LIHI Certificate #124 – Comtu Falls Project, Vermont

Project Name	Comtu Falls
LIHI Certificate No.	124
LIHI Certificate Term	July 10, 2020 to July 9, 2030
Owner	Comtu Falls Corporation, a subsidiary of Gravity Renewables, Inc.
State	Vermont
Location	Located at river mile 4.4 on the Black River in Windsor County, Vermont.
Installed Capacity	0.46 MW
Average Annual Generation	2,300 MWh
Facility Type	Run-of-river
FERC No.	P-7888 issued in 1986, expires 06/30/2026

The Comtu Falls Project is located on the Black River in the City of Springfield, Vermont. The Black River is a tributary of the Connecticut River and the project is the third dam on the Black River. There 14 dams on the Black River, with five hydro facilities in a 3/4 mile stretch in Springfield. The downstream dams are the Lovejoy Dam and Slack Dam (LIHI #78) while dams upstream of the project include Gilman, Fellows, and US Army Corps of Engineers North Springfield flood control dam, as well as the Cavendish Project (LIHI #97).

The project dam was built in 1902 and hydropower was added in 1987. The project includes a 4-foot-high, 128-foot-long concrete gravity dam, tapering from 5.5 feet high at its western side to zero feet high at its eastern side with irregular bedrock comprising the last 17-18 feet, situated on top of a natural falls. Two-foot-high wooden flashboards are installed on 74 feet of the dam. The intake structure is located at the west side of the dam with a 1.5-inch clear bar spacing trash rack set at a 45-degree angle to the intake. The penstock is 6 by 6 feet wide and 65 feet long and made of reinforced concrete. The powerhouse houses one vertical Kaplan turbine/generator with a capacity of 460 kW.

The project operates in a run-of-river mode and impounds a 0.4-acre reservoir that extends approximately 150 feet. There is a very short, 100-foot-long bypassed reach. A 4-cfs minimum flow, 0.5-inches of flow over the flashboards is provided for aesthetic purposes whenever river flow is 44 CFS or greater. When inflow is less than 44 cfs, all flows are spilled over the falls. Impoundment levels are monitored using a pressure transducer that sends water level information to the project’s Programmable Logic Controller (PLC). The PLC automatically adjusts the turbine blade settings or powers down the turbine depending on the readings from the pressure transducer, ensuring run-of-river operations.

Waters within the project reach are designated as Class A2, suitable for fish and aquatic biota habitat, wildlife support, and primary/secondary contact recreation. The waters are listed as impaired for sediment, nutrients and E. coli, due to combined sewer overflows, upstream urban runoff, land development. Stressed uses include aesthetics, aquatic life (biota and/or habitat support) and direct contact recreation. The project does not contribute to this impairments.

Downstream dams prevent upstream fish passage at the project. Migratory species have not been observed in the project vicinity due to passage barriers in the Connecticut River. Consultation with the Vermont Agency of Natural Resources concluded that the natural falls at the project has historically been a natural barrier to upstream passage. The project provides 20 cfs into a downstream fish passage facility which consists of a 2.5-foot-wide by 3.0-foot-high discharge weir at the west abutment of the dam leading to a 3-foot-deep plunge pool. The project operates the passage facilities from April 1 – June 15 annually and voluntarily operates passage in the fall from September 15 – November 15.

The project lands consist of roughly 2 acres. The project does not have any natural shoreline, most of the shore is armored or developed. Run-of-river operations further minimize any potential for shoreline erosion or adverse impacts.

Threatened or endangered species potentially present in the project vicinity include the Northern long-eared bat and Northeastern bulrush. The bulrush is a flowering plant found in emergent wetlands, of which there are none in the project area, thus it is unlikely to occur at the project. Similarly, the project area does not provide any roosting habitat or hibernacula for the bat species.

The Comtu Falls Dam is included in the Springfield Downtown Historic District, listed on the National Register of Historic Places. Consultation with the Vermont Historic Preservation Office is conducted for any construction at the project.

The project is very small, and the reservoir is not safely accessible. The falls and tailrace area are not safety accessible and are bordered by the industrial and commercial buildings owned by others. Access is not available and thus no recreational amenities are provided.

