LIHI Certificate # 46 --- Ashuelot & Lower Robertson Hydroelectric Projects (FERC #7791 & #8235) on the Ashuelot River, New Hampshire
LIHI Governing Board Certifies the Ashuelot River Hydro Project (FERC Nos. 7791 and 8235) Ashuelot River, Ashuelot and Hinsdale, New Hampshire .
Portland, Maine (November 20, 2009) – At their November Governing Board meeting, the Low Impact Hydropower Institute (LIHI) certified the Ashuelot River Hydro Project, New Hampshire. The Board's decision to certify the three projects was unanimous, and included the addition of non-standard conditions to the Ashuelot River Project. The Board also recognizes that this Project has avoided or reduced their environmental impacts pursuant to the LIHI criteria.
The Lower Robertson and Ashuelot Hydroelectric Projects - are located on the Ashuelot River in Winchester, NH, off Route 119 between the village of Ashuelot and the Town of Hinsdale. The Lower Robertson facility is easily visible from Route 119 and is approximately 1 mile upstream of Ashuelot, which is located at 80 Lost Road, an unmarked road off of Route 119. Both projects have FERC Exemptions that were issued on July 31, 1986. The Lower Robertson Hydroelectric Project, operates under FERC Exemption No. 8235 and Ashuelot River Hydroelectric Project operates under FERC Exemption No. 7791. Both projects are small, low head, run-of-river hydro plants built in the mid 1980's at existing paper company dams. The Applicant purchased the projects in 2007 and has operated them ever since. The run-of-river Lower Robertson Project consists of: an 18-foot-high Dam with a spillway crest elevation 384.6 mean sea level (msl); 1.5-foot-high flashboards; An impoundment with a surface area of 8.6 acres; An intake structure and powerhouse at the north end of the dam with 3 turbine generator units with a total installed capacity of 840 kw; and, a short tailrace.
The run-of-river Ashuelot Hydro Project consists of: an 18-foot-high timber cribbed Dam with a spillway crest elevation of 335.4 mean sea level (msl); 3.5-foot-high flashboards which raised the normal maximum pool elevation to 338.9-feet msl; A small impoundment; An intake structure and powerhouse at the south end of the dam with 3 turbine generator units with a total installed capacity of 870 kW ; and, a 100-foot-long tailrace.
The FERC exemption orders require the Applicant to adhere to conditions originally issued by New Hampshire Fish & Game and U.S. Fish and Wildlife that instantaneous flows of 203 cfs (0.5 cfs/sm) be passed at all times. At the request of a previous project owner, FERC and those agencies approved a stream flow gauging plan by orders dated November 1, 1994 (ASH) and May 16, 1995 (ROB). Under the current ownership, both projects are operated as run-of-river facilities in compliance with the conditions in the FERC exemption orders.
The LIHI Governing Board's decision to certify the project was unanimous and included non-standard conditions requiring that the Applicant provide documentation that the Projects meet New Hampshire surface water quality standards by the end of 2010 and that the Applicant finalizes and formalizes a recreational plan accepted by FERC by the end of February 2010.
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Ashuelot Hydro, Inc., Applies for LIHI Certification for their Ashuelot (FERC # 7791) and Lower Robertson (FERC # 8235) Hydroelectric Projects on the Ashuelot River, New Hampshire
Portland, Maine (June 29, 2009) – The Low Impact Hydropower Institute (LIHI) announced today that Ashuelot Hydro Inc. , ( Applicant) has submitted a consolidated application for certification of their Ashuelot and Lower Robertson Hydroelectric Projects located on the Ashuelot River, in Winchester, New Hampshire.
Project Description - Both projects have FERC Exemptions that were issued on July 31, 1986. The Lower Robertson Hydroelectric Project, operates under FERC Exemption No. 8235 and Ashuelot River Hydroelectric Project operates under FERC Exemption No. 7791. Both projects are small, low head, run-of-river hydro plants built in the mid 1980's at existing paper company dams. The Applicant purchased the projects in 2007 and has operated them ever since.
