List of FERC Documents
1/11/24
Fish counts through 3 ladders, 2023
Descriptor: If really want to know how many shad or lamprey made it past
through the fish ladders, this is for you.
The dirty truth of Northfield Mountain’s ‘clean’ energy, Karl Meyer
Commonwealth Beacon, Spring 2022
Neonics – Ask before you buy
“Did you know that many flowering plants sold at local stores can harm our pollinators instead of nurturing them?”
Who are our local pollinators & why do we need them?
Bees, butterflies, birds, bats and insects are pollinators. They transfer pollen from plant to plant or move pollen within flowers. This pollen then fertilizes the plant. Only fertilized plants can make fruit and/or seeds, and without them, plants cannot reproduce. Without plants, our food supply is severely compromised.
What are neonics and what’s the problem?
- Neonicotinoid insecticides (Neonics for short) are used to reduce insect damage to plants by American farmers and plant nurseries.
- Neonics are absorbed by plants and can be present in pollen and nectar, making them toxic to pollinators by affecting the central nervous system of not only insects, but also fish, birds and mammals, causing paralysis and death.
- They have a half-life of 1000 days. That means it takes 1,000 days for the concentration of neonic to reduce by half in the environment, so if you plant a contaminated flower, it could be toxic to pollinators for years to come.
Why native plants are best
Our pollinators have evolved with our native plants for millions of years. Some of our plants and pollinators cannot survive without each other! One example is the monarch butterfly. It relies on milkweed to feed its babies which are caterpillars that survive by eating the leaves.
Buy pesticide free and pollinator friendly.
Learn more about efforts to ban neonicotinoids
- 2019 Neonicotinoid Legislation
- Washington Post, “EPA blocks a dozen products containing pesticides thought harmless to bees,”
Pollinators: Our Favorite Books and Articles
Why Pollinators:
- Bringing Nature Home, How You Can Sustain Wildlife with Native Plants, by Doug Tallamy
- Nature’s Best Hope, A New Approach to Conservation That Starts in Your Yard, by Doug Tallamy
- The Pollinator Victory Garden, Win the War on Pollinator Decline with Ecological Gardening, by Kim Eierman
What to Plant and How:
- Native Plants for New England Gardens, by Mark Richardson and Dan Jaffee
- 100 Easy-to-Grow Native Plants, by Lorraine Johnson
- Pollinators of Native Plants, Attract, Observe and Identify Pollinators and Beneficial Insects with Native Plants, by Heather Holm
- Native Ferns, Moss & Grasses, by William Cullina
- Native Trees, Shrubs, and Vines: A Guide to Using, Growing, and Propagating North American Woody Plants, by William Cullina
- The New England Wild Flower Society Guide to Growing and Propagating
- Wildflowers of the United States and Canada, by William Cullina
- Understanding Perennials: A New Look at an Old Favorite, by William Cullina
- Native Plant Landscaping:
- Garden Revolution, How our Landscapes can be a Source of Environmental Change, by Larry Weaner and Thomas Christopher
- The Living Landscape, Designing for Beauty and Biodiversity in the Home Garden, by Rick Darke & Doug Tallamy
- Planting in a Post-Wild World, Designing plant communities for resilient landscapes, by Thomas Rainer and Claudia West
Periodicals:
- Wild Seed, Returning Native Plants to the Landscape, a periodical published by the Wild Seed Project, Portland, ME
Important Articles:
PROBLEMS
- Birds Are Vanishing From North America by Carl Zimmer, 2019
The number of birds in the United States and Canada has declined by 3 billion, or 29 percent, over the past half-century, scientists find. - UN Report: Nature’s Dangerous Decline ‘Unprecedented’; Species Extinction Rates ‘Accelerating’
- Can Reducing Light Pollution Help Pollinators?
- How Non-Native Plants Are Contributing to a Global Insect Decline
SOLUTIONS
Key Players
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.
The MEPA Office is under the Energy & Environmental Affairs (EEA) umbrella.
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 is currently 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.
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.
Bag-Making Equipment
Funded in part by a MassDEP 2020 Reduce, Reuse Repair Micro-Grant, Friends of Reusable Bags now owns a fleet of equipment that may be borrowed to make bags, or to do other projects, such as adding grommets to banners. Be creative! (Sign-out sheet coming soon.) We currently own:
3 Hiker brand standard grommet machines. These are used, generally with feed or malt bags, in the structural applications of forming the bottom of the bag and attaching handles to the bag. Modified from how they come from the factory, these machines have had the metal of the front end narrowed to allow them to fit in tighter spaces (compare to how a sleeve board works instead of a full sized ironing board), they are adjustable to match the thickness of material, and they are mounted on a wooden base that gets secured to a work table.
1 Giraffe grommet machine. As the name implies, this machine has a very long “neck”, which allows the user to get a grommet into the center of the bottom of a bag without bunching up the bag more than is possible with a standard unit. One of only 5 in existence, this endangered giraffe was constructed by The BagShare Project. Currently yellow, we dream of painting it with proper brown splotches.
2 Bates brand eyelet machines. Eyelets are like tiny grommets. They are used for non-structural applications, especially holding the folded rim of a bag together. They free up the other equipment and allow more people to make bags without waiting in line.
4 Wooden forms. We currently have 2 “tombstones” and 2 “pushers” made in house. (Thank you Bob!!) The tall tombstones are used to help turn the stiff bags inside out, though one can use the back of a chair if it is the right shape. The pushers look like a little rectangular-top stool, and serve a couple purposes, including making a shape against which to fold the bottom of the bags like one would wrap a present (short ends in first, farther than you’d think, then long sides, clip, then grommet.) We hope to add more and smaller sizes of forms for some of the narrower feed bags.
No-sew T-shirt bag, with and without fringe
This is the same bag! There are instructions you can find on the internet, but this is one of our favorites: Click here for Mommypotamus instructions.
Decide before you start whether you want the fringe to show and which side of the t-shirt you want to see (inside out for plain). You can then use the same instructions.
Grommeted Feed and Malt/Grain Bags
To make bags fastened with grommets, rather than sewn together, one needs a grommet machine, We have some! BagShare has some. They can be borrowed with everything you need to run your own bag-making workshop. Friends of Reusable Bags can help. After a bit of practice, a bag can be made in about 10 minutes. We will post step-by-step instructions here in the future, too.
Malt bags are large, sturdy, usually double thickness, waterproof, and have a carrying capacity of about 50 pounds.
Greenwashing 1
February, 2020.
I picked up a single-use plastic bag today to wrap around a food package that was leaking. That I’d asked for a produce bag and this one still had handles, in violation of Greenfield’s recent ban, is a different story. The bag was bragging about itself, and I find myself compelled to dissect these claims one at a time.
Firstly, know that the bag is #4 LDPE. That’s the plastic resin code intended to assist recyclers in knowing what plastic is used in the item, namely low density polyethylene. The bag is mostly clear, but has the slightly green tint often used to identify either a so-called “biodegradable” bag, or one that might hold organic produce. Neither was the case here. It also already had a 2.5 inch rip along one seam. It is very flimsy.
The bag states in a folksy first person narrative:
1) Thank You
For using the bag? Or shopping at the store? Whichever. Not going to pick that apart.
2) I am made from recycled materials. I am made from at least 30% post-industrial waste.
Translation: it is made from 70% virgin material plus 30% material that has never been used before, but that went in one end of the manufacturer’s factory and then back in the front side to try again, probably after scraps were cut off of other finished products. Better than throwing those scraps away, but I am unimpressed. Paper grocery bags in Greenfield are now required to be made out of at least 40% Post-Consumer material, and to say so.
3) I reduce road traffic. One truck can carry 2 million bags like me. Seven trucks are needed to carry 1 million paper sacks.
True as far as it goes. Also, it’s not just the traffic, but the fossil fuel use and pollution from those trucks. And this is part of why we’re NOT advocating for people to switch from single-use plastic bags to single-use paper bags. We are advocating eliminating single-use items in favor of reusable items of many sorts, including bags. Though also keep in mind grocery stores average just THREE (3) items placed in each plastic bag [circa 1980’s data, even before plastic bags were as thin as now]. Paper bags hold more, so it’s not a one-to-one comparison, or probably even one-to-two, as suggested here.
