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Subject: increased communication re FirstLight hydro relicensing

To: David Hilgeman,

Thank you for your efforts to date to include the public in the Water Quality Certificate (401) process for FirstLight Power to complete their relicensing application with the Federal Energy Regulatory Commission (FERC).  This license is needed by FirstLight in order to continue to operate the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  I appreciate the new website, the commitment to hold a series of four public meetings, and the new ability to add our name to a mailing list to receive updates.  There are additional steps I hope the DEP will take now to continue to make this a robust and transparent process:

  • Please update your website when new major documents are filed, including continuing delays in the process, such as the January 12th letter from FERC to allow delay of submission of a Final Settlement Agreement until March 31, 3023, and use the new email list to let members of the public know when milestones are delayed, as well as reached.  It is not reasonable to expect residents to repeatedly check the website just in case something has changed. 
    • Could you add a "last updated" date to the website so that we know if we need to review again for newer information?
  • Please commit to recording the public meetings and making them available on the website.  I hope this is already the intention, but it is not clearly stated on the website.
  • Please widely advertise the existence of this website now, and the dates of the meetings as soon as they are known.  For example, I have not yet seen any articles in our local papers, such as the Greenfield Recorder, announcing the website.  With a license to operate that expired in 2018 and keeps getting extended, but with such a short window for public comment as we anticipate, it will be important for the public not to lose any time once the dates are known.

 Also, I understand that Director Tori Kim is still 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 up to 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 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


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