The run-of-river Lower Robertson Project consists of:
- an 18-foot-high by 125-foot-long Lower Robertson Dam with a spillway crest elevation of 384.6 mean sea level (msl);
- 1.5-foot-high flashboards which raised the normal maximum pool elevation to 386.1-feet msl;
- An impoundment with a surface area of 8.6 acres;
- An intake structure and powerhouse at the north end of the dam with 3 turbine generator units with a total installed capacity of 840 kw; and, a
A short tailrace.
The run-of-river Ashuelot Hydro Project consists of:
- an 18-foot-high by 144.5-foot-long timber cribbed Ashuelot Paper Company Dam with a spillway crest elevation of 335.4 mean sea level (msl);
- 3.5-foot-high flashboards which raised the normal maximum pool elevation to 338.9-feet msl;
- A small impoundment;
- An intake structure and powerhouse at the south end of the dam with 3 turbine generator units with a total installed capacity of 870 kW ; and,
- a 100-foot-long tailrace.
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The FERC exemption orders require the Applicant to adhere to conditions originally issued by New Hampshire Fish & Game and U.S. Fish and Wildlife that instantaneous flows of 203 cfs (0.5 cfs/sm) be passed at all times. At the request of a previous project owner, FERC and those agencies approved a stream flow gauging plan by orders dated November 1, 1994 (ASH) and May 16, 1995 (ROB). Under the current ownership, both projects are operated as run-of-river facilities in compliance with the conditions in the FERC exemption orders.
PUBLIC COMMENT
We encourage public comments on this application. Specifically, we are interested in knowing whether you think these projects meet our LIHI criteria. Review the program and criteria in greater detail and then review the Projects' application. Comments that are directly tied to specific LIHI criteria (flows, water quality, fish passage, etc) will be most helpful, but all comments will be considered.
Comments may be submitted to the Institute by e-mail (preferred) at info@lowimpacthydro.orgwith " Ashuelot River Hydro Project comments" in the subject line; by fax at (206) – 984-3086; or by mail addressed to LIHI, 34 Providence Street, Portland, ME, 04103. Comments must be received at the Institute on or before 5 pm Eastern time on August 30, 2009 to be considered. All comments will be posted to the web site and the applicant will have an opportunity to respond. Any response will also be posted.
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August 31, 2009 - NOTE: LIHI received a comment letter from the Ashuelot River Local Advisory
Committee (ARLAC) and the Connecticut River Watershed Council (CRWC). Both letters can be found by scrolling to the bottom of this page.
September 22, 2009 - Ashuelot River Hydro, Inc. (Applicant) submitted a response to the letter from ARLAC. Through an oversite by LIHI we did not post this response until October 4, 2009. The Public Comment period closed August 30, 2009 and we have not received any other comments on this application. The text of the letter follows:
Ashuelot River Local Advisory Committee
Washington Lempster Marlow Gilsum Sullivan Surry Keene Swanzey Winchester Hinsdale
August 30, 2009
Low Impact Hydropower Institute
34 Providence Street
Portland, ME 04103
RE: Lower Robertson & Ashuelot Hydroelectric Projects
The Ashuelot River Local Advisory Committee (ARLAC) was established in 1994, one year after the Ashuelot River was enrolled into the State Rivers Management and Protection Program. Since then, members, nominated by local municipal officials and appointed by the Commissioner of New Hampshire Department of Environmental Services (NHDES), have been educated in a broad array of issues associated with the River and its watershed. It is the hope of the committee to be a resource that works well between the interests and concerns of the citizens in the watershed and local, state and federal authorities.
ARLAC is familiar with the two hydroelectric projects noted above and have had minimal concerns with the projects over the years. The projects appear to have been running within the parameters established at the time of their FERC exemptions in 1986. Our comments in relation to the LIHI criteria are as follows.
River Flows
With the current ownership being local, it appears the Ashuelot River Hydropower, Inc. (ARH) operation is more closely watched and managed than in the past. During the Oct. 2005 flood, abutters to the Lower Robinson project felt the dam operators were not responsive to the rising water levels resulting in the massive erosion and collapse of the river bank and flooding of the adjacent business. On other occasions downstream of these projects, there had been instances where poor dam management turned the upstream pool of one of the downstream dams into a mud flat. We anticipate that these problems will not be experienced with ARH and that flows will be maintained per USFWS recommendations. Also habitat problems associated with fluctuating pool levels and downstream runs should not be an issue if the facility is truly operated in run-of-the-river mode.
