LIHI Certifies the Gardners Falls Project in Massachusetts
Portland, Maine (October 31,2011) - At their October 27, 2011 meeting the Institute’s Governing Board determined that the Gardner Falls Hydroelectric Project met the LIHI Certification Criteria. In reaching its decision to certify the Gardner Falls Hydroelectric Project, the LIHI’s Governing Board reviewed the application for certification, as well as the Application Reviewer’s report. The Board’s vote to certify the Gardner Falls Hydroelectric Project was unanimous, and the Board approves certification for the Gardner Falls Hydroelectric Project for five-years.
The effective certification date for the Gardner Falls Hydroelectric Project is February 18, 2011 and will expire on February 18, 2015. Any Commenter may submit a letter to the Certification Administrator requesting an appeal within 30 days of the posting of the Certification Decision on the Institute’s Web page. An appeal request must include specific reasons why the hydropower facility should have failed one or more criteria. If an individual or organization did not comment on the initial Application Package, they may not file an appeal.
Portland, Maine (May 11, 2011) – LIHI received the Applicant's response to comments (via email) The NORTH AMERICAN ENERGY ALLIANCE, LLC letter can be found at the very bottom of this page.
Portland, Maine (April 28, 2011) – LIHI received comments (via email) by Robert May for the Deerfield River Watershed Association today at 1:15PM. The one page letter can be found at the bottom of this page.
Portland, Maine (April 25, 2011) – The Low Impact Hydropower Institute received the Applicant's response to the following comment letters: one each was from the Massachusetts Department of Fish and Game (the “MDFG”), dated April 5, 2011, Massachusetts Department of Environmental Protection (“MDEP”), dated April 19, 2011 and the Connecticut River Watershed Council (“CRWC”), April 18, 201. Two letters were received from the Massachusetts Historical Commission (“MHC”). One letter, dated March 21, 2011, expressed its concern that NAEA not conduct any new construction, demolition or other project modification to its Gardners Fall Hydroelectric Project in conjunction with its LIHI application. In its second letter, dated April 13, 2011, after being given written assurances from NAEA that no new construction, demolition or other project modification would occur to the Project as a result of its LIHI application, MHC has no opinion and would take no action on the LIHI request of NAEA. An e-mail was received from the Massachusetts Department of Conservation and Recreation (“MDCR”) on March 12, 2011 and stated that the MDCR does not have any issues pertaining to recreational use with the Gardners Falls Project with its respect to its certification by LIHI. A copy of this letter in red appears at the bottom of this page.
Portland, Maine (April 19, 2011) – The Low Impact Hydropower Institute received a comment letter from the Massachusetts DEP. A copy of this letter in Black appears at the bottom of this page.
Portland, Maine (April 6, 2011) – The Low Impact Hydropower Institute received a comment letter from the Massachusetts Division of Fisheries and Wildlife. A copy of this letter in red appears at the bottom of this page.
Portland, Maine (March 25, 2011) – The Low Impact Hydropower Institute received a comment letter (email) from the Massachusetts Historical Commission. A copy of this note in red appears at the bottom of this page.
Portland, Maine (March 12, 2011) – The Low Impact Hydropower Institute received a comment letter (email) from the Massachusetts Department of Consevation and Recreation. A copy of this note in red appears at the bottom of this page.
Portland, Maine (February 18, 2011) – The Low Impact Hydropower Institute (LIHI) announced today that the North American Energy Alliance, LLC (“Applicant”) has submitted an application for certification of the Gardner Falls Hydroelectric Project (“Project”).
The Gardners Falls project, licensed by the Federal Energy Regulatory Commission (“FERC”) as Project No. 2234, is owned by North American Energy Alliance, LLC (“NAEA”).
The project is located in the Towns of Buckland and Shelburne in Franklin County, Massachusetts, at approximate river mile 15.8 on the Deerfield River. The Project was originally constructed in 1904. The original project included two hydro-electric turbines. The powerhouse was expanded in 1914 with the installation of two more turbines, followed by a final expansion in 1924 with the addition of a fifth turbine. One of the original turbines (“Unit 1”) was retired in 1971. The Unit 1 penstock was plugged and filled in when the unit was removed from service. Currently, the Project is semi-automated and contains four active units.
