TOWNSHEND — If a proposed Windham County project to create hydroelectric operations on two existing federal flood control dams gains final approval from the Federal Energy Regulatory Commission (FERC), hydroelectric power development in southern Vermont may see a resurgence.
After several years of meeting interim requirements, Plainfield-based Blue Heron Hydro LLC is now applying for its final federal license to install turbines at two dams – one in Townshend, and one on the West River at Bald Mountain in Jamaica.
Blue Heron's plan would generate about three megawatts of electricity, or enough to power about 3,000 average Vermont homes.
While Blue Heron's application and permitting procedures have been active for more than three years, the outcome is by no means certain. The New England District of the U.S. Army Corps of Engineers, which has jurisdiction over the flood control dams, has identified critical problem areas at Ball Mountain Dam.
Ball Mountain Dam has significant foundation seepage issues and is in need of repairs for continued operation, the Corps said in a recent assessment report.
“The Corps is currently analyzing the data gathered from the subsurface investigation program in order to decide on the most efficient long-term repair,” the report says. “Any proposed repair will increase the reliability of the dam. A Dam Safety Modification Study, including a full engineering-design analysis, is currently in progress.”
The Corps categorizes dams for safety issues using the Dam Safety Action Class (DSAC). The lowest DSAC number identifies the most endangered dam. Ball Mountain is classified as having a DSAC II rating.
However, Blue Heron CEO and project leader Lori Barg believes an upgrade is distinctly possible.
“Hopefully, the studies will show that the dam can be reclassified as DSAC III or IV,” she said. “In any case, we have not proposed to do any construction on or around the dam embankment itself, which is the structure that has a small amount of leakage, but only at the upstream side of the tower. The dam embankment is actually outside the project limits. We also feel that development of the project will have a net benefit to any dam safety issues, due to such things as better debris management and closer management of water levels.”
Counting on the upgrade, Blue Heron is asking for an expedited review in order to take advantage of federal and state incentives that require actual development to begin before the end of the year.
The Townshend Dam Hydroelectric project, using the existing dam and reservoir, would consist of two turbine generators placed in the existing intake tower and connected to six submersible generators, for a total capacity of 925 kilowatts.
The larger Ball Mountain project would also use the existing dam and reservoir in somewhat the same configuration, but with appropriate adaptations and a capacity of 2,200 kilowatts.
The estimated cost for both installations combined is about $10 million.
Brian Keefe, vice president for government and public affairs with Central Vermont Public Service (CVPS), has written in support of the project. Last year, CVPS awarded Blue Heron a $30,000 grant to help with early-stage planning and permitting.
Blue Heron also secured $50,000 in feasibility study grants from Vermont's Clean Energy Development Fund, about half of that from federal economic stimulus money.
And recently, the state Agency of Natural Resources gave its approval, with conditions, for Blue Heron's compliance with water-quality standards.
Brian Fitzgerald, Agency of Natural Resources streamflow protection coordinator, explained why the regulatory framework for this sort of project is so strenuous.
“We're dealing with a public trust resource,” he said. “In Vermont, public waters are held in trust for everyone. FERC licenses last for 30 or 50 years.”
Who's in charge?
At public meetings on the proposal held last week in Brattleboro, David Deen, river steward for the Connecticut River Watershed Council and a state legislator, wanted to know what would happen if one of these projects went bad. Deen wanted to know who took care of potential problems, and whether the state would suddenly have lots of dead projects up and down its rivers.
Fitzgerald said that was a reasonable question. He also noted that, for him, the chain of command was unclear. Who operates the turbines and the flow in times of trouble?
According to the FERC, the Townshend Dam is operated by the Corps, in coordination with the Ball Mountain Dam, to provide flood protection for downstream communities within the West River Valley, and is operated as part of a system of 14 dams.
These two West River dams, part of a series of seven Corps-operated dams in the Upper Connecticut River Basin (in Vermont and New Hampshire), were built between 1958 and 1961 at a cost of just under $18 million. They are part of a network of flood-control projects in the Connecticut River Basin, monitored by the Reservoir Control Center in Concord, Mass., which oversees the 32 flood-control dams in the New England District.
The Townshend site, including the dam and associated land, consists of 1,010 acres and is 1,700 feet long and 133 feet high; the Ball Mountain site, including the dam and associated lands, is composed of 1,227 acres. The dam is 915 feet long and 265 feet high.
