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CT River Hydro Relicensing

Help Greening Greenfield make sure that FirstLight Power does not operate Northfield Mountain Pumped Storage and other hydroelectric facilities on the CT River for another 50 years as they have been operated for the last 50.

Greening Greenfield mostly focuses on the PROCESS of relicensing. 
Consult other sources for more information about the technical aspects of river flow, erosion, fish habitat, recreation, and more.

View just south of FirstLight Hydroelectric facilities, Turners Fall, MA

The FirstLight Hydro Licenses all expired in 2018, but have received multiple 1 year extensions to keep operating under the old terms.  Plans and negotiations for new license terms (presuming licenses are approved) have been happening since around 2012.

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. 

Quote of the Day: Erosion

From Comments to FERC by Christine Hatch, Extension Professor in the
Department of Earth, Geographic, and Climate Sciences at UMass Amherst: “…the current analysis [of potential shoreline erosion at the TFI*] is insufficient and incomplete….[S]ince most geomorphic change [e.g.erosion] occurs during uncommon events, basing the BSTEM model analysis in typical days within the middle of the
range of flow events is essentially meaningless for geomorphic change – such a model will most likely miss all of the events that cause change.”

The FERC vs. Mass DEP*

At the Federal level, the Federal Energy Regulatory Commission, or FERC is the ultimate agency reviewing the relicensing. But Massachusetts has the POWER to define how our river can be used, by issuing a Water Quality Certificate (WQC), sometimes called the “401” process.  At different times, we need to communicate more with one than the other.  Since MassDEP has issued the WQC, all attention now turns to the FERC.  

However, a number of entities are filing appeals or lawsuits about the WQC and since they are sometimes filed with FERC, this makes the distinction murky.  See Appeals below Current Action.

Current Action

  1. Support Mass S.2237, an Act Defining Clean Energy.  A hearing was held 07/29/25.  Without this, pumped storage counts as “clean”.  More here.
  2. Keep an ear open to hear what happens with the appeals of the state Water Quality Certification, and how the FERC’s draft Environmental Impact Statement gets changed or doesn’t, based on all our comments, including those of MassDEP.

Appeals of Water Quality Certificate (401 process)

Documents to & from MassDEP

The State Process for Water Quality Certificate (WQC) or “401”

Background Material to Learn More about FirstLight Relicensing Process

Key Players / Agencies

Descriptions of FirstLight, FERC, Greening Greenfield, MassDEP / EEA,  MEPA & their relationships to this project.  

The Federal and State Permitting Processes, and the General Timeline

How does MassDEP permitting relate to the FERC process? What are Settlement Talks? Where does the Public get a chance for input?

PUMPED STORAGE AND ITS ROLE IN THE GRID

What is pumped storage in general? How is Northfield Mountain different?  Good and bad tradeoffs.

$$ THREE OTHER NOTES ON MONEY $$

1. Set up a decommissioning fund

Some of us requested that MassDEP make one of the Conditions of the WQC a requirement that FirstLight set up a decommissioning fund.  MassDEP said they may NOT do this, and didn’t.  So instead, make this comment to the FERC on their draft Environmental Impact Statement (EIS) even though they also claim it’s unlikely. If enough of us ask, it’s always a chance.  If we don’t, they won’t.  Some day – sooner or later – the day will come when the dam or generating stations or pumped storage facility isn’t cost-effective.  While it is, they are making money and are going to want to run it.  When it is not, by definition, it will not be a good time to convince the owners to put forth the large amounts of money to remove structures and restore a free-flowing river.  Require the money to be set aside now.  When it is de-licensed, there is much less ability for government to keep an owner from walking away and leaving us holding the bag.

2. Cover MassDEP’s Costs of Inspection

The MassDEP’s WQC also did not heed our request that while the facilities are operating – under the principle that the responsible party should pay – that FirstLight be required to pay MassDEP an annual fee sufficient to cover MassDEP’s costs of inspection of the facilities and enforcement of any issues that may arise.  An understaffed, publicly-financed agency cannot keep up with all of its oversight functions while only utilizing taxpayer dollars.  Private, for-profit facilities should not be allowed to overwhelm staff who have other duties beyond this oversight.  So make this request to the FERC on the draft Environmental Impact Statement comments.

