a commercial urban environment. Because TFH is not proposing any changes to project operations as currently licensed, it is expected that there would be no adverse environmental impacts on wildlife and botanical resources during the next license term.
4.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Wildlife and Botanical Resources Because TFH is not proposing to change project operations as currently licensed, which includes the flexibility to continuously operate, and expects wildlife and botanical resources to reflect existing conditions during the next license term, TFH is not proposing protection, mitigation, or enhancement measures for wildlife and botanical resources.
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5 WETLANDS, RIPARIAN, AND LITTORAL HABITAT
Wetland, riparian, and littoral habitats in the Project area are associated with the margin and shoreline areas of the Power Canal and Connecticut River bypassed reach. The spatial extent of wetland, riparian, and littoral habitat of these areas is very limited and only occurs around the tailrace and canal intake because the Project is located in a commercial, urban area in an existing mill building. The only type of wetland in the immediate Project area is classified as riverine and open water by the FWS and MassDEP, respectively (Figure 5.0-1). Riparian and littoral habitat consists of scoured bedrock intermixed with boulder, cobble, gravel, sand, with some vegetation adjacent to the Project tailrace (Figures 3.1-5 and 3.1- 6).
5.1 Environmental Impacts on Wetland, Riparian, and Littoral Habitat There is little riparian and littoral habitat in the immediate Project vicinity, and the only wetland habitat is the riverine habitat of the Connecticut River bypassed reach and Power Canal. The Power Canal is owned and operated by FirstLight; therefore, the Project has little affect the wetland habitat of the Power Canal. When the Project is operating, an additional 289 cfs is provided to the Connecticut River bypassed reach, which would result in a very minor increase in available wetland (mostly open water) and littoral habitat because of the large expanse of the bypassed reach. TFH is not proposing to change current operations as currently licensed, which includes the flexibility to continuously operate.. As a result, there would be no adverse impacts on wetland, riparian, and littoral habitats of the Project area, which would reflect the existing conditions during the next license term.
5.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Wetland, Riparian, and Littoral Habitat Resources Because TFH is not proposing to change operations as currently licensed, which includes the flexibility to continuously operate, and wetland, riparian, and littoral resources will reflect existing conditions during the next license term, TFH is not proposing protection, mitigation, or enhancement measures for wetland, riparian, and littoral resources.
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Figure 5.0-1. Wetlands in the Project area.
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6 RARE, THREATENED, AND ENDANGERED SPECIES
The FWS Information for Planning and Consultation (IPaC) online tool identifies one mammal and one flowering plant listed as threatened or endangered, respectively, under the Endangered Species Act that could occur in the vicinity of the Project boundary (FWS, 2018). The two species are the northern long- eared bat (Mytois septentrionlis), a federally threatened mammal, and northern bulrush (Scirpus ancistrochaetus), a federally endangered plant. FWS (2018) does not identify any critical habitat near the Project for the two federally listed species. FirstLight (2016h) performed a special status plant species survey within the Connecticut River bypassed reach during 2014 and 2015. The survey targeted an area approximately 0.7 miles downstream of the Project. The survey documented six state listed species: • Mountain Alder – state special concern • Great Blue Lobelia – state endangered • Upland White Aster – state endangered • Sandbar Cherry – state threatened • Sandbar Willow – state threatened • Tradescant Aster – state threatened Mountain Alder ((Alnus viridis ssp. crispa) The mountain alder (Alnus viridis ssp. crispa) is a shrub that can reach approximately 12 feet in height, similar to other alders. It has toothed leaves, generally with six to nine main veins. The range of the mountain alder extends from Canada south to northern New England, and in Massachusetts the species is primarily found on exposed ledges, boulders, and cobble bars — habitats that coincide with high-energy rivers. The primary threat to this species is from disturbance of habitat as well as competition from exotic, invasive species such as Japanese knotweed (Fallopia japonica). In 2014, 83 shrubs were recorded in the bypassed reach by FirstLight at higher elevations outside the influence of operations by their project (FirstLight, 2016h). Great Blue Lobelia (Lobelia siphilitica) In 2014, FirstLight identified only one stem of the great blue lobelia in the bypassed reach. Great blue lobelia prefer open areas of partial shade, but the individual discovered by FirstLight was located in an exposed rocky area. Although this species is listed, the plant was formerly cultivated and continues to be popular in gardening, and therefore some populations are likely introduced (FirstLight, 2016h). Upland White Aster (Aster ptarmicoides) The upland white aster is a small composite plant that flowers from July into early September. The species prefers rocky outcrops of sandstone, shale, or limestone. It is commonly found growing in cracks or fissures in bedrock outcrops. The upland white aster requires significant sunlight exposure, and shading may be a threat. In addition, the species is often located along exposed river banks. In 2014, FirstLight counted in excess of 638 individual plants within the bypassed reach area (FirstLight, 2016h). However, the bypassed reach in the immediate vicinity of the Project generally does not contain preferred habitat of the upland white aster. Sandbar Cherry (Prunus pumila var. depressa) The sandbar cherry (Prunus pumila var. depressa) is a member of the rose family that is a low-growing shrub forming mats up to 6 feet in breadth. The species, in Massachusetts, rarely grows above 3 feet in height. The species prefers flood-scoured areas, often along islands and shores. Habitat is generally
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dominated by cobble, gravel, and sloping rock at or near the highwater line. In 2014, approximately 1,400 individuals were identified by FirstLight in the bypassed reach (FirstLight, 2016h). Sandbar Willow (Salix interior) The sandbar willow is a small shrub, growing up to 10 feet in height, which forms interconnected thickets. In Massachusetts, the willow is commonly found on islands, sandbars, and beaches within the flood zone. It prefers sandy, gravely, or rocky substrates that are tied closely to the annual flood regimes and disturbance from water surface elevation fluctuations and are subjected to annual inundation by high water. The plants are usually low and sprawling, and, in the Connecticut River drainage, stems are generally less than 6 feet in height. The primary threat to this species is a scarcity of habitat, which is related to shoreline development. FirstLight (2016h) reported that sandbar willow is present within the bypassed reach within the actively flooded areas. Tradescant Aster (Symphyotrichum tradescantii) The Tradescant aster is a small, white-rayed aster that rarely grows more than 1.5 feet in height. It is often found with a basal rosette of leaves and a cluster of erect stems. This aster is typically found rooted in fissures and cracks of rocky stream shores or river banks. These habitats are generally subjected to flooding throughout the year. The plant flowers late in the summer, when water levels are normally lower. The primary threats are modification of flood regimes that would allow the establishment of other species. Surveys within the bypassed reach in 2014 identified approximately 16,770 stems. In all locations, the habitat was dominated by exposed bedrock, boulders, and large cobbles (FirstLight, 2016h). Odonates4 In 2015 and 2016, FirstLight (2016e) performed field surveys for state-listed odonates in the Connecticut River bypassed reach near Rock Dam, approximately 1.5 miles downstream of the Project. The surveys revealed the presence of three listed species: • Spine-crowned Clubtail – state special concern • Cobra Clubtail – state special concern • Stygian Shadowdragon – state special concern Spine-crowned Clubtail (Gomphus abbreviates) Spine-crowned clubtails inhabit large streams and rivers. In Massachusetts the nymphs are aquatic and burrow just under the sediment of the river bottom. The adults inhabit the riparian areas, forested uplands, and fields. Adults merge in late May and fly through July. Cobra Clubtail (Gomphurus vastus) Cobra clubtails inhabit large, sandy-bottomed rivers and large, windswept lakes. They have a long flight period, and emerge in early June when nymphs crawl up onto the exposed rocks and vegetation and transform into adults. Breeding occurs in the summer, eggs are deposited in the water, and nymphs hatch and cling to bottom substrate. Stygian Shadowdragon (Neuocordulia yamaskanensis) Stygian Shadowdragon are crepuscular and have been observed flying in Massachusetts from early June through July. Breeding in Massachusetts likely occurs in mid-June through mid-July. Females deposit their eggs directly into the water. When the eggs hatch, the nymphs cling to the underside of rocks, sticks, and other debris in the water, where they stay and grow for about a year before emerging as adults.
4 Odonates are dragonflies and damselflies of the Order Odonata.
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Shortnose Sturgeon (Acipenser brevirostrum) A population of the federally endangered shortnose sturgeon is known to inhabit the Connecticut River between the Turners Falls Dam downstream to the Holyoke Dam. Shortnose sturgeon typically inhabit slow-moving, riverine waters or near-shore marine waters and periodically migrate into faster-moving freshwater areas to spawn. In spring, as water temperatures increase above 8º C, pre-spawning shortnose sturgeon move from overwintering grounds to spawning areas. Spawning occurs from April to May and may last from a few days to several weeks depending upon water temperature, photoperiod (day length), and bottom water velocity (Dadswell et al. 1984; Kynard et al., 2012). In the Connecticut River between Turners Falls Dam and Cabot Station, shortnose sturgeon are known to spawn in the bypassed reach near Rock Dam to the vicinity of Cabot Station’s tailrace, approximately 0.9-mile stretch of river. Spawning substrate of this reach is rock, rubble, and boulder shoals. Shortnose sturgeon are not known to occur in the vicinity of the Project tailrace.
6.1 Environmental Impacts on Rare, Threatened, and Endangered Species Northern long-eared bat No critical habitat of the northern long-eared bat was determined to be in the vicinity of the Project. Therefore, continued operation of the Project as currently licensed would have no effect on the northern long-eared bat. Plants The federally endangered northern bulrush could occur in the greater Project area. However, the FWS identified no critical important north bulrush habitat in the immediate Project vicinity. Therefore, continued operation of the Project as currently licensed would have no effect on northern bulrush or its habitat. Surveys performed by FirstLight (2016h) identified six state-listed plants occurring in the Connecticut River bypassed reach. FirstLight (2016h) concluded that these plants would not be negatively impacted by maintaining the current flow regime within the bypassed reach, and higher minimum flows would likely not have negative impacts as long as flows are reduced to allow exposure during July when these species are flowering. It is important to note that these RTE plant populations became established under the current flow regime in the bypassed reach. Because TFH is not proposing to change operations as currently licensed, which includes the flexibility to continuously operate, the existing state-listed RTE plant community would not be adversely affected by TFH operations. Odonates Three state special concern odonates are known to occur in the Connecticut River bypassed reach. The location of the species is approximately 1.5 miles downstream of the Project, as determined by FirstLight (2016e). TFH is proposing to continue to operate the project as currently licensed, which includes the flexibility to continuously operate. As such, 289 cfs would be discharged into the Connecticut River bypassed reach. Continued operation of the Project would not adversely affect existing odonate populations because the bypassed reach is expansive, which attenuates any effect of the small Project discharges, and these populations have developed under current operations. Shortnose Sturgeon A population of the federally endangered shortnose sturgeon is known to occur in the Connecticut River between Turners Falls Dam and Holyoke Dam, and known spawning habitat exists between Rock Dam and FirstLight’s Cabot Station within the Connecticut River bypassed reach. Continued operation of the Project as currently licensed would have no effect on shortnose sturgeon because known spawning areas within the bypassed reach are downstream of the Project and would be mostly influenced by operations of FirstLight’s Station No. 1 and Cabot Station. These facilities discharge into the bypassed reach near the
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known spawning areas, whereas the Project discharges upstream of both stations. In addition, any effect of increased water levels and changes in water velocity caused by the addition of 289 cfs relative to existing flows in the bypassed reach during spawning would be substantially attenuated because of the large size of the bypassed reach.
6.2 Proposed Measures for Enhancement of Rare, Threatened, and Endangered Species TFH is not proposing protection, mitigation, or enhancement measure to protect existing RTE species that are known to occur or have the potential to occur in the Project vicinity, because continued operation of the Project as currently licensed, which include the flexibility to continuously operate, would have no effect on existing RTE species.
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7 HISTORICAL AND ARCHAEOLOGICAL RESOURCES
The Project is located within an existing mill complex known as the Strathmore Mill (Figure 7.0-1). The Strathmore Mill is a 1.9-acre site situated on an island between the Connecticut River and Turners Falls Power Canal within the Turners Falls Historic District, and is owned by the Town of Montague. The Turners Falls Historic District is listed in the National Register of Historic Places (National Register Information System ID 82004966). The mill complex consists of 10 buildings with a total area of approximately 224,000 square feet and an overall footprint approximately 55,000 square feet (excluding the Project). The Project is in the middle of the mill complex but is not officially a part of the Strathmore Mill (Town of Montague, 2011). Due to neglect the historic Mill complex, the Project parcel that is in good condition, while the remainder of the complex is dilapidated. . Most floors are wide, open spaces. Exterior walls are constructed of brick, and the interior has large wood beams, columns, and flooring. The complex was constructed between 1874 and 1970, with most construction complete by 1906 (Town of Montague, 2011). The main mill building is a four-story structure with a pitched roof, dormer windows, dentilled cornices, and projecting stair towers. The tower cupolas and company offices have been removed, and some changes to the roof line have changed. The Strathmore Mill is one of a few surviving historic mill structures and has been an integral part of the Turners Falls economy, history, and landscape. The mill was originally built in 1874 by the Keith Paper Company (KPC), which operated the mill for over 80 years. KPC modernized the mill twice, in 1935 and 1952. In 1953, the mill was acquired by the Strathmore Paper Company to produce high-quality artist paper. Paper production continued at the mill for 40 years until 1994 (Town of Montague, 2011). Since 1994, the mill has served a variety of uses, including artist space, manufacturing, and storage. In 2007, a fire destroyed part of the complex. Also in 2007, the mill was transferred to the Swift River Group, and was taken over by the Town of Montague in 2010 (Town of Montague, 2011). Due to the dilapidated condition, the Town of Montague is seeking proposals to demolish the portion of the Mill complex under their ownership, despite it being designated by the Commonwealth of Massachusetts as one of the most endangered historic resources in the Commonwealth. This development recently became known to TFH, as such, TFH anticipates it will engage in discussion with the Town of Montague to fully understand the scope of the issue.
7.1 Environmental Impacts on Historical and Archaeological Resources TFH is not proposing any construction that would affect the historical nature of the adjacent mill buildings. TFH will continue to maintain and operate the Project as currently licensed, which include the flexibility to continuously operate. Therefore, historical and archeological resources in the vicinity of the Project would not be adversely affected by maintenance and operation of the Project during the next license term.
7.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Historical and Archaeological Resources TFH will continue to maintain and operate the Project as currently licensed. Because construction that would adversely affect the adjacent mill buildings is not proposed, TFH is not proposing any measures to enhance, protect, or mitigate effects to historical or archeological resources.
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Source: Town of Montague (2011) as modified by TFH. Figure 7.0-1. Location of the Strathmore Mill Complex.
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8 RECREATION RESOURCES
The Project does not have recreation facilities and provides no public access within the Project boundary. However, there is a plethora of recreational opportunities and other recreation facilities close to the Project, within approximately a 1-mile radius (Figure 8.0-1). These opportunities consist of public and trust-administered facilities and lands: • Canal Side Bike Trail (Massachusetts Department of Conservation and Recreation [Mass DCR]) • Barton Cove Boat Ramp (Mass DCR) • Peskeomskut Park (Town of Montague) • Canada Hill Conservation Area (City of Greenfield) • Silvio O. Conte National Fish and Wildlife Refuge (FWS) • Westwood Wildlife Sanctuary (City of Greenfield) • Unity Park (Town of Montague) • Connecticut River Greenway State Park (Mass DCR) • White Ash Swamp Conservation Area These offer miles of biking, hiking, bird, wildlife, and scenic viewing, fishing and boating access and playgrounds. In addition, recreation facilities that are a part of FirstLight’s Turners Falls Hydroelectric Project (FERC No. 1889) are close to the Project (Figure 8.0-1): • Gatehouse Fishway Viewing and Picnic Area • Cabot Woods Fishing Access • Turners Falls Overlook • Turners Falls Canoe Portage • Information put-in and fishing access downstream of Turners Falls Dam These facilities offer fishing and boating access and wildlife and scenic viewing.
8.1 Environmental Impacts on Recreation Resources The Project boundary and footprint is small, and no public recreation access is available at the Project. All existing recreation resources in the area are outside the Project boundary, and all maintenance activities associated with operation of the Project do not affect those areas. Therefore, the Project would not affect existing recreation resources in the area.
8.2 Proposed Measures to Enhance, Protect, or Mitigate Effects on Recreational Resources Because continued operation of the Project as currently licensed during the next license term, which include the flexibility to continuously operate, would have no effect on existing recreation resources, TFH does not propose any measures to protect recreation resources in the Project area.
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Figure 8.0-1. Recreation facilities and opportunities near the Project.
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9 LAND USE AND AESTHETIC RESOURCES
9.1 Land Use The Project is located within the Connecticut River Valley ecoregion. This ecoregion is mostly urban and built up but also has croplands, pasture, and oak-hickory and maple-beech-birch forest in higher elevations (MassAudubon, 2018). Within the Project boundary land use is entirely industrial and water. On the opposite side of the river the land is steeply sloped and entirely forested, permanently protected by a conservation easement.
9.2 Aesthetic Resources The Project is situated within a prominent mill complex within the Village of Turners Falls along the Connecticut River. The Project can be viewed from the Turners Falls Bridge, which crosses the Connecticut River bypassed reach approximately 0.2 miles downstream of the Project, and from Canal Street directly across from the Project (Figure 9.2-1 and 9.2-2). Flows within the bypassed reach are largely influenced by operations of Turners Falls Dam upstream of the Project by FirstLight. When the Project is operating, an additional 289 cfs is provided to the bypassed reach and the additional flow produces a barely noticeable current that extends from the tailrace into the bypassed reach (Figure 9.2-3).
9.3 Environmental Impacts on Land Use and Aesthetic Resources TFH proposes to operate and maintain the Project as currently licensed, which includes the flexibility to continuously operate. TFH is not planning any construction activity that would affect existing land use and aesthetics resources in the Project area. Therefore, there would be no adverse impacts on land use and aesthetic resources in the next license term.
9.4 Proposed Measures to Enhance, Protect, or Mitigate Effects on Land Use and Aesthetic Resources Because continued operation of the Project as currently licensed, which includes the flexibility to continuously operate, would not adversely affect existing land use and recreation resources, TFH does not propose any mitigative measures for land use and aesthetic resources in the Project area.
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Figure 9.2-1. View of the Project from the Turners Falls Road Bridge.
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Figure 9.2-2. View of the Project from Canal Street.
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Note : Date of Photo March 7, 2017. Flow in bypassed reach approximately 19,700 cfs. Figure 9.2-3. View of the Connecticut River bypassed reach downstream of the tailrace when the Project is generating.
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10 COMPLIANCE WITH COMMISSION-RECOGNIZED COMPREHENSIVE PLANS
10.1 Relevant Comprehensive Waterway and Resource Management Plans Section 10(a)(2)(A) of the Federal Power Act (FPA), 16 United States Code (USC) § 803(a)(2)(A), requires FERC (the Commission) to consider the extent to which a project is consistent with federal or state comprehensive plans for improving, developing, or conserving a waterway affected by the project. FERC Order No. 481-A, issued on April 27, 1988, established that the Commission will accord FPA Section 10(a)(2)(A) comprehensive plan status to any federal or state plan that: • is a comprehensive study of one or more of the beneficial uses of a waterway or waterways; • specifies the standards, the data, and the methodology used; and • is filed with the Secretary of the Commission. Based on the Commission’s January 2018 revised list of comprehensive plans for the Commonwealth of Massachusetts, 20 of the 31 listed comprehensive plans pertain to the Connecticut River watershed. In general, the plans have identified water quality and habitat loss as the primary factors affecting aquatic resources. The Project’s continued operation as currently licensed will ensure continued consistency with the uses outlined in the plans listed below. • Atlantic States Marine Fisheries Commission. 1999. Amendment 1 to the Interstate Fishery Management Plan for shad and river herring (Report No. 35). April 1999. • Atlantic States Marine Fisheries Commission. 2000. Interstate Fishery Management Plan for American eel (Anguilla rostrata) (Report No. 36). April 2000. • Atlantic States Marine Fisheries Commission. 2000. Technical Addendum 1 to Amendment 1 of the Interstate Fishery Management Plan for shad and river herring. February 9, 2000. • Atlantic States Marine Fisheries Commission. 2008. Amendment 2 to the Interstate Fishery Management Plan for American eel. Arlington, Virginia. October 2008. • Atlantic States Marine Fisheries Commission. 2009. Amendment 2 to the Interstate Fishery Management Plan for shad and river herring, Arlington, Virginia. May 2009. • Atlantic States Marine Fisheries Commission. 2010. Amendment 3 to the Interstate Fishery Management Plan for shad and river herring, Arlington, Virginia. February 2010. • Atlantic States Marine Fisheries Commission. 2013. Amendment 3 to the Interstate Fishery Management Plan for American eel. Arlington, Virginia. August 2013. • Atlantic States Marine Fisheries Commission. 2014. Amendment 4 to the Interstate Fishery Management Plan for American eel. Arlington, Virginia. October 2014. • Connecticut River Atlantic Salmon Commission. 2017. Connecticut River American Shad Management Plan. Sunderland, Massachusetts. June 9, 2017. • Connecticut River Atlantic Salmon Commission. 1998. Strategic plan for the restoration of Atlantic salmon in the Connecticut River. Sunderland, Massachusetts. July 1998. • Massachusetts Department of Environmental Management. n.d. Commonwealth connections: A greenway vision for Massachusetts. Boston, Massachusetts. • Massachusetts Department of Environmental Quality Engineering. 1983. Connecticut River Basin water quality management plan. Westborough, Massachusetts. June 1983.