The major project works consist of a dam and impoundment, a power canal, an intake structure and a powerhouse. Specifically, the Project consists of: (1) a concrete gravity dam, 337 feet long with a maximum height of 30 feet at permanent crest elevation 332.79 feet mean sea level (msl) and flashboard elevation 334.79 feet msl, (2) an impoundment 3,200 feet long, with a surface area of 21 acres, 190 acre-feet gross storage and 37.2 acre-feet usable storage, (3) a brick and concrete powerhouse equipped with four turbine-generator units with total capacity 3.58 MW, (4) a 1,300-foot power canal 31 feet wide and 15 feet deep, and (5) a double circuit 13.8 KV transmission line connecting the Gardners Falls project to the Montague substation.
The Gardners Falls project is situated among nine other hydroelectric facilities located on the Deerfield River. All of the other nine facilities are owned and operated by an affiliate of TransCanada Corporation, and eight are licensed as one project (“Deerfield River Project,” FERC No. 2323). The Deerfield River Project consists of one storage facility (Somerset Development) and seven hydroelectric facilities (Searsburg, Harriman, and Sherman Developments, and the Deerfield No. 5, No. 4, No. 3 and No. 2 Developments). A pumped-storage project (Bear Swamp Project), owned by Bear Swamp Power Company, LLC and operated by Brookfield Renewable Power, is licensed by the FERC as Project No. 2669 and is located below the Deerfield No. 5 development. The Deerfield River Project (FERC No. 2323) also underwent FERC relicensing at the same time as the Gardner Falls project.
While the Project operates as a limited pond-and-release mode, several of the upstream hydroelectric facilities on the Deerfield River are operated primarily during the daily peak demand periods. Flows into the Gardners Falls project, which is located between Deerfield Developments 3 and 2, are dependent upon flow releases from TransCanada’s upstream projects. The Gardners Falls project is operated in a limited pond-and-release mode, utilizing the small storage capacity (37.2 acre-feet) afforded by a maximum 1.8–foot drawdown to accommodate the flows caused by the upstream peaking operations.
The operating mode of the Gardner Falls project does not change during dry, mean or high water years. As flows vary at the Project, the number of turbines operating and the duration of operation changes, increasing and decreasing the amount of annual generation realized.
Public Comment - We encourage public comments on this application. Specifically, we are interested in knowing whether you think this project meets our LIHI criteria. Review the program and criteria in greater detail and then review the Project’s 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.org with " Gardners Falls Hydropower 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 April 18, 2011 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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From: Trail, Mohawk (DCR) <Mohawk.Trail@state.ma.us>
Subject: Gardner Falls Project LIHI Cert. Application
Date: March 12, 2011 3:21:45 PM EST
April 5, 2011
RE: The Gardners Falls Hydroelectric Project FERC No. P-2234
Dear Mr. Ayer:
The Department of Fish and Game (“DFG”) hereby submits the following comments on the Low Impact Hydropower Institute’s (“LIHI”) Pending Application for the proposed LIHI certification of North American Energy Alliance, LLC’s (“NAEA”) Gardners Falls Hydroelectric project, located on the Deerfield River, in the Towns of Buckland and Shelburne, in Franklin County Massachusetts.
DFG is submitting these comments to LIHI in order to fulfill the requirements of the Massachusetts Department of Energy Resources (“DOER”) Renewable Energy Portfolio Standard Regulations (225 CMR 14.00; “RPS I” and 225 CMR 15.00; “RPS II”). The RPS I and RPS II regulations were promulgated by DOER on January 1, 2009 and require that any hydroelectric project wishing to qualify as either a RPS I or RPS II generator first obtain LIHI certification. These regulations also require all relevant regulatory agencies to comment on the pending LIHI application.
The Department does not support NAEA’s application for LIHI Certification of the Gardners Falls Hydroelectric Project for the reasons outlined below.