Water quality
ARLAC is in its ninth year of Ashuelot River water quality monitoring. With 64 miles of river to cover, we have not had the opportunity to monitor the pools immediately upstream of the noted projects. We have reviewed the recommendations of NHDES to ARH and believe the required testing will adequately determine the temperatures and oxygen levels of the waters there.
Our monitoring of two sites a couple miles upstream and downstream of the projects does reveal some concern with phosphorus levels at or above the NHDES level of concern of 0.05mg/L. E.coli can run above NH standards after a storm event or in low flow situations. The Ashuelot River also exhibits pH readings below the NH surface water standard of 6.5-8.0. While the river is victim to acid deposition from rainfall, snowmelt, etc. and has limited natural buffering capacity, we are concerned what effect the pools behind the dams would have on phosphorus accumulation and E.coli levels.
Of note is a petroleum contamination site in the bank at the former American Paper Mills site adjacent and downstream of the Ashuelot dam. During the period between 2002 and 2006 a number of petroleum underground storage tanks were permanently closed here. Sheens were noted on the river here especially during periods of low water. Since January of 2002 oil containment and sorbent booms have been utilized to contain the outflow. We understand ARH is not responsible for this contamination, but feel they need to be aware of this situation in the management of the dam.
Fish passage and protection
A significant impact of dams is the alteration of the fish community composition behind the dam to accommodate more stillwater species with a decrease in riverine species, and the inability for fish passage beyond the dam structure. Since these dams have been in place since the mid 1980's, those alterations have already occurred. Restoration efforts for American shad, Atlantic salmon, and blueback herring in the Ashuelot River have been underway since 1995. It has been estimated that an annual run of more than 11,500 shad and 47,000 herring on the Ashuelot River could occur based on the acres of spawning and nursery habitat identified downstream of the Surry Dam by NHF&G.
We understand ARH has agreed to create upstream passage either within 2 years after 750 American shad are passed at Fiske Mill or within 4 years after 150 shad pass Fiske Mill, whichever comes first. ARLAC has concerns that this fails to take into account the presence of resident fish species that also inhabit the river but are unable to pass freely due to the dams, and are being cut off from suitable habitat in the river and its tributaries. If ARH is truly interested in being "low impact" then provisions should be made immediately to accommodate all fish passage and should not wait until only shad or salmon appear.
While downstream passage had been installed at the Lower Robertson dam in the summer of 1999 and at the Ashuelot dam in late 2001, ARLAC has no documentation as to the effectiveness of these installations and asks if ARH could provide some data on this. Also of interest is the level of injury or mortality of fish using the downstream passage or from entrainment or impingement on screens or trash racks that may exist at the dam sites.
Watershed protection
ARLAC commends ARH for their contribution to the important land conservation project in the headwaters of the Ashuelot River watershed. Conservation of these lands is significant for the protection and health of the river.
ARH notesthat a formal buffer zone does not exist at either site due to the proximity of the public road, private property and railroad right-of-way. If any of the property adjacent to the pool at Lower Robertson especially on the southern edge is owned by ARH, we would ask for the planting of trees within the buffer to improve shading of the river as well as help retain the bank here. The NH Comprehensive Shoreland Protection program criteria could be used as a guideline for density. This is one of the banks that was so severely eroded during the Oct. 2005 flood.
Threatened and Endangered species protection
ARH provides documentation from USFWS regarding the lack of presence of threatened or endangered species in the area of the two dams. ARLAC asks that ARH also request a review by the NH Natural Heritage Inventory for any state threatened or endangered species.
Cultural Resource protection
To our knowledge there is no disturbance or destruction of archaeological or historic sites at either of the two dam locations.
Recreation
The run of river between the two noted dams is well known for its recreational use by whitewater enthusiasts who begin their run upstream of the dams at the Ashuelot Covered Bridge and continue downstream to Hinsdale. Portage at the two dams can be difficult and dangerous due to steepness and the rocky nature of the banks.