3.  Local towns rely on lots of tax money from FirstLight

Northfield says

“FirstLight is the largest taxpayer in the Town of Northfield, accounting for 20% of the total assessed real and personal property taxes levied for Fiscal Year 2023. FirstLight MA Hydro LLC…and Northfield Mountain LLC…own a total of 3.5% of the land area of the Town. All corporate FirstLight properties in Northfield have a total assessed value of $132.1 million.”

Montague says

“FirstLight is one of the largest landowners in the Town of Montague and is the largest taxpayer, accounting for 11.9% of the total assessed real and person property taxes for Fiscal Year 2024. …FirstLight MA Hydro owns…2.7% of the land area of the town …[which] gave a total assessed value of $141 million.”

Erving says

“FirstLight is the largest taxpayer in the Town of Erving, accounting for 77.83% of the total assessed real and personal property taxes for Fiscal Year 2024. … Northfield Mountain LLC…and FirstLight Hydro Ma LLC… [own parcels totaling] 19% of the Town…[with] a total assessed value of [over $629.9 million].”

Documents to & from the FERC

Does not include appeals to the FERC on the MassDEP WQC-401 Process.  See Appeals of Water Quality Certificate above.

Documents to and From Massachusetts Department of Energy Resources (DOER)

Energy Storage Study and its potential significance

*ACRONYMS

Current Status

Last updated 09/03/2025

  • 08/28/25 FERC public comment period on draft EIS closed.
  • 08/28/25 MassDEP files with the FERC as an intervenor and lists ways in which draft EIS did not correctly incorporate the state Water Quality Certification.
  • Through 08/28/25 Many people and entities file Comments on the Draft Environmental Impact Statement (DEIS) with the FERC.  A large sample of major commenters is available under Documents to & From the FERC
  • 07/11/25  The FERC granted the extension through 8/28/25, 5:00 pm for comments on the draft EIS.
  • 06/23/25  CT River Conservancy and American Rivers jointly requested an extension through 8/28/25 to comment on (fed) Draft Environmental Impact Statement.
  • 06/02/2025  MassDEP filed a motion to consolidate all five appeals;  FirstLight filed a motion to dismiss Earth Law Partners’ appeal and Karl Meyer’s appeal, both for lack of standing. (No links.)
  • 06/02/2025 FirstLight Confirms 5 Appeals
  • 05/30/2025  The FERC issued the draft Environmental Statement (EIS).  There will be two public comment sessions on July 16, 2025 at GCC, 9am-11am and 6pm-8pm.  Public comments will be accepted through July 29, 2025 (note extension request).  See FERC Notice.
  • May 2025  Various entities have filed appeals on the final Water Quality Certificate (WQC).  See Appeals of Water Quality Certificate section below Current Action.

  • 04/22/2025 MassDEP issues the final  WQC to FirstLight in this “401 process.” 

  • 03/18/25  MassDEP posts all written comments on their website.
  • 02/24/25 Public comment on MassDEP WQC closed.
  • On 01/24/25 DEP updated their website by releasing a  draft Water Quality Certificate (WQC).

  • 10/10/24  DEP Public Information Session video

  • On 06/20/24 MassDEP submitted a consultant’s peer review to the FERC critiquing FirstLight’s erosion studies.  Among its findings were that the study’s assumptions were not demonstrated to be accurate, the choice of where and what to study was insufficient, and the conclusions drawn were not substantiated by the data.

  • On 05/22/24 the period for public comment on the entire FirstLight application to FERC concluded.

  • On 04/22/24 FirstLight submitted its Water Quality Certificate Application to DEP.

  • On 03/22/24 FirstLight submitted lots of additional information in an amended filing to the FERC.  

  • On 02/22/24 FERC issued their Ready for Environmental Analysis (REA).

News & Updates

*ACRONYMS

FirstLight Power Connecticut River interrelated hydroelectric projects* up for relicensing:

  • 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 FERC changed its mind and will no longer issue  a single Environmental Impact Statement for all projects. Nevertheless, we urge you to learn more from Connecticut River Conservancy and Great River Hydro about these related projects.

Advocacy

Resources