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]

Commissioner Martin Suuberg, MassDEP

Governor Charlie Baker, state of Massachusetts

Director Tori Kim, MA Environmental Policy Act Office

Senator Jo Comerford

Representative Paul Mark

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