LIHI Certificate #40 - Vernon Project, New Hampshire/Vermont

The Vernon Project, located at river mile 142 on the Connecticut River, consists of a concrete gravity dam (a 500-foot-long overflow spillway with 10-foot high flashboards, a 100-footlong gated sill block with two 20-foot-high by 50-foot-long tainter gates, and a 336-foot-long non-overflow section) and powerhouse. The project operates as a daily cycling generating facility with limited storage and has a minimum flow requirement, set in the 1979 relicensing, of 1250 cfs.

The Environmental Assessment associated with the 2006 license amendment describes the flow regime as follows:

“Flows in this reach of river are highly regulated by upstream hydroelectric projects, except under high flow conditions. Typically when flows are less than the project’s hydraulic capacity, the project operates in a daily cycle run-of-river mode, where daily inflow matches daily outflow. Generation can vary in the day between the required minimum flow and full capacity if flows are available. The minimum flow at the project is 1,250 cfs or inflow, whichever is less.”

The 401 Certification issued for the license amendment notes:

“The Applicant operates the Vernon Hydroelectric Project on a daily cycle, receiving inflow from upstream hydroelectric storage and un-regulated inflow. The Applicant stated that water level fluctuations greater than two feet occur infrequently in the Vernon impoundment, as the normal reservoir operating range is 218-220 ft above mean sea level.”

The powerhouse structure and dam contain 10 Francis type turbines. Units 1 through 7 operate at 133.5 RPM and units 9 and 10 operate at 75 RPM.

The Federal Energy Regulatory Commission (FERC) relicensed the project in 1979. In a 1992 license amendment FERC authorized replacement of the circa 1909 dam’s four remaining original three-wheel turbines. The new authorization would have increased the generating capacity of the project from 24.4 megawatts (MW) to 44.4 MW and raised the total hydraulic capacity of the project from 15,530 cubic feet per second (cfs) to 20,930 cfs. However, the owner at the time never installed the turbines, and the project changed ownership, eventually being acquired by the applicant in 2005. After the acquisition the applicant applied to FERC for another license amendment to replace the antiquated and inoperable turbines. Instead of installing two 14.0-MW units, as authorized in the 1992 amendment, the applicant asked to replace the four existing inoperable 2.0-MW turbines with four new 4.0-MW units.

The following agencies were consulted prior to the filing of the amendment, and none objected to the project:  United States Department of Interior Fish and Wildlife Service (DOI/USFWS), New Hampshire Department of Environmental Services (NHDES), New Hampshire Fish and Game Department (NHFG), Vermont Department of Fish and Wildlife (VDFW), Vermont Agency of Natural Resources (VANR), New Hampshire Division of Historic Resources (NHDHR), Vermont Division of Historic Preservation (VTDHP), US Army Corps of Engineers (USACE), an advisory committee to the Connecticut River Joint Commissions, and the Town of Hinsdale Conservation Commission. The following agencies provided post-filing comments expressing concerns about natural resource issues and providing recommendations:  DOI/USFWS, VANR, NHDES, and the Connecticut River Watershed Council.

FERC issued a license amendment approving the change in 2006. The change decreased the project’s total authorized generation capacity from 44.4 MW to about 32.4 MW. The maximum authorized hydraulic capacity decreased from 20,930 cubic feet per second (cfs) to 17,130 cfs; however, the change increased hydraulic capacity compared to the existing conditions by 1600 cfs. The added generation first generated electricity in 2008, and did not change the facility’s mode of operation.

Project Name Vernon
LIHI Certificate No. 40
LIHI Certificate Term December 15, 2013 December 15, 2018Extended to December 31, 2021
Owner Great River Hydro, LLC
State New Hampshire, Vermont
Location Located at river mile 142 on the Connecticut River, in Cheshire County, New Hampshire and Windham County, Vermont.
Installed Capacity 32.4 MW
Average Annual Generation 162,557 MWh (2008-2016)
Facility Type Daily cycling
FERC No. P-1904 issued 1979, expired 2019 - in relicensing

Certification History

December 17, 2020: The Vernon project's LIHI Certificate has been extended again until December 31, 2021 in order to allow for LIHI to address the unique situation of a recertification taking place at a time within a FERC relicensing when studies have been completed but no agency recommendations are available yet.