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• Massachusetts Department of Fish and Game. 2006. Comprehensive wildlife conservation strategy. West Boylston, Massachusetts. September 2006. • Massachusetts Executive Office of Energy and Environmental Affairs. Statewide Comprehensive Outdoor Recreation Plan (SCORP): Massachusetts Outdoor 2006. Boston, Massachusetts. • National Marine Fisheries Service. 1998. Final Recovery Plan for the shortnose sturgeon (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for the National Marine Fisheries Service, Silver Spring, Maryland. December 1998. • National Park Service. The Nationwide Rivers Inventory. Department of the Interior, Washington, D.C. 1993. • Technical Committee for Fisheries Management of the Connecticut River. 1981. Connecticut River Basin fish passage, flow, and habitat alteration considerations in relation to anadromous fish restoration. Hadley, Massachusetts. October 1981. • U.S. Fish and Wildlife Service. 1989. Atlantic salmon restoration in New England: Final environmental impact statement 1989-2021. Department of the Interior, Newton Corner, Massachusetts. May 1989. • U.S. Fish and Wildlife Service. 1995. Silvio O. Conte National Fish and Wildlife Refuge final action plan and environmental impact statement. Department of the Interior, Turners Falls, Massachusetts. October 1995. • U.S. Fish and Wildlife Service, Canadian Wildlife Service. 1986. North American waterfowl management plan. Department of the Interior, Environment Canada. May 1986.
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11 RESPONSIVENESS SUMMARY
Attachment 1 to this Final License Application summarizes the Applicant’s responses to Draft License Application comments received from stakeholders. Copies of the stakeholder’s comment letter will be provided in the Final License Application, Exhibit E, Appendix A.
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12 REFERENCES
Bell, M.C. 1990. Fisheries Handbook, Fish Passage Development and Evaluation Program, 3rd edition. U.S. Army Corps of Engineers, North Pacific Division, Portland, OR. 353 pp.
Dadswell, M.J., B.D. Taubert, T.S. Squires, D. Marchette, and J. Buckley. 1984. Synopsis of biological data on Shortnose Sturgeon, Acipenser brevirostrum LeSueur 1818. FAO Fish. Synop. 140:1-45.
FERC (Federal Energy Regulatory Commission). 1990. Environmental Assessment for Turners Falls Project FERC Project No. 2622. June 26, 1990. 32 pp.
FERC (Federal Energy Regulatory Commission). 2014. Study Plan Determination for Aquatic Studies – Turners Falls Hydroelectric Project and the Northfield Mountain Pumped Storage Project. February 21, 2014. 97 pp.
FirstLight Power Resources. 2012. Pre-Application Document for the Turners Falls Hydroelectric Project (No. 1889) and Northfield Mountain Pumped Storage Project (No. 2485). FirstLight Power Resources, New Milford, CT. 537 pp.
FirstLight Power Resources. 2013. Revised Study Plan for the Turners Falls Hydroelectric Project (No. 1889) and Northfield Mountain Pumped Storage Project (No. 2485). FirstLight Power Resources, New Milford, CT. 558 pp.
FirstLight. 2015a. Relicensing Study 3.3.4 Evaluate Upstream Passage of American Eel at the Turners Falls Project Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). March 2015. 17 pp.
FirstLight. 2015b. Relicensing Study 3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms Study Report. March 2015. 52 pp.
FirstLight. 2016a. Final Application for New License for Major Water Power Project – Existing Dam, Exhibit E – Environmental Report. 530 pp.
FirstLight. 2016b. Relicensing Study 3.2.1 Water Quality Monitoring Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889), March 2016. 196 pp.
FirstLight. 2016c. Relicensing Study 3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). October 2016. 260 pp.
FirstLight. 2016d. Relicensing Study 3.3.3 Evaluate Downstream Passage of Juvenile American Shad Interim Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). October 2016. 203 pp.
FirstLight. 2016e. Relicensing Study 3.3.10 Assess Operational Impacts on Emergence of State-Listed Odonates in the Connecticut River 2014-2016 Study Report Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). December 2016. 118 pp.
62 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT E – ENVIRONMENTAL REPORT
FirstLight. 2016f. Relicensing Study 3.3.11 Fish Assemblage Assessment Study Report Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). March 2016. 132 pp.
FirstLight. 2016g. Relicensing Study 3.3.15 Assessment of Adult Sea Lamprey Spawning within the Turners Falls Project and Northfield Mountain Area Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). June 2016. 60 pp.
FirstLight. 2016h. Relicensing Study 3.5.1 Baseline Inventory of Wetland, Riparian, and Littoral Habitat in the Turners Falls Impoundment and Assessment of Operational Impacts on Special Status Species Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). February 2016. 166 pp.
FirstLight. 2016i. Relicensing Study 3.4.1 Baseline Study of Terrestrial Wildlife and Botanical Resources Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). February 2016. 75 pp.
FirstLight. 2017a. Relicensing Study 3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad Addendum 1, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). May 2017. 665 pp.
FirstLight. 2017b. Relicensing Study 3.3.5 Evaluate Downstream Passage of American Eel Study Report, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). March 2017. 199 pp.
FirstLight. 2018. FirstLight Hydro Generating Company, Turners Falls Hydroelectric Project (FERC No. 1889) and Northfield Mountain Pumped Storage Project (FERC No. 2485). Response to FERC’s March 13, 2018 letter regarding Downstream Juvenile Shad Study. April 6, 2018. 5 pp.
FWS (U.S. Fish and Wildlife Service). 2017. 2017 Connecticut River Basin Fishway Passage Counts. FWS, U.S. Department of the Interior, Washington, DC. https://www.fws.gov/r5crc/pdf/CT_River_Fishway_Count_Rpt_12_30_17.pdf. Accessed July 18, 2018.
FWS. 2018. IPaC Information for Planning and Consultation – the Environmental Conservation Online System. < https://ecos.fws.gov/ipac/> Accessed July 20, 2018.
Guy, C.S., P.J. Braaten, D.P. Herzog, J. Pitlo, and R.S. Rogers. 2009. Chapter 5: Warmwater Fish in River. Standard Methods for Sampling North American Freshwater Fishes. S.A. Bonar, W.A. Hubert, and D.W. Willis (eds.). American Fisheries Society, Bethesda, MD.
Hartel, K.E., Halliwell, D.B., & Launer, A.E. (2002). Inland Fishes of Massachusetts. Lincoln, MA: Massachusetts Audubon Society.
Kynard, B., Bronzi, P., and Rosenthal, H. (2012). Life history and behavior of Connecticut River Shortnose and other sturgeons. World Sturgeon Conservation Society. Special Publication No. 4. 320 pp.
MassAudubon (Massachusetts Audubon Society). 2018. Breeding Bird Atlas 2 Full Ecoregions. MassAudubon, Lincoln, MA. https://www.massaudubon.org/our-conservation-work/wildlife-
63 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT E – ENVIRONMENTAL REPORT
research-conservation/statewide-bird-monitoring/breeding-bird-atlases/bba2/full-ecoregions. Accessed July 16, 2019.
MassDEP (Massachusetts Department of Environmental Protection). 2013. 314 CMR 4.00 Massachusetts Surface Water Quality Standards. MassDEP, Boston. https://www.mass.gov/files/documents/2016/11/nv/314cmr04.pdf. Accessed July 17, 2018.
MassDep (Massachusetts Department of Environmental Protection). 2016. Massachusetts Year 2016 Integrated List of Waters Proposed Listing of the Condition of Massachusetts’ Water Pursuant to Sections 305(b), 314, and 303(d) of the Clean Water Act. MassDEP, Boston. https://www.mass.gov/files/documents/2017/ 08/zu/16ilwplist.pdf. Accessed July 17, 2018. 357 pp.
Massachusetts Department of Health and Human Services (MassDHHH). 2017. Public Health Fish Consumption Advisory, Town of Montague. MassDHHH, Boston. https://eohhs.ehs.state.ma.us/DPH_FishAdvisory/ SearchTown.aspx>. Accessed July 18, 2018.
NOAA [National Oceanic and Atmospheric Administration]. 2018. NowData – NOAA online Weather Data, Station, Greenfield No.3, Greenfield, MA. http://w2.weather.gov/climate/xmacis.php?wfo=box Accessed July 16, 2018.
Stier, D. J., & Crance, J.H. (1985). Habitat suitability index models and American Shad instream flow suitability curves: U.S. Fish Wildl. Serv. Biol. Rep. 82(10.88).
Town of Montague. 2011. Request for Expression of Interest Strathmore Mill at Turners Falls. June 9, 2011. http://montague-ma.gov/Pages/MontagueMA_News/ I0172FF21.0/Strathmore%20REI%205%2025%2011%20(2).pdf Accessed January 9, 2017
U.S. Census Bureau. 2010a. American Fact Finder, 2010 Demographic Profile, Turners Falls CDP, Massachusetts. Available at https://factfinder.census.gov/faces/nav/jsf/pages/ community_facts.xhtml . Accessed July 16, 2018.
U.S. Census Bureau. 2010b. American Fact Finder, 2010 Demographic Profile, Montague town, Franklin County, Massachusetts. Available at https://factfinder.census.gov/faces/nav/jsf/pages/ community_facts.xhtml. Accessed July 16, 2018.
U.S. Census Bureau. 2010c. American Fact Finder, 2010 Demographic Profile, Franklin County, Massachusetts. Available at https://factfinder.census.gov/faces/nav/jsf/pages/ community_facts.xhtml. Accessed July 16, 2018.
U.S. Census Bureau. n.d. American Fact Finder, 2012–2016 American Community Survey 5-Year Estimates, Franklin County, Massachusetts. Available at https://factfinder.census.gov/faces/ tableservices/jsf/pages/productview.xhtml?src=CF . Accessed July 16, 2018.
USDA (U.S. Department of Agriculture). n.d. Natural Resources Conservation Service, Rhode Island, Udorthents Soils. USDA, Washington, DC. https://www.nrcs.usda.gov/wps/portal/nrcs/detail/ri/soils/?cid=nrcs144p2_016612. Accessed July 16, 2018.
USGS (U.S. Geological Survey). n.d. Mount Toby Formation. USGS, Reston, VA. https://mrdata.usgs.gov/geology/state/sgmc-unit.php?unit=MAJm%3B0 Accessed July 16, 2018.
64 TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
DRAFT APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT E - ENVIRONMENTAL REPORT
APPENDIX A – CONSULTATION SUMMARY 1 SUMMARY OF CONSULTATION WITH RESOURCE AGENCIES, TRIBES, AND OTHER STAKEHOLDERS
On February 26, 2016, the former owner of the Project and Tuners Falls Hydro, LLC (Swift River Hydro) filed with the Commission the Notice of Intent, Pre-Application Document (PAD), and Request to use the Traditional Licensing Process. In response to that filing the Massachusetts Division of Fisheries and Wildlife and the Connecticut River Watershed Council provided comments. Upon acquiring the Project and Turners Falls Hydro, LLC, Eagle Creek redistributed the PAD and restarted the relicensing process, commencing with consulting with stakeholders on the time and place of the Joint Meeting and Site Visit. Pursuant to 18 CFR 16.8(b)(3)(A) a Joint Meeting and Site Visit was held. Following the Joint Meeting and Site Visit, Turners Falls filed with the Commission a recording of the Joint Meeting and summary of the Joint Meeting and Site Visit. Within this appendix we provide the letters received by Turners Falls from the resource agencies as well as evidence and related documents of all other attempts to consult with the resource agencies and tribes. Turners Falls did not receive any letters from the public. There were also no disagreement with any resource agency or tribe on studies or protection, mitigation, or enhancement measures. There were also no waivers pursuant to 18 CFR 16.8(e). A draft license application was distributed to the resource agencies, tribes, and other interested stakeholder on September 27, 2018. Within the required 90-day comment period comments were received from NOAA Fisheries, the U.S. Fish and Wildlife Service, and the Town of Montague. On January 11, 2019 TFH e-mailed a consultation package to the Massachusetts Coastal Zone Management Program seeking Federal Consistency Review of the Project. By letter dated January 11, 2019 the Massachusetts Coastal Review Program responded stating the Project does not need federal consistency review because the Project is outside the Massachusetts coastal zone boundary. 20160404-5109 FERC PDF (Unofficial) 4/4/2016 9:16:19 AM
Commonwealth of Massachusetts
Jack Buckley, Director
April 4, 2016
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E., Room 1A Washington, DC 20426
Turners Falls Project, FERC No. 2622 Comments of the Massachusetts Division of Fisheries and Wildlife Preliminary Application Document
Dear Secretary Bose:
The Massachusetts Division of Fisheries and Wildlife (Division) is the agency responsible for the protection and management of the fish and wildlife resources of the Commonwealth. The Division is also responsible for the regulatory protection of imperiled species and their habitats as codified under the Massachusetts Endangered Species Act (M.G.L. c.131A). The Massachusetts Endangered Species Act (MESA) was enacted in December 1990. Implementing regulations (321 CMR 10.00) were promulgated in 1992 and recently revised and implemented as of November 2010. The MESA provides a framework for review of projects or activities that occur within mapped areas of the state, called Priority Habitat, and published in the Natural Heritage Atlas. As such, we monitor operations at hydroelectric projects within the Commonwealth, as well as comment on proposed hydroelectric facilities. The Division offers the following comments on the Preliminary Application Document (PAD) for the Turners Falls Hydroelectric Project (FERC No. 2622) dated February 28, 2016.
PROJECT DESCRIPTION
The Turners Falls Hydroelectric project (TFH) P-2622 is located in Franklin County, Massachusetts on the Turners Falls Power Canal off of the Connecticut River.
TFH draws its flow through an intake gate in the wall of the Turners Falls Canal to an 8.5 foot diameter, 50 foot long steel penstock. Water flow is controlled at the powerhouse by two slide gates. After passing through the turbine, water flows in a flume underneath the adjacent mill complex approximately 50 feet to an excavated , walled, tailrace, approximately 80 additional feet back into the Connecticut River .
www.mass.gov/masswildife Division of Fisheries and Wildlife Field Headquarters, One Rabbit Hill Road, Westborough, MA 01581 (508) 389-6300 Fax (508) 389-7890
20160404-5109 FERC PDF (Unofficial) 4/4/2016 9:16:19 AM
TFH does not control the Turners Falls dam, impoundment or canal, but rather has rights, via an indenture, to draw 100% of its hydraulic capacity (289 cfs) continuously whenever it is operating, not a proportion of the canal flow available.
The TFH turbine is a vertical Francis unit with a scroll case that enhances the efficiency of the GE runner, which was new in 2000. The generator stator was rewound in 2005. The project has an installed capacity of 937 kW.
PROJECT OPERATIONS
The Turners Falls dam is operated and maintained by Cabot Station (P-1889) and the Northfield Mountain pump storage project (P-2485) as a component of its lower reservoir. Connecticut River flow is diverted by Turners Falls dam into the Turners Falls power canal for the use of TFH, Southworth Manufacturing (formerly Esleeck Paper), and Cabot Station at the lower end of the canal. Since 1951 TFH has operated under a Water Exchange Agreement (WEA) with the owners of the dam and power canal to stop power generation whenever Connecticut River flow is less than 15,000 cfs.
PROPOSAL
There are no proposed changes to existing facilities or operations for the Turners Falls Hydroelectric Project. However the project owner does understand that if the current relicensing of the Cabot Station (P-1889) results in changes to canal operations that impact TFH, TFH will have to adjust its mode of operations to comply with such measures in the future.
FISH AND WILDLIFE RESOURCES
The Connecticut River provides essential habitats and a migratory corridor for numerous species of fish and wildlife. As the second impassable barrier to upstream migration on the Connecticut River, the Turners Falls Dam has a significant impact on these resources, particularly anadromous and catadromous fish. These species require safe and effective passage past the dam on their upstream and downstream migrations. Likewise the bypass reach below the dam provides a unique riffle area for quality resident fish and macroinvertebrate habitat. Additionally, the dam acts as a passage barrier to resident fishes who act as host-fishes to state- and federally- listed mussels located both up and downstream of the dam.
IMPACTS AND MITIGATION
TFH does not own or operate the Turners Falls dam, power canal, impoundment, or bypass reach. The Turners Falls/Northfield Mountain Project (P-1889/2485) owns and operates all of these components, and as such most fish and wildlife protection and mitigation are assigned to that license (P-1889/2485).
Because the surrounding project (P-1889/2485) is now going through relicensing which will be completed prior to the TFH relicensing, many of the potentially controversial topics (fish passage, recreation, etc.) will have been decided and will be mitigated by that project’s license.
20160404-5109 FERC PDF (Unofficial) 4/4/2016 9:16:19 AM
The TFH license (P-2622) does contain the following articles which relate to fisheries issues.
Article 401. The licensee shall install, operate, and maintain a trashrack as proposed in its May 3, 1990, filing with the Commission. The trashrack bar spacing shall not exceed 1 inch and the intake velocity shall not exceed an average of 0.68 fps, as estimated within 3 inches of the face of the trashrack. The licensee, within 90 days after completing construction of the trashrack, shall file as-built drawings of the trashrack with the Commission.
Article 402. The licensee, upon joint notification by the Massachusetts Division of Fisheries and Wildlife (MDFW), the Connecticut River Atlantic Salmon Commission (CRASC), and the U.S. Fish and Wildlife Service (FWS), shall file with the Commission for approval, and upon approval, implement a plan to include, but not be limited to, tailrace screens or other structures needed to minimize delays to upstream migrating anadromous fish at the Turners Falls Project, when such delays are identified by the MDFW, CRASC, and the FWS. For any structures needed, the plan shall include functional design drawings of the structures, and a schedule for construction, operation, and maintenance of the structures. Comments and recommendations of the consulted agencies on the adequacy of the design must be included in the plan filed with the Commission; the plan shall be filed within 180 days of the joint notification by the MDFW, CRASC, and the FWS. The Commission reserves the right to require changes to the plan.
Article 403. Authority is reserved to the Commission to require the licensee to construct, operate, and maintain or provide for the construction, operation, and maintenance of such fishways as may be prescribed by the Secretary of the Interior pursuant to Section 18 of the Federal Power Act.
COMMENTS
Request for Approval to Use the Traditional Licensing Process
The surrounding project (P-1889/2485) is now going through relicensing which will be completed prior to the TFH relicensing, many of the potentially controversial topics (fish passage, recreation, etc.) will have been decided and will be mitigated by that project’s license. Therefore, the Division does not object to the request to use the traditional licensing process for the relicensing of the TFH.
20160404-5109 FERC PDF (Unofficial) 4/4/2016 9:16:19 AM
Preliminary Application Document
General The PAD is comprehensive and provides most of the information necessary.
Specific Section 5.6(d)(2) Project location, facilities and operations (v) (1) The applicant should explain the current license articles.
Section 5.6(d)(3)(iii) Water Resources The applicant should provide Connecticut River flow duration curves as project operations are directly affected by the CT River flow (no operation when the River flow is below 15,000 cfs). This will show when the project is able to generate.
Section 5.6 (d)(3)(iv) Fish and Aquatic Resources The applicant should include a brief description of the fishery resources present in the Connecticut River and the bypassed reach in the area of the project. Much of this information is now in the public record from the relicensing process underway for the surrounding project (P-1889). This is important because project operations may have an effect on American Shad and American Eel migration via false attraction to the project’s tailrace as fish attempt to pass through the bypassed reach to reach spillway fishway located at the Turners falls dam. This potential adverse impact should be stated in section (C). Section (D) should contain a statement that references license articles 401, 402, and 402 and why they are necessary (possible false attraction to the project tailrace).
Thank you for this opportunity to comment.
Sincerely, Sincerely,
Caleb Slater, Ph.D. Thomas W. French, Ph.D. Anadromous Fish Project Leader Assistant Director for the Natural Heritage & Endangered Species Program
cc: Melissa Grader, USFWS Robert Kubit, MA DEP
20160404-5109 FERC PDF (Unofficial) 4/4/2016 9:16:19 AM Document Content(s) Turners Falls (Canal) PAD comments.PDF...... 1-4 Burak, Matthew
From: Bob Gates
Sent via the Samsung Galaxy S™ III, an AT&T 4G LTE smartphone
------Original message ------From: Martha Brennan Date:10/03/2016 11:29 AM (GMT-05:00) To: Bob Gates Subject: FW: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
Hi Bob,
Here are the comments from the CT River Watershed Council, as requested.
Martha
From: Andrea Donlon [mailto:[email protected]] Sent: Friday, April 01, 2016 1:10 PM To: Martha Brennan; Peter Clark Cc: Melissa Grader; Caleb Slater; 'Kubit, Robert (DEP)' Subject: RE: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
Martha,
Here are some brief, informal comments on the PAD on behalf of the Connecticut River Watershed Council
CRWC does not object to the traditional licensing process (TLP) for this project. CRWC’s concerns with the project are limited to the following issues: • Entrainment of migratory fish in the canal through the unit. o Although the PAD says that the project doesn’t run when the flow through the canals is less than 15,000 cfs, I didn’t find information about when this typically happens – what dates is it running and what dates is it not, typically? • Attraction of fish in the “bypass” section of the CT River to the outfall of the unit. o Please provide a diagram and map of the tailrace into the CT River bypass section. Are the flows from the unit either 289 cfs or 0, or are there flows in between? • The PAD didn’t have any information on Native American history in the area. CRWC sees that you are consulting with the tribes (a letter posted yesterday). We also recommend you get in touch with the Nolumbeka Project (they have a website) to discuss the project with them, as they have much local knowledge.
Andrea ______Andrea Donlon, River Steward 1 CONNECTICUT RIVER WATERSHED COUNCIL, INC. 15 Bank Row Greenfield MA 01301 Phone: (413)772-2020 x. 205 [email protected] Become a member today! Join at www.ctriver.org . Find us on Facebook, LinkedIn, Twitter, YouTube, and Flickr
From: Martha Brennan [ mailto:[email protected] ] Sent: Friday, April 01, 2016 9:04 AM To: Andrea Donlon Subject: RE: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
Hi Andrea,
The official deadline was March 29 th for comments. But I don’t see why you couldn’t still send your in.
