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i'd like to welcome everybody to season two of connecticut river conservancy's live stream series we're launching the new year with hydropower in new hampshire and vermont three dams two states one better deal for rivers my name is stacy leonard and i'm the events coordinator here at crc we really appreciate you tuning in today when there are so many large issues attracting our attention these live streams have been a great means of bringing our work and our rivers to you wherever you may reside we're excited to bring a new season of offerings in the weeks and months ahead on topics such as how we test our waterways for bacteria and microplastics how the connecticut river formed and shaped the land around it how to combat invasive species and become a community science volunteer to name a few you can find all of this information on our website at ctriver.org livestream and i'll be sharing this link in a follow-up email and all the resources that have to do with our presentation today after the presentation before we move on i want to let you know that we are recording this presentation for later access and it will be posted on our website within 24 hours we really encourage your questions this is a big topic and we'll field them at the end of the program so you can type them into the chat box and we'll answer as many as we have time for all right if you've come today to better understand the complexity of hydro re-licensing and how you can get involved you're in the right place this presentation is the first of two on the topic focusing today on the three major hydroelectric dams in vermont and new hampshire and in two weeks on facilities in massachusetts so we hope you'll join us for that as well re-licensing comes up once every 40 to 50 years and there's a lot at stake for the preservation and conservation of aquatic animals humans and culture crc has been advocating for stronger protections for our river for the better part of nine years in this process we'll be led on the journey today by kathy irfer crc river steward in new hampshire and vermont and katie kennedy applied river scientist with the nature conservancy based in western mass kathy erfur advocates for our rivers around multiple aspects including aquatic habitat water quality recreation and transparent public involvement to protect our public trust resource katie kennedy's work involves understanding the impacts of river management decisions on river ecology and function and finding solutions that benefit multiple water users also on the line is andrea donlin our massachusetts river steward who leads our efforts on re-licensing in massachusetts and she'll be leading that next live stream january 27th and helping answer your questions today so without further ado i'd like to turn it over to kathy to lead us on thanks for being here great thanks stacy and thanks so much for everyone who is attending today we still i see people who are still being admitted from the waiting room coming in so um i will dive right in here you know we're going to start with a little bit of background just to make sure everybody is up to speed and we want to start with like why we care essentially so uh you know we are working in the connecticut river watershed and there is a long history of um dams for industrial uses and so our waters are heavily impacted by dams and some of the ecological impacts of dams you know when you have a free-flowing river you have the water that is being oxygenated it stays cool the fish are able to pass when you add dams to any river system certain things happen automatically it starts to slow the water down the water will drop sediment which changes the habitat at the bottom it it will warm the water because it's not you know being aerated the same way so the dissolved oxygen levels can be impacted um and you know in big reservoirs there is a opportunity where the uh the different layers may be heated at different levels so there's a lot of ecological impact dams you know and can't migrate up and down around obstacles uh and so that's really where we're starting from why we care why why dams are a problem we have hydro dams which have additional issues but they also provide a benefit in it they generate electricity for us so um a little background on ferc not a curse word uh stands for the federal energy regulatory commission which is the federal agency that issues licenses for hydroelectric facilities for most of the hydroelectric facilities um the license terms are generally from 30 to 50 years so when we say we have a once in a lifetime opportunity we mean it this the way i see this is this is a contract with the public to use our public resource waterways to generate electricity also in the public interest but often for profit companies so we have this opportunity you know once every 30 to 50 years to revisit this contract and decide if uh it is still in the public's best interest for this to occur this the licenses we're talking about today were last updated in 1979. and a little background on the federal legislation so it is required to provide equal consideration for many different uses of the waterway and that includes power and development electrical generation energy conservation the protection of our fish and wildlife species and endangered species recreational opportunities and preservation of other aspects of environmental health so water quality things like that so you can think of this as like multiple federal regulations that sit on par with each other and the license is supposed to address all of those and so some of the other federal laws that come into play are the federal clean water act the endangered species act the