4) I’m cleaner. Producing me generates fewer pollutants than producing paper bags: 70% less air pollutants and only 2% of the water pollutants.
Probably true on a one-to-one comparison with paper bags. Again, we’re not advocating a switch to paper bags.
5) I use less energy. Making me involves a quarter of the energy used for a paper bag.
See #4 above.
6) I help save trees. My material is created from plentiful natural gas rather than ever more valuable trees or oil.
Oh, where to start? First of all, I love trees. Doesn’t saving trees make you feel all warm and fuzzy? Arguments that you suspect are trying to make you feel warm and fuzzy should be giant red flags that someone is trying to manipulate your emotions more than present you with facts. Yes, paper bags are made from trees and plastic bags are not. That could save trees. It’s good to save trees. Trees are a renewable resource, though the carbon uptake of a replacement seedling or sapling does not match that of the harvested adult tree.
Natural gas, to the extent that it is a byproduct of oil extraction, has sometimes been considered plentiful. But oil and natural gas are both fossil fuels, made, in my simplistic world view, from dinosaurs. They (oil, natural gas, and dinosaurs) are all non-renewable resources. This is one of those arguments about making sure the resource is still there for the seventh generation. It’s not just our own that counts. Unless we can start to agree that the world is not all about just humans, and certainly not just the currently present humans, we’re all in a lot of trouble.
7) I help in landfills. I’m light and take much less space than a paper bag.
Sigh. We’re not advocating using paper bags instead of plastic. (Have I said this already?) “Light” is a fascinating argument to make about filling landfills. Weight bears no relevance to the carrying capacity of the land. If each plastic bag was the same size and somehow weighed 3000 pounds, the earth in the landfill would probably not sink appreciably because of it. “Take much less space” in a landfill is true, but irrelevant if one, instead, were to compost or to recycle the paper bag, as one ought. And even taking less space doesn’t “help” in a landfill; it just doesn’t hurt as much – nothing about putting plastic in a landfill is beneficial to the landfill, the bag, or the earth.
Edited 2024
And finally, this is an argument that made no difference to Greenfield in 2020 when the bag was found, (nor to most of Massachusetts, and nearly all of Connecticut). Our municipal solid waste did not go to any landfill. It went to a waste-to-energy facility in the Springfield, MA area where trash was burned to make electricity. There are good and bad things about that, but that, too, is an argument for another day. Since that waste-to-energy facility closed abruptly, Greenfield’s trash now goes to a hauler, who, as far as we know, is taking it to a landfill in South Carolina. This only emphasizes the fact that we have to be paying the most attention to waste reduction of all kinds, including replacing single-use items with more durable ones, or skipping them altogether.
There ends the bag’s remarks with no discussion of land or marine litter, climate change, wasteful habits, or better alternatives. Friends of Reusable Bags, however, has come to the conclusion that the best material to make bags out of is any material that already exists. Please join us.
Peg Hall
Friends of Reusable Bags
Greening Greenfield
Solid Waste Consultant, Retired
Member, Product Stewardship Institute
Solid Waste Manager, Branford, CT, retired
All opinions expressed here are my own and do not necessarily reflect those of every group with which I am affiliated.
Acronyms
Acronyms (some used by GG; many more in formal documents)
AIP – Agreement in Principle
AFLA – Amended Final License Application
AMC – Appalachian Mountain Club
AMM – Adaptive Management Measures
APE – Area of Potential Effects
AW – American Whitewater
CRC – Connecticut River Conservancy
CTB – Cobblestone Tiger Beetle
DEP or MassDEP – Massachusetts Department of Environmental Protection
EEA / EOEEA – Executive Office of Energy and Environmental Affairs
EIS – Environmental Impact Statement
FERC – Federal Energy Regulatory Commission
FL – FirstLight Power
FLA – Final License Application
FPA – Federal Power Act
GG – Greening Greenfield
ISO-NE – Independent Systems Operator – New England
MDFW – Massachusetts Division of Fisheries and Wildlife
MEPA – Massachusetts Environmental Policy Act
MW – Megawatts
NEPA – National Environmental Policy Act
NMFS – National Marine Fisheries Service
NRF – Naturally Routed Flow
PM&E – Protection, Mitigation, & Enhancement
PTB – Puritan Tiger Beetle
REA – Ready for Environmental Analysis
SNS – Shortnose Sturgeon
TF – Turners Falls
TFI – Turners Falls Impoundment
TNC – The Nature Conservancy
USFWS – U.S. Fish and Wildlife Service
USGS – United States Geological Survey (usually used in FirstLight documents for USGS “gage” or “gage flow”)
WSE – Water Surface Elevation
WQC – Water Quality Certificate
Mass DEP Recent Changes
As a result of our advocacy MassDEP launched their new web page to help us track this process, but there are changes to some of their previous positions.
As of their January 3, 2024 website update, DEP has committed to:
- Holding the public hearings on line (we asked for this);
- Holding a hybrid public information session where there will be back and forth dialogue (more below);
- Recording the above and making it all available on their website (also new at our request);
- Extending the public comment period from 21 to 35 days,
- Note: They have moved the sign-up for their email list to let us know when hearing dates are set, (we fought hard for this!) to a sidebar instead of buried in their text.
However,
- They are no longer planning a public information session at the start of the process to inform the public about the process and the initial proposal. The only information the general public will have is
- what they can glean about the process themselves, and
- what they read in the Water Quality Certificate (WQC) application itself.
- They have announced that the only publication where the hearing dates will be publicized besides on their website will be the Massachusetts Environmental Monitor. (Do you read this often?)
- They have never agreed to use the email list to advertise any changes to their website like this collection; only for the hearing dates themselves (we just stumbled upon these changes).
Net Pricing – MRF Processing Fees
This is correspondence between Arlene Miller of the Springfield Recycling Facility and Peg Hall of Greening Greenfield.
December 20, 2023
Re: Springfield New Pricing
Peg,
Thank you for your note regarding clarification about the MRF processing fees. It certainly can be a very confusing issue.
Let me begin with a bit of history. You may remember that in FY 2020, the 10 year contract extension the regional communities signed with the MRF operator (Waste Management) expired. That contract was very favorable to our towns. We never paid anything and we most often received revenue for our recycling. However, around 2018, the recycling markets took a deep dive. We were protected by the contract and our “deal ” remained in place for several years after the market dive until the contract expiration date.
The recycling world changed at that point–not just in Massachusetts. All over the country. The MRF processors demanded an up front processing fee to cover the operating costs. Our current contract began in July 2020 expires June 30th 2025. The processing fee in that contract began at $93.50 and will increase to $103.31 by the last year of the contract.
The western MA communities negotiated a revenue component to this contract. The revenue section is based on a monthly market driven AMV–Annual Monthly Value. Put very simply, the dual stream communities are responsible to pay the net amount of the different between the operating fee (processing fee) and the AMV.
We are now 3.5 years into that contract. The actual average cost to the MRF communities for the first 3 years was : FY 2021 -$41.81, FY 2022 +21.72, FY 2023 -$47.80. As of December 2023 (FY 2024) we are paying $44.50 . You will note that in year #2 of this contract the AMV was greater than the operating cost. During that year–the towns 12 month average was a positive revenue of +$21.72. I have sent you copies of the reports we receive monthly, delineating the operating cost, the AMV and the net cost to member towns. The better the market–the better we do. It is that simple.
I am attaching here for you three year end summary reports plus the most recent operations report through December. (the AMV is given one month in advance)
Congratulations to Greenfield for receiving this fabulous EPA grant award. I hope this summary helps you and the town officials better understand the financial picture that is in place at the Springfield MRF.
Please feel free to let me know if you have any additional questions.
Sincerely,
Arlene Miller
In response to Ms. Miller’s letter, Peg writes to the Greenfield Town Councillors:
December 23, 2023
Dear City Councilors and Councilors-elect,
Please see (ab0ve) for a letter from Arlene Miller, Chair of the Springfield MRF Advisory Board. Although she included a number of past annual reports with lots of details, I am forwarding only the most recent one, along with her cover letter as they are large files. I can make any other years available upon request.