Martha
From: Andrea Donlon [ mailto:[email protected] ] Sent: Thursday, March 31, 2016 2:03 PM To: Martha Brennan Subject: RE: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
Martha,
Is there a comment deadline on the PAD and request for TLP?
Andrea ______Andrea Donlon, River Steward CONNECTICUT RIVER WATERSHED COUNCIL, INC. 15 Bank Row Greenfield MA 01301 Phone: (413)772-2020 x. 205 [email protected] Become a member today! Join at www.ctriver.org . Find us on Facebook, LinkedIn, Twitter, YouTube, and Flickr
From: Alan Morgan [ mailto:[email protected] ] Sent: Wednesday, March 02, 2016 9:58 AM To: Andrea Donlon Subject: FW: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
From: Martha Brennan [ mailto:[email protected] ] Sent: Tuesday, March 01, 2016 1:31 PM To: [email protected] ; [email protected] ; Grader, Melissa; Robert Kubit; Marold, Misty-Anne (FWE); Kevin R. Mendik; Caleb Slater; Warner, John; [email protected] Subject: NOI, PAD and request for TLP for Turners Falls Hydro (P-2622)
2 Attached please find NOI, PAD and request to use the TLP for the Turners Falls Hydro project (FERC P-2622). These documents have been filed electronically with FERC.
Please feel free to contact me using the information below or Peter Clark at [email protected]
Martha Brennan Swift River Company 978-468-3999 office 978-468-1210 fax [email protected]
3 Burak, Matthew
From: Splenda, Jot Sent: Friday, December 02, 2016 2:12 PM To: Susan Giansante ([email protected]) Cc: Bob Gates; [email protected]; Splenda, Jot; Burak, Matthew; Amanda Veinotte; Amy Singler; Andrea Donlon; Andrew Raddant; Angela O'Connor; Bettina Washington; Bob Nasdor; Brian Harrington; Brona Simon; Bruce Carlisle; Bruce Maytubby; Caleb Slater; Cindy Delpapa; David Turin; Dawn Macie; Deborah Tuttle; Debra Boureau; Doug Harris; Gregory Penta; Gus Bakas; Jack Buckley; Jennifer Jillson-Soper; Jessica Pruden; John Warner; Julie Crocker; Ken Kimball; Ken Sprankle; Kevin Mendik; Kim Lutz; Leo Roy; MA Office of Dam Safety; Maeve Vallely-Bartlett; Martin Suuberg; Melissa Grader; Michael Stroman; Paul Jahnige; Peggy Sloan; Rachel Ruppel; Robert Kubit; Robert Mccollum; Robert Sheehan; Sherry White; Ted Castro-Santos; Tim Purinton; Timothy Brennan; Wade Blackwood; Walter Ramsey; William McDavitt Subject: FERC Project No. 2622 Turners Falls Hydroelectric Project NOI, PAD, and Joint Meeting and Site Visit Attachments: FERC Project No. 2622 Turners Falls Hydro_NOI and PAD.pdf; FERC Project No. 2622 Turners Falls Hydro_NOI-PAD Redistribution and JAM Invitation Letter - Signed.pdf
Dear Stakeholder,
The Turners Falls Hydroelectric Project (FERC Project No 2622), located on the Connecticut River and Turners Falls Power Canal within the Town of Montague, Massachusetts, is currently undergoing FERC relicensing. Eagle Creek Renewable Energy, LLC, on behalf of Turners Falls Hydro LLC, the owner and Licensee of the Turners Falls Hydroelectric Project, has retained the services of Louis Berger US Inc. to assist with Project’s relicensing. Louis Berger is redistributing the Notice of Intent (NOI) and Pre-Application Document (PAD), in preparation for the Joint Agency / Stakeholder / Public Meeting and Site Visit for the Project.
Additionally, please find attached the invitation to the Joint Agency / Stakeholder / Public Meeting and Site Visit for the Project, with a request for an RSVP.
Thank you,
Jot Splenda Senior Project Manager | Power and Energy direct +1.919.866.4417 mobile +1.781.801.6047 email [email protected] web louisberger.com
Louis Berger 1001 Wade Ave, Suite 400 | Raleigh, North Carolina 27605 | office 919.866.4440 | fax 919.755.3502
1
December 2, 2016
Re: Turners Falls Hydroelectric Project (FERC Project No. 2622); Redistribution of Notice of Intent to File License Application and Pre-Application Document
Dear Stakeholder:
In August 2016, Eagle Creek Renewable Energy, LLC (“Eagle Creek”), through its subsidiary Eagle Creek Swift River, Inc., acquired Turners Falls Hydro LLC (“TFH”) which is the owner of the Turners Falls Hydroelectric Project (“Project”). TFH is licensed by the Federal Energy Regulatory Commission (“Commission”) to operate the 0.9 megawatt Project, located on the Connecticut River and the Turners Falls Power Canal, in Franklin County, within the Town of Montague, Massachusetts, under FERC Project No. 2622.
On February 26, 2016 TFH initiated the relicensing process by filing with the Commission, a Notice of Intent (“NOI”) to relicense the Project, a Pre-Application Document (“PAD”), and a request to use the Traditional Licensing Process (“TLP”). Concurrently, TFH provided a copy of the NOI, PAD, and request to use the TLP to appropriate federal and state agencies, Indian tribes, local governments, and members of the public likely to be interested in the relicensing proceeding. TFH received approval to follow the TLP from the Commission by letter dated April 22, 2016.
On behalf of TFH (or “Licensee), Eagle Creek will be conducting a Joint Agency / Stakeholder / Public Meeting (Meeting) and Site Visit for the Project. As such, Eagle Creek is redistributing the NOI and PAD pursuant to 18 CFR §4.38 (b)(1) to an updated and expanded list of stakeholders likely to be interested in the relicensing of the Project (attached).
The Meeting and Site Visit will be conducted pursuant to 18 CFR 4.38 (b)(3)(ii) and is tentatively scheduled for Tuesday February 7, 2017. Confirmation of the date, with a specific time, meeting location and agenda will be delivered to the attached distribution list at least 14 days before the meeting and will be filed with the Commission at least 15 days before the meeting.
Eagle Creek kindly requests those agencies and stakeholders planning to attend the Meeting and Site Visit to RSVP with Jane Manibusan at Eagle Creek via e-mail at [email protected] or via phone at (920) 293-4628 extension 318 by January 6, 2017.
Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 2
Parties’ written comments on the PAD and Study requests must be filed with the Commission, with a copy to TFH, no later than 60 days following the Meeting and Site Visit.
If there are any questions concerning the NOI or PAD please do not hesitate to contact me at (973)-998-8400.
Sincerely,
Robert A. Gates Executive Vice President of Operations Eagle Creek Renewable Energy, LLC
Attachment: NOI, PAD, Distribution List cc: Susan Giansante, Eagle Creek (via email) Michael Scarzello, Eagle Creek (via email) Jot Splenda, Louis Berger (via email) Matt Burak, Louis Berger (via email) Distribution List (via email and mail)
Eagle Creek Renewable Energy 65 Madison Avenue, Suite 500 – Morristown, NJ 07960, USA Tel: (973) 998-8400 – Fax: (973) 998-8401 www.eaglecreekre.com Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 3
TURNERS FALLS HYDRO PROJECT FERC PROJECT NO. 2622 DISTRIBUTION LIST
Name/Affiliation E-mail/Mailing Address MA Division of Energy Resources 100 Cambridge St., Ste. 1020 Hydro Section Boston, MA 02114-2533 270 Turners Falls Rd Susanne LaCosse Greenfield, MA 01301-1350 Andrew L. Raddant, Regional Environmental Officer [email protected] U.S. Department of Interior Angela M. O'Connor, Chairmen [email protected] Massachusetts Dept. of Public Utilities 1 Ashburton Pl Fl. 19 Attorney General, Utilities Division Boston, MA 02108-1518 Bob Nasdor, Northeast Stewardship Director [email protected] American Whitewater Brian D. Harrington, Deputy Regional Director [email protected] MA Department of Environmental Protection Cindy Delpapa, Riverways Program Manager [email protected] Massachusetts Riverways Program David Turin [email protected] U.S. Environmental Protection Agency Deborah Tuttle, Town Clerk [email protected] Town of Greenfield Edward J. Markey, Senator 218 Russell Senate Office Bldg. U.S. Senate Washington, DC 20510 Edward R. Niederriter 6400 Poplar Ave International Paper Company Memphis, TN 38197-0100 Gus Bakas, Director [email protected] Massachusetts Hydro Jack Buckley, Director [email protected] Massachusetts Dept. of Fisheries & Wildlife
Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 4
Name/Affiliation E-mail/Mailing Address Michael Stroman, Program Chief [email protected] Massachusetts Division of Wetlands Kevin Mendik, Esq., NPS Hydro Prgm Coord., [email protected] U.S. National Park Service Martin Suuberg, Commissioner, [email protected] MA Department of Environmental Protection 1 Winter St Massachusetts Division of Water Pollution Control Boston, MA 02108-4747 U.S. Geological Survey 10 Bearfoot Rd. Massachusetts-Rhode Island Dist., Wrd Northborough, MA 01532-1528 10 Park Plz. Massachusetts Dept. of Public Works Boston, MA 02116-3933 Melissa Grader [email protected] U.S. Fish & Wildlife Service Doug Harris, Assistant Historic Preservation [email protected] Narragansett Indian Tribe Bruce Carlisle, Director [email protected] Massachusetts Office of Coastal Zone Management Bruce Maytubby, Regional Director Eastern Regional Office [email protected] Bureau of Indian Affairs Dr. Caleb Slater [email protected] Massachusetts Division of Fisheries and Wildlife Charles Olchowski, Chapter President 28 Smith Street Deerfield/Millers Chapter Trout Unlimited Greenfield, MA 01301 Greg Penta New England District [email protected] US Army Corps of Engineers John Brown, Director Narragansett Indian Tribe Historic Preservation PO Box 700 Narragansett Indian Tribe Wyoming, RI 02898 John Warner New England Field Office [email protected] US Fish and Wildlife Service
Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 5
Name/Affiliation E-mail/Mailing Address Ken Kimball, PhD, Director of Research [email protected] Appalachian Mountain Club Ken Sprankle, Connecticut River Coordinator Connecticut River Coordinator's Office [email protected] US Fish and Wildlife Service Leo Roy, Commissioner Massachusetts Department of Conservation and [email protected] Recreation Paul Jahnige, Director Greenways and Trails Program Massachusetts Department of Conservation and [email protected] Recreation Robert Kubit Massachusetts Department of Environmental [email protected] Protection Division of Watershed Protection Robert Longtoe Sheehan Tribal Headquarters [email protected] Elnu Abenaki Tribe Robert McCollum, Regional Section Chief Massachusetts Department of Environmental [email protected] Protection Ron Lamberston, Chairman 103 East Plumtree Rd. Connecticut River Atlantic Salmon Commission Sunderland, MA 01375 Tim Purinton, Director [email protected] Massachusetts Division of Ecological Restoration Timothy Brennan Executive Director [email protected] Pioneer Valley Planning Commission Wade Blackwood Executive Director [email protected] American Canoe Association William McDavitt, Environmental Specialist Northeast Regional Office [email protected] National Marine Fisheries Service Amanda Veinotte, Regulatory Review Administrator Natural Heritage & Endangered Species Program [email protected] Massachusetts Division of Fisheries and Wildlife
Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 6
Name/Affiliation E-mail/Mailing Address Amy Singler, Associate Director River Restoration Program [email protected] American Rivers Andrea Donlon, Massachusetts River Steward [email protected] Connecticut River Watershed Council Bettina Washington, Tribal Historic Preservation Officer [email protected] Wampanoag Tribe of Gay Head Brona Simon, State Historic Preservation Officer & Executive Director [email protected] Massachusetts Historical Commission Dawn Macie Tribal Council [email protected] Nulhegan Abenaki Tribe Debra Bourbeau, Town Clerk [email protected] Town of Montague Jennifer Jillson Soper, Land Protection Specialist Massachusetts Department of Conservation and [email protected] Recreation Jessica Pruden, Sturgeon Recovery Coordinator Northeast Regional Office [email protected] National Marine Fisheries Service Julie Crocker, Protected Resources Division [email protected] National Marine Fisheries Service Kim Lutz, Director Connecticut River Program [email protected] The Nature Conservancy Walter Ramsey, AICP Town Planner & Conservation Agent [email protected] Town of Montague, MA Maeve Vallely-Bartlett, Director Massachusetts Executive Office of Energy and [email protected]. Environmental Affairs Nancy Martin PO Box 1048 Mashpee Wampanoag Indian Tribe Council Mashpee, MA 02649 Peggy Sloan, Director of Planning & Development [email protected] Franklin Regional Council of Governments
Turner Falls Project (FERC No. 2622) December 2, 2016 Redistribution of NOI and PAD Page 7
Name/Affiliation E-mail/Mailing Address Rachel Ruppel, Program Manager [email protected] Connecticut River Joint Commissions Sherry White, Historic Preservation Officer [email protected] Stockbridge-Munsee Community U.S. Coast Guard 447 Commercial St. MSO Boston Boston, MA 02109-1027 Office of Dam Safety [email protected] Massachusetts Dept. of Conservation & Recreation Office of Senator Elizabeth Warren United States Senate United States Senate Washington, DC 20510 Office of the Solicitor 1849 C Street, NW, MS 6557 U.S. Department of Interior Washington, DC 20240 5515 17th Street North Paul Nolan, Energy Consultant Arlington, VA 22205-2722 Roger A Hunt, Director 370 Main St, Ste. 800 Quinebaug Associates, LLC Worcester, MA 01608-1741 Simeon Bruner 130 Prospect Street Cambridge Development Corporation Cambridge, MA 02139 Dr. Ted Castro-Santos Conte Anadromous Fish Research Center [email protected] US Geological Survey
20170117-0031 FERC PDF (Unofficial) 01/17/2017
EAGLE I CREEK RENEWABLE ENERBY —EXCELLENCE IN HYDno—
In reference to: P-2622 Turners Falls Hydroelectric Project NATDAM ID No. MA01274
January 10,2017
Ms. Kimberly D. Bose, Secretary I c I Federal Energy Regulatory Commission C
Office of Energy Projects C.
0 R I GINA L
Re: Turners Falls Hydroelectric Project (P-2622) License Appllcatlon and Pre-Application Document W IW
Dear Secretary Bose:
Turners Falls Hydro, LLC ( TFH ), Licensee for the Turners Falls Hydroelectric Project (FERC Project No. 2622) is hereby requesting to supplement the Pre-Application Document filed with the Commission on February 26, 2016.
On July 29, 2016, Eagle Creek Renewable Energy, LLC ('agle Creel'), through its subsidiary Eagle Creek SwiR River, Inc., acquired and assumed management ofTFH.
Under its former management, TFH identified in section 5.6 (e) ofthe Pre-Application Document (PAD), the applicant will not be seeking benefits under PURPA .TFH hereby notifies the Commission that it now intends to seek benefits under the Public Utility Regulatory Polies Act (PURPA).
The PAD filed with the Commission on February 26, 2016 was redistributed to an updated and expanded list of Stakeholders on December 2, 2016 with notice of TFH's plans to conduct the Joint Agency / Stakeholder / Public Meeting and Site Visit Ooint Meeting) for the Turners Falls Project on February 7, 2017. Confirmation of the date and details of the meeting location and agenda will be delivered to the distribution list at least 14 days prior to the Joint Meeting and to FERC at least 15 days prior to the Joint Meeting. During the Joint Meeting, TFH will state its intent to seek PURPA benefits.
snare Oaeh Renewahre Enway 116N. Secre Shaec 00 sea rar, Nmhhww. ua $60606167 Tel: MVRIE&400- Ewe 000-100~ wwwnesrecmehencwn 20170117-0031 FERC PDF (Unofficial) 01/17/2017
EAGLE CREEK
Ifyou have any questions regarding this matter, please contact me at (973)998-8403 by telephane Or elnail bob.satesiaeanlecreekre.corn.
Sincerely, hgent for Licensee Tumors Pulls Ilydro, LLC
Robert h. Gates Executive Vice President of Operations
CC: Susan Giansante, Eagle Creek (via email) Michael Scatuello, Eagle Creek (via email) ).~ends, Louis Berger (via email) M. Burak, Louis Berger (via email) Distribution List (via email)
sesie Cewk awwwehh sewer 110N. hl ~ seeeL PO Sen 107, .' Wl MesQH107 res 020-2004CR -Fwe SR04I0-0007 www~lsweeleacwn 20170117-0031 FERC PDF (Unofficial) 01/17/2017 Document Content(s) 14467724.tif...... 1-2 Burak, Matthew
From: Jane Manibusan
Dear Stakeholder,
Please find attached the invitation to the Joint Agency / Stakeholder / Public Meeting and Site Visit Agenda for the Project, with a request for an RSVP. On behalf of Turners Falls Hydro LLC, the owner and Licensee of the Turners Falls Hydroelectric Project (FERC Project No. 2622).
Thank You; Jane Manibusan, Compliance Associate/Librarian EAGLE CREEK RENEWABLE ENERGY LLC [email protected] Office 920-293-4628 ext. 318 Fax 920-293-8087 Cell 920-273-5390
1 20170119-5120 FERC PDF (Unofficial) 1/19/2017 2:19:26 PM
Via Electronic Filing (Public)
January 19, 2017
Ms. Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426
Re: Turners Falls Hydroelectric Project (FERC No. 2622) Notice of Joint Meeting and Site Visit
Dear Secretary Bose:
Turners Falls Hydro, LLC (“TFH”), which became a wholly owned subsidiary of Eagle Creek Renewable Energy, LLC in the summer 2016, is licensed by the Federal Energy Regulatory Commission (FERC) to operate the 0.9 megawatt Turners Falls Hydroelectric (“Project”, FERC No. 2622), located on the Turners Falls Power Canal and Connecticut River in Franklin County, Massachusetts. The current license for the Project was issued on June 29, 1990 and expires on February 28, 2021. On February 26, 2016, TFH initiated the pre-filing process for the relicensing of the Project by filing its Notice of Intent and Pre- Application Document (PAD), along with a request for approval to use the Traditional Licensing Process (TLP). By letter order dated April, 22 2016, the Commission granted TFH’s request to use the TLP for the Project.
Pursuant to 18 CFR §4.38(b)(3)(i)(A)(3),TFH hereby provides written notice of its upcoming joint meeting and site visit to be conducted in accordance with the requirements of 18 CFR §4.38(b)(3)(ii) for the relicensing of the Project. The joint meeting and site visit for the Project is open to all interested resource agencies, Indian tribes, members of the public, and other interested parties. The joint meeting will be held on Tuesday February 7, 2017 at 1:30 pm to at the Montague Town Hall Upstairs Meeting Room at 1 Avenue A, Turners Falls, MA 01376 and a brief site visit of the Turners Falls Hydroelectric Project will be held the same day after the meeting. Due to limited access and parking, stakeholders interested in participating in the site visit are asked to meet at the Montague Town Hall. An agenda for the joint meeting and site visit is attached.
The purpose of the joint meeting is to provide an overview of the Project and of the information provided in the PAD filed with the Commission on February 26, 2016; discuss the licensing process and schedule; discuss any necessary studies to be conducted by TFH to support its license application; and receive input and feedback regarding the information presented. All interested parties are invited to attend the joint meeting to assist in identifying and clarifying the scope of issues to be addressed during this phase of the relicensing process for the Project. Comments on the PAD and study requests are due within 60 days of the joint meeting. A copy of the PAD is available on Eagle Creek’s website at http://www.eaglecreekre.com/facilities/ northeast-region/connecticut-river-ma/turners-falls-relicensing- information or via the FERC e-library. A hardcopy of the PAD is available at the Selectman’s Office in the Montague Town Hall, 1 Avenue A, Turners Falls, MA.
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com 20170119-5120 FERC PDF (Unofficial) 1/19/2017 2:19:26 PM
2 January 19, 2017
In accordance with the requirements of 18 C.F.R. § 4.38(g), at least 14 days in advance of the joint meeting, TFH will publish notice of the joint meeting and site visit in the Montague Reporter, a newspaper that is in general circulation in Franklin County.
If you have any questions regarding this filing, please contact me at (973) 998-8400, or by email at [email protected].
Sincerely,
Mr. Robert A. Gates Vice President Turners Falls Hydro, LLC
Attachment: Joint Meeting Agenda, Distribution List
cc: Susan Giansante, Eagle Creek (via email) Michael Scarzello, Eagle Creek (via email) Jot Splenda, Louis Berger (via email) Interested Parties Distribution List (via email)
File: 2017-01-19_ECRE_TF_FERC Notice JAM
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
20170119-5120 FERC PDF (Unofficial) 1/19/2017 2:19:26 PM
3 January 19, 2017
Agenda for Joint Meeting and Site Visit Turners Falls Hydro, LLC Turners Falls Hydroelectric Project FERC Project No. 2622
JOINT MEETING
Date: February 7, 2017 Time: 1:30 p.m. Location: Montague Town Hall Meeting Room at 1 Avenue A, Turners Falls, MA 01376
Agenda:
1. Welcome and Introductions 2. Review of the FERC Traditional Licensing Process and Schedule 3. Overview of the Project 4. Overview of Information Provided in the Pre-Application Document (PAD) 5. Public Utility Regulatory Policies Act (PURPA) Benefits 6. Proposed Resource Studies 7. Next Steps 8. Comments
SITE VISIT
Date: February 7, 2017 Time: After the Joint Meeting. Location: Montague Town Hall upstairs meeting room
NOTE: Turners Falls Hydro, LLC has a limited amount of visitor safety gear available for use during the site visit and kindly asks you to bring your own including a hard hat, and safety glasses. Also, please wear appropriate foot attire, no open toed shoes or high heels; steel toed shoes or hard soled shoes are preferable, if available.