national environmental policy act and national historic preservation act and then recreation because it's a big part of our economy has also been included as an important value as we consider licensing so to dig in a little bit on these particular projects we collectively um have been working on these since uh they started in 2012 and you have the wilder dam which is up in wilder vermont and lebanon new hampshire uh the bellows falls dam in bellows falls vermont and walpole new hampshire the vernon dam which is in the river between vernon and hinsdale these three facilities are owned by great river hydro they were formally owned by transcanada and were sold in i think around 2017 and then south of the border in massachusetts and if you want to learn more about these next two join us on january 27th where andrea will take over and talk about these facilities you have the northfield mountain pump station and turner's falls dam in massachusetts these are owned by a different company first light the four facilities not the pump station are have been peaking hydropower facilities meaning uh you know they are passing water through the dam and through the turbines to make electricity northfield mountain pump station sucks water out of the river and then puts it in a reservoir and flushes it back into the river to generate electricity so they're a little bit different in their function so to dive more into great river hydro and those three facilities that we're focusing on today great river hydro when the facilities were sold uh great river hydro owns a suite of hydroelectric facilities so it's it's many of the facilities are almost all the facilities on the connecticut river in vermont new hampshire including the 15 mile fall facilities further north than what we're talking about today and then they also own several facilities on the deerfield river great river hydro itself is an llc that is owned by a company called arclight out of boston which is an investment company um and so we just want to make that clear that the parent company is interested in supporting raising money for folks that have invested in this asset company so talking about essentially the last 40 years these facilities uh have functioned in a way that's considered hydro peaking and what that means is that you know the the water coming down the river would be held behind the dam the impoundment level would go up as that water gets stored and that at a certain point in the day when electricity prices generally go up like in the evening they would then start to put that water through generate electricity and the impairment would go down and they would generate for you know three four five hours depending sometimes that might occur twice a day and so what you're looking at here is a graph of um just as an example the surface water elevation behind the bellows falls dam between june and august and you can see the surface water elevation change which it corresponds to the amount of water that is getting discharged out of the dam so that goes up and it goes down right in the former um you know in the past 40 years that's essentially how the companies have been working i will pass it off to katie now to sort of turn our attention to the future and what this looks like what may look this will look like under the new um new license well hi everybody good to be here thank you um crc um kathy and stacey and andrea for inviting me to um participate today uh so i'm gonna start yeah with just talking about where we've come from uh we've been at this for quite a while we started let's say this will go we started the licensing process back in october 2012. with a scoping process and then we launched into our study phase relicensing processes on paper take five to five and a half years this one is taking a bit longer for several reasons some of which um are the vermont yankee closure there were two government shutdowns um we had some studies that even redone um and then uh so we had a bunch of information we had this aquatic resource group of which kathy and i were part and um this particular group was very much interested in figuring out ways that we could that we could propose to change operations that would benefit the ecosystem while continuing to maintain the value of the hydropower dam for supporting the energy grid and the nature conservancy had a partnership with umass they did some modeling for us to help us understand this concept of flexibility that um the company had said was very important to them and so we came up with some ideas proposed those two river hydro kind of pitched these ideas we have a hydro in march and then in a couple of months they initiated some discussions with us to talk about this further can we include some of these ideas um into into a proposal for operations um so let's see let's keep going um so what were the resource concerns that we were bringing we brought into the room again this was the aquatic resource working group so we were primarily looking at habitat um and fish spawning success and movement um and then habitat for riverine fish species but but also and and maybe importantly so for some of the threatened endangered species in the system like cobblestone tiger beetle and dwarf wedge muscle on great river hydro's part they're of course interested in maintaining their project economic viability being in compliance with the energy regulate regulatory body and then having this operational flexibility that's important so important to them and we had i think of course we had these interests at the table but there were several others that weren't brought to the room specifically because we were focused on the biology the aquatic biological resources but these are also very