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Abbreviations:
- FERC = Federal Energy Regulatory Commission
- WQC = Water Quality Certificate
- MassDEP = Massachusetts Department of Environmental Protection
- FL = FirstLight Power
- NMPS = Northfield Mountain Pumped Storage Station
February 2025 Action Update – Its Happening Now!
FirstLight has filed a WQC with the MassDEP, a FERC requirement for licensure. MassDEP is required to review this application to determine how FL intends to operate NMPS in the future and crucially, whether FL meets the standards of the Federal Clean Water Act. NMPS was given its first 50 year license to operate prior to the passing of the Clean Water Act in 1972. FL’s present application is the first licensing sought for NMPS under the requirements of the Clean Water Act.
Connecticut River Defenders do not believe that NMPS can operate within the mandates of the Clean Water Act. It’s time for MassDEP to hear from us! It is those of us, the people who live here, who experience first hand the impacts to the river by FirstLight. We must inform MassDEP of our strong opposition to FL’s relicensing application and demand that the WQC be DENIED. The Clean Water Act, among other things, requires that the natural flow of waterways not be interfered with. NMPS does not meet this requirement!
SUMMARY OF THE CLEAN WATER ACT
DEP’s website states: “Our mission is to protect and enhance the Commonwealth’s natural resources—air, water, and land, to provide for the health, safety, and welfare of all people, and to ensure a clean and safe environment for future generations” WE must hold our public officials accountable. FirstLight’s impact on the river is in direct violation of the Clean Water Act of 1972. MassDEP activities have been insufficient over the past 50 years in fully evaluating the vital signs of the Connecticut River Ecosystem as the life has literally been sucked out of its waters.
Be There For the River! Wednesday February 19 6:00 pm
GCC, 1 College Drive Greenfield MA
The public has very important opportunities to state their objections to the relicensing of NMPS with written comments until 5:00 p.m. on February 24, 2025 and/or by participating in the MassDEP’s hybrid official public hearing on Wednesday, February 19 6:00 pm at GCC, 1 College Drive Greenfield MA. Registration is required for remote participation: Click here for the Zoom Registration Form.
JOIN US – YOUR ATTENDANCE at this event is critical!
Our river needs people to show up en masse to let them know that we hold DEP accountable as they decide whether to grant or deny a WQC to FirstLight.
Public standout at GCC 5pm 2/19. Bring yourselves and your signs.
WE CAN SPEAK LOUDLY FOR OUR RIVER! Read on for information about how we will make our voices heard at this event. CRD position has been clear; SHUT IT DOWN NOW! RESTORE the RIVER, and LAND BACK.
THE CRITICAL WQC Public Involvement Process Ends at 5pm on February 24
For email comments, mentioned above with all the details, email dep.hydro@mass.gov.
For all the DEP’s 401 WQC FirstLight Hydroelectric Re-Licensing Project information, here’s a link to their website.
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This is the time to tell DEP that the NMPS river desecration must end. The WQC must be denied.
Our Demands:
- The DEP must DENY the WQC.
- The DEP must PUSH FERC to end the annual license extension.
- The DEP must allow NO disrupting the natural downstream flow of the river and its ecology.
- The DEP must allow NO disruption of Native Nations’ lands and Sacred Sites.
- The DEP must uphold all aspects of the Clean Water Act.
- The DEP must protect fish and flows passage.
- The DEP must allow NO death to aquatic life pulled into the deadly turbines including endangered species such as the short nose sturgeon.
- The DEP must allow NO erosion and silt columns.
- The DEP must allow NO oil spills.
Want help submitting comments or speaking? Here are some suggestions we hope will help.
- FirstLight’s Northfield Mountain Pump Storage Station (NMPS) is not clean energy. It essentially plugs into the grid, like any household appliance, manipulating the river using 4 huge reversible turbines that pump the river backward several miles 800 ft to the man- made mountain top reservoir. Using fossil and nuclear fuels it unnaturally pumps enormous amounts of water killing all river life and deeply damaging the ecosystem while causing erosion to the surrounding shore. It sucks up and then releases the water with such force that it alters the flow of the river for miles, eroding the river banks and disturbing the fish and fish eggs. Even if they were to use clean energy in pumping up the river, the damage they are causing makes their impact unsustainable.
- FirstLight uses an open loop pumped storage system which uses a living river as its bottom reservoir, in this case a 20+ mile stretch of the river between Great Falls (Turners Falls) dam and Vernon Dam in Vt. This causes grave environmental harm and death to countless numbers of fish species, fish eggs and aquatic life – estimated to be in the 100 million of fish per year that get entrained in the process with no chance of survival as they are pulled on the deadly journey up and down the mountain. In this time of climate chaos and biodiversity loss, this is not a viable solution . The unnatural dramatic manipulation of the river water levels, through the drag and surge, leads to erosion of the banks, affecting agricultural lands, fish spawning areas and damage to indigenous historic and traditional sites. Silt dragged from the river bottom has effects on water quality diffusing sunlight and oxygenation.
- FirstLight has not been a responsible steward of the land or river and has presented incomplete analysis in reports of the impact of the NMPS on the river. Studies completed by FirstLight skewed results looking only at a single year and choosing and deleting aspects to include and omitting details needed for thorough analysis.