At the November 15 City Council meeting, the packet presented to the Council from the City Recycling Grant “Team” included at the top of page 12 the following misleading statements regarding pricing: “Currently the City pays $100/ton for procession dual stream materials at the Springfield Materials Recycling Facility (Operated by Waste Management Recycle America). Technically in our contract we qualify for an “Average Commodity Revenue” or ACR for the monthly net per ton revenue from the sale of recyclables in our contract. With an ACR clause, in months where material markets are good, we’ll receive more revenue, however, when markets are down, we receive no revenues. For this past year to date, we have not received any revenues.”
As I stated in public comment following the Team’s presentation, we do not and have not paid $100/ton for our dual stream. The revenue we receive is credited against this base fee so that our actual payments have been considerably less, such as the $44.50 we are paying for December 2023. In case there was any confusion about the differing amounts you heard about, I solicited and received this confirmation of my numbers directly from the Springfield MRF Advisory Board.
Also, as you can see from the attached public report, the residue rate at the Dual Stream Springfield MRF is calculated at 5%. This is much lower than the national average quoted on the bottom of page 10 of the 11/15 packet where it says “dual stream on average has about a 12.67% contamination rate”. Note that near the bottom of page 11, the proposed Berlin single stream MRF is said to have contamination of 15 – 20 % and then a residue rate of 2% of the remaining fraction. At a December cost of $86.15 / ton (as in attached chart) that alone, represents a considerable cost differential between dual stream and single stream. Actual contamination plus residue at the dual stream MRF totals between 5 & 5.7% (personal communication).
Peg Hall
Greening Greenfield
Solid Waste & Recycling Consultant, retired
CT River Hydro – Current Status section
[Updated 05/05/23]
FirstLight Power has applied to relicense a number of existing hydroelectric power facilities on our portion of the CT River. Greening Greenfield does not want these licenses to allow operations for another 50 years like the last 50 have been. Read on to learn more background and see how you can Take Action.
Current Status
In early January 2023, another delay was approved (see last 2 paragraphs), giving FirstLight until March 31 2023 and FERC until May 31 2023 to issue the REA notices. See LEARN MORE for a description of the process. This will probably be delayed due to change below.
FirstLight has submitted a “final” Flow and Fish Passage Settlement Agreement to FERC dated 3/31/23 seeking a 50-year license. Topics such as Erosion (truly not done), Cultural Heritage (there is an Memorandum of Understanding), and Recreation (lots addressed in Flow, and perhaps in separate documents) are still not fully done and may still be being negotiated.* Don’t forget that the “Final” Settlement Agreement, is only “final” for the entities who agreed to it, which does not include all Interested Parties, nor the DEP itself, nor the FERC.
The FERC responded on April 7, 2023 with a Notice of Settlement Agreement, giving the public until May 7, 2023 to file comments on the Settlement Agreement with their reply comments due by May 22, 2023.
BUT
On April 26, 2023, the FERC told FirstLight to submit cost information for the various provisons of the Settlement Agreement within 15 days.
Connecticut River Conservancy asked the FERC to extend the public comment period until 15 days after the financial information is received so all could include that in their comments, and the FERC has agreed and extended the comment period until MAY 26!
We have until May 26 to submit our initial comments, and if this new data gives us something else to say, or we think of something we forgot, we can Comment again.
* “This Settlement Agreement is the end product of the Parties’ work on: (1) fish passage, (2) flows for fishery, ecological conservation and recreation purposes, and (3) protected, threatened and endangered species, and as to the Parties, addresses all outstanding issues for the relicensing of the Projects on those topics (“Topics within the Scope of this Agreement”)”
In April and May 2023 our attention is now focused on the FERC. But we will shift back to MassDEP again soon. Greening Greenfield has mostly focused on the PROCESS of this relicensing, especially the neglected part that the state has to play. In this regard we’ve made some good progress with your help and the help of our legislative delegation:
- Our Request for public meetings has been heard!
Our legislative delegation is allowing us to share these June 2022 notes from their monthly meetings with EEA agreeing there will be FOUR public meetings. THANK YOU to everyone who wrote. It’s a start.
- MassDEP launched their new web page to help us track this process. And it is confirming and giving details about the 4 public meetings. Great work everyone!!
- MassDEP has added an option to be added to their mailing list to be notified of updates to the 401 process. We recommend you sign up to hear the latest.
What’s Next? See Take Action for what DEP has agreed to and what still needs work.
Greening Greenfield would like as many people as possible to be involved in the relicensing effort, continuing to make local voices heard about the health of our river.
Although the federal government is the ultimate licensing agency, Massachusetts has the POWER to define how our river can be used, by issuing a Water Quality Certificate. MassDEP* does not have a well-defined required process for soliciting public comment on a Water Quality Certification. In the recent past, they have simply required a public notice in the newspaper, which is easily missed, and a 20-day comment period. This is now much better than that minimum, but we need to stay on top of their proposed process and convince them to get the details right. AND it appears that according to regulations they don’t control, there will still only be 20 days in the FORMAL public comment period. We have to pay attention.
FirstLight Power operates interrelated hydroelectric projects on the Connecticut River that are currently up for relicensing. These hydro projects include
- Northfield Mountain Pumped Storage Facility
- The “impoundment area” – the 20 miles of CT River above the Turners Falls Dam, from Barton Cove to Vernon, VT
- Turners Falls Dam itself
- Station One – a tiny power generating plant, and
- Cabot Station
Upstream dams in VT & NH are not covered here, but we urge you to learn about other relicensing projects from other sources, such as the Connecticut River Conservancy and Great River Hydro. The FERC has indicated it will issue a single Environmental Impact Statement for all of these combined projects. Flow available from upstream affects us.
Go to:
TAKE ACTION for
- Prior action successes
- A description of our new, current ACTION ITEMS: Comment to FERC, add yourself to DEP lists for updates, & request better communication
- Sample letter ideas
- Names and addresses
Go to:
LEARN MORE for background information including:
- Players
- Process
- Pumped storage: purpose and problems
- $$ Two other notes on money $$
- Links to other sources of information including documents
Greening Greenfield is currently focusing on the PROCESS of relicensing, and urges you to contact other sources for more information about the technical aspects of river flow, erosion, fish habitat, recreation, and more, including
The Connecticut River Conservancy hydro pages
Karl Meyer’s CommonWealth Journal article
*Acronyms (some used by GG; many more in formal documents)
AIP – Agreement in Principle
AFLA – Amended Final License Application
AMC – Appalachian Mountain Club
AMM – Adaptive Management Measures
AW – American Whitewater
CRC – Connecticut River Conservancy
CTB – Cobblestone Tiger Beetle
DEP or MassDEP – Massachusetts Department of Environmental Protection
EEA / EOEEA – Executive Office of Energy and Environmental Affairs
EIS – Environmental Impact Statement
FERC – Federal Energy Regulatory Commission
FL – FirstLight Power
FLA – Final License Application
FPA – Federal Power Act
GG – Greening Greenfield
ISO-NE – Independent Systems Operator – New England
MDFW – Massachusetts Division of Fisheries and Wildlife
MEPA – Massachusetts Environmental Policy Act
MW – Megawatts
NEPA – National Environmental Policy Act
NMFS – National Marine Fisheries Service
NRF – Naturally Routed Flow
PM&E – Protection, Mitigation, & Enhancement
PTB – Puritan Tiger Beetle
REA – Ready for Environmental Analysis
SNS – Shortnose Sturgeon
TF – Turners Falls
TFI – Turners Falls Impoundment
TNC – The Nature Conservancy
USFWS – U.S. Fish and Wildlife Service
USGS – United States Geological Survey (usually used in FirstLight documents for USGS “gage” or “gage flow”)
WQC – Water Quality Certificate
Recycling decision can be better, cheaper, By Peg Hall
My Turn The Recorder, December 11, 2023, Page A6
In a recent article covering Greening Greenfield’s Community Conversation about Proposed Recycling Changes because of the $2 million EPA grant, while we appreciate the front page coverage, some important facts were skipped that we feel residents need to hear. [“Talk considers city’s recycling future,” Recorder, Nov. 1].
Yes, Single Stream recycling would require having our recyclable materials be driven twice as far, though the article did not mention the most likely ultimate destination of Berlin, CT, nor the extra greenhouse gas emissions to double the driving distance.