important and i just want to acknowledge that this was not the center of this particular discussion and those include recreation fish passage erosion and cultural resources and we'll talk about these more a little bit later in the presentation um so here's some model data i'm a scientist i love this stuff um this is some of the data that umass helped to help us understand how the river was functioning right now so these are modeled current operations this is not observed data this is um model data but it does align pretty closely and along this horizontal axis this is time so these each of these blocks is a period from july to october and um nine different years so just to look at the variability across different years we looked at a lot or at least nine and then on the vertical axis that's discharged from the dam so flow or just releases from the dam um this is wild dirt and as as cathy said these facilities hold and release water in response to energy market demand and so we see that it happens very often so there's kind of like really really a lot of up and down and that corresponds to the daily sometimes twice daily peaking these projects um undergo and then there's some gaps where water is really low or water is really high um in contrast we have this other model that usgs provided that gives us an idea about what natural flows would have looked like so imagine the connecticut river without any dams so this is minus any dams in this system and this gives us an understanding of what the species in the river evolved to um so a lot lot fewer fluctuations you can actually see the whole continuous line um and oh yep vertical is cfs that's exactly right so discharge in cfs and there is quite a bit of variability among years but much more a much smoother flow regime as we call it however there are 3 000 dams in the watershed so we are not anticipating getting back to natural so another question we have is what would the best case scenario be you know if we wanted to reduce some of this modification and return some of that natural variability to the system and so these images represent what we call inflow equals outflow so there are projects upstream that are peaking facilities that um are not being currently licensed i believe that that relationship ended in the late 90s i was not around at that point um so we will we have been thinking about of course also think about the next period so they will be re-licensed again in now what 15 years so um something to think about but they still peak and so we wanted we we can't do anything about that today but we can think about um what we can do for these facilities and this is essentially the best case scenario um the water that comes in leaves the dam in an instantaneous basis so um we had a lot of really good discussion with our great river hydro team and these are some of the outcomes that we came up with in those discussions one thing that we were really pleased with is great river hydro agreed to that kind of best case scenario given the current circumstances which is inflow equals outflow as base operations this corresponds kind of like imagine a bathtub where um the drain what's going out what's coming in is going out that water level stays pretty constant so as a result of the inflatables outflow we have steady water surface elevations and then we did we did allow for a one foot bandwidth there um to account for great river hydro's needs we have some periods of flexible operations and those vary by season according to the needs the power needs and according to the resource needs so more flexible hours in per month in the winter fewer in the rest of the year when there's more resource concerns and then we also were really interested in ramping how quickly the water turns on and off and so great river agreed to have a gradual up ramping in most cases a lot of detail there we can talk about it later and then um gradual down ramping so from peaking back to inflow eagles outflow in all cases um and then um lastly oops well i can say quickly when the water is released the water the water surface elevation goes down so we want to make sure that that came up relatively quickly so um we agreed very hard to agree to get that back up to full that target water surface elevation within 48 hours so these are some simulations that great river hydro provided us to illustrate how these proposed operations might look and so the red line there's a lot here but it's super cool so bear with me the red line represent those current operations so we have that regular peaking and this is um february so the horizontal axis is time and represents the full month of february again and the and the vertical axis is discharge in cubic feet per second or cfs so the red line is current operations that daily peaking going low to high every day the dotted line um is the dot of gree line is that inflow equals outflow so water in equals water out and then the purple line is the proposed operations so this is winter where we have the most allowable um periods of flexible operations so in this case 65 hours i mean you can see that the purple line tracks the green line pretty closely except for those times of flexibility when they peak and what we see in comparison to the red is higher base flows fewer peaks and shorter peaks and then if you look at the top of the graph this is represents water surface elevation where the lower dark blue line is current so a lot wider fluctuations and a lot more frequent and then the lighter blue line is the proposed operation so much steadier and fewer fluctuations and again this is winter so this is kind of the most flashy that the system will be um because this is the most allowable flexible operations to show you another