Enron Redux in New England

Posted by on 14 Oct 2014 | Tagged as: Brayton Point coal plant, Cheryl Lafleur, Energy Capital Partners, Enron, Federal Energy Regulatory Commission, GDF-Suez FirstLight, Greenfield Recorder, Mt. Tom Coal Plant, Northfield Mountain Pumped Storage Project, Public Citizen, Rutland Herald, Times Argus

Note: the following piece appeared in September 2014 in the Sunday edition of the Rutland Herald(www.rutlandherald.com); the Times-Argus in Montpelier, VT(www.times-argus.com),  and The Recorder in Greenfield, MA(www.recorder.com).

Copyright © 2014 by Karl Meyer

ENRON REDUX

Kids: go to your parent’s bedroom and find mommy’s purse and take $110 out of it. Then go out and have some fun. Why? Because the Federal Energy Regulatory Commission and its own creation–the Holyoke, MA-based Independent System Operator of New England (ISO-NE), just confirmed that it’s ok to steal. The theft took place in June at a rigged ISO-NE “forward market” energy auction. There, Hartford-based Energy Capital Partners made off with the public’s loot to the tune of $110 from every New England ratepayer, according to consumer watchdog Public Citizen.

In a pre-dawn, September 17th press release, FERC Chair Cheryl LaFleur argued that it was legitimate for corporate-citizen ECP to manipulate the market and pick the pockets of ratepayers from Hartford to Springfield, and Boston and Montpelier—three years in advance. That panicked missive arrived directly on the heels of two FERC Commissioners, Norman Bay and Tony Clark, issuing their own September 16th press release terming the summer ISO-NE ratepayer swindle a “non-competitive auction.” It was a tiny crack in the curtain surrounding FERC decisions. In a split vote, LaFleur and one other Commissioner voted against intervening in the bogus outcome—thus tabling it, and letting the theft stand as legitimate commerce.

Given that, I’m figuring parents would prefer their kids got the cash, rather than a clique of market manipulators. Give your child a head start.

According to Public Citizen, FERC’s failure to intervene will have New Englanders forking out and additional $1.4 billion for the inflated BTU prices ECP manipulated into place for energy to be delivered three winters hence. That, Public Citizen says, will cost each of us over a hundred bucks.

With LaFleur providing the leadership, FERC, our public watchdog on energy projects, rates, regulation and reliability, gave the nod to its puppet-cousin ISO-NE–signaling that its “independent” actions letting ECP game the auction system were acceptable business as usual.

Just like stealing from your parents, Energy Capital Partners was pretty brazen in their market rigging. What they did was purchase an old New England dinosaur, the Brayton Point coal plant in Somerset, MA in 2013. Then, just weeks later, they announced they would be closing Brayton Point–citing environmental and economic constraints. That closure was timed perfectly to influence “forward” market prices. It would take place in May 2017—creating an energy “deficit” timed to show up on the books precisely as the 2017 energy auction was to take place. That staged BTU shortfall caused the spike in prices and accepted forward market bids at ISO-NE’s auction—all to be born at the public’s expense.

ECP will profit handily from their own paper tiger—silent proceeds flowing like electric current to investors, steered directly through ECP’s five other New England venture capital energy plants. That’s how you spike an energy market. It’s the stuff investors gush over.

FERC is charged with ensuring fair pricing for the public, as well as energy reliability in a deregulated market. In its own words its core responsibility is to “guard the consumer from exploitation by non-competitive electric power companies.” It was FERC that created ISO-NE, the regional grid’s independent system operator charged with keeping the lights on in the public’s interest. It’s now clear ISO also referees sham auctions.

Maybe New Englanders won’t mind getting their pockets picked; utility bills are clever at never revealing what you’re actually paying for. But I mind–$110 isn’t chump change to me. I’m worried too that today it’s FERC that’s also overseeing virtually all the controversial energy proposals now swamping the New England region: from mega Northern Pass power lines entering from Canada, to the Tennessee Gas Pipeline, to the relicensing of five large-scale hydro projects on the Connecticut River including the Northfield Mountain Pumped Storage Project.

Curiously, Energy Capital Partners sold the Northfield Mountain Pumped Storage Plant to GDF-Suez FirstLight Energy over half a decade back. Now it looks like FirstLight may be taking a page out of ECP’s market playbook. They just requested an open-ended and unprecedented “emergency” power uprate and a 20% increase in storage capacity for NMPS, due to a perceived–but as yet undocumented, energy shortfall for the coming winter. What FirstLight withheld in its lengthy application arguments to FERC, was that it is closing down its own 135 megawatt Mt. Tom coal plant in Holyoke this October. Create your own energy deficit. It is also an end-run around environmental relicensing studies set to take place next year. We’ll all pay.

So if you thought “no-bid” government contracts were a thing of the past and that energy market manipulation and wash-through trades were a distant echo of the Enron and Arthur Anderson scandals, think again. Given the pressing concerns of climate change and the dismal record of market manipulation, the time has arrived to re-regulate energy.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists.

Stakeholder COMMENTS to FERC on Northfield Up-rate Request

Posted by on 10 Oct 2014 | Tagged as: Connecticut River ecosystem, Federal Energy Regulatory Commission, FERC, GDF-Suez FirstLight, ISO New England, Northfield Mountain Pumped Storage Project

*The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on October 2, 2014.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 October 2, 2014

The Honorable Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, NE
Washington, DC 20426

COMMENTS: on P- 2485-065, GDF-Suez FirstLight Hydro Generating Company’s:
Application for Temporary Amendment of Minimum and Maximum Reservoir
Elevation Requirement.

Dear Secretary Bose,

The Northfield Mountain Pumped Storage Project is currently undergoing
studies under the 5-year FERC relicensing process in order to continue
plant operations beyond 2018. NMPS was built as a peaking power plant—
making use of the surplus power generated from a cluster of Western New
England nuclear power facilities: Yankee Atomic, Vermont Yankee, and
Haddam Neck. Yankee Atomic and Haddam have long-since ceased operation,
and VY will close on December 29, 2014.

After that date, NMPS is requesting to remain in service as an entirely
different entity: a peaking plant, with no surplus regional nuclear power
to draw on. It will then be relying on coal, oil, gas, and imported
hydro to pump water uphill—a very expensive and inefficient process,
consuming what amounts to baseload energy to create peaking generation.
This will be bought on the open market; then resold to ratepayers at
peaking-market prices. The first question that must be asked is: is it
fair to consumers?

Why should such an open-ended power up-rate be allowed when stakeholders
are deep in the discovery phase of the relicensing process? Studies just
months down the road will help determine the current operational,
commercial and environmental impacts of NMPS.

This open-ended request uses NMPS’s “emergency” capabilities as a veil.
In truth, as ISO-NE well knows, it can—and does, take over NMPS on rare
emergency occasions, paying market rates to GDF-Suez for the plant’s
output. Thus, hiding behind an “emergency” goodwill intention is not a
forthright argument from FirstLight, and should not be accepted rationale
for granting NMPS an open-ended and, unstudied, 20-plus percent power
generation capability increase.

Looked at head-on, this is an attempt to turn a plant into a facility
that would now generate using legacy fuels to supply ratepayers with
peaking-priced, spot-marketed power in a quasi-baseload producer fashion.
If FERC were to allow such an increase for a full one-third of a year, it
would be creating a whole new animal in the energy market—without a
requisite public process.

FirstLight’s argument in its generation and storage capacity increase is
that it will be available for “emergency” situations which might arise in
winter markets. The reality is—request aside, NMPS is and has always
been a station prescribed for emergency use. That has been a chief
selling point since it opened 1972. And, it is still available as such—
without any amendments to its current license. Thus, no changes should
be made to current operational limits, as the plant can be called upon
under unusual-event circumstances by ISO within all currently sanctioned
parameters.

Allowing NMPS to begin generating as a baseload plant
without study or understanding of the full impacts of longer pumping and
generation would be an abrogation of FERC’s public responsibilities.
Under current operating conditions, NMPS creates what amount to erosive
tidal conditions in the Turners Falls Impoundment that exceed the daily
tides experienced at Hyannisport, MA. The requested new pumping and
expanded limits at NMPS during winter months will undoubtedly result in
an increase in erosion and sediment load in the river and at the NMPS
reservoir. Daily increases in freezing and thawing along sensitive
riverbanks dictate that.

In 2010 FirstLight attempted to clear its reservoir of sediment and failed
to accomplish the task. The result was a complete outage lasting seven months,
with NMPS unavailable for any emergency output. Most troubling was that
FL attempted to clear its reservoir and intakes by shoveling the silt and muck
directly into the Connecticut River. The EPA issued a cease and desist order in early
August, and FL was found to be in gross violation of the federal Clean
Water Act for polluting the navigable waters of the United States.

It should also be helpful to know that NMPS has never successfully
discharged the silt from its reservoir in its entire history without
experiencing a partial or full outage in its turbine battery. Given that
history, allowing NMPS to potentially create more siltation in the CT
River at their plant should not be allowed until they have proven it will
not impact emergency operations.

Further, attempts by a previous owner to utilize more of the NMPS
reservoir in the 1980s were turned back by a public process that
shed light on the fact that increased pumping of the Connecticut River
would result in significant impacts to the ecosystem. That request—to use
the Connecticut River as a drinking water source to be shifted up to the
NMPS reservoir and then transferred out of basin tothe Quabbin Reservoir,
was ultimately not implemented. In fact, it resulted in the implementation of
a new law, the Inter-Basin Transfer Act, which would only allow water to be
taken from the river in an emergency situation, after all logical engineering
steps were taken to plug holes and eliminate waste in the Boston water delivery
system.

That should be the situation going forward. NMPS remains in service as
currently licensed—available for use in specifically defined emergency
situations by ISO-NE, until studies are complete.

Lastly, is important to note that GDF-Suez FirstLight made no mention of
the closure of their own 135 megawatt Mt. Tom coal plant in Holyoke this
20141002-5022 FERC PDF (Unofficial) 10/2/2014 8:40:09 AM
fall, when they listed several outlier plant closures as reason for their
request to help as fill -in for a tight winter market. At the very least
that is disingenuous. Some might see it as market manipulation.

Thank you,
Karl Meyer, MS

FERC Notice of Northfield Mountain expansion request, and Public Comment period

Posted by on 05 Sep 2014 | Tagged as: Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Motion to Intervene, Northfield Mountain, Northfield Mountain Pumped Storage Project, Public Comment period

On September 4, 2014, the Federal Energy Regulatory Commission issued the following Notice of Application for FirstLight Hydro Generating Company’s request to expand operations at the Northfield Mountain Pumped Storage Project, P-2485-065. Public COMMENTS, MOTIONS TO INTERVENE, and PROTEST filings will be accepted by FERC for 30 Days from their September 4, 2014 Notice.

UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION

FirstLight Hydro Generating Company Project No. 2485-065

NOTICE OF APPLICATION ACCEPTED FOR FILING, SOLICITING COMMENTS, MOTIONS TO INTERVENE, AND PROTESTS

(September 4, 2014)

Take notice that the following hydroelectric application has been filed with the Commission and is available for public inspection:

a. Type of Application: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement

b. Project No.: 2485-065

c. Date Filed: August 8, 2014

d. Applicant: FirstLight Hydro Generating Company (Firstlight)

e. Name of Project: Northfield Mountain Pumped Storage Project

f. Location: The project is located on the east side of the Connecticut River, in the towns of Northfield and Erving, in Franklin County, Massachusetts.

g. Filed Pursuant to: Federal Power Act, 16 USC 791(a)-825(r).

h. Applicant Contact: Mr. John Howard, Director of FERC Compliance, FirstLight Hydro Generating Company, 99 Millers Falls Road, Northfield, MA 01360. Phone (413) 659-4489.

i. FERC Contact: Mr. Christopher Chaney, (202) 502-6778, or christopher.chaney@ferc.gov.

j. Deadline for filing comments, motions to intervene, protests, and recommendations is 30 days from the issuance date of this notice by the Commission. The Commission strongly encourages electronic filing. Please file motions to intervene, protests, comments, or recommendations using the Commission’s eFiling system at http://www.ferc.gov/docs-filing/efiling.asp. Commenters can submit brief comments up to 6,000 characters, without prior registration, using the eComment system at http://www.ferc.gov/docs-filing/ecomment.asp. You must include your name and contact information at the end of your comments. For assistance, please contact FERC Online Support at FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). In lieu of electronic filing, please send a paper copy to: Secretary, Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426. Please include the project number (P-2485-065) on any comments, motions to intervene, protests, or recommendations filed.
k. Description of Request: FirstLight is seeking temporary authorization to modify the upper reservoir’s upper and lower water surface elevation limits from 1000.5 and 938 feet, to 1004.5 and 920 feet, respectively. FirstLight proposes to use the additional storage capacity between December 1, 2014, and March 31, 2014. According to FirstLight approval of changes in the water surface elevations would result in an increase in the maximum daily generation from 8,475 megawatt-hours (MWh) to 10,645 MWh.

l. Locations of the Application: A copy of the application is available for inspection and reproduction at the Commission’s Public Reference Room, located at 888 First Street, NE, Room 2A, Washington, DC 20426, or by calling (202) 502-8371. This filing may also be viewed on the Commission’s website at http://www.ferc.gov/docs-filing/elibrary.asp. Enter the docket number excluding the last three digits in the docket number field to access the document (i.e. P-2485). You may also register online at http://www.ferc.gov/docs-filing/esubscription.asp to be notified via email of new filings and issuances related to this or other pending projects. For assistance, call 1-866-208- 3676 or e-mail FERCOnlineSupport@ferc.gov, for TTY, call (202) 502-8659. A copy is also available for inspection and reproduction at the address in item (h) above.

m. Individuals desiring to be included on the Commission’s mailing list should so indicate by writing to the Secretary of the Commission.

n. Comments, Protests, or Motions to Intervene: Anyone may submit comments, a protest, or a motion to intervene in accordance with the requirements of Rules of Practice and Procedure, 18 CFR 385.210, .211, .214. In determining the appropriate action to take, the Commission will consider all protests or other comments filed, but only those who file a motion to intervene in accordance with the Commission’s Rules may become a party to the proceeding. Any comments, protests, or motions to intervene must be received on or before the specified comment date for the particular application.

o. Filing and Service of Responsive Documents: Any filing must (1) bear in all capital letters the title “COMMENTS”, “PROTEST”, or “MOTION TO INTERVENE” as applicable; (2) set forth in the heading the name of the applicant and the project number of the application to which the filing responds; (3) furnish the name, address, and telephone number of the person protesting or intervening; and (4) otherwise comply with the requirements of 18 CFR 385.2001 through 385.2005. All comments, motions to intervene, or protests must set forth their evidentiary basis and otherwise comply with the requirements of 18 CFR 4.34(b). All comments, motions to intervene, or protests should relate to project works which are the subject of the license surrender. Agencies may obtain copies of the application directly from the applicant. A copy of any protest or motion to intervene must be served upon each representative of the applicant specified in the particular application. If an intervener files comments or documents with the Commission relating to the merits of an issue that may affect the responsibilities of a particular resource agency, they must also serve a copy of the document on that resource agency. A copy of all other filings in reference to this application must be accompanied by proof of service on all persons listed in the service list prepared by the Commission in this proceeding, in accordance with 18 CFR 4.34(b) and 385.2010.

Kimberly D. Bose,
Secretary.

The Hidden Costs of Northfield Mountain Pumped Storage

Posted by on 01 Sep 2014 | Tagged as: Connecticut River, Connecticut River ecosystem, ecosystem, Entrainment, Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Ludington Pumped Storage Plant, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, resident river fish, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic, Yankee Rowe Nuclear Plant

Copyright © 2014 by Karl Meyer

The hidden costs of Northfield Mountain Pumped Storage: after Vermont Yankee closes, FirstLight wants to ramp up pumping and profits

(a version of this piece first appeared in the Greenfield Recorder, August 23, 2014)

Vermont Yankee, the last of the region’s nuclear plants, will close in December. In response, GDF-Suez FirstLight’s Northfield Mountain Pumped Storage plant is looking to change its stripes. On June 27th it applied to the Federal Energy Regulatory Commission for a “temporary” license amendment to allow it broad new freedoms to consume unprecedented amounts of the Connecticut River from December 1, 2014 through March 31, 2015. That plan would add an additional 22 feet of pumping capacity to its 5-billion gallon reservoir, sucked directly from the river. More pumping is certain to create more riverbank erosion and draw more silt into that reservoir. It will also kill untold thousands of the public’s resident river fish.

The unprecedented request defies logic. Northfield was built specifically to use energy from local nuclear plants to push water up to its reservoir. In its request FirstLight also cited the closing of the 330 megawatt Salem Harbor coal plant as rationale for why it should be allowed to pump more, and grow larger. FirstLight Hydro Compliance Director John Howard stated, “The requested increase in operational flexibility is needed to provide ISO-New England with additional resources to deal with a potential shortage of energy in the Northeast this winter.” However Andrea Donlon of the Connecticut River Watershed Council found that ISO-New England, the grid’s Independent System Operator, had made no requests concerning Northfield, stating it expected to have adequate energy supply this winter.

FirstLight’s application failed to mention is that it is shutting down its own 135 megawatt Mt. Tom Coal Plant this October. Rather than the “peaking energy” and “emergency resource” plant it’s been since coming on-line in 1972, Northfield seems to be implying it will somehow serve as a replacement for those 24/7 “baseload” energy plants. The other logic-defying reality is that it would be consuming more baseload energy to create more brief pulses of high-priced energy to re-sell to us at “spot” market prices.

Northfield was fashioned during the nuclear build-out in the late 1960s to use the excess power generated at night from nuclear plants in Rowe, Vernon, VT and Haddam, CT to gulp giant slugs of the Connecticut up to its reservoir. When demand “peaked” during mornings or late afternoons it would release that stored nuclear energy—our river, back to its bed through massive turbines. It could produce some 1,000 megawatts in just minutes, great for short-term needs and emergencies. But it could only store enough water to produce 6-8 hours of electricity, total. Depleted, it then waited to re-start the process.

In her book “Inventing Niagara” Ginger Strand described the inefficiencies and rationale behind selling pumped storage electricity to the public as a textbook case of corporate capitalism: buy low, sell high. Northfield has never been a renewable hydro source. It is inefficient and operates at a net-energy loss. While its impacts on the river ecosystem are profound, its brief, staggering pulses of violent, high-volume output are no more efficient than that of legacy electric producers, just more short-term profitable.

Northfield only makes sense while it operates as a designated nuclear adjunct, run on the excesses of the region’s short-lived and now-shuttered nuclear fleet. But now it wants to soldier on, utilizing imported power and climate-changing resources. Meanwhile the river pays an as-yet unstudied price–as the public is asked to accept yet more “peak” energy, repackaged and re-sold at “peak” prices culled from bidding boards on the “spot” market.

FirstLight’s FERC request sparked official replies from entities involved in the current 5-year relicensing of Northfield. The National Marine Fisheries Service’s William McDavitt noted to John Howard “the timing of this temporary amendment application is a bit unfortunate as the proposed change could bear some impact on proposed 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability. Were the proposed changes to go into effect, it seems as though the duration that NMPS pumps or generates could be changed.”

MA Fish and Wildlife made no objections to the up-rate, but the Watershed Council noted that fish kills there–known as “entrainment”, are worrisome, “Currently the entrainment impact of the NMPS facility during the winter is not well understood, which the pending appeal by USFWS regarding the sufficiency of FirstLight’s proposed entrainment study well illustrates,” further noting, “So until such time as we have a much better understanding of the entrainment impacts of NMPS, it seems inappropriate to request additional pumping capacity.”

In 1995 the owners of the Ludington(MI) Pumped Storage Plant agreed to a $172 million dollar settlement for its killing of the public’s fish across the previous two decades. There, according to the Ludington Daily News, they at least had the benefit of a one-time study showing LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

Since 1972 it’s been a free ride up at Northfield.

Karl Meyer is a member of the Society of Environmental Journalists.

Kynard,Part II: Fisheries restoration, or a new half-century of death in the TF Power Canal?

Posted by on 06 Aug 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, Dr. Boyd Kynard, ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Station, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

Tune in to Local Bias on Greenfield Community Television, GCTV.org, for Part II of a wide ranging interview with fisheries biologist and US Fish & Wildlife Service Conte Anadromous Fish Research Center founder Dr. Boyd Kynard. He gives direct answers to questions about the fate of the millions of American shad that have been tricked out of the Connecticut River into the deadly and alien habitats of the private Turners Falls Power Canal for the last 35 years.

Dr. Boyd Kynard Part II; a Deadly Canal or a River Migration Solution?

http://mfi.re/watch/pdx5yqvqv7ygzdk/Local_Bias_147.mpg

The current Federal Energy Regulatory Commission Re-licensing process for FirstLight Power’s Turners Fall/Cabot Station and Northfield Mountain Pumped Storage Stations represents the last chance the Connecticut River gets to recover some of its biodiversity, fecundity and ecosystem functions for many decades to come. A second failure by the public agencies charged with protecting the public’s fisheries resources and endangered species will likely close off–forever, the last, best chance to restore New England’s Great River.

Will the federal and state agencies responsible for protecting and guiding the migratory fisheries restoration since 1967 (USFWS, National Marine Fisheries Service, VT, NH, and MA Division of Fish & Wildlife), again steer migratory fish headed upstream to northern MA, VT and NH spawning habitats into a private “roach motel” of deadly hydro blades and muck? Or, will they bring them directly upstream to a fish elevator at the Turners Falls and redeem decades of failure? Get the low-down, and hear about viable alternatives in this half-hour interview.

Tune in to Local Bias this Thursday, August 7 at 9 pm, or on Saturday, August 9th, at 9 pm. The shows repeat at those scheduled times the following week.

THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

Posted by on 08 Jul 2014 | Tagged as: Atlantic salmon, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, ecosystem, Endangered Species Act, Extinction, federally-endangered shortnose sturgeon, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Turners Falls, US Fish & Wildlife Service, USFWS

THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

Click on the link above for: Part one of Local Bias interview between Karl Meyer and Dr. Boyd Kynard, produced by Drew Hutchison of Greenfield Community Television.

Watch an interview with fisheries biologist Dr. Boyd Kynard who has made a career of researching migratory fish behavior and fish passage at dams in large rivers across four continents. Kynard is the long-standing research expert on the federally-endangered Connecticut River shortnose sturgeon.

For 45 years federal and state fisheries agencies plowed $100s-of-millions into a program targeting “restoration” of a strain of Connecticut River salmon extinct since 1809. Failing to understand the concept of extinction, that project failed.

For those same 45 years agencies including NOAA’s National Marine Fisheries Service, the US Fish & Wildlife Service, and Massachusetts and Connecticut fish and wildlife departments ignored, dismissed, and failed to provide the protections, outreach, and funding needed to rescue a native, four foot-long, living fossil: the federally-endangered Connecticut River shortnose sturgeon.

Listed among just 22 fish species in the original 1967 federal Endangered Species Act, these agencies–as well as regional non-profits, have failed to protect the 2-mile stretch of river decimated by industrial flows containing the only known natural spawning grounds of this pre- Dinosaur-Age fish: the pool below a natural rocky cleft in the river known as the Rock Dam, in Turners Falls, MA. Just 300 Connecticut River shortnose sturgeon can access the Rock Dam site today–where industrial flows cripple their spawning attempts, and endangered species protections are ignored.

New Stakeholder Comments submitted to FERC, re: Shad Spawning Habitat Studies and Fish Assemblage Assessment

Posted by on 19 Jun 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River ecosystem, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, shad, Station 1

The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on June 16, 2014, re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

Karl Meyer, M.S., Environmental Science
85 School Street, # 3
Greenfield, MA 01301 June 16, 2014

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, N.E.
Washington, DC 20426

Stakeholder Comments RE: FERC P-2485-063, and P-1889-081:

These comments pertain to Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

My comments are specific to a Study Plan Determination meeting and consultation that took place at Northfield Mountain on June 3, 2014, to determine proper Study Plan parameters and procedures.

As a Stakeholder who has contributed to these fisheries discussions throughout the FERC process, I was dismayed that notification of this Stakeholder meeting was not sent out until the day before it was to take place. Along with Katie Kennedy, Andrea Donlon, and Don Pugh, I did not receive an email-invitation from FirstLight consultant Chris Tomichek to continue participating in the discussions until 9:15 a.m. on the morning of June 2, 2014—for a meeting that was to take place at 9:00 a.m., June 3, 2014. This is an abrogation of the FERC relicensing process for Stakeholder participation, and once again leaves these legal proceedings open to question. As I was on vacation when the less-than-24-hour-notice was sent, I was not aware that a meeting had taken place until the day after. With notice, I could have participated via teleconference.

I trust that the Notes and Transcript of this June 3rd meeting will be posted on both the FERC and Northfield Mountain relicensing web sites as part of the public record.

As I do not know the content of Stakeholder remarks or positions stated at the June 3, 2014 meeting, it’s possible that some of my comments may reiterate those of others. I will try to be brief, and address areas of my expertise.

My Comments re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects

In response to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard filed a response with FERC on January 28, 2014, stating, “Kieffer and Kynard (2012) have documented a spawning period of 5-17 days during the same 26 day period each year (April 27-May 22). Early life history stages (eggs and larvae) are present in the project area for 20 to 30 days after spawning (Kynard et al. 2012a). So the period when shortnose sturgeon eggs and larvae are present overlaps with the proposed sampling period for shad egg collection. Consequently, the collection of shad eggs may have the potential to impact shortnose sturgeon, and NMFS recommended in its December 2 letter that the study be revised.”

“To address this potential concern, FirstLight proposes to replace shad egg collection efforts, which studies have shown are duplicative of visual observations of shad spawning, with enhanced visual observations and splash counts.”

The best way to determine the presence of shad spawning, habitat and egg deposition in the By Pass Reach is to use both recommended efforts: egg collection and splash counts Using plankton nets to capture eggs and larvae should be employed to determine shad reproduction in the 2 miles of the By Pass Reach. NMFS did not at any time state that this method should not be employed. They merely noted the presence of SNS and their spawning period and egg/larvae deposition schedule.

Dr. Boyd Kynard states that there is no reason that plankton nets cannot be deployed in the channels opposite the islands on the west side of the river while SNS are present at their east-side ancestral Rock Dam spawning site, or the default site adjacent to Cabot Station if inadequate flows at Rock Dam have chased them downstream. Kynard states that this seining can take place all the way up to TF dam without impacting SNS spawning or egg deposition and larvae development. (Personal communication, 6/14/2014) Kynard is available if FL or Kleinschmidt would like to consult with him.

It is noteworthy that my own observations found FirstLight dumping water back into the river from its canal bypass flume above Cabot Station on three consecutive days at 12;25 pm: May 13, 14, and 15—all dates when SNS are potentially in spawning mode in the Connecticut River section known as the By Pass Reach. Station 1 was also operating off the canal at all these times, and the flows emanating from each were similar—though the whitewater flume-dumping off the canal appeared slightly less rigorous than the generation at the Station 1 outfall.

It is obvious from their notes that FL understands the requirements of SNS for successful reproduction. This canal-dumping practice has been noted by Kynard et al, as a flow regime that can abruptly end spawning efforts and bury or strand SNS eggs and larvae.

As suggested, splash counts should be also be done throughout the By Pass Reach. However, river regulation by FirstLight has a profound impact on whether and when shad are present in the By Pass Reach—River Segments 1 – 4 in the Study Plan—just as it impacts SNS.

FirstLight’s proposal to use splash counts to determine spawning should be carefully calibrated with river flows throughout the By Pass Reach. In order to have get a “clean” picture of when and where American shad may use this reach of river for spawning and egg deposition, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace federal trust fish from this river segment.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass from noon on the day the study is to commence until after midnight when spawning tapers off.