The Report also neglected to point out that Single Stream facilities cost more. In July, through October of 2023 it was about $42/ton more, with single stream charging towns a net of from $103.08 to $110.49 per ton, (frequently more than trash) while our dual stream program cost us a high of $68.33 in August, and a low of $55.82 in October. This would be an extra $60,000 per year or more to give up taking materials to our current dual stream facility in Springfield.
The article does not mention that the Springfield Material Recycling Facility we currently deliver to for “dual stream” materials (containers kept separate from paper products) is owned by MassDEP and overseen by an Advisory Board made up of municipal and regional representatives. The single stream facilities are owned by private, for-profit entities who do not have this level of government oversight and cannot be claimed to have a town’s best interests at heart.
Just as Greenfield has Greenfield Light and Power, and thus saves residents a lot of money on electric bills because of that local control, and has GCET and saves residents a lot of money on internet because of that local control, our Springfield, regional Materials Recycling Facility has local control and saves us a lot of money.
Why would we give that up? We don’t have to if we continue with dual stream recycling.
And while a City representative is quoted as saying Single Stream is “the future,” the article neglected to include the fact that nine municipalities in our region tried single stream and have gone back to dual stream since 2020: Cummington, Granby, Granville, Huntington, Ludlow, New Marlborough, Orange, Westhampton, and most recently Holyoke. These municipalities have put single stream in their past. Montague also recently declined to change to single stream.
For those of us in a part of the state and country to still have the option of a public, well-managed dual stream facility, there are cost advantages and, not unrelated, superior products created, that can yield better prices.
We can all agree that the cost of trucks and labor must be factored into decisions, but it did not mention possible alternative collection methods, such as collection of paper products one week and containers another, such as is done in Ludlow, for example. With larger containers, could collection be less frequent? A thorough analysis needs to be performed and shared.
The article never mentioned the EPA grant guidance that “community concerns will be considered in the decision-making process, and decision makers will seek out and facilitate the involvement of those potentially affected.”
Instead the City is quoted saying they will enter into a public education and enforcement effort with the assistance of the 3-year Project Assistant to be funded by the grant. But, public education about what has been decided is not a substitute for working with the public to make these decisions that will affect our habits and pocketbooks into the future.
The grant has been approved, but not “awarded”. The EPA has already agreed to make changes to the contract that will allow the City to choose between dual stream and single stream.
Now that the election has confirmed there will be new Councilors and a new Mayor, and now that EPA has agreed to let the grant have the flexibility we need, let’s all work together to make the best recycling decisions we can for implementing this wonderful grant.
Peg Hall is a member of Greening Greenfield and a retired municipal department head and solid waste and recycling consultant.
Plastic and Styrofoam Ordinance
a) “Packaging” shall mean all food and beverage related wrappings, bags, boxes and containers.
b) “Styrofoam” shall mean single-use expandable polystyrene foam products including cups, bowls, plates, takeout containers and trays.
c) “Retail Food and/or Beverage Establishment” shall mean any restaurant, food operation public or private, or any other place, other than a private residence, where food and drink is prepared or served, with or without charge for consumption on or off the premises, including any catering establishment or any eating place, whether fixed or mobile, restaurant, bar, cafe, cafeteria, public or private school, hospital, private club, coffee shop, sandwich stand, or any other type of food service operation.
d) “Prepared” shall mean ready for immediate consumption.
Tree and Shrub Planting at Jon Zon Center
Fall 2023 – Greening Greenfield has finished up the planting/landscaping work we had hoped to do this summer! As you know we worked on planting trees and shrubs to beautify and add native habitat to the site. We also worked with the Greenfield Tree Committee to plant additional trees as noted below. Although our dream of planting along Davis Street was impossible because of underground utilities and for the same reason we were unable to plant several trees & shrubs as planned on the north side of the building, we are very pleased with the outcome, and we hope everyone who uses the building will appreciate the plantings as they grow in the coming years.
Here are the details of what we, and the Greenfield Tree Committee planted:
Greening Greenfield’s effort: planted 12 trees/shrubs & moved 4 shrubs
8 Trees planted:
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4 clumps of Birches on east side of the building (School Street side), among the sweet fern
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2-Amelanchier (shadbush/Juneberry) on North side of building among the red-stem dogwoods
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1 pagoda dogwood east of patio outside of the fence next to the Patio
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1 sourwood near School St, North of building
4 shrubs planted:
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high bush cranberry (Viburnum trilobum)on Northwest corner of building among the red stem dogwoods
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northern bush honeysucke (Diervilla lonicera) on the Southeast corner of the red stem dogwoods
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highbush cranberry (Viburnum trilobum) in the rain garden nearest School Street
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shrubs moved: We moved 4 inkberry (Ilex glabra) that were obstructing the view of the Sr. Center sign, and replanted them along Pleasant St extending the existing ilex glabra hedge.
Greenfield Tree Committee’ effort: planted 12 trees
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2 pairs of trees behind the 2 large signs on Pleasant St. (crabapple near Davis St + redbud near School St)
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2 redbuds near the Patio on the south
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5 trees along School St. (3-musclewood (Carpinus caroliniana + 2 Amelanchier x grandifolia (Autumn brilliance)
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1 tree near the chickens to replace one that had died. (red maple)
Greening Greenfield and the Tree Committee will follow-up with any maintenance needed in the next few years. Please contact Nancy Hazard (nancyhazard30@gmail.com 413-774-5667), if you have any questions.
Greening Greenfield would like to thank you for the opportunity to beautify the John Zon Center and increase native habitat in Greenfield. We hope that the many people that use the John Zon Center will enjoy both the beauty and the increased bird and insect life that will be drawn to the area because of the new plantings that not only build native habitat, but also sequester carbon dioxide to help restore our climate.
Plant lists to help you make decisions
LISTS!
Greening Greenfield compiled these lists to help you find plants that support our ecosystem including birds, butterflies, moths, caterpillars and pollinators in your yard and community.
- “Finding plants” helps you find a specific plant for a specific spot.
- “Specialty lists” allows you to dive deeper into the plants you are considering. Do they support moths, butterflies and caterpillars? Birds? Bumblebees? And how many?
- “Local Lists” – helps you find trees for your community, for streets, parks, and your yard, and a unique plant list, created for us by Dr. Tallamy, of trees, shrubs and herbaceous plants for our area.
- FINDING PLANTS THAT WILL THRIVE IN YOUR YARD OR COMMUNITY
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- Plant Finder – by Native Plant Trust This unique list includes ONLY plants that are native to the Northeast. The advanced search function enables you to specify what you are looking for: growing conditions, plant type, who it attracts, flower color and more! This leads to beautiful photos of the plants that meet your criteria. Click on the photo to find more information about that plant!
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- Missouri Botanical Garden Plant FinderThis is an easy, well organized website you can use to search for information about native and non-native plants. While it is focused on the St Louis, MO area, it is an excellent tool to find an overview of a plant including where in the world the plant is native.
- SPECIALTY LISTS
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- Moths/butterflies – Native Plant Finder – Doug Tallamy’s work on moths and butterflies. Enter your zip code and see a list of trees, shrubs, and herbaceous plants that butterflies and moths lay their eggs on, with the plant that hosts the most species listed first. Search on a specific genus, such as maple/Acer and find a list of species that are native to our area, OR click on the picture of moths and butterflies and find out which plants they depend on. The site also lets you create a personalized list.
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- Birds and more – Audubon’s Native Plant Database
Enter your zip code to find out which birds are attracted to which native plant, a photo of the tree, shrub, or herbaceous plant, and a description – size, and optimal growing conditions, etc. It also mentions if it is used by butterflies and moths, but no details about that. You can create a personalized list which is emailed to you.
- Birds and more – Audubon’s Native Plant Database
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- Bumblebees and more: Native Plant Finder for Pollinator Species at Risk by Dr. Gegear This unique list was created by bumblebee bee specialist Robert Gegear, professor of entomology at UMass Dartmouth, to help you make your yard friendly to bumblebees, bees, and others that are at risk. The table includes flower bloom time and color, so your garden can support pollinators all year long. It is organized by categories such as a source of nectar, pollen, or a host plant. Dr. Gegear is adding information about butterflies and moths.