time period so in comparison this is a um an example of august this is a relatively wet august we did look at a range of months and water conditions dried wet this is kind of a wet august and again the purple line tracks the green line pretty closely except for those times of flexible operations and august has 20 hours of flexible operations and then again looking at that water surface elevation the comparison between current and the proposed is pretty striking when i first saw this so we're anticipating very steady water surface elevations which is pretty exciting um so let's see just to recap um we tnc and crc and the other stakeholders really do consider this a win for the river um there there will be a significant improvements to flows that benefit the ecosystem um in turn these these improvements and flows will really improve aquatic habitat both upstream and downstream and we really think that these steady water surface elevations will address some of the other issues like erosion in the impoundment and kathy we'll speak more to that here in a minute and then at the same time um the facility is able to maintain their energy and economic value so these projects are valued for their ability to turn on when the regu the energy regulators ask them to and when they're needed to maintain grid stability and under this proposal they are still able to do that so that's pretty exciting that we have this pretty incredible win and for the nature conservancy balancing renewable energy needs with ecosystem needs is really important to us so this is a really great example of how we can do that as a reminder however there are issues that are not covered here erosion we are hopeful to some degree but there are others too that were definitely not discussed and um the nature conservancy's position here is awesome we're really happy about this flow regime's proposed flow regime we still need to be sure that fish passage issues are addressed and work with our we're working with our resource agency partners understand how that is going they're in discussions with great river hydro currently i believe um and then for these other issues it's really important to nature conservancy that we find creative solutions to make sure that all of the users of the river are able to able to ensure that they have continued use of these resources and um oh it's fine um kathy is going to go ahead and describe some of these additional issues and um the approach that the connecticut river conservancy will be taking so kathy hand it over to you thanks katie so um so again i do want to reiterate i i think that this operational change is going to be a profound positive effect on the river and uh we're excited about that we were limited to that specific conversation about that operational change from the perspective of how it affects the aquatic species and we did not have the opportunity to have uh conversations to delve into some of the other issues that crc cares about um and so you know i was i was anticipating you know as everyone else when the license came out there was information in the license that i was not privy to until it was made public and so i have to say when i started digging into the license really looking for like what else what other protection mitigation and enhancement measures are there going to be i was really actually quite disappointed in how little additional um pm and ease they're called or protection measures were included so the application clearly states that great river hydro as a recreation mitigation will maintain three primitive campsites on the river that are part of the connecticut river paddlers trail they have been maintaining those sands those campsites but they're going to make that more formal and bring them into their recreational assets as it were um we were expecting a lot more and i'll go into that uh they will be operating the fish ladders from april 1st to july 15th which is a slight expansion of what they're already doing but not not too much of an expansion but probably what is needed and then as as katie mentioned you know they indicate in the application that they will discuss additional fish passage requirements with resource agencies ideally you know the application this is the final application that the details of those decision decisions should be in this application for the public to be able to comment on and they are not there and so to a certain extent from my view the application is deficient in that this is not already included and similarly uh they discussed developing and signing a programmatic agreement for managing historic resources that also there should be details for the public so over the course of the next several months burke will be requesting additional information from the company and we are hopeful that rapidly some additional details will be provided to the public so that folks can comment on that so just to dig into these a little bit um you know great river hydro did uh two separate recreation studies one focused on white water and one on kind of infrastructure needs um and then in addition connecticut river conservancy and the appalachian mountain club did a recreation survey in the towns and then spoke directly to many of the uh recreation planners and town leaders to find out like what the towns in the project area would like to see for recreational enhancement and we submitted a list of recommendations to ferc and to great river hydro that called out a lot of specific things um you know great river hydro has not indicated for instance that they are willing to address the portage issue around bellows falls which is a mile and a half portage um you know improvements to fish viewing facilities would be great that has not