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
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4 January 19, 2017
Distribution List
Name/Affiliation E-mail/Mailing Address MA Division of Energy Resources 100 Cambridge St., Ste. 1020 Hydro Section Boston, MA 02114-2533 270 Turners Falls Rd Susanne LaCosse Greenfield, MA 01301-1350 Andrew L. Raddant, Regional Environmental Officer [email protected] U.S. Department of Interior Angela M. O'Connor, Chairmen [email protected] Massachusetts Dept. of Public Utilities 1 Ashburton Pl Fl. 19 Attorney General, Utilities Division Boston, MA 02108-1518 Bob Nasdor, Northeast Stewardship Director [email protected] American Whitewater Brian D. Harrington, Deputy Regional Director [email protected] MA Department of Environmental Protection Cindy Delpapa, Riverways Program Manager [email protected] Massachusetts Riverways Program David Turin [email protected] U.S. Environmental Protection Agency Deborah Tuttle, Town Clerk [email protected] Town of Greenfield Edward J. Markey, Senator 218 Russell Senate Office Bldg. U.S. Senate Washington, DC 20510 Edward R. Niederriter 6400 Poplar Ave International Paper Company Memphis, TN 38197-0100 Gus Bakas, Director [email protected] Massachusetts Hydro Jack Buckley, Director [email protected] Massachusetts Dept. of Fisheries & Wildlife Michael Stroman, Program Chief [email protected] Massachusetts Division of Wetlands
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
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5 January 19, 2017
Name/Affiliation E-mail/Mailing Address Kevin Mendik, Esq., NPS Hydro Prgm Coord., [email protected] U.S. National Park Service Martin Suuberg, Commissioner, [email protected] MA Department of Environmental Protection 1 Winter St Massachusetts Division of Water Pollution Control Boston, MA 02108-4747 U.S. Geological Survey 10 Bearfoot Rd. Massachusetts-Rhode Island Dist., Wrd Northborough, MA 01532-1528 10 Park Plz. Massachusetts Dept. of Public Works Boston, MA 02116-3933 Melissa Grader [email protected] U.S. Fish & Wildlife Service Doug Harris, Assistant Historic Preservation [email protected] Narragansett Indian Tribe Bruce Carlisle, Director [email protected] Massachusetts Office of Coastal Zone Management Bruce Maytubby, Regional Director Eastern Regional Office [email protected] Bureau of Indian Affairs Dr. Caleb Slater [email protected] Massachusetts Division of Fisheries and Wildlife Charles Olchowski, Chapter President 28 Smith Street Deerfield/Millers Chapter Trout Unlimited Greenfield, MA 01301 Greg Penta New England District [email protected] US Army Corps of Engineers Narragansett Indian Tribe Matthew Thomas, Chief Sachem PO Box 268 Narragansett Indian Tribe Charlestown, RI 02898 John Warner New England Field Office [email protected] US Fish and Wildlife Service Ken Kimball, PhD, Director of Research [email protected] Appalachian Mountain Club
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
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6 January 19, 2017
Name/Affiliation E-mail/Mailing Address Ken Sprankle, Connecticut River Coordinator Connecticut River Coordinator's Office [email protected] US Fish and Wildlife Service Leo Roy, Commissioner Massachusetts Department of Conservation and [email protected] Recreation Paul Jahnige, Director Greenways and Trails Program Massachusetts Department of Conservation and [email protected] Recreation Robert Kubit Massachusetts Department of Environmental [email protected] Protection Division of Watershed Protection Robert Longtoe Sheehan Tribal Headquarters [email protected] Elnu Abenaki Tribe Robert Kubit, Regional Section Chief Massachusetts Department of Environmental [email protected] Protection Ron Lamberston, Chairman 103 East Plumtree Rd. Connecticut River Atlantic Salmon Commission Sunderland, MA 01375 Tim Purinton, Director [email protected] Massachusetts Division of Ecological Restoration Timothy Brennan Executive Director [email protected] Pioneer Valley Planning Commission Wade Blackwood Executive Director [email protected] American Canoe Association William McDavitt, Environmental Specialist Northeast Regional Office [email protected] National Marine Fisheries Service Amanda Veinotte, Regulatory Review Administrator Natural Heritage & Endangered Species Program [email protected] Massachusetts Division of Fisheries and Wildlife Amy Singler, Associate Director River Restoration Program [email protected] American Rivers Andrea Donlon, Massachusetts River Steward [email protected] Connecticut River Watershed Council
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
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7 January 19, 2017
Name/Affiliation E-mail/Mailing Address Bettina Washington, Tribal Historic Preservation Officer [email protected] Wampanoag Tribe of Gay Head Brona Simon, State Historic Preservation Officer & Executive Director [email protected] Massachusetts Historical Commission Donald Stevens, Cheif [email protected] Nulhegan Abenaki Tribe Debra Bourbeau, Town Clerk [email protected] Town of Montague Jennifer Jillson Soper, Land Protection Specialist Massachusetts Department of Conservation and [email protected] Recreation Jessica Pruden, Sturgeon Recovery Coordinator Northeast Regional Office [email protected] National Marine Fisheries Service Julie Crocker, Protected Resources Division [email protected] National Marine Fisheries Service Kim Lutz, Director Connecticut River Program [email protected] The Nature Conservancy Walter Ramsey, AICP Town Planner & Conservation Agent [email protected] Town of Montague, MA Matthew Beaton, Director Massachusetts Executive Office of Energy and [email protected] Environmental Affairs Cedric Cromwell, Chairmen 483 Great Neck Road South Mashpee Wampanoag Indian Tribe Council Mashpee, MA 02649 Peggy Sloan, Director of Planning & Development [email protected] Franklin Regional Council of Governments Rachel Ruppel, Program Manager [email protected] Connecticut River Joint Commissions Sherry White, Historic Preservation Officer [email protected] Stockbridge-Munsee Community U.S. Coast Guard 447 Commercial St. MSO Boston Boston, MA 02109-1027
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
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8 January 19, 2017
Name/Affiliation E-mail/Mailing Address Office of Dam Safety [email protected] Massachusetts Dept. of Conservation & Recreation Office of Senator Elizabeth Warren United States Senate United States Senate Washington, DC 20510 Office of the Solicitor 1849 C Street, NW, MS 6557 U.S. Department of Interior Washington, DC 20240 5515 17th Street North Paul Nolan, Energy Consultant Arlington, VA 22205-2722 Roger A Hunt, Director 370 Main St, Ste. 800 Quinebaug Associates, LLC Worcester, MA 01608-1741 Simeon Bruner 130 Prospect Street Cambridge Development Corporation Cambridge, MA 02139 Dr. Ted Castro-Santos Conte Anadromous Fish Research Center [email protected] US Geological Survey William Connelly [email protected] Federal Energy Regulatory Commission Bjorn Lake [email protected] National Marine Fisheries Service
Eagle Creek Renewable Energy 116 N. State Street, PO Box 167, Neshkoro, WI 54960-0167 Tel: 920-293-4628 – Fax: 920-293-8087 www.eaglecreekre.com
20170119-5120 FERC PDF (Unofficial) 1/19/2017 2:19:26 PM Document Content(s) 17-01-19 ECRE TF Notice Joint Mtg and Site Visit Letter.PDF...... 1-8 From: Jane Manibusan To: Andrew Raddant; [email protected]; Bob Nasdor; Brian Harrington; Cindy Delpapa; David Turin; Deborah Tuttle; [email protected]; Jack Buckley; Michael Stroman; Kevin Mendik; Martin Suuberg; Melissa Grader; Doug Harris; Bruce Carlisle; [email protected]; [email protected]; [email protected]; Gregory Penta; John Warner; Ken Kimball; Ken Sprankle; Leo Roy; Paul Jahnige; Kubit, Robert (DEP); [email protected]; Robert Sheehan; Tim Purinton; Timothy Brennan; Wade Blackwood; William McDavitt - NOAA Affiliate; Amanda Veinotte; Amy Singler; Andrea Donlon; Bettina Washington; Brona Simon; [email protected]; [email protected]; Debra Boureau; Jennifer Jillson-Soper; Julie Crocker; Kim Lutz; Walter Ramsey; [email protected]; Peggy Sloan; Rachel Ruppel; Sherry White; MADCR, Dam Safety ([email protected]); Ted Castro-Santos; [email protected]; Lake, Bjorn; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: Susan Giansante; Michael Scarzello; Splenda, Jot; Burak, Matthew Subject: P-2622_TFH JAM and Site Visit Transmittal Letter and Summary with Attachments Compiled Date: Thursday, March 02, 2017 11:08:15 AM Attachments: 17-03-02 P-2622 Joint Agency Mtg and Site Visit Summary-resized.pdf
Dear Stakeholder,
Enclosed copy in accordance with 18 CFR §4.38(b)(4), Licensee hereby provides the attached Summaries for both the Meeting and the Site Visit. (Audio Recording can be view in the FERC e- library).
Thank You; Jane Manibusan, Compliance Associate/Librarian EAGLE CREEK RENEWABLE ENERGY LLC [email protected] Office 920-293-4628 ext. 318 Fax 920-293-8087 Cell 920-273-5390
20170215-5036 FERC PDF (Unofficial) 2/15/2017 11:10:01 AM
Commonwealth of Massachusetts
Jack Buckley, Director
February 15, 2017
Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E., Room 1A Washington, DC 20426
Turners Falls Project, FERC No. 2622 Comments of the Massachusetts Division of Fisheries and Wildlife Preliminary Application Document
Dear Secretary Bose:
The Massachusetts Division of Fisheries and Wildlife (Division) is the agency responsible for the protection and management of the fish and wildlife resources of the Commonwealth. The Division is also responsible for the regulatory protection of imperiled species and their habitats as codified under the Massachusetts Endangered Species Act (M.G.L. c.131A). The Massachusetts Endangered Species Act (MESA) was enacted in December 1990. Implementing regulations (321 CMR 10.00) were promulgated in 1992 and recently revised and implemented as of November 2010. The MESA provides a framework for review of projects or activities that occur within mapped areas of the state, called Priority Habitat, and published in the Natural Heritage Atlas. As such, we monitor operations at hydroelectric projects within the Commonwealth, as well as comment on proposed hydroelectric facilities. The Division offers the following comments on the Preliminary Application Document (PAD) for the Turners Falls Hydroelectric Project (FERC No. 2622) dated February 28, 2016.
PROJECT DESCRIPTION
The Turners Falls Hydroelectric project (TFH) P-2622 is located in Franklin County, Massachusetts on the Turners Falls Power Canal off of the Connecticut River.
TFH draws its flow through an intake gate in the wall of the Turners Falls Canal to an 8.5 foot diameter, 50 foot long steel penstock. Water flow is controlled at the powerhouse by two slide gates. After passing through the turbine, water flows in a flume underneath the adjacent mill complex approximately 50 feet to an excavated , walled, tailrace, approximately 80 additional feet back into the Connecticut River .
www.mass.gov/masswildife Division of Fisheries and Wildlife Field Headquarters, One Rabbit Hill Road, Westborough, MA 01581 (508) 389-6300 Fax (508) 389-7890
20170215-5036 FERC PDF (Unofficial) 2/15/2017 11:10:01 AM
TFH does not control the Turners Falls dam, impoundment or canal, but rather has rights, via an indenture, to draw 100% of its hydraulic capacity (289 cfs) continuously whenever it is operating, not a proportion of the canal flow available.
The TFH turbine is a vertical Francis unit with a scroll case that enhances the efficiency of the GE runner, which was new in 2000. The generator stator was rewound in 2005. The project has an installed capacity of 937 kW.
PROJECT OPERATIONS
The Turners Falls dam is operated and maintained by Cabot Station (P-1889) and the Northfield Mountain pump storage project (P-2485) as a component of its lower reservoir. Connecticut River flow is diverted by Turners Falls dam into the Turners Falls power canal for the use of TFH, Southworth Manufacturing (formerly Esleeck Paper), and Cabot Station at the lower end of the canal. Since 1951 TFH has operated under a Water Exchange Agreement (WEA) with the owners of the dam and power canal to stop power generation whenever Connecticut River flow is less than 15,000 cfs.
PROPOSAL
There are no proposed changes to existing facilities or operations for the Turners Falls Hydroelectric Project. However the project owner does understand that if the current relicensing of the Cabot Station (P-1889) results in changes to canal operations that impact TFH, TFH will have to adjust its mode of operations to comply with such measures in the future.
FISH AND WILDLIFE RESOURCES
The Connecticut River provides essential habitats and a migratory corridor for numerous species of fish and wildlife. As the second impassable barrier to upstream migration on the Connecticut River, the Turners Falls Dam has a significant impact on these resources, particularly anadromous and catadromous fish. These species require safe and effective passage past the dam on their upstream and downstream migrations. Likewise the bypass reach below the dam provides a unique riffle area for quality resident fish, macroinvertebrate habitat, and high quality habitat for a variety of state-listed plants. Additionally, the dam acts as a passage barrier to resident fishes who act as host-fishes to state- and federally-listed mussels located both up and downstream of the dam.
IMPACTS AND MITIGATION
TFH does not own or operate the Turners Falls dam, power canal, impoundment, or bypass reach. The Turners Falls/Northfield Mountain Project (P-1889/2485) owns and operates all of these components, and as such most fish and wildlife protection and mitigation requirements are assigned to that license (P-1889/2485).
Because the surrounding project (P-1889/2485) is now going through relicensing which will be completed prior to the TFH relicensing, many of the potentially controversial topics (fish passage, canal flows, recreation, etc.) will have been decided and will be mitigated by that project’s license. 20170215-5036 FERC PDF (Unofficial) 2/15/2017 11:10:01 AM
The TFH license (P-2622) does contain the following articles which relate to fisheries issues.
Article 401. The licensee shall install, operate, and maintain a trashrack as proposed in its May 3, 1990, filing with the Commission. The trashrack bar spacing shall not exceed 1 inch and the intake velocity shall not exceed an average of 0.68 fps, as estimated within 3 inches of the face of the trashrack. The licensee, within 90 days after completing construction of the trashrack, shall file as-built drawings of the trashrack with the Commission.
Article 402. The licensee, upon joint notification by the Massachusetts Division of Fisheries and Wildlife (MDFW), the Connecticut River Atlantic Salmon Commission (CRASC), and the U.S. Fish and Wildlife Service (FWS), shall file with the Commission for approval, and upon approval, implement a plan to include, but not be limited to, tailrace screens or other structures needed to minimize delays to upstream migrating anadromous fish at the Turners Falls Project, when such delays are identified by the MDFW, CRASC, and the FWS. For any structures needed, the plan shall include functional design drawings of the structures, and a schedule for construction, operation, and maintenance of the structures. Comments and recommendations of the consulted agencies on the adequacy of the design must be included in the plan filed with the Commission; the plan shall be filed within 180 days of the joint notification by the MDFW, CRASC, and the FWS. The Commission reserves the right to require changes to the plan.
Article 403. Authority is reserved to the Commission to require the licensee to construct, operate, and maintain or provide for the construction, operation, and maintenance of such fishways as may be prescribed by the Secretary of the Interior pursuant to Section 18 of the Federal Power Act.
COMMENTS
Preliminary Application Document
General The PAD is comprehensive and provides most of the information necessary.
Specific Section 5.6(d)(2) Project location, facilities and operations 20170215-5036 FERC PDF (Unofficial) 2/15/2017 11:10:01 AM
(v) (1) The applicant should explain the current license articles.
Section 5.6(d)(3)(iii) Water Resources The applicant should provide Connecticut River flow duration curves as project operations are directly affected by the CT River flow (no operation when the River flow is below 15,000 cfs). This will show when the project is able to generate.
Section 5.6 (d)(3)(iv) Fish and Aquatic Resources The applicant should include a brief description of the fishery and rare plant and wildlife resources present in the Connecticut River and the bypassed reach in the area of the project. Much of this information is now in the public record from the relicensing process underway for the surrounding project (P-1889/2485). This is important because project operations may have an effect on American Shad and American Eel migration via false attraction to the project’s tailrace as fish attempt to pass through the bypassed reach to reach spillway fishway located at the Turners falls dam and downstream passage protection. This potential adverse impact should be stated in section (C). Section (D) should contain a statement that references license articles 401, 402, and 402 and why they are necessary (possible false attraction to the project tailrace and downstream passage protection).
Joint Agency Meeting
Water use agreement. The Division would like more clarification on how potential (likely) changes to the flow allocation at the Turners Falls Dam under the new license for P-1889/2485 will affect Project operations.
Intake rack spacing. The current license calls for 1 inch clear space racks- this was for the protection of Atlantic Salmon smolts. It is likely that the Division will ask for ¾ inch clear space racks to guard against adult downstream migrant American Eel entrainment. The new license for P-1889/2485 will include upstream eel passage. Passing more eels upstream will lead to more eels migrating downstream, and a need for entrainment prevention.
Fishery resources in Project area. Atlantic Salmon: The US Fish and Wildlife Service withdrew support from the Connecticut River Atlantic Salmon Restoration Program in 2013. The last Atlantic salmon fry were stocked in the basin upstream of Turners Falls in 2013. As such the last adults produced by the program should be returning to the CT River in spring 2017. Therefore Atlantic salmon should be removed from the list of migratory fish in the project area. Striped Bass: There have been just over 1,000 Striped Bass passed over the Holyoke dam in the last five years combined. As many of these undoubtedly went back down stream later in the season it is unlikely that Striped Bass need to be a concern in the Project area.
20170215-5036 FERC PDF (Unofficial) 2/15/2017 11:10:01 AM
Changes in operations. The Project owner stated that they are contemplating changes in Project operations, but could not elaborate at this point. Resource agencies need to know of any potential changes in Project operations so that we may develop appropriate study requests.
Thank you for this opportunity to comment.
Sincerely, Sincerely,
Caleb Slater, Ph.D. Thomas W. French, Ph.D. Anadromous Fish Project Leader Assistant Director for the Natural Heritage & Endangered Species Program
cc: Melissa Grader, USFWS Robert Kubit, MA DEP
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UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE GREATER ATLANTIC REGIONAL FISHERIES OFFICE 55 Great Republic Drive Gloucester, MA 01930-2276
March 27, 2017
Mr. Robert A Gates Vice President – Turners Falls Hydro, LLC 116 N. State Street PO Box 167 Neshkoro, WI 54960
RE: Comments on Preliminary Application Document for the Turners Falls Hydro Project (FERC No. 2622)
Dear Mr. Gates,
On April 22, 2016, FERC issued a Notice of Intent to file a license application for the Turners Falls Hydro LLC project (FERC No 2622), located in Montague, MA. Your company held a joint agency meeting on February 6, 2017, to discuss various aspects of the project and to provide an overview of the relicensing process. Our primary interest for this project is the protection of migratory fish within the Turners Falls power canal. Migratory fish such as American shad are at risk for entrainment through the intakes or impingement on the trashracks. We also seek to ensure that upstream migrating fish in the bypass reach are not delayed by any false attraction created by the powerhouse as they approach the fishway near the Turners Falls Dam (FERC No. 1889) that is operated by FirstLight Power Resources. Attached herein are our comments on the Preliminary Application Document and one study request.
If you have any questions, please contact Sean McDermott, at ([email protected]) (978) 281-9113.
Sincerely,
Louis A. Chiarella Assistant Regional Administrator for Habitat Conservation
cc: Service List
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National Marine Fisheries Service's Comments on the Preliminary Application Document for the Turners Falls Hydro Project (FERC No. 2622) and Study Request
1.0 PROJECT DESCRIPTION
The Turners Falls Hydroelectric project (TFH) P-2622 is located in Franklin County, Massachusetts on the Turners Falls Power Canal off of the Connecticut River.
TFH draws its flow through an intake gate in the wall of the Turners Falls Canal to an 8.5-foot diameter, 50-foot long steel penstock. Water flow is controlled at the powerhouse by two slide gates. After passing through the turbine, water flows in a flume underneath the adjacent mill complex approximately 50 feet to an excavated, walled, tailrace, and approximately 80 additional feet back into the Connecticut River.
TFH does not control the Turners Falls Dam, impoundment or canal, but rather has rights, via an indenture, to draw 100% of its hydraulic capacity (289 cfs) from the Turners Falls power canal continuously whenever it is operating. The project has an installed capacity of 937 kW.
The Turners Falls Dam is operated and maintained by Cabot Station (P-1889) and the Northfield Mountain Pump Storage Project (FERC No. 2485) as a component of its lower reservoir. Connecticut River flow is diverted by Turners Falls Dam into the Turners Falls power canal for use by TFH, Southworth Manufacturing (formerly Esleeck Paper), and Cabot Station at the lower end of the canal. Since 1951 TFH has operated under a Water Exchange Agreement with the owners of the dam and power canal to stop power generation whenever Connecticut River flow is less than 15,000 cfs. The Turners Falls/Northfield Mountain Projects (P-1889/2485) owns and operates all of these components, and a range of fish and wildlife protection and mitigation requirements are currently assigned to that license (P-1889/2485).
While additional protection and mitigation measures are being considered in the Turners Falls (FERC No. 1889) relicensing, we expect that the licensee for Turners Falls Hydro (FERC No. 2622) will implement downstream protective measures for migratory fish that are expected to be present in the power canal. The existing license articles for this project call for the trash rack spacing to not exceed 1 inch and for the intake velocity to not exceed 0.68 feet/second.