It is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flows, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

My Comments re: Study No. 3.3.11 Fish Assemblage Assessment

In his letter responding to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard formally responded to FERC on January 28, 2014, stating: “To avoid any potential impacts to sturgeon, FirstLight proposes to conduct all sampling in the bypass reach after June 30, and in the reach below the Deerfield River, FirstLight proposes to use both existing data and the data it obtains in the Turners Falls Impoundment.”

I will restrict my comments to fish assemblage sampling in the By Pass Reach:

Again, in order for electro-fishing sampling to be effective and get a “clean” picture of when and where resident and migratory fish may use this By Pass Reach of river, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace fish from this reach.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass for a full 24 hour cycle before this study is to commence.

And, again, it is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flow, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

End of Formal Comments

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,
Karl Meyer, M.S.

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by on 21 May 2014 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, ecosystem, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, GDF-Suez FirstLight, Ludington Pumped Storage Plant, New Hampshire, Northfield Mountain Pumped Storage Station, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments were filed today, 5/21/2014, with the Federal Energy Regulatory Commission respecting Connecticut River fish mortality investigations at Northfield Mountain Pumped Storage station (NMPS)

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301

 

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments, RE: FERC P-2485-063, and P-2680-108: relevance of FirstLight Hydro Generating Company’s document submission issued by FERC as “Conference/Meeting Transcript issued in FERC P-2485-063, et al” on May 9, 2014 for Northfield Mountain Pumped Storage project (NMPS).  The inclusion ofTranscript of the April 17, 2014 FERC Scoping Meeting held in Pentwater, Michigan re Consumers Energy Company’s et al Ludington Pumped Storage Project under P-2680-108” offers an incomplete, unsubstantiated and confusing picture of its applicable connection to the relicensing of NMPS on the main stem of a four-state river system in Massachusetts.

Dear Secretary Bose,

Please consider the following comments respecting the relevance of FirstLight Hydro Generating Company’s recent document filing as it seeks a new license for the Northfield Mountain Pumped Storage station.  I testified as a Stakeholder in the NMPS Study Dispute Panel Technical Conference along with officials from the USFWS and Trout UnLimited on Tuesday, April 8, 2014.  The Dispute Panel was convened out of concerns that no study of the entrainment of eggs and larvae of migratory American shad was being required as part of a relicensing bid from GDF-Suez FirstLight Power for NMPS.  I find no clear context provided by FirstLight for the inclusion of a transcript for the April 17, 2014 FERC Scoping Meeting for the Ludington Pumped Storage Plant–a lakeside Michigan-based facility, as part of the NMPS relicensing proceedings. 

NMPS’s pumping/generating impacts are known to reach downstream to Holyoke Dam at river-mile 86 and affect spawning-run migratory fish that utilize Massachusetts, New Hampshire and Vermont habitats upstream to Bellows Falls Dam at river-mile 172.  It is critical to the relicensing of any pumped storage generation on this four-state river to have robust studies with measurable outcomes to protect the public’s interest in a balanced and functioning Connecticut River ecosystem. 

NMPS impacts migrating and spawning anadromous fish in a four-state ecosystem that has been the focus of a federal fisheries restoration program begun in 1967, “to provide the public with high quality sport fishing opportunities in a highly urbanized area, as well as provide for the long term needs of the population for seafood.”  NMPS, completed in 1972, has been shown to have direct impacts on migratory fish entrainment and fish passage from northern Massachusetts to central Vermont and New Hampshire.

The US Fish & Wildlife Service, National Marine Fisheries Service, and fisheries directors in MA, NH, VT, and CT are all charged with protecting these resources for the public.  Federal and state laws, licenses and statutes governing these mandated protections include the federal Clean Water Act, Endangered Species Act, and federal-trust fish protections beginning with the Anadromous Fish Conservation Act of 1965.  FERC authority also mandates licensee compliance and protections for the public’s fisheries resources and restoration projects.  FERC itself is mandated to comply with federal environmental law. 

The Ludington Pumped Storage Plant is a FERC licensed facility sited and operating within a single state on a lakeshore well over 100 miles from it closest bordering state—and situated with 118 miles of open water at its back.  Northfield Mountain Pumped Storage, situated adjacent to the Connecticut River, operates on the Navigable Waters of the United States in Massachusetts just 10 miles from where the Connecticut River passes out of Vermont and New Hampshire.  NMPS pumps and generates from a narrow ribbon of river that is less than 1,000 feet wide—during warm seasons can draws more water than the river’s natural output. 

In short, these are two very different animals, operating in very different habitats. 

However, there are similarities in the long-term environmental impacts of these far-flung pumped storage facilities.  They both kill large quantities of the public’s fish.  Unfortunately, those impacts were not cited or included in FirstLight’s submission to FERC in either Dispute Resolution Panel documents or its license application documents.  In 1995 the owners of the Ludinton Plant agreed to a $172 million dollar settlement for its killing o fish during the previous two decades.  The public there at least had the minor benefit of one-time study that showed LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

Unfortunately, to date, we have no such data from a study of NMPS, nor any compensation for the long-term damage to a public resource and a long-term fisheries restoration project.  In Michigan, a US-based entity was required to pay restitution and undertake remedial action.  Here at NMPS the plant operator is a transnational corporation, based outside the United States, that is “taking” an unknown quantity of a public resource without compensation or required analysis.  If a US Citizen were to do this they would be subject to legal action.  

 

Please see below: Ludington Daily News, August 13, 1987: “Federal agency rules on fish kill, Ludington hydro plant must comply within 60-90 days.” 

The Ludington plant had begun operations in 1973, and had been the subject of legal proceedings from that time forward.  The State of Michigan had filed a suit in Ingham County Circuit Court seeking more than $147 million in damages, and the National Wildlife Federation had won a federal court order that Consumers needed a pollution discharge permit for the plant. 

In summary here are several excerpts from that article defining the impacts at that time including references to a single study that found the plant killed millions of native fish in a single year, species that are today disappearing, or have essentially disappeared, in Lake Michigan waters: 

 “Environmentalists and state officials Wednesday hailed a federal ruling designed to end the fish kills at the Ludington Pumped Storage Facility operated by Consumers Power Co.”  (Co-owned with Detroit Edison Co.) 

“Finally, after 14 years of negotiations and litigation, and the destruction of millions of Lake Michigan sports fish, we’re going to see an end to this needless waste of an important resource,” said Thomas Washington, executive director of the Michigan United Conservation Clubs. 

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”

“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators.  In the pumping process, it kills millions of fish.” 

“The MUCC said that a study commissioned by Consumers Power showed the plant, in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

However, it took another eight years of environmental damage and drawn-out court proceedings before a settlement—totaling $172 million, was finally reached in 1995.  See: Ludington Daily News, March 7, 1995: “Local groups urged to begin working on projects for fish kill settlement plan.” 

“While 12 to 18 months more may pass before the settlement, valued at $172 million, becomes final state officials urged local groups not to wait to prepare proposals for enhancing local fishing.” 

“Many audience questions fielded by the five-person panel concerned the perception the settlement doesn’t do much for Ludington area fishing specifically—the fishing most affected by the fish kill at the plant.” 

It was only after 1995 that some of the large-scale impacts of Ludington Pumped Storage Plant began to be addressed.  Ultimately, a FERC-sanctioned 2-1/2 mile long (12,850 ft) barrier net was deployed across hundreds and hundreds of acres of riverbed and bank. 

Sadly, it seems that net did not mitigate or resolve the loss of local fisheries in the Ludington region.  Its deployment was either ineffective or far too late for a regionally- and culturally-important sustained harvest of local- sourced and eaten native yellow perch and lake trout.  Those perch have now essentially disappeared in the Ludington-Manistee region—which is noted in Stakeholder Testimony supplied for the Ludington Scoping Meeting on April 17, 2014 where Mr. Richard Underwood testified that past Michigan DNR creel surveys had found: “close to a quarter million perch” in Ludington habitats.  “In the last few years, four years, we have had a total of zero count of perch in Ludington, and that’s how it has affected.” 

The giant Ludington barrier net appears to be one key player in the puzzle of the missing perch. It appears to act as a fish trap.  According to Mr. Underwood that net, along with an artificial reef constructed nearby, attracts a giant collection of cormorants that feed on the fish trapped within the confines of the net, “There were so many birds on the reef and inside the barrier net you couldn’t count them.  I estimated there were 3,500.”  

Ironically too, in recent years, federal hatcheries in the Connecticut River basin have been producing lake trout to supplement the now-crippled and dwindling native population of lake trout on Lake Michigan. 

Another similarity in these two relicensing proceedings is that FERC’s Scoping Site Visits at both the NMPS plant and LPSP were scheduled either before the PAD had been given to Stakeholders, as it was NMPS, or—as noted in state fisheries testimony at Ludington, the Site Visits are not scheduled to take place until well after Study Requests and Stakeholder Comments are due. 

Both of these processes deprived the public and officials the ability to visit, witness, and develop an understanding of the complex impacts of these pumped storage plants before submitting testimony, comments, and informed study requests. 

Similarly, both plants have deployed barrier nets as a means of diminishing their fish kills and entrainment/mortality impacts.  And, at both sites the fishing is poor and with stocks deteriorating. 

The difference on the Connecticut River is that migratory fish here are forced to encounter two entrainment opportunities through FirstLight facilities.  The first occurs seven miles downstream, when they are deflected by attraction flows into the Turners Falls Power Canal, with Cabot Station turbines operating on the downstream end.   The small percentage of fish that manage to survive the 2-1/2-mile, 8-day (average) transit to the head of that canal—and the even smaller number that actually exit upstream(1-10%), then get the chance to be culled by NMPS turbines, just five miles further upstream.        

In its filing of the Ludington Scoping Meeting documents, GDF-Suez FirstLight seems to be suggesting some link between the large-scale wind power facilities built by LPSP owners Consumers and DTE, and a key, future role for renewables here in sucking the Connecticut River backward and pulling it uphill into the Northfield Mountain Pumped Storage reservoir. 

That connection is tenuous, at best.  Consumers and its partner DTE now own and operate a large-scale wind farm consisting of some 56 turbines.  Its deployment required the purchase or easement rights to 16,000 acres of Michigan property, most of it to trench-out underground power lines to reach back to their grid and pumped-storage plant.  Their large-scale wind operations are due to the presence of 118 miles of open Lake Michigan at their back, as well as a flat, open, prairie landscape to site giant turbines on. 

FirstLight seems to be implying that NMPS will be similarly employed at some future date—its ecosystem impacts ignored because of the huge amount of surplus, cheap, local, renewable energy available to pump a river uphill at night.  But solar doesn’t generate at night; and available local hydro here is modest and run-of-river—it would not constitute a “renewable” source to be tapped to pump water uphill.  And, wind power opportunities here are spotty, small scale, and generally available on isolated ridge tops. 

Clearly the Connecticut River Valley has none of the necessary features that might facilitate the large-scale wind renewables/pumped storage relationship found at LPSP.  Nor, has FirstLight proposed plans for any large-scale wind projects in the region.  No other entity has either.  Cape Wind, whose large scale deployment will be installed miles off the Atlantic shore, is not proposing a pumped storage plant be built above the Truro Cliffs in order for its renewable energy megawatts to be consumed.  Here, there just aren’t flatland mega-farm acres available, and only a few ridge tops here have proven suitable for siting isolated turbines.

GDF-Suez Manager John Howard stated at the Dispute Resolution Panel: “We can manage fluctuations in energy schedules with wind, solar, and imports from Canada and New York, primarily.  And then the ability to respond very quickly to energy and operating reserve needs of the power system, any time of the day or calendar year.”  He states that “We can manage…”  But there is nothing backing up the statement.  Nothing that proves there is a surplus amount of renewable energy reaching NMPS to state clearly that “We do manage…” or “We will be managing…”   The implication is that NMPS is a necessity here in order to implement renewable energy in the region.  Where is the science to back that up?  Solar is not around at night.  And the region is sub-marginal for large-scale wind, as well as lacking in opportunities for securing thousands of acres of right-of-way here. So, where is the implied connection between these two facilities—beyond fisheries destruction? 

Michigan, with its open face to the winds—which do blow at night, apparently ignores the to damage to its Great Lake ecosystem and fish, and tallies the wind-energy driving Lake Michigan waters and uphill to its pumped-storage plant as “renewable.”  We don’t have that wind here, and solar power generation is a whole different animal–not in any way the high-octane source needed to push a river uphill at NMPS.  FirstLight has built a 2 MW solar installation atop the 11 acres of land it was mandated to construct for silt-settling ponds by the EPA in 2010 after being sanctioned for massive infractions of the federal Clean Water Act by dumping up to 45,000 tons of pumped storage reservoir silt and sludge into the Connecticut River , the company has not included any information on how that solar facility connects to, and interacts with, and powers its pumped storage operations.  Unlike large-scale wind, solar does not deliver its energy at night–when NMPS asserts that it will do most of its pumping.

Pumped storage can only be deemed “renewable” energy in a generating environment where ecosystem impacts are not considered.  Pumped-storage itself was a net-loss bargain that was ill-considered even back when there was actually surplus nuclear available in the region.  Now this taking-of-a-river is mostly accomplished at NMPS by climate-warming, non-renewable fossil fuels.  This is a lose-lose situation for renewable energy use–and for an ecosystem. 

GDF-Suez FirstLight’s NMPS plant does feature “black-start” capabilities, and does offer FERC and ISO the ability to accomplish load-leveling at certain critical times.  However, these attributes must be balanced against long-standing federal and state efforts to complete a forty-seven year old migratory fisheries restoration on the Connecticut, and the public’s long-term need to have a sustainable Connecticut River ecosystem.  NMPS operations also need to adhere to federal and state environmental law.

In 1995, Consumers and DTE paid the public $172 million for their past fish kills of the previous decades.  Thus far, the public has not been compensated for the on-going taking of fish at NMPS on the Navigable Waters of the United States, nor have citizens in MA, VT, NH and CT been able to reap the benefits of anything near the stated goals of a four-state fisheries restoration program targeting recreation fishing and harvestable seafood. 

Studies with measurable results are required for a fair relicensing process.  Stated steps in the FERC relicensing process should be followed to allow the public a contextual look at the operations before the need to suggest studies or prepare testimony.  To facilitate a fair process, FERC should require context and full disclosure of all submitted documentation on the part of the applicant, as well as phone conference transcripts to allow an understanding of the ongoing dispute procedure. 

Placing a net in front of LPSP and NMPS has not stopped the fish kills at either plant.  A band-aid should not be applied to a gaping wound.  Complete and proper studies of all life stages of fish mortality are needed for NMPS relicensing.  Regulatory pumping and generating restrictions that protect the public resources of US citizens are overdue and necessary there.  The studies needed to accomplish this should take place before any new license allows this ongoing “take” to continue through 2048.     

                                                End of Formal Comments

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,

Karl Meyer, M.S.

The curious nucelar history of Northfield Mountain Pumped Storage Station

Posted by on 08 May 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Millstone 1, Montague Nuclear Station, Northfield Mountain, Northfield Mountain Pumped Storage Station, right-to-know, shad, shad larvae, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic

Copyright © 2014, by Karl Meyer

The curious nuclear history of Northfield Mountain’s pumped storage plant

(The following piece first appeared on April 30, 2014 in The Recorder in Greenfield, MA, under: Follow the power currents; How the pumping station once fit)

GDF-Suez FirstLight has applied for a new 30-year license from the Federal Energy Regulatory Commission for its Northfield Mountain Pumped Storage plant on the Connecticut.  In this 5-year relicensing process US Fish & Wildlife Service has requested a study to protect a public resource: they want to know the mortality impacts NMPS has on eggs and larvae of migratory American shad.  But FirstLight wants FERC to substitute data from a 22 year-old Northfield study–their counsel has argued that eggs and larvae aren’t technically migratory, and thus have no right to protection at NMPS. 

Pumped storage is a most inefficient form of generating “hydro” electricity, and NMPS is not what it once was.  When proposed, Northfield was to be a nuclear-charged plant designed to gulp-up massive amounts of the Connecticut River, pushing it uphill to a reservoir carved into a mountain.  This would be done purchasing cheap, otherwise-wasted, night-generated nuclear energy from a fleet of soon-to-be-built local plants–which don’t switch off at night.

Once the net-loss task of pushing water uphill was accomplished via nuclear megawatts and reversing turbines, they’d send that water charging downhill to generate large pulses of energy during peak-use times.  Profits would come from reselling that energy back into the electric grid when demand and prices were highest, with consumers picking up the tab. 

But a river system also bore the hidden costs of NMPS and now USFWS wants to know what they are. FirstLight today doesn’t dispute NMPS kills all adult and juvenile shad drawn into its plant.  But that’s just one species.  FERC itself is mandated to protect federal trust fish, and the public is entitled to information on NMPS’s impacts.  Researchers report it sometimes draws so much river water that boats 5 miles downstream are pulled backward.    

Because of the limits of physics NMPS can only operate for 6 – 8 hours.  Then, water-depleted and power-less—it must again purchase new outside electricity to pump water uphill.  It was new technology when NMPS was proposed–technically “hydro” electricity, but not in the way people commonly understood it. 

During mid-1960s Federal Power Commission hearings, questions arose about the proposed NMPS plant’s impacts on the ecosystem.  One option, never implemented, was that it would cease operating during migration season to avoid slicing up the public’s fish in accordance with goals of the federal Anadromous Fish Conservation Act of 1965.

Back then just one local nuclear plant was operating, Yankee Atomic, 20 miles away in Rowe, MA.  But big, local, nuclear build-out plans were in the offing—the lion’s share of which would come to be owned by Northeast Utilities.  Fifteen miles upstream Vermont Yankee was under construction.  It opened in 1972 in lock-step with the completion of Northfield.  As VY and NMPS began tandem, nuclear-powered operation, plans were already underway for NU to build two reactors at a new Montague Nuclear Station, five miles from Northfield.

By fall of 1973 a 500 foot tower loomed over the Montague Plains, testing humidity, temperature, and prevailing winds in preparation for construction.  That tower was toppled in an act of civil disobedience by Sam Lovejoy the following February, helping bolster opposition to the plants.  But NU rebuilt the tower and collected the mandated data by 1975.  By then however, the playing field was changing.

Environmental questions were raised about the effects of Montague Nuclear Station’s drawing huge amounts of river water and dumping heated effluent back into the Connecticut on the federally-endangered Connecticut River shortnose sturgeon.  Questions also arose about the cumulative effects of entraining various life stages of American shad into the intake systems of two Montague plants and NMPS. 

Meanwhile, NU moved ahead on planned nuclear plants for the heavily-populated I-95 Providence-/New Haven corridor–some 100 and 125 miles distant from Northfield.  Four got built, but just two operate today. Their Haddam nuclear plant on our river was shut permanently in 1996 for safety and equipment failures.  So too in 1998 was Millstone Unit I in Waterford, CT.  In 1999 NU to accepted the largest nuclear fine to that time–$10 million for operational failures at those plants. 

Opposition, environmental impacts, soaring costs, and a partial meltdown at Three Mile Island saw NU abandon Montague Station in 1980.  Thus the Connecticut River basin doesn’t today host a forth, de-facto, nuclear waste dump.  Rowe’s Yankee Atomic closed in 1992—it’s now repository to hundreds of tons of spent nuclear fuel.  Vermont Yankee will close in December.  Entergy Nuclear has yet to fully endow their mandated decommissioning fund. 

Local nuclear power to push a river up Northfield Mountain is today nearly nonexistent.  The net-loss “hydro” generating process now taking place there essentially derives from a non-renewable, climate-warming mix of oil, coal and natural gas, plus some nuclear and even pulses of conventional hydropower purchased from as far away as Quebec. Beyond the yet-to-be-examined costs to the public’s ecosystem and fish, consumers are paying dearly for Northfield’s twice-sold electricity.  A fair relicensing process requires robust public information on the lethal aspects of Northfield’s operations.  FERC will decide the issue by early May.

Greenfield writer and journalist Karl Meyer has contributed written and oral testimony in the FERC relicensing process for the Northfield Mountain and Turners Falls power stations.

New Stakeholder Comments filed with FERC

Posted by on 31 Mar 2014 | Tagged as: American shad, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, FirstLight, Northfield Mountain, US Fish & Wildlife Service, USFWS

The following Public Stakeholder Comments were filed today with the Federal Energy Regulatory Commission and Dispute Resolution Proceedings concerning Relicensing Studies to be conducted at the Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301                                                                        March 31, 2014

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments for: FERC Project No. 2485-063, the Northfield Mountain Pumped Storage Project; and FERC Project No. 1889-081, the Turners Falls Hydroelectric Project.

 RE: US. Fish and Wildlife Service’s Notice of Study Dispute, filed March 13, 2014; and FirstLight’s response filed March 28, 2014, as Information Relevant to the US Fish & Wildlife Service Notice of Study Dispute.

Dear Secretary Bose,

Please consider the following comments concerning the necessity of robust study information being required of the license applicant in order for the US Fish and Wildlife Service and stakeholders to be fairly represented in this process.  The requested full Study on impingement and entrainment and data arising from examination of Northfield Mountain Pumped Storage Station’s operational effects on all life stages of American shad is new information that will also assist FERC in fully considering public resources and the public’s interest in a balanced and functioning Connecticut River ecosystem.

On March 13, 2014, the U.S. Fish and Wildlife Service (USFWS) filed a Notice of Study Dispute with the Federal Energy Regulatory Commission (Commission) stating that the Study Plan Determination issued by Commission staff would not elicit adequate information specific to “the effects of Northfield Mountain Pumped Storage Project (NMPS) on certain migratory fish species.”  FirstLight argued that information from a 1992 entrainment study would be sufficient to stand-in for current relicensing information.

The USFWS’s information request was made to fulfill responsibilities in determining the impact of NMPS pumping operations on American shad mortality, from eggs and early-life stages, to juvenile and adult fish.  USFWS noted that a “failure to provide this information will compromise the Commission’s ability to establish license conditions and the Service’s ability to set mandatory conditions under Section 18 of the Federal Power Act (FPA).”

The USFWS further stated:

“A new study of NMPS is needed because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation that could increase the potential for entrainment at NMPS. With anticipated improvements to fish passage facilities as part of the relicensing process for the Turners Falls Project, those numbers could increase into the hundreds of thousands.”

Under Goals and Objectives USFWS stated: “The goal of the Service’s original study request (Appendix A) was to determine the impact of NMPS pumping cycle on entrainment of American shad (including early life stages.)”

Pursuant to a March 26, 2014 teleconference between USFWS, FirstLight, and Commission staff, FirstLight formally responded on March 28, 2014, by supplying a portion of six years of seasonal pumping information from NMPS.  FirstLight submitted it as being representative of an overall decrease in plant pumping operations since the original 1992 mortality/entrainment study.  FirstLight supplied monthly and daily pumping data for the bracketed years of 1991 – 1993; and then again for 2011 – 2013.  In its filing FirstLight stated that, aside from the 1992 study-year data included, the other five years “were arbitrarily selected.”

A preponderance of accepted data shows NMPS operations impacting reaches of river at least as far downstream as Holyoke Dam, 36 miles distant, as well as throughout the Turners Falls Impoundment nearly to Vernon Dam, 20 miles upstream. In the months of June and July NMPS’s unrestricted pumping output of up to 15,000 CFS actually outstrips the Connecticut’s natural flow volume. Studies confirm that entrainment of eggs, juveniles, and adult fish have significant impacts on ensuing year-class strength.  They can impact whole-river populations.

Given this understanding, the “arbitrary” pumping years FirstLight has submitted to support limiting the scope of this study appear selective, rather than “arbitrary.” They coincide exactly with the all-time peak years of fish migration on the Connecticut during the early 1990s, and again, with the only shallow bit of improvement for shad migrating into the Turners Falls Impoundment since deregulation in 2000–the years 2011, 2012, and 2013, leading directly into a relicensing application. It should be noted that “arbitrary” is not synonymous with “random.”  Random is an accepted scientific parameter.

It is noteworthy that FirstLight selected as its first grouping the years 1991 – 1993 for pumping information.  Those years selected can be characterized as skewed, rather than arbitrary or random, in that two of them represent the highest years of fish passage ever recorded (1991, 1992) through Turner Falls Gatehouse.  These were record years along the entire river. However, the slight fall-off starting in 1993, began the first extended period where shad returns along the Connecticut River began a steady downward spiral.

The other data set FirstLight offers as “arbitrary” are from the years 2011 – 2013.  What is interesting about this “arbitrary” FirstLight data is that it excludes the entire decade–beginning in 2000, when NMPS began operating as a deregulated entity. Then, as today, NMPS could draw, and release—unrestricted, up to 15,000 CFS into the TF Pool, according to market prices and demand.  What is powerfully obvious about the years not included in their study data is that 2000 – 2009 represent the worst decade of fish passage at Turners Falls Gatehouse ever, with passage counts dropping to 1% or less some years. Some might describe this as cherry picking data.  They arbitrarily picked the only two minor peaks of any note across a very dismal quarter-century of poor upstream shad recruitment.

Good science requires, at minimum, randomly selected figures when data samples are too large. That is not the case here.  We are only considering 25 years of data, and only three months from each year.  A complete data set should be provided—especially when it is small, as in the present case.  Given such a brief span of time, and considering that a FERC license may be in place for 30 or 40 years—data from years 1991 to 2013 should be presented to better understand entrainment, mortality and recruitment of all life stages.

Significantly, as history, in 2010, FirstLight entrained its own turbines at NMPS plant while attempting to clear silt from its upper reservoir. NMPS operations came to an abrupt halt; the US EPA sanctioned them for “polluting the navigable waters of the United States,” and no pumping occurred at NMPS from May 1st, until November.

Fish passage at TF Gatehouse in 2010 saw a 400-500% increase over averages for the previous decade that year NMPS remained inoperable.  However significant that increase was, it merely represented a return to disappointing fish passage and recruitment levels regularly reached there in the 1980s.  The following year, Holyoke Dam saw a 30% increase in fish passage, yet no corresponding increase in shad passage was tallied at TF Gatehouse in 2011. 

However Gatehouse fish passage did continue–across the “arbitrary” 3-year data set FirstLight submitted for 2011 – 2013, to show a level of fish passage comparable to the returns achieved in the mid-1980s.  By not including pumping files from 2000 – 2009, FirstLight offers just three years of data during which improved fish passage numbers could be shown—but only if passage and recruitment targets are scaled back to the disappointing results of the 1980s.

As “arbitrary” as those selected years of data may be, they only give a snapshot of three “good” years of fish movements and recruitment above Gatehouse toward Northfield and VT/NH habitats. Certainly it’s possible that pumping operations get skewed over some years for various reasons.  But three years of data–just prior to a relicensing bid, is no substitute for the full set of pumping files.  Pumping data beginning from the year of deregulation—2000, to the present, will shed light on the impacts of pumping on entrainment and recruitment across the time frame necessary to help make decisions on issuing a decades-long license.

Ample decision-making studies and data—beyond just the most recent years FirstLight wants to supply, is what are called for in this instance.  The remaining pumping data, monthly, daily, along with standard deviations for the years 2000 – 2009, should be supplied in order to protect public resources.

Stakeholders should have an understanding of the plant’s potential pumping impacts and a fuller knowledge of the spectrum of its operating regimes since becoming a deregulated entity across three different owners—as there is no guarantee of single, long-term ownership over the term of license.

It is also critical to note that an overall “decrease” in pumping across selective years is just a single factor and may not be as significant to various life-stages of fish survival as the actual days, dates, and times when pumping and entrainment is occurring.  This is why the full USFWS entrainment study and a full report of pumping operations are necessary.  This is information that is sorely lacking.

