Northfield Mountain Pumped Storage Project

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Stakeholder COMMENTS to FERC on Northfield Up-rate Request

Posted by on 10 Oct 2014 | Tagged as: Connecticut River ecosystem, Federal Energy Regulatory Commission, FERC, GDF-Suez FirstLight, ISO New England, Northfield Mountain Pumped Storage Project

*The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on October 2, 2014.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 October 2, 2014

The Honorable Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, NE
Washington, DC 20426

COMMENTS: on P- 2485-065, GDF-Suez FirstLight Hydro Generating Company’s:
Application for Temporary Amendment of Minimum and Maximum Reservoir
Elevation Requirement.

Dear Secretary Bose,

The Northfield Mountain Pumped Storage Project is currently undergoing
studies under the 5-year FERC relicensing process in order to continue
plant operations beyond 2018. NMPS was built as a peaking power plant—
making use of the surplus power generated from a cluster of Western New
England nuclear power facilities: Yankee Atomic, Vermont Yankee, and
Haddam Neck. Yankee Atomic and Haddam have long-since ceased operation,
and VY will close on December 29, 2014.

After that date, NMPS is requesting to remain in service as an entirely
different entity: a peaking plant, with no surplus regional nuclear power
to draw on. It will then be relying on coal, oil, gas, and imported
hydro to pump water uphill—a very expensive and inefficient process,
consuming what amounts to baseload energy to create peaking generation.
This will be bought on the open market; then resold to ratepayers at
peaking-market prices. The first question that must be asked is: is it
fair to consumers?

Why should such an open-ended power up-rate be allowed when stakeholders
are deep in the discovery phase of the relicensing process? Studies just
months down the road will help determine the current operational,
commercial and environmental impacts of NMPS.

This open-ended request uses NMPS’s “emergency” capabilities as a veil.
In truth, as ISO-NE well knows, it can—and does, take over NMPS on rare
emergency occasions, paying market rates to GDF-Suez for the plant’s
output. Thus, hiding behind an “emergency” goodwill intention is not a
forthright argument from FirstLight, and should not be accepted rationale
for granting NMPS an open-ended and, unstudied, 20-plus percent power
generation capability increase.

Looked at head-on, this is an attempt to turn a plant into a facility
that would now generate using legacy fuels to supply ratepayers with
peaking-priced, spot-marketed power in a quasi-baseload producer fashion.
If FERC were to allow such an increase for a full one-third of a year, it
would be creating a whole new animal in the energy market—without a
requisite public process.

FirstLight’s argument in its generation and storage capacity increase is
that it will be available for “emergency” situations which might arise in
winter markets. The reality is—request aside, NMPS is and has always
been a station prescribed for emergency use. That has been a chief
selling point since it opened 1972. And, it is still available as such—
without any amendments to its current license. Thus, no changes should
be made to current operational limits, as the plant can be called upon
under unusual-event circumstances by ISO within all currently sanctioned
parameters.

Allowing NMPS to begin generating as a baseload plant
without study or understanding of the full impacts of longer pumping and
generation would be an abrogation of FERC’s public responsibilities.
Under current operating conditions, NMPS creates what amount to erosive
tidal conditions in the Turners Falls Impoundment that exceed the daily
tides experienced at Hyannisport, MA. The requested new pumping and
expanded limits at NMPS during winter months will undoubtedly result in
an increase in erosion and sediment load in the river and at the NMPS
reservoir. Daily increases in freezing and thawing along sensitive
riverbanks dictate that.

In 2010 FirstLight attempted to clear its reservoir of sediment and failed
to accomplish the task. The result was a complete outage lasting seven months,
with NMPS unavailable for any emergency output. Most troubling was that
FL attempted to clear its reservoir and intakes by shoveling the silt and muck
directly into the Connecticut River. The EPA issued a cease and desist order in early
August, and FL was found to be in gross violation of the federal Clean
Water Act for polluting the navigable waters of the United States.

It should also be helpful to know that NMPS has never successfully
discharged the silt from its reservoir in its entire history without
experiencing a partial or full outage in its turbine battery. Given that
history, allowing NMPS to potentially create more siltation in the CT
River at their plant should not be allowed until they have proven it will
not impact emergency operations.

Further, attempts by a previous owner to utilize more of the NMPS
reservoir in the 1980s were turned back by a public process that
shed light on the fact that increased pumping of the Connecticut River
would result in significant impacts to the ecosystem. That request—to use
the Connecticut River as a drinking water source to be shifted up to the
NMPS reservoir and then transferred out of basin tothe Quabbin Reservoir,
was ultimately not implemented. In fact, it resulted in the implementation of
a new law, the Inter-Basin Transfer Act, which would only allow water to be
taken from the river in an emergency situation, after all logical engineering
steps were taken to plug holes and eliminate waste in the Boston water delivery
system.

That should be the situation going forward. NMPS remains in service as
currently licensed—available for use in specifically defined emergency
situations by ISO-NE, until studies are complete.

Lastly, is important to note that GDF-Suez FirstLight made no mention of
the closure of their own 135 megawatt Mt. Tom coal plant in Holyoke this
20141002-5022 FERC PDF (Unofficial) 10/2/2014 8:40:09 AM
fall, when they listed several outlier plant closures as reason for their
request to help as fill -in for a tight winter market. At the very least
that is disingenuous. Some might see it as market manipulation.