2.0 NOAA TRUST RESOURCES
NOAA’s National Marine Fisheries Service (NMFS) acts on behalf of the U.S. Department of Commerce as a trustee for natural resources. Specifically, we are a trustee for coastal and living marine resources, including commercial and recreational fisheries; diadromous species; marine mammals, and estuary and coastal habitat systems. Estuaries and coastal riverine habitat systems, including rivers such as the Connecticut River, provide an integral component of significant ecological functions for the larger marine environment. Many living marine resources are 20170327-5271 FERC PDF (Unofficial) 3/27/2017 4:48:59 PM
supported by estuaries and coastal rivers throughout their life cycles. Species such as endangered shortnose sturgeon, alewife, blueback herring, American shad, American eel, and sea lamprey rely on these coastal systems for refuge, spawning, rearing and nursery habitat. National Marine Fisheries Service’s Habitat Enterprise Strategic Plan (NMFS 2016) includes a goal to conserve habitat for managed fisheries and protected resources. This goal is focused on strengthening how the Habitat Enterprise addresses its core mandates of supporting managed fisheries and protected resources. It targets six key habitat types that support fisheries and protected resources and their prey, including rivers. Historically, all these species were present at the Turner’s Falls Hydro tailrace.
3.0 FEDERAL STATUTORY REQUIREMENTS
We are responsible for the conservation, management, and protection of the nation’s living marine and aquatic resources throughout jurisdictional river basins. We work in coordination with other state and federal agencies, local governments, Indian tribes, fisheries commissions, commercial and recreational fishers, and conservation organizations. Our authority to manage diadromous fish in these river basins comes from Congress. Specifically, Congress has directed our agency to manage diadromous species in river basins, including a grant of discretionary authority to us, to order fish passage at dams licensed by the Federal Energy Regulatory Commission (FERC). Our congressionally mandated statutory authorities include the Federal Power Act, the Endangered Species Act, the Magnuson-Stevens Fishery Conservation and Management Act, the Atlantic Coastal Fisheries Cooperative Management Act, the Fish and Wildlife Coordination Act, and the National Environmental Policy Act. Based on these laws, we have developed policies designed to implement these laws.
4.0 NOAA FISHERIES HABITAT ENTERPRISE STRATEGIC PLAN
The NOAA Fisheries Habitat Enterprise Strategic Plan (NMFS 2016) identifies the protection and restoration of coastal marine habitats that support NOAA trust resources. An important objective of the strategic plan is to “Increase resilience of coastal ecosystems, communities, and economies through habitat conservation.” Our strategic plan further identifies the Protected Resources program to protect and work to recover species at risk of extinction, and the Fisheries Management program to ensure maintenance of fisheries at productive levels for supporting sustainability and the ecosystems to which they contribute. Strategies utilized to achieve this objective include implementing cooperative approaches at the local level in habitat conservation and restoration, including greater involvement in the review of FERC activities; and, by working to increase the survival of anadromous fish passing through hydroelectric facilities.
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5.0 COMMENTS ON THE PRELIMINARY APPLICATION DOCUMENT (PAD)
5.1 PAD § 5.6 (d)(2) – Project Location, facilities and operations: Section (E)(v)(1) Description of current license requirements (page 7)
The PAD indicates that licensee expects to see a continuation of the Water Exchange Agreement. We anticipate that operational changes to FirstLight’s Turners Falls Project (FERC No. 1889) and FirstLight’s Northfield Mountain Pumped Storage (FERC No. 2485) will result in flow changes to the Turners Falls canal, from which Eagle Creek draws upon its water source. Eagle Creek should be aware that the timing and duration of generation operations could change as a result of changes to FirstLight’s operations.
5.2 PAD § 5.6 (d)(3)(i) - Existing environment and resource impacts: Section (A) Description of existing environment (pages 7 and 8)
We agree with the U.S. Fish and Wildlife Service and Massachusetts Division of Fisheries and Wildlife that timing and drawing of flow from the canal may need to be mitigated to avoid impacts on the upstream migrating shad.
5.3 PAD § 5.6 (d)(3)(iv) - Fish and aquatic resources: Section (A) Identification of existing fish and aquatic communities (page 11)
The if-then statement in this sentence is confusing. It is not clear why Eagle Creek cannot continue its use of the Water Exchange Agreement and install fish barriers in its tailrace to prevent upstream migrating shad from being stalled in their migration.
6.0 REQUESTED STUDY
We are requesting one desktop study to assess the potential effect of project operations on migratory fish within the Turners Falls Power Canal.
6.1 Desktop assessment of American shad and sea lamprey impingement and entrainment of within the Turners Falls canal.
We have been heavily involved in the relicensing of the Turners Falls Project (FERC No. 1889) in order to protect and restore our trust species in the Connecticut River. We seek to ensure safe, timely and effective passage for our migrating trust species that are within the Turners Falls Power Canal.
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6.1.1 Goals and Objectives
The goal of this study is to estimate entrainment and impingement rates of American shad, sea lamprey and American eel that migrate past the Turners Falls Hydro intakes. Table 1 summarizes the species and life stages that should be assessed in this study.
Table 1. Species, life stage and migratory direction to be assessed.
Upstream Downstream Species (life stage) migration migration American shad (adult) Yes Yes American shad (juvenile) No Yes Sea lamprey (juvenile) No Yes Sea lamprey (adult) Yes No American eel (silver) No Yes
6.1.2 Resource Management Goals
A long-term goal of our Habitat Enterprise Strategic Plan (NMFS 2016) is to “conserve habitat for managed fisheries and protected resources.” To the extent that sea-run migratory species continue to use the Turners Falls Power Canal for their upstream and downstream migration, we seek to ensure that safe, timely and effective passage is provided past the intake units for this project. A desktop analysis of this project can provide estimated rates of impingement and entrainment, and inform the need for mitigation measures.
6.1.3 Public Interest
The requestor, NMFS, is a federal resource agency.
6.1.4 Existing Information and Need for Additional Information
Staff at the U.S. Geological Survey’s S.O. Conte Anadromous Fish Research Center have tracked shad movement through the Turners Falls Power Canal. As part of relicensing FERC Project No. 1889, FirstLight has tracked adult American shad, juvenile American shad and adult American eel through the Turners Falls Power Canal. To date, no information exists regarding impingement and entrainment rates for fish that migrate past the Turners Falls Hydro intake.
6.1.5 Project Nexus
During the spring migration season, FirstLight passes thousands of shad and sea lamprey at its Cabot Station fish ladder. Many of the fish that successfully pass this ladder swim directly past the Turners Fall Hydro Project. The Turners Fall Hydro Project operations have the potential to impinge or entrain fish during their upstream migration.
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Adult American shad, juvenile American shad, and adult American eel migrate downstream and are present in the Turners Falls Power Canal as part of their migration to the ocean. Here too, our trust species may be impinged or entrained by the Turners Falls Hydro Project.
6.1.6 Proposed Methodology
We request that a report include the frequency of project operating in the spring when upstream migration is occurring for American shad and sea lamprey. Based on this information, an estimate of the likelihood of impingement on the trash racks and entrainment through the units is needed. We also request a similar analysis of the frequency of project operations in the fall when post spawning shad, juvenile shad, juvenile sea lamprey and adult eels are expected to be migrating past the project. If this analysis determines that entrainment is likely for any of these upstream or downstream migrating species, then mortality rates can be estimated using the methods described in Franke (1997) which are based off of the type of turbine and speed of the turbine blades. Velocity in front of the trash rack and trash rack clear spacing should be taken into account when determining impingement and entrainment for each species and life stage.
6.1.7 Level of Effort and Cost
The Turners Falls Hydro Project is a small project with limited time of production and generates approximately 20% of a given year based on the flow duration curve and has a rated capacity of 937 KW. The cost of this desktop study is commensurate with the size and scale of this project.
7.0 LITERATURE CITED
Franke, GF, Webb, DR, Fisher, RK, Mathur, D, Hopping, PN, March, PA, Headrick, MR, Laczo, IT, Ventikos, Y & Sotiropoulus, F. 1997. Development of environmentally advanced hydropower turbine system design concepts. U.S. Department of Energy and Hydropower Research Foundation. National Marine Fisheries Service (NMFS). 2016. NOAA Fisheries Habitat Enterprise Strategic Plan: 2016-2020.
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Ss ss FISH AND WILDLI}'E SERVICE SStcs 3 33" New Fngland Field Office 70 Commercial Street, Suite 300 Concord, NH 03301-5087 http //www fwc gov/newennl anrl
REF: Turners Falls Hydro LLC April 13, 2017 Tumers Falls Hydroelectric Project, FERC No. 2622 Connecticut River COMMFNTS ON PRF.-APPLICATION DOCUMFNT STUDY REQUESTS
Robert Gates Eagle Creek Renewable Energy
65 Madison Avenue, Suite 500 I '1 Morristown, NEI 07960 co
Dear Mr. Gates:
This responds to the Pre-Application Document (PAD) for the Turners Falls Hydroelectric Project (TFHP, or Project), located on the Connecticut River in Franklin County, Massachusetts. The PAD was submitted to us on December 2, 2016 by Eagle Creek Renewable Energy on behalf of Turners Falls Hydro LLC (TFH, Applicant) in preparation of an application for a new Federal license for the Project. TFH held a Joint Agency Meeting (JAM) and site visit on February 7, 2017 that we participated in remotely. Based on information provided in the PAD and at the JAM we offer the following "";ments.
PROCEDURAL
Concurrent with the filing of the PAD, TFH submitted a request to the Federal Energy Regulatory Commission (FERC) to use the Traditional Licensing Process. By letter dated April 22, 2016, FERC approved TFH's request.
PRE-APPLICA TION DOCUMENT
PROPOSAL
The Project consists of an intake off of the power canal associated with FirstLight Power Resources'FL) Turners Falls Project (FL-TF; FERC No. 1889). Water is conveyed from the intake through an 8.5-foot-diameter, 50-foot-long steel penstock to a single 937-kW vertical Francis turbine that operates with a hydraulic capacity of 289 cfs. After leaving the turbine, water flows into a 130-foot-long tailrace, which discharges into the FL-TF bypass reach. The 20170421-0233 FERC PDF (Unofficial) 04/21/2017
E obert Gates April 13, 2017
project works are contained within a 3,026 square foot area inside the former International Paper Company (IPC, a.k.a. Strathmore Paper) paper mill building that stands alongside the power canal. There is no dam associated with the Project. The Applicant operates the Project pursuant to a Water Exchange Agreemcnt (WEA) that requires TFHP to pass llov by its intake, downstream to the FL-TF generating stations. In return, FL-TF pays TFH for these flowage rights, which are exercised whenever canal flow rates are less than 15,000 cfs.
'fFH states there will be no change in the operation of the Project after relicensing. Minor improvements, such as automating the gate lifters to replace the manually operated rack and pinion gears, may occur in the future.
Over the last 5 years, annual generation has averaged 1,512,009 kilowatt hours (kWh) with annual non-generation averaging 7,493,697 kWh (i.e., the extra output credited to TFII as part of the WEA).
In the PAD, TFH has proposed no protection, mitigation and enhancement measures beyond those required in the current license.
COMMENTS
Description of Proposed Facilities
Future consultation documents should provide additional information, including:
~ the dimensions of the trashrack (wetted portion) and clear spacing between rack bars; ~ the minimum hydraulic capacity of the Francis turbine; ~ the turbine specifications (i.e., number of buckets, runner diameter, runner speed, etc.); ~ a map showing the project boundary; and ~ project drawings in plan, section and elevation views.
TFH does not specify whether the station is manned or automated. When we presented this question during the JAM, TFH stated that the station is unmanned. Similarly, little information on the operations control system is provided in the PAD. There is ret'erence to a Programmable Logic Control system but no details on how it actually works. Given that the site is unmanned, the Project is not automated, and it always runs at the same gate setting, it is unclear what the purpose of the PLC system is.
Description of Existing Environment
TFH states that its operations do not impact the environment in and around the Project, then references two issues that we and the Massachusetts Division of Fisheries and Wildlife (MADFW) have raised in the past: potential impact of project operations on adult American shad (Alosa sapidissima) migrating upstream through the canal and false attraction to the station's tailrace. 20170421-0233 FERC PDF (Unofficial) 04/21/2017
April 13, 2017
TFH should be aware that the canal issue related to downstream migrating juvenile Atlantic salmon (Salmo salar), not adult shad. In addition, it bears noting that issues raised by the agencies resulted in FERC imposing two conditions on the existing license: Article 401 requires the licensee to install trashracks with specification designed to minimize impingement and entrainment, and Article 402 requires the licensee, upon joint notification of our office, the MADFW, and the Connecticut River Atlantic Salmon Commission, to file a plan to implement measures needed to minimize delays to upstream migrating anadromous tish at the TFHP when such delays are identified by the aforementioned agencies.
TFH indicates that the WEA makes it unlikely the station would operate during summer months. However, adult shad do not migrate upstream in the summer; rather, they move upstream from May through June. According to the project generation information provided in Appendix B of the PAD, on average TFHP generates 77 percent of the time in April, 55 percent of the time in May, and 36 percent of the time in June.
Existing Data or Studies Regarding the Resource
TFH provides no summaries of existing data or studies regarding river resources. While resource issues may be somewhat limited due to the Project being located on a canal, there is much information available on resources within the vicinity of the TFHP as a result of the studies completed by FL for the relicensing of the FL-TF project. TFH should provide summaries of all relevant resources (e.g., canal and bypass reach), as appropriate.
Known or Potential Adverse Impacts and Issues Associated with the Project
TFH states there are no known or potential adverse impacts of its Project. One obvious potential impact is impingement on and entrainment through the trashracks. The existing license contains Article 401, which requires the licensee to install. operate, and maintain a trashrack as proposed in TFH's May 3, 1990 filing with FERC, including bar spacing not to exceed I inch and intake velocities not to exceed an average of 0.68 feet per second (fps) (as estimated within 3 inches off the face of the trashrack). During the JAM, stakeholders were informed that, while trashracks meeting those specifications had been in place for a number of years, in 2007 they were replaced with racks having a clear spacing of 1.25 inches.
A second potential impact is false attraction to the tailrace discharge. As noted above, the TFHP operates, on average, from 36 to 77 percent of the time during the anadromous upstream migration season. Currently mandated flows from the FL-TF dam vary seasonally: beginning May I, FL maintains a continuous flow of 200 cfs at the dam, which increases to 400 cfs once the fish passage season begins. This flow is maintained until July 15 or the end of the fish passage season, whichever occurs first. Once the ftshways are closed, FL provides 120 cfs to the bypass reach until river temperature drops below 7'C.
Given that TFHP's flow (298 cfs) represents nearly 43 percent of the total (required) flow in the upper bypass reach during the fish passage season, it represents a potential source of false 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert Gates April 13, 2017
attraction for upstream migrants, particularly when those are the only flows present in the upper bypass reach (i.e., when Turners Falls Dam is not spilling).
Existing or Proposed Protection, Mitigation or Enhancement Measures
TFH states that the project license does not contain any mitigation measures. As noted above, the existing license requires, and TFH fulfilled, an obligation to install trashracks with specifications to reduce the potential for impingement and entrainment. Although the racks were subsequently replaced with wider-spaced racks that did not meet these specifications, the requirement for fish- excluding trashracks should be noted in future consultation documents.
The Applicant also states that it does not contemplate further impacts on its operations due to any changes that may occur in the FL-TF project license. However, if FERC orders changes to the way the canal is operated, TFH would adjust its operations to comply with those measures. There likely will be substantial changes to the way the FL-TF project operates. This in turn could have implications on the WEA and TFH's operations. Although TFH states that it is not a party to the FL-TF relicensing, it could participate in the proceedings and probably should, given that its operations may be impacted.
As the FL-TF license should be issued prior to the TFHP license, TFH should address and incorporate any anticipated changes to its operations and any related resource impacts from those changes in future consultation documents.
Water Resources
TFH provides no water quality information in this section, stating that the control ot'ater quality is the obligation of the FL-TF project. While we defer to the Massachusetts Department of Environmental Protection on this matter, it seems appropriate for TFH to address water quality, as its Project uses river water to generate power. We recommend that TFH provide results of water quality studies done as part of the relicensing proceeding for the FL-TF proiect relevant to the TFHP (i.e., present water quality monitoring results for the canal and bypass reach).
Fish aud Aquatic Resources
As with the Water Quality section of the PAD, TFH provides no information on fish and aquatic resources within the project area, stating that it does not control flow in the canal, above the Turners Falls Dam (TFD), or in the bypass reach. The TFHP draws water off of the canal, passes it through the project turbines and back into the Connecticut River downstream of the TFD. Operation of the Project potentially impacts aquatic resources both within the canal and in the bypass reach.
As noted above, many studies were conducted as part of the relicensing of the FL-TF project, including fish assemblage surveys, an American eel (Angttilla rostrata) migration timing assessment, an adult American shad upstream and downstream radio telemetry study, juvenile American shad and adult American eel downstream passage studies, an impingement and 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert cates April 13, 2017
entrainment assessment. a canal drawdown survey, and an instream flow study. Some component of all of those studies relate to either the Turners Falls canal or the Turners Falls bypass reach; therefore, it is reasonable and appropriate for TFH to synthesize, summarize and report the results of those studies that are relevant to the TF'H project area.
Rare, Threatened and Endangered Species
TFH states that there is no habitat for rare, threatened and endangered, or special status (RTE) species on its property. Actually, in this section of the PAD, the Applicant is asked to describe any RTE species in the project vicinity. TFH should review the study reports generated as part of the relicensing proceedings for the FL-TF project and use that information to ascertain which (if any) RTE species are located in the vicinity of the TFHP, as well as potential project impacts on those species. For example, the bypass reach is a known spawning location of the federally endangered shortnose sturgeon (Acipenser brevirostrum) and a number of State-listed RTE plant species have been documented there also.
Preliminary Issues and Studies List
Issues Pertaining to Identified Resources
TFH states that the only issues related to this Project raised previously were potential measures to minimize false attraction of shad and Atlantic salmon to the project tailrace and entrainment of shad migrating upstream through the canal. The entrainment concern actually related to Atlantic salmon smolts migrating downstream, not for adult shad migrating upstream. This concern was the reason why I-inch-spaced trashracks were required to be installed.
While salmon smolts may have been the focus of entrainment discussions during the last license proceeding for this Project, that is no longer a concern given the suspension of the Connecticut River Atlantic salmon restoration efforts. However, entrainment of outmigrating juvenile shad and adult silver eels is aLso a concern. Results of recent fish passage studies conducted as nart of the relicensing proceedings for the FL-TF project indicate high entrainment ofjuvenile shad and adult eels into that project's turbine intakes. The FL-TF Cabot Station intake has trashracks with I-inch-clear spacing for the upper 11 feet, then 5-inch-clear spacing for the bottom 13 feet of the racks. While those studies did not assess the depth at which entrainment occurred, passage through the upper I-inch-spaced portion is possible and we are aware of other instances where eels have been entrained through racks with I-inch spacing and juvenile shad are physically able to pass through racks with I inch spacing. Therefore, even if the TFH Project had the required I- inch-spaced racks in place (which it has not had since 2007), entrainment would be an issue of concern.
In additiorn as identified above, the Project operates during a portion of the upstream migration season and potentially provides as much as 43 percent of the flow to the upper bypass reach which could result in false attraction to the tailrace. Migration delays exert additional energy demands which could reduce passage and/or spawning success, as well as increase the risk of post-spawn mortality. It is likely that FL will be required to release more flow to the bypass reach which may alter the effects of the TFH Project. However, assessing false attraction to the 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert cates April 13, 2017
project tailrace will be difficult until the quantity and means of providing additional bypass flows have been determined for the FL-TF project.
Potential Studies Associated with identified Issues
TFH states that it "must await agency consultation to obtain more detail about changes in the FL- TF project before it is possible to detail the information needs of the studies that may be required." We are unclear what this statement actually means. Regardless, we have identified study needs that are independent of the FL-TF relicensing.
Relevant Comprehensive Waterway or Resource Management Plans
While TFH does not identify any qualifying comprehensive plans in the PAD, we believe there are at least seven plans recognized by FERC that are relevant to the TFHP:
1. Atlantic States Marine Fisheries Commission. 1999.Amendment I to the Interstate Fishery Management Plan for shad and river herring. (Report No. 35). April 1999; 2. Atlantic States Marine Fisheries Commission. 2000. Technical Addendum I to Amendment I of the Interstate Fishery Management Plan for shad and river herring. February 9, 2000; 3. Atlantic States Marine Fisheries Commission. 2009. Amendment 2 to the Interstate Fishery Management Plan for shad and river herring, Arlington, Virginia. May 2009; 4. Atlantic States Marine Fisheries Commission. 2010. Amendment 3 to the Interstate Fishery Management Plan for shad and river herring, Arlington, Virginia. February 2010; 5. Atlantic States Marine Fisheries Commission. 2000. Interstate Fishery Management Plan for American eel (Anguilla rostrata). (Report No. 36). April 2000; 6. Connecticut River Atlantic Salmon Commission. 1992. A management plan for American shad in the Connecticut River Basin. Sunderland, Massachusetts. February 1992; and 7. National Marine Fisheries Service. 1998. Final Recovery Plan for the shortnose sturgeon (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for the National Marine Fisheries Service, Silver Spring, Maryland. December 1998.
in addition, until such time as FERC qualifies them as Comprehensive Plans, the following should be considered as relevant resource management plans:
1. Atlantic States Marine Fisheries Commission. 2008. Addendum II to the Fishery Management Plan for American Eel. October 23, 2008; and 2. Massachusetts Division of Fisheries and Wildlife. 2015. Massachusetts State Wildlife Action Plan 2015. Accepted November 8, 2016. 20170421-0233 FERC PDF (Unofficial) 04/21/2017
R ~he rt (:~ts e April 13, 2017
ADDITIONAL INFORMATION
The following information is needed:
~ the approach velocity at the TFHP intake (based on the trashrack width and wetted depth at normal water surface elevation, given the turbine's maximum hydraulic capacity and the clear spacing on the trashrack): ~ design drawings of the proiect facilities and structures in plan. section and elevation view, and ~ a description of the system and equipment used to operate the Project under its existing license requirements (e.g., headpond sensor locations, set points for start-up, run and shut- down, details on how turbines are brought on- and off-line, etc.).
RECOMMFNDFD STUDIES
TFH has proposed no studies in the PAD. Enclosed please find our formal study requests (Attachment A) in the format required pursuant to 18 CFR $4.38(b)(5).