- LOCAL LISTS
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- Trees – Resilient Trees for your Yard & Community by Greenfield Tree Committee (2019) A unique list of trees that will support our ecosystem and thrive on our streets, in our parks and in our yards, with data on moths, butterflies, bees, birds, and mammals! The 2-page PDF offers quick comparisons, while the on-line list links to photos and growing conditions. Evergreens and willows, and other trees that will thrive in your yard, but not on streets, are missing but you can find those trees by checking the Franklin County list below. A few non-natives are included, as noted on the 2-pager.
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- Franklin County – Butterfly & Moth Host Plants by Doug Tallamy, PhD (2019) This link will take you to an explanation of why this unique list is important, how to use it, and a link to a spreadsheet, which can be downloaded to your computer. This Franklin County spreadsheet, created for Greening Greenfield by Doug Tallamy, lists trees, shrubs, and herbaceous plants by genus, and ranks then according to how many species of butterfly and moths use then as host plants. The spreadsheet also includes generalized common plant names. Greening Greenfield has added names of invasive plants to avoid; as well as several tabs that highlight trees, shrubs; and a sheet where you can manage information about your yard by documenting an inventory and plan what you’d like to add to improve the diversity of plants in your yard.
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- Grow Native Massachusetts is a 10 year old organization in Waltham, MA that has been working to “inspire people to action across the Commonwealth, on behalf of native plants and the diversity of life they support.” Their website has a wealth of resources including a booklist, a collection of their “Evenings with Experts” videos, and sources for plants and seeds and more.
Supporters and Co-sponsors
We wish to heartily thank our supports and sponsors
. . . and invite you to visit their websites!
Supporters:
Community Foundation of Western Massachusetts
Franklin County Community Development Corp
New England Grassroots Environment Fund
Co-Sponsors:
Franklin County Chamber of Commerce
Franklin County Community Development Corp.
Franklin County Community Health Center
Franklin County Continuing the Political Revolution
Franklin Regional Council of Governments
Local Access to Valley Arts (LAVA)
Traprock Center for Peace and Justice
What Friends of Reusable Bags has Accomplished to Date
During Co-Vid bag-making workshops were temporarily halted and most of the bag-making done among Friends of Reusable Bags volunteers in private basements.
Review of past Reusable Bag events
Friends of Reusable Bags held bag making sessions at Winter Farmers’ Markets, and Wow! What a great and busy time. We had over 50 people at each one, including all ages. Everyone was happy and helpful, and while most people brought their pretty bags home, we also had over 50 donated that we’ll be passing on through one of our many partners in the community. Although continuing workshops with schools are on hold right now, and we’re sad that the event with the Deerfield Valley Art Association has been postponed indefinitely, we expect that enthusiasm to return when we’re able to get out more. Besides making reusable bags, including for those in need, we’re excited to see the opportunities increase for discussing issues of single-use items, and plastics in the environment, especially with kids and sometimes BY kids. Please note for warmer months that grommeted bag making outside is troublesome because of the little disks of plastic stamped out by the grommets, but we’ll continue to explore protected areas for future workshops.
Connecticut River Conservancy also offered us space to make bags at the Sound to Sea gathering at the Green River Swimming & Recreation Area. Despite having spent the morning picking up trash, at least 29 willing volunteers were excited to make themselves a sturdy, grommeted bag from malt bags donated by The People’s Pint with handles made from some of the miles of drip tape otherwise discarded yearly by many area farms. We even weight-tested the finished bag by holding one of our youngest volunteers and proved that they are really sturdy! Several people made another bag to donate, which is how we like to do it. Despite the truly huge tarp to protect the grass from the little disks of plastic cut out by the grommet machines, we still had to be careful in the wind not to create any plastic pollution of our own, but we swept them all up at the end. The Bag Project graciously let us borrow their grommet machines, and other equipment for this event as our first big test run.
Franklin County — Butterfly and Moth Host Plants & Invasives
ABOUT THIS LIST … AND HOW TO USE IT Link to list How to download to your computer – see end of article
All plants are important, but some are much more useful to our local web of life. Greening Greenfield hopes this list will help you have fun learning about the important role of plants in your yard and community. Additionally, since we all have limited space and aesthetic preferences, hopefully it will help you make informed decisions about what to plant, or remove, to foster a healthy ecosystem.
The list was compiled in 2020 by Doug Tallamy, PhD for Greening Greenfield. Dr. Tallamy is an entomologist, professor, and behavioral ecologist, and the author of Bringing Nature Home (2009), The Living Landscape (2014) and Natures Best Hope (2020). His Homegrown National Park campaign encourages homeowners to shrink their lawn and plant with biodiversity in mind, which collectively will provide meaningful habitat. Greening Greenfield then added various “sorts” and information about invasives.
[A note about interpreting Latin (scientific) names: the genus name refers to the general type of closely related plants (for example, oaks are the genus Quercus.) The species name is the specific plant in that genus, such as Quercus alba, or white oak. The plural of “genus” is “genera.” One confusing thing is that at the moment some plants are being reclassified as DNA data of plants is being discovered. For example, “Asters” are now two different genera. Do not despair!]
The list includes all genera of native plants that are in our area and notes how many species of Lepidoptera (butterflies and moths) use plants as “host plants in each genus.” A Lepidopteran host plant is a plant upon which a butterfly or moth lays its eggs and which provides food for the caterpillars that hatch from those eggs.
Caterpillars grow by eating leaves of the host plant. Caterpillars are not only the young of butterflies and moths; they are also the major source of food for birds to raise their young. Caterpillars have been called a “keystone” species because they move resources in plants up the food chain. A keystone species is a species on which other species in an ecosystem largely depend, such that if it were removed the ecosystem would change drastically. New England is host to over 2200 moth and butterfly species.
Doug Tallamy’s research has found that plants native to a region support many more native caterpillar species than non-native plants. In addition, Dr. Tallamy’s student, Desiree L. Narango PhD, found that for chickadees to find the 6,000-9,000 caterpillars that they need to successfully raise four chicks, over 70% of the plant foliage near their nest must be native to the region! This also helps explain why we rarely see much damage from native insects on our plants. Most of the damage we see is from non-native insects that have few predators or natural means of control. In general, most native plants have co-evolved alongside the insects and other animals that use them for their nectar, pollen, seeds, berries and more! Thus, plants that are not native to our area, especially those brought in from other countries, are generally not as useful to our native wildlife.
HOW TO USE THIS LIST
Genus: The plant genus is listed in the order of those hosting the most butterfly and moth species to the fewest. Browse it.
Native plant species within a genus have similar defenses against insect feeding. So, the insect species that have adapted to feed on one species within a plant genus, are able to feed on other plants within that genus (but they may have preferences). Remember that being native to our area is critically important! Species NOT native to our area do not host as many butterflies and moths. For example, a sugar maple hosts 271 species, but a Norway maple hosts only seven. A Gingko hosts zero.
When it comes to native plants, those hosting both large and small numbers of butterfly and moth species are important to biodiversity. Plants with highest use harbor mostly “generalist” Lepidoptera that lay eggs on many different native plants. Native plants that host only a few Lepidopteran species are critically important to the “specialists,” who depend on them exclusively. For example, the monarch butterfly is a specialist that only lays its eggs on milkweeds. Milkweed is also a host to two other specialist Lepidopteran species. These species have adapted to be able to use milkweed despite its toxic sap, while other Lepidoptera avoid them. Although not covered in this spreadsheet, it is known that milkweed flowers provide nectar for a wide range of insect species.
Searching for Common names in the Spreadsheet… and Genus
If you know the common name of a plant you want to find more about, use the “Find” feature of the spreadsheet (control F) and enter that into the box in the upper right hand corner. If that name is in the spreadsheet it will find it. However, all common names are likely not listed. Another approach is to search on the web for the common name, discover it’s Latin name (genus and species), and look for that on this spreadsheet. We have also added a tab that is alpha sorted by Genus for your use.