PROJECT
Project consists of: (1) a concrete gravity dam, 337 feet long with a maximum height of 30 feet at permanent crest elevation 332.79 feet mean sea level (msl) and flashboard elevation 334.79 feet msl, (2) an impoundment 3,200 feet long, with a surface area of 21 acres, 190 acre-feet gross storage and 37.2 acre-feet usable storage, (3) a brick and concrete powerhouse equipped with four turbine-generator units with total capacity 3.58 MW, (4) a 1,300-foot power canal 31 feet wide and 15 feet deep, and (5) a double circuit 13.8 KV transmission line connecting the Gardner Falls project to the Montague substation. The Gardners Falls project is situated among nine other hydroelectric facilities located on the Deerfield River. All of the other nine facilities are owned and operated by an affiliate of TransCanada Corporation, and eight are licensed as one project (“Deerfield River Project,” FERC No. 2323). The Deerfield River Project consists of one storage facility (Somerset Development) and seven hydroelectric facilities (Searsburg, Harriman, and Sherman Developments, and the Deerfield No. 5, No. 4, No. 3 and No. 2 Developments). A pumped-storage project (Bear Swamp Project), owned by Bear Swamp Power Company, LLC and operated by Brookfield Renewable Power, is licensed by the FERC as Project No. 2669 and is located below the Deerfield No. 5 development. The Deerfield River Project (FERC No. 2323) also underwent FERC relicensing at the same time as the Gardners Falls project.
FISH AND WILDLIFE RESOURCES
The Deerfield River System in MA includes over 100 recognized Cold Water Fishery Resource waters including many of the Deerfield’s major tributaries such as the North, South, Cold, Bear, and Chickley Rivers. The Deerfield River supports a diverse fish community of both resident and migratory fish. The Deerfield River has been stocked with juvenile Atlantic salmon for 23 years (600,000 per year at current rates) as part of the multistate Connecticut River Atlantic Salmon Restoration Program. In Massachusetts, the entire Deerfield River corridor has been identified as “priority habitat” for rare species under the Massachusetts Endangered Species Act (MESA).
IMPACTS AND MITIGATION
FLOWS
Run-of-river Operation
NAEA states that the Gardners Falls project is operated in a “limited pond-and-release mode”, utilizing the small storage capacity (37.2 acre-feet) afforded by a maximum 1.8–foot pond drawdown to accommodate the flows caused by the upstream peaking operations.
Flows into the Gardners Falls project, which is located between Deerfield Developments 3 and 2, are dependent upon flow releases from TransCanada’s upstream projects which operate in a daily peaking mode.
Bypass reach
The project’s FERC license guarantees a minimum flow of 150 cfs or inflow (Guaranteed 100cfs from upstream projects) is released into the project’s 1,300 foot long bypass reach.
FISH PASSAGE
The Gardners Falls project operates downstream fish passage facilities for Atlantic salmon smolts.
COMMENTS
The Department does not support NAEA’s application for LIHI Certification of the Gardners Falls Project. This project, with its daily peaking operations contributes to dramatic changes to the nature of the Deerfield River and can not be described as “Low Impact”. While it is true that much of the flow alteration is caused by upstream projects not owned or operated by NAEA, the department believes that until such time as these other projects are operated in a significantly more environmentally sensitive manner, neither Gardner Falls nor any other hydro project on the Deerfield River is deserving of LIHI certification.
Thank you for this opportunity to comment.
Sincerely,
Caleb Slater, Ph.D.
Anadromous Fish Project Leader
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NORTH AMERICAN ENERGY ALLIANCE, LLC
c/o William P. Short III
44 West 62nd Street
P.O. Box 2371773
New York, New York 10023-7173
(917) 206-0001; (201) 970-3707
April 25, 2011
Via E-Mail Only
Re: Application of Gardners Falls Project for Certification by the Low Impact Hydropower Institute
Dear Mr. Ayer:
During the course of the public comment portion of the certification process of the Gardners Falls Project (the “Project”), the Low Impact Hydropower Institute (“LIHI”) received five sets of comment letters,[1] of which one each was from the Massachusetts Department of Fish and Game (the “MDFG”), dated April 5, 2011, Massachusetts Department of Environmental Protection (“MDEP”), dated April 19, 2011 and the Connecticut River Watershed Council (“CRWC”), April 18, 2011 (collectively, the “Opposing Parties”). Essentially, each of these letters asserted that the Project is not low impact hydroelectric generation since the Project “with its daily peaking operations contributes to dramatic changes to the nature of the Deerfield River.” Accordingly, the Project “can not be described as “Low Impact”.” Furthermore, each Opposing Party contents that “that until such time as these other [hydro] projects [on the Deerfield River] are operated in a significantly more environmentally sensitive manner, neither Gardner Falls nor any other hydro project on the Deerfield River is deserving of LIHI certification.” The letter from CRWC also asserts that, since the Project has no upstream fish and eel passage as well as a diminutive road sign and poorly maintained dirt road to the state park adjacent to the project boundary, LIHI certification for these reasons should also be denied.