been included in this application so these are some of the things that connecticut river conservancy will be advocating for as we comment on this application similarly just a little bit of details about our concerns around fish passage vernon ladder is actually a very uh it's a good ladder and it passes fish quite well but there are some specific enhancements that will make that ladder even better at um helping to pass fish upstream and the fisheries biologists are really looking for safe and effective upstream and downstream passage for uh our species of concern migratory species including american eel american shad and sea lamprey uh there are some concerns about downstream passage and mortality through some of the turbines that need to be addressed um and then you know again different fish need different passage ways right so american eel slithers on their belly shad swim in the stream so so you know providing for the details to make sure those fish are passed appropriately and um one of our continued concerns is since before 1979 uh has been the erosion caused by the peaking by the surface water elevation fluctuations under this new operational scenario crc anticipates that because the surface water elevation will be held stable behind the dam there will be significantly less of that up and down every day which should be more protective of our stream banks and so to to us that is a positive outcome the one caveat or concern is at the northernmost end of the wilder pool you still have potential you know peaking inflows coming downstream from macindos which is also owned by great river hydro and so we would really like to see some analysis or monitoring of the of that upper end of the impoundment um really of the whole river ideally but of the upper end of the pound ensure that that erosive force is um being reduced and that we do in fact see less erosion up there as well and the other thing that you know given the profoundness of this operational change for the river um you know there is the potential for for really interesting research basically and monitoring of the changes in the river system so for instance you know all of the tributaries that come into the river in the impoundment areas have been meeting much of the time sort of slow moving or not moving water and so what that means is the tributaries have dropped their sediment at the mouths of as they enter the connecticut river over the past 40 years and so as we start to see more water moving actively through the river we can expect changes in the tributaries um in terms of like how sediment moves possibly what kind of bottom habitat is there and so now is actually like a really opportune moment to monitor this change over the next couple decades at least to see how when you change operations in this way it uh how a river rebounds really and what additional um benefits may come from it and being able to track that from a scientific perspective so you know we're coming to the end here we did it on time um and the thing that you know i want to reiterate is these this is a public process and we really need the public to and be engaged in it um you know connecticut river conservancy and tnc like we have been engaged and we are commenting um but we really need uh our are towns people organizations and individuals to you know know what's going on and be willing to step up and speak up for your river and what you want in your community so the ways to go about doing that are to sign up for the ferc docket to begin to get what comes out of ferc on these facilities um we're expecting in terms of the timeline that ferc will be requesting additional information from great river hydro as i said in the next month or two and then there will be a point at which they deem the application complete which we expect will be some time after may and at that point uh individuals and organizations can intervene and comment and submit formal comments on this final revised application and so you can basically tell for for what you would like to see um and what you want for your river and then in addition once that application is deemed complete there is a corollary corollary process in the states where each state has the right to um develop a water quality certificate which will provide requirements in the license and so there is a public there will be a public process in both vermont and new hampshire and massachusetts to take additional input from the state's perspective and so you know being aware and being involved in that process and commenting would be good also and then ultimately there will also be a an environmental impact statement um prepared by ferc and you can comment on that as well so you know after this we will send a follow-up email with links to our website with waze to kind of dig into the details of this and and andrea and i are standing by glad to help you work through figuring out how to do this um contact us often so all in there there's our contact information and then we can open it up to questions fabulous thank you so much kathy and katie i just wanted to reiterate no need to necessarily write all these email addresses down everyone here will get all this later today the follow-up with all the resources links etc so reminder to please put your questions in the chat because there's a lot of people here it's pretty impossible to raise hands so i'm going to start with an earlier one can you talk about the specific criteria used to measure whether licenses are in the public interest sorry can you talk about the specific criteria used to measure whether licenses are in the public interest andrea maybe you want to field that one well um i guess one it's sort of a low bar the public interest question um which