To find a list of plant species native to our area within a given genus, check the generalized common name(s) listed next to the genus in the spreadsheet. For a more detailed list of species, go to the Native Plant Finder hosted by National Wildlife Federation, a photo-enhanced website featuring Doug Tallamy’s findings. To use the Native Plant Finder, a) enter your zip code, and b) enter the name of the genus (e.g. Quercus, Acer, etc.). A box will pop up with the list of species native to your area. You can also search on a specific butterfly or moth to learn which plants it lays its eggs on.
Tree? Shrub? Vine? Groundcover?
We have added several tabs (look at the bottom of the screen) to make your search easier to find the plant form you are looking for. It turns out that in some cases a single woody genus may include trees, shrubs, vines, and/or groundcovers! So, don’t discount the idea of adding a plant to your yard from the genus “Prunus” because you don’t have space for a tree. You could find a large or small shrub form in the Prunus genus perfect for your yard! An entirely different tool with a similar name is The Native Plant Trust’s Plant Finder. It is the perfect tool to explore your options and learn about attributes of various species appropriate for landscaping purposes.
Invasives and weedy plants – Plant Species to Avoid
Note that some genera on the list include exotic, non-native plant species that are invasive and should not be planted. They could become problematic, especially if they spread to our natural areas. We have added a column that lists the species that are labeled invasive in Massachusetts by the Massachusetts Invasive Plant Advisory Group (MIPAG) and cannot be sold in our state. Nearby states’ invasive plant lists include additional species that would be safer to avoid (VT, NH, ME, RI, CT, NY).
In addition, there are invasive plants that are not listed in this excel spreadsheet, because they belong to a genus that is not native to Franklin County. If you would like to plant something that is not on this plant list, double check MIPAG to be sure it is not invasive to our area, or you could search on a plant name and add the word “invasive” to the search. The results can help you assess if a species may be risky to plant in your yard.
You may also recognize other native plants on this list as weedy. Although you probably wouldn’t want to add them to your yard (for instance ragweed and poison ivy) at least it is interesting to see that they serve a purpose about which you might not have been aware.
We encourage you to remove and replace invasive species in your yard. Mass Audubon has good photos of MA invasives to help you identify them, and recommendations on how to remove them by pulling and/or use of chemicals.
Making Decisions – What to plant? & Make your own list
We have added a tab to encourage you to take an inventory of your yard, assess it, and note what you would like to plant to support Lepidoptera. If you are familiar with spreadsheets we invite you to download it and play with it! You may also be interested in which plants are useful to birds and other wildlife, and to pollinators (in addition to Lepidoptera) such as beetles, ants, flies, and hummingbirds, or learn more about how you can support declining bumblebees. Finally, you will also want to determine which of these native plants fulfill other needs for your landscape (shade, privacy, color, etc.) and which would grow well with your specific soil, sunlight and moisture conditions. Explore Our favorite online tools to help you make decisions.
How to download the list to your computer
1. Double click on the spreadheet and it will take you to GoogleDocs where it is posted.
2. In the center top “open it-choose “Google Docs”
3. At the way top left click “file”
4. in the dropdown menu…choose “Microsoft Excel” or “Open document format” & check your download folder
Sample letter by Peg Hall
Sample Letter to Katie Theoharides, Massachusetts Executive Office of Energy and Environmental Affairs (EEA), President and CEO (2016-2022)
December 15, 2021
Dear Secretary Theoharides:
I am writing today to request that there be a robust public hearings process for the Water Quality Certificate sought by FirstLight Power as part of their proposed relicensing of the Northfield Mountain Pumped Storage Power and Turners Falls dam project before the Federal Energy Regulatory Commission.
It is my understanding that the Donahue Institute has been retained to conduct one or two hearings, which is marvelous news, but probably insufficient. There is lots of public interest in the project, and the impacts of it reach across all 4 states that border the length of the Connecticut River, so at least in Massachusetts, there should be sufficient attention paid to the ongoing and long-term effects of this project on the local and extended environment.
Environmental objections fall into two basic categories:
- the fact that grid electricity is used to pump water to the upper reservoir, thus currently using fossil fuels, despite the repeated public claims of FirstLight that it is all renewable; and
- the fact that unlike any modern design, this system has no lower reservoir, using the Connecticut River as if it were a lower reservoir, with catastrophic environmental consequences.
I also recognize the state’s (and world’s) need to find storage solutions to pair with various renewable energy sources such as wind and solar. There will need to be much balancing of those competing desires. But the maximum profit for a Canadian company that only talks about its New England connections should not be at the top of the state’s list, as it surely is not at the top of the citizens’ list. Some elements of their proposal would be laughable, were it not deadly serious. For example, in portions of the document accessible to the public they propose resolving the problem of fish passage by putting a net with a 3/4 inch mesh across the mouth of the intake during some particular season for some particular fish migrations. Since when has the value of an entire living ecosystem been represented only by fish and only by fish bigger than their net?
This is a re-licensing process with the FERC, for a facility built 50 years ago. But it is a Water Quality Certificate sought in Massachusetts. I respectfully suggest that the standard that we should continually remind ourselves of is “if this were a new license application, proposing building an upper, but no lower reservoir, is there any way this would receive an initial license?” If that answer is “no”, then their current application should be held to the same standard as any new license.
By this email I also point out that the Massachusetts Environmental Policy Act should surely be triggered by this application. There has been little-to-no acknowledgment to date from FirstLight that climate change may affect the water levels of the river, and that alternative plans and progressive improvements must be in place to address various potential scenarios that are unfortunately likely over the period of any future license.
And I strongly urge that FirstLight be required to establish a decommissioning fund for this combined operation of dam and pumped storage. The world is changing rapidly and government and ratepayers/taxpayers/citizens too often get left with the costly messes made by industry when they are no longer turning a profit to their satisfaction.
I would appreciate being added to any email list informing me of future hearings and relevant steps and public decisions.
Thank you all for your time.
Margaret J. (Peg) Hall
[postal address]
[email]
[phone]
cc:
Commissioner Martin Suuberg, MassDEP
Governor Charlie Baker, state of Massachusetts
Director Tori Kim, MA Environmental Policy Act Office
Senator Jo Comerford
Representative Paul Mark
Sample Letter to MEPA
Please use the letter below as a guide for writing to the Massachusetts Environmental Policy Act Office. Modify the content and formatting to suit your needs. Remember to cc all suggested people linked at the bottom of this letter.
Subject: Please review FirstLight’s hydro relicensing application under MEPA
To: Commissioner Tori Kim
I recognize that in 2012, MEPA responded favorably to a request from FirstLight Power for an Advisory Opinion that MEPA would not apply to their relicensing application for Turners Falls dam and Northfield Mountain Pumped Storage facility. Since many things have changed since 2012, including the possibility that the new application meets MEPA’s current review thresholds, I hope that MEPA may still be reviewing MEPA applicability. I strongly hope the MEPA office becomes involved. FirstLight’s relicensing application is for facilities built 50 years ago. Note that
- they are requesting that this license be valid for another 50 years;
- over the past 50 years there have been extreme and negative effects of these operations on the river’s embankments and its animal and plant inhabitants;
- the climate crisis will cause many changes over the next 50 years, and while many cannot be known, fluctuating water availability and temperature changes should be anticipated;
- neither MEPA nor even the 401 process existed 50 years ago, so these reviews have never been completed for these facilities.
Therefore, I believe it is imperative that MA EEA, DEP, and the MEPA office invite as much input as possible into the issuance of the Water Quality Certificate. In the Clean Water Act, the federal government gave us this one measure of leverage in dealing with FERC’s licensing power. We must use it judiciously.
Thanking you for your time, I am
Sincerely yours,
[Your name]
[Your address]
[Your email address]
[Your phone number (optional)]
cc: Public Officials names and addresses
How to contact FERC
To Comment to the Federal Energy Regulatory Commission (FERC):
- Go to www.ferc.gov
- In the “Quick Links” box, click Documents and Filings
- In the new “Quick Links” box, click FERC Online
- On the page that opens, click eComment
- Follow the instructions to register
- Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),”
- Be sure to use Northfield’s FERC project number, P-2485, to enter your comments.
To Review Comments already submitted to the FERC:
(N.B. eLibrary works best with Chrome and Edge browsers.)