While NAEA can understand the desire by the Opposing Parties for a near-perfect environment to support a diverse community of both resident and migratory fish in the Deerfield River, the observations of the Opposing Parties are not accurate and their conclusions are not supported by the facts. NAEA believes that the Project is low impact within the criteria of LIHI. Its operations do not contribute to any “dramatic changes to the nature of the Deerfield River.” At this time, upstream fish and eel passage at the Project makes no sense unless all downstream dams cooperate. The situation at Wilcox Hollow described by CRWC contradicts the written statement received from the Massachusetts Department of Conservation and Recreation (“MDCR”) as well as inspections conducted by the FERC. Accordingly, LIHI certification should be granted.
The Opposing Parties all agree that the Facility is not the direct source of the perceived adverse impact on the flows of the Deerfield River.[2] They profess that that entity is TransCanada, the operator of seven of the upstream dams to the Project. It is the daily peaking flows of the TransCanada and Brookfield (the operator of Fife Brook Project, the eighth dam on the Deerfield River) dams that are responsible for what, if any, dramatic change in the Deerfield River that occurs at Gardners Falls. While the Project is permitted by its FERC license to operate in a “limited pond-and-release mode”, utilizing the small storage capacity (37.2 acre-feet) afforded by a maximum 1.8–foot pond drawdown to accommodate the flows caused by the upstream peaking operations, it does not do so. Rather, NAEA operates the Project with a maximum drawdown of only one (1) foot and not in a daily peaking manner. The small amount of useable storage, 37.2 acre-feet, does not permit daily peaking operation. Assuming that the minimum inflow is 100 cfs, this drawdown would only be capable of operating one generating unit (out of the Project’s four generating units) for one hour. Thus, the ability of the Gardners Falls dam to cause an “adverse impact on the flows of the Deerfield River” simply does not exist. Furthermore, the LIHI criteria does not hold a project applicant responsible for upstream operations or actions unless that applicant is a participating responsible party to the upstream operations. For the record, NAEA has no control of or ownership interest in the operations of TransCanada’s Deerfield Project or Brookfield’s Bear Swamp Project.
CRWC makes the objection that upstream fish and eel passage should be installed at Gardners Falls although no such passage is required at the downstream dam to the Project. Without such passage downstream, it makes no sense to require these installations until such time as they are installed on the downstream dam to the Project. Paraphrasing the statement in the preceding paragraph, the LIHI criteria does not hold a project applicant responsible for downstream operations or actions unless that applicant is a participating responsible party to the downstream operations. As aforementioned, NAEA has no control of or ownership interest in the operations of TransCanada’s Deerfield Project.
CRWC makes a series of statements that the Wilcox Hollow tract is neither properly marked nor maintained. These assertions contradict the comment letter received from the MDCR in conjunction with this LIHI application. Specifically, MDCR made the following statement on the issue of the maintenance of Wilcox Hollow:
“Wilcox Hollow is a recreation area maintained by the Massachusetts DCR (emphasis added) and is one of 10 satellite areas that is managed by the Mohawk Trail State Forest. It is strictly an unstaffed, unimproved, (no structures) day use area allowing access to the Deerfield River for fishing, canoeing, and hiking on the Mahican Mohawk Trail foot path that follows the Deerfield River to the town of Deerfield, MA.”
On the issue of poor marking of the entrance to the Wilcox Hollow area, while the MDCR made no mention of the size of the entrance sign to Wilcox Hollow out on Route 2, the MDCR did make the following comment on the signage inside of the park area:
“Their [NAEA’s] provision of warning signage along the Wilcox Hollow access road alerting the public to be aware of changing water levels has provided a needed communication for safe recreation activities while in the area.”
A review of the latest FERC Environmental Inspection Report found the following conditions at Wilcox Hollow:
“The improvements to the Wilcox Hollow facility included a redesigned entrance from Route 2, additional parking, a turn-around area for cars and trailers, and enhancements to the boat launch and angler fishing area (Photo Nos. 16 through 18). The Wilcox Hollow facility was in excellent condition (emphasis added) and was being utilized by boaters and fisherman at the time of inspection.