Thank you for this opportunity to comment. If you have any questions regarding these comments, please contact Melissa Grader at 413-548-8002, extension 8124.
Sincerely y~o
Thomas R. Chapm Supervisor Nie * En I nd Field Offi
Enclosure 20170421-0233 FERC PDF (Unofficial) 04/21/2017
n to+I stoa April 13, 2017
cc: FERC, Secretary NMFS, Bill McDavitt (via email) NMFS, Bjorn Lake (via email) MA DFW, Caleb Slater (via email) MA DEP, Robert Kubit (via email) MA NHESP, Jesse Leddick (via email) CRC, Ken Sprankle (via email) CRWC, Andrea Donlon (via email) TU, Don Pugh (via email) Louis Berger, Matthew Burak 9 Jarvis Avenue Holyoke, MA 01040 Reading file ES: MGrader:4-13-17:603-223-2541 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert Gates April 13, 2017
Literature Cited
Franke, G.F., D.R. Webb, R.K. Fisher, Jr., D. Mathur, P.N. Hopping, P.A. March, M.R. Headrick, I.T. Laczo, Y. Ventikos and F. Sotiropoulos. 1997. Development of environmentally advanced hydropower turbine system design concepts. Prepared for V.S. Department of Energy, Idaho Operations Office. Contract DE-AC07-94IDI 3223. 20170421-0233 FERC PDF (Unofficial) 04/21/2017
ATTACHMENT A
Study Request: Migratory Fish Downstream Passage Assessment and Protection Evaluation
(I) Goals and Obiectives
The objectives of the study are to: (I) Assess the risk of American eels (Anguilla rostrara) and American shad (Alosa sapidissima) becoming impinged or entrained; (2) estimate turbine survival; and (3) evaluate potential passage and protection measures.
(2) Resource Manaaement Goals
The Atlantic States Marine Fisheries Commission has developed two documents related to the management of American eel:
1. Interstate Fisherv Management Plan for American Eel. April 2000. Atlantic States Marine Fisheries Commission; and 2. Addendum II to the Fisherv Manaaement Plan for American Eel. Atlantic States Marine Fisheries Commission. Approved October 23, 2008. 8 pp.
Objectives of these management plans include: (I) protect and enhance American eel abundance in all watersheds where eels now occur; and (2) where practical, restore American eel to those waters where they had historical abundance but may now be absent by providing access to inland waters for glass eel, elvers, and yellow eel and adequate escapement to the ocean for pre- spawning adult eel.
Addendum II contains specific recommendations for improving upstream and downstream nassam of A meric an er!, includina requesting that member states and jurisdictions seek special consideration for American eel in the FERC relicensing process.
The Atlantic States Marine Fisheries Commission has developed several documents related to the management of American shad and river herring:
1. Atlantic States Marine Fisheries Commission. 1999. Amendment I to the Interstate Fisherv Manauement Plan for shad and river herrina. (Report No. 35). April 1999; 2. Atlantic States Marine Fisheries Commission. 2000. Technical Addendum I to Amendment I of the Interstate Fisherv Manaaement Plan for shad and river herrinu. February 9, 2000; 3. Atiantic States lvfarine Fisheries Commission. 2009. Amendment 2 to the Interstate Fisherv Manauement Plan for shad and river herrinv, Arlington, Virginia. May 2009; and 4. Atlantic States Marine Fisheries Commission. 2010. Amendment 3 to the Interstate Fisherv Manaaement Plan for shad and river herrina, Arlington, Virginia. February 2010. 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert Oaiec April 13, 2017
Amendment 3 to the Interstate Fishery Management Plan tor Shad and River Herring includes an objective of maximizing the number of juvenile recruits emigrating from freshwater stock complexes and recommends enhancing survival at dams during emigration by evaluating survival of post-spawning and juvenile fish passed via each route (e.g., turbines, spillage, bypass facilities, or a combination of the three) at any given facility, and implementing measures to pass fish via the route with the best survival rate.
In addition, the Connecticut River Atlantic Salmon Commission (CRASC) developed A Management Plan for American Shad in the Con»ecticat River in 1992. Management objectives in the plan include maximizing outmigrant survival for juvenile and spent adult shad.
Specific to resident riverine and migratory fish entrainment, the U.S. Fish and Wildlife Service's (Service) goals are:
1. minimize current and potential negative project operation effects such as turbine entrainment that could hinder management goals and objectives; and 2. minimize project-related sources of mortality to resident and migratory fishes in order to restore natural food web interactions and ecosystem functions and values.
Our study requests are intended to facilitate the collection of information necessary to conduct effects analyses and to develop reasonable and prudent conservation measures, and protection, mitigation, and enhancement measures pursuant to the Endangered Species Act of 1973, as amended (16 U.S.C. fj1531 et seq.), the Fish and Wildlife Coordination Act, as amended (16 U.S.C. Ij661 et seq.), and the F'ederal Pov er Act (16 U.S.C. ss791 a, et seq.).
(3) Public Interest
The requestor is a resource agency.
(41 Existinp, Information
No project-specific information exists regarding risk of impingement and/or entrainment of fish at the Turners Falls Hydroelectric Project (TFHP). In the Pre-Application Document (PAD), Tumers Falls Hydro, LEC (TFH) provided little information that would inforni tlie i'elative risk of impingement or entrainment. During the Joint Agency Meeting, TFH informed stakeholders that the licensed I-inch-clear racks had been replaced in 2007 with racks having 1.25-inch-clear spacing. While the existing license required the intake velocity to not exceed 0.68 fps, without design drawings or trashrack specifications (wetted area), we are unable to verify if this criterion is being adhered to. Relevant turbine specifications provided in the PAD include the type (vertical Francis), speed (225 rpm), hydraulic capacity (289 cfs), and head (44 feet).
(5) Nexus to Proiect Onerations and Effects
Hydropower projects generate electricity by moving water through a turbine-generator system. Typically, there are trashracks in front of the intakes leading to the turbines. If the rack spacing is narrow and the velocities at the racks too high (relative to the swim speeds of fish species 20170421-0233 FERC PDF (Unofficial) 04/21/2017
Robert Gat-s April 13, 2017
inhabiting or moving through the headpond), fish may become impinged against the racks and ultimately die. If the rack spacing is wide and the velocities too high (relative to the swim speeds of fish species inhabiting or moving through the intake area), fish may become entrained (i.e., pass through the racks) and get injured or die while passing through the turbines.
Adult eels and juvenile shad use the Turners Falls canal to move downstream as they migrate to the ocean. During this migration, they are at risk of becoming impinged on the racks or entrained through the racks and subsequently exposed to potential turbine-induced injury or mortality.
Under the existing Water Exchange Agreement (WEA) with FirstLight Power Resources (FL; licensee for the Tumers Falls Project, FERC No. 1889), TFH only operates the Project when flow in the canal exceeds 15,000 cfs. The downstream migration period for juvenile shad and adult eels generally runs from August I through November 15. Based on the generation data provided in Appendix B of the PAD, the Project operates from 0 to 18 percent of the time during this period. When it does generate, it represents Jess than 2 percent of the flow in the canal. In addition, the racks are oriented parallel to the river flow. While these factors help reduce the potential for impingement and entrainment under the current WEA, it is unclear if this WEA may be modified as a result of new operational conditions that may be imposed by FERC on any new license issued for the FirstLight Power Resources'urners Falls Project.
(6) Methodolouv Consistent with Accepted Practice
The Service proposes a phased approach to this study.
Phase I: Determine the clear rack spacing and velocities at the intake. The intake velocity can be calculated by the dimensions of the trashrack (width by wetted depth at normal pool elevation). In addition, the calculated average velocity should be ground-truthed with empirical velocity measurements with an appropriate velocity meter to determine if velocity "hot spots" occur along the rack face during generation. If velocities are less than 1.5 feet per second and the clear rack spacing is '/~-inch or less, no additional information would be needed. If either of these criteria are not met, TFH should proceed to Phase 2.
Phase 2: TFH should assess impingement, entrainment and survival at the Project for adult eels and juvenile shad via a desktop analysis. The desktop analysis should characterize the potential for impingement or entrainment based on the relationship of site-specific intake characteristics, along with swim speed and life history characteristics of these species. The general protocol should be similar to the one outlined in TransCanada's Revised Study 23 for the relicensing of its Wilder, Bellows Falls, and Vernon projects on the Connecticut River (FERC Nos. 1892, 1855, and 1904; Accession ¹20130814-5021).In particular, we support and encourage use of the Franke et al. (1997)turbine blade strike equation to estimate turbine survival. If the results of the desktop analysis indicate a through-project survival rate of 95 percent or greater for all species/life stages, no further analysis would be required. However, if survival is estimated to be less than 95 percent, TFH should proceed to Phase 3. 20170421-0233 FERC PDF (Unofficial) 04/21/2017
RUUelTl -L- l Vdles April 13, 2017
Phase 3: TFH should investigate existing or potential future operational and/or physical measures that would minimize injury or mortality to eels and shad migrating past the Project. Based on the results of this investigation, TFH should provide a range of potential alternatives (e.g., seasonal or nightly shut-downs, opening a lov level outlet or waste/sluice gate, installing seasonal rack overlays, etc.).
(7) I,evel of Effort/Cost. and Whv Alternative Studies will not suffice
The cost and effort of each individual phase of this study are expected to be low. A similar study on the Connecticut River that involved multiple species at three separate projects was estimated to cost $65,000. Based on the scale and scope of the subject study, we estimate the cost to be $ 10,000 to $20,000.
In the PAD, TFH proposes no studies to address this issue. The Service is not aware of any previously conducted or ongoing studies related to impingement, entrainment or survival of eels or shad at the Project. 20170421-0233 FERC PDF (Unofficial) 04/21/2017 Document Content(s) 14568839.tif...... 1-13 Burak, Matthew
From: Burak, Matthew Sent: Thursday, September 27, 2018 12:13 PM To: Amanda Veinotte; Amy Singler; Andrea Donlon; Andrew Raddant; Angela M. O'Connor ; Bettina Washington; Bob Nasdor; Brian Harrington; Brona Simon; Bruce Carlisle; Bruce Maytubby; Charles Olchowski; Cindy Delpapa; David Cameron ; David Jensen; David Turin; Deborah Tuttle ; Debra Bourbeau; Donald Stevens; Doug Harris; Dr. Caleb Slater; Dr. Ted Castro-Santos; Greg Penta; Jack Buckley ; Jeanne Golrick; Jennifer Jillson-Soper; Jesse Leddick; Joe Lucas; Julie Crocker; Ken Kimball; Ken Sprankle; Kevin Mendik; Kim Lutz; Kimberly Noake MacPhee; Leo Roy; MA Executive Office of Energy and Environmental Affairs; MA Office of Dam Safety; Martin Suuberg; Melissa Grader; Michael Stroman ; Paul Jahnige; Peggy Sloan; Peter Golrick; Rachel Ruppel; Robert Kubit; Robert Longtoe Sheehan; Sherry White; Tim deChristopher; Tim Purinton; Timothy Brennan; Wade Blackwood; Walter Ramsey; William Connelly; William McDavitt Subject: Turners Falls Hydroelectric Project (FERC No. 2622) Draft License Application Attachments: Turners Falls P-2622 Draft License Application.pdf
TrackingTracking: Recipient Read Amanda Veinotte
Amy Singler
Andrea Donlon
Andrew Raddant
Angela M. O'Connor
Bettina Washington
Bob Nasdor
Brian Harrington
Brona Simon
Bruce Carlisle
Bruce Maytubby
Charles Olchowski
Cindy Delpapa
David Cameron
David Jensen
David Turin
Deborah Tuttle
Debra Bourbeau
Donald Stevens
Doug Harris
Dr. Caleb Slater
Dr. Ted Castro-Santos
Greg Penta
Jack Buckley
Jeanne Golrick
Jennifer Jillson-Soper
1 Recipient Read
Jesse Leddick
Joe Lucas
Julie Crocker
Ken Kimball
Ken Sprankle
Kevin Mendik
Kim Lutz
Kimberly Noake MacPhee
Leo Roy
MA Executive Office of Energy and Environmental Affairs
MA Office of Dam Safety
Martin Suuberg
Melissa Grader
Michael Stroman
Paul Jahnige
Peggy Sloan
Peter Golrick
Rachel Ruppel
Robert Kubit
Robert Longtoe Sheehan
Sherry White
Tim deChristopher
Tim Purinton
Timothy Brennan
Wade Blackwood
Walter Ramsey
William Connelly
William McDavitt
Michael Scarzello ([email protected])
Melissa Rondou
Splenda, Jot
Burak, Matthew Read: 9/27/2018 12:47 PM
Dear Stakeholder:
Turners Falls Hydro, LLC (TFH) is distributing to resource agencies, Indian tribes, and other interested parties a Draft Application for a Subsequent License for a Minor Water Power Project for its Turners Falls Hydroelectric Project (FERC Project No. 2622). Attached to this e-mail is a copy of the Draft License Application, which includes a transmittal letter that provides instructions on how to provide comments on the application to TFH. FERC regulations allows for a 90 day
2 comment period on the Draft License Application. Therefore, comments are due to TFH no later than December 27, 2018.
If you have any questions regarding this notice please contact Michael Scarzello at (973) 998-8400 or [email protected].
Respectfully,
Matthew Burak Agent for TFH
Matthew K. Burak Senior Fisheries Biologist | Natural Resource Management mobile 518.727.5453 email [email protected] web louisberger.com
Louis Berger 9 Jarvis Avenue | Holyoke | Massachusetts | 01040 | United States
3 20181217-5216 FERC PDF (Unofficial) 12/17/2018 2:00:12 PM
UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE GREATER ATLANTIC REGIONAL FISHERIES OFFICE 55 Great Republic Drive Gloucester, MA 01930-2276
December 17, 2018
Robert A. Gates Vice President Turners Falls Hydro, LLC 116 N. State Street Neshkoro, WI 54960
RE: Comments on Eagle Creek Renewable Energy’s Draft License Application for the Turner’s Fall Hydroelectric Project (FERC No 2622)
Dear Mr. Gates:
On September 27, 2018, we received your draft license application (DLA) for your Turners Falls Hydroelectric Project (FERC No 2622) located on the Turners Falls power canal in Montague, Massachusetts. On March 27, 2017, we provided comments on the Pre-Application Document. In those comments, we requested a desktop assessment of impingement and entrainment for American shad and sea lamprey (Accession #20170327-0233).
The DLA discusses the potential project related impacts on migratory species, including American shad, sea lamprey, and American eel. As stated in the DLA, you propose, “to develop in consultation with the resource agencies a Trashrack Replacement Plan to replace the existing trashrack with a trashrack with 3/4 –inch clear spacing to mitigate entrainment, impingement, and turbine mortality of migratory species at the Project.” Your proposal to mitigate the entrainment of migratory fish directly addresses our principle concern. Therefore, a study would not be necessary at this time. We reserve the right to seek studies such as those recommended in our earlier comments if your plans for mitigation change.
We look forward to working with you to develop the Trash Rack Replacement Plan and the design of the trash rack system. If you have any questions or need additional information, please contact Sean McDermott via email ([email protected]) or 978-281-9113.
20181217-5216 FERC PDF (Unofficial) 12/17/2018 2:00:12 PM
Sincerely,
Christopher Boelke New England Field Office Supervisor for Habitat Conservation
cc: Service list
20181217-5216 FERC PDF (Unofficial) 12/17/2018 2:00:12 PM Document Content(s) P-2622 Turners Falls Hydro Comments on DLA.PDF...... 1-2 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
United States Department of the Interior
IIISH AND WILDt,IFE SERVICE
Ncw England Irield Office 70 Commercial Street, Suite 300 Concord. NH 03301-5087 http ://www. fivs. gov/newengland
Deccmber 2l . 201 8
Robert A. Gates Eagle Creek Renewable Energy 65 Madison Avenue. Suite 500 Morristown, NJ 07960
ItE FERC No. 2622 Eagle Creek Renewable Iinergy Connecticut River COMMENTS ON DRAF'T LICENSE APPLICATION
Dear Mr. Gates:
The U.S. Fish and Wildlife Service (Service) is in rcceipt of the draft License Application (DLA) submitted on September 27, 2018 by Eagle Creek Renewable Energy on behalf of I'umers Falls Hydro, LLC (TFH, Applicant), as parl ol the relicensing of the Turners Falls Hydroelectric Project (TFHP: Project), located on the Connecticut River in Franklin County, Massachusetls. We offer the following comments based on our revicw of the DLA.
BACKGROUND
TFH requested, and was granted, use of the Traditional Licensing Process by the Federal Energy Regulatory Commission (FERC). In response to TFH's Pre-Application Document, the Service provided comments and study requests by letter dated April 13, 2017 . In our letter, we requested additional information and one study: a Migratory Fish Downstream Passage Assessment and Protection Evaluation. No additional consultation bewveen the Applicant and the Service has occurred since submittal of our April I 3, 201 7 letter.
PROPOSAL 'l'he Project consists of an intake off the power canal associated with Firstlight power Resources' (F-[-) Tumers Iralls Project (t-L-l'F; FI]RC No. I 889). Water is conveyed from the intake through an 8.5-foot-diamcter,S0-floot-long steel penstock to a single 937 kw vertical Francis turbine that operates with a hydraulic capacity of 289 cfs. After leaving the turbine, water flows into a 130-foot-long tailrace, which discharges into the FL-TF bypass reach. The 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robert A. Gates 2 December 21, 2018
project works are contained within a 3.026-square-foot area inside of the former Intemational Paper Company mill building that stands alongside the power canal. There is no dam associatcd with the Project. The Applicant operates the Project pursuant to a Watcr Exchange Agreement (WEA) that requires TIil{P to pass flow by its intake, downstream to the FL-TF generating stations. In retum, FL-'f F pays 'fFH fbr these flowage rights, which are exercised whenever canal flow rates are less than 15,000 cfs. No changes to project operations are being proposed as part ofthe relicense proceeding.
COMME,NTS
Exhibit A
In our April 13,2017 letter, we requested additional information relative to project equipment, structures and f'acility operation. While the DLA provides some of the requested information, the following requests have not becn addressed.
a While the DLA provides thc trashrack dimensions, TIiH shouid state whether the racks are fully wetted under normal canal levels. If not, the wetted rack dimensions should be provided. a The DLA only provides the maximum hydraulic capacity of the Francis turbine. TFH should state whether the unit has an operating range or if it only operates at 289 cfs- Some turbine specifications (i.e., runner speed, horsepower, head) are provided in the DLA but others are not. TFII should provide all unit specifications relevant to potential entrainment injury/mortality (e.g., number of buckets, runner diameter). a Beyond stating that the station is manually operated, TFH provides no details on operational protocols, monitoring and/or recording equipment, etc. This information should be provided in the final liccnse application.
F,xhihir E
General Description
TFH states that the Tumers Falls Power Canal is 120 feet wide at the upstream end and 920 feet wide at the downstream end. Actually, the upper end ofthe canal is about 30 feet wide and at the downstream end it is approximately 300 I'eet x,ide.
Fisheries
In Section 3.2.2, TFH states that the Connecticut River supports both anadromous and diadromous species. We believe "diadromous" should be "catadromous." 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robert A. Gates J December 2l ,2018
American Shad
While the DLA discusses results of studies undertaken by FL as part of the relicense proceeding fbr the FL-TF with respect to upstream migrating American shad, TFH provides no discussion of adult shad downstream migration through the canal. [t is downstream passage of migratory fishes through the canal that is a concern rclative to operation of 'fFH's project. Therefore, the final license application should summarizc the results of the FL's downstream passage analysis fbr adult shad.
American Eel
TFH summarizes the results of upstream and downstream eel studies conducted by FL for the relicensing of the FL-TF. Because all radio{agged eels detected in the power canal escaped the project (i.e., were detected either at a passage route or downstream of the Project), TFH states they successfully bypassed the Project. However, it is possible some of those eels incurred injuries or even died as a result ol passing out of the canal; therefore, we do not believe the term "successfu lly bypassed" is an appropriate characterization.
Fish Passage
TFH states there are no fish passage facilities at the Project. While there are no structures to pass fish, there is a license requirement to protect fish liom entrainment into the turbine. The final license application should include a discussion of existing fish protection requirements.
Fisheries Resources Study Requests & Results
In response to requests submitted by the resource agencies, TFH assessed the intake velocity of the existing trashrack and calculated the velocity o1'a trashrack with %-inch spacing. Results showed that the intake velocity at the existing racks is 0.96 feet per second (lps), and with %- inch racks the velocity would increase to 1.13 fps. Rather than proceeding to undertake a desktop impingement, entrainment and mortality study, TFH is considering the installation of lo-inch trashracks to protect against turbine entrainment.
Environmental Impacts on Aquatic Resources
TFH identifies potential project impacts to migratory fish, including entrainment and impingement at the project intake, turbine mortality, and false attraction at the project tailrace. As noted in our April 13,2017 lelter, the existing project license contains Article 401, which requires the licensee to install, operate, and maintain a trashrack as proposed in TFH's May 3, 1990 filing with FERC, including bar spacing not to exceed I inch and intake velocities not to exceed an average of 0.68 fps. During the Joint Agency Meeting held on February 7,2017, stakeholders were informed that, while trashracks meeting those specifications had been in place for a number of years, in 2007 they were replaced with racks having a clear spacing of 1.25 inches. 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robert A. Gates 4 December 21. 201 8
While the calculated intake velocity ofthe existing trashrack does not exceed our design criteria for American shad or American eel, the rack spacing presents a risk of entrainment and subsequent turbine injury or mortality to both juvenile shad and adult eels. TFH states that the intake velocity ofthe existing rack is lower than the swim speed range ofjuvenile shad and adult eel documented by Bell (1990). However, results of an empirical study undertaken by FL showed substantial entrainment of adult eels occurring at the Cabot trashrack (Firstlight 2017), which also has a calculated intake velocity below that species' identified swim speed;r clearly, just because a fish can avoid entrainment is no guarantee that it will, absent physical exclusion.
