New England Hydropower Company Responds to National Park Service Comments on Ashton Dam Hydroelectric Project

Strategic Insights -

The New England Hydropower Company, LLC (NEHC) has submitted a response to the National Park Service's (NPS) comments on the Ashton Dam Hydroelectric Project, addressing five rounds of duplicative and redundant comments submitted to the Federal Energy Regulatory Commission (FERC) over the past three years. The NPS's refusal to review the project's information in a timely, professional, and credible manner has delayed the licensing process, requiring NEHC to waste hours responding to uninformed comments and expend significant financial resources.

Key Takeaways:

  • The NPS has finally reviewed the project's information by a qualified professional engineer or hydrologist, after three years of delays and misrepresentations.
  • The project will have none or de minimis impacts on the Blackstone Canal, which lies outside the FERC Project Boundary and the Project's Limit of Disturbance.
  • NEHC has provided significant, additional information concerning impacts to the Blackstone Canal that were not reviewed or were not provided to the NPS reviewer.
  • The WRD's hydraulic review of the project concluded that any impacts to the Blackstone Canal are the result of the NPS's stewardship of the canal.
  • NEHC agrees that additional consideration concerning impact(s) of coffer-damming during construction should be worked through by NEHC with its engineering and construction contractors.
  • NEHC has proposed monitoring activities, including monitoring river and Canal levels for the first year of Project operations and reporting the results to FERC.

Statistics:

  • Over three years, the NPS submitted five rounds of duplicative and redundant comments to FERC.
  • NEHC has spent significant financial resources responding to uninformed comments and delaying the licensing process.
  • 500-year flood study and a Blackstone Canal Impact Assessment were commissioned by NEHC at the request of the National Park Service.
  • NEHC provided the NPS with the 2021 Ashton Dam Inflow Design Flood, the Preliminary Supporting Design Report, the May 10, 2022 Flood Analysis, and the January 6, 2023 Memoranda prepared by Kleinschmidt Associates.
  • The proposed changes to the dam, associated structures, and grading for the access road and parking lot are reflected in the post-development model.

Sources:

  • Secretary Debbie-Anne Reese, Federal Energy Regulatory Commission
  • New England Hydropower Company, LLC (NEHC)
  • National Park Service (NPS)
  • Kleinschmidt Associates
  • Federal Energy Regulatory Commission (FERC)
  • Blackstone Canal Masonry Assessment (September 2021)
  • Kleinschmidt Associates Memorandum (January 6, 2023)