we found out when we were commenting on um sort of a corporate restructuring of first life that it's really for this proceeding and ferc it's really about whether the companies are uh proficient and capable of running the facilities so it's it's not what you sort of instinctively feel is the public interest i'll add that that's why it's important that graph that kathy showed with all the different um regulatory authorities kind of looped in um we really depend on those to ensure that you know it's more than just energy interests that the public are concerned with great i'll jump in and also mention um this is another question that just came to me privately so that everybody wouldn't have seen this but the question was why are the contracts or the ferc licenses um 30 to 50 years long has there been any advocacy to have the length of the contracts changed particularly moving forward with climate change and that sort of thing um the public needs opportunity to ask uh the holders of the licenses to change to meet and support the needs of the environment um i'll take a stab at some answers to that and the 30 to 50-year time frame is something that's stated in the federal power act so it would take a an act of congress to change that time frame which can be a heavy lift um to do anything really but um and i think from the opera that the project owner standpoint um what i've heard is you know if you're going to ask them to put in a 10 million dollar fish lift or something they want stability and know that the sort of goal posts are not constantly shifting for them to put that much of an investment into the license parameters so i think it's it's a balance between i you know the length of time that maybe the people would want versus um investing in changes to the way that the facilities are operating i don't know if kathy and katie want to add to that yeah i mean i think that's a really good question i had the same question when i started getting involved in this is like why is that so long um and the answer that i heard is that it's really about the investors so in order and that's one reason why new facilities have a longer period so a brand new facility is going to have a 50-year license because that's the time that's needed to recover the cost of building the facility older facilities with fewer investments are going to have shorter timeline because it takes less to to recover the costs of re-licensing and of the changes so basically if if if you shorten the timeline there's less likely for investors to want to invest because they won't recruit the costs they're that investment cost and so the the facility can't function um so that's that's that's how i understood it in a nutshell um whether that's good or right is another question entirely it might be i think we got a lot of questions so maybe we move on to the next one sure uh what is the connection enforcement relationship between the bodies who agree to change operational behavior and systems and those who would actually carry out the agreed changes in other words what is the chance the agreements will be implemented and is there any penalty if they are not yeah ferc is a you know ferc is a regulatory agency right so what is uh what is ultimately you know this this operational change is in the application and it is the preferred alternative uh by both great river hydro and the stakeholders that have been involved in this um so uh very likely you know we expect to see this in the license but ultimately what ends up going into the license is the regulation that the company must function by under the new uh under the new license when that when that starts and great river hydro is a compliant company right so they are not you know you you as we work with multiple different hydro companies you know you can see who is like a good actor and who is not a good actor in terms of their compliance if they were out of compli nce there's a process through ferc to be able to complain and then you know ferc would address that great river hydro is a compliant company and i don't have any reason to believe that they are not going to do what they is required of them under the license this is a little bit related echo um but uh the question is about enforcement and the responsibility to maintain protect and guard the recreational facilities we live next to a mandated boat launch and it is a continual source of bad behavior and negative impact with no authority to monitor vermont troopers say it is private great river hydro claims they are not required to monitor combined with the power line it's a major crime attractant do you have any thoughts on that so that's a perfect example of something that you would want to comment on you know so if this happens to be a great hydro facility that you as a you know a local constituent are having issues with that would be a comment you want to send to ferc so they're aware of that and they take that into consideration as they consider the new license great um a question about the fish ladders you said that the fish letters have been operating does this include wilder we have not observed it being operational in recent years right so the fish ladders were built for atlantic salmon and you know there was a multi-year effort to restore the atlantic salmon to the connecticut river and that effort was suspended several years back so what that means is you know the trigger for the wilder fish ladder to operate currently has to do with the number of atlantic salmon that pass through the vernon and bellows falls ladder so as part of these discussions with the fisheries biologists under this new license you know the focus has switched to frankly being um the more comprehensive uh consideration of