Great River Hydro’s FERC-Filed Notes from the 3/8/18 Study Results Summary

Cover letter:

Great River Hydro, LLC (“Great River Hydro”) is the owner and licensee of the Wilder Hydroelectric Project (FERC No. 1892), the Bellows Falls Hydroelectric Project (FERC No. 1855), and the Vernon Hydroelectric Project (FERC No. 1904). The current licenses for these projects each expire on April 30, 2019. On October 31, 2012, TransCanada initiated the Integrated Licensing Process by filing with the Federal Energy Regulatory Commission (“FERC” or “Commission”) its Notice of Intent to seek new licenses for each project, along with a separate Pre-Application Document for each project.

With this filing, Great River Hydro submits its March 8, 2018 Updated Study Results Meeting Summary for the three projects, as required by 18 C.F.R. §5.15(c)(3) and the Commission’s current Process Plan and Schedule (dated February 15, 2018). The meeting for the Updated Study Reports filed between May 1, 2017 and February 9, 2018 was held at Great River Hydro’s Renewable Operations Center in Wilder, Vermont, with teleconference and call-in capability for participants who could not attend in person.

Below is a comment excerpt:

ILP Schedule – Brandon Cherry reviewed the Revised Process Plan and Schedule FERC issued on February 15, 2018, noting that GRH is required to file a progress report on May 15, 2018 and every 90 days thereafter until studies 9 and 24 are completed. The progress report is to include the status of study 33 – Cultural and Historic Resources Study.

Study 33 – Cultural and Historic Resources Study – Rich Holschuh concurred that this study is still open and indicated that while the draft TCP includes timetables for consultation, no consultation has taken place. John Ragonese disagreed that no consultation had occurred, citing several meetings with native American tribal leaders and informational resources but recognized the present open status of the study. He said the Programmatic Agreement (PA) and Historical Properties Management Plan (HPMP) are in development and will be shared for comment and review. The PA is a signed agreement among affected parties that usually includes SHPO’s, licensee and federal tribe(s). GRH suggests that no federal tribe is affected by this PA, but local tribes are and therefore should be included. The PA will reference the HPMP which includes details of how properties will be managed.

Doug Harris in Northampton Aug. 5th: Let the Landscape Speak

A fundraiser to support the Indigenous Tribes of the Northeast in protecting Ceremonial Stone Landscape Features in Sandisfield, Massachusetts.

Presenter: Doug Harris
Preservationist for Ceremonial Landscapes
& A Deputy Tribal Historic Preservation Officer for the Narragansett Indian Tribal Historic Preservation Office (NITHPO)

Doug Harris will present a history of Ceremonial Stone Landscape Features in the Northeast region and the struggle to preserve them. The hills and valleys of New England are dotted with living prayers of stone (Ceremonial Stone Landscapes) created by the Indigenous peoples of this region. These stone structures were built to create and restore harmony between human beings and Mother Earth. The prayers that they embody continue to live as long as the stones are kept intact.

As has happened before in other places, our government, more specifically, the Federal Energy Regulatory Commission (FERC) has been complicit in the destruction of these sacred stone landscapes. Over 1/3 of the 73 features identified in Sandisfield have been desecrated by the construction of a new gas pipeline. This occurred because FERC approved the project before the stone features were identified, and then failed to consult with the tribes in a meaningful manner to resolve the adverse impacts. While harm has been done, this is also an opportunity to support the Indigenous peoples of our region so they can challenge FERC’s behavior in the courts. If successful, ceremonial stone landscapes will be preserved, not destroyed, a result that would have national implications.

Saturday, August 5, 2017
3:00-5:00 pm
First Churches, 129 Main Street
Northampton, MA
The church is handicap accessible and on a bus line
Please enter on the Center Street side of the building
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You can make a tax deductible contribution in one of two ways

1) Write a check to Creative Thought and Action (memo: CSL), and mail it to Climate Action Now’s treasurer: Rene Theberge, 250 Shutesbury Road, Amherst, MA, 01002.

2) Donate online by going to https://tinyurl.com/protectsacredstones

Please share far and wide with friends and family.

For more info and/or to help with this campaign contact Susan Theberge
Please include CSL in the subject line.

VT Public Service Department Backs Sale of 13 TransCanada Hydro Dams

TransCanada Bellows Falls Station Randy Holhut

key state agency has signed off on the sale of 13 hydroelectric stations to a Boston company. The Vermont Department of Public Service – whose job is to represent the public interest in energy matters – has approved a deal pledging to support Great River Hydro’s proposed purchase of TransCanada’s dams on the Connecticut and Deerfield rivers.

Jim Porter, director of the department’s Public Advocacy Division, said the agreement came after a thorough review of the sale and after negotiation with Great River. “We did conclude the sale facilitated the general good of the state,” Porter said. “The sale will not affect Vermont jobs, and Great River Hydro demonstrated it is capable of managing these assets.”

Read the full story by Mike Faher at VTDigger.org.

More on the Impacts of the Tennessee Gas CT Expansion Pipeline

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A comprehensive resource listing of the ongoing situation in Sandisfield/Otis, MA, along the planned route of the Kinder Morgan – Tennessee gas pipeline expansion project.

“FERC filings and newspaper articles are expressing some deep concerns over Kinder Morgan / Tennessee Gas’s (TGP”) plans for dealing with ceremonial stone landscape (“CSL”) features sacred to native peoples with cultural, religious and historical connections to land in Sandisfield, Massachusetts along the proposed route of the TGP Connecticut Expansion Project.

