Prior to the renovations, the plant was non-jurisdictional because it predated the Federal Power Act. Prior to the renovations, the plant was non-jurisdictional because it pre-dated the Federal Power Act. Now that the equipment is being updated, the plant falls under the commission's jurisdiction. The company, which is currently rated at 1.9 megawatts, will be rated at 2.1 megawatts after the project is complete, said Martha Brennan, regulatory affairs coordinator of Swift River Company, which owns Pepperell Hydro.
The last time the penstock was replaced was around 1950, said Peter Clark, manager of Pepperell Hydro Company, during a public meeting on Dec. 11. Because the wooden structure was several decades old, it was leaking in several places, reducing the capacity of the plant.
"Water is essentially fuel, so if you've got some of it squirting out the penstock, you're not going to get as much efficiency," said Brennan.
This past fall, the old penstock was removed and is currently being replaced by a steel penstock. Portions of the penstock are being shipped up from Georgia and are currently being installed.
One of the turbines that had been damaged in 2011 has also been replaced by new, modern equipment.
"That whole rehab is triggering the need to get a license," said Clark.
In addition to replacing the penstock, Pepperell Hydro has installed a notch in the dam to allow access for fish to swim downstream without getting caught in the penstock.
Although this is not technically required under FERC's regulations to receive a license, "We felt that we wanted to work with Fish and Wildlife
Service who asked us to install a fish passage," said Clark.
The passage is in preparation of future requirements by the Department of Fishery and Wildlife.
"We are anticipating that they're going to require us to have fish passage at some point, so it made sense while we were repairing the flashboards to install," said Brennan.
Below the notch is a pool to allow the fish a soft landing. Currently, there are no immediate plans to install an upstream passage but the concept will likely be reevaluated at a later date.
Under FERC's guidelines, Pepperell Hydro was required to hold the public meeting to get feedback from the community members as well as local agencies. Several members of the public came out for the discussion of the licensure, from local fishermen to members of the Nashua Water Shed Association to members of MassWildlife.
The purpose of the meeting, said Brennan, is to allow for a mutually beneficial, structured environment for the agencies to understand the process and voice concerns.
"We want to cast as wide a net as possible to make sure any concerns that people have out there are addressed," said Brennan.
Prior to the meeting, said Al Nash, project engineer, "We did begin some consultation with various resource agencies and amongst those items that were identified was the need for fish passage and also water quality concerns and minimum flow requirements."
Martha Morgan of the Nashua Watershed Association, who was present at the meeting, also mentioned some concerns over the impoundment being affected a few miles upriver. For these kinds of concerns, said Brennan, the agencies can submit comments or requests for more studies to FERC. Now that the meeting has been held, agencies have 60 days to submit comments if they choose.
In general, said Brennan, she expects the process to be fairly low controversy.
"As far as citizen involvement, the kinds of triggers that cause most citizen groups to get involved usually involve things like nuclear power," she said. "The plant has been here for a while. If there was a huge environmental impact, it would already be showing."
The FERC license will allow the company to have a clear set of regulations. As a non-jurisdictional facility, they have to go through several agencies to receive permission for projects such as replacing the penstock. With the license, the regulations will come down from the federal level.