- Go to www.ferc.gov
- In the “Quick Links” box, click eLibrary
- A new page opens showing “Enter Docket Number”
- Type “P-2485” in that box and a list opens showing all names
To Subscribe to Notifications from the FERC:
- Go to www.ferc.gov
- In the “Quick Links” box, click eFile
- If you have previously registered, fill in your email and password, then click Log In
- if not, click the New User link and follow the instructions
- On the left side, click eSubscription
- At the top, click Add New Subscription
- Where it says “Enter Docket Number”, type in “P-2485” for Northfield Pumped Storage
- At the bottom, click Subscribe
- If you also want Turner’s Falls/Cabot Station, repeat last 3 steps, using “P-1889”. Note that since licensing for these projects has been combined, using both project numbers will frequently result in duplicates.
FERC recommends to be the most powerful and persuasive to them
- Keep your comments short and succinct: a few pages at most unless you have some 100 page study they haven’t seen;
- Be very specific. Generalities like “I think it’s a bad project” or “it’s a travesty” don’t add to their knowledge;
- Go ahead and make it personal about things they wouldn’t know from their distance;
- Be really clear and loud if you think you have facts they don’t know;
FERC 01-12-23 letter requesting REA Notice be delayed
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426
January 12, 2023
OFFICE OF ENERGY PROJECTS
Project No. 1889–085
FirstLight MA Hydro LLC
Project No. 2485–071
Northfield Mountain LLC
VIA ELECTRONIC MAIL
Mr. Alan Douglass
Regulatory Compliance Manager
Northfield Mountain LLC and FirstLight MA Hydro LLC
alan.douglass@firstlightpower.com
Reference: Requests to Delay Issuance of Notice of Ready for Environmental
Analysis
Dear Mr. Douglass,
Northfield Mountain LLC and FirstLight MA Hydro LLC (collectively, the
Licensees) filed relicense applications for the Northfield Mountain Pumped Storge
Project No. 2485 and Turners Falls Hydroelectric Project No. 1889 on April 29, 2016,
and amended the applications on December 4, 2020. On December 16, 2020,
Commission staff issued procedural schedules that included a target date of May 2021,
for the notice that the license applications are ready for environmental analysis (REA
notice).
On August 3, 2021, the Massachusetts Department of Environmental Protection
requested that the Commission delay the REA notice until November 12, 2021, to
provide time for relicensing participants to negotiate a settlement agreement. On August
5, 2021, the Massachusetts Division of Fish and Wildlife and the Licensees filed
comments in support of delaying the REA notice. The Licensees stated, in the August 5,
2021 filing, that they were engaging resource agencies and other stakeholders in
settlement discussions involving fish passage, streamflow, recreation, and cultural
resources.
On November 12, 2021, the Licensees filed an update indicating that
substantial progress had been made on a settlement. The Licensees stated their intent to
file a settlement agreement in June 2022, and requested that the Commission continue to
delay the REA notice. The Licensees subsequently filed updates on January 4 and
January 31, 2022, indicating that conceptual agreements had been reached on several
issues.
The Licensees filed agreements in principle on whitewater boating releases and
recreation improvements on February 28, 2022; and on flow releases, water level
management, and fish passage on March 18, 2022. In the March 18 letter, the Licensees
stated that they were targeting the summer of 2022 for filing a comprehensive settlement
agreement that resolves all relicensing issues.
On July 25, 2022, Commission staff requested an update on the settlement
agreement. The Licensees filed the update on August 9, 2022, indicating that substantial
progress had been made toward a comprehensive settlement agreement and that an
agreement would be filed by December 31, 2022. On October 31, 2022, the Licensees
filed an amended agreement in principle on flow releases and fish passage, and reiterated
that a settlement agreement would be filed by December 31, 2022.
On January 4, 2023, the Licensees filed an update stating that although a
comprehensive settlement agreement has not been reached on all issues, they have
finalized a settlement agreement on operations, fish passage, and protected, threatened,
and endangered species. The Licensees state that the agreement is being circulated for
signature by: Massachusetts Division of Fish and Wildlife, National Marine Fisheries
Service, U.S. Fish and Wildlife Service, and the Nature Conservancy. The Licensees
commit to filing an update on settlement discussions involving recreation, whitewater
boating, cultural resources, and shoreline erosion by March 31, 2023.
To provide time for the licensing participants to finalize the settlement
agreement(s), staff will delay the REA notices until May 31, 2023. The Licensees should
file any settlement agreement(s) by March 31, 2023, to provide time for the Commission
to provide public notice and solicit comments on the agreement(s) prior to issuing the
REA notices. We expect the Licensees to file biweekly updates on the settlement
discussions until March 31, 2023.
Sincerely,
Vince Yearick
Director
Division of Hydropower Licensing
401 WQC update for FL relicensing site
I am hoping you can share this with the other members and staff for the delegation. Today we updated our 401 WQC for the FL re-licensing site to reflect updates and changes in our Water Quality Certification public process.
We have modified DEP’s approach to the FL 401WQC public engagement process to accommodate releasing a draft WQC for public review and comment. The past process consisted of a public hearing on the application at the beginning of the year-long process, three public information sessions, and no comment period on a draft WQC. Going forward, we will be hold a public hearing on the application, hold one public information session a few months later, and then at approximately the eight month mark we will release the draft WQC and hold another public hearing with a comment period that closes in time to allow for the agency to consider comments, revise WQC as needed, and issue by the 1-year deadline.
We believe the updated public process will allow for further engagement with members of the community and stakeholders. We do not have an update on any application filing at this time. If there are any questions please let me know.
Elena Cohen
District Director
Office of Senator Jo Comerford
Hampshire, Franklin, Worcester District
413.367.4656
elena.cohen@masenate.gov
Pronouns: she/her/hers
CT River Hydro Relicensing – June 2022 Delegation notes
CT River Hydro Relicensing – June ’22 Delegation notes
The following are notes as of a 6/9/22 meeting that members of the legislative delegation had with EEA and DEP.
- Updates from EEA/DEP since last call, especially focused on timing
- Timing still appears to be August for the Ready for Environmental Assessment**. EEA/DEP has not heard anything further from FERC that would indicate them moving forward any faster. DEP is lining up what they need, assuming the process will start around then.
- There are still negotiations going on re: comprehensive assessment. Those negotiations seem to be productive.
- MEPA Involvements
- MEPA Director Tori Kim is reviewing the previous determination and looking at whether a MEPA filing will be needed. Director Kim was actively looking at it when they spoke earlier in the week. DEP’s impression is that Director Kim would like to have a decision well before the August clock starts.
- DEP public-facing website on the relicensing
- DEP has developed a website with information both about the process and with links to FirstLight’s website for easy access to the information they are required to post. They added a mailing list feature so constituents can elect to receive email updates from DEP on the process. They plan for the website to be live in the next couple of weeks.
- Public meetings
- DEP is contracting with the UMass Donahue Institute to hold public meetings. Donahue will help with the public outreach and with an economic analysis.
- There will be four public meetings
- An introductory meeting, mainly a presentation of what’s in the application and about the process
- A listening session coinciding with the public comment period
- A presentation as DEP has processed the application to report back on what their direction is with the 401 WQC
- As they’re finalizing it, letting people know what’s in it and why
- It’s important that people submit comments during the formal public comment period because this establishes their rights to appeal, even though they’ll continue to have dialogue after that period.
** FERC issues the “Ready for Environmental Assessment (REA)” at which point, FirstLight will submit their application for a 401 Water Quality Certificate (WQC) to DEP, which will then start the one-year clock for DEP to issue the 401 WQC.
Greenwashing 2, Biodegradable Bags
Similar to the discussion of Greenwashing about a different plastic bag, here’s a discussion about another sample, this time an allegedly biodegradable bag that is quite horrid. There are better biodegradable bags, but this is not one of them. Do not encourage its use, and always read claims with a cupful of salt.
This handled, plastic bag sample is light green, like many compostable bags. But just read carefully what it says about itself:
THANK YOU [for what?]
This bag is our commitment to the environment. [and I worry very much what kind of commitment that is – deceptive or just misled?]
Reusable, recyclable & biodegradable. [NO!!! If it is biodegradable, which it is not, then BY DEFINITION that makes it not recyclable. Putting such bags into plastic bag recycling wrecks the plastic bag recycling. Putting into a curbside collection container wrecks even more.]
