PUTNEY — The owner of three dams in the upper valley is seeking Federal Energy Regulatory Commission (FERC) relicensing. For most, the relicensing of three hydroelectric dams is not exciting news, but quite honestly this is a once-in-a-lifetime opportunity to work for the Connecticut River.
A little history might help in understanding why this is such a remarkable opportunity.
In 1971, Congress passed National Environmental Policy Act (NEPA), pushed by the outcry of the 1969 Santa Barbara, Calif., oil spill and Rachael Carson's 1962 book Silent Spring, which shined a light on the catastrophic impact of chemical pesticides on the environment, particularly on birds.
NEPA initiated quite an important change in the hydropower licensing process. Along with other provisions, the law requires an Environmental Impact Statement whenever the federal government issues a license, spends money on a project, or takes an action on its own. NEPA requires that FERC look at more than just the maximum amount of power produced at a generation facility. FERC must also look at a project's environmental impact.
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The process underway in the Upper Valley involves three dams: Wilder, Bellows Falls, and Vernon. To complicate matters a bit more, two additional hydro facilities in Massachusetts owned by a different company are undergoing relicensing on the same schedule, but that is another story.
The reality is, five facilities undergoing FERC review at the same time affect over 175 miles of river through their reservoirs alone. Flow manipulation at the Northfield Mountain pumped-storage hydroelectric plant affects the river for miles above and below the facility.
The last license issued to all of these facilities was 40 years ago, predating the full implementation of NEPA. When last licensed, these facilities did not need to meet the NEPA-required balance between environmental impacts and power production.
These applications for relicensing, if successful, will lock the power production and environmental impacts in place for the next 40 years. When you think about what happens to a river when there is a dam across it, 40 years is a long time, and this effort to make dam operations better is a big deal with long-lasting results.
The most straightforward way to ensure the natural health of the river is to yank the dams out of the river and be done with it. That option has not been put forward by anyone and is not being talked about in the FERC process. These are important electric power and economic assets to our valley, so the dams will stay.
Yet our knowledge over the past 40 years about rivers and how to achieve healthy river conditions has grown exponentially. This new and more powerful understanding should apply to these facilities.
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In order to think about what should change in the operation of the facilities, you have to understand the condition of the river right now. Once you have a handle on that, you can begin to talk about how to improve things.
Establishing current conditions will put a large flock of consultants to work on the river in 2014 and 2015. Guiding the consultants are study plans. These set out what is to be studied and how the consultants should conduct their fieldwork.
The plans are developed by people with an interest in the facility operations like Connecticut River Watershed Council (CRWC) and state and federal resource agencies, who met with FERC and the applicants for 18 months to discuss what the consultants should look at out there on the river.
So the study plans are not invented out of whole cloth. They are the results of requests from groups like federal and state fish and wildlife agencies, water quality agencies, Native American tribes, historic preservation interests, recreation groups, landowners, and watershed organizations like CRWC, based on the owners' preliminary application for relicensing.
In the preliminary application, the owners presented everything they could to FERC about each of the facilities. We at the CRWC reviewed the applications, thought about missing information necessary to make informed recommendations to FERC, and then made our requests for study plans. Among the five facilities, more than 60 field studies will be conducted between now and December 2015 - hence, the flock of consultants.
Examples of the studies are evaluations of shoreland erosion; modifications of water temperature and dissolved oxygen; models of river flows; dewatered bypass reaches; fish assemblages; fish access to spawning areas; effects of flows on overall aquatic habitat assessment; up- and downstream passage for fish, including the American eel; and effects of the dams on known threatened and endangered species.
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The stakeholders using the field study reports will compare and contrast the report findings with the best science known about the issue. This analysis will become the basis for potential changes in operations of the facilities.
Thanks to NEPA, changes necessary to make the river healthier are now part of the relicensing discussion. The license process offers a chance to talk through FERC with the project owners about potential mitigation of the facilities' impacts on the river.
This long and complex process stretches 5{1/2} years from start to finish. Stay tuned.