“The licensee implemented its erosion and sediment control measures during the construction of enhancements and improvements to the Wilcox Hollow Recreation Facility (see Photo No. 18). The licensee appears to be in compliance with its requirements with regards to all other environmental resources (emphasis added).”
Finally, a review of the FERC record for the Project since licensing in 1997 to the present showed no reports of poor signage or lack of maintenance at Wilcox Hollow. Accordingly, there appears to be nothing in the record that supports these claims of CRWC. Nevertheless, assuming that LIHI certification is granted to the Project, NAEA is willing to work with CRWC to improve the entrance sign on Route 2 and to alert MDCR of poor road conditions to the entrance road to Wilcox Hollow.
For the aforementioned reasons, NAEA believes that the reasons cited by the MDFG, MDEP and CRWC for LIHI denying its application for certification of the Gardners Falls Project are not supported by the facts or the LIHI criteria. Accordingly, these comments should be dismissed and NAEA reiterates that its LIHI application for the Project should be approved.
If you have any questions or concerns about NAEA’s answer, please do not hesitate to contact me.
Sincerely yours,
William P. Short III
[1] Two letters were received from the Massachusetts Historical Commission (“MHC”). One letter, dated March 21, 2011, expressed its concern that NAEA not conduct any new construction, demolition or other project modification to its Gardners Fall Hydroelectric Project in conjunction with its LIHI application. In its second letter, dated April 13, 2011, after being given written assurances from NAEA that no new construction, demolition or other project modification would occur to the Project as a result of its LIHI application, MHC has no opinion and would take no action on the LIHI request of NAEA. An e-mail was received from the Massachusetts Department of Conservation and Recreation (“MDCR”) on March 12, 2011 and stated that the MDCR does not have any issues pertaining to recreational use with the Gardners Falls Project with its respect to its certification by LIHI.
[2] Specifically, the MDFG letter noted that “… it is true that much of the flow alternation is caused by upstream projects not owned or operated by NAEA.” CRWC letter noted that “ … although much of the flow alteration on the Deerfield River is caused by upstream projects not owned or operated by NAEA, …” Finally, the MDEP letter noted that “ … there are eight [other] hydroelectric stations that control the flow of the [Deerfield] [R]iver.”
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April 28, 2011 – LIHI received these comments by Robert May for the Deerfield River Watershed Association today at 1:15PM
Comments on the Gardeners Falls Hydro Project Application for Low Impact Hydro Certification
The Deerfield River Watershed Association is a broadly-based volunteer group dedicated to preserving, protecting and enhancing the natural resources of the Deerfield River watershed. We were signatories of the 1994 settlement agreement which formed the basis of the license for most of the dams on the Deerfield and we have continued to be involved in issues concerning the flow regime and its effects on both the biological health and the recreational possibilities of the river.
We have previously submitted comments on the applications of Transcanada for the Deerfield Project (since withdrawn) and of Brookfield Renewable Power for the Fife Brook pumped storage project. Please see those comments for more detail.
The Gardeners Falls application must be seen in the context of the flow regime of the other dams on the river. Since the Gardeners Falls dam is situated between the Transcanada number two and number three dams, and since Gardeners Falls does not have a large storage capacity, it must run a similar flow regime. Utilities were deregulated in Massachusetts in the late 90’s and since then the flow regime has been one of daily peaking. This means is that the river can ramp up and down by a factor of ten or more, multiple times a day. These changes can come without notice and in response not to seasonal or natural variations but in response to rapidly changing demand in the regional energy market.
The Settlement Agreement did not envision this peaking regime and it is our belief that it has multiple negative effects on the river. The extremes of rise and fall mean that large areas of the river bottom repeatedly go from submerged to dry and back again. We have studied the macroinvertebrates in the main stem of the river and have found that the flow regime decreases both the diversity and the density of bug species that are considered part of a healthy river. The variations in flow also promote bank erosion and create a “bathtub ring.” It is also likely that these flow variations interfere with fish spawning, and in spite of some provision for downstream fish passage, fish and other aquatic organisms are lost in passage through the turbines.
It is apparent that this flow regime has been very detrimental to the recreational fishery on the Deerfield. We have gone from what used to be the best trout fishery in Massachusetts, and one of the best in New England, to a river where unpredictable high water has made fishing very difficult. The Deerfield used to support several fly shops and up to a dozen guides who would regularly bring clients to the river. No longer. The only commercial guiding now consists of three hundred dollar per day raft trips.