Thank you,
Karl Meyer, MS

FERC Notice of Northfield Mountain expansion request, and Public Comment period

Posted by on 05 Sep 2014 | Tagged as: Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Motion to Intervene, Northfield Mountain, Northfield Mountain Pumped Storage Project, Public Comment period

On September 4, 2014, the Federal Energy Regulatory Commission issued the following Notice of Application for FirstLight Hydro Generating Company’s request to expand operations at the Northfield Mountain Pumped Storage Project, P-2485-065. Public COMMENTS, MOTIONS TO INTERVENE, and PROTEST filings will be accepted by FERC for 30 Days from their September 4, 2014 Notice.

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

FirstLight Hydro Generating Company Project No. 2485-065

NOTICE OF APPLICATION ACCEPTED FOR FILING, SOLICITING COMMENTS, MOTIONS TO INTERVENE, AND PROTESTS

(September 4, 2014)

Take notice that the following hydroelectric application has been filed with the Commission and is available for public inspection:

a. Type of Application: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement

b. Project No.: 2485-065

c. Date Filed: August 8, 2014

d. Applicant: FirstLight Hydro Generating Company (Firstlight)

e. Name of Project: Northfield Mountain Pumped Storage Project

f. Location: The project is located on the east side of the Connecticut River, in the towns of Northfield and Erving, in Franklin County, Massachusetts.

g. Filed Pursuant to: Federal Power Act, 16 USC 791(a)-825(r).

h. Applicant Contact: Mr. John Howard, Director of FERC Compliance, FirstLight Hydro Generating Company, 99 Millers Falls Road, Northfield, MA 01360. Phone (413) 659-4489.

i. FERC Contact: Mr. Christopher Chaney, (202) 502-6778, or christopher.chaney@ferc.gov.

j. Deadline for filing comments, motions to intervene, protests, and recommendations is 30 days from the issuance date of this notice by the Commission. The Commission strongly encourages electronic filing. Please file motions to intervene, protests, comments, or recommendations using the Commission’s eFiling system at http://www.ferc.gov/docs-filing/efiling.asp. Commenters can submit brief comments up to 6,000 characters, without prior registration, using the eComment system at http://www.ferc.gov/docs-filing/ecomment.asp. You must include your name and contact information at the end of your comments. For assistance, please contact FERC Online Support at FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). In lieu of electronic filing, please send a paper copy to: Secretary, Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426. Please include the project number (P-2485-065) on any comments, motions to intervene, protests, or recommendations filed.
k. Description of Request: FirstLight is seeking temporary authorization to modify the upper reservoir’s upper and lower water surface elevation limits from 1000.5 and 938 feet, to 1004.5 and 920 feet, respectively. FirstLight proposes to use the additional storage capacity between December 1, 2014, and March 31, 2014. According to FirstLight approval of changes in the water surface elevations would result in an increase in the maximum daily generation from 8,475 megawatt-hours (MWh) to 10,645 MWh.

l. Locations of the Application: A copy of the application is available for inspection and reproduction at the Commission’s Public Reference Room, located at 888 First Street, NE, Room 2A, Washington, DC 20426, or by calling (202) 502-8371. This filing may also be viewed on the Commission’s website at http://www.ferc.gov/docs-filing/elibrary.asp. Enter the docket number excluding the last three digits in the docket number field to access the document (i.e. P-2485). You may also register online at http://www.ferc.gov/docs-filing/esubscription.asp to be notified via email of new filings and issuances related to this or other pending projects. For assistance, call 1-866-208- 3676 or e-mail FERCOnlineSupport@ferc.gov, for TTY, call (202) 502-8659. A copy is also available for inspection and reproduction at the address in item (h) above.

m. Individuals desiring to be included on the Commission’s mailing list should so indicate by writing to the Secretary of the Commission.

n. Comments, Protests, or Motions to Intervene: Anyone may submit comments, a protest, or a motion to intervene in accordance with the requirements of Rules of Practice and Procedure, 18 CFR 385.210, .211, .214. In determining the appropriate action to take, the Commission will consider all protests or other comments filed, but only those who file a motion to intervene in accordance with the Commission’s Rules may become a party to the proceeding. Any comments, protests, or motions to intervene must be received on or before the specified comment date for the particular application.

o. Filing and Service of Responsive Documents: Any filing must (1) bear in all capital letters the title “COMMENTS”, “PROTEST”, or “MOTION TO INTERVENE” as applicable; (2) set forth in the heading the name of the applicant and the project number of the application to which the filing responds; (3) furnish the name, address, and telephone number of the person protesting or intervening; and (4) otherwise comply with the requirements of 18 CFR 385.2001 through 385.2005. All comments, motions to intervene, or protests must set forth their evidentiary basis and otherwise comply with the requirements of 18 CFR 4.34(b). All comments, motions to intervene, or protests should relate to project works which are the subject of the license surrender. Agencies may obtain copies of the application directly from the applicant. A copy of any protest or motion to intervene must be served upon each representative of the applicant specified in the particular application. If an intervener files comments or documents with the Commission relating to the merits of an issue that may affect the responsibilities of a particular resource agency, they must also serve a copy of the document on that resource agency. A copy of all other filings in reference to this application must be accompanied by proof of service on all persons listed in the service list prepared by the Commission in this proceeding, in accordance with 18 CFR 4.34(b) and 385.2010.

Kimberly D. Bose,
Secretary.

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