Guest columnist Kelsey Wentling: Too little, too late — what FirstLight won’t be doing for the next 10 years


Published: 05-03-2023 8:26 PM

While a lot can happen in 10 years, FirstLight is proposing to do very little in the next decade under their recently submitted Flows and Fish Passage Settlement Agreement.

Ten years from now, the Intergovernmental Panel on Climate Change (IPCC) estimates we will cross a pivotal threshold for climate action. A new license for FirstLight needs to account for how a rapidly changing climate will impact the Connecticut River and its inhabitants — but FirstLight’s settlement agreement, released just days after the IPCC report, does not do that.

The settlement agreement, however, does include benefits to river health in the form of fish passage upgrades as well as flow modifications. For example, migratory fish will benefit from increased flows in the springtime, along with a new fish lift and improvements to downstream fish passage.

But here’s the thing: These improvements for fish passage won’t be completed for 10 years, roughly when the IPCC estimates we’ll cross that climate threshold. While there will be smaller improvements made to fish passage about four years in (adding some gates so fish don’t get crushed in the turbines), the new fish lift and the more significant downstream improvement won’t be operational until nine years after the license begins.

Speaking of fish getting crushed in turbines, FirstLight is proposing to add a barrier net to the Northfield Mountain Pumped Storage intake to prevent fish from getting killed as the river is sucked up the mountain. Under expanded operations, studies on the impact of the facility showed that, while the net will improve chances for adult shad passing by the intake, it won’t do a great job of protecting juveniles and eggs.

Each year about 1,300 juveniles, 500,000 larvae and 3 million shad eggs will end their journey prematurely at Northfield Mountain, and that’s just one species.

And yet the problem here isn’t just if the barrier net is working, but when the barrier net will be working.

Let’s say the barrier net is installed in 2032 (scheduled to be installed 7 years post-license). In 2035, FirstLight will evaluate if it’s working and will report those findings by 2037. If those findings show they aren’t hitting their performance goals, between 2039 and 2044 FirstLight may adopt minor adaptive management measures, like changing the size of the net and cleaning it more often.

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Still not working? Under this agreement, state and federal agencies agreed not to exercise any regulatory authority for the first 25 years of the license, meaning they cannot use their regulatory power to request or require other adaptive management measures until 2050.

In the meantime, the river will experience some relief due to increases in water FirstLight will put into the river during the springtime migration, but the proposed minimum summer flow is not enough to support the diversity and function seen in free-flowing rivers.

The settlement agreement allows for 500 cubic feet per second of water directly below Turner’s Falls dam in the summer; it currently drips out at about 120 cfs. To scrape by on a kayak, you would need about 570 cfs and for wildlife to thrive, FirstLight needs to more than double the flow proposed. Shallow, low-flow waters are susceptible to warming and drying up; leaving the current precarious habitat at risk even without added climate stress.

After operating on a license that’s been expired for five-plus years, all the improvements in the settlement agreement are wrapped up in a request for a 50-year license term. None of us can claim to know how the climate and Connecticut River ecosystem will change throughout the next five decades.

Today, operating under conditions from the 1960s is a cruel joke played on the Connecticut River. Why would we assume this won’t be the case in the 2070s?

FirstLight talks a big game about combating the threats posed by climate change. Undoubtedly, we need to accelerate the transition to renewable energy and existing hydropower has a role to play in that transition. However, decarbonization at the cost of ecosystem devastation is short-sighted and only serves to diminish biodiversity.

FirstLight has the resources and ability to put more water back in the river and to pass fish up and down river before the end of the decade, all while generating low-emissions energy. You have a chance to make sure they do that.

The comment period on FirstLight’s Flows and Fish Passage Settlement Agreement is open until May 7; we at the Connecticut River Conservancy urge you to write to the Federal Regulatory Energy Commission to demand improvements to this license. Learn more about how to submit comments online at

Kelsey Wentling is river steward at the Connecticut River Conservancy, formerly the Connecticut River Watershed Council.