multiple migratory species not just you know the atlantic salmon so under this new license the consideration is uh many species and they're they're all of their needs um and so that may depending on what ends up in the license you may see the wilder ladder functioning more if it is required to pass about to past shad or you know american eel or sea lamprey but that you know it's a little beyond my fisheries biologist expertise so at the moment you don't wilder has not uh the fish ladder has not been open for several years because there are not atlantic salmon being passed up river and so under this new license we should see this addressing you know are the the migratory fish that we want to support at this moment in time and over the next few decades okay there's a question about the campsites you mentioned that maintaining the three camp sites would that mean others would close or can close is the question so the the connecticut river paddlers trail um has been formed by a coalition of multiple landowners many land trusts private landowners great river hydro who have supported the these primitive campsites up and down the river and the idea being that this would be a way to travel the river you know on an extended trip um uh from the headwaters all the way down to the long island sound ultimately and so uh great river hydro's commitment here is to maintain three of those campsites um there are multiple campsites along the river and the rest of them will continue to be maintained and you know based on the recreation that we saw last summer i can only assume that you would be able you will be seeing more people on the river using those campsites and passing passing on down there and we will have more information on the powders in a later live stream so stay tuned for that um and also reminding folks that we will share all the links and information on on the ferc docket in the email that was another question did the hydro operator or anyone else calculate how much the proposed new mode of operation will decrease the power company revenues i'll take this one um i would say of course the hydro operator did calculate that um and that's how they knew that they'd be able to do this um the model that we use with umass did um did estimate the cost of that info equals outflow and then did estimate um you know some scenarios under this flexible operation and um and so so when if we did strict input goes outflow that we estimated about a 10 reduction in annual revenue strictly from generation revenue and this is really important um because um the one thing that we learned is that the company actually gets a lot of revenue um through what's called um reserve payments so so these facilities are super important to the iso the energy regulator for being ready to come on on demand so there's they're valued because they're fast start facilities they're very important for keeping the grid stable and so they get paid for just being held in reserve um and then the other piece of that is when we added in flexibility we were amazed um at you know how how much value the company can continue to provide to their to their economic um value in a short amount of time so like there are really windows of really high energy value where they make a big proportion of their um revenue so we don't have an exact number but um it's somewhere between 0 and 10. i think well i'll say in the economic analysis as part of the application and if i'm remembering correctly i think what they provided was a comparison between 2019 uh revenues and it was a just a one percent uh reduction under between a current scenario and the new scenario so you know um i don't based on that i i don't think there is a large economic impact for this operational change that's good it's good that the company was so forthcoming those are good answers thank you great has great river hydro tested the operating changes in real time um they uh yes there was a period in the summer when uh they i think attempted at least for a week or something to run this to kind of test how this would go um so yeah i mean i i i they they've as we went through our conversations they did their due diligence to make sure that they can do this and that it's in their best interest from an economic perspective and an um you know an electricity generation perspective that that it is functional and workflow i don't want to speak for them i mean so i don't you know that's why i'm sure we could ask matt to respond um anyway next question okay uh are there any interveners addressing historical preservation we so um both the vermont and new hampshire offices of historic preservation over the course of the past eight years they have commented i fully expect that those offices will be engaged and comment i don't know if there will be you know uh how those additional discussions might go to work at the details of the historic properties management plan in addition to that um you know there are in our area the ebenecke um tribes are interested in the impacts of the river and they i know uh there are representatives of those tribes that have been involved in the discussions and will also likely be commenting so yeah did that answer the question how about the town level historical commissions in new hampshire and vermont are there such things the way there is massachusetts i don't know i mean there's so many towns involved and i don't remember from the previous comments and stuff if there may have been some towns who did comment and have been involved in the process um but i think for the most part it's been the states involved but again if there's a historic consideration you know this is a public process and people should comment with their concerns great will the new