TFH's estimated intake velocity with %-inch racks, while higher than the current intake velocity, would remain below our design criterion; therefore, we support, and will be requiring, TFH to install and maint ain'/c-inch racks to design specifications.
Another identified potential impact is false attraction to the tailrace discharge. The Project operates, on average, from 36-77 percent ol the time during the anadromous upstream migration season. Currently mandated flows fiom the FI--TF dam vary seasonally: beginning May 1, FL maintains a continuous flow of 200 cfs at the dam. which increases to 400 cfs once the fish passage season begins. This flow is maintained until July 15 or the end of the fish passage season, whichever occurs first. Once the fishways are closed, IrL provides 120 cfs to the bypass reach until river temperature drops below 7'C.
Given that the Project's flow (298 cl's) represents nearly 43 percent of the total (required) flow in the upper bypass reach during the fish passage season, it represents a potential source of false attraction for upstream migrants, pa(icularly when those are the only flows present in the upper bypass reach (i.e., when Tumers Falls Dam is not spitling). Further, while under the present WEA between TFH and F[., the Project only operates when canal flows exceed 15,000 cfs, there is no guarantee this WEA will remain in place for the duration of any new license issued for the Project. If the Project were to start operating under lower canal flows, it would increase the risk ofpotential false aftraction, relative to other discharge locations.
The FL-TF is still undergoing relicensing. Because it is unknown how that Project will operate under a new FERC license, it is difficult to assess the potential fbr false attraction to the Project's tailrace discharge. Therefore, we will be recommending that FERC include a license article similar 1o Article 402 of the curent license (i.e., requiring the licensee to file a plan to implement measures needed to minimize delays to upstream migrating anadromous fish at the Project when such delays are identified by the resource agencies).
Proposed Protcction, Mitigation and Enhancement Measures for Aquatic Resources
In the DLA, TFH suggcsts FL is considering installing screens at the gatehouse to prevent juvenile shad tiom the power canal. If this were to occur, it likety would obviate the need for TFH to install trashracks u,ith %-inch clear spacing. As noted above, the FL-TF has not completed the relicensing process. To our knowledge, IrL has not proposed a gatehouse screen to prevent migrants lrom entering the canal. TFII slates that, should FL not be required to install a I The calculated intake velocity at Cabot Station is 2.0 fos (Relicensing Study 3.3.7; Accession Number 20 r6 r 0 r4-51 l9). 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robcrt A. Gates ) December 21. 2018
screen at the canal gatehouse, it will develop (in consultation with the resource agencies) a plan to replace the existing trashrack with %-inch clear racks to protect downstream migrants from entrainment.
Exhibit F
In our April 13.2017 letter, we requested the Applicant provide project drawings in plan, section and elevation views. The DLA is lacking Exhibit F. We again request project drawings be provided.
Thank you for the opportunity to comment on the DLA. Should you have any questions regarding these comments, please contact Melissa Grader at 413-548-8002, extension 8124.
Sincerely yours ) /^ (
Supervisor New England Field 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robert A. Gates 6 December 2l , 201 8
BII]LIOCRAPIIY
Bell, M.C. 1990. Fisheries Handbook. Fish Passage Development and Evaluation Program,3'd edition. U.S. Army Corps of Engineers, North Pacific Division, Podand, OR. 353 pp.
Firstlight. 2017. Relicensing Study 3.3.5 Evaluate Downstream Passage of American Ee[ Study Report, Northfield Mountain Pumped Storagc Project (No. 2485) and Tumers Falls I{ydroelectric Project (No. 1889). March 2017 . 199 pp. 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM
Robert A. Gatcs 7 December 21. 2018
cc: FERC, Secretary NMFS, Bill McDavitt (via email) NMFS, Bjorn Lake (via email) MA DFW, Caleb Slater (via email) MA DEP, Robert Kubit (via email) MA NHESP, Jesse Leddick (via email) CRC, Ken Sprankle (via email) CRWC, Andrea Donlon (via email) TU, Don Pugh (via email) Reading File ES: MGrader:12-2I-18:(603)223-2541 20181221-5238 FERC PDF (Unofficial) 12/21/2018 1:37:37 PM Document Content(s) eagle creek-2622 dla letter.PDF...... 1-7
Building areas scheduled to be abated and demolished under Building 10 - previously separate funding demolished.
11 8 5/5A 7 6/6A 4
3 Off-site treatment 2 1 plant to remain.
Off-site Building 9 (not part of project)
Lowest level Building areas scheduled to be abated only, and to remain
Note - Floor plans are for general illustration only, including the limits of individual buildings. Actual building limits may differ.
Burak, Matthew
From: Boeri, Robert (ENV)
Follow Up Flag: Follow up Flag Status: Completed
External
Good morning Mr. Burak,
My name is Bob Boeri and I am the Project Review Coordinator for the Massachusetts Office of Coastal Zone Management. You could email the package for the above-referenced hydro project directly to me at [email protected] . I should be able to respond with an determination shortly after reviewing the package. Please feel free to contact me should you have any further questions.
Regards,
Bob Boeri
Robert L. Boeri Massachusetts Office of Coastal Zone Management | Project Review Coordinator/Dredging Coordinator | 251 Causeway Street, Suite 800 | Boston, MA 02114 | 617.626.1050 | [email protected]
1 Burak, Matthew
From: Burak, Matthew Sent: Friday, January 11, 2019 10:00 AM To: '[email protected]' Cc: Michael Scarzello ([email protected]); Splenda, Jot Subject: Request for Federal Consistency Review - Turners Falls Hydroelectric Project Attachments: Turners Falls_MA CZMP Letter_Submitted.pdf
Hello Bob,
Thank you for responding to my e-mail. Attached is the consultation package. If you have any question please reach out to me directly at this e-mail or on my cell at 518-727-5453.
Thank you again,
Matthew Burak
Matthew K. Burak Senior Fisheries Biologist | Natural Resource Management mobile 518.727.5453 email [email protected] web louisberger.com
Louis Berger 9 Jarvis Avenue | Holyoke | Massachusetts | 01040 | United States
1
January 11, 2019
Mr. Robert A. Gates Vice President Turners Falls Hydro, LLC Eagle Creek Renewable Energy 116 N. State Street PO Box 167 Neshkoro, WI 54960-0167
RE: Federal Consistency Certification: Turners Falls Hydroelectric Project FERC Licensing; Turners Falls
Dear Mr. Gates:
The Massachusetts Office of Coastal Zone Management (CZM) has received your email with information relating to the proposed FERC license referenced above. Turners Falls Hydro LLC is in the process of applying for a new FERC license for its Hydroelectric Project, located on the Turners Falls Power Canal in Turners Falls MA. This canal system is fed by the Connecticut River.
The activities associated with this project fall outside the geographical boundaries of the Massachusetts Coastal Zone as described in the Massachusetts Coastal Zone Management Plan. Therefore, these activities are not subject to federal consistency review by this office.
Thank you for submitting the information to CZM. If you have any questions regarding our review process, feel free to call me at (617) 626-1050.
Sincerely,
Robert L. Boeri Project Review Coordinator
TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT F – DRAWINGS OF PROJECT WORKS AND SUPPORTING DESIGN REPORT
Turners Falls Hydroelectric Project (No. 2622) EXHIBIT F – DRAWINGS OF PROJECT WORKS
[This page is intentionally left blank]
Turners Falls Hydroelectric Project (No. 2622) EXHIBIT F – DRAWINGS OF PROJECT WORKS
As defined by 18 CFR § 388.113(c) Exhibit F – Drawings of Project Works are considered by the Federal Regulatory Commission to be Critical Energy Infrastructure Information (CEII). As such Exhibit F – Drawings of Project Works and Supporting Design Report have been omitted from the public volume (Volume 1) of the Final License Application.
TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
FINAL APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT G – PROJECT BOUNDARY Turners Falls Hydroelectric Project (FERC No. 2622) EXHIBIT G – PROJECT BOUNDARY
[This page is intentionally left blank] OWNERSHIP WITHIN PROJECT BOUNDARY EXHIBIT G R 1 SHEET 1 OF 1 IVE T R ICU ECT NN CO 2 3 LEGEND 4
4 R VE TAILRACE RI UT IC 2 CT NE ON 1 C 2
1 POWERHOUSE
2 3
L NA CA ER SURVEYORS STATEMENT W PO
INSERT A INTAKE SUBSTATION TRANSMISSION LINE
L A N A C ER W O P
VILLAGE OF TURNERS FALLS
WSP USA Inc. 9 Executive Park Dr, Suite 101 Merrimack, NH 03054 603.595.7900 TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
FINAL APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT TABLE OF CONTENTS
INTRODUCTION ...... 1 INFORMATION TO BE PROVIDED BY ALL APPLICANTS ...... 1 2.1 Efficient and Reliable Electric Service ...... 1 2.1.1 Increase Capacity or Generation Capacity ...... 1 2.1.2 Coordination With Any Upstream or Downstream Water Resource Projects...... 1 2.1.3 Coordination of Operations with Electrical Systems ...... 1 2.2 Applicants Short and Long Term Need for Electricity Generated by the Project ...... 1 2.2.1 Reasonable Costs and Availability of Alternative Sources of Power ...... 1 2.2.2 Increase in Fuel, Capital, and Other Costs to Replace the Power Generated by the Project ...... 2 2.2.3 Effects of Alternative Sources of Power ...... 2 2.3 Need and the Reasonable Cost and Availability of Alternative Sources of Power ...... 2 2.3.1 Average Annual Cost of the Power Produced by the Project ...... 2 2.3.2 Projected Resources Required to Meet Capacity and Energy Requirements ...... 3 2.3.3 Total Annual Cost and Merits of Each Alternative Source of Power ...... 3 2.4 Effect on Providers of Alternative Sources of Power ...... 3 2.5 Applicant Owned Industrial Facilities ...... 3 2.6 Need for Power If the Applicant is a Tribe ...... 3 2.7 Effect on Operations and Planning of the Applicant’s Transmission System of Receiving or not Receiving the License ...... 3 2.7.1 Effects of the Redistribution of Power Flows on Line Loading ...... 3 2.7.2 Advantages of the Applicants Transmission System ...... 4 2.7.3 Single-Line Diagram ...... 4 2.8 Modifications of Project Facilities or Operations ...... 4 2.8.1 Plan and Need for the Modifications ...... 4 2.8.2 Effects and Cost of the Modifications ...... 4 2.8.3 Conformance of the Modification with a Comprehensive Plan for the Waterway ...... 4 2.9 Financial and Personnel Resources ...... 4 2.10 Notification of the Project to Expand and Encompass Additional Lands ...... 4 2.11 Electricity Consumption Efficiency Improvement Program ...... 5 2.11.1 Customer Energy Efficiency Program ...... 5 2.11.2 Compliance of Energy Conservation Programs with Regulatory Requirements ...... 5 2.12 Names and Mailing Addresses of Affected Tribes ...... 5 INFORMATION TO BE PROVIDED BY AN APPLICANT WHO IS AN EXISTING LICENSEE ...... 5 3.1 Measures Taken or Planned to Ensure Safe Management, Operation, and Maintenance of the Project ...... 5 3.1.1 Existing and Planned Operation of the Project during Flood Conditions...... 5 3.1.2 Warning Devices for Downstream Safety ...... 5
i Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT 3.1.3 Operational Changes that Might Affect the Emergency Action Plan ...... 5 3.1.4 Existing and Planned Maintenance and Monitoring Programs and Monitoring Devices 5 3.1.5 Project Employee Safety and Public Safety Record ...... 6 3.2 Current Operation of the Project ...... 6 3.3 Project History and Upgrades to operations and Maintenance Programs ...... 6 3.4 Lost Generation Over the Previous Five Years ...... 6 3.5 Record of Compliance with the Existing License Terms and Conditions ...... 6 3.6 Licensee Actions Related to the Project that Affect the Public ...... 6 3.7 Ownership and Operating Expense Reductions if the Project License was Transferred ...... 6 3.8 Annual Fees for Use of Federal or Tribal Lands...... 6
ii Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT INTRODUCTION
18 CFR § 16.10(a) requires all applicants for a new license for a minor water power project to provide certain information that pertains to an applicant’s plans and ability to operate and maintain the project. Such information required in 18 CFR § 16.10(a) is provided in Section 2 of this Exhibit below. Furthermore, 18 CFR § 16.10(b) requires information to be provided by an applicant who is an existing licensee. The required information in 18 CFR § 16.10(b) is provided in Section 3 of this Exhibit below.
INFORMATION TO BE PROVIDED BY ALL APPLICANTS
2.1 Efficient and Reliable Electric Service
2.1.1 Increase Capacity or Generation Capacity
As discussed in Exhibit A, the Applicant has no current plans to increase capacity of the Project. The Applicant expects to maintain the high degree of process and controls to maintain the efficient use of the water supply to maximize the generation output and provide a reliable and environmentally sound source of generation. An evaluation of existing facilities shows that it is neither practical nor economical to increase capacity at this time. The Applicant periodically re-evaluates its hydroelectric generating facilities to assess life-extension and upgrade alternatives and should an economically feasible capacity expansion alternative be identified, the Applicant will pursue a license amendment to increase capacity as appropriate.
2.1.2 Coordination With Any Upstream or Downstream Water Resource Projects
The Project currently uses waters of the Turners Falls Power Canal for hydroelectric generation. The Power Canal begins at a gatehouse at the upstream end of the Power Canal adjacent to the Turners Falls Dam, owned and operated by FirstLight. Situated on the Power Canal are three hydroelectric generating stations: Turners Fall Hydro (FERC Project No. 2622), Station No. 1 (FERC Project No. 1889), and Cabot Station (FERC Project No. 1889). Station No. 1 and Cabot Station are downstream of the Project. Currently coordination with FirstLight is conducted following an off-license Water Use Agreement (WUA) between FirstLight and Turners Falls (dated January 1, 1998 as amended May 14, 2003). The WUA dictates that Turners Falls will generate only when flows within the Turners Falls Power Canal are greater than 15,000 cfs and the needs of FirstLight’s Station No. 1 and Cabot Station hydroelectric developments are met. Direct communication between FirstLight and Turners Falls operators occurs by telephone as to when Turners Fall can start and stop generation.
2.1.3 Coordination of Operations with Electrical Systems
The Applicant is an independent power producer and does not provide electric service to any customers. All Project power is sold into the power grid. The Project is interconnected with regional distribution and transmission systems.
2.2 Applicants Short and Long Term Need for Electricity Generated by the Project
2.2.1 Reasonable Costs and Availability of Alternative Sources of Power
Alternative sources of power could be obtained by purchasing power from one of the electricity markets operated in the region. Power could also be supplied through the construction of new power plants. Should a new license for the Project not be granted, the services that the Project provides to the electric grid would need to be provided by other existing projects or in some other fashion by the system operator.
1 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT The equivalent amount of power would be provided from the Wester/Central Massachusetts load zone of the New England Independent System Operators (WCMA NEISO) and the costs are based on market pricing resulting from the operation of the electric market in Massachusetts by the WCMA. Therefore, it is difficult for the Applicant to speculate the cost and availability of such alternative sources of power since the price and source can vary hourly.
2.2.2 Increase in Fuel, Capital, and Other Costs to Replace the Power Generated by the Project
Costs of replacing services that the Project provides would be passed to the consumer. This would largely relate to reduced efficiency of other projects as they would need to modify operations to meet daily demand. Resulting loss in efficiencies caused by varying thermal plant generation would increase fuel usage (in addition to increased emissions) and therefore cause additional rate increases to the customer base.
2.2.3 Effects of Alternative Sources of Power
Effects on the Applicants Customers
The primary purpose of the Project is to supply energy to the local region. As a hydropower facility, the Project provides an important source of renewable electricity. Alternative sources of power, many of which would most likely be sourced by fossil fuel generation such as coal, gas-fired and diesel generation may need to adjust their production levels, which would reduce their overall efficiency. Energy production costs, environmental costs, and construction costs would be higher than the utilization of hydropower used by the Project. None of these increased costs would be beneficial to the consumer base. Decommissioning of the Project’s generating facilities or the removal of the Project would result in increased costs as well.
Effects on Operating and Load Characteristics
The Applicant is an independent power producer and, as such, does not maintain a separate transmission system that could be affected by replacement or alternative power sources.
Effects on the Communities Served
The loss of the license for the Project through a takeover by the Federal Government or through the decommissioning of the Project would result in a loss of tax revenues. In 2018, the Project contributed approximately $48,000 in state and local taxes. The governmental entities affected by this loss in revenue would ultimately have to seek a reduction in expenses or an increase in other sources of revenue.
2.3 Need and the Reasonable Cost and Availability of Alternative Sources of Power
2.3.1 Average Annual Cost of the Power Produced by the Project
The average annual cost of the power produced by the Project includes capital costs, operating costs, and costs associated with Project relicensing, including proposed Protection Mitigation and Enhancement (PM&E) measures. As described in Exhibit A, the Applicant has performed an analysis of the costs of producing Project power (see table 2.3.1-1 below). The total levelized annual cost of power produced by the Project is approximately $214,150.
2 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT Table 2.3.1-1. Analysis of the costs of producing Project power.
Capital Cost Annual Cost Levelized Cost Descriptions ($) ($) Cost ($)
Annual operations and maintenance $0 $142,000 $142,000
Annual insurance, taxes, and administrative costs $0 $53,000 $53,000
Cost of relicensing $103,000 $0 $7,900
Trashrack Replacement Plan $75,000 $5,500 $11,250
Total $178,000 $200,500 $214,150
2.3.2 Projected Resources Required to Meet Capacity and Energy Requirements
The Project serves a role in the regional energy market by providing 937 kW of generation capacity and an average of 1,512 MWh of annual generation. The Project and other electric generating facilities owned and operated by the Applicant and affiliates are non- regulated, wholesale electric power producers. Power generated by the Project is sold in an open, competitive market to respond to consumer demands.
2.3.3 Total Annual Cost and Merits of Each Alternative Source of Power
The Applicant does not have alternative sources of power that could be provided should a license not be granted. As such, alternative sources of power to compensate for any potential losses should this Project not be licensed would need to be purchased from the open market.
2.4 Effect on Providers of Alternative Sources of Power
The Applicant does not propose to change how the Project is currently operated, which allows the flexibility to continuously operate; therefore, there is no effect on providers of alternative sources of power.
2.5 Applicant Owned Industrial Facilities
The Applicant does not directly use power generated by the Project to operate industrial facilities.
2.6 Need for Power If the Applicant is a Tribe
The Applicant is not an Indian tribe applying for a project on a tribal reservation; therefore, this section is not applicable.
2.7 Effect on Operations and Planning of the Applicant’s Transmission System of Receiving or not Receiving the License
2.7.1 Effects of the Redistribution of Power Flows on Line Loading
The Applicant is an independent power producer and, as such, does not maintain a separate transmission system that could be affected by power flow redistribution.
3 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT 2.7.2 Advantages of the Applicants Transmission System
The Applicant is an independent power producer and, as such, does not maintain a separate transmission system.
2.7.3 Single-Line Diagram
A single-line diagram for the Project is shown in Exhibit A.
2.8 Modifications of Project Facilities or Operations
2.8.1 Plan and Need for the Modifications
The Applicant currently has no plans to modify operations at the Project. If required, the Applicant will consult with the resource agencies regarding trashrack replacement.
2.8.2 Effects and Cost of the Modifications
The Applicants anticipates the cost for the proposed modification of consulting with the resource agencies and install new trashracks at the Project would be $75,000 should new trash rack designs be initiated. Effects of the proposed trashracks are discussed in Exhibit E.
2.8.3 Conformance of the Modification with a Comprehensive Plan for the Waterway
The Project will be operated under the terms and conditions of a license issued by the Commission, which will be based on the Commission’s determination of the license terms and conditions which are best suited to comprehensive development of the waterway. The environmental impacts of the Project in the context of the Turners Falls Power Canal and Connecticut River are addressed in Exhibit E, along with the Project’s conformance with comprehensive plans for the waterway. See Section 10 of Exhibit E.
2.9 Financial and Personnel Resources
The Power Canal is owned and operated by FirstLight Hydro Generating Company (FirstLight) as a part of their Turners Falls Hydroelectric Project (Federal Energy Regulatory Commission [FERC] Project No. 1889). Eagle Creek Renewable Energy, the Applicant’s parent company, is a leading owner and operator of renewable energy plants in North America. Eagle Creek owns and operates over 63 hydroelectric plants with an installed capacity of approximately 216 MW. The Applicant has the financial resources to maintain and operate the Project. Capital financing required for implementation of the proposed environmental enhancements would come from a combination of sources, depending on the amount of financing, other company financing needs, and total company revenues and expenses. The Project has a full complement of operations personnel who perform all necessary day-to-day functions related to Project operations and maintenance. On-site staff is fully qualified to handle all aspects of the operation and maintenance of the Project. The Project is fully equipped to allow staff to perform virtually all routine maintenance functions. All personnel receive training commensurate with their responsibilities in an ongoing effort to improve their ability to operate the Project in the safest and most efficient manner possible.
2.10 Notification of the Project to Expand and Encompass Additional Lands
The Applicant currently has no plans to expand the project to encompass additional lands; therefore any notification is not applicable.
4 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT 2.11 Electricity Consumption Efficiency Improvement Program
2.11.1 Customer Energy Efficiency Program
The Applicant is an independent power producer and all power generated at the Project is sold on the open market. The Applicant strives routinely to minimize station electrical usage to improve plant performance. The Applicant does not transmit power or sell electricity to retail customers, and the Project does not have other venues for energy conservation programs to assist customers with power conservation.
