The owner/operator of all the hydro facilities we are watching. Despite the impression one could receive from their website, their parent company is Canadian. (Video describing the intricate family tree here.) These facilities are estimated to bring in revenue of up to $140 million/year as recently as 2019. They have applied to the FERC for a federal power license to continue operations of existing facilities.
At the federal level, the Federal Energy Regulatory Commission (FERC*) is where most efforts have focused to date. Karl Meyer’s blog and his letters in the Greenfield Recorder have explained how to look up information about their records on this project, and how to add your own comments to the public record. We have gathered this information about how to contact FERC here.
Greening Greenfield
OK, we’re not exactly a key player, but on January 24, 2022, Greening Greenfield held a web event entitled Save the Connecticut River: New Opportunity to Speak Up on Relicensing. Watching this will give you some background.
At the state level, the Executive Office of Energy and Environmental Affairs, EEA, houses a number of state agencies, including the Department of Environmental Protection. Under Section 401 of the federal Clean Water Act “a federal agency may not issue a permit or license to conduct any activity that may result in any discharge into waters of the United States unless a Section 401 water quality certification (WQC) is issued, or certification is waived. States and authorized tribes where the discharge would originate are generally responsible for issuing water quality certification.” 
In Massachusetts, the DEP is the entity that will issue the WQC. We know this is confusing. An analogy for how to think about this relationship is in this MyTurn.
Massachusetts Legislative Delegation for CT River communities
Our State Senators and Representatives are currently meeting regularly with EEA to track progress and pass on our comments and concerns. Thank them for their hard work! They have shared with us: their August 2020 joint delegation letter to EEA/DEP & the Governor, about the re-licensing; and their June 2022 notes of progress and commitments.
There is a potential parallel state track under which the projects might be reviewed, which is the Massachusetts Environmental Policy Act, or MEPA. The MEPA Office like the MassDEP, is under the Energy & Environmental Affairs (EEA) umbrella. Its purpose includes requiring state agencies, such as the MassDEP, to study the environmental consequences of their actions. See MEPA purpose & intent.
On July 6, 2012, FirstLight applied to the MEPA Office for an “Advisory Opinion” about whether “the upcoming licensing of the Northfield Mountain and Turners Falls Projects by the Federal Energy Regulatory Commission (FERC) subjects either project to” MEPA jurisdiction. That document, though old, is very helpful in understanding the exact language of the pieces of the projects, and the originally projected timeline. In it, FirstLight essentially argues that they will not be making enough changes to their existing practices allowed under the then-current license to make them subject to MEPA review. Or if they do make changes that major, it will only be because the FERC makes them, so MEPA shouldn’t get involved until after FERC checks in. A week later, the MEPA Office agreed, granting them the Advisory Opinion that MEPA review was not necessary.
However, that decision was supposed to be under review and could be revised by the current MEPA Director, who has not stated definitively yet whether or not they agree with this prior opinion, as of June, 2022, nor apparently by February 2023, nor as far as we know by February 2024.
Some of us feel that letters to the MEPA Office, encouraging their immediate involvement could be helpful. MEPA has a strong interest in having parties explore alternatives, and with the climate crisis and the potential 40-50-year license, we think some things will change during that time frame.