more stable inflow outflow regime apply to heavy storm events don't they also have responsibility to downstream communities and liability concerns about downstream infrastructure i'll take this one that's a really good question um so a couple of things that are important to note that there are so when inflows get over a certain um amount um things shift so they're they go under what's called flood um uh profile operations that that said that is primarily to deal with upstream impact so the impacts of flooding in the upstream portion of particular wilder reservoir um these facilities are technically not um but control facilities so there are 14 plus other dams in the watershed that um are responsible for maintaining storm events so um essentially essentially when water gets over a certain amount um they it just goes over the dam and we rely on those flood control facilities to do their job basically um i don't know if they answered that question fully but that's a it is that is a good question great um here is a comment rather than so much of a question around framing of questions around enforcement i highly encourage people to educate themselves on the ways in which behaviors particularly behaviors in relations to landscapes and natural resources are historically and contemporaneously racially criminalized enforcement feels reactive rather than proactive i wonder if there is a way sorry it's flip jumping on me i wonder if there's a way to think about policing by law enforcement and for-profit corporations of our natural resources to address some of crc's interests in culture and recreation if anyone wants to brainstorm with me ahead of the public comment period you're welcome to send me an email this is robert eastman does anybody want to say more about that kathy or katie i think um that's a whole other ball of wax so it's sort of a lot time for another conversation because there's a lot of you know when you're thinking about access to the river there's a lot of different this is less about this particularly licensing and more about the multi-jurisdictional control over access sites and who has control over them and funding and a lot of stuff so we we have to save that conversation i think for another time but um yeah i agree there are there are definitely some considerations in terms of how um you know how those things could be addressed more proactively as opposed to sometimes how we have done it in the past great um i'm going to try and fit in one or two more questions here and again invite people to uh ask questions by email or phone to our presenters um after this and i also sorry stacy i'll just say you know i am glad to like for planning commissions or select boards or you know i'm glad to come and um present and help unpack this for other organizations so you know if uh people can certainly reach out to me that to ask try to set up a time and i'm glad to present this at other meetings so that more people can understand the details of this process great um okay let's try here's another one in order to have greater control over the characteristics of the flow regime is their language in the document that will require the power company to add battery storage to their interface with the grid as battery technology improves we um we looked at battery storage preston yeah katie you want to answer it um go ahead i could we looked at battery storage as we were uh you know realizing that what we wanted to see for the river was really inflow equals outflow right that that the most natural kind of flow regime we were in our own thinking were you know acknowledging that that that that made a major economic impact on the company's ability to access the capacity market right which is um you know different than the money you get from just generating electricity as it goes through the turbines so in trying to help you know solve that problem we um you know did some analysis and reached out to a consulting firm to look at this idea of adding battery storage um to these facilities and interestingly this idea has been taken up by some of the other hydro re-licensing processes around the country so the alabama rivers alliance included this as a potential study in that re-licensing effort in alabama bama which ferc approved to have them look into this as an opportunity to move away from peaking hydropower in this scenario um you know we talked to we suggested this to great river hydro and i think you know uh that is something that maybe they would consider in the future but in the meantime we ended up um you know we were able and well great river hydra i really should say was able to find a different pathway forward which is the one that was included in the license that essentially accomplishes that right so we're moving the river to inflow equals outflow most of the time and they figured out how to do that without needing to rely on battery storage to maintain those revenues stacey you're muted thank you both i think we're going to need to close it for now and just remind folks that you can continue to have this discussion by email or phone call and we're going to have our next live stream on january 27th with andrea donlin sharing more about the massachusetts facilities and i just want to thank everybody for joining us today i hope you learned a lot about these important hydro issues and how you can raise your voice for action a special thanks to katie kennedy for sharing her time and expertise with us and to katie and andrea for always helping to make this work understandable and accessible and to all the folks who are at the table during these re-licensing proceedings we are grateful for your advocacy so thank you everybody and we look forward to seeing you next time bye