Dear Secretary Theoharides:
I was thrilled to learn that the DEP will take the opportunity to issue a Water Quality Certificate (WQC) so MA can add “conditions” to the license that will enable FirstLight to continue to operate their electricity-generating facilities on the Connecticut River for the next 40-50 years.
I have been active in supporting the environmental for over 50-years as a builder, director of the Northeast Sustainable Energy Association (NESEA), member of Greenfield’s Sustainable Greenfield Implementation Committee, and Greening Greenfield
As I understand it, EEA/DEP will be holding two listening sessions for input into the WQC.
Recently, Greening Greenfield held an on-line informational session, where Massachusetts Sen. Comerford, Rep. Blais, and Andrea Donlon, of the Connecticut River Conservancy (CRC) shared their understanding of the purpose of the WQC and what they knew of the process. I now understand that the timeline for issuing the Certificate is very tight – only 12-months, from the time that FirstLight applies for the Certificate to issuance of the Certificate. Greening Greenfield has set up a web page to help interested people be connected to the WQC process.
I am writing to request that the EEA/DEP hold a robust citizen engagement process.
Following are my Recommendations about how to most fully engage the public.
1. Informational session: Prior to the listening sessions, and prior to FirstLight’s submission of the WQC application, I’d like to see EEA/DEP hold an on-line, informational session that is recorded. The goal would be to outline the purpose of a WQC, and share the details of what DEP’s responsibilities are to Massachusetts residents. I recommend that the meeting be recorded, and posted with the slide-deck, so that interested parties can view or re-view it.
In addition, I would like to learn what else EEA/DEP could add that would benefit the river, surrounding land and the critters and people that live near it. For example, could one of the conditions be that FirstLight use only 0-carbon electricity to pump water up to their upper reservoir, so as to reduce carbon emissions and address the climate crisis? Are there other less-technical things EEA/DEP could add?
3. Web presence: I have recently been listening to EEA-held webinars on the Roadmap to 2025-30 to achieve goals set by the 2008 Global Warming Solutions Act (GWSA). Their set-up is excellent, and I recommend that there be a similar set-up/web presence to enable the general public to have input into the WQC for FirstLight’s operation.
In particular EEA has a dedicated website for the GWSA/Roadmap process where A) Webinars are posted prior to the meeting. B) The recording of the webinar and a PDF of the slide-deck are posted immediately after the webinar is held. C) There is an opportunity to sign up to receive notifications of upcoming webinars. D) There is a clear way to submit comments, with end dates posted.
3. Outreach/Advertising: Please reach as many people as possible about MA opportunity and responsibility to issue a WQC for FirstLight’s operations on the Connecticut River via news releases and social media, as well as emails to those who have expressed interest in this topic.
4. Engagement/ WQC specifics & time line challenges: In an ideal world, EEA/DEP would be able to share a DRAFT WQC enough before it must be submitted to FirstLight and the Federal Energy Regulatory Commission (FERC), so that citizens can comment on the specifics of the conditions for FirstLight’s operations laid out in the WQC, and the DEP/EEA still has sufficient time to incorporate any new information received. This would be in addition to the earlier opportunity for the public to share concerns.
I look forward to your responses to my recommendations, and learning if and when you will hold an early informational meeting, as well as create a web page dedicated to the WQC process. Please also add my name to your e-list, so that I will receive notification of opportunities for the public to participate and learn more about the WQC and submit comments.
Thank you for listening. I look forward to your replyNancy Hazard
Commissioner Martin Suuberg, MassDEP
Governor Charlie Baker, state of Massachusetts