February 26, 2020: The Vernon project's LIHI Certificate has been extended until December 31, 2020 in order to allow for LIHI to address the unique situation of a recertification taking place at a time within a FERC relicensing when studies have been completed but no agency recommendations are available yet.

July 13, 2019:  The public comment period has closed, the application remains under review pending receipt of additional information.

July 2, 2019:  The public comment period for the Vernon recertification application has been extended to 5 pm Eastern time on July 12, 2019. All comments must be received by that time to be considered.

May 7, 2019: The Low Impact Hydropower Institute has received a complete application for Low Impact Recertification of the Vernon Hydroelectric Project.  LIHI is seeking public comment on this application.  Specifically, we are interested in knowing whether you think the Project meets the LIHI Low Impact Certification Criteria, as revised in the 2nd Edition Handbook.  Please review the program and criteria in LIHI’s revised Handbook and then review the Project’s application materials below.

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 with “Vernon Project Comments” in the subject line, or by mail addressed to the Low Impact Hydropower Institute, 329 Massachusetts Avenue, Suite 6, Lexington, MA 02420.  Comments must be received on or before 5 pm Eastern time on July 6, 2019 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.

May 15, 2016: LIHI received notice that TransCanada Hydro Northeast Inc. was converted to a limited liability company on April 7, 2017, becoming TransCanada Hydro Northeast LLC.  On April 19, 2017, the name of the company was changed from TransCanada Hydro Northeast LLC to Great River Hydro, LLC.

October 21, 2016:  On September 19, 2016, LIHI announced the Preliminary Decision that the Vernon Station Hydroelectric Project (FERC No. P-1904) satisfies the 2014 LIHI Certification Criteria.  A 30-day appeal period was open until October 20, 2016, and no requests for appeal were received.

The Vernon Station Hydroelectric project is now deemed certified by LIHI. The effective date for the Vernon Station certification is December 15, 2013 for a five (5) year term, which will expire on December 15 2018.

This Certification Decision includes six facility-specific conditions, as follows:

  • Condition 1:The facility must provide effective upstream and downstream fish passage and protection for migratory fish species.  Therefore, the Owner shall continue consultation with the USFWS, VANR, VFWD and NHFG to identify appropriate measures to pass juvenile shad downstream, as well as for any other migratory species that the agencies deem appropriate. If any agency recommends that improvements are needed to achieve satisfactory downstream passage, the Owner shall provide to LIHI a copy of those recommendations, along with the Owner’s position on those improvements as soon as is practicable.  No later than December 31, 2016, and annually after that date, the Owner shall report to LIHI on the status of fish passage improvements and associated agency consultations.
  • Condition 2:The Owner shall proactively consult with the resource agencies regarding possible interim opportunities to enhance fish passage for American eel and riverine species while the FERC relicensing activities are underway. Such opportunities may involve study and design of fish passage mitigation measures for these species so that they can be implemented more quickly once a new license is issued. During the term of this new LIHI certification, should a resource agency request implementation of upstream or downstream passage measures for anadromous, catadromous, or riverine fish as part of their recommendations/mandates under the new licensing proceedings, the Owner shall notify LIHI within 30 days, provide LIHI with a copy of the request, and describe the Owner’s plan to address these requests.
  • Condition satisfied 2017. Condition 3:The Owner shall develop a plan and schedule for repair and maintenance of the recreational facilities at the Governor Hunt Picnic Area, including the boat launch, trash collection, and sanitary facilities.  The Owner shall make best efforts to ensure these recreational facilities are well maintained. The recreation plan and schedule for its implementation shall be submitted to LIHI as soon as practicable, but no later than June 30, 2017.
  • Condition 4:The Owner will provide a concise letter report to LIHI annually, providing a status report on FERC licensing progress, listing significant agency interactions that have occurred in the past year that are relevant to LIHI’s certification criteria, and highlighting major topics of agreement or disagreement.  This report will be provided to LIHI as part of the owner’s annual compliance statement.  LIHI reserves the right to request additional details if necessary, if highlighted topics are relevant to LIHI’s certification criteria and their associated goals.
  • Condition 5:If the on-going FERC relicensing proceeding is concluded and a new Commission Order is issued for the facility during the term of the new LIHI certification, the Owner shall notify LIHI within 30 days of that action. Within 60 days of a new FERC license being issued, the owner shall provide LIHI with a report that identifies all material differences between the requirements of the new FERC license and the standards used to satisfy LIHI’s criteria or conditions on the new LIHI certificate. LIHI reserves the right to adjust any and all conditions on the LIHI certificate, pending the outcome of the FERC relicensing, to ensure consistency between the LIHI certificate and the new FERC license.  If the on-going relicensing proceeding is not concluded prior to the expiration of the term of the new LIHI certification, no action is required on this condition.
  • Condition 6:  The Connecticut River basin is highly developed for water resources and the operation of multiple hydropower facilities and other water uses in the basin are interconnected to a degree that requires a systematic approach for future water management.  Solutions for individual facilities are insufficient to achieve the environmental protection and restoration needed for long-term, sustainable water uses.  Therefore, the owner of the Vernon facility shall continue to play a constructive, supportive role in promoting integrative water management in the basin, both in the ongoing FERC relicensing and in other regulatory proceedings that may develop in the basin.  The owner shall report to LIHI on its activities relative to this condition each year in its annual compliance report. LIHI reserves the right to modify the certificate conditions again if needed.