Under Existing Information the USFWS states: “In its original study request, the Service noted that, while a number of studies had been conducted over the years, only one study attempted to quantify the number of shad entrained at NMPS.”

USFWS further stated that information from a single study conducted in 1992 would be insufficient for determining new protective licensing requirements: “The ichthyoplankton sampling requested by the Service would follow the methodology used in the 1992 study.”  USFWS further argues: “Existing information is not sufficient to use in the relicensing proceedings because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation as part of relicensing and that could increase the potential for entrainment at NMPS.”

Nexus to project operation and Effects: “Both the previous licensee (Northeast Utilities Service Company) and FirstLight assume that all fish entrained are lost to the Connecticut River system (i.e., 100% mortality). Without quantification of entrainment of all life stages of American shad, it is not possible to determine what the overall impact of that entrainment is on the shad population. This information relates both directly and indirectly to the Service’s statutory responsibilities under Section 18 of the FPA;”

Cost: The US Fish and Wildlife Service notes that a suitable entrainment study that includes early life stages can be conducted at NMPS for well under $50,000.  This is a modest expense to attain critical information that is not available elsewhere.  Not gathering such information would amount to a failure of due diligence in the current relicensing.  A single, 22 year old study is inadequate science on which to base conditions for a license that could impact the Connecticut River ecosystem until 2048—at which time the last data collected will be 60 years old.

I urge you to require the full study of NMPS entrainment on all life stages American shad. The information gathered will enrich and inform decision-making gathered from related shad studies occurring under relicensing, including 3.3.2; 3.3.3; 3.3.6; and 3.3.7. Further, please require that the full spectrum of May, June, and July, pumping files for the years 1991 – present, be released as information critical to making decisions on NMPS’s long-term impact on the entire Connecticut River ecosystem.

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,

Karl Meyer, M.S.

Cc: John Nagle, U.S. Environmental Protection Agency

USFWS Designee: Dispute Resolution Panel

Endangered fish beer? YES: Shortnose Stout!

Posted by on 13 Mar 2014 | Tagged as: Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, Shortnose Stout

Endangered fish beer??  YES: Try a Shortnose Stout! 

Come to the debut celebration of this brew and the endangered fish it honors! 

On Sunday, March 16th, at 4 pm, The People’s Pint of Greenfield, MA introduces Shortnose Stout, a traditional, locally-fermented Irish brew created to honor the biological legacy and highlight the eroded river conditions that keep the ancient, federally-endangered Connecticut River Shortnose Sturgeon tottering on the brink of extinction. 

Join Dr. Boyd Kynard, author, professor, and shortnose sturgeon expert, along with myself, People’s Pint Brewer Chris Sellers, Pint Owner Alden Booth, and Manager Tina Bodensteiner, to celebrate the beer, the fish, and sample the new brew.  Have some fun on St. Pat’s Eve, and get your questions answered about beer-brewing–and the issues facing the Connecticut River shortnose sturgeon. 

The opening is casual, and begins at The Pint at 4 pm, at 24 Federal Street in Greenfield, MA.  Shortnose Stout will be available in bottles at various outlets from Cambridge to the Berkshires. 

For more information on the endangered Connecticut River shortnose sturgeon and Dr. Kynard’s book defining the 17 years of state and federal research his team conducted on this species, refer to the highlighted buttons on shortnose sturgeon at:  www.bk-riverfish.com  

River Science Dead Ends….Again

Posted by on 11 Feb 2014 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FirstLight, New Hampshire, Northfield Mountain, power canal studies, shad, Turners Falls dam, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont

Copyright © 2014, by Karl Meyer 

                          River Science Dead Ends…Again

Since 1980 it’s been clear the Turners Falls power canal is a dead end for the Connecticut River’s American shad migration.  Thirteen years of federal fish research in that watery rabbit hole only serves to reinforce the point.    

A Federal Energy Regulatory Commission inquiry of US Geological Survey Conte Fish Lab researchers in Turners Falls, MA, found that it takes a radio-tagged American shad an average of eight days to swim the 2-1/2 miles from the end of the Turners Falls power canal to an area near the dam.  A person can stroll those same 2-1/2 miles along the Canal Side Rail Trail to the dam (basically the entire TF power canal) in less than 45 minutes.  So, what’s dragging these fish down?

Things are becoming clearer as information dribbles out from Conte Lab’s endless fish passage studies in the Turners Falls power canal via the FERC hydro-relicensing process on the Connecticut River.  What’s obvious is how little we know about conditions encountered by the thousands of migrating shad forced into the private canal.  Nor do we have any definitive science describing what happens to tens of thousands of shad that choose their ancient migratory route directly up the Connecticut to Turners Falls Dam.  These are fish seeking passage toward Gill, Millers Falls, and Northfield, MA; Brattleboro and Bellows Falls, VT; and Chesterfield and Walpole, NH.  That dam holds back migration-sustaining flow to feed FirstLight’s deregulated pumped-storage hydro plant inside Northfield Mountain.   

The first thing noticed from a FERC memo dated January 27, 2014, is that the 2008 – 2012 studies from the USGS fish lab are being provided “with the caveat that they contain preliminary data that is subject to revision and that the reports have not been subject to independent peer review.”  In short, this un-vetted research does not meet some basic scientific benchmarks for making long range decisions on river regulation.  And, while conducted by federal researchers, some of it is over a half decade old, while all of it’s been subsidized with power company funds.

Today just one-fish-in-ten passes upstream through that canal to the river beyond TF dam–no better than averages tallied there in the mid-1980s.  So why has hydro-company FirstLight had access to this study information over these years while the public has gone wanting?   And when do study findings from 2008, 2009 or 2010 get finalized—when do they get published and made available for peer review?  Is this public-science, or private consulting?  How much weight can FERC accord them?

Here are further tidbits from a January 30, 2014 memo released by FERC.  They’re from a follow-up phone call between FERC’s Ken Hogan and Conte Lab’s Dr. Ted Castro-Santos, a principal investigator in the Turners Falls canal studies.  “Specifically, Mr. Hogan sought information from Dr. Castro-Santos on the duration of the upstream migration of adult shad within the Turners Falls power canal.”  Though there isn’t an exact transcription for the public record, we do have this telling quote: “Dr. Castro-Santos stated that duration of the radio-tagged shad migration within the power canal from Cabot Station to the vicinity of the Gatehouse, is a median of 8-days.”

Examined carefully, the language of Dr. Castro-Santos’s reply is specifically—vague.  What it reveals is that most tagged spawning-run shad take over a week to swim less than 30 city blocks.  Some take much longer.  But on average that’s a full four days to swim the mile from The Farren Care Center to 18th Street, and another four days to fin the last 18 blocks to 1st Street–the “vicinity” of the dam.  Castro-Santos specifically describes fish as reaching “the vicinity of the Gatehouse.”   “Vicinity” in this instance, is exculpatory language.  It means shad experience further delay here, with some not proceeding upstream past TF dam.  It describes another fatal choke point in the power canal configuration–underscoring failed engineering, fish passage, and science. 

Curiously, Dr. Castro-Santos has noted at fisheries meetings that a small segment of the shad population that does manage to thread the canal maze and emerge above Turners Falls Dam to continue upstream arrives at the base of Vermont’s Vernon Dam just 1-1/2 to 2 days later.  That’s a 20 mile swim in 36-48 hours.  After 14 years of study and 34 years of excruciatingly poor fish passage through that canal towards the 50 miles of empty Connecticut River spawning habitat upstream, the only explanation for shad taking 8 days to arrive at the “vicinity” of the dam through a 2-1/2 mile-long canal is this: it’s a failure. 

 What’s dragged these fish down?—clearly an alien migration route, unasked questions and poor public science.  But electricity demand eases in spring; and FERC is asking good questions now.  Federal statutes require working fish passage and river flows that facilitate the time-sensitive spawning and migration requirements of the public’s fish.  Those requirements have clearly not been met at Turners Falls these last 34 years.  FERC releases its Study Plan Determination for new science required for hydro-relicensing on February 17th.

Note: new book on restoring East Coast migratory fish runs: Running Silver: Restoring Atlantic Rivers and Their Great Fish Migrations, by John Waldman, published by Lyons Press.  A good read, with fine, thought-provoking writing—and plenty to chew on about the Connecticut River including takes on the Turners Falls power canal migration route, river rats, and researchers.  www.LyonsPress.com

 

DUE DILIGENCE: looking beneath the surface

Posted by on 27 Dec 2013 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, Daily Hampshire Gazette, ecosystem, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC license, FirstLight, hydraulic study, shad, The Greenfield Recorder, Turners Falls power canal, USFWS

Copyright © 2013, by Karl Meyer

NOTE: the following piece appeared recently in Daily Hampshire Gazette, www.gazettenet.com; The Recorder, www.recorder.com; the Montague Reporter, and the Shelburne Falls and West County Independent.

                    DUE DILIGENCE: looking beneath the surface

New England’s Great River is at a critical juncture in the closing days of 2013.  An ecosystem door was slammed shut at Turners Falls 215 years ago when private investors built a dam across the river.  After 1798, migrating fish no longer reached northern Massachusetts, Vermont or New Hampshire.  In a landmark 1872 decision the US Supreme Court reopened the door to an ecosystem restoration via “Holyoke Company vs. Lyman.”  It upheld a Massachusetts law requiring dam owners to provide fish passage as part of the public interest of stakeholders upstream and down. Yet today there’s still no working fish passage at Turners Falls. 

As a stakeholder wishing to see the Connecticut River’s fisheries restoration succeed after decades of failure, I’m participating in the current 5-year Federal Energy Regulatory Commission’s hydro relicensing process.  It will determine conditions in the river for the next 30-40 years.  If you go to www.northfieldrelicensing.com and click on “2013 Documents,” you’ll find FERC’s “Study Plan Determination Letter” dated 9/13/2013.  It’s a 74-page catalogue of studies FERC has determined necessary to protect the public interests as they move to issue new long-range hydro licenses on the river in 2018.  Curiously, if you open that letter and scroll to the last word on the last page (74) you’ll find “Karl Meyer,” listed as “Recommending Entity” for Study 4.2.3, “Hydraulic Study of the Turners Falls Power Canal.”

I was surprised to find my name there, given that each of the 18 studies above it lists Firstlight, owners of the Turners Falls Power Canal, as Recommending Entity.  But this was no accident on FERC’s part.  They’d originally included the canal study as part of Study 3.2.2 in their preliminary judgments on the science needed to define the impacts of FirstLight’s hydro operations on river environments.  I’d agreed with them.  But FirstLight, in all subsequent filings, seemed determined to exclude it.  They simply excised “power canal” from 3.2.2: “Hydraulic Study of Turners Falls Impoundment, Bypassed Reach, power canal and the Connecticut River below Cabot Station.”  Their main argument was that the water surface level in the canal remains relatively stable through the year.  But given that what happens below the surface is what’s critical to the needs of migrating fish, I argued a canal study was a critical consideration. 

Two generations back a chance to restore fish runs beyond Turners Falls was squandered when the US Fish & Wildlife Service and four state fisheries agencies agreed to steer migratory fish into the chaos of the privately-owned Turners Falls power canal.  A singular New England opportunity to recoup and expand the river’s biodiversity was lost.  Just as in 1980, at best one-fish-in-ten emerges alive upstream there today.  Some years it’s 1-in-100.  That mistake stemmed from a failed quest to create a hatchery-strain of extinct Atlantic salmon here.  As a result, due diligence wasn’t applied to the needs of growing populations of herring, shad and sea lamprey, who would now have to survive a trip through an industrial canal on their spawning runs.  It also scuttled the only natural spawning grounds of the endangered Connecticut River shortnose sturgeon. 

Merriam-Webster defines due diligence as “the care that a reasonable person exercises to avoid harm to other persons or their property.”  Today, after 14 years of power company-subsidized canal studies that remain unpublished, we know scant little about conditions fish encounter throughout that canal.  Save for a few dozen yards at its entrances and exits, two full miles of watery terra incognita lay in between.  That missing knowledge comprises this ecosystem’s black hole. 

Yet with just tidbits of canal study information leaking into the public sphere, there is evidence that canal conditions–and the weeks-long migratory delays fish experience there, are proving lethal.  “Shad are dying in droves in the canal and we don’t know why,” is how one federal Conte Lab researcher responded to a question about mortality in the canal they’ve repeatedly studied using FirstLight funds.  Since dead fish don’t head back to sea to return as repeat spawners, the canal impoverishes a full 172 miles of river ecosystem up to Bellows Falls, VT. 

Thus, I’m proud to have my name listed next to canal hydraulics study 4.2.3.  I believe it represents FERC’s effort to exercise due diligence in getting the information needed to make the best choices in these proceedings.  It certainly represents my own.  FERC’s Ken Hogan has stated that thorough studies and reliable data are what FERC is aiming for as they decide on conditions hydropower interests will have to adhere to as they operate on our river for generations to come.  Anything less would constitute a failure of their public mandate.

 FERC’s Public Comment Period on any of the 39 studies they may require for the relicensing of Turners Falls and Northfield Mountain projects ends December 31, 2013.  Go to www.ferc.gov , and “filing e-comments.”  P-1889 is the Project # required for Turners Falls dam and canal; P-2485 is for Northfield Mountain.

 Karl Meyer is a member of the Society of Environmental Journalists.

Unconscionable: The Fate of the “Canal Nine”

Posted by on 09 Sep 2013 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Conte, Dead Reach, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, shad, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab

Note: the following piece appeared this August in Connecticut River Valley publications including: Vermont Digger, www.vtdigger.org; the Daily Hampshire Gazette, www.gazettenet.com, The Montague Reporter and The Shelburne Falls Independent, and at The Recorder www.recorder.com, (edited version).

THE FATE OF THE CANAL NINE

Copyright © 2013, by Karl Meyer     All Rights Reserved

Forty-three years after being chosen as the upstream route for migratory fish, the Turners Falls power canal remains the black hole of fisheries restoration on the Connecticut.  In current filings the US Fish & Wildlife Service is requesting telemetry coverage across the mid-Turners Falls canal to puzzle out the unexplained fate of thousands of fish.  Trout Unlimited wants balloon-tagged shad and more monitors bracketing its powerhouse to study turbine kills and migratory delay.  The Federal Energy Regulatory Commission wants a hydraulics study of that canal, where all migrants must bypass two turbine stations, then negotiate blistering turbulence just to have a shot at spawning in Vermont and New Hampshire.  On August 14, 2013, canal/dam owners GDF-Suez FirsLight rejected those studies as unnecessary in legal filings for a new 30 – 50 year federal operating license.

While every fish attempting to spawn upstream of Turners Falls dam must enter the canal, scores of questions about their fate there remain unanswered.  Basic questions like, do shad spawn in the canal, have never been studied–even though shad spend an average of 25 days there and just one-fish-in-ten that enters emerges beyond the canal.  US Geological Survey Conte Fish Lab researchers have been paid by Northeast Utilities and FirstLight for studies to improve the fish exit from the canal for the past 15 years.  Yet forty-three years after this system was put in place, it’s still one-fish-in-ten.  And canal spawning, germane to the ecosystem restoration puzzle, has never been studied.

Even more basic to success is this: if only one fish in ten makes it through—what’s the fate of the other “canal-nine”?  But you don’t pose that question if you want to keep being paid to study the public’s fish in the company’s private canal.  You study little sections of the canal–fiddle around near the company’s preferred exits and entrances—make big claims for tiny, discreet successes.  A mountain of data is collected, yet never finalized, published; nor peer reviewed.  After 15 years of study and reengineering, it’s still one-fish-in-ten.  Other agency experts wink in this shared belief: most fish entering that canal don’t survive.  Sliced-up in downstream turbines, they flush directly into the river.

“Unconscionable” is the term Dr. Boyd Kynard uses for plans afoot to move hundreds of thousands of shad into that canal via a new lift (as opposed to tens of thousands today.)   He’s an award-winning fish passage expert who logged over 25 years as a federal fish scientist– helping found the Conte Fish Lab while with the US F&WS.  Kynard believes the ineffective ladder system in place there for decades may have actually saved hundreds of thousands of fish from death in Cabot Station turbines, “The Cabot ladder is so bad most fish never reach the canal where most will exit downstream through deadly station turbines.”

Kynard, a fish behavior specialist who studied shad passage and turbine mortality at Holyoke Dam through the 1980s, believes a new lift below Cabot Station could prove the ecosystem’s next 50-year disaster.  He witnessed massive fish kills in Holyoke’s canals in the early 1980s when, starting in 1976, a new lift passed hundreds of thousands of fish upstream to spawn for the first time in 120 years.  It was hugely successful, but no one foresaw what would happen when adults headed back to sea.  While part of the migrants rode over the dam during high flows, others reencountered the dam-and-canal-system.  Tens of thousands got sucked into turbines at Hadley Falls Station or died in the canal–unable to return safely to the river. A stench of rotting fish hung over that city while dump truck after dump truck hauled tens of thousands of dead shad from the canal to the landfill.  (That condition was eventually remediated when dam owners installed a louver system in the canal to divert down-running shad into a pipe and back to the river, thus bypassing all turbines.)

But whereas Holyoke’s lift allowed shad to first spawn upstream in the river before encountering turbines, at Turners two hundred thousand fish could find themselves in a turbine-filled canal before ever getting a chance to spawn in Vermont, New Hampshire or northern Massachusetts.  And this canal’s Frances-type turbines are far more deadly than Holyoke’s.  Stressed, those newly-lifted shad can encounter two discreet turbine sites before meeting the massive canal turbulence near the dam.

This ecosystem can’t absorb another 40-year failure in the Turners Falls canal.  The USFWS, TU, and the Connecticut River Watershed Council are backing a study–adopted from Kynard’s Holyoke work, which would use low-frequency sound to deflect shad from entering the canal.  If deployed correctly it could send migrating fish straight upriver to a lift at the dam, like the one that’s succeeded at Holyoke for decades.  It’s a simple, inexpensive study–one FirstLight is already seeking to limit to a single year, or exclude altogether.  But it’s FERC who’ll decide by September 13th.  And they have a mandate to protect the public’s fish.

Comments sent to FERC Re: Northfield/TF Canal Relicensing

Posted by on 15 Jul 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, New Hampshire, Rock Dam, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont, Vernon Dam Fishway

The following are my formal Stakeholder Comments submitted on July 15, 2013, to the Federal Energy Regulatory Commission concerning GDF-Suez FirstLight’s Updated Proposed Study Plan for gaining relicensing for the Northfield Mountain and Turners Falls/Cabot Power Canal projects.  Please excuse wide line-spacing due to document format.

                                                                                                          

July 14, 2013

 

Karl Meyer, M.S., Environmental Science
Greenfield, MA  01301

 

 

 

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, N.E.
Washington, DC  20426

 

Stakeholder Comments, RE: FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) for Northfield Mountain Pumped Storage Project, FERC Project No. 2485-063; and Turners Falls Hydroelectric Project, FERC Project No. 1889-081

 

Dear Secretary Bose,

 

 

Please consider the following comments, changes and proposed improvements to FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) in order to achieve the best measurable outcomes for the public’s interest in a balanced and functioning Connecticut River ecosystem as you consider new operating licenses for hydropower generation at these two projects.

 

 

Comments refer to Updated PSP #s: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; 3.3.3; 3.3.5; 3.3.6; 3.3.7; 3.3.8; and 3.3.19.

 

Comments:

 

 

2.2.1 & 2.3.1: Proposed Changes to Project Operation

 

FL Updated Proposed Study Plan, Numbers 2.2.1 and 2.3.1: Operator is considering additional generation by adding volume, flow and velocity in, 1(p.2-15): the Turners Falls Power Canal at either Station #1 or Cabot Station, or operating Cabot Station at full capacity; and, 2(p-2-35): at the Northfield Mountain Project.  Hydraulic capacity increase at TF/Cabot sites, and at Northfield Mountain would be near 2,000 CFS respectively.

 

Any back-dated decisions in adding generation at these two licensed sites may impact the effectiveness and criteria of studies that will be implemented in the interim, and may prove confounding to the two-year study regimen.  Both would certainly impact downstream habitats and flows.  What criteria is FirstLight looking at when deciding on new generation requests—and when will they reveal their choices?

 

3.2.2: Hydraulic Study of the Turners Falls Impoundment, Bypass Reach, (“power canal”—now omitted by FL) and below Cabot Station

 

 

Note: Hydraulic study of the TF Power Canal is a key need if this is again to be considered an upstream route for migratory American shad.  After 14 years of continuous study and project improvements near the head of the Turners Falls Canal, Gate House fish passage numbers are no more improved–nor consistent, compared to numbers of fish passing Holyoke Fish Lift, than they were a quarter century ago: Holyoke Lift versus the actual percent that were able to pass up through the TF Power Canal and through the Gatehouse: (Figures from the Connecticut River Atlantic Salmon Commission Tech. Committee Meeting, Secretary’s Report: 6/18/2013)

 

Gatehouse passage success: 1989: 2.7%; 1990:7.8%; 1991:10.5%; 1992: 8.3%; 1993:3.0%

 

Gatehouse passage success: 2009: 2.4%; 2010:10.0%; 2011:6.9%; 2012:5.4%; 2013: 9.2%.

 

 

 

(p. 3-50) “FERC has requested that FirstLight develop an unsteady state HEC-RAS model in the Turners Falls Impoundment, bypass reach, power canal, and below Cabot Station to the upper limit of the Holyoke Impoundment.”

 

 

FirstLight states that a hydraulic study of the TF power canal is unnecessary, as surface (WSEL) elevations fluctuate very little.  “Given the power canal’s limited WSEL fluctuations, FirstLight does not believe a hydraulic model of the power canal is warranted.”

 

 

FERC is correct.  A full hydraulics study of the TF Canal is needed.  It is necessary as baseline information if migratory fish continue to be diverted into the power canal.  It will also be critical information if generating capacity in the TF Canal and upstream at the Northfield Project is increased by 2,000 cfs, respectively(2.2.1 & 2.3.1).  This would certainly impact hydraulics at the head gates and downstream in the power canal.

 

There are 14 head gates at the TF Gatehouse flushing directly into the TF Power Canal.  Surface level elevations have very little to say about actual flow hydraulics at this site.  Those head gate openings and the fluctuating head-levels from the TF Impoundment behind the dam create a region of extreme turbulence in the canal running some 500 feet downstream from Gatehouse.  This is one of the bottlenecks in the power canal route that has not been overcome after 43 years of study and structural changes in this upstream route.

 

 

When the agencies and the public were taken on FERC site visits, only one group in three was given a tour of this side of the TF Gatehouse.  At that time, only 4 head gates were open.  The canal appeared a relatively calm place.  When all head gates are open—as the Northfield Project and Cabot are run in peaking modes, or the TF Canal is run at baseload capacity through the day, this region is a boiling-roll of water.  Surface speeds reach nearly 10 mph (as monitored by cyclists on the canal path).  We need to know how this affects velocity and turbulence throughout the water column

 

 

Given recent fish passage increases at Holyoke Dam, it is feasible that building a facility to lift migratory fish out of the CT River and into the TF Canal below Cabot Station could divert as many as 100,000 fish into the canal over a period of a few days.  Recent work by USGS Conte Anadromous Fish Research Center showed American shad spending an average of 25 days in the power canal.  Researchers did not investigate whether this was a signature of fish mortality, spawning, or milling. Nor has the TF canal ever been investigated as spawning habitat—which would have been logical, given those lengths of stopover.  American shad notably do not do well with stress.  Piling up the population in a power canal will likely result in major migratory delays and increased mortality—which needs a full investigation if this path remains an option.

 

This should be a two-year effort, to control for differences in flow years, fish tagging and handling, and to assure that full acoustic coverage is gained through proper array deployment.

 

American shad have not been able to negotiate this region of high turbulence since this canal route was chosen for them in 1980.  At Holyoke, as well as at Vernon Dam, fish follow attraction water that leads them directly upstream to the dams.  Rates of passage at both are within the acceptable range of 40-60% that the agencies have set as targets.  When the Connecticut River above Cabot Station—aka, the Bypass Reach, was allowed to be de-watered in deference to this power canal route, shad and herring were expected to locate and negotiate a series ladders, turns, turbines, and turbulence at a half dozen canal sites in order to reach upriver spawning areas.  It’s a migratory knot; created by humans.

 

The Connecticut River migratory fisheries restoration effort risks repeating four new decades of failure if it again ignores logic.  The TF Power Canal is in need of a full hydraulic study.

 

Hydraulic modeling must be done here in order to avoid another migratory fisheries restoration disaster at Turners Falls.  Northern Massachusetts, Vermont and New Hampshire have yet to see their guaranteed shares of the targeted shad and herring runs, nor has the program achieved anything near its stated goals:  “The intent of this program is to provide the public with high quality sport fishing opportunities in a highly urbanized area as well as to provide for the long term needs of the population for food,” as stated in the New England Cooperative Fisheries Statement of Intent in 1967.

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Please ADD to Existing Information: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu.  Chapter 3-Migrations, Effect of River Regulation documents over a decade of highly relevant studies.

 

 

FirstLight’s Water Level Recorders (River Stage)The Water Level Recorders deployed by FL in 2010 that supplied “limited data” from the By Pass Reach and below Station 1 should be removed from “existing information” status.  WSEL monitoring in this reach needs to be redone.  Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Add to information list for specific information on this reach: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.

 

Additional WSEL monitors needed. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

3.3.1 Conduct Instream Flow Habitat Assessments in the Bypass Reach and below Cabot Station 

 

If migratory fish are again to be diverted into the TF Power Canal via a new lift in the river near Cabot outflows (proposed), special consideration needs to be made when considering siting the lift facility.

 

Federally-endangered shortnose sturgeon will likely enter the lift, and there exists the risk of putting them into the power canal where there is potential for turbine mortality.

 

Migratory delay: another reason for special care in considering diversion is migratory delay for American shad and blueback herring at this site.  If a lift gets built at Cabot, there will be a need for full-time monitoring personnel in order not to risk sending SNS into the canal.  Just as at Holyoke, with Atlantic salmon monitoring, the lift would then have to shut down—sometimes for weeks at a time, due to turbidity and the risk of NOT identifying a migrant salmon(or in this case, a federally endangered SNS).  This type of migratory delay would not likely be acceptable to the agencies, or FL (see FL’s added text about “without delay” under 3.3.19 : “Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.”

 

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

The IFIM Study needs to be conducted with increased WSEL monitors given FL’s stated intent to potentially increase generation and flow at the Northfield Project, Station 1, and Cabot Station.

 

Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Information list for specific information on this reach, ADD: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

Additional WSEL monitors needed to capture fuller By Pass flows profile. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

Table 3.3.1-1: Target Species and Life Stages Proposed for the IFIM Study Reaches.

 

Under Reach 1 & 2: blueback herring: add “spawning”—as New England Cooperative Fisheries Research Studies document BBH spawning in this reach, at the mouth of the Fall River.

 

 

Under Reach 1 & 2: shortnose sturgeon: add “pre-spawning.”

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.”

 

 

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

 

Study Goals and Objectives (18 CFR § 5.11(d)(1))

 

“The goal of this study is to identify the effects of the Turners Falls and Northfield Mountain Projects on adult shad migration. The study objectives are to:”

 

 

Add: “Determine route selection, behavior and migratory delays of upstream migrating American shad through the entire Turners Falls Power Canal.

 

Add to “Describe the effectiveness of the gatehouse entrances;” …

 

 

ADD IN: “and describe the behavior of migratory American in the Turners Falls Power Canal within 500 feet of the gatehouse entrances.”

 

ADD IN: “Evaluate attraction for shad reaching the dam spillway under a range of spill conditions.” 

Note:  Since a lift is being considered at this site, evaluating spillway attraction is most important.