2.11.2 Compliance of Energy Conservation Programs with Regulatory Requirements
Not applicable. The Applicant is an independent power producer, does not have other venues for energy conservation programs to assist customers with power conservation.
2.12 Names and Mailing Addresses of Affected Tribes
There are no Indian Tribes with land that will be affected by the Project. Please see Section 2(v) of the Initial Statement for a list Tribes potentially affected by the Project.
INFORMATION TO BE PROVIDED BY AN APPLICANT WHO IS AN EXISTING LICENSEE
3.1 Measures Taken or Planned to Ensure Safe Management, Operation, and Maintenance of the Project
3.1.1 Existing and Planned Operation of the Project during Flood Conditions
The Project is situated on the Turners Falls Power Canal. The Power Canal is owned and operated by FirstLight Hydro Generating Company (FirstLight) as a part of their Turners Falls Hydroelectric Project (FERC Project No. 1889). FirstLight regulates flow into the Power Canal therefore is not subject to flooding.
3.1.2 Warning Devices for Downstream Safety
The Project is example from Emergency Action Plan requirements; therefore, there is no warning devices for downstream safety at the Project.
3.1.3 Operational Changes that Might Affect the Emergency Action Plan
The Project is not proposing any significant changes to the Project facilities and no changes to project operations as currently licensed, which allows the flexibility to continuously operate. The Project is also example from Emergency Action Plan requirements. Therefore, there are no operation changes that might affect emergency action plans requirements.
3.1.4 Existing and Planned Maintenance and Monitoring Programs and Monitoring Devices
Monitoring equipment at the Project consists of a call-out device that alerts the operator if there is a problem at the Project. The operator also maintains a station log book, which includes information and conditions that affect operations.
5 Turners Falls Hydroelectric Project (No. 2622) EXHIBIT H – PLANS AND ABILITY TO OPERATE THE PROJECT 3.1.5 Project Employee Safety and Public Safety Record
The Applicant manages the Project consistent with their long-standing commitment to employee safety. This commitment begins with compliance with applicable local, state, and federal regulations regarding the safe operation of industrial and electrical facilities. As the Applicant operates the Project’s generation facilities, this commitment is implemented primarily through a rigorous safety program. Detailed inspection and maintenance programs ensure employee and contractor safety relative to operating equipment and facilities. The safety program involves employee and contractor training sessions, as well as making safety information available to employees. The Applicant places a high priority on public safety at the Projected. In accordance with 18 CFR 12.10, the Applicant files public safety incident reports with the Commission when such an incident occurs. No public safety incident have occurred at the Project.
3.2 Current Operation of the Project
Operation of the Project is described in Exhibit A.
3.3 Project History and Upgrades to operations and Maintenance Programs
Operation of the Project is described in Exhibit A.
3.4 Lost Generation Over the Previous Five Years
The Project operates under an off-license Water Use Agreement with FirstLight. The Applicant acquired the Project in 2016, and does not have outage records prior to the acquisition. Aside from periods of not generating under the off-license Water Use Agreement, the Applicant experienced 39 unexpected outages during since acquiring the Project. Staff worked quickly and efficiently to return the Project to working order as quickly as possible.
3.5 Record of Compliance with the Existing License Terms and Conditions
The Project has been, and continues to be, in compliance with the terms and conditions of the current license. Over the term of the current license, the Project has been subject to FERC's standard operational and environmental inspections. Any compliance-related issues noted during the inspections have been promptly addressed by the Applicant.
3.6 Licensee Actions Related to the Project that Affect the Public
The Project provides electricity that contributes to the stability of the regional power system. This alone significantly affects the general public by providing a low-cost and renewable-energy source to the Applicant’s customers and contributing to the balance of regional power supply and demand.
3.7 Ownership and Operating Expense Reductions if the Project License was Transferred
If the Project license were transferred to another entity, the Applicant’s cost of operating and maintaining the Project (see Exhibit A) would be eliminated.
3.8 Annual Fees for Use of Federal or Tribal Lands
The Applicant does not pay annual charges for Federal or Indian tribal reservation lands because the Project does not occupy any such lands.
6 TURNERS FALLS HYDROELECTRIC PROJECT FERC PROJECT NUMBER 2622
FINAL APPLICATION FOR SUBSEQUENT LICENSE FOR A MINOR WATER POWER PROJECT 5 MEGAWATTS OR LESS
ATTACHMENT 1
DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
[This page is intentionally left blank] Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
1 RESPONSIVENESS SUMMARY
The Turners Falls Draft License Application was provided to resource agencies, tribes and other stakeholders on September 27, 2018 for review and comment. Comments on the Draft License Application were requested to be provide to Turners Falls no later than December 27, 2018, 90 days after the Draft License Application distribution. The following comment letters were received: • NOAA Fisheries, DLA Comment Letter dated December 17, 2018 • Town of Montague, DLA Comment Letter dated December 17, 2018 • U.S. Fish and Wildlife Service, DLA Comment Letter dated December 21, 2018 Table 1 provides the responses to comments received on the Draft License Application within the above letters. Copies of the comment letters are provided in Exhibit E – Appendix A, Consultation Summary. Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
[This page is intentionally left blank] Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
Table 1. Turners Falls Hydroelectric Project Draft License Application Comment Responsiveness Summary.
Comment Commenter Date of Comment Letter Comment Comment Response Number
1 NOAA Fisheries December 17, 2018 Page 1 - As stated in the DLA, you propose, “to develop in consultation with the Although we agree that developing a trashrack replacement plan would mitigate resource agencies a Trashrack Replacement Plan to replace the existing trashrack with a entrainment, impingement, and turbine mortality of migratory species at the Project, we trashrack with 3/4 –inch clear spacing to mitigate entrainment, impingement, and turbine would like to clarify our proposal. In section 3.6 of Exhibit E we describe the proposed mortality of migratory species at the Project.” Your proposal to mitigate the entrainment measures to enhance, protect, or mitigate effects on aquatic and fisheries resources. In of migratory fish directly addresses our principle concern. Therefore, a study would not that section we propose to develop a Trashrack Replacement Plan in consultation with be necessary at this time. We reserve the right to seek studies such as those the agencies whereby a trashrack with ¾-inch clear spacing would be installed. recommended in our earlier comments if your plans for mitigation change. However, as stated in section 3.6 of Exhibit E, the consultation regarding the Trashrack Replacement Plan is contingent upon whether FirstLight will install a fish screen at the Power Canal gatehouse entrance.
2 Town of December 17, 2018 The THP is located within a collapsing building, and is dependent on the continued Commission regulations do not specifically require an analysis and discussion of the Montague structural viability of buildings on the Town Property which have deteriorated to the structural integrity of the Project powerhouse in a DLA, as such, no analysis or point where reconstruction/rehabilitation is deemed to be impracticable, if not discussion of the structural viability of the Project was provided in the DLA. We note impossible. The Town is of the opinion that the DLA does not accurately portray these that the Exhibit F, Supporting Design Report of the FLA contains a stability and stress circumstances, and that, as a result, the submission is incomplete and deficient. analyses for all major structures and critical abutment slopes under all probable loading conditions, including seismic and hydrostatic forces induced by water loads up to the Probable Maximum Flood, as appropriate. Exhibit F is considered by the Commission to be Critical Energy Infrastructure Information (CEII). As such, Exhibit F would need to be requested directly from Commission Staff.
3 Town of December 17, 2018 The DLA states that the buildings are generally in "good" condition. It relies on We have updated Exhibit E in the FLA to reflect the existing condition of the Strathmore Montague marketing materials from 2011, which refer to a 2007 architectural assessment of the Mill Complex. Strathmore Mill complex. The buildings, however, have deteriorated dramatically since 2007. Portions of the complex that were in "good" condition eleven years ago, would now be characterized as "poor" and "failing" under the same criteria. In 2017, the complex was ordered to be boarded and marked as abandoned by the State Fire Marshal. Moreover, the DLA does not mention that the Strathmore Mill has been vacant for over a decade. In 2009, the Mill was designated by Preservation Massachusetts as one of the most endangered historic resources in the state.
4 Town of December 17, 2018 The Town Property has deteriorated to the point where the Town has determined that As mentioned above Exhibit F of the FLA contains a stability and stress analyses for all Montague demolition of the improvements on the site is warranted. The Town does not have the major structures and critical abutment slopes under all probable loading conditions. In resources to do otherwise. As noted, the hydroelectric plant shares walls with the Town addition, the FLA contains a single line electrical diagram which details electrical building, and uses the Town Property for access and the running of utilities. The DLA connections. These documents are considered by the Commission to be Critical Energy does not acknowledge that the structural integrity and other essential components of the Infrastructure Information (CEII). As such, they would need to be requested directly hydroelectric plant are dependent upon a building that has failed to such a degree that from Commission Staff. Until there is a formal plan in place that would involve the Town sees no alternative but to demolish it. demolition of the buildings, Turners Falls is continuing to pursue a new FERC license to operate the project.
5 Town of December 17, 2018 Section 9 of the Environmental Report, which addresses Land Use and Aesthetic Exhibit E, section 9.1, Land Use (in the DLA and FLA) indicates that land uses adjacent Montague Resources, should note that current use of the Strathmore Mill complex is vacant to the Project are industrial and water. Whether the parcels are occupied or not is industrial. irrelevant to an analysis of potential Project effects on land use.
6 Town of December 17, 2018 the Town has explored demolition of the building on the Town Property, and It is Turners Falls understanding that the town is continuing to explore potential Montague conversion of the parcel to public park land and developable open space. At this redevelopment options for their property near the Project. Until there is a formal plan in juncture, unless the Town and the Applicant can come to some mutually acceptable
1 Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
Comment Commenter Date of Comment Letter Comment Comment Response Number arrangement regarding reinforcement and/or reconstruction of the walls surrounding the place that would involve demolition of the buildings, Turners Falls is continuing to hydroelectric plant, this plan is, in all likelihood, unfeasible due to the expense of pursue a new FERC license to operate the project. reinforcing the powerhouse walls. This means that the building on the Town Property - upon which the powerhouse relies for its structural integrity, access and utilities, will continue to deteriorate.
7 U.S. Fish and December 21, 2018 Page 2 - While the DLA provides the trashrack dimensions, TFH should state whether Under normal operating conditions the trashracks are fully wetted, that is, submerged. Wildlife Service the racks are fully wetted under normal canal levels. If not, the wetted rack dimensions We clarified this Exhibit A in the FLA. should be provided.
8 U.S. Fish and December 21, 2018 Page - The DLA only provides the maximum hydraulic capacity of the Francis turbine. The Project turbine has the capability to operate from approximately 60 cfs to the Wildlife Service TFH should state whether the unit has an operating range or if it only operates at 289 maximum hydraulic capacity of 289 cfs. Flow through the turbine is regulated by cfs- wicket gates to optimize electrical generation. The head gates are either fully open during operation or closed for unit outage and/or repair. We clarified this in Exhibit A of the FLA.
9 U.S. Fish and December 21, 2018 Page 2 - Some turbine specifications (i.e., runner speed, horsepower, head) are provided The Project turbine has runner diameter of 38.5 inches. We included this in the Exhibit Wildlife Service in the DLA but others are not. TFII should provide all unit specifications relevant to A in FLA. Turners Falls is unable to locate documentation that provides the number of potential entrainment injury/mortality (e.g., number of buckets, runner diameter). buckets the turbine has.
10 U.S. Fish and December 21, 2018 Page 2 - Beyond stating that the station is manually operated, TFH provides no details Exhibit A section 1.3 describes how the project is operated pursuant to an off-License Wildlife Service on operational protocols, monitoring and/or recording equipment, etc. This information Water Use Agreement between Turners Falls and FirstLight Hydro Generating should be provided in the final license application. Company. The Water Use Agreement stipulates that the Project can generate when indicated by FirstLight. FirstLight indicates Turners Fall may start and stop generation by telephoning the operator, who manually turns on and off the Project. Monitoring equipment at the Project consists of a call-out device that alerts the operator if there is a problem at the Project. The operator also maintains a station log book, which includes information and conditions that affect operations. We added this in Exhibit A in the FLA.
11 U.S. Fish and December 21, 2018 Page 2 - TFH states that the Tuners Falls Power Canal is 120 feet wide at the upstream We made the appropriate correction in Exhibit E of the FLA. Wildlife Service end and 920 feet wide at the downstream end. Actually, the upper end of the canal is about 30 feet wide and at the downstream end it is approximately 300 feet wide
12 U.S. Fish and December 21, 2018 Page 2 - In Section 3.2.2, TFH states that the Connecticut River supports both We made the appropriate correction in Exhibit E of the FLA. Wildlife Service anadromous and diadromous species. We believe "diadromous" should be "catadromous."
13 U.S. Fish and December 21, 2018 Page 3 - TFH provides no discussion of adult shad downstream migration through the In Exhibit E, section 3.2.2 Migratory Species, American Shad we discuss FirstLight’s Wildlife Service canal. It is downstream passage of migratory fishes through the canal that is a concern downstream passage analysis for adult shad relative to the Project. We state, “In relative to operation of TFH's project. Therefore, the final license application should addition, FirstLight estimated that 100% of adult American shad that emigrate through summarize the results of the FL's downstream passage analysis for adult shad. the Power Canal also successfully passed by the Project (FirstLight, 2017a).” FirstLight, 2017a being “Relicensing Study 3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad Addendum 1, Northfield Mountain Pumped Storage Project (No. 2485) and Turners Falls Hydroelectric Project (No. 1889). May 2017. 665 pp.”
2 Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
Comment Commenter Date of Comment Letter Comment Comment Response Number
14 U.S. Fish and December 21, 2018 Page 3 - Because all radio tagged eels detected in the power canal escaped the project As noted, the radio telemetry data indicate all tagged American eels that entered the Wildlife Service (i.e., were detected either at a passage route or downstream of the Project), TFH states power canal were detected downstream of the project. Therefore, regardless of the they successfully bypassed the Project. However, it is possible some of those eels vitality of the tagged eels, all tagged eels bypassed the Project. By extension, it is incurred injuries or even died as a result of passing out of the canal; therefore, we do not reasonable to infer that, based on these data, the Project does not have a significant believe the term "successfully bypassed" is an appropriate characterization. effect on American eel downstream movement in the power canal in the vicinity of the Project.
15 U.S. Fish and December 21, 2018 Page 3 - TFH states there are no fish passage facilities at the Project. While there are no We describe current license articles relative to fish passage in Exhibit E section 3.2.3 Wildlife Service structures to pass fish, there is a license requirement to protect fish from entrainment Fish Passage of the FLA. into the turbine. The final license application should include a discussion of existing fish protection requirements.
16 U.S. Fish and December 21, 2018 Page 3 to 4 - As noted in our April 13, 2017 letter, the existing project license contains We agree, that just because a fish’s swimming ability can exceed a trashrack intake Wildlife Service Article 401, which requires the licensee to install, operate, and maintain a trashrack as velocity it doesn’t necessarily fully guarantee against entrainment because many other proposed in TFH's May 3, 1990 filing with FERC, including bar spacing not to exceed 1 factors affect a fishes susceptibility to entrainment at a project. However, it does inch and intake velocities not to exceed an average of 0.68 fps. During the Joint Agency mitigate entrainment susceptibility in this specific case for American shad and American Meeting held on February 7, 2017 stakeholders were informed that, while trashracks eel. Another important factor that mitigates entrainment at the Project is its meeting those specifications had been in place for a number of years, in 2007 they were configuration. The Project essentially has two downstream passage routes: through the replaced with racks having a clear spacing of 1.25 inches. While the calculated intake turbine and the power canal. In fish passage parlance, the power canal can be velocity of the existing trashrack does not exceed our design criteria for American shad considered a fish bypass. The canal entrance to the turbine is parallel to canal flow, and or American eel, the rack spacing presents a risk of entrainment and subsequent turbine the entrance area is substantially smaller relative to the cross-sectional area of the power injury or mortality to both juvenile shad and adult eels. TFH states that the intake canal in front of the entrance. Furthermore, water velocities in front of the Projects velocity of the existing rack is lower than the swim speed range of juvenile shad and canal entrance and across the canal are typically higher than the Projects existing adult eel documented by Bell (1990). However, results of an empirical study undertaken calculated intake velocity. Therefore, any fish that approaches the Project from by FL showed substantial entrainment of adult eels occurring at the Cabot trashrack upstream likely will bypass the project due to the high velocities and large cross-section (FirstLight 2017) which also has a calculated intake velocity below that species’ area of the canal (fish bypass) relative to the Projects canal entrance. This hypothesis is identified swim speed;1 clearly just because a fish can avoid entrainment is no guarantee supported by FirstLight’s radio telemetry studies of American shad and American eel, that it will, absent physical exclusion. which indicate that of all the tagged emigrating adult and juvenile American shad and all tagged emigrating adult American eel that were detected in the Power Canal upstream of the Project, 100 percent were detected downstream of the Project. Thus, entrainment at the Project is likely not a significant issue. The results of these studies are summarized in Exhibit E of the FLA.
17 U.S. Fish and December 21, 2018 Page 4 - TFH's estimated intake velocity with ¾-inch racks, while higher than the Please see our response to the NOAA Fisheries comment from comment letter dated Wildlife Service current intake velocity, would remain below our design criterion; therefore, we support, December 17, 2018 above (Comment Number 1). and will be requiring, TFH to install and maintain ¾-inch racks to design specifications.
18 U.S. Fish and December 21, 2018 Page 4 - Another identified potential impact is false attraction to the tailrace discharge. Under existing conditions, FirstLight’s upstream adult American shad passage data Wildlife Service The Project operates, on average, from 36-77 percent of the time during the anadromous indicate that the median travel time past the Project in the Power Canal and bypassed upstream migration season. Currently mandated flows from the FI--TF dam vary reach are similar, and that night time surveys performed by FirstLight near the Project seasonally: beginning May 1, FL maintains a continuous flow of 200 cfs at the dam. tailrace indicate that juvenile American eel do not attempt to ascend at or become which increases to 400 cfs once the fish passage season begins. This flow is maintained delayed at the Project. These studies are summarized in Exhibit E of the FLA. until July 15 or the end of the fish passage season, whichever occurs first. Once the Collectively, these data indicate false attraction that results in migratory delay is not a fishways are closed, FL provides 120 cfs to the bypass reach until river temperature significant issue at the Project. Furthermore, by letter dated April 13, 2017 from the drops below 7'C. Thomas Chapman (U.S. Fish and Wildlife Service) to Robert Gates (Eagle Creek Renewable Energy), the U.S. Fish and Wildlife Service states, “It is likely that FL will Given that the Project's flow (298 cfs) represents nearly 43 percent of the total (required) be required to release more flow to the bypass reach which may alter the effects of the flow in the upper bypass reach during the fish passage season, it represents a potential
3 Turners Falls Hydroelectric Project (FERC No. 2622) DRAFT LICENSE APPLICATION COMMENT RESPONSE SUMMARY
Comment Commenter Date of Comment Letter Comment Comment Response Number source of false attraction for upstream migrants, particularly when those are the only TFH Project.” Because more flow in the bypassed reach is likely, false attraction in the flows present in the upper bypass reach (i.e., when Tuners Falls Dam is not spilling). Project tailrace would be further mitigated. Further, while under the present WEA between TFH and FL, the Project only operates when canal flows exceed 15,000 cfs, there is no guarantee this WEA will remain in place for the duration of any new license issued for the Project. If the Project were to start operating under lower canal flows, it would increase the risk of potential false attraction, relative to other discharge locations.
19 U.S. Fish and December 21, 2018 Page 4 - The FL-TF is still undergoing relicensing. Because it is unknown how that Comment noted. Wildlife Service Project will operate under a new FERC license, it is difficult to assess the potential for false attraction to the Project's tailrace discharge. Therefore, we will be recommending that FERC include a license article similar to Article 402 of the current license (i.e., requiring the licensee to file a plan to implement measures needed to minimize delays to upstream migrating anadromous fish at the Project when such delays are identified by the resource agencies).
20 U.S. Fish and December 21, 2018 Page 4 to 5 - In the DLA, TFH suggests FL is considering installing screens at the The Service is correct that FL has not formerly proposed a screen to prevent juvenile Wildlife Service gatehouse to prevent juvenile shad from the power canal. If this were to occur, it likely shad from moving downstream of the power canal. However, by letter dated April 6, would obviate the need for TFH to install trashracks with ¾-inch clear spacing. As 2018 regarding FirstLight Hydro Generating Company, Turners Falls Hydroelectric noted above, the FL-TF has not completed the relicensing process. To our knowledge, Project (FERC No. 1889) and Northfield Mountain Pumped Storage Project (FERC No. FL has not proposed a gatehouse screen to prevent migrants from entering the canal. 2485). Response to FERC’s March 13, 2018 letter regarding Downstream Juvenile Shad TFH states that, should FL not be required to install a screen at the canal gatehouse, it Study (Accession No. 20180406-5061) FL states, “FirstLight is considering various will develop (in consultation with the resource agencies) a plan to replace the existing options to protect juvenile shad at the Turners Falls Project including a) a potential trashrack with 3/4-inch clear racks to protect downstream migrants from entrainment. plunge pool below one of the bascule gates, and b) measures to screen juvenile shad moving downstream in the power canal.” We interpreted this statement as screening juvenile shad from moving downstream in the power canal. With regard to our proposed consultation concerning ¾ inch trashracks at the Project please see our response to the NOAA Fisheries comment from comment letter dated December 17, 2018 above (Comment Number 1).
21 U.S. Fish and December 21, 2018 Page 5 - In our April 13.2017 letter, we requested the Applicant provide project Project plan, section, and elevation drawings are within Exhibit F of the FLA. Wildlife Service drawings in plan, section and elevation views. The DLA is lacking Exhibit F. We again According to Commission regulations Exhibit F drawings are considered Critical Energy request project drawings be provided. Infrastructure Information (CEII). As such, we recommend FWS staff pursue CEII information through formal request to Commission Staff.
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