73 CSLs were identified in an on-the-ground survey conducted by  several Tribes in the second half of 2016.  According to Deputy Tribal Historical Preservation Officer Doug Harris of the Narragansett Indian Tribe, a full one-third of these CSLs will be destroyed during the construction of this pipeline.”

Full article at No Fracked Gas in Mass here.

A previous post on Sokoki Sojourn, as the story was developing, is here.

 

 

 

VCNAA Support for Standing Rock Brings It Home

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The Vermont Commission on Native American Affairs approved a proclamation in support of North Dakota tribes, 14 days before the new president announced he would resume two controversial pipeline projects.

“We approve everything unanimously because that’s the native way,” said Rich Holschuh, a Brattleboro resident on the commission. “As a commission, we work with the native people within what is now the state of Vermont. We also recognize that borders are political constructs, so we try to support similar people with similar interests and this is one way we can do that.”

The commission “proclaims support for those protectors at Standing Rock, N.D., who are resisting destruction of sites sacred to Dakota, Lakota and Nakota people, disruption of traditional ways and potential environmental contamination from crude oil pipeline construction and use.” The entire document can be found here.

Commissioner Joelen Mulvaney drafted the document, which was discussed and approved during the commission’s Jan. 11 meeting.

Read the full article by Chris Mays in the Brattleboro Reformer. Photo by Kristopher Radder of the Brattleboro Reformer.

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Nolumbeka Project Files Letter of Support for Narragansett THPO with FERC

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January 12, 2017

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission 888 First Street NE, Room 1A Washington, DC 20216Re: Docket No. CP14-529, TGP Connecticut Expansion Project
Support for Narragansett Indian Tribal Consultation on Traditional Cultural Properties

Dear Secretary Bose:

The Nolumbeka Project is a non-profit corporation with an all-volunteer board whose mission is to preserve, protect, and educate the public about Native American cultural resources in what is now called New England and the Northeastern United States. We are writing to voice deep concerns over plans of Kinder Morgan/Tennessee Gas (“TGP”) that will result in the destruction of ceremonial stone landscape (“CSL”) features sacred to Tribes with cultural, religious and historical connections to land in Sandisfield, Massachusetts along the proposed route of the TGP Connecticut Expansion Project (FERC docket #CP14-529, the “Project”). As TGP is well aware, 73 CSL features were identified in an on-the-ground survey conducted by several Tribes in the second half of 2016.

According to Deputy Tribal Historical Preservation Officer Doug Harris of the Narragansett Indian Tribe, a full one-third of these CSL features will be destroyed during the construction of this pipeline. Although some have suggested that it would be acceptable to disassemble the features and reassemble them when construction of the Project is completed, Mr. Harris explains that their disassembly would be an interruption of the prayers placed there. According to Mr. Harris, “Then what you have is an artistic replica of something that was spiritual. Once you remove the stones, the spiritual content is broken.”

On December 29, 2016, the Federal Energy Regulatory Commission (“FERC”) sent a “Notification of Adverse Effect” to the Advisory Council on Historic Preservation’s Office of Federal Agency Programs, seeking resolution of this matter. FERC’s Environmental Assessment (“EA”), issued in 2015, included alternative routes that may have avoided many of the CSLs, but FERC approved the primary route before the CSL survey was undertaken. Thus, the FERC certificate was issued in violation of the implementing regulations of the National Historic Preservation Act (the “NHPA Regulations”), which require that the agency “complete the section 106 process ‘prior to the issuance of any license.’” 36 CFR 800.1(c). This regulation also makes clear that the purpose of initiating the section 106 process early in project planning is to ensure “that a broad range of alternatives may be considered during the planning process”. 36 CFR 800.1(c).

Disturbance or destruction of these sites would further erase traces of a part of our history, and a still living segment of our culture that is already too often ignored – that of this region’s first peoples.

To disturb these ceremonial features is damaging to the religious sensibilities of our Native citizens who still embrace the beliefs of their forebearers. Proceeding without full Tribal participation “in the resolution of adverse effects” is an unconscionable act that also violates the NHPA Regulations, specifically 36 CFR 800.2(c)(2)(ii)(A).

Regardless of our heritage, all citizens of our region would be poorer for the loss of these original historic sites, and their destruction should not be allowed.

FERC should not allow the Project to proceed before this matter is fully and properly resolved. Furthermore, Sandisfield Taxpayers Opposing the Pipeline (STOP) filed a request for a rehearing of FERC’s order issuing the Certificate of Public Convenience and Necessity in April of 2016 that has yet to be acted upon. FERC should grant the rehearing request without further delay, taking into consideration issues raised by the Narragansett Indian Tribe, STOP, and others over the course of the FERC proceeding.

David Brule
Nolumbeka Project Co-President

cc:        Advisory Council on Historic Preservation, Office of Federal Agency Programs;
U.S. Army Corps of Engineers

Tennessee Gas Pipeline May Bulldoze Sacred Native Sites

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A letter from a Narragansett Indian Tribal official to the Federal Energy Regulatory Commission (FERC) and the federal Advisory Council on Historic Preservation (ACHP) accuses FERC of understating the “likely” destruction of “ancient ceremonial stone landscape features” along the path of Tennessee Gas Pipeline Company’s proposed new storage loop through Otis State Forest.

In his Jan. 3, 2017, letter, Doug Harris, the Narragansett Tribal Nation’s deputy tribal historic preservation officer and preservationist for ceremonial landscapes, said FERC’s Dec. 29, 2016, letter to Reid Nelson, director at ACHP, which was copied to preservationists from seven different tribes, “mildly portrays the dire” consequences of “bulldozing” sacred features on the company’s newly acquired easement there.

Read the entire story in The Berkshire Edge.