 

 

 “Evaluate attraction, entrance efficiency and internal efficiency of the spillway ladder for shad reaching the dam spillway, under a range of spill conditions;”  see immediately below.

 

Footnote 35 “This may be achieved with existing information; FirstLight is awaiting data from the USGS Conte Laboratory.”

 

 

NOTE: USGS has done 6 years (2008 – present) of study and data collection at Spillway and Gate House.  All of it remains “preliminary”—hence never finalized, or peer-reviewed.  Only “finalized” study data and findings should be included in FERC study plan design, and made available to all stakeholders for review.  All studies are partially FirstLight funded.

 

The Need for Additional Information

 

Under  Task 1: “Review existing information:”

Only finalized USGS study information should be considered.

Task 2: Develop Study Design:

As per FERC request, a radio and PIT tag study of the entire Turners Falls Power Canal should be included in this study.

 

 

Task 3: Evaluation of Route Selection and Delay

 

             Under: Radio Telemetry Tracking: Add in:

 

“Tagged fish will be tracked throughout the Turners Falls Power Canal during bothupstream and downstream migration with fixed antennae and mobile tracking; usingPIT tags in addition to radio telemetry tags.”

 

“Additional tagged individuals may need to be released farther upstream (Turners Falls power canal, * (ADD IN: “top of Cabot Station Ladder,”) upstream of Turners Falls Dam), to ensure that enough tagged individuals encounter project dams on both upstream and downstream migrations, that these individuals are exposed to a sufficient range of turbine and operational conditions to test for project effects, and to provide adequate samples sizes in order to address the objectives.”

 

Under: Video Monitoring

 

 

Video monitoring at the Spillway Ladder is insufficient.

 

Note: Video monitoring is insufficient in determining the number of fish attracted to the spillway.  It will only register fish that can FIND the Spillway Ladder Entrance.  This in confounded by a range of competing flows, water levels present in the By Pass, and spill from the dam.  A full range of telemetry tracking needs to be employed at the TF Spillway—not simply at the Spillway Ladder and SL Entrance.

 

Task 4: Evaluation of Mortality

 

Note: Preliminary USGS TF Canal studies have suggested uninvestigated data indicating mortality within the Turner Falls Power Canal.  Mortality tagged fish and data should be collected throughout the entire TF Power Canal, to correct for overall mortality.

 

 

The number of fish suggested to be fitted with mortality tags is insufficient in all these studies, and should be increased by a factor of two.

 

Table 3.3.2-1: Proposed locations and types of monitoring and telemetry equipment proposed for the upstream and downstream passage of adult shad study.

 

 

ADD in: (to identify migration routes and delays):

 

After “Cabot Ladder”, add new location: Eleventh Street Canal Bridge: PIT Tag Reader

 

Before “Rawson Island”, add new location: TF Power Canal, 400 feet downstream of Gate House.  PIT Tag Reader and Lotek SRX.

 

 

Also before “Rawson Island”, add new location: “Rock Dam Pool, immediately downstream of Rock Dam.”  Lotek SRX.

 

 

After “Turners Falls Spillway Ladder,” add: Turners Falls Spillway, Montague Dam.  Lotek SRX;  followed by a new location, add in: Turners Falls Spillway, Gill Dam.  Lotek SRX.

 

QUESTION: What is the exact location considered for “Below Turners Falls Dam” ?

 

 

3.3.3 Evaluate Downstream Passage of Juvenile American Shad

 

Task 3: Turbine Survival

 

Evaluations should be done for all turbines, with all turbines operating, at both Cabot and Station 1, to capture the broadest range of conditions at these sites.

 

 

3.3.5  Evaluate Downstream Passage of American Eel

 

Level of Effort and Cost (18 CFR § 5.11(d)(6))

 

Study ticket price is too expensive.

 

 

“The estimated cost for this study is approximately between $350,000 and $450,000.”

 

Note: Costs of this American Eel Study are prohibitive, particularly since there is no benchmark data on the ecosystem importance of eels above Mile 122, TF Dam.

 

This rivals the costs of all studies supported to assess migration and mortality of American shad, a restoration target species to Vermont and New Hampshire for 46 years.

 

 

 A significant proportion of that money could best be used to increase the scope of study: 3.3.2, and 3.3.7: Evaluate Upstream and Downstream Passage of Adult American Shad; and 3.3.7 Fish Entrainment and Turbine Passage Mortality Study.  These could then include a full study of the Turners Falls Power Canal–and increasing the number of mortality-tagged fish.

 

Cost effectively, a literature survey, and results from Holyoke Dam studies and Cabot data collection should suffice to gauge survival of American eel at Turners Falls/Cabot/Northfield.  A portion of the funding could be used to construct an eel-way at TF Dam—a relatively inexpensive structure.

 

3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects

 

 

Under: Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Information as American spawning and spawning habitat is missing for the pool where shortnose sturgeon spawn, the Rock Dam Pool, immediately downstream of that notched ledge in the river.

 

Task 2: Examination of Known Spawning Areas Downstream of Turners Falls Dam

 

Note: The Turners Falls Power Canal needs to be investigated as a spawning location for American shad.  USGS studies have registered migratory shad remaining in the TF Canal for and average of 25 days.  Adult shad, which do not feed during spawning migration, must complete their salt-to-river-to salt spawning runs within 44 days in order to survive.  A critical need is to know whether these fish are spawning in the TF Power Canal, milling in the canal, or whether they have expired.

 

3.3.7 Fish Entrainment and Turbine Passage Mortality Study

 

Increase the number of mortality-tagged fish; run tests for all turbines at Station 1 and Cabot, with all turbines operating.

 

3.3.8 Computational Fluid Dynamics Modeling in the Vicinity of the Fishway Entrances and Powerhouse Forebays

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

 

Note: Three-dimensional CFD Modeling needs to extend 500 feet downstream of the Gate House in the Turner Falls Power Canal to capture the influence of the 14 head gates at the dam on migratory fish behavior and delay.

 

3.3.19 Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace  

 

 

General Description of Proposed Study

 

FirstLight’s added language: “This study will be conducted in 2015 pending the results of Study No 3.3.1 and Study No. 3.3.2, which include analysis of historic fish passage data.

 

Note: This study should be conducted for two seasons, the same time span accorded to American eel. 

 

Historic fish passage data likely has only minimal importance, as early spring freshet flows over the TF Spillway generally out-compete Cabot Station flows and send fish treading water at the base of TF dam—often for weeks.  Those freshet flows at the dam typically overwhelm any flow from the Spillway Ladder, and the shad essentially run down their engines treading water until the freshet subsides.  At that point, flows over the Spillway are allowed to be cut to 400 cfs, which sends the shad downstream to fight their way into the spill of the canal system. For this reason, historic data has limited value as the quantified presence of shad at the base of TF Dam is missing, and data on the effectiveness of Spillway attraction flow does not exist.

 

Resource Management Goals of Agencies/Tribes with Jurisdiction over Resource (18 CFR § 5.11(d)(2)) 

 

“• American shad must be able to locate and enter the passage facility with little effort and without stress.”

 

“• Where appropriate, improve upstream fish passage effectiveness through operational or structural modifications at impediments to migration.”

 

 

“• Fish that have ascended the passage facility should be guided/routed to an appropriate area so that they can continue upstream migration, and avoid being swept back downstream below the obstruction.”

 

Note: This study should not be contingent on results of other studies, and should be conducted for two seasons. 

1.    Its effectiveness at another Connecticut River bottleneck has been tested.

 

2.    It addresses the need to avoid migratory delay and failure for two key species that have topped the CT River fisheries restoration since 1967: American shad and blueback herring.

 

3.    It keeps the fish migrating in the Connecticut River.

 

4.    If it proves effective, it would simplify fish passage mechanisms and cut by millions of dollars the cost required for passing TF Dam.  A single set of lifts at the dam would pass fish, as it has at Holyoke for decades.

 

5.    It would avoid the expense and pitfalls of requiring fish to negotiate two mechanisms at Cabot Station, another out of the canal, and a final grid through Gate House. 

 

6.    It presents the opportunity to avoid the stress required of migratory fish when they are driven into the TF Power Canal, then must find their way through turbulence and fight a path through several more untried, built mechanisms.

 

7.    USGS studies have found the average passage time through the TF Canal is 25 days; whereas transit times in the actual river—from Holyoke to TF Dam, or from TF Dam to Vernon Dam, are generally accomplished in a matter of 2 – 3 days.

 

8.    This would avoid the problem of shortnose sturgeon being picked up in a lift at Cabot Station, which would be a cause for further migratory delay as lifts would have to stop to retrieve fish—and also might have to be shut for days during times of high turbidity. 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3)) 

Information from Proposed Project Changes, Flow, Hydraulics, Habitat, and Telemetry studies: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; should be used to inform the implementation of this study. 

 

FirstLight’s added-in text:

 

“however, simply repelling shad from the Cabot tailrace is not a satisfactory result, for this behavioral barrier to be successful the fish would also have to keep going upstream, without delay, as opposed to dropping down below Cabot.”

 

Note: this caveat does not present a satisfactory argument.  In order to be proven ineffective, delays caused by sonics repelling fish from the Cabot entrance would have to out-compete any delays American shad and blueback herring encounter by being drawn to the Spillway during spring freshet and not find a readable upstream flow or passage at the dam. To this must be added the delay and stress of having river attraction and Spillway flow cut to 400 cfs, thus sending them DOWNSTREAM to fight their way into the TF Power Canal. 

Question: Should FL be deciding what constitutes delay?  Shouldn’t American shad dropping back two miles downstream from the TF Spillway to Cabot Station be considered an “unsatisfactory result”? 

 

Methodology (18 CFR § 5.11(b)(1), (d)(5)-(6))

 

Note: Ensonification coverage may need to be deployed far enough out into the main stem so as to lead fish out to the thalweg/main flows on the west side of Rawson Island.  Simply steering fish out of the Cabot entrance, but then only allowing them the choice of the minimal flows coming down through Rock Dam at the time paltry 400 cfs release would likely keep the fish milling and confused below Station # 1. 

Study Schedule (18 CFR § 5.11(b)(2) and (c))

 

FirstLight’s Added text: “ 

If performed, the study is anticipated to conclude by mid-July 2015.”

 

Note: This should not be a contingent study. 

                                                End of Formal Comments 

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations. 

Sincerely,
Karl Meyer, M.S.

Double Standard on the Connecticut

Posted by on 09 Jul 2013 | Tagged as: American shad, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Riverkeeper, Rutland Herald, shortnose sturgeon, Times Argus, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Rutland Herald and the Barre-Montpelier Times-Argus during the first week of July.

Copyright © 2013, by Karl Meyer

This is the habitat all upstream migrants are diverted into at Turner Falls

This is the habitat all upstream migrants are diverted into at Turners Falls


                               A River Double Standard

On June 28, 2013, Federal Energy Regulatory Commission Director of Energy Projects Jeff C. Wright ruled against the US Fish & Wildlife Service as it sought two extra weeks to review hundreds of pages of just-released Proposed Study Plans for the relicensing of five Connecticut River hydro projects. “The request for a 15-day EOT to file comments on the licensee’s proposed study plans is denied.”  EOT is FERC-speak for “extension of time.”  Those studies will impact this four-state river for the next 20-40 years. Agencies joining that request included the National Marine Fisheries Service, MA Div. of Fish & Wildlife, The Connecticut River Watershed Council, The Nature Conservancy, Trout Unlimited, the Franklin Regional Council of Governments, NH Dept. of Environmental Service and The Vermont Agency of Natural Resources.

One big reason for that request was the difficulties in evaluating the impacts of FirstLight’s Northfield Mountain/Turners Falls hydro operations on the entire Connecticut River ecosystem.  Beginning last fall, FERC began deviating from its standardized relicensing model when it scheduled public site visits to FirstLight sites weeks before the company released a publicly-required 500-page Pre-Application Document describing its complex pumped storage operations and machinery.

This spring FERC also supported FirstLight’s expedited-request to conduct a series of complicated river flow studies this summer—an allowance falling well outside FERC’s strict licensing timelines.  In doing so they let the company schedule three days of river visits by fed/state agencies smack in the middle of their deadline to comment on FirstLight’s 434-page Updated Proposed Study Plan.  FirstLight released that document June 28th; comments to FERC are due July 15, 2013.  Even after nine meetings with the power company and FERC, many agency representatives continued to decry the lack of critical scientific detail provided in FirstLight documents.  Those were put together by its team of five consulting firms.  Ironically, those handpicked FirstLight firms will conduct the next two years of river studies—the ones meant to protect the river.  A fox and chicken coop analogy applies.

FERC is employing a legal double standard here on the Connecticut.  If you a public agency or citizen seeking protections for the ecosystem—well, even little rules are THE RULES.  At the same time it appears corporations can continuously and sometimes massively ignore federal license requirements with impunity.

In FERC’s own words, the Commission “enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”  Yet today Holyoke Gas & Electric is half a decade–and counting, in violation of its 2002 agreement to construct facilities to end the evisceration of federally endangered shortnose sturgeon and other “federal trust” fish migrating downstream at their Holyoke Dam facility.  So, why have a license at all? 

Upstream in 2010 GDF-Suez FirstLight dumped some of 45,000 cubic square yards of reservoir sludge directly into the Connecticut at Northfield Mountain over a 90-day period—the equivalent of 40 dump truck loads of muck per day, smack in the middle of fish migration season. Yet in current documents FERC states their inspections have never found FirstLight in violation of its license.

The US EPA found FirstLight in violation of the Clean Water Act in August of 2010 and ordered a massive clean-up, though the ecosystem damage was already done.  In an August 4, 2010 letter EPA sanctioned FirstLight for violating “FERC License No. 2485” and polluting the “navigable waters of the United States.”  A subsequent letter dated August 10, 2013 from FERC’s Biological Resources Branch Chief Steve Hocking to FirstLight Manager John Howard specifically referenced the EPA’s sanctions, directing him to “article 20 of your license.”  Yet there is virtually no FERC mention of that egregious violation in current relicensing documents.

That’s the standard that for-profit companies are held to here.  It rivals the Pirate Code.  Currently there is no watchdog entity on this river willing to go to the mat to protect the ecosystem.  If, like on the Hudson, there was an organization like Riverkeeper—which cites “enforcement” as one of its main responsibilities, these egregious injuries to the Connecticut would not likely stand.  Holyoke Gas & Electric would have been in court long ago for killing endangered sturgeon; and the full range of FirstLight’s lethal impacts on the Connecticut’s migratory fish when all are diverted into their turbine-filled power canal would’ve been fully investigated.  FERC’s inaction is a disgrace.

FERC Director Wright requested that questions regarding that EOT denial go to Ken Hogan at: 202-502-8434, or Kenneth.Hogan@ferc.gov. Ken has presided over the CT River relicensing hearings.  Also, you can find FirstLight’s 434-page “Updated Proposed Study Plan” at: www.northfieldrelicensing.com under Documents.  The public has until July 15, 2013 to send comments on that plan to FERC.  You do that at: www.ferc.gov/docs-filing/efiling.asp .  You must cite FirstLight’s project numbers, P-2485 and P-1889, and be sure to note that you are commenting on the “Updated Proposed Study Plan.”

Karl Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield, MA. Read more at: www.karlmeyerwriting.com

Crunch Time for the Connecticut River: you snooze; you lose…

Posted by on 30 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, ecosystem, federally-endangered shortnose sturgeon, FirstLight, National Marine Fisheries Service, Rock Dam, US Fish & Wildlife Service

Copyright © 2013, by Karl Meyer

Crunch Time for the Connecticut River: you snooze; you lose

(Note: the following piece appeared earlier this month in the Rutland Herald, www.rutlandherald.com, and Times-Argus in Montpelier, www.timesargus.com, as “Fish Future Hangs in Balance”) 

On May 7th the Holyoke Fish Lift passed 21,608 American shad upstream.  The next day they lifted 44,456—the all-time, single-day record for the Connecticut River.  In two days they’d passed over 66,000 shad–6,000 more than the highest number ever to pass upstream through the Turners Falls power and beyond its dam in a single season.  That occurred back 1992.  Sadly, upstream denizens may never see but a shadow of the ecosystem’s annual run of fish.  Here’s why:

 As April ended, GDF-Suez FirstLight Power cut off flow to the Connecticut below Turners Falls Dam.  Essentially the river died, reduced to a drool of 400 CFS (cubic feet per second) of flow leaking through a wide, 200 million year-old chasm of cobble, bedrock and shale.  In order to remain a working migratory system, 3,000 CFS of flow would’ve been needed to nourish the river below that dam.  Pinching off the flow there ensured that the fittest, early-arriving American shad and any remaining blueback herring (currently candidates for federal endangered species listing) would be forced from the river and into that power canal 2-1/2 miles downstream.

Right at the cusp of spawning season FirstLight diverted at least 97% of river’s flow.  It sent some 16,000 CFS through the dam head gates into the power canal to supply a portion of the region’s base-load electricity.  But beyond that, a still-undisclosed percentage of the Connecticut was gobbled-up to serve the massive pumping and generating operations of the Northfield Mountain Pumped Storage Station, five miles upriver.  Tumultuous, tide-like effects created by those operations create a whole different animal.  There, using river water amassed in a five billion-gallon mountaintop reservoir, FL generates electricity via massive surges into- and out-of the riverbed either when demand peaks—or, when prices spike instantly on the electricity “spot market”.  So, while habitats are being deeply impacted by flow manipulations at the dam for Northfield, FirstLight harvest profits form a crippled riverbed.

One result this year is that an unknown number of the last 300 federally-endangered shortnose sturgeon surviving here were forced from their ancient river spawning pool to attempt their spring rite elsewhere.  The overwhelming yearly result is, in retreat from a de-watered river, nearly all upstream migrating fish here are left with no choice but to swim into the flows exiting the Turners Falls canal and turbines 2-1/2 miles downstream.

To successfully get upstream there, fish must move through two miles of alien flows and habitat.  Then they must thread their way through brutal currents, blinding turbulence and tangled cross-currents while approaching the dam’s head gates, where–unknowingly, they are required to locate a tiny canal exit.  If they get this far, all shad and herring must punch through more quickened flow, a final series of steps, and yet another narrow opening through fluctuating water levels at that gatehouse in order to emerge above the dam.  In the best of years less than 1-in-10 shad succeeds.  For most adult fish, any trip through that canal will prove fatal.

If, this year–like at Holyoke, two fish elevators had been installed at the base of Turners Falls Dam, and–if ample flow nourished the river bed, as it does below Holyoke, some 33,000 of those 66,000 Holyoke shad would’ve passed Turners Falls a few days later.  A couple of days after that—say May 13 – 15, some 16,000 shad would’ve begun wriggling their way up the Vernon ladder past Brattleboro and Hinsdale on their way to Walpole and Bellows Falls.  And thousands more would’ve followed.  But with a deadly canal intervening, that just wont’ be happening.

Connecticut River fans anywhere from Turners Falls and Northfield, MA, to Chesterfield, NH and Bellows Falls, VT are currently hoping this ecosystem will be revived through improvements via the federal relicensing of dams at Vernon, Bellows Falls, and Wilder.  But two federal hydro licenses here in Massachusetts for the Northfield Mountain and Turners Falls hydro complex are also up for 2018 renewal.  The hard truth is, if they don’t get it right down here, there won’t be more than a whiff of a renewed ecosystem upstream.  Forget any connection to the sea.  Turners Falls/Northfield really is the ballgame.  An ugly compromise that uses that power canal as an upstream migration route will ensure a functioning river ecosystem and ancient runs of shad and blueback herring to Bellows Falls and Walpole won’t ever materialize.

Public relicensing meetings are taking place at 9 a.m. at the Northfield Mountain Visitor Center, 99 Millers Falls Rd. (Rt. 63), Northfield, MA, on Tues. and Weds., June 4 & 5.  Those ecosystem-shaping decisions will be made by those who participate.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists.

Dam Relicensing: Diving into the Dead Reach

Posted by on 28 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, federally-endangered shortnose sturgeon, FERC license, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Rock Dam, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab

Watch Diving into the Dead Reach on LOCAL-BIAS: Learn why information about fish mortality in the the deadly Turners Falls Power Canal has been kept from the public these last 14 years.

Tune-in Greenfield Community Television’s (GCTV) Local-Bias Host Drew Hutchison and guest Karl Meyer, and find out what happened when he went snorkeling in this critical segment of the Connecticut–which should be deemed a spawning sanctuary for shortnose sturgeon and migrating American shad.

The program airs Weds. May 29th at 5 pm, and again on Thursday, May 30, at 9 pm; then again on Saturday, June 1, at 9 pm.  The series repeats at those time the f0llowing week.

Go to:  http://www.gctv.org/node/5264

See also: http://www.gctv.org/schedule

The Connecticut River shortnose sturgeon

Posted by on 21 Apr 2013 | Tagged as: American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, shortnose sturgeon, US Fish & Wildlife Service, USFWS

 

Copyright © 2013, by Karl Meyer

The following piece appeared earlier this April in the Rutland Herald, Vtdigger.org, The Recorder, Daily Hampshire Gazette, Shelburne Falls Independent, and on other sites.

                       The Shortnose Sturgeon and Spring’s Teachable Moment 

There’s a watershed opportunity for teachers investigating migratory fish this spring.  It’s the final season classrooms will raise Atlantic salmon eggs from a massive federal hatchery program, dismantled after 46 years.  It’s a chance to teach kids that “extinct,” in evolutionary biology terms, means exactly that: gone, forever.  It’s a profoundly simple lesson, with ramifications that can be fully grasped in a week.  I’m hoping teachers will put a living dinosaur of a fish in that salmon’s place—one still here, though teetering on the edge of extinction these 46 years: the federally endangered Connecticut River shortnose sturgeon.  As teachable as T. Rex, this marvelously adapted, 3-4 foot fish has survived for 100 million years. 

On April 20, 1967, two federal agencies and four states signed the Cooperative Fisheries Restoration Compact for the Connecticut River.  It specifically targeted American shad and blueback herring, plus salmon–extinct here since Darwin’s birth in 1809. Within two years its emphasis had overwhelmingly veered to conjuring up a new salmon.  Still, with a little help shad and herring populations blossomed.  Combined runs reached 1,000,000 fish in the 1980s; then dropped precipitously.  Bluebacks are now rare as hen’s teeth. 

By 1975, what was then the Federal Power Commission had heard testimony that Long Island Sound had warmed to a point that might prevent cold-water salmon from entering rivers in its basin.  The climate had changed.  Still, in 1980 MA and US Fish and Wildlife Service officials insisted a series of salmon ladders be built, leading all migrants into a power canal at Turners Falls.  It failed instantly; yet skewed logic continued.  In 1983 Congress renamed the restoration The Connecticut River Atlantic Salmon Commission.  It continues today. 

Those extinct salmon had only visited here–the southern tip of their range, for a few centuries.  Importing eggs from Canada and Maine, the program proved futile, costing millions annually.  It left the real problem for native shad, herring and endangered sturgeon—a broken Connecticut River, quietly untended.  Those species had returned here for thousands of years.  Bony-plated sturgeon had been vacuuming-up freshwater mussels eons before the present valley took shape. 

On March 11, 1967, the shortnose was listed as “endangered” in the original Endangered Species Preservation Act.  No one knew how they’d survived, or how many remained.  Shortnose were sometimes landed downstream of the 1849 Holyoke Dam; and a few were recorded upstream below Turners Falls.  By 1980, researchers discovered embryos and larvae upstream–proof shortnose spawned somewhere below Turners Falls.

Beginning in 1990, Dr. Boyd Kynard and colleagues began 17 years of continuous federal and state-funded sturgeon research.  Kynard ultimately uncovered the structure of the population, its migratory patterns, and ancient spawning grounds.  A key finding established that all shortnose head upstream to an ancient spawning pool between Greenfield and Turners Falls known as Rock Dam.  Less than 2,000 survive today.  They exist in two groups of a single genetic population, separated over 150 years ago by the raising of Holyoke Dam—which luckily had left some adults upstream with access to spawning.  Fish trapped downstream were out of luck.  

Today, the bulk of the population lives in the river below Holyoke Dam.  Known as “reproductive nulls,” some 1,500 sturgeon linger in a forced limbo created by agencies charged with protecting them.  If one manages to slip into Holyoke Gas & Electric’s fish lift for a spawning ride upstream, it is trapped and pointedly dropped downstream—per orders of the National Marine Fisheries Service and the MA Natural Heritage and Endangered Species Program.  Surviving for 40 years or more, adults will repeatedly attempt to pass the dam until, genetically unfulfilled, they expire.

NMFS, MA NHESP and USFWS claim this protects sturgeon from being sliced up in HG&E’s turbines, if they return downstream after spawning.  All the while HG&E is 5 years in violation of license agreements mandating construction of safe downstream fish passage.  The Federal Energy Regulatory Commission has done nothing to enforce environmental statutes that were key to Holyoke receiving a new hydro license in 1999.

Today, some 300 sturgeon cling to life upstream of Holyoke.  An unknown number are adults.  Some attempt to spawn near Rock Dam each spring (females spawn once every 5 yrs).   According to Kynard et al, success is far from guaranteed.  Unregulated flows emanating from FirstLight’s Northfield Mountain and Turners Falls dam and canal imperil that endangered process.  Annually, spawning fails 79% of the time at Rock Dam; and 29% of the time at a default site just downstream.  Fertilized embryos are also killed when waffling flows flush them out, or leave them parching on river banks.  Many years, no young are produced.

Laws ignored; habitats decimated, river groups mum: it’s a blueprint for extinction.  Yet, amazingly, our dinosaurs persist. It’s this spring’s teachable moment.  Anyone up to a challenge? 

Karl Meyer’s Wild Animals of North America won a 2008 Teachers Choice Award for Children’s Books.  He lives in Greenfield, MA.

March 1st Deadline: Comments to FERC on Northfield/Turners Falls Hydro Relicensing

Posted by on 25 Feb 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Conte, endangerd shortnose sturgeon, EPA, ESA, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Reservoir, Rock Dam, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab

Last Call to send comments and study recommendations to the Federal Energy Regulatory Commission to guide the Connecticut River conditions mandated in the 2018 relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  The licenses will the river ecosystem for decades to come.

To file any comments on the relicensing of the Northfield Mountain Pumped Storage Project and the Turners Falls Hydroelectric Project you will need to register at: www.ferc.gov/docs-filing/efiling.asp

You must include the following project numbers for Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project respectively, with any comments: P-2485-063, and P-1889-081.

All comments are due before MARCH 1, 2013.  Be sure to include your full mailing address, phone number, and email address in your comments. (I’ve attached my comments, which are now registered with FERC, below.)

Karl Meyer, M.S. Environmental Science

Greenfield, MA, 01301                                                             February 25, 2013

To: Federal Energy Regulatory Commission

RE: Comments on FERC Relicensing Projects: No. P- 2485-063 (Northfield Mountain Pumped Storage Project) and No. P-1889-081 (Turners Falls Hydroelectric Project)

Dear Commissioners,

Please carefully adhere to the standard FERC relicensing processes and deadlines as you relicense these two projects.  Holding public and agency site visits in early October 2012 may have been deemed convenient for circumventing winter weather that might have affected visits, however it placed invested parties in the difficult position of having to view and judge hydro operations and configurations at both facilities without the benefit of knowing what operational changes and information FirstLight Power Resources was including in its PAD.

Further, of the three FERC group tours at Northfield/Turners Falls, only one group, mine, was able to view the area of the By-Pass Reach and the Turners Falls Canal and head gates from the downstream side of the Turners Falls gate house.  This is a critical area to view, and the excuse being given was that there was construction happening on the Turners Falls Bridge.  However, unrestricted access to view these sites was available to any passing citizen just yards away via a bike and walking path, open to the public.  My group only received access because I made a direct request to FirstLight’s John Howard, who was my former boss.

