How to Kill A Dam
A very New England story
Today, Green Tape is publishing its second guest post, authored by the pseudonymous F. Ichiro Gifford. Gifford is an energy analyst at an electric utility, a Senior Fellow at the Defense Analyses and Research Corporation (DARC), and the author of the Energy Crystals blog on Substack.
Disclaimer: The views and opinions expressed in guest posts do not necessarily reflect the official position or views of Green Tape.
Vermont is a strange state with respect to energy. It doesn’t have any domestic fossil fuel production; it gets all its natural gas from Canada; and it is too dark, mountainous, and forested to facilitate large-scale solar farms.
What Vermont’s geography does offer is a network of rivers, streams, and dams that have enabled Vermont utilities to utilize a fleet of hydroelectric generators, from Bellows Falls to Winooski One to the Green River Hydroelectric Dam. Green River is—was—a hydroelectric dam managing a reservoir in the Green River State Park. And for the small utility Morrisville Water and Light, the dam made up a good chunk of their power supply. Plus, the dam had a special party trick: pondage. By adjusting the waterline of the reservoir behind the dam, Green River could make its electricity “dispatchable,” allowing the dam to ramp production up or down to meet demand.
Dispatchability, Briefly
The core challenge with renewable electricity generation systems—solar and wind, particularly—is that they’re intermittent: they only generate when the sun is shining or the wind is blowing. Especially in New England where the weather is famously unpredictable, this creates significant planning and reliability challenges.
By contrast, generators using conventional fossil fuels like natural gas are dispatchable, and can thus respond to changes in demand. This has long been a challenge for climate hawks, as replacing gas with renewables means reducing the grid’s ability to respond to demand fluctuations. But hydroelectric dams are unique in this respect. While they’re dependent on precipitation and are vulnerable to droughts, rivers don’t abruptly stop flowing in the middle of the night. They’re not all dispatchable, but they’re more predictable than wind or solar power. And of course, they’re clean.
Furthermore, some hydro facilities are dispatchable: If the hydroelectric dam holds a reservoir behind it, it can typically adjust the waterline to vary electric output. Reducing water flow reduces electric generation; increasing water flow increases it. This allows a hydroelectric facility to achieve the effect of battery storage without the costs and supply chain challenges of megawatt-scale batteries.
The Green River Dam had this capacity at a small scale. Its 1.8 megawatt output was small compared to the rest of the grid, but it helped stabilize electric prices for the 4000 local ratepayers.
As an electric utility analyst, I think this is great. Unfortunately, the Vermont Agency of Natural Resources (ANR) had other ideas.
The History of Morrisville v. FERC
Morrisville Water and Light operates three hydroelectric facilities—two on the Lamoille River, and one on the Green River. All three of these facilities were licensed by the Federal Energy Regulatory Commission (FERC) from 1981 to 2015. As the expiration date rolled in, Morrisville applied for a new license in 2013 and a water quality certificate less than a year later.
ANR responded that Morrisville’s submission was incomplete. The agency wanted dramatic changes, asking Morrisville to completely redesign how the dam operated, converting it from a flexible power generation facility to a "run-of-river" system that would simply let water flow through. This would eliminate Morrisville's ability to store water and serve as a dispatchable electricity source.
In response, Morrisville provided a series of revisions, hoping to preserve some of their operational flexibility while satisfying ANR's environmental concerns. But by the end of the third round of revisions in October 2014, Morrisville could see they were at an impasse. Rather than face outright rejection, they withdrew and resubmitted their application. A year later, they withdrew and resubmitted again.
By this point, ANR had hardened its stance, adding even more stringent requirements around water quality. So Morrisville escalated, first to the Vermont Supreme Court, and then to FERC in 2020, arguing that ANR had taken so long to review their water quality certification that their "deliberate and contractual idleness" counted as refusal to act.
FERC wasn’t convinced. While Morrisville Water and Light had been waiting on ANR to approve their certification for years, the court reasoned that Morrisville had ultimately made the decision to withdraw its applications unilaterally.
Finally, in January of this year, The DC Court of Appeals heard oral arguments on the case. But it was irrelevant—Morrisville Water and Light had already given up on the Green River Dam. The previous March, the utility had filed notice with FERC of their intent to surrender their federal license. Now, Morrisville will focus on relicensing the two hydro plants on the Lamoille River—run-of-river plants which do not have ponding capacity and thus, unlike Green River, cannot ramp generation up or down to meet demand.
Some People Think We Have Enough Energy
In late 2022, ANR Secretary Julie Moore met with a group of stakeholders, including a representative from the Department of Environmental Conservation (DEC). Their focus was telling. Rather than discussing Vermont's energy needs, the press release emphasized environmental concerns:
Vermont has over 1,000 dams and the DEC estimates that hundreds no longer serve a useful purpose. Many of these dams degrade water quality and aquatic habitat, restrict the movement of fish and other wildlife, increase maintenance and liability costs, and pose significant risks to public safety.
Moore's own comments doubled down on this perspective:
The agency, in coordination with the Vermont Dam Task Force, is dedicated to restoring rivers through the vigorous assessment within the context of Vermont's natural resources, cultural, and historic values. This statewide cooperative effort among federal and state agencies, private organizations, and individuals has improved public safety and benefited the environment for Vermonters and visitors alike.
This stance is particularly striking given Vermont's unique energy challenges. The state has no pipeline link to the boom in shale natural gas, leaving its urban spine reliant on Canadian gas and its rural reaches dependent on fuel oil and firewood. Its largest power plant, the Vermont Yankee nuclear power plant, closed in 2013, leaving the state dependent on its neighbors for electricity.
Despite these vulnerabilities, Vermont has untapped potential for energy independence. It has a thriving logging industry, well-separated from the patches of old-growth forest left in the state. It has mountain peaks and the wind corridor of Lake Champlain, both well-situated for wind generation. And it has more than a thousand dams, many of which could provide predictable, renewable, local electricity that would insulate Vermont from tariffs, critical minerals shortages, and fluctuations in global energy prices. A well-considered combination of wind, hydroelectric, and biomass could pull together a financially and ecologically sustainable energy system for the state, without relying on energy imports from Massachusetts, New York, or Quebec.
But the ANR's priorities lie elsewhere. Their website says shockingly little about hydroelectric power outside of a cursory webpage. Almost all the materials linked are 10-20 years old. They simply don't seem interested.
Many leaders in New England think this way. They would rather dams be removed, infrastructure licenses revoked, and permitting requirements tightened in service of “rural character” and “historic values” than expand much-needed clean baseload generation. This thinking will destroy the region. As Renewable Electricity Standards constrain the amount of gas that states allow themselves to use, states are simultaneously suffocating their clean generation with permitting, licensing, and siting requirements.
The Green River Dam's fate shows where this path leads. A small but valuable source of dispatchable clean power has been sacrificed, not because it was failing or dangerous, but because regulatory requirements made it impossible to operate. As electricity demand reaches historic highs across the United States, New England cannot afford to keep dismantling its clean energy infrastructure in the name of environmental purity.
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