Reduces landfill volume [our trash did not go to a landfill, except the ash after waste-to-energy plant has burned it (See discussion under Greenwashing 1); and “volume”?? Compared to what?]
Helps the environment [how??]
Thank you [again] We appreciate your business. [OK, maybe that’s clarifying for what they are thanking us.]
[the not terribly fine print] 49.28% biodegradation in 900 days under Non-typical conditions. No evidence of further biodegradation. ASTMD5511.
Wow. That last one needs its own paragraph. Or 6. Lets start at the end and go backwards. “ASTM International, formerly known as American Society for Testing and Materials, is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials, products, systems, and services.” (why write when I can just copy Wikipedia?)
D5511, and yes I looked this one up, here is to test for how much biodegradation of plastics there will be under conditions of “high-solids anaerobic digestion”. In other words, they are not trying to mimic lifespan in air (litter), in water (litter), in an anaerobic digester (probably more liquids and not “high-solids”), or in your home compost bin (should not go anaerobic), or in a commercial compost facility (ditto). They are trying to approximate conditions in a landfill, so they are presuming that you are throwing it “away” and that’s where it’s going. And even then, it concludes that it doesn’t really prove anything that’s not in a laboratory. And what do they mean by “biodegrade” – turns solid carbon into gaseous carbon. Gee. I thought we were trying to REDUCE carbon going into the atmosphere. Though it, again, totally depends on compared to what.
So what did they find? Even in a landfill only about half of whatever this bag is, decomposes. That’s not “biodegradable”. I still don’t know what this bag is made of, but most likely, it is a beast I had thought/hoped was disappearing that is half plastic and half starch, creating a monster I call “bio-disintegratable”, meaning half biodegrades, and the other half becomes micro- or nano-plastics. Sound good? Yuck!
And return to the setting. Even if a landfill mimicked the testing lab, it took 900 days. You can bet that if ANY biodegradation happened in a litter environment, A) it would take longer, and B) I don’t want to look at it that long, nor deal with the byproducts.
AND a landfill is NOT SUPPOSED TO BE A GIANT COMPOST PILE. The entire point of a landfill, even if we had them around here, which we do not, is to be a giant tomb. They are designed to reduce as much air (yes, anaerobic) and water, so that things stay inert. Decomposing means converting to a combination of leachate (water pollution, whether surface or ground water) and smell or other gasses (air pollution and greenhouse gases). We don’t want things in landfills to decompose. Over enough time, most will anyway, but we want to minimize that, not encourage it.
So then what do they mean by “non-typical conditions”? Darned if I know. Probably they mean laboratory high solids anaerobic. But it’s just possible they mean anything other than the conditions under which it was tested. In any case, their technical claim is that under “perfect” conditions, less than half will biodegrade. And the rest never will.
Public Officials
Names and addresses of public officials involved in the CT River Hydro Re-licensing Project
If writing about website improvements or other comments or questions about the 401 process, please write to:
David Hilgeman and Tim Jones
Although their contact information is below, they have requested that we reach them and their team (other than for formal comments on the 401) by using the “Contact us form” on the MassDEP website so that they can track your requests and respond promptly.
David Hilgeman PE, PWS
Senior Environmental Engineer
MassDEP Wetlands Program
Major Projects and Policy Unit
100 Cambridge Street, Suite 900, Boston, MA 02114
(781) 898-8740 / David.Hilgeman@mass.gov
Timothy M. Jones, JD
MassDEP Office of Appeals & Dispute Resolution (“OADR”)
Bureau of Water Resources
Timothy.M.Jones@mass.gov
We try to keep this section up-to-date, but welcome your assistance in alerting us to any information that is out-of-date. We will continue to update this section since different contacts are appropriate for different topics.
If writing about policy topics, also write
Secretary Rebecca Tepper
Executive Office of Energy and Environmental Affairs
100 Cambridge St, Suite 1020
Boston, MA 02114
env.internet@mass.gov
DEP Commissioner Bonnie Heiple
MA Department of Environmental Protection (DEP)
1 Water Street,
Boston, MA 02108
Bonnie.Heiple@state.ma.us
DEP Undersecretary for Environment
Stephanie Cooper
One Winter St 2nd Floor
Boston, MA 02108
Stephanie.Cooper@mass.gov
Governor Maura Healey
Massachusetts State House
Room 280, Office of the Governor
Boston, MA 02133
Constituent.Services@state.ma.us or
gov.webmail@state.ma.us
If you are expressing a desire for MEPA involvement
Director Tori Kim
MA Environmental Policy Act Office
100 Cambridge Street, Suite 900
Boston, MA 02114
tori.kim@mass.gov
Copy at least your own state elected representatives, but copies to the entire Western MA/CT River legislative delegation would be good for policy comments. Sending copies to key staffers can also be helpful:
Senate:
Comerford, Joanne (SEN) <Jo.Comerford@masenate.gov>; Cohen, Elena (SEN) <elena.cohen@masenate.gov
Mark, Paul (SEN) <Paul.Mark@masenate.gov>; Gould, Jon (SEN) <Jonathan.Gould@masenate.gov>
House:
Blais, Natalie – Rep. (HOU) <Natalie.Blais@mahouse.gov>; Coryat, Corinne (HOU) <Corinne.Coryat@mahouse.gov>;
Carey, Daniel – Rep. (HOU) <Daniel.Carey@mahouse.gov>; O’Reilly, Kelly (HOU) <Kelly.O’Reilly@mahouse.gov>;
Domb, Mindy – Rep. (HOU) <Mindy.Domb@mahouse.gov>; Lily Stowe-Alekman (HOU)
<Lily.Stowe-Alekman@mahousegov>;
Sabadosa, Lindsay – Rep. (HOU) <Lindsay.Sabadosa@mahouse.gov>; Mathis, Julia (HOU) <Julia.Mathis@mahouse.gov>;
Whipps, Susannah – Rep. (HOU) <Susannah.Whipps@mahouse.gov>; McMahon, Rachel (HOU) <Rachel.McMahon@mahouse.gov>;
If you choose to write to FERC, see instructions here.
Also, below are the federal and state department heads and the public trust officials with long-term seats at the negotiating table during settlement talks.
wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service;
andrew.tittler@sol.doi.gov, lead council at the table for USFWS;
melissa_grader@fws.gov, at the table for our migratory fish;julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon);
william.mcdavitt@noaa.gov, at the table for our migratory fish;
mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife,
jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife.
Legislative Delegation Notes
CT River Legislative Delegation Notes following the meeting held 6/9/2022 with EEA and DEP
- Updates from EEA/DEP since last call, especially focused on timing
- Timing still appears to be August for the Ready for Environmental Assessment**. EEA/DEP has not heard anything further from FERC that would indicate them moving forward any faster. DEP is lining up what they need, assuming the process will start around then.
- There are still negotiations going on re: comprehensive assessment. Those negotiations seem to be productive.
- MEPA Involvements
- MEPA Director Tori Kim is reviewing the previous determination and looking at whether a MEPA filing will be needed. Director Kim was actively looking at it when they spoke earlier in the week. DEP’s impression is that Director Kim would like to have a decision well before the August clock starts.
- DEP public-facing website on the relicensing
- DEP has developed a website with information both about the process and with links to FirstLight’s website for easy access to the information they are required to post. They added a mailing list feature so constituents can elect to receive email updates from DEP on the process. They plan for the website to be live in the next couple of weeks.
- Public meetings
- DEP is contracting with the UMass Donahue Institute to hold public meetings. Donahue will help with the public outreach and with an economic analysis.
- There will be four public meetings
- An introductory meeting, mainly a presentation of what’s in the application and about the process
- A listening session coinciding with the public comment period
- A presentation as DEP has processed the application to report back on what their direction is with the 401 WQC
- As they’re finalizing it, letting people know what’s in it and why
- It’s important that people submit comments during the formal public comment period because this establishes their rights to appeal, even though they’ll continue to have dialogue after that period.
** FERC issues the “Ready for Environmental Assessment (REA)” at which point, FirstLight will submit their application for a 401 Water Quality Certificate (WQC) to DEP, which will then start the one-year clock for DEP to issue the 401 WQC.