Compliance Status

The Certificate includes the following facility-specific conditions:

Condition 1: If either the USF&WS or the state fisheries management agency requires the facility to provide upstream eel passage in the future, the facility Owner shall notify LIHI within 30 days of receipt of such a notification. The Owner shall then consult with the requesting agency(ies) to develop plans to implement upstream passage and shall provide LIHI with a copy of these plans pursuant to the schedule required by the requesting agency(ies), but no later than one year after receiving the notification.

Condition 2: For the full term of the LIHI certification, the facility Owner shall continue to operate the downstream fishway in the spring from April 1 through June 15 and in the fall from September 15 through November 15 or as otherwise requested by the state fisheries agency.

2023: No material changes or compliance issues were identified. The project remains in compliance based on the annual review. For Condition 1, the project report no change. For Condition 2, the project reported operating the fishway as required.

2022: No material changes or compliance issues were identified. The project remains in compliance based on the annual review. The project filed its FERC relicensing PAD on 06/30/21 and is using the Traditional Licensing Process. For Condition 1, the project report no change. For Condition 2, the project reported operating the fishway as required.

2021: Annual reporting for the current Certificate has not yet taken effect.

Certification History

January 1, 2022: The LIHI Certificate term has been extended in accordance with Revision 2.05 of the LIHI 2nd Edition Certification Handbook issued January 1, 2022. Refer to the facility table above for the new term.

August 6, 2021: The Low Impact Hydropower Institute has issued a final decision on the recertification of the Comtu Falls Project located on the Black River in Vermont. The 30-day appeal window closed on August 5, 2021 and no appeals were filed. Therefore, the decision to certify the project is now final. The new term is July 10, 2020 through July 9, 2025.

July 6, 2021: The Low Impact Hydropower Institute (LIHI) has preliminarily approved the Comtu Falls Project for a new 5-year term of Low Impact Certification. This decision is preliminary pending the 30-day appeal window. Only those who commented on the initial application during the 60-day comment period are eligible to file an appeal. Such appeal needs to include an explanation as to how the Project does not meet the LIHI criteria. Appeal requests can be submitted by email to comments@lowimpacthydro.org with “Comtu Falls Project” in the subject line, or by mail addressed to the Low Impact Hydropower Institute, 1167 Massachusetts Ave, Office 407, Arlington, MA 02476. All requests will be posted to the website. The applicant will have an opportunity to respond and any response will also be posted. Requests must be received by 5 pm Eastern time on August 5, 2021. The full application and reviewer’s report are available below. If no appeal requests are received and the decision becomes final, the Certification term for the Project will be July 10, 2020 through July 9, 2025.

April 19, 2021:The Low Impact Hydropower Institute (LIHI) has received a complete recertification application from Comtu Falls Corp. for the Comtu Falls Project located on the Black River in Vermont. The complete application can be found below. LIHI is seeking comment on this 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 at comments@lowimpacthydro.org with “Comtu Falls Project Comments” in the subject line, or by mail addressed to the Low Impact Hydropower Institute, 1167 Massachusetts Avenue, Office 407, Arlington, MA 02476. Comments must be received at the Institute on or before 5 pm Eastern time on June 18, 2021 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.

December 23, 2015 – LIHI Executive Director Michael J. Sale, using authority delegated from the LIHI Governing Board and a full review of the Application Reviewer’s report and all public comments and additional materials provided by the Applicant, has certified that the Comtu Falls Hydroelectric Project (FERC No. P-7888) satisfies the LIHI Certification Criteria. A Preliminary Decision was announced on October 12, 2015, and a 30-day appeal period was open through November 12, 2015. No requests for appeal were received. This Certification Decision includes one facility-specific condition, as follows:

Condition 1. The Owner shall operate the downstream fish passage facilities annually from April 1 through June 15 and from September 15 through November 15.

The effective certification date for the Comtu Falls Project is July 10, 2015 for a five (5) year term, which will expire on July 10, 2020.

July 13, 2015 – On July 10, 2015, the Low Impact Hydropower Institute (LIHI) received a complete application from Comtu Falls Corporation, on behalf of Gravity Renewables Inc., for the Low Impact Certification of the Comtu Falls Hydroelectric Project, FERC P-7888, located on the Black River in Windsor County, Vermont.