- The adjustments mentioned in the WQC would be experimental. There is no guarantee that these will all be done appropriately nor that they will stop the problems that NMPS is causing. In addition, the time allotted for the changes to occur will result in more damage at a time we cannot afford worsening our already damaged environment.
- FirstLight is owned by one of Canada’s largest pension investment managers, Public Sector Pension Investments (PSP), part of the Treasury Board of the Canadian Government.. It’s concern is profits for its investors, contributors, beneficiaries and CEOs. Profits made by FirstLight from us the ratepayers primarily benefit Canadian financial interests. Purchased in 2016 for $1.2B FirstLight’s recent filing reported $195M revenue in 2019. In 2018 FL registered in Delaware tax shelter, all at the expense of the public good.
- The state must find better less environmentally destructive avenues for meeting energy storage needs. Reduced energy use by all is one way and is necessary if we are to survive these crisis. The destruction of the river is not a just solution to insatiable desire for energy.
- FirstLight claims it is a steward of the land. They own properties in some of the most beautiful areas of New England and beyond. The Ct River is a 4 state system that runs through the heart of the Silvio Conte National Park. In accordance with the Public Trust law, they are obligated to maintain open access to the river and mountain for purposes of recreation and enjoyment for all into posterity. FirstLight and our public officials have failed the public trust as they have allowed disruption and destruction of the river ecosystem affecting fishing, farming, and public enjoyment, creating a dead river. They charge fees and require permits to the public for access and use in many cases. We recognize the indigenous people of this area as the true stewards of the land and wholly commit the land back movement.
- PSP/FirstLight is designated as an Environment Social Governance (ESG) corporation by using false claims that they are suppliers of “clean energy”. As part of this standing they are mandated to engage in community “giving”. FirstLight then uses its economic strength to tout its practices and to garner support in local communities most affected by its operations. In essence using money it takes from the rate payer to then buy their favor.
- Federal, State and local agencies that are charged to protect the river for the public good are instead complicit with FirstLight continuing destruction of the river. The enormous wealth of FirstLight and its greenwashing language have cast a net over our environmental protection agencies as well as the Maura Healey administration including Climate Chief Melissa Hoffer.
- FirstLight violates ab1973 endangered species act with failure to protect the Short-Nosed Sturgeons delicate spawning area in the 2 mile stretch below TF dam and recently found evidence above the dam too.
- FirstLight has been operating in violation of the clean water act of 1972. NMPS was completed in 1968 coupled with Yankee Nuclear power but only began operating in 1972.
- Because the ongoing river desecration is intolerable (turbines grinding up fish and push/pulling the river backwards) the DEP must use its legally valid authority to DENY the WQC. In doing so, also because of the intolerable river desecration, the DEP must also find every way possible, using any possible interpretation of it’s legally valid authority, to push FERC to end automatic annual renewals of NMPS’s operating license. (On May 9, 2018 FERC issued a NOTICE OF AUTHORIZATION FOR CONTINUED PROJECT OPERATION [FERC Accession #: 20180509-3013] which provides annual licenses for NMPS under the terms and conditions of the current license, which is renewed automatically without further order or notice by the Commission[FERC,] until a new license is issued, unless the Commission[FERC] orders otherwise.) These two legally possible actions, in combination, taken within the valid authority we’ve granted the DEP and FERC, can bring a swift end to FirstLight’s currently legally sanctioned, though intolerable NMPS river desecration.
We ask that the DEP stop the issuance of WQC in an effort to deny FirstLIght its ability to continue harming the environment. At the very least, we ask that FirstLIght not be allowed to monitor itself. We do not want the fox guarding the chicken coop.
ONGOING ACTIONS: Things you and I can do NOW to SAVE the Connecticut River from destruction:
#1 Send letters to FERC to let them know you strongly oppose relicensing NMPS. Let them know what a living river means to you. SEND e-comments to FERC, www.ferc.gov. Go to: eFile, then to eComment. Make sure you use the FERC Project number, P-2485, for the Northfield Mountain Pumped Storage Station. Use it exactly as printed. Continue through the FERC registration and make your on-the-record opposition to NMPS clear. (Writing ferconlinesupport@ferc.gov. or calling 866-208-3676 can be helpful with FERC Online issues.)
#2 Write letters to state officials:
- Bonnie Heiple, Commissioner, MassDEP – bonnie.Heiple@mass.gov
- Tim Jones, Acting Director of Division of Wetlands & Waterways, MassDEP – timothy.Jones@mass.gov
- David Hilgeman, Wetlands, Supervisor of the Major Projects and Policy Unit, MassDEP – david.Hilgeman@mass.gov
- Melissa Hoffer, Climate Chief – melissa.Hoffer@mass.gov
- Stephanie Cooper, Undersecretary for the Environment, Office of Energy and Environmental Affairs: stephanie.Cooper3@state.ma.us
- Jesse Leddick, Asst. Director of Natural Heritage and Endangered Species Program, MA Division of Fisheries & Wildlife – jesse.leddick@mass.gov
- Caleb Slater, Chief of Hatcheries, MA Division of Fisheries & Wildlife – caleb.slater@mass.gov
- Paul Jahnige, Director, Massachusetts Office of Outdoor Recreation (formally DCR) – paul.L.Jahnige@mass.gov
- Find the contact information for state senators and representatives here.
Let them know that NMPS is a false solution to our Climate Emergency. It is dirty energy and does not bring us closer to Net Zero by 2050. NMPS sacrifices a river to destroy our futures.