Gardners Falls is part of a system that imposes a number of significant environmental impacts on the Deerfield River. It is our view that these impacts cannot be ameliorated without fundamental changes in current hydropeaking operations. Thus, since LIHI standards aim at certifying projects that have “avoided or reduced their environmental impacts,” we do not see how Gardners Falls can qualify.
Robert May
For the Board of Directors
Deerfield River Watershed Association
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May 11, 2011
Via E-Mail Only
Re: Application of Gardners Falls Project for Certification by the Low Impact Hydropower Institute
Dear Mr. Ayer:
After the close of the public comment portion of the certification process of the Gardners Falls Project (the “Project”), the Low Impact Hydropower Institute (“LIHI”) received an additional comment letter from the Deerfield River Watershed Association (“DRWA”). This letter asserts some of the same adverse comments that the Project received from Massachusetts Department of Fish and Game, Massachusetts Department of Environmental Protection and Connecticut River Watershed Council. To that extent, North American Energy Alliance, LLC (“NAEA”) refers LIHI to its reply letter filed with LIHI of April 25, 2011 as its answer to these charges made by DRWA. However, since this letter makes new assertions, NAEA feels that it must respond in order to correct the misimpressions of the Project that DRWA attempts to perpetuate.
DRWA states that the extreme rise and fall of the Deerfield River exposes large areas of the river bottom repeatedly over the day, implying that this occurs in the Project area. DRWA also alleges that these actions have destroyed the river environment by decreasing both the diversity and the density of bug species, promoting bank erosion and creating a “bathtub ring” and interfering with fish spawning. Collectively, these actions have destroyed “the best trout fishery in Massachusetts, and one of the best in New England.” None of these conditions occur in the Project area if they occur at all on the Deerfield River.
The river bottom at Gardners Falls is never exposed, fully or otherwise, let alone exposed repeatedly during the day. DRWA presents no evidence that the Project has destroyed the river environment. NAEA completely refutes those accusations that its actions do any of those aforementioned things. Specifically, NAEA notes that no FERC Environmental Inspection Report has ever made any mention of bank erosion or “bathtub ring.” Instead, the latest report speaks favorably about the recreational fishing that occurs at Wilcox Hollow, an area immediately downstream of the Project’s powerhouse.
While NAEA can understand the desire by DRWA for near-perfect conditions to support a thriving river environment in the Deerfield River, its observations are not accurate and their conclusions are not supported by the facts. NAEA believes that the Project is low impact within the criteria of LIHI. Its operations do not contribute to any dramatic changes to the Deerfield River. Accordingly, LIHI certification should be granted.
DRWA, like the other Opposing Parties, agrees that the Facility is not the direct source of these perceived adverse impacts to the Deerfield River.[1] DRWA acknowledges that that entity may be TransCanada, the operator of seven of the upstream dams to the Project. It alleges that the numerous peaking flows of the TransCanada and Brookfield (the operator of Fife Brook Project, the eighth dam on the Deerfield River) dams that are responsible for what, if any, dramatic change in the Deerfield River that occurs at Gardners Falls. The ability of the Gardners Falls dam to cause an adverse impact on the flows of the Deerfield River simply does not exist. Furthermore, the LIHI criteria does not hold a project applicant responsible for upstream operations or actions unless that applicant is a participating responsible party to the upstream operations. For the record, NAEA again states that it has no control of or ownership interest in the operations of TransCanada’s Deerfield Project or Brookfield’s Bear Swamp Project.
For the aforementioned reasons, NAEA believes that the reasons cited by DRWA for LIHI denying its application for certification of the Gardners Falls Project are not supported by the facts or the LIHI criteria. Accordingly, DRWA comments should be dismissed and NAEA reiterates that its LIHI application for the Project should be approved.
If you have any questions or concerns about NAEA’s answer, please do not hesitate to contact me.
Sincerely yours,
William P. Short III
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[1] Specifically, the DRWA letter noted that “The Gardeners Falls application must be seen in the context of the flow regime of the other dams on the [Deerfield] river. Since the Gardeners Falls dam is situated between the Transcanada number two and number three dams, and since Gardeners Falls does not have a large storage capacity, it must run a similar flow regime.”