ARLAC sought the input of paddlers of this stretch of river who suggested improvements that could be made for safer use by the recreational user. Among them was installation of stairs with a railing, possibly constructed with a slide in the middle or to one side to allow canoes to be slid up and down. Also the reinstatement of a portage trail on river left (going downstream) at Ashuelot dam that existed prior to the bank washout in 2005.
We would appreciate better accommodation of recreational uses by the public, e.g. canoeing, kayaking, fishing, and suggest working with groups such as the NH Appalachian Mountain Club Paddlers or the Merrimack Valley Paddlers to create safer access at the two dam sites.
Recommended for removal
To our knowledge there have not been any recommendations for removal of either damby the state or federal governments, though conditional upstream fish passage has been negotiated for these dam sites. Nonetheless, ARLAC is on record as being in favor of free-flowing rivers and would advocate for establishment of upstream passage for all fish species sooner rather than later.
Thank you for the opportunity to comment on this application by Ashuelot River Hydropower, Inc. for Low Impact Hydropower Institute certification at the Lower Robertson and the Ashuelot Dams.
Respectfully submitted,
Barbara Skuly
Chairman
Cc: Ashuelot River Hydropower, Inc.
L. Weit, NHRMPP
August 31, 2009
Fred Ayer
Low Impact Hydropower Institute
34 Providence Street
Portland, ME 04103
Re: LIHI Pending Application --- (FERC #7791 & #8235) Ashuelot and Lower Robertson Hydroelectric Projects on the Ashuelot River, New Hampshire
The Connecticut River Watershed Council, Inc. (CRWC) is a nonprofit membership citizen group that was established in 1952 to advocate for the protection, restoration, and sustainable use of the Connecticut River and its four-state watershed. CRWC's organizational mission is directly impacted by the presence and operation of any hydro facility within the watershed. As examples of our attention to the hydroelectric sites in the watershed CRWC is an intervener in new licenses for the Holyoke Dam (Project No. 2004), Canaan Dam (Project No. 7528) and Fifteen Mile Falls Dams (Project No. 2077), and for license amendments at Vernon Dam (Project No. 1904) and Northfield Mountain Pumped Storage project (P-2485).
From the CRWC perspective and despite the fact that the USF&W set the target fish passage numbers for American shad at the Fiske Mill dam, the dam downstream of the two dams under consideration for LIHI certification, it seems at odds with good river management that these dams would be issued low impact certification from LIHI based on a condition for passage of 750 shad at the Fiske Dam before Ashuelot and Robertson must install upstream fish passage. That is not low impact in the opinion of the Watershed Council. What anadromous fish face getting up river to the Ashuelot River are the ENVY thermal discharge plume and the poorly designed passage facilities at the Turners Falls Dam. Unfortunately shad are stopped in their upstream migration in the Turners Falls reach of the river before they even get to the Ashuelot River. In addition I have to wonder about how a 750 trigger number was established in a small tributary to the main river when the main river dams now are required to provide downstream passage, period and installing upstream passage would be triggered by as few as 20 salmon over Wilder dam all the way up through the Fifteen Mile Falls dam complex.
Fish passage into tributaries is NOT a matter solely of passing anadromous fish. Resident species use our rivers to spawn including any trout that remain in the main river, small mouth bass and rock bass. They do not find good spawning habitat in the main river and there is an upstream migration every year of these species into the tributaries. So the Ashuelot dams do more damage than just stop shad in their migration. Passage would help mitigate this impact.
Given the reality of the conditions in the main river, the return numbers that would trigger fish passage are artificially high. Unfortunately the resource agencies have not set standards for passage of our resident fish although NH is thinking about the whole issue of resident fish passage because of the Vermont 401 Certification requirement for potential up and down stream resident fish passage at Canaan Dam but that discussion is taking place way up where NH meets Canada and VT.
CRWC does not feel that relying on a high number of American shad returns at Fiske dam is a rational to certify Lower Robertson and Ashuelot dams as low impact relative to fisheries. It would be a show of good faith to the health of the Ashuelot River if the project owner would underwrite the cost of studies to be conducted by NH F&G to evaluate the effects of these two dams on resident species. Once those impacts are understood and addressed LIHI certification would make more sense in terms of protecting the health of the Ashuelot River.