The two other tour groups did not get to see the confused flows created by the 14 head gates at the upstream end of the Turners Falls Canal.  The canal has been a major disappointment as the upstream conduit for all migratory fish these last 34 years.  Those head gates are open at full bore during much of the upstream fish migration season; they should have been a key component of the tour.  Nor did interested parties get to view the exposed rock bed and de-pauperizing flow regimes created by flood gate manipulations at the Turners Falls Dam that renders the By-Pass Reach a non-river.  FERC should place particular emphasis on any studies that redirect upstream migrating fish away from the confused and failed conditions experienced in the Turners Falls Power Canal, and send them directly upstream to a lift at TF Dam.  That configuration has worked quite effectively at Holyoke Dam these last 58 years.

In late January 2013, GDF-Suez FirstLight Power Resource representatives noted at public hearings that it intends to apply to FERC with a Proposed Study Plan to begin its own investigations of flows in the reach below Turners Falls Dam this April 2013, rather than the 2014 and 2015 study seasons noted in the FERC Relicensing Process.  No study in this critical segment of river known as the By-pass Reach should be undertaken without a full vetting of the proposals.  This section of river is critical spawning habitat for the federally-endangered Connecticut River shortnose sturgeon, also listed as endangered under the Commonwealth of Massachusetts Natural Heritage and Endangered Species Act.  It is also the age-old upstream route for spawning federal-trust American shad and blueback herring.  It is noteworthy that in their expedited study application that FirstLight cites the area below Cabot Station as a key shortnose sturgeon spawning location, while the critical site for these fish—used for likely thousands of years, is the natural escarpment in the riverbed known as Rock Dam, a half mile upstream of Cabot Station.

In a letter from FERC to Mr. John Howard of FirstLight Power Resources dated March 12, 2010, the Commission noted that FirstLight had failed to comply with Article 34 of the license for the Turners Falls Project, releasing just 120 cubic feet per second to this segment of the river to protect shortnose sturgeon from the effects of low flows.  The minimum requirement is 125 CFS.

With respect to measured, in-depth, long-term investigations on flow and river regulation in this reach I would direct you to the 17 years of research done by Dr. Boyd Kynard and colleagues at the Conte Anadromous Fish Research Center adjacent to this river segment in Turners Falls, MA.  The work was largely conducted via the federal Conte Lab under the US Fish & Wildlife Service and later, under the US Geological Survey, when it took over responsibilities for Conte Lab after 1999.  These investigations were also supplemented by funds, research and personnel from the University of Massachusetts at Amherst.

This research is documented in: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society and produced by Books on Demand, GmbH, Norderstedt, Germany: ISBN 978-3-8448-2801-6.  Copies can be obtained from the North American Sturgeon and Paddlefish Society:

www.nasps-sturgeon.org/#!publications  Chapter 3 concerns the long-term study of flows and river regulation on spawning success of the last 300, spawning-capable, federally endangered shortnose sturgeon in this river system—covering the period of 1993 – 2005.  This is critical, long-term research that includes seven years of findings from the time before Northfield Mountain Pumped Storage and Turners Falls Hydroelectric Project operated as a regulated utility, and the seven years when Northfield’s pumping was unconstrained by regulations and operated to profit from price spikes and drops in the energy spot market using the public’s river.  Deregulation was fully implemented here in 2000 or thereabouts.  All of these issues need careful consideration before sanctioning a rushed study plan in such a critical river reach.

When considering a new license for these facilities, careful consideration of the public’s interest should be made respecting the changes and power generation, flows, and operational practices from the commencement of the current licenses down to the present.  In 2012, Northfield Mountain Station added 40 megawatts of power to its generating facilities through retooling two of its turbines.  This increase nearly equals the total power generated at HG&E’s Holyoke Dam, the next downstream project licensed by FERC.  Two remaining turbines await power up-rates, which is a considerable addition to the generation at this plant, originally proposed and installed at 1,000 megawatts.  Currently, due to mid-license changes, it now produces 1,119 megawatts of power in an unregulated power market. noteworthy and important to be considered in weighing the public’s right to a living ecosystem, upstream fish passage, and protection of endangered species, is that Northfield Mountain’s original license was for a plant used to create “peaking power, and as a reserve unit.”  It can only produce 6-8 hours of stored power before it is spent and needs to purchase replacement power on the open market.  Its stated intention was to peak twice daily in high-demand winter and summer months, and once a day during shoulder months in spring and fall when energy demand is low.  Northfield now generates when demand is present, or—when energy prices will make the greatest profit for investors.  The river and the states have been impoverished by this profound change.

The building of Northfield was based on the availability of current and proposed power from collected regional nuclear sources (New England Power Pool) that included Maine Yankee (closed 1997); Yankee Rowe (closed 1992) Connecticut Yankee’s Haddam Neck (closed 1994), as well as two proposed nuclear plants at Montague, MA (never built.)  Vermont Yankee is currently the only “local” nuclear plant still operating, and its 40 year operating license expired March 21, 2012.  Its continued operation is contingent on findings in the courts.  It is currently operated at a loss by Entergy, and has a failing condenser system which could force its closure.  In short, Northfield is now operated well beyond the bounds of its originally stated purpose.  The public’s river is paying a high price for power, much of it now imported to pump river reserves uphill to Northfield’s reservoir from sources outside the region.  The ecological impacts to fish runs and the damaging flow regimes imperiling endangered species in the river are apparent.

As a facility with great ecological impacts that cannot produce any of its own power–one totally dependent on outside sources for power, one proposal for using this stored power source put before the Federal Power Commission in the 1960s was that Northfield not operate during the spring fish migration due to its impacts on the runs.  It is time to revisit the option of silencing the effects of Northfield Mountain so that towns and cities including Greenfield, Montague, Gill, Turners Falls, and Northfield, MA; and all the towns north to Vernon, Brattleboro and Bellows Falls, VT, and Hinsdale and Walpole, NH receive their share of the river’s ecological bounty.

Northfield does serve a function as an emergency “reserve unit” for ISO New England (Independent Systems Operator) during times of severe heat waves, or high winter demand, to deliver a high volume of power on short notice to accommodate spikes in the power grid.  Northfield could be taken off-line and kept in reserve to be operated by ISO New England solely for that purpose during the low-demand spring energy months when fish are migrating.  This would greatly benefit river ecology, species, and all upstream stakeholders.  New England’s power grid resources are currently rated at 15% above demand.  Removing the damaging effects of these operations on river ecology during critical months is a simple, equitable solution.

Northfield and Turners Falls have greatly profited by incremental power increases and operational changes over the past 34 years, while the public has watched flows, regulation, and conditions in the By-pass Reach wither to a brutal, feast-or-famine regime that denies spawning for endangered fish, and passage for upstream migrants.  This situation has effectively privatized the 2-1/2 miles of river, depriving my town, Greenfield, as well as Gill, of its share of fish and a river.  This de-pauperization has impacted all the towns upstream of Cabot Station and Turners Falls dam into central Vermont and New Hampshire.  None of these municipalities have received compensation, though in many states the loss and damage to these fish populations would be considered “take” under state statutes.  Damage in the By-Pass Reach to the Connecticut River’s last 300, spawning-capable Connecticut River shortnose sturgeon carries a significant federal fine, as well as possible imprisonment.

FirstLight’s new requests for more generation at both licensed sites should be rejected, and the damaging mid-license flow and power increases should be reversed in any new license.  Indeed, since there have now been no less than FIVE different owner/operators of this facility in the last 14 years, it would be prudent to grant only the shortest license possible in order to help track and minimize damage to the ecosystem due to operational/managerial changes, and protect the public’s interest in a living river.

Northfield’s impacts have never been fully measured with respect to flows in the By-pass Reach, but it is clear that fish passage is now at, or below, the paltry levels of the 1980s, and just a fraction of the 40 – 60% passage upstream long-targeted by the US Fish & Wildlife Service of fish that had been passed at the Holyoke Fish Lift.  Regulated, continuously monitored flows should be returned to the By-pass Reach at this time, and continuous monitoring should be included in any new licenses issued.  FirstLight has noted that in-stream data loggers for river levels and flow have been subject to vandalism.  Continuous camera monitoring of river levels and open and closed gate positions at the Turners Falls Dam would go a long way toward insuring compliance with any new license conditions.  This is an inexpensive solution that could easily include a back-up system.

With a federally endangered species present in the By-pass Reach, as well as federal-trust migrating American shad and blueback herring, FERC would do well to consider enforcing regulated flows in this stretch in accordance with law and statutes in the current license.  NOAA’s National Marine Fisheries Service has had the USGS Conte Lab findings from studies in the By-Pass reach by Kynard et al, in their possession since 2007.  This agency—as well as the MA Division of Fisheries and Wildlife, could intervene at any time.  These impacts are also affecting the success of the federal/state Connecticut River Migratory Fisheries Restoration, begun in 1967, which stipulates that all the states share equally in the bounty of migratory fish—as both a recreational and seafood resource.  In several studies by the Massachusetts Cooperative Fisheries Unit at UMass/Amherst from the 1980s it is noted that blueback herring, (Alosa aestivalis) were noted gathering at the base of Turners Falls Dam, and were also noted spawning in the mouth of the Fall River–just 300 feet downstream of the dam, by then Conte Lab Director Steve Rideout.

Further, in the late 1980s, in another mid-license power up-rate, up to 5,000 CFS was redirected out of the By-pass Reach and into the Turners Falls Power Canal for use by Cabot Station and a refurbished Unit # 1, some 1-1/2 miles upstream of Cabot.  This was undoubtedly another blow to the shortnose sturgeon attempting to spawn at their ancient grounds at the Rock Dam, though sturgeon spawning in the Connecticut here was not confirmed until 1993.

In the PAD, it is noted that FERC had not found any compliance issues during its inspections of these two projects.  However, as well as a failure to release minimum flows for sturgeon in 2009, I would direct you the US Environmental Protection Agency’s August 3, 2010 letter and Administrative Order Docket No. 10-016, sent to Mr. James Ginnetti, FirstLight Vice President, noting violations of the federal Clean Water Act.  FirstLight knowingly dumped up to 45,000 cubic square yards of silt into the Connecticut River below its fouled pumped storage plant in an attempt to clear its tunnels and intake.  This illegal enterprise was undertaken by FirstLight after failing to conduct silt removal in a manner consistent with the “due diligence” stated in its operating license.  This dumping took place throughout upstream fish migration season, May 1, 2010, or thereabouts, and continued until the EPA Cease and Desist Order of August 2010.  At that time, FERC then became involved in this egregious license violation, requesting a full report from Mr. John Howard, Plant Manager, in a FERC letter dated August 10, 2010.

In a subsequent fall meeting with agency and non-profit river interests, a FirstLight representative stated that they did not know how to remove silt from their upper reservoir, and that it had never been done successfully.  That admission came after 40 years of operating their plant.  Hence, the public, and FERC are being asked to grant a new license to operators who have not shown they can successfully maintain their facility without profoundly affecting a navigable four-state waterway and a migratory fish highway.  FirstLight has now asked for deadline relief, and is promising to have a study of siltation completed in 2014.  Perhaps all study decisions should be held in abeyance until that time, 2014—which would comply with FERC Licensing Guidelines.

 

Sincerely,

Karl Meyer

Greenfield, MA

The Dead Reach: A Community Forum on WHMP

Posted by on 20 Jan 2013 | Tagged as: American shad, blueback herring, Dead Reach, federally-endangered shortnose sturgeon, US Fish & Wildlife Service

On Tuesday, January 22, from 8 – 10 a.m., WHMP Radio, 1240 and 1400 a.m., and 96.9 f.m. in Northampton, will host a community forum to explore the future of the Connecticut River’s Dead Reach at Mile 120 in Turners Falls.  Hosted by Bob Flaherty, Denise Vozella, Bill Newman, and Mary Serez, the Live Forum will be held at Sylvester’s Restaurant on Pleasant Street in Northampton. Panel will be made up of myself, Dr. Boyd Kynard who has conducted a quarter century of fish behavior research in this stretch of the CT including groundbreaking work on federally endangered shortnose sturgeon, and US Fish & Wildlife Service Connecticut River Coordinator Ken Sprankle, as well as US F&WS dam and fish passage expert John Warner.

Stop by Sylvester’s, or listen to the forum, which will also be available by Podcast.  Find out how federal licensing decisions being made for Mile 120 on the CT will affect the ecosystem for decades to come.  Will shortnose sturgeon be protected?  Will American shad and blueback herring finally reach Vermont and New Hampshire after being locked out of this river reach for 214 years?  Tune in!

THE RIVER FIX FOR FATAL ATTRACTION

Posted by on 12 Dec 2012 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, ecosystem, endangerd shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, salmon hatchery, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab, USFWS

NOTE: The following piece, slightly edited, appeared earlier this month in Connecticut River Valley publications and outlets in CT, MA, and VT. The original version is below.

http://www.rutlandherald.com/article/20121206/OPINION04/712069975/1018/OPINION

http://www.recorder.com/home/3161519-95/falls-shad-fish-canal

Copyright © 2012, by Karl Meyer

The River Fix for Fatal Attraction

With a salmon hatchery program no longer clouding issues, the US Fish & Wildlife Service, National Marine Fisheries Service, and directors from MA, VT, NH and CT have a singular opportunity to redeem the Connecticut River restoration. They’re currently making choices for restoring migratory fish north to Bellows Falls, VT, begun under the 45 year-old New England Cooperative Fisheries Compact. The decisions stem from the 1965 Anadromous Fish Conservation Act. They’ll seal this ecosystem’s fate at four federally-licensed dams and the Northfield Mountain Pumped Storage Station until 2058.

US F&WS’s Region 5 Director Wendi Weber, John Warner, and Ken Sprankle will join National Marine Fisheries’ Daniel Morris, Julie Crocker, and MA Fish & Wildlife’s Caleb Slater in making the decisions—with input from state directors. Their 1967 mandate is restoration of shad and herring runs to offer the public “high quality sport fishing opportunities” and provide “for the long-term needs of the population for seafood.”

Sadly, in 1980 their predecessors abandoned two miles of the Connecticut to the power company operating at Turners Falls and Northfield Mountain. By allowing privatization of the river at mile 120, they killed chances of passage success for millions of American shad barred from spawning at Greenfield, Gill and Northfield, MA, right to the foot of Bellows Falls at Walpole, NH at mile 172. Unwittingly, they also continued the decimation of the ancient spawning grounds of the river’s last, 300, viable federally-endangered shortnose sturgeon.

Instead of mandating river flows and a direct route upstream to a lift at the dam, they acquiesced to diverting migrants into a power canal. That Rube Goldberg–a three-trick knot of currents and ladders, proved an utter failure to the hundreds of thousands of shad moving upstream annually through elevators at Holyoke Dam. There, via a lift built in 1955, 380,000 American shad streamed north in 1980. It’s the East Coast’s most successful fish passage; it by-passes the city’s canals.

Half or more of those shad swam upstream; but foundered in the treacherous Turners Falls complex. At the dam, just as today, some depleted their energies by treading water for weeks—washed back and forth by a power company’s deluge-and-trickle releases, finding no elevator or upstream entrance. Many eventually turned back, only to be tempted by spill from their power canal. Fish unlucky enough to ascend the ladder there found a desperate compromise. Over 90% wouldn’t exit alive. Just as today, alien habitat and extreme turbulence overwhelmed them. Only 1-in-100 emerged upstream. For the rest, a turnaround spelled almost certain death in turbines. Others lingered for weeks in an alien canal environment, until they expired. Just as today.

This year over 490,000 shad passed Holyoke. Half or more attempted to pass Turners Falls. Just 26,000, or 1-in-10, swam beyond the dam–a percentage consistently reached in the 1980s. This is described as “success” by US Geological Survey Conte Lab scientists, Dr. Alex Haro and Dr. Ted Castro-Santos, after fourteen seasons of canal study. In work garnering annual power company subsidies, they’ve attempted to model that canal is a viable migration path.

I interviewed Dr. Haro in 2007, subsequent to a 1999-2005 study finding shad passage at Turners Falls had plummeted to “one percent or less” directly on the heals of Massachusetts 1999 energy deregulation for the Northfield Mountain-Turners Falls’ complex. I asked why passage had failed there, “I wouldn’t call it failure,” Haro replied. Fish passage saw no significant rebound until 2010, when the effects of GDF-Suez’s Northfield Mountain plant were stopped cold for 6 months—sanctioned by the EPA for massive silt dumping. Likewise, Dr. Castro-Santos’s claims to passage of one-in-ten fish as progress seem deeply troubling when his findings, after 14 years, are just now revealing shad dying “in droves” in that canal, “We don’t know why.”

In 1865, James Hooper, aged 86, of Walpole, NH reported: (from The Historical Society of Cheshire County (NH) “The area just below Bellows Falls was a famous place for catching shad because they gathered there but did not go up over the falls. The fish were caught with scoop nets. One spring Hooper helped to haul out 1300 shad and 20 salmon with one pull of the net.”

Citizens upstream of the 1798 Turners Falls Dam need not accept the dead shad runs and severed ocean-ecosystem of the last 214 years at a dam operated to cull price-spikes from the electricity “spot market.” An 1872 US Supreme Court decision against owners of Holyoke Dam mandates passage of the public’s fish. Nor do citizens from Old Saybrook, CT to Bellows Falls have to accept endangered sturgeon, a lethal canal, and a dead river at mile 120. After 32 years of fatal attraction at Turners Falls, its time to stop steering fish into a canal death trap. Holyoke proves that’s possible.

Karl Meyer is a member of the Society of Environmental Journalists.

The Last, BEST Hope for the CT River: GET INVOLVED!

Posted by on 06 Nov 2012 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, USFWS

The Federal Energy Regulatory Commission re-licensing process for GFD_Suez FirstLight Power’s Northfield Mountain and Turners Falls Power Canal Projects on the CT River officially began with FirstLight’s Notice of Intent to file for two new operating licenses to use our river to make electricity for the next four decades.  Over the next four months–until the end of February 2013, officials from the US Fish & Wildlife Service, National Marine Fisheries Service, and directors of fish & wildlife programs will be meeting to decide the critical studies needed to restore and safeguard the Connecticut River through the year 2058.

FirstLight is anxious to see that the main studies guiding the “restoration” of migratory fish is based on moving migratory fish upstream through their power canal, NOT upstream through the ACTUAL Connecticut River, sitting directly adjacent to their canal.  The Power Canal route has proven a disaster, patently deadly for any river restoration.  After 32 years, and study after study, “improvements” enable ONE fish in TEN, to emerge alive, upstream of the Turners Falls Power Canal passage.  It is a death sentence for any true restoration of the river.

To learn more, tune into a broadcast of Greenfield Community Television’s LOCAL BIAS, with host Drew Hutchinson.  In the program I attempt to explain how complexity is clouding the thinking and priorities of our wildlife officials, and h0w simply requiring the Connecticut River to be allowed to flow through its own bed at critical times is the key to having a working ecosystem for the next three generations to come.

Here’s how you can tune in:

Episode (# 127) will be cablecast Wednesday 5:30pm, and Thursday and Saturday 9pm starting November 7th for two weeks. It will also be available via video on demand at gctv.org sometime next week.

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

Posted by on 24 Sep 2012 | Tagged as: Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey

Copyright © 2012 by Karl Meyer.  All rights reserved.

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

The only public site visits scheduled in the Federal Energy Regulatory Commission (FERC) relicensing process for five giant hydro-power facilities and dams operating on the Connecticut River are taking place in less than two weeks.  In Massachusetts few members of the public appear to have been apprized of the opportunity to attend federally-mandated public site tours to GDF-Suez-FirstLight’s Northfield Mountain Pumped Storage Station and their Turners Falls Dam and Canal generating facilities.  A few news items appeared in the local media about the visits, published less than 48 hours before the deadline to sign up for tours.

Thus, few members of the public registered in time to tour the complex of facilities GDF-Suez operates on a seven-mile long stretch of the Connecticut that profoundly hamper upstream migratory fish runs, and directly impact the annual spawning success of the federally endangered Shortnose sturgeon. The shortnose sturgeon’s Connecticut River spawning grounds are on a short stretch riverbed a mile below the Turners Falls Dam, adjacent to the US Geological Survey’s Silvio O. Conte Anadromous Fish Research Center.

The next chance for the public to visit and judge the impacts these facilities have on New England’s Great River may not come around again for two generations. These site visits are the critical beginnings to a six-year process that will dictate whether or not the Connecticut River is a restored and functioning ecosystem through at least the year 2058.  FERC licenses are issued to corporations for up to 40 years. The Connecticut belongs to the public, but licenses allow the leasing of a certain amount of flow to corporations to produce power, while dictating conditions that will protect the public’s interest in a restored and functioning ecosystem–including migratory and resident fish, and other riverine species and critical habitats.

Today, the Connecticut River ecosystem restoration fails profoundly at approximately river-mile 120, where most of the river’s flow and its upstream migratory fish have been shunted out of the riverbed and into the Turners Falls Power Canal.  Most migrants never emerge upstream of the punishing currents, upwellings, slicing turbines and silt-laden habitats found in the power canal.  The Connecticut River above the Northfield Mountain/Turners Falls hydro facilities has never been restored to anything resembling a functioning ecosystem.

In 1975 hearings before the Federal Power Commission (today’s FERC) that established the fish passage facilities that have failed for decades at Turners Falls, Colton Bridges, then Deputy Director of Massachusetts Fisheries and Wildlife, appeared as a member of the federal/state Connecticut River Fishery Program (established in 1967, and today known as the Connecticut River Atlantic Salmon Commission).  Bridges was asked, on the record, about the specific goals of the program:

“The program was designed to establish a run of a million American shad at the river’s mouth and extend their range to historic spawning and nursery grounds near Bellows Falls, Vermont.”

Thirty-seven years later, after Commissioners from four New England States and federally fisheries directors from what is today’s US Fish and Wildlife chose a complex series of Pacific salmon-based fish ladders and the Turners Falls Power Canal as the primary upstream route for migratory fish on the Connecticut, nothing resembling restored fish runs or an ocean-connected ecosystem exists above Turners Falls.

Simply put, those officials chose wrong—and the hangover has impacted this river for decades.

They get just one chance to do it right this time; for all of us.  But again, their silent stance seems to exclude bringing the public in on the process.  No messages or notices on state and federal public websites were posted about site tours and input.  Little or nothing on non-profit, river group sites, either. Once again it’s: “Don’t worry, we’ll take care of this.”  That’s a pretty dangerous position, considering the track record.  State and federal agencies have failed to demand operational changes that should have provided protection of federal-trust American shad, and federally endangered Shortnose sturgeon all these decades.  They have simply kept mum about their little mistake at Turners Falls back in 1975.  It has served no one well, save the power companies.

Dr. Boyd Kynard, an expert on migratory fish behavior and fish passage at large dams who helped established the federal Conte Fish Lab under the US Fish and Wildlife Service in 1990, led studies of the federally endangered Shortnose sturgeon in the Connecticut River at Turners Falls for 17 years.  It’s the fish fisheries officials don’t talk about in public.  Dr. Kynard spent over a decade compiling his work and that of nearly a dozen co-authoring scientists into a book entitled Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Conservation Society in Germany last February.  Intervention by the US Geological Survey delayed distribution of the book in the US for several months, and it continues to be difficult to purchase.

However, Dr. Kynard, with permission from the World Sturgeon Conservation Society, released a chapter of the book to me for citation while it was “in-press” back in August of 2011.  Since so few members of the public will get a chance to visit these sites, and since the book is currently only easily available through its chief author, Boyd Kynard, (contact Dr. Boyd Kynard at BK Riverfish, LLC, kynard@eco.umass.edu), I’m printing the abstract from the chapter on spawning and the effects of power company regulation of downstream flows at Turners Falls Dam.  The chapter’s science was done at the federal Conte Lab using funds from UMass, along with federal funding from US Fish & Wildlife Service and USGS.  Kynard’s co-author on this chapter is Micah Keiffer.  Note that the “Rock Dam” is not a conventional dam, but an ancient stone formation in the riverbed, creating a natural spawning pool that Shortnose sturgeon have used for centuries.

Abstract: “During 17 years, we studied the spring spawning migration and spawning of adult Shortnose Sturgeon Acipenser brevirostrum in the Connecticut River, Massachusetts.  Increasing day length (13.4−14.2 h), not increasing temperature (7.0–9.7°C) or river flow during 13 April–2 May likely triggered pre-and non-spawning adults to leave wintering areas and migrate.  Females initiated pre-spawning migration later than males, during lower flows and higher water temperatures, a strategy that conserved energy after wintering.  The pre-spawning migration failed one year (2002), an event probably related to reduced energetic resources of wintering fish caused by high temperatures and low flows during the previous summer foraging and wintering periods.  Pre-spawning adults homed each year to the same 1.4-kilometer-long spawning reach at Montague, Massachusetts, where river current likely determined where spawning occurred: either the Cabot Hydroelectric Station tailrace (area, 2.7 ha) or the Rock Dam, a natural mainstem fast run (area, 0.4 ha).  Spawning occurred when three spawning suitability windows were simultaneously open: (1) day length = 13.9−14.9 h (27 April–22 May), (2) mean daily water temperature = 6.5–15.9°C, and (3) mean daily river discharge = 121–901 m3s-1.  Annual spawning periods were short (3–17 d), which may be typical when only a few females are present.  Spawning periodicity was 1–5 years (mean 1.4 years) for males and 2−10 years (mean 4.5 years) for females.  Peaking operations at Cabot Station did not prevent females from spawning in the tailrace, but likely displaced and stranded early life stages.  During 14 years, spawning at Cabot Station succeeded 10 years and failed 4 years (28.6% failure); while spawning at Rock Dam succeeded 3 years and failed 11 years (78.6% failure).  Spawning failures at Rock Dam were due to river regulation.  Females spawned in a wide range of water velocities (0.2−1.3 m/s); however, the flow regimes created by river regulation and peaking operations exceeded even their broad adaptation for acceptable water velocities.”

* It should also be noted here that not a single representative from the National Marine Fisheries Service the agency federally mandated by Congress to protect the shortnose sturgeon, signed up to tour FirstLight’s power facilities.

 

A Failure to Protect

Posted by on 02 Aug 2012 | Tagged as: American shad, Bellows Falls Fishway, Connecticut River, Connecticut River ecosystem, Conservation Law Foundation, Conte, endangerd shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, NOAA, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey, US Geological Survey's Conte Fish Lab, USFWS

Copyright © 2012, by Karl Meyer      All Rights Reserved

The following essay appeared in July in the Vermont Digger (www.vtdigger.org); the Rutland Herald (www.rutlandherald.com), and other Valley venues.

A Failure to Protect

This Valley lost a lion of environmental defense when former Conservation Law Foundation Attorney and Antioch University Professor Alexandra Dawson of Hadley, MA died last December.  Quietly today, time grows desperately short for the ecosystem’s only federally-endangered migratory fish–the Connecticut River Shortnose sturgeon.  Alive since the dinosaurs, they arrived shortly after the glaciers left.  They are clinging to life by a thread–with perhaps 300 attempting to spawn annually in miserable conditions created in the 2-mile stretch of river below Turners Falls Dam.  NOAA’s National Marine Fisheries Service is responsible for protecting them; NMFS has known fully of those conditions since 2004.

FirstLight-GDF-Suez creates those conditions, right next to the US Fish & Wildlife’s Great Falls Discovery Center.  Yet the public is taught nothing of them.  Abandoned by federal agencies, the Shortnose is one industrial disaster or spill from extinction.  Your grandkids wouldn’t have been interested anyway…

But just in case, describe something that was a cross between a dinosaur, a catfish, and a shark.  At 3 – 4 feet long, Shortnose have bony plates instead of scales, with shark-like tails at one end, and suctioning, toothless mouths below cat-like feelers at the other.  They scarf down freshwater mussels whole; then grind them up in gizzards.  Shortnoses can live over 40 years: one alive today might’ve witnessed Richard Nixon signing the Endangered Species Act in 1973.  They had other priorities though, like survival.  But for how much longer?