This LIHI recertification is taking place in the middle of a very complex set of FERC relicensing proceedings, the outcome of which is not at all clear at this time.  While the current LIHI certification decision is based on findings that indicate the Vernon facility satisfies the LIHI criteria defined in the applicable, April 2014 version of our Certification Handbook, the environmental conditions in the Connecticut River are dynamic and changing — the full effects of issues such as the shutdown of the Vermont Yankee Nuclear Power Plant, the changing status of Atlantic salmon, American shad, and American eel stocks, etc., will continue to evolve. LIHI’s current decision on a new certification covering the period from 2013 to 2018 should not be interpreted as an indication that the Vernon facility’s current effects on the river basin will continue to be satisfactory over the longer-term future.  The next time that Vernon comes due for recertification, LIHI’s decision will be based either on the new, 2nd Edition Certification Handbook or on subsequent revisions if they occur.  LIHI strongly encourages the Vernon owner to work with all stakeholders in the basin to reach long-term, sustainable solutions to water management that will produce positive outcomes for both clean energy and the environment.

September 19, 2016:  LIHI Executive Director Michael J. Sale announced a Preliminary Certification Decision that the Vernon Station Hydroelectric Project (FERC No. P-1904) satisfies the 2014 LIHI Certification Criteria and will be issued a new LIHI certification with an expiration date of December 15, 2018. This certification decision was made by the LIHI Governing Board’s Technical Committee after a full review of the Application Reviewer’s report, all public comments and additional materials provided by the Applicant.

Once final, the effective certification date for the Vernon Station Project is December 15, 2013 for a five (5) year term, which will expire on December 15, 2018. As provided for in Section 4.2.5 of the LIHI 2nd Edition Handbook, the Preliminary Certification Decision to certify, along with the Application Reviewer’s report will be posted on the Institute’s Web page for 30 days.  The Application Reviewer Report and all the application materials are available at the bottom of the page. Individuals or organizations that commented on the initial Application Package (“Commenter”) may submit a letter to the Executive Director requesting an appeal within the 30-day period beginning on September 19, 2016, and closing on October 18, 2016. The appeal request must state specific reasons why the hydropower facility should have failed one or more criteria. If an individual or organization did not comment on the initial Application Package, they may not file an appeal.

January 27, 2014: The Low Impact Hydropower Institute has received an application from TransCanada for a second term of certification of the Vernon Station Hydroelectric Project. The 2013 application was received on December 5th, but due to administrative backlog, the certificate has been granted a three month extension beyond the date of December 15th. The application materials can be found in the “Files” section below.

June 25, 2009: The Vernon Station Hydroelectric Project has been certified as low impact for a five year term, effective December 15, 2008 and expiring December 15, 2013.