Apart from flood control, the Townshend and Jamaica dams provide lake and river recreation sites, and rafting and kayaking during whitewater releases (usually two a year). They also make possible hiking trails and other Corps-related camping and nature programs.
More recently, fish and wildlife management has become a significant undertaking for the Corps, and includes elaborate systems and facilities for the restoration of Atlantic salmon.
In the early 1990s, fish passageways were constructed at both dams ,and can involve the transportation in a tank of just one salmon traveling upstream around the dam and back into the West River, for an unimpeded journey toward the ocean.
Difficult process
All of these river-related concerns bear upon the final licensing of the Blue Heron project.
Barg, who founded Community Hydro in Plainfield less than 10 years ago, also formed Blue Heron. She is a geologist with a special interest in hydrology and is the CEO of both companies.
Barg and a host of supporters point to the low environmental impact of small hydroelectric projects such as hers. Other supporters have commented on her project's efficient use of an existing resource.
Blue Heron, in accordance with federal regulations, filed an application to do a feasibility study of Ball Mountain as a hydroelectric site in July 2008. It followed that request, in February 2009, with the Townshend Dam application. Since that time, Barg and her colleagues have been negotiating the permitting process, with both successes and setbacks.
The FERC recently conducted site visits, which drew a handful of citizens not involved with the project. The meetings attracted only two people who were not associated with either the developer or the government. By contrast, when meetings in connection with the Ball Mountain dam were held in Jamaica Town Hall some time ago, a large crowd attended.
The Townshend Selectboard recently gave its endorsement to the project, as did the Selectboard in Jamaica.
Even though the study and permitting phases of the project have gone on for more than three years, and either directly or tangentially required the approval of, or communication with, nearly 50 interested entities, the outcome remains uncertain.
At one point in a recent FERC meeting, after she had finished her presentation, Borg said to no one in particular, “If I had known all this before, I might not have done it.”
While the FERC and other agencies still have very specific hurdles for Barg to overcome, her colleague, Tom Willard, a consulting engineer at Blue Heron who attended the meetings, said he thought it sounded worse than it was.
He said that frequently, when you have multiple agencies asking questions, it turns out that, while worded differently, many of the questions are really asking the same thing. As a result, answering them is not as hard as it looks.
But he did point out some uncertainties - including water quality, fish species interruption for salmon and other invertebrates, and the amount of dissolved oxygen in the water, which varies when the stream is diverted instead of going over the dam, where the water picks up oxygen.
The biggest objection came from the analysis of Bruce Williams, environmental manager for the New England District of the Corps of Engineers.
The Corps is listed as a “cooperating agency” with the FERC. It helps to streamline regulatory requirements by, among other things, holding joint meetings with the FERC.
“It's going to be close,” Williams said, citing damage at the Ball Mountain Dam that is the source of leaking and seepage.
He explained that regulations require that federal approval, including design impact, must be granted before any civil structure is repaired. He said that a request has been submitted and the Corps is waiting for approval to begin working on the dam.
“Even if FERC gives them (Blue Heron) a license, we have veto power,” Williams said.
“I see Townshend as doable,” he said. “Give us the design, a construction plan, and meet our comfort level, and the Corps can be convinced.”
“Ball Mountain,” he continued, “has been ranked by the Corps as unsafe” - not for the public, he emphasized, but for the kind of work the Blue Heron project would require.
“How much water can the dam safely store?” he asked.
He added that the repairs now required at Ball Mountain are expensive and take time.
“These two proposals are stand-alone projects. If I was a business person, I'd wait until all these details (are worked out) before I invested any money,” he concluded.
Willard thinks Williams' analysis is too dire.
Borg concurs, and points out that people at the highest levels of the Corps, including JoEllen Darcy and District Commander Tom Feir of the New England District, support hydroelectric development at existing dams.
In March, the Department of Energy and the Department of the Interior, working with the Corps, created a so-called Memorandum of Understanding, supporting the development of environmentally sustainable hydroelectric power. By signing the memorandum, the three federal agencies agreed to focus on increasing energy generation at federally owned facilities.
Until the 1940s, hydroelectric power accounted for most of Vermont's electricity generation. As Vermont's population grew, coal and natural gas entered the mix. Today, according to the U.S. Department of Energy, nuclear energy is the dominant source of electric power in Vermont and nationwide, while Vermont's 78 hydroelectric facilities meet about 10 percent of the state's electric needs.