Conditions most-imperiling the Shortnose are overwhelmingly the result of FirstLight-GDF-Suez’s floodgate manipulations and punishing water pulses sent to the riverbed and coursing down their two-mile long Turners Falls Power Canal via their dam, and operations at their giant 1,080 megawatt (now 1102 MW) Northfield Mountain Pumped Storage Station upstream.  Below the dam you won’t find anything like a river.  For a fish its manipulated chaos–a feast or famine flow regime run largely to maximize the day-trader profit margins of today’s deregulated energy spot-market.  And things may have just gotten worse.

FirstLight’s pumping and dam operations are the biggest disruptor to this ecosystem for a 7 mile stretch–affecting migratory fish restoration failures upstream to Bellows Falls, VT, and down to the Sound.  Instead of shad and other migrants moving up natural river habitat to the dam, they are funneled into a deathtrap: the turbine-riddled bottleneck of the Turners Falls Power Canal.  Barely one shad in ten emerges upstream alive–while crowded-in fish turning back out of that canal are diced-up in its blades.  US Conte Fish Lab researchers dubbed last year’s power canal shad passage a “success.”  FirstLight helped fund their study.  The dismal 16,000 shad they tallied mirrored “success” from 1987, a quarter century back.

And, if you are a spawning-age Shortnose wholly-dependent on spring riverbed flows resembling a natural system below that dam: you’re out of luck.  Annually, attempts at spawning fail in an ancient pool near Conte Lab.  Or, as conditions deteriorate, they default downstream to try spawning below the canal’s outflow.  Here again reproductive failure is common.  Dam-deflected surges deluge their gatherings; or flows get cut-off in minutes, causing mating-stage fish to abandon spawning.  Even when eggs get fertilized, embryos get silted-over or washed away by floodgate surges–or left to die on de-pauperized banks when flow is cut.  Most years no young are produced.  That’s extinction’s fast-track.

FirstLight’s Northfield Mountain offers tours of its 2 megawatt solar installation, but none to its reservoir and pumped-storage plant where, during fish migration in 2010, they dumped 45,000 cubic square yards of sludge directly in the river over 92 days.  This winter they quietly added 22 megawatts to those giant turbines: more than half all the power generated by HG&E’s Holyoke Dam.  This occurred despite their failure last July to have an EPA-mandated plan in place to prevent “polluting the navigable waters of the United States” with a mountain of pumped-storage silt.  Where are the public Federal Energy Regulatory Commission hearings on this license change?  Where is the Environmental Impact Assessment for endangered Shortnose sturgeon?

Northfield, dependent on nuclear power to pump its water, opened in 1970.  Its legally-stated purpose was as a “reserve” power source—to operate a few hours mornings and afternoons during peak energy use.  It can generate just 8-1/2 hours; then its reserve is depleted. Originally it was proposed they’d shut during fish migration.  Today, wildly outside its stated intent, those giant pumps are switched on like a coin-op laundry–day, night, with turnaround intervals of as little as 15 minutes.

Time is running out for the Shortnose; corporate fines for harming one start at $200,000. Our region’s electric capacity now exceeds 15% of demand.  Except for emergency power grid situations, why is this plant allowed to cripple an ecosystem?  Alexandra Dawson would surely cheer if her old Conservation Law colleagues sued National Marine Fisheries Service: for failure to protect a New England biological gem.

Environmental journalist Karl Meyer writes about the Connecticut River from Greenfield, MA and holds an MS in Environmental Science from Antioch University.

On the Hook: on WHMP, Tuesday, May 1st, 6:30 & 8:00 a.m.

Posted by on 29 Apr 2012 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, endangerd shortnose sturgeon, federal trust fish, federally-endangered shortnose sturgeon, shortnose sturgeon, Turners Falls power canal, Vernon Dam Fishway

On Tuesday morning, May 1st,  at 6:30 a.m., I  join Morning Show Host Bob Flaherty on WHMP Radio in Northampton for a short segment best described as “On the Hook,” a dam-by-dam, power plant-by-power plant assessment of the regulations and laws being broken and skirted that continue the institutionalized failure of the 45 year migratory fish restoration  on the Connecticut from Holyoke, MA to Vernon, VT.  The segment repeats at 8:00 a.m.

Get a snapshot of who’s doing what, where–and why misdirected science continues to stress sending “federal trust” American shad and blueback herring into a black hole at the Turners Falls power canal while no one is talking about the Connecticut’s federally-endangered shortnose sturgeon.  Should be of interest to anglers, teachers, artists and anyone concerned with the Connecticut River ecosystem.

Tune in if you can at: http://www.whmp.com  Locally@ 1400, or 1240 AM.

The DEAD REACH CHRONICLE on LOCAL-BIAS

Posted by on 31 Mar 2012 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Dead Reach, endangerd shortnose sturgeon, Endangered Species Act, Northfield Mountain Pumped Storage Reservoir, shortnose sturgeon, teachers, Turners Falls dam, Vermont

THE DEAD REACH CHRONICLE on LOCAL-BIAS: Why the Connecticut River Ecosystem dies in the two mile stretch between Greenfield and Turners Falls, MA—and what could fix it right now!

Tune-in Greenfield Community Television’s (GCTV) Local-Bias Host Drew Hutchison and guest Karl Meyer, and find out why it would be compelling to hold a “DEAD REACH FESTIVAL” in Turners Falls and Greenfield–and how it could help artists, teachers, anglers, and school kids get to the truth about our River and begin fixing the ecosystem right here in our own back yard.

New England’s Great River system essentially withers and dies in the miserable dearth-or-deluge conditions caused by flows and manipulations below Turners Falls dam—conditions largely imposed on this critical reach to operate the Northfield Mountain Pumped Storage Station just upstream.  For the sake of creating a total of 8-1/2 hours of reserve electrical generation, the River’s ocean connection and the American shad run upstream to Bellows Falls, VT is sacrificed—while the Connecticut’s ONLY federally endangered migratory fish, the shortnose sturgeon, is literally brought to the brink of total reproductive failure, year-in, and year-out, by miserable instream conditions forced upon them by dam operations.

This show airs tonight: Saturday, March 31, 2012, at 9 pm, on Local Channel 15; and repeats this coming week on Weds., April 4 at 5:30 pm; Thurs. April 5 at 9; and Sat. April 7 at 9.  You can also view it online.  Go to:  http://www.gctv.org/node/5264

See also: http://www.gctv.org/schedule

Its about the River, AND the Fish…

Posted by on 19 Jan 2012 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Dead Reach, ecosystem, federal trust fish, FirstLight, Northfield Mountain Pumped Storage Reservoir, river steward, salmon, Salmon eggs, salmon hatchery, sea lamprey, shad, Turners Falls dam, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, Vermont, Vernon Dam Fishway, Walpole

© Copyright 2012 by Karl Meyer   All Rights Reserved

The following Opinion piece appeared in publications and media sites in CT, MA, VT, and NH.  It is a reply to writing in support of the status quo on the Connecticut River fisheries restoration, emphasizing extinct salmon.  The writer, Mr. Deen, is a river steward, flyfishing guide, and VT representative.  This piece appeared mainly in a shorter, Letter to the Editor format.  Here it appears in an expanded OpEd, this version from The Vermont Digger.  Find them at www.vtdigger.org. 

                        It’s about the river, AND the fish…

The Connecticut River Watershed Council’s Vermont River Steward David Dean asks the public not to judge the 45 year-old Connecticut River Atlantic Salmon Commission’s fisheries restoration by numbers of returning fish, while 74 salmon reached the CT’s first dam at Holyoke, MA in 2011.  As someone advocating rededicating funds away from an extinct salmon strain, I found the piece well-intentioned but short on fact.

After decades and hundreds of millions spent on the science, genetics, and hatcheries dedicated to a centuries-extinct, cold-water salmon on the southern-most river it ever briefly colonized, the public has a right to a return on investment in this time of demonstrated climate warming.  I agree that that return should be an improving river ecosystem.  Useless dams should be eliminated; hydro operations damaging rivers and skirting regulations protecting fish should be prosecuted.

But Mr. Deen cites as salmon-program benefits “growing populations of other anadromous fish,” specifically shad and lamprey.  Science is, and should be, about measurable results.  Yet in results coming back from a hatchery program dedicated to elite angling, salmon represented less than three-hundredths of 1% of this year’s fish returns, while devouring 90% of funding for all migrants.  As to the 244,000 American shad and 19,000 sea lamprey he touted as reaching Holyoke–that’s a 66% plunge from the 720,000 shad counted there two decades back; and 19,000 lamprey?—only 4 years have seen lower numbers since tallies began.  Personally, I’d note 138 blueback herring–a might shy of the 410,000 Holyoke counted in 1992.

It is time for an ecosystem restoration.  Turn this upside-down species pyramid back on its base–rededicate funds to bedrock species of this ecosystem.  River groups could contribute greatly by opening public discussion about desperate river conditions just below Turners Falls, the second dam on the CT.  Migratory fish there are funneled into an ecosystem death trap: Turners Falls power canal.  Meanwhile the adjacent Connecticut is strangled in its own bed by pummeling and parching flows–deeply impacted by pumping operations at Northfield Mountain just upstream.

Today, the only shad regularly reaching VT/NH waters are a few hundred sometimes trucked there from Holyoke.  However, in 2010 Northfield Mountain Pumped Storage Station choked on its own silt.  Its mile-long intake tunnel and turbines became massively clogged.  From May 1st to November, it did not add a single watt of energy to the grid.  Few noticed.  There was no energy interruption—even while Vermont Yankee was down for refueling in early May.

Yet something amazing happened: shad numbers passing Turners Falls skyrocketed over 600% to levels not seen in 15 years.  Without Northfield pumping–and with river levels kept steady and artificially high at TF dam as FirstLight Power tried to conceal a 65,000 ton mountain of silt it was dumping in the river, the miserable conditions in the riverbed below the dam actually improved.  With May and June rains arriving, artificially brimming river levels behind the dam meant more steady flows were released directly downstream to the oft-parched and pummeled “dead reach” of river below the falls.  Shad got their ancient migration route back—swimming upriver, rather than being deflected into the punishing currents and turbines of the Turners Falls power canal.

Even with suspect tallies and FirstLight’s counting equipment inoperable for parts of 37 days, 16,768 shad were counted passing toward VT–the most since 1995.  Vermont salmon expert Jay McMenemy expressed surprise when all eight free-swimming salmon also used the ancient riverbed to shoot directly upstream to the ladder at the dam.  Since 1967 over 11 million shad have passed Holyoke.  All but a whisper of them ever made it to the Green Mountain State, while they once spawned to Bellows Falls and Walpole, NH.  Ironically, federal studies show 17,000 shad is a shadow of the run that should be passing: at least half of all shad passing Holyoke eventually attempt to pass Turners Falls–95% get deflected into the meat-grinder of currents and turbines of the Turners Falls power canal, never to emerge.

The main reason for no Vermont fish runs: no regulated flows in the riverbed; no easy-access fish lift built upstream at TF dam.   The ecosystem dies in the 2 miles of river directly below Turners Falls—due in large part to floodgate manipulations to accommodating Northfield’s pumping.  There is no working fish passage at Turners Falls.  It is legally required and should have been in place over a decade back.

Northfield Mountain is a reserve energy source that can produce a large amount of energy, 1,000 megawatts, in a very short time.  But it can only run for 10 hours, and then its reservoir is depleted.  It is dead in the water.  Owners must then go out on the market and buy electricity to divert the Connecticut’s flows uphill to its 5.6 billion gallon reservoir again.  Then, they sell our river back to us as expensive energy.  Northfield’s efficiency is just 67%.  Add in its profound river impacts and you have to question: Why is no one talking publicly about this ecosystem-killing elephant in the room?

Karl Meyer is an environmental journalist and award-winning non-fiction children’s author who writes frequently about Connecticut River issues from along its shores at Greenfield, MA.

THE “BIG GAME” PROSECUTION of RYAN MCCULLOUGH: another red herring in a failing Connecticut River restoration

Posted by on 19 Jan 2012 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Dead Reach, didymo, endangerd shortnose sturgeon, Endangered Species Act, ESA, federal trust fish, FERC license, FirstLight, Northfield Mountain Pumped Storage Reservoir, Pioneer Valley News, Rock Dam, salmon, salmon hatchery, shad, shortnose sturgeon, The Pioneer, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Walpole

© Copyright 2012 by Karl Meyer    All Rights Reserved

The “big game” prosecution of Ryan McCulough: another red herring in a failing Connecticut River restoration

(NOTE: the following article first appeared in The Pioneer, January 5, 2012, available now on free newsstands from Springfield, MA to Bellows Falls, VT.   Find it online at: www.pioneervalleynews.com )

Legend has it a reporter once asked career criminal Willy Sutton, aka Slick Willie, to explain his long history of thefts, “Willy, why do you rob banks?”  Sutton, a master of disguise, purportedly answered in terms as honest as a crisp January day: “Because that’s where the money is.”

At criminal proceedings in a jtrial scheduled for January 12, 2012 in State Superior Court at Windsor, VT, accused Atlantic salmon poacher Ryan McCullough will likely be asked why he was fishing downstream of the US Fish & Wildlife Service’s White River National Fish Hatchery(WRNFH) last July 25th.  With the Connecticut River and a failed migratory fish restoration looming as backdrop, I’m hoping McCullough replies with a similar bit of direct irony: “Because that’s where they make the fish.”

Last August a hatchery-bred Atlantic salmon created in controlled environs at the White River hatchery in Bethel, VT, was traced via a receiver to a radio-tag blipping away in the freezer of a nearby home.  That tag, hidden inside a 31-inch, 9-1/2 lb. salmon, landed the 22 year-old fisherman in hot water.  McCullough, an aspiring fishing guide, contended he mistook the fish for a huge brown trout.  He’s now charged with taking a “big game species” under Vermont fish and wildlife statutes.  Conviction carries a $1,500 fine and a possible 3-year suspension of his hunting and fishing license.

That big game fish McCullough caught was not even remotely connected to a healthy river system.  It was homing back from the sea to an artificial environment only a factory fish would recognize as habitat—the climate-controlled conduits of WRNFH.  That aqua-culture facility is part of a 19th century industrial idea: factory production substituted for a working ecosystem under the 44-year old banner of the Connecticut River Atlantic Salmon Commission (CRACS)’s Connecticut River migratory fish “restoration.”

The fly-fishing community was abuzz about this incident.  Yet the only “wild” thing about that salmon was its public perception.  It had been conceived at the hands of humans.  The egg and milt (sperm) that spawned it had been matched up by computer models, those genetic fluids were mingled together in plastic tubs, swirled by human hands.  In that immaculately-sterile conception a tiny fish was produced—one of ten million “fry” that were later flushed into Connecticut River tributaries to swim to the ocean.  Every tiny fish produced and released that year along with the one McCullough was to catch two years later was at least two generations removed from any salmon that had ever tasted the salt sea.

In the months just prior to McCullough’s apprehension fisheries personnel at the Holyoke, MA, fish lift on the Connecticut had intercepted the entire spring salmon “run” from the decades-old, half-billion-dollar-plus effort—still politely referred to as a “restoration.”  They trapped all 107 returning fish.  Of those, all but nine were put in trucks and rushed to sterile, hatchery-lab settings where they were weighed, genetically profiled, vaccinated, quarantined, had their fins clipped, and tissue samples taken.  All would ultimately be needed as breeding “stock” for next years dump of millions of “state-farmed” salmon babies into Connecticut River tributaries.

However, ensuing developments at White River will make it interesting to see if Vermont Fish & Wildlife continues in its attempt to make an example of Ryan McCullough.  Tragically and ironically, WRNFH was all but washed away by Tropical Storm Irene just weeks after he was brought up on poaching charges.  A storm surge of White River water entered pools, conduits, wells and buildings throughout the facility—overwhelming well-water fed fish ponds and carrying in the seeds of didymo, aka Rock Snot.  Didymo is an easily-spread invasive alga that was discovered upstream of the hatchery 3 years back.  It smothers river bottom habitats.

Suddenly, tiny salmon fry and over a half-million surviving hatchery fish had become potential carriers of a Rock Snot plague–if they were to be spread in the annual truck-and-dispersal system into Connecticut tributaries and the lakes and streams of four New England states.  Annual production costs alone for five salmon hatcheries around New England can reach a million bucks per facility.  Mistakes and the necessity for new “bio-security” protocols and upgrades repeatedly send costs skyrocketing.  And, after 44 years of trying to create a new strain of cold-loving salmon on the southern-most river it ever colonized, the number of hybrid salmon returning to a warming Connecticut River averages between 40 -100 fish.

A quick damage estimate by USFWS for White River was put at between $10 – 14 million.  But the hatchery would have to be “depopulated;” then sterilized, before any rebuilding could start.  They’d likely have to kill and landfill half a million fish, including hatchery trout and salmon.  Desperate to put a good spin on this second million-dollar disaster at WRNFH in 3 years, USFWS and CRASC scrambled to find a feel-good PR angle.

Ultimately they “reached out” to federally-recognized Native American tribes, inquiring if they would like a “gift” of expensive hatchery salmon—some 8,000 of the table-sized fish were still swimming on site.  Some tribes immediately accepted.  CRASC convened quickly to take a unanimous vote legalizing the “donation.”  They then began killing, gutted and icing the largest salmon, happy to pass them along to indigenous peoples of the Northeast.  Within hours of that vote, CRASC’s feel-good ‘fish-to-the-Indians’ story hit the media via the Associated Press.

Ironically, the 600 largest of those choice “gift” salmon were near replicas–in size and weight (30 inches, 9 lbs), to the fish Ryan McCullough sits accused of poaching months earlier.  But at this point it appears the angler can mount a pretty decent defense.  Back in July he’d actually let a local paper photograph him holding his prize “brown trout” prior to placing it in that freezer.  Though the photo showed a fish appearing to have the slightly hooked lower jaw of a “cock” salmon–that PR move would have been a hugely naïve bit of bravado, something a knowing, and aspiring, fishing guide would never do.  His supporters, including fish and game people, contend he simply may have made a rookie mistake.

Curiously, if he’d purchased a MA fishing license and landed a tagged salmon there, the Bay State penalty would have been akin to a parking ticket: $50 – $100.  Why??  MA doesn’t have a hard classification for exactly what these hybrid fish are.  They aren’t considered a native Connecticut River migratory fish in MA, where the Connecticut’s minor salmon strain has also been extinct for over 200 years.  This is also likely the reason there isn’t a federal prosecution looming for McCullough.  Connecticut River Atlantic salmon are officially classified as “extirpated” by the US Fish & Wildlife Service.  To prosecute him they’d have to hold a monkey trial with a hybrid fish at its center, a spectacle Darwin himself would shake his head at. Considering the fish give-away status at the WRNFH–and the endlessly-failed Connecticut River salmon restoration program, Vermont is going to look foolish if they don’t let young Ryan McCullough off the hook.

But the Green Mountain State has long had a blind spot about all other native migratory fish on the Connecticut save for extinct salmon.  Fisheries officials there long-ago staked Vermont’s idea of pristine environments and elite sport fishing on the creation of a new salmon strain to replace one not seen since 1809.  Decades later, Vermont anglers, as well as those just across the river in New Hampshire, are left without a nifty shad run anglers could be tapping into all the way to Bellows Falls and Walpole.  They get no fish at all, save spawned-out hatchery lunkers dumped into local lakes as salmon program PR (*USFWS Region 5 put out an official advisory on consuming hatchery salmon way back in 2004).  Meanwhile, their rivers and tributaries face the ongoing specter of new and potentially-catastrophic emerging fish diseases being spread through hatchery operations in a time of warming climates.

The full ironies of last summer’s comedy of errors become even more apparent looking just south of the Vermont/New Hampshire border to the federal Conte Fish Lab where CRASC meetings are held beside the dead stretch of Connecticut River in Turners Falls, MA.  CRASC and USFWS are responsible for all the “federal trust” migratory fish on the Connecticut including blueback herring, American shad, and federally endangered shortnose sturgeon.  Yet there, state and federal fish guardians continue to ignore the river’s most-critical 2-1/2 mile chasm—one that’s been key to migratory fish restoration to Vermont and New Hampshire for decades.

Thirty years ago VT and NH should’ve begun crying foul due to the lack of accommodating flows and a fish elevator (still yet to be built) directly upstream at Turners Falls dam.  Implementing those proven remedies–required under federal and state license regulations for migratory fish to reach upstream waters, would long ago have revived those “dead reach” flows during spawning season—concurrently providing easy upstream passage for very fishable runs of American shad all the way to Walpole, NH and Bellows Falls, VT.  Today, the Connecticut’s federal trust run of American shad expires in the dead reach below Turners Falls dam, deflected into the treacherous environs of a power canal.  For decades now VT and NH anglers have been denied fishing for what would’ve amounted to millions of 3 – 6 lb. shad, a tasty catch that makes for excellent fishing in anyone’s book.

Today, funded in part by FirstLight-GDF-Suez, (the global power company manipulating pulses sent downriver from their Northfield Mountain Pumped Storage Station, and flows diverted into their Turners Falls Power Canal) USFWS, CRASC, and federal Conte lab researchers continue ignoring the devastation to migrating and spawning river fish from company flow regimes.  In deference to FirstLight’s preferences, annual agency studies continue emphasizing sending migrating fish into miserable habitats, cross currents, and slicing turbines of the Turners Falls Power Canal.  Meanwhile, virtually next door to the federal Conte Fish Lab, federal trust American shad runs and whole season’s production of eggs and young from the river’s only spawning population of federally-endangered shortnose whither in a dying reach of river annually.

Perhaps most shameful of all is that there is virtually no federal enforcement or prosecution for the year-in, year-out, damage to those federally endangered sturgeon.  US Endangered Species Act protections are wholly ignored for this population, which measures only in the hundreds.  The beleaguered two-mile reach behind the federal Conte Lab has served as their historic mating ground for untold centuries.

Annually, successful shortnose sturgeon spawning in this reach occurs less than half of the time.  Much of the loss is preventable, and could be stemmed in large part by enforcing environmental statutes that would quell the punishing effects of the water pulses and parching trickles sent downstream by Northfield Mountain/Turners Falls dam operators toward an ancient, low escarpment in the river known as the Rock Dam.  Shortnose sturgeon have spawned at this site since before well before Columbus sailed.

More losses arise from the company’s spawning-season water diversions into—and out of, the Turner Falls Power Canal.  That flow can be, alternately, either so strong, or so halting, that it can stop an entire season’s worth of sturgeon mating dead in its tracks.  Or, those same vacillating pulses will either wash downstream, or strand, a season’s worth of tiny sturgeon embryos–leaving them to decay beneath the silt, or desiccate on barren riverbanks.  Either way, a year’s worth of endangered shortnose sturgeon production regularly gets sideswiped to oblivion.

The penalty to an individual for catching, killing or interfering with a federally endangered shortnose sturgeon is up to a year in jail, and a $100,000 dollar fine per instance.  That penalty is increased to $200,000 for corporations, which seems a bit out of balance.  Right at Turners Falls–adjacent to the US Geological Service’s Silvio O. Conte Anadromous Fish Lab and just downstream from the US Fish & Wildlife Service’s Great Falls Discovery Center, there is documented evidence of annual damage to the Connecticut River’s only spawning population of endangered shortnose sturgeon, yet here no one is being dragged into court…

At the November 10, 2011 CRASC meeting in Turners Falls, USFWS’s Connecticut River Coordinator Ken Sprankle announced the outlines and some preliminary observations from a multi-year American shad migration study he’s begun.  With assistance, Sprankle caught and radio-tagged over a hundred shad, some at the mouth of the Connecticut, some at the Holyoke fish lift.  This allowed him to track their movements via receivers placed along the river as they made their upstream runs.  Partly funded by FirstLight Power, federal Conte Lab researcher Dr. Ted Castro-Santos partnered on the Sprankle study.  Castro-Santos was the point person responsible for siting receivers along the river from downstream of the Turners Falls Power Canal up to the Vernon dam in Vermont.

Sprankle termed the undertaking a “whole river study for shad,” one that would help in understanding how they use the river in migration.  He further noted that Dr. Castro-Santos had placed radio receivers throughout FirstLight’s Turners Falls Power Canal.  At that point I asked how many receivers had been set up in the “actual river bed”—referring to the Connecticut’s embattled, 2-mile “dead reach” just beyond Conte Labs west windows.  As expected, he answered that none were in place to monitor that section or river.  It’s remains the river’s missing link.

Thus, from the foot of the Turners Falls canal to the base of Turners Falls dam, Sprankle and Castro-Santos will have no data on shad movement in a critical river reach.  I pointed out to Sprankle that the undertaking could not then be considered a bona fide “whole river study for shad.”  This is decidedly a broken river study—missing the miles of streambed where a river’s ocean-connected ecosystem dies.  I further observed that the section Castro-Santos has chosen to monitor promotes a power “canal restoration”—a configuration that has failed for the past 40 years, and one that let’s the power company wholly off the hook in terms of sustainable flows for federally-endangered shortnose sturgeon and working, direct, upstream fish passage for federal trust American shad.

Ryan McCullough is scheduled to appear on Thursday, January 12, 2011, in Room 1 of Vermont Superior Court in Windsor at 9:00 a.m.  He is pleading not guilty to the charge of knowingly taking a “big game species” and has chosen to be tried by jury, represented by attorny Jordanna Levine.

Mirror to the Past: a legacy of failure at Turners Falls

Posted by on 21 Dec 2011 | Tagged as: American shad, Anne Makepeace, Atlantic salmon, blueback herring, Captain William Turner, Connecticut River, Connecticut River Atlantic Salmon Commission, CRASC, Daily Hampshire Gazette, Dead Reach, didymo, federal trust fish, Jessie Little Doe, Narragansett, Pilgrims, Rock Dam, Rock Snot, Rutland Herald, shortnose sturgeon, The Greenfield Recorder, Times Argus, Turners Falls dam, US Fish & Wildlife Service, USFWS, Wampanoag, William Pynchon

The following essay appeared on the November OpEd pages of the Rutland Herald, Times Argus, Greenfield Recorder, and Daily Hampshire Gazette.

December 21, 2011

Copyright © 2011 by Karl Meyer     All Rights Reserved

A Mirror to the Past: the legacy of failure at Turners Falls

Some history is worth repeating.  In Deerfield, MA on November 9th I listened as independent filmmaker Anne Makepeace introduced, “We Still Live Here” in a church at a place once called Pocumtuck.  There in 1638, Springfield’s William Pynchon bargained with the Pocumtuck for 500 dirt-cheap bushels of corn—selling it at inflated prices to Connecticut colonists who’d run out of food while warring against the Pequot.  The Pequot massacre at Fort Mystic, as well as Pynchon’s low-ball trading, established a posture toward Native Americans that overran a continent.

But Ms. Makepeace’s documentary displayed a clear sensitivity in depicting the 18-year odyssey of a Wampanoag woman, Jessie Little Doe.  Through vision and genius, a seemingly-everyday working mom has begun reviving the spoken Wampanoag language, last heard over a century ago.  At Mashpee and Gay Head, MA, a bedrock tongue of indigenous North America is again being taught and spoken, where starving Pilgrims first encountered it.

The next evening the Associated Press published a story: ‘Rock Snot’ Fear Means Salmon For Native Tribes.  It told how the disaster of an invasive alga picked up by thousands of hatchery salmon at the US Fish &Wildlife Service’s flooded White River National Fish Hatchery during Tropical Storm Irene was turning into a curious windfall for Native Americans.  The USFWS and Connecticut River Atlantic Salmon Commission (CRASC) had just unanimously voted to give free fish to the Indians.