Sincerely
David L. Deen
Cc Ashuelot River Hydropower, Inc.
Laura Weit NHRMPP
Barbara Skully Ashuelot LRAC
USF&W Service
Connecticut River Watershed Council
David L. Deen River Steward
PO Box 206
Saxtons River, VT 05154
802-869-2792
FAX 802-869-1103
ddeen@ctriver.org
http://www.ctriver.org
Ashuelot River Hydro, Inc.
42 Hurricane Road
Keene, NH 03431
(603) 352-3444
September 22, 2009
Ashuelot River Local Advisory Committee
c/o Barbara Skuly, Chairman
19 Spring St.
Swanzey, NH 03446
RE: Response to your comments re LIHI Certification
Dear Barbara:
Thank you for the opportunity to meet with you and the Committee last Tuesday to discuss our application for LIHI certification of our Ashuelot and Lower Robertson hydroelectric projects. At that time, we discussed several issues raised in your insightful letter of August 30, 2009. This letter follows up on that discussion and responds to points raised in your letter.
River Flows
We believe as you do that local ownership will improve responsiveness to issues of all kinds at both plants. We do operate both plants run of river. In order to improve reliability of this operation, we have upgraded the automatic control system at Ashuelot. Lower Robertson will be upgraded this winter.
Water quality
We are half way through the phosphorous and chlorophyll monitoring required by NHDES. The five samples collected thus far show average phosphorous of 0.025 mg/L, or half NHDES's level of concern. Average chlorophyll is 0.0015 mg/L, which is an order of magnitude less than NHDES's level of concern. In consultation with Ted Walsh at NHDES, because of the cooler water temperatures at this time, we have agreed to take the final five water samples next summer. Ted also said that it would be fine to run the dissolved oxygen sampling (two weeks continuous at four sampling sites) next summer since this summer the flows never fell below his designated 147 cfs. Because of the significant rapids above and below both projects, we do not anticipate any problems with dissolved oxygen, but we will perform the testing as required next summer.
Fish passage and protection
We are committed to installing fish passage according to the USF&W triggers, at the latest. We have already put aside funds for fish passage construction, and we will be adding to this reserve account as time goes on. We are certainly not in theory opposed to installing fish passage prior to the triggers being met. However, installation will be expensive, and thus we are open to alternative funding sources (to match our own funds) if we are to install passage prior to USF&W triggers.
Watershed protection
Thank you for your commendation regarding our contributions to land conservation in the watershed. We see many reasons to conserve land and biodiversity everywhere. Locally, however, I am reminded of the story of the Weeks Act of 1911, which formed the national forest system, starting with the White Mountain National Forest. After languishing for years, the legislation was finally pushed through when the politically connected mill owners of Manchester, Lowell and Lawrence realized the impact of clear cutting and erosion in the headwaters of the Merrimack River on their hydro power operations!
Regarding tree planting on the edges of the Lower Robertson pond, I showed you our property bound demonstrating that we do not own real property in that vicinity (rather we own flowage rights). Also, at other hydro projects we own, inspectors from the Federal Energy Regulatory Commission are continually asking us to remove trees from the banks for dike and dam safety reasons. I am in constant battle with them in my desire to retain existing trees for ecological and aesthetic reasons. They would not take kindly to a tree planting program close to a dam or embankment.
Threatened and Endangered species protection
As you requested, we looked at the NH Natural Heritage Inventory data base (using the buffered data) and found no instances of any state threatened or endangered species within the project bounds or impoundments.
Recreation
We are paddlers ourselves and have no objections to portages taking place at our dams as long as the paddlers respect the property and take proper care. I would be happy to speak with representatives upon receipt of a contact name and number. We were not aware of an old portage route on the left bank at Ashuelot, but we are willing to work with the paddlers to restore that path if it can be done safely and practically. We note that slope was completely rebuilt with heavy rip rap by Algonquin after the flood of 2005, so it may be challenging to cut a terraced trail, but we will do what we can to accommodate paddlers.
Again, thank you for your thoughtful consideration and input to this process.
Bob King, President
Cc: Fred Ayer, LIHI