The headline was unfortunate, sounding like the tribes were being used.  CRASC’s half-billion-dollar CT River salmon restoration had had another dismal year—returning just 106 fish.  The Irene flood was the second million-dollar disaster befalling the White River VT hatchery in 4 years.  Giving a tiny portion of the facility’s half-million surviving fish might play better in the media than advertising a likely fate for most—killing and burying the lot to avoid releasing rock-snot-infested salmon and trout to New England rivers and Great Lakes habitats.

Filed from Montpelier, VT, the story sketched that morning’s CRASC meeting at Turners Falls, MA, once known as Peskeomscut, just 7 miles from Pocumtuck.  It missed some substance an attending reporter might’ve caught–that CRASC Chair Bill Hyatt had become chairman that day; that it was his first meeting ever.  Hyatt’s quotes hit the media so quickly—hours after the meeting, it might appear someone had been spoon fed a cheery “salmon-for-the-Indians” pre-Thanksgiving tale.  But an editor made a good call on its content: rock-snot-means-gift-to-tribes.

On-the-ground reporting might also have uncovered that—just beyond the federal Conte Lab where CRASC meets, sits two miles of beleaguered Connecticut River identified on colonial maps as Peskeomscut.  It’s a delicate place to fashion an ‘Indian-fish-rescue’ story from.  Here on May 19, 1676, Captain William Turner and Hadley-based soldiers surprise-attacked hundreds of sleeping Wampanoags, Narragansetts, Pocumtucks and Nipmucks–largely women, children, and elders. They’d come to rest, plant, and dry-harvest massive blooms of migrating shad, herring, and a knot of spawning shortnose sturgeon.  If time allowed, they’d tap a small, later-arriving salmon run.

Time did not.  This was King Phillips War, their fight for sovereign lands.  Dawn brought the Turners Falls massacre.  Just past Conte Lab’s windows warriors encamped at the ancient fishing-island today called Rock Dam counterattacked–routing and killing 37, including Captain Turner.

This day, 335 years later, it was noted that half the hatchery’s 8,000, two-to-four year old salmon, the small ones, could likely be released to already didymo-infected rivers.  Regulations would prevent any sale.  Still, all remaining baby salmon, plus 500,000 didymo-infected lake trout still faced a quick landfill burial before the hatchery could be flushed with chlorine.  They could not be released for anglers—and way back in 2004 the USFWS Region 5 actually issued a consumer advisory on eating hatchery salmon.  Those remaining 4,000 larger salmon, some to 9-1/2 lbs., might also have had to be killed and land-filled–had they not found someone to take them…

CRASC, charged with protecting all of the river’s migratory fish species, unanimously voted to donate those big fish—killed, gutted and iced, to any federally tribe who’d take them.  It might be a PR coup for the disastrous restoration, buffering perceptions away from the millions lost producing ten dozen salmon returns annually.  As with the Pilgrims, Pynchon and William Turner, the Indians had not come calling: USFWS had.  Region 5’s William Archambault noted, “We reached out to the federal tribes.” Ironically, that included the Wampanoag and Narragansett.

I hope all fully understood that in accepting fish they did USFWS a huge favor.  They should also know the embattled 2-mile reach of river they know as Peskeomscut remains today a desolate place.  There, USFWS and CRASC have abandoned spawning federally-endangered shortnose sturgeon and beleaguered American shad to the excesses of a for-profit power company.  Certainly they know that Jessie Little Doe was awarded a MacArthur genius grant in 2010.  “We Still Live Here” premiered nationwide on November 17th, funded in part by WGBY in Springfield, MA.

#          #          #

DESPERATE MEASURES : salmon hatchery program a grave threat to the Connecticut River

Posted by on 13 Nov 2011 | Tagged as: alewives, American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, CRASC, didymo, MA Division of Fish and Wildlife, Rock Snot, salmon, Salmon eggs, salmon hatchery, shortnose sturgeon, US Fish & Wildlife Service, USFWS

Copyright © 2011 by Karl Meyer        All Rights Reserved

This article first appeared in the Pioneer Valley News, www.pioneervalleynews.com, on November 9, 2011.  Hard copies of the free Pioneer Valley News are available at many locations from Holyoke, MA through Brattleboro and Bellows Falls, VT.

DESPERATE MEASURES: salmon program a grave threat to the CT River

TURNERS FALLS, MA.  “Didymo is not going to drive our decisions,” said Dr. Caleb Slater, Anadromous Fish Project Leader for the MA Div. of Fish & Wildlife and Tech Committee Chair of the Connecticut River Atlantic Salmon Commission (CRASC) at a hastily convened CRASC meeting September 23, 2011.  Their 44 year-old federal/state salmon restoration program was in crisis, having again produced just nine-dozen returning fish on the year.  Now, their main hybrid salmon hatchery had been reduced to rubble by rampaging White River waters from Tropical Storm Irene.  But moving out the surviving salmon at the White River National Fish Hatchery (WRNFH) in Bethel, VT, posed a big problem: it could potentially increase the spread of river-bottom smothering “didymo” throughout the Connecticut River basin.

CRASC and its US Fish and Wildlife Service partners were scrambling at the Conte Anadromous Fish Lab, trying to figure out how best to lobby federal representatives to get $10 – $14 million in “emergency Congressional funding” to “completely rebuild” USFWS’s White River hatchery.  They’d even brought back Jay McMenemy, recently retired from VT Fish & Game, and CRASC’s Tech Committee, and seated him at the members table.  CRASC’s Steve Gephard of Connecticut’s DEP was worried officials might not be willing to again resuscitate this facility to produce its main product: 5 million salmon fry released to the Connecticut River each spring, “You guys have to do that lobbying,” said William Archambault, USFWS Region 5 Deputy Assistant Regional Director of Fisheries.  A week prior his boss, USFWS Region 5 Director Wendy Weber sent a letter to Washington outlining the giant funding request.

But first, WRNFH would have to be completely “de-populated,” then “disinfected,” according to Archambault.  There were also other significant risks involved in doling-out it’s surviving fish beyond spreading didymo–a bottom-smothering algae known as Rock Snot that New England states have been working hard to contain.  Nonetheless Archambault was encouraging CRASC members from VT, CT, MA and NH to quickly find a way to parse-out the 900 surviving “broodstock” salmon left at the hatchery to a handful of federal and state hatcheries–and also to find places to release remaining excess “stock” into lakes and basin streams.  Caleb Slater remarked on how stocking spawned-out hatchery salmon to Bay State ponds “gets a real PR boost” from anglers.  Once the $ millions in emergency public funds were in hand, CRASC and USFWS could start all over.

“As a Service we’re uncomfortable with the risks,” Archambault said as disclaimer, “It (the decision to accept potentially tainted fish) will have to be done on a state-by-state basis.  We can’t be 100% sure that didymo won’t be taken out of the facility.”  Spawning the survivors at White River was out of the question.  Those salmon had been newly-exposed by the dace, white suckers and other fish–living and dead, which had mixed into the crippled facility when Irene sent them upstream infected waters where didymo had been found in the White River four years prior. “Our focus is on rebuilding, not spawning right now,” said Archambault.

Alternatively, they’d have to again destroy all surviving hatchery fish and eggs—an extreme procedure that had been employed twice recently at White River facility.

But fall breeding season was arriving.  Full hatchery production—“stripping” salmon females of eggs and mixing in the milt of surviving sea-run males (who’d be injected with stimulating hormones a week prior), could not wait long.  They could delay injections a week or two, tricking the hybrids.  But then staff would have to get down to fish production—mixing the genetic fish fluids by hand, careful that computer-matched genes of certain fish were mingled into the correct plastic eggs tubs; then placing fertilized hybrid eggs on industrial racks to be washed over by an endless stream of water.

But there was another big catch: the ever-present and growing risk of centralized hatcheries spreading emerging fish diseases.  Before any surviving WRNFH salmon could be moved they’d have to be tested; quarantined for 28 days.  Hatchery salmon can spread a variety of plagues deadly to river systems and new fish populations—including angler-beloved native brook trout and still-wild salmon populations clinging to survival in rivers up north.  All WRNFH fish would have to be quickly screened for Infectious Salmon Anemia (ISA), Furunculosis, and Infectious Pancreatic Necrosis (IPN)–a disease discovered infecting salmon downstream in 2007 at the Cronin National Salmon Station in Sunderland, MA.

From there, federal biologists had ferried that deadly virus 140 miles north to the Vermont’s WRNFH–through the salmon eggs Cronin Station sent them for winter incubation. Both WRNFH and Cronin Station were subsequently depopulated; chemically disinfected.  Personnel at Cronin had to kill all 121 “sea-run” salmon on-station that fall.  It was the public’s seasonal return on 40 years and over a $ half-billion spent on hybrid efforts to create a substitute fish for a strain extinct here since 1809.  Ten dozen fish were the Connecticut’s entire salmon “run” back from the ocean in 2007; when their program began in 1967 they’d predicted 37,000 salmon annually.  WRNFH staff also incinerated all 718,000 salmon eggs it had begun nursing for the following year’s stocking.  Of the millions of fry delivered into Connecticut River tributaries the next season–by school kids, trout groups and fisheries technicians, not a single baby salmon would come directly from a fish that had arrived back from the ocean.  All fry stocked into the ecosystem from Cronin and White River that spring were at least two industrial generations removed from anything that natural.

Following that 2007 disaster over $500,000 in emergency-funded “bio-security” upgrades had to be put in place at the USFWS’s Cronin Station in Sunderand, MA.  A similar mix of costly hardware and complex chemical protocols were installed at WRNFH.

But just months after the IPN debacle of 2008, disaster again struck WRNFH.  Upstream in the same White River waters the hatchery used to nurture its eggs, didymo was discovered choking the bottom.  WRNFH now risked spreading this algal plaque through the Connecticut River basin via hatchery salmon.  They could no longer use the very river water they were expecting their hybrid salmon to be restored to.  No water, equals no hatchery.  Again, CRASC and USFWS put out an SOS for emergency public funds for White River —and, again, millions in public funding was procured to design, dig and computerize a segregated system of wells and piping to water their fish, eggs, and fry.

In 2010 yet another disaster befell WRNF.  A sampling of young salmon groups being raised from eggs for CT River stocking programs revealed that 60% of those hatchery fish were developing cataracts, crippling their ability to feed.  Again, thousands had to be destroyed.  No publicly-disclosed disasters were known to befall WRNFH or Cronin National Salmon Station in 2010, yet White River infrastructure consumed $723,000 in American Recovery and Reinvestment Act (ARRA) cash for “upgrades”—the bulk of it funneled to corporations far from New England.  Over $590,000 in contracts for electrical upgrades and new “chillers” went to two firms: one in Missouri and the other Washington State.

THIS DAY, just four years after the IPN outbreak; just three years after the didymo crisis and new well fields, one year after cataracts—and a year after a yet another WRNFH Recover Act cash infusion, the USFWS, CRASC and the White River National Fish Hatchery are going to the mattress to save their foundered hatchery at all costs.  Didymo, and the millions of dollars spent to protect against its spread throughout the Connecticut River watershed, are being downplayed as just the price of doing business.

The plan coming out of this emergency CRASC meeting at Conte Lab, is to disease-test the White River salmon ASAP; then quickly get them dispersed and “bred” at other sites including Sunderland’s Cronin National Salmon Station.  In another unprecedented move, they would then transport, hatch, and feed several million salmon fry until spring at hatcheries in river basins across New England: North Attleboro National Fish Hatchery in the Ten Mile River basin in North Attleboro, MA, the Berkshire National Fish Hatchery in the Housatonic basin in New Marlboro, MA,  Cronin National Salmon Station in the Connecticut basin in Sunderland, MA, the formerly-mothballed Whittemore Salmon Station on the Farmington at Barkhamsted, CT, and Eisenhower National Fish Hatchery in the Otter Creek/Lake Champlain drainage basin in North Chittendon, VT.  Come spring, those baby hybrid salmon fry would get re-dispersed again—stocked-out by trout groups, school children, and fish and wildlife staff to a vast network of Connecticut River tributaries.

It was desperate, seat-of-the-pants, industrial fish science policy-in-the-making by the USFWS and CRASC’s various state fish and wildlife officials.  And it was fraught with opportunity for miscalculations, mistakes and dire consequences for the web of linked ecosystems they are charged with protecting.  As with all bureaucracies, USFWS’s Bill Archambault quietly mentioned a Plan B to procure public funds if Congress balked at this latest hatchery cash pitch.  WRNFH had recently done a bit of branching out into work other than just salmon production for the Connecticut.  They were now hatching “Klondikes,” lake trout for stocking in Lake Michigan.  It might be possible to “use Great Lakes money” to resurrect White River, Archambault said.

CRASC members and the hatchery personnel in attendance left the Tech meeting that afternoon with one big, gnarly question sitting fat and unanswered on the table: would their plan disperse didymo?  You can’t vaccinate against an algae spread via tiny plant bits carried in fish gills or transported in hatchery fry or egg-nurturing waters.  Yet almost to a one, they’d expressed a blind willingness to risk spreading that plague.  Even if all emergency disease tests proved negative, no one stepped-up to guarantee there wouldn’t be the seeds of didymo hiding in fish transported to new river basins, or in the necessary waters required for shuttling those live fish and eggs.  To his credit CRASC’s Matt Carpenter from New Hampshire Fish & Game kept returning to worries about spreading didymo.  After a pause, long-time CRASC leader Steve Gephard from CT DEP offered, “We’re using salt solutions,” but it came across sounding like soft science, and he too added his disclaimer, “No guarantees can be made.”

In the group-think being employed to save the program and sway Carpenter, Gephard then went on to restate the PR value of dispersing spawned-out salmon to swim in the basin’s rivers for casual anglers.  But, there was nothing eco-system-natural in his language, it was purely industrial, “If we’re going to save this program we’re going to have to come up with a way to keep fish in production.”  Of the decades-old system created to produce a new stand-in fish for a cold-water species centuries-extinct on today’s climate-warmed Connecticut (now classified a ‘warm water fishery’) Gephard warned, “If we get down to the point where we get back 10 fish a year–its like death from a thousand cuts, the public isn’t going to accept this program.”

These were the plans and decisions USFWS and CRASC’s Tech Committee took away with them at the end of a four hour meeting on September 23, 2011.  It was expected they’d be discussed and accepted at a full, semi-annual Connecticut River Atlantic Salmon Commission meeting just six days hence.  However, without explanation, an emergency notice went out from CRASC’s Executive Secretary Ken Sprankle at his office in Sunderland, MA, just days later, September 27, 2011: “I have just been directed by CRASC Vice Chairman Wayne MacCallum to POSTPONE the September 29th CRASC meeting until further notice.”                  #          #          #

Author’s addendum: Upon finishing this writing as the Nov/Dec. issue of Pioneer Valley News was set to go to press, no official notice had been made of when that postponed CRASC meeting would reconvene.  Yesterday (10/25/11), I learned it will likely take place November 10, 2011, but that was still unofficial.  What, if any, of these decisions have been implemented in the interim five weeks is unknown at this time.  More about CRASC plans, changes and decisions may be revealed at that next meeting.  However, when I recently noted the Public’s Right-to-Know, and asked for specifics and notes from backroom negotiations between USFWS’s John Warner and FirstLight Power/GDF-Suez to divert more migratory fish out of the Connecticut River and into the treacherous Turners Falls power canal, Warner refused to give a direct answer.  His colleague at that CRASC meeting, USFWS Region 5 Deputy Assistant Director of Fisheries Bill Archambault, then pointedly stepped in and referred me to the Freedom of Information Act.  CRASC is a Congressionally-authorized public entity that tends to share little upfront information with the public (costs, budgets, open-meeting dates, disease threats, etc.) beyond what is self-promoting for their salmon program.

This story comes directly from an emergency CRASC Technical Committee meeting.  There should be no mistake that these decisions–and the gambles being advocated with the Connecticut River ecosystem, were being promoted by key federal and state decision makers at CRASC and USFWS.  Dr. Caleb Slater is Anadromous Fish Project Leader for the MA Div. of Fish & Wildlife; Dr. Steve Gephard is Supervisor of Inland Fisheries for CT DEP, CRASC’s Genetics Subcommittee Chair, liaison to the Atlantic States Marine Fisheries Commission, and former international representative to NASCO (North Atlantic Salmon Commission); Wendy Weber is Region 5 US Fish & Wildlife Service Regional Director, William Archambault is USFWS Region 5 Deputy Assistant Regional Director of Fisheries; John Warner of the USFWS’s New England Field Office is CRASC’s Fish Passage Subcommittee Chair; Jay McMenemy (retired, but somehow again seated at that CRASC table) of VT Fish & Wildlife was CRASC’s Salmon Studies Subcommittee Chair, and a key long-time promoter of the Atlantic Salmon Egg Rearing Program (ASERP) in VT’s schools.   Matthew Carpenter, CRASCs lone voice of question and potential dissent that day, attended the meeting via speaker phone.  He is Anadromous Fish Program Coordinator for New Hampshire Fish & Game.

What is clear is that this program and its insular decision-making process represent an ongoing danger to the Connecticut River ecosystem.  As long as the public remains unaware of the costs and consequences of continuing to spend tens of millions of dollars on a coldwater fish strain that went extinct on the southern-most edge of its historical footprint over 200 years ago, the USFWS and CRASC will continue to dump 6 million factory fry into the Connecticut River system each spring.  In turn, we’ll continue to see a return of 10 dozen or so fish from the sea, ad infinitum, if our representatives continue funding a program with hybrid salmon at its core.

Conservatively calculating that the basic salmon restoration effort—in a year without new disease or disaster, costs taxpayers a minimum of $10 million annually (salaries aside)–the cost for the 91 “wild” sea-run salmon returning from the Atlantic this year was $110,000 per fish.  Add to that any number of “bad” years with an emerging disease or disaster–pitch in say another $14 million from public coffers, and the price of one returned hybrid salmon goes to $264,000.   Each of these then must be ferried right back to the hatchery for next year’s production.

And that doesn’t begin to calculate the huge “what-ifs?”…didymo, ISA, IPN gets shipped out of the salmon factories…

In recent OpEds from Holyoke, MA to Bellows Falls and Montpelier, VT, I’ve taken the position that the Connecticut River desperately needs a well-funded restoration program.  But it should be an ecosystem restoration program, not one based on a failed 19th century idea that substitutes fish hatcheries for functioning river systems, and prioritizes an extinct species ahead of a still-living pyramid that includes native alewives, American shad, blueback herring, endangered shortnose sturgeon, sea lamprey and American eels.  With less than half the $14 million USFWS and CRASC hope will rescue their program you could build a state-of-the-art ecosystem laboratory.  It would an excellent fit for the Five College area—where advances in upstream ecosystem restoration remain stalled behind Turners Falls dam, as they have since its construction in 1798.

With such a facility in place, you could easily attract endowment funding—and start producing independent science.  CRASC, and Conte Lab’s state and federal scientists and studies are now regularly contracted with, and supported by, money from power companies operating on the Connecticut—companies concerned with maximizing profit.   Corporations have little interest seeing independent science come to light that would quantify for the public their true impacts on New England’s River.

At minimum, it’s high time to stop the losses the Connecticut River ecosystem is sustaining from propping up a dangerously failed hatchery program.  Invest in keeping the Connecticut’s remaining half-dozen, naturally-breeding migratory species alive and moving upstream.

Karl Meyer, Greenfield, MA, October 26, 2011.

Desperate Measures: portrait of a CRASC Meeting

Posted by on 09 Nov 2011 | Tagged as: American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, didymo, MA Division of Fish and Wildlife, Rock Snot, salmon hatchery, Turners Falls power canal, US Fish & Wildlife Service

The PIONEER VALLEY NEWS will be out on news stands beginning tomorrow, November 10th.  Right now you can read about the last meeting of the Connecticut River Atlantic Salmon Commission, aka CRASC, on-line at:  www.pioneervalleynews.com ,

Or simply type in the link below.

http://www.pioneervalleynews.com/main-1/environmental/desperate-measures

The Connecticut River Atlantic Salmon Commission, aka CRASC, meets tomorrow, November 10, at 10 a.m. at the USGS Silvio Conte Anadromous Fish Lab in Turners Falls.  Though the meetings are not publicly announced, this is the federal/state public entity responsible for protecting migratory fish and the Connecticut River ecosystem–fisheries officials responsible for protecting runs of blueback herring, American shad, and the Connecticut’s only spawning population of federally-endangered shortnose sturgeon.

The public can attend these meetings, and should be made aware of them.  To attend tomorrow, take the 11th Street Bridge across the Turners Falls Power Canal, go left at the first stop sign, and follow down along the widened power canal until you see Conte Lab on the right.  Parking is right there.

USFWS requests $14 million in “emergency” funds for hatchery as native fish runs founder

Posted by on 31 Oct 2011 | Tagged as: American shad, Atlantic salmon, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, didymo, Rock Snot, Salmon eggs, salmon hatchery, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS

The following OpEd appeared in MA and VT publications, including at: www.gazettenet.com; www.recorder.com , www.rutlandherald.comwww.timesargus.com; www.commonsnews.org;  and The Montague Reporter, www.montaguema.net .  My apologies go to USFWS Region 5 Director Wendy Weber for incorrectly spelling her name and noting her as “Acting” Director in the original.  They are here-in corrected.

Ms. Weber formally replied to my piece in the Daily Hampshire Gazette on Friday, October 29th .  I appreciate her thoughtful response, and welcome the prospect that an evaluation of the 44 year old salmon-creation effort might lead to real USFWS policy change here on the Connecticut.  A true restoration effort desperately needs to focus on the living migratory species still diverted into the debased habitats at the Turners Falls power canal.  The Connecticut River itself remains all but dead as a river system for the two miles immediately below Turners Falls dam.

I stick by my characterization that this group of ranking federal/state fisheries officials were indeed ready to “play fast and loose” with the Connecticut’s ecosystem as they left their Sept. 23rd emergency CRASC Tech Committee meeting.  The “ask”–noted at that meeting, was indeed stated as $14 million in “emergency” Congressional funding.  I put together my OpEd, to denote the dangers of spreading didymo,  and get the issue into the public record.  Days later an emergency dispatch went out cancelling the scheduled Sept. 29, 2011 meeting of the full CRASC, where the proposed emergency fish-dispersing measures would have presumably been adopted.  That meeting has been rescheduled for November 10, 20011, 10:00 a.m., at the federal Conte Anadromous Fish Lab in Turners Falls.  CRASC is a public entity, thus the public may attend.

I would love to see USFWS hold an open public forum on the future of the Connecticut River migratory fisheries restoration program.  I would be happy be a part of such a panel.  My original OpEd is below.

Karl Meyer, Greenfield, MA, Oct. 31, 2011

ORIGINAL OpEd text below

Oct. 5, 2011                                                       Copyright © 2011 by Karl Meyer

 

USFWS requests $14 million in “emergency” funds for hatchery as native fish runs founder

Wendy Weber, Region 5 Director of the US Fish and Wildlife Service in Hadley, MA, and Deputy Assistant Regional Director of Fisheries Bill Archambault, want a boatload of pork for the failed Connecticut River Atlantic Salmon Commission’s (CRASC’s) salmon program.  Now!  Through an Act of Congress they are seeking $10 – $14 million in emergency funding to rebuild the White River National Fish Hatchery (WRNFH) in Bethel, VT, wiped out by Tropical Storm Irene in August.  Webber sent out a letter requesting the Congressional funds in mid-September.  The primary product of WRNFH is salmon eggs—six million annually for our river’s longest running failure, the 44 year attempt to recreate an extinct salmon strain here: 107 fish returned this season.  What will Senators Kerry, Brown, Leahy and Sanders do with this request in a time of paper-thin budgets and collapsing native herring and shad runs?

Last year, the WRNFH got $723,000 in federal stimulus funds for a makeover–over $420,000 went to a refrigeration manufacturer in Missouri for an egg-chiller.  Ironically, a $100,000 egg chiller has sat useless at the Cronin National Salmon Station in Sunderland, MA for years.  Upon delivery, it simply never worked.  Four years ago White River spent millions in taxpayer dollars to build a well system to supply its hatchery salmon—upstream the White River had become infected with the invasive, bottom-smothering algae didymo, which could be transported via eggs and fry they disperse to tributaries and sent to school programs. They want to start again.

Meanwhile, state/federal CRASC Commissioners seem willing to play fast and loose with the potentially-disastrous dispersal of didymo to CT River tributaries through hatchery fry.  Right now they are devising a rush plan to parcel out the surviving 900 “broodstock” hatchery salmon at White River to hatcheries in MA, VT, and CT—though they admit they can’t be “one hundred percent certain didymo won’t be taken out of the (White River) facility.”  They’d jeopardize an ecosystem for their program.

All this was revealed at an emergency CRASC Tech Committee meeting on September 23, 2011.  This capital-intensive, million dollar system of four federal and two state hatcheries, floats a small number of well-benefitted government jobs, while ignoring native migrant fish and the lessons of a river ecosystem.  It’s a PR machine reaching into public schools, assisted via a few hundred, spawned-out hatchery salmon dumped into lakes and streams to mollify anglers duped into believing it will work.

With $14 million you could do a lot of good for the Connecticut.  With just a fraction of that money, independent scientists could conduct investigations and get real answers about why millions of migratory American shad have remained blocked from getting upstream to Vermont and New Hampshire on the main stem Connecticut at Turners Falls for decades, abandoned to a treacherous power canal literally behind the federal Conte Fish Lab.  A tiny share of those dollars could begin getting real answers to why a flood of 630,000 blueback herring passing Holyoke dam in 1985 collapsed like the September Red Sox to a “run” of 138 fish here in 2011.

Less than half of $14 million could easily build an independent, Five College-based river ecology lab that would advance our understanding of native fish, the food web, and the mix of seasonal life cycles critical to sustaining a healthy ecosystem.  MA is the crossroads of the Connecticut—where migratory fish have remained blocked from VT and NH waters since 1798.  Once built, a sustaining endowment could surely be found for such a facility.  New England’s River would finally have a think tank worthy of its critical importance.

Today, just a few hundred thousand could easily get an answer to the simple question that’s left New Englanders in the dark for generations: Why hundreds of millions of dollars spent on an extinct, cold water fish is never going to sustain anything but pork production for the 44 year old Connecticut River Atlantic Salmon Commission–on a warming  river in the era of climate change.

In 1967, New Englanders from Enfield, CT to Walpole, NH, and Bellows Falls, VT were promised great fishing and a bounty of seafood by the New England Cooperative Fisheries Restoration Program, today’s CRASC.  The chief objective of this federal/state amalgam: “provide the public with high quality sport fishing opportunities in a highly urbanized area as well as to provide for the long term needs of the population for seafood.”   Runs of a million American shad, commercially harvestable blueback herring returns—and a hypothetical run of fishable (though centuries extinct) salmon were promised.  Instead, we’re left with an endless conveyor of salmon pork, no seafood–and damned poor fishing.

It’s time to stop this recklessness and waste on the Connecticut–time for accountability from the USFWS.  Jettison the Age-of-Aquarius salmon scheme; refocus the program on still-living native runs.  A new name, the “Connecticut River Migratory Fisheries Commission” would help; all new commissioners and an ecosystem focus would be a real start.

END

USFWS Region 5 Director Wendy Weber’s piece from the Gazette can be found at:

http://www.gazettenet.com/2011/10/28/wildlife-official-differs-on-fisheries-management

A New Ecosystem Gamble: know when to hold ‘em; know when to run…

Posted by on 22 Sep 2011 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, CRASC, EPA, FERC license, FirstLight, MA Division of Fish and Wildlife, New Hampshire, salmon, shortnose sturgeon, Turners Falls power canal, USFWS

© Copyright 2011, by Karl Meyer

(the following OpEd, appeared in the Greenfield Recorder, www.recorder.com , on 8/31/11)

A new Ecosystem Gamble: know when to hold’em; know when to run…

Some deals just smell fishy—like one for the Connecticut River being cooked up by global giant FirstLight/GDF-Suez and the US Fish & Wildlife Service and the Connecticut River Atlantic Salmon Commission (CRASC.)   Today CRASC, US F&WS and MA Div. of Fish & Wildlife are pushing a deal ignoring ongoing damage to federally-endangered shortnose sturgeon and federal-trust American shad.  It prioritizes retrenching the river’s migrating fish in FirstLight’s Turners Falls power canal—filled with slicing turbines, stress-filled currents and silt.  It’s this ecosystem’s black hole, crippling fisheries restoration here for decades–literally at the doorstep of the federal Conte Fish Lab in Turners Falls, MA where CRASC meets.

CRASC meetings can be Orwellian. The USFWS’s John Warner all but stated at an August 3rd meeting that the river’s only spawning population of federally-endangered shortnose sturgeon were immaterial to talks he’s leading.  Their ancient spawning grounds, just beyond Conte Lab’s west window, weren’t documented when the Federal Energy Regulatory Commission (FERC) license currently governing Northfield MT-Turners Falls hydro operations was signed in 1978.  So Endangered Species Act be damned, those fish don’t count.

UMass professor Dr. Boyd Kynard, an expert on many of the world’s endangered sturgeons who consults on fish passage behavior at large river dams including the Yangtze and upper Amazon, might disagree.  In a book on 20 years of sturgeon research slated for December publication, Kynard and colleagues cite manipulated hydro flows in a 2 mile stretch below the Turners Falls dam and canal as contributing to significant breeding failure for shortnose sturgeon.  Sentences from adjoining paragraphs fall out like this: “Flow regulation at Rock Dam makes spawning for shortnose sturgeon impossible during most years.” And, “Peaking operation of Cabot Station causes discharge shifts that have deleterious effects on spawning success of shortnose sturgeon.”  On March 12, 2010, FERC notified FirstLight they’d failed to comply with licensed provisions for “minimum flow” for those sturgeon during fall 2009.

When I asked Mr. Warner about any existing notes from talks with FirstLight, he wouldn’t give a direct answer.  Make no mistake, what’s being cooked up is a de-facto reopening of the current 40 year FERC hydro license governing conditions and flows from FirstLight’s Northfield Mt.-Turners Falls operations–only it sidesteps details like public input, endangered species, and disclosure.  Until caught last year, FirstLight used the river as its flush-sink for 65,000 tons of silt at its Northfield MT plant during peak migration and spawning season. Clean Water Act, be damned.

CRASC is the protector-of-record for the river’s ocean migrants and ecosystem, our federal trust.  They’re excited FirstLight is now interested in negotiating migratory fish passage—though river, fish, and fish passage protection and enhancements are mandated under federal law, and included in the current license.  CRASC’s never demanded them.  Instead of negotiating critical flows for shad–and spawning shortnose sturgeon documented since 1993 on Conte Lab’s doorstep, they’re again blithely substituting a canal restoration for a river restoration.

“Trust us,” say USFWS and CRASC, “We’ll protect the river–we just have to wait until the next full 40-year FERC license negotiation in 2018.”  But they’ve failed for 40 years now, emphasizing their salmon “restoration” which returned 107 fish this year; and its hundred million dollar federal (genetic hybrid)salmon hatchery system—essentially a jobs-program that’s never produced  a single, fishable-fish for this river.  It’s been CRASC–formerly “The New England Cooperative Fisheries,” that’s repeatedly abetted channeling 90% of the river’s migratory fish into a meat grinder: Turners Falls canal.  Fish don’t emerge from the other side.

Hydro companies like to use a river like there’s tomorrow–like they own it.  Their interests are profit; the weight of water shunted through turbines.  Ecosystem-protections don’t maximize profit.  USFWS’s John Warner, negotiating with FirstLight, admits any new river help from a 2018 license may take “until 2025” to be implemented by a foot-dragging company.  Yet everyone’s lining up with FirstLight’s “canal-first” idea—when they should be prosecuting for sustaining river flows, and prioritizing direct fish passage up the Connecticut’s currently-crippled reach to a lift at Turners Falls dam.  Several CRASC’s partnering scientists at Conte Lab are being paid by FirstLight—for ongoing fish passage studies in the TF canal.  With federal scientists on your payroll, how can you lose?

New England’s River can’t survive another losing hand.  Unlinking ecosystem-sustaining flows and fish-lift passage at Turners Falls dam from the current canal-restoration scheme is a recipe for disaster that could set a failed restoration back another half century.  Negotiate a sustainable river first.  If CRASC and USFWS allow themselves to be slow-danced into repeating a dead-end canal configuration for the Connecticut, its renewed use will be cited by the power company as an endorsement of its suitability as the best upstream route for migratory runs when a new 40-year license is negotiated in 2018.  Nothing is further from the truth.  Today, 44 years and three states shy of CRASC’s 1967 MA, VT and NH restoration goals, ecosystem fish runs choke to a halt in the Turners Falls power canal.

(* note: the Connecticut River Atlantic Salmon Commission is holding an emergency Tech Committee Meeting, tomorrow, Sept. 23, at 10:00 a.m., at 1 Migratory Way, in Turners Falls at the Conte Lab.  Use the 11th Street Bridge to cross the Canal, then take a left.  ALSO, the full CRASC meets on Sept. 29th, same time, same place.  Though not publicized, these are PUBLIC meetings with your public officials calling the shots.  There is currently NO Massachusetts “public representative on CRASC, the seat has sat empty for 3 -plus years.)

Writer Karl Meyer of Greenfield, MA, has served on the boards of two watershed associations and is former member of the Northfield Mountain Pumped Storage Safety Committee.  Reach him and read more at: www.karlmeyerwriting.com

IT’S THE DEAD REACH STUPID: the selling of the Connecticut River ecosystem

Posted by on 24 Jul 2011 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Dead Reach, EPA, federal trust fish, FERC license, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, New Hampshire, Northfield Mountain Pumped Storage Reservoir, salmon, salmon hatchery, Sanctuary Magazine, shortnose sturgeon, The Greenfield Recorder, The Springfield Republican, Turners Falls power canal, USFWS, Walpole

Copyright © 2011 by Karl Meyer                                   All Rights Reserved.

* The following article first appeared in the July/August 2011 issue of the Pioneer Valley News.

                          IT’S THE DEAD REACH, STUPID: the selling of the Connecticut River ecosystem

If you think the Connecticut River is worth saving for your children and their grandchildren, you’d better act fast.  New England’s River is dying in the two-mile stretch directly below the dam in Turners Falls, MA.  Go take a look.  It’s a section subjected, alternately, to channel-starving flows and punishing deluges caused by manipulations at the dam from the Northfield Mountain-Turners Falls hydropower operations.  Look just to the left, where roiling water churns and hurtles down the Turners Falls Power Canal.  That’s where most of the river’s water goes—into an unnatural conduit that’s the final stop for most of the Connecticut’s migratory fish.  It’s killing this ocean-connected ecosystem, which once stretched north to Walpole, NH and Bellows Falls, VT.

For decades US Fish and Wildlife Service agents, federal scientists at the Conte Fish Lab in Turners Falls, and MA Fisheries & Wildlife officials have ignored this “dead reach” where the river’s only breeding population of federally endangered shortnose sturgeon spawns; and migrating “federal trust” American shad and blueback herring are turned out of their ancient river highway two miles downstream.   That power canal has hydro-turbines slicing through the current at three sites, and warming, silted-in habitats along its middle stretch.  Few fish emerge from that habitat to swim to Vermont and New Hampshire.  An ecosystem dies at Turners Falls.

Yet federal and state fisheries officials don’t monitor the flows, releases and river levels coming down past the Turners Falls dam.  They leave it to the complex’s owners, global giant FirstLight, to police themselves on this critical reach.  They then use what little data the company deigns to give them, often months late—about flow and numbers of migrating fish, in the fisheries science that’s been supposed to restore New England’s migratory fish here these past last 40 years.  Boy is that smart.

Last year, FirstLight surreptitiously dumped 65,000 tons of silt into the Connecticut here after it got clogged in its massive turbines–also fouling the entire, mile-long intake tunnel to its sprawling 5-billion gallon Northfield Mountain Pumped Storage Reservoir.  They were mucking the sludge out of the reservoir for the first time in 20 years; that’s supposed to happen every five.  On May 3rd FirstLight manager John Howard grossly under-represented the extent of the pollution to the US EPA when he notified them that “silt was entering the river.”   From May 1 – August 4th, FirstLight pushed at least 45,000 cubic square yards of muck into the Connecticut at Northfield.  Daily, between 40 – 50 dump truck loads flowed in.

On June 23, 2010, boater Bruce Miriam called the EPA’s hotline reporting piles of silt in the river.  Yet EPA didn’t make its initial inspection until 3 weeks later, and it wasn’t August 4th that EPA finally ordered them to cease and desist “polluting the navigable waters of the United States.”  Fisheries agencies didn’t pursue the critical matter of that oxygen-and-light-robbing silt.  It was visible from Northfield to the mouth of the Deerfield River.  Silt is known to affect the spawning, eggs and young of endangered sturgeon and federal-trust shad—struggling here in the upper-most stretch that ocean-going migrants can reach in any meaningful numbers.

FirstLight was belatedly ordered to dredge up the mess they’d largely kept from the public by hiding it underwater–keeping the river’s levels at maximum height behind their TF dam gates for months.  Ultimately they sucked out just a third of it, 15,000 cubic square yards.  They were also ordered to come up with a future plan on how they would deal with the sludge clogging their reservoir.  Last November, when EPA Council Michael Wagner was asked who will monitor FirstLight’s actions in the future he replied, “Most compliance happens from the company.  We just expect the company will comply.”   In another river-pollution non-sequitur, FirstLight quietly agreed to spend a few thousand dollars to fund a study of dragonfly larvae, far downstream from their pollution.  That backroom deal was cut with MA Dept. of Environmental Protection, and agreed to by EPA.  It was the public’s recompense.

Though the Connecticut belongs to the United States, Massachusetts, and all New Englanders, it appears its ownership and control has been ceded to FirstLight—who could sell their hydro complex here tomorrow.   The EPA, US F&WS, the US Geological Service’s Conte Anadromous Fish Lab, the Connecticut River Atlantic Salmon Commission (CRASC), MA DEP and MA Div. of Fisheries & Wildlife–agencies charged with protecting this river system for all time, have offered up our river ecosystem to the short-term, profit desires of FirstLight’s shareholders.

What’s more, they are about to concede this river’s ecosystem disaster to the power company for all time–decades after they should have conducted the independent science and required that changes be instituted here that would have taken the river off life-support.  That should have been in 1998–the halfway point in the current federal operating license.  If they succeed, it will ensure the ecosystem remains comatose for generations.

In behind-the-scenes negotiations that should be subject to open-meeting laws and public input, federal and state fisheries officials are talking with FirstLight owners about permanently accepting the diversion of the bulk of the river’s flow and fish out of the riverbed–sending the mass of migratory fish into the trap they co-created with Northeast Utilities back in 1978: the treacherous currents and warming muck that’s the Turners Falls Power Canal.

An ample flow of natural seasonal current left in the river–leading fish directly upstream to a fish elevator at the dam would instantly revive the Connecticut’s dead reach.  That’s what they’ve done downstream at Holyoke since 1955.  It’s the East Coast’s most successful fish passage.  Between 40 – 60% of the fish would quickly be able to pass Turners Falls, according to statements from US Conte Lab fish scientist Alex Haro at a 2010 fish passage symposium held at the US Fish & Wildlife Service’s Region V Headquarters in early 2011.  That passage would send meaningful numbers of American shad upstream toward VT and NH for the first time since John Adams was president.  No honest fish scientist disputes this.

But instead, federal fish scientists including Haro’s colleague at Conte, Ted Castro-Santos, are prioritizing building a fish lift at the foot of the Turners Falls Power Canal—continuing to sentence embattled fish into a migratory limbo few emerge from.   Both Haro and Castro-Santos are salaried federal employees, but up to half the money they’ve accepted for doing fish passage studies that center on keeping fish in the power canal comes from FirstLight.  If federal and state fisheries officials sell-out the dead reach once more, it will be the fourth time in as many decades that watchdog agencies have failed our river here.

That power canal fish diversion was put in place by forerunners of these agents in 1978.  It’s the Roach Motel of fish passage: millions of shad have checked in, but hardly a fish checks out the other side.  A 1988 study conducted by John O’Leary of the Massachusetts Cooperative Fisheries Unit and supervised by Dr. Boyd Kynard, spelled out the failure of using that canal for fish passage.  Successful passage that year came in at a whopping 5.4% at the Turners Falls Gatehouse–after years of tinkering with the hopeless system.  The study’s summary sized-up the situation succinctly, “Remarks:  “Upriver Passage: None.”

But FirstLight makes electricity along this 5-mile reach in a deregulated market, and works to maximize profits for shareholders.  Conversely, it sends pulses of water downstream from its giant Northfield generators through this industrial reach into critical spawning and migratory habitats while taking advantage of price spikes the energy “spot market.”   Ironically, the Northfield plant actually requires more energy to run than it produces.  But when prices and demand climbs, they quickly spill punishing flows downstream at the dam; while at other times their hydro gates close and the river is left treacherously de-watered.  Migrating shad and (formerly) blueback herring swim to this reach in numbers of at least 100,000 fish annually.  But just a few get beyond Turners Falls dam, in place here since 1798.  Whole seasons of just-spawned shortnose sturgeon eggs and young have been washed out of the riverbed by surges in this broken stretch—where most migrating shad are conveniently shunted out of the river into miserable canal habitat.  US F&WS and MA Fisheries & Wildlife leaders sit on their hands.

Caleb Slater, from MA Division of Fisheries and Wildlife, Technical Committee Chair and fish passage subcommittee leader at the Connecticut River Atlantic Salmon Commission (CRASC) is one of those talking to FirstLight.  With Massachusetts personnel negotiating on behalf of our interests, “open meetings laws” should apply.  But there’s no public input or access.  There’s been an unfilled MA “public sector” seat at the CRASC table since 2008.  It’s a rubber stamp position anyway, really concerned with keeping money flowing for CRASC’s massively-failed, half-billion-dollar salmon restoration and hatchery program.  After 40 years, a few dozen hybrid salmon return.  The other federal officials charged with representing our interests include John Warner of the US F&WS Field Office, Julie Crocker of NOAA’s National Marine Fisheries Service, and NOAA attorney Kevin Collins.  All are charged with protecting the ecosystem for our grandkids, not the power company of the day.

FirstLight only leases the use of some of our river’s water—subject to conditions in the current federal operating (FERC) license, in place until 2018.  That license requires them to protect and improve passage for the migratory federal trust fish impacted by their facilities and operations.  By law they must maintain conditions and construct new fish passage that protects the public’s migrating and spawning fish—or they can be ordered to cease generating.

But the company has a powerful incentive to keep as many fish as possible out of the river–as it would be inconvenient to shareholders not to maximize profits by having to tailor flow regimes in the river at certain seasons to the needs of the ecosystem’s fish.  If this backroom deal gets made it offers FirstLight–or the power company-of-the-moment, carte blanch to continue profiting from free-wheeling, unmonitored operations on the dead reach–where FirstLight and its predecessors have been notably out of compliance with respect to pollution, flows, fish passage and federal trust species.  Those activities go unchallenged.

Federal fisheries leaders and scientists at the nearby $12 million dollar Conte Anadramous Fish Lab, located on that canal, also have a powerful motive for wanting the fish to continue to be shunted into that debased canal habitat. It’s where their lab is and where they do their fish science, though the bulk of it involves studying baby, hatchery-produced, hybrid salmon.  The results after 20 years of lab operations are abysmal: 100 returning adult salmon this year—in a program that has cost taxpayers hundreds of millions.  The public won’t be willing to fund this white elephant forever.

Which sort-of leaves the federal Conte Lab scrambling for a reason to exist.  They’ve now even begun studying freshwater fish that are non-migratory–to fill the rather large hole in their failed collective purpose here.  Just like FirstLight, it would be best to keep those formerly-ignored shad coming up into that canal and past their lab.  They can then look like they are doing something.  So, with renewed energy, they are once again conducting studies remarkably similar to ones done in past decades–to answer a question that seems more like a children’s riddle at this point: Why can’t fish taken out of their true riverbed habitats find their way through the labyrinth and roiling waters of a warming power canal—and then jump up into flows from a higher pond at the dam to swim to Vermont and New Hampshire?   Like the power company, there’s a money motive here to.  It’s a co-dependency that’s developed over decades.

At a 2010 meeting of the Connecticut River Atlantic Salmon Commission, Vermont CRASC Tech Committee Member Jay McMenemy expressed surprise that four hybrid Atlantic salmon—the season’s entire free-swimming crop at Turners Falls, had reached the site by swimming directly up the dead reach of river, by-passing the power canal.  With Northfield shut down, it shouldn’t have surprised anyone.  I’d first noted the looming disaster at Turners Falls in print a dozen years prior, and in 2007 had written a front-page story about the impacts of the Northfield plant’s operations on dying shad passage in the Springfield Republican.  I’d put shad and Northfield impacts on the cover of Massachusetts Audubon’s Sanctuary Magazine again in 2009.

With FirstLight keeping river levels behind the dam as high as possible to cover their silt piles upstream, they tried to divert the rest of the river’s water into the canal—their preferred route for struggling fish.  But a canal is a finite conduit: it can only carry just so much water.  It started raining really hard here in late-May; and flows from heavy late-spring rains kept coming downstream through June.  That forced FirstLight to spill water over their dam–releasing substantial and steady flows to the river’s natural bed: the dead reach.  Apparently even million-dollar, hatchery-hybrid salmon can tell a true river current from a by-pass trick.  They followed their noses straight upstream to use the rarely-accessed fish ladder at the dam to pass Turners Falls.

So did the American shad.

When I enquired of FirstLight’s Bob Stira about the already 600-800% increase in shad passing Turners Falls at a June 22, 2010 CRASC meeting—trying to find out how many had been recorded swimming directly upstream to the dam and ladder at the top of that dead reach, he was hesitant, downplaying his answer, “Oh, maybe three or four thousand.”  In fact, allowing that 4,000 American shad had likely passed upstream by this route alone was hugely significant: yearly averages had dropped to a paltry 2,000 – 3,000 fish making it through the fish passage system at Turners Falls in the past decade.

Yet in 2010, with Northfield down–and FirstLight’s releasing public fish tallies lagging weeks behind the daily figures available from Holyoke, 10,000 shad had already made it past Turners Falls dam.  When I pointedly noted the relationship between the Northfield outage and record shad passage at Turners Falls, commissioners at the CRASC table had little in the way of response.  Ultimately it was months before FirstLight released their final fish tallies for shad passage, which included numbers swimming up the dead reach, and ascending the ladder directly at the dam.  In 2010, some 16,768 fish passed Turners Falls—the most fish recorded since 1995.

But even that number is highly suspect and likely low.  FirstLight’s fish counting equipment failed on 35 different occasions—with 17 of those failures occurring at the dam’s spillway ladder.    Those cameras record the fish that swim up the riverbed when they have ample flow through their natural migration corridor—that mostly-dead reach of river ecosystem.  FirstLight’s figures are the data Conte Lab and federal and state fisheries biologists use in their science.  As I first noted about these instititutions to the Greenfield Recorder’s Gary Sanderson last June, “Do you think they’re hiding something?”

FirstLight and Conte researcher Ted Castro-Santos appeared anxious last year to attribute the huge increase in shad passage at Turners Falls to experiments they’d done changing the exit opening for shad in their preferred upstream fish passage route—the canal.  But that new hole had first been cut three years prior, with the subsequent results admittedly “poor.”

To me it seemed obvious they were trying to steal the credit and credibility that belongs to nature: water in the actual riverbed, and a large population of American shad that has wanted to follow the river upstream to Vermont and New Hampshire for centuries now.

Managers and engineers at the Northfield-Turners Falls complex have been operating dam gates and manipulating flows along this five-mile stretch for decades.  They operate their gates day and night.  Federal and state fisheries managers and scientists don’t monitor the impacts.  Operating with few constraints, it’s certainly possible to create conditions that move struggling fish in any direction you want them to go.  For the fish, that’s usually a trip through the power canal.  Rarely–when flows vary, it can be something else…

Way back in the early 1980s hundreds of shad found enough current in the riverbed to follow it straight upstream to the dam.  But operators wanted more water elsewhere—to fill their mountaintop reservoir upstream, and the power canal flowing just east of the river.  They closed the dam’s gates and shut off flow.  Without flow and water left in the river to find a path downstream, hundreds of shad perished in the warming, oxygen-starved pools they got trapped in.  Needless to say, that visible configuration was never seen again.

Today, both FirstLight and federal Conte Fish Lab scientist find themselves in a bit of a bind over the choked ecosystem and fish passage.  It’s important to each to show that the best thing for those migratory fish is to be shoved out of the riverbed and into the power canal.  They want to build a fish lift there first–at the foot of the canal, to keep that system in place.  And it’s today’s paltry flows coming downstream through the dead reach that allow this to happen.  That status quo solution would keep everybody comfortably remunerated.

But with the anomaly of record numbers of shad passing Turners Falls while Northfield Mountain was down last year, you can’t just return to business as usual.  With those parching or punishing flows through the dead reach now a matter of public record–through recent news articles and OpEds, what you can do is try and optimize conditions that get a few more fish through that dismal system.  This season there has been a dismally small, but consistent, current spilling downstream at Turners Falls dam, noted by the public.  It seems mainly for show.

But downstream at Holyoke there has been a full 33% increase in American shad passage this year.  Sadly for Mr. Castro-Santos and the canal-route proponents–the corresponding increase that should have followed at Turners Falls if their new exit strategy was indeed the savior of those migratory runs, has not occured.  The numbers at Turners Falls were flat this year—actually down by a few hundred from last year.  They are below the shad numbers passing Turners Falls dam a quarter century back, when John O’Leary’s study characterized similar failing fish passage the “Remarks” section of his 1988 study as: “Upriver Passage: None.”

Sending fish into a power canal won’t fix the Connecticut River’s broken ecosystem—the ocean connection and its shad and herring runs that once swam north to Vermont and New Hampshire.  Only real flows in the dead reach and a single fish lift directly upstream at the dam will make that possible.  That needs to happen today–should’ve happened a decade back.  It remains a debt under requirements in the current license.

But that would require integrity, determination, leadership—even a bit of courage, something citizens have come to no longer expect from the people charged with protecting their river.  And some of the folks making deals on the river today may be the same people in charge when a new federal license—also ostensibly designed to improve the river ecosystem, comes up for retooling in 2018.  It’s the recipe for a failed ecosystem for your great-grandchildren.

I recently spoke with the US F&WS’s Ken Sprankle, the Connecticut River Coordinator and fish researcher who works from a Sunderland office.  Ken seems to have some integrity.  He’s trying to do some of the catch-up science that was left a decade in arrears at the federal Conte Lab.  Last year he spent months cobbling together grant monies that enabled him to pay for a study that electronically tagged 100 American shad this year, to follow document their upstream migration patterns.  He says he’s getting lots of data.

But, when I questioned Ken about whether he is getting the critical independent data about flows, levels, and releases into the dead reach at Turners Falls dam—the ancient route for fish up the river, he said he is not.  He’s asked FirstLight’s Bob Stira for that information.  It’s been promised, but he doesn’t know when he’ll get it.

This is virtually the only real independent data and science that matters.  It’s the stuff that measures the damage to endangered shortnose sturgeon spawning populations and migrating federal trust fish that have always required a Connecticut River with water in it.  I was disheartened to hear this.  As other fisheries people tell me, however dedicated Ken might be, his work will only get as far as his US F&WS Region V supervisors allow him to go.

So, it appears the task of saving the Connecticut River ecosystem has been left up to New England citizens.  You and me.  Environmental groups have remained largely mute for decades.  Most accept power company funding, and many have boards of directors littered with former power company managers.  Though it would take just one with the courage to stand apart to perhaps change the course of this river’s history, I wouldn’t bet on it.

But you can act.  Contact your Congressmen and state representatives.  Ask them about open meeting laws and to hold hearings on protecting the federal trust and the river’s ecosystem at Turners Falls.  Ask them about the wisdom of spending $10 million a year on a failed salmon program that produces a few dozen fish—while endangered sturgeon go unprotected and federal trust shad runs remain dead to Vermont and New Hampshire, stuck behind Turners Falls dam since 1798. Write a letter to the paper. And, where’s the independent environmental watchdog that’s publicly going to go to bat for the river’s dead reach?  That might begin with you.

As research, take a ride to the Turners Falls dam and look south into the dead reach, then to the left at that churning canal.  Then, beginning around September 10, 2011, go south in Turners Falls and cross the canal on the 11th Street Bridge.  Head downstream along the public roads following the canal to where the paved road is called Migratory Way.  That’s where our federal fish lab is.  You may have to walk; they sometimes close the gates to cars.

But, beginning September 12th, that canal is set to be dredged of its muck by FirstLight.  Take a good look–before and after, at the muck-filled expanse.  Then, decide for yourself whether this is a suitable place to send even a few of the future’s precious remaining fish.

Karl Meyer of Greenfield, MA writes on many topics as freelance journalist. He has written for national and regional publications and been featured on public radio’s MarketPlace. Meyer is also an award-winning non-fiction children’s author. He holds an MS in Environmental Science from Antioch New England University and writes often about Connecticut River issues. Read his blog at: www.karlmeyerwriting.com  Contact him about writing and school and environmental presentations at: karl@karlmeyerwriting.com .

 

 

Lunar Retreat

Posted by on 27 Jun 2011 | Tagged as: Bank Row Writers, Personal Essays

Copyright © 2011 by Karl Meyer.  All Rights Reserved.

Lunar Retreat

June 16,2011                                                                                         South Wellfleet, MA 3 pm

Half of the Bank Row Writers are asleep–or trying to be, on a sun-drenched June afternoon on outer Cape Cod. This June sun, bumped fully into the open by last night’s amber full moon, has proven a worthy obstacle. Coming on the heels of day-upon-day of gray spring chill–the intense June light, coupled with these glittering, sandy shoals, has quickly melted our Yankee defenses.  We are relaxed. We are comfortable.  We are drooling on pillowcases in the middle of the day.

Yet, here on this temporary sand spit that will remain known as Cape Cod for a time, there is a single, profound reality permeating the collective subconscious as we daydream; as we sleep. It is ocean; the awareness of ocean. It is the inescapable presence of the great water that links us all to this past, and this future.

Moon, sea, cloud, tide–earth is nothing if not a water planet–a wet, chaotic and wondrous place that has offered a foothold to random, organized collections of complex atoms from time to time.

Staring at last night’s brimming tide and spring full moon at Nauset, it seemed inevitable that we would come to meet at this place.  Inevitable too, even for our three Bank Row comrades toiling at daily work a hundred miles from any tide–someday, not long off, their presence will be co-mingled with the same consciousness now holding us in its grip–here, today, at Ocean.

But for all, the question will remain; the puzzle will linger as the sea breeze presses through the fingers of whispering pitch pines: what’s to be done with this great consciousness? Is the mystery more sacred?, or were we shoved into our agitated awareness merely to solve one riddle, following closely on the heels of the next??

The answer to existence could be Ocean.  The proper response to awareness could be awe.  At this moment, half-awake under sunny June skies on the sands of Cape Cod, I can manage but a simple gesture to the full tides waiting to accept me: thanks.

Next »