The following Stakeholder Comments/Requests on FERC Projects P-1889 and P-2485, Turners Falls Hydro and Northfield Mountain Pumped Storage were submitted on November 13, 2014 to the Secretary of the Federal Energy Regulatory Commission.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301                                                              November 13, 2014

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

ILP COMMENTS–including: Disagreements/Modifications to Study/Propose New Study on Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process in order to continue plant operations beyond 2018. An Initial Study Report Meeting Summary has been filed by GDF-Suez FirstLight. Please accept these comments on the ISR and my proposals for modifications and new study requirements in the FERC ILP for these projects.

3.3.11 Fish Assemblage Assessment:

Further information/study needed:

FirstLight has declined to undertake any study in the By Pass Reach of the Connecticut River due to stated concerns of interference with spawning and development of embryos of federally endangered shortnose sturgeon in this area. Information from the 2009 EPA study is insufficient to quantify presence and abundance of resident and migratory fish in this reach during critical migration and spawning periods—April through June. That investigation used only 3 sites in the By Pass Reach and was not undertaken to illuminate key species requirements in the current ILP for this critical reach.

NMFS notes that FirstLight has failed to consult with stakeholders on SNS issues here. I am in agreement with USFWS that a dedicated snorkeling, SCUBA, or hookah diving assessment of this critical reach of the four-state CT River be conducted in the riverbed between the Turners Falls Dam and downstream of Cabot Station during the April-June migration and spawning window–and that it continue after FirstLight’s suggested June 30 beginning target date.

I personally snorkeled parts of this reach in May 2013 and found that identification of migrants and resident species was easily attained. An in-situ investigation of this river reach in order to assess species presence and relative abundance is necessary groundwork for making decisions that will impact the 45-year long fisheries restoration on the Connecticut.

Dr. Boyd Kynard, who FirstLight cites in their argument and who spent decades investigating shortnose sturgeon on this reach of the Connecticut told me (personal communication 11/12/2014) that this study method can be accomplished without impacting SNS from the pool below the Rock Dam upstream to the base of Turners Falls Dam.

3.3.12 Evaluate Frequency and Impact of Emergency Water Control Gate Discharge Events and Bypass Flume Events on Shortnose Sturgeon Spawning and Rearing Habitat in the Tailrace and Downstream from Cabot Station.

Further information/study needed: FirstLight has supplied a grid of information for emergency gate and by pass flume openings for the years 2005 – 2012, though 2010 is missing, and we have no information on gate openings and placement for 2011 and 2012 in some instances, other than that there were no instances when greater than 4 emergency flume gates were open.

This study information should be updated with full information for years 2011, 2012—as well as 2013 and 2014 gate opening numbers, placements and CFS information.

Study findings from Kynard and Keiffer, as well as the long-term study of SNS in this reach catalogued in Life History and Behaviour of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Society, 2012, specifically delineate emergency and canal flume gate spill as having a profound and deleterious impact on shortnose sturgeon spawning and early life stage development.

As was stated recently by sturgeon biologist Micah Kieffer at a fall 2014 meeting of the Connecticut River Atlantic Salmon Commission, “one instance” of ramped-up or ramped-down flow from TF dam or emergency spill gate and flume operation can abruptly terminate or abort spawning attempts at Rock Dam and below Cabot Station by federally-endangered SNS for the entire year. Operations of emergency and by pass flume gates on the TF canal also can have deadly parching or burying impacts SNS embryos.

FirstLight contends that its operations of Bypass flume gates above Cabot Station are aimed at either emergency load rejection at Cabot Station, or opened to flush debris. They also contend that it is rare to have more than one flume spill gate open, though most of the numbers belie this statement–and the number of days when 4 or more gates have been open during SNS spawning window is highly significant and impactful. Opening of 4 flume gates needlessly diverts flows approaching 4,000 CFS out of the Connecticut’s By Pass Reach at TF Dam, and sends it into the canal to be needlessly flushed back into the river in a configuration that impacts migratory species and imperils annual spawning attempts of the federally-endangered CT River shortnose sturgeon.

In May 2014, I personally witnessed 3 consecutive days when two or more spill gates were open at the TF canal bypass above Cabot—all at the same time of day: 12:25 pm. These openings occurred while both Station 1 and Cabot were generating, which would appear to indicate that the spill gates had been left in this position for hours, or perhaps days, as part of flow regulation in the canal–rather than emergency or debris clearing. I have sent this information to both FERC and the federal and state fisheries agencies.

It is clear to anyone who examines the TF power canal that it is mostly a lake-like, slow-water habitat, save for the thalweg. It is rare to see debris of any significant size floating in the canal. It gets culled off at the trash racks in front of the TF Gatehouse, or at racks on the canal that dog-leg off to Station 1, or it simply settles out in the lake section of the TF Canal.

The minor amount of small, floating debris that enters the fat part of the canal is culled off by the trash rack skirt above Cabot that steers it to the east side of the canal where a bascule gate can be operated to pass anything of significant size.

The continuous openings of two or more bypass gates, up to six and seven gates open on a “non-emergency” basis on the TF canal above Cabot Station during SNS spawning and early life stage periods threatens the recovery of the Connecticut River’s only federally endangered migratory species.

As I have witnessed, multiple gates open on the canal while both Station 1 and Cabot were in operation indicates that canal flow is at times being regulated at this site, rather than at the TF Gatehouse, where excess flow could be delivered to the river in the Bypass Reach, which would nourish, rather than destroy SNS chances for successful spawning at Rock Dam and below Cabot. During SNS spawning season, mid-April – June 30th, endangered species protections dictate that all flow, save for documented, specific emergency situations, by controlled at the Head Gates of the Turners Falls Dam.

Information for years 2013 and 2014 should further be included, and a Study and study season for 2015 should be implemented that documents both the reason and instances when emergency gates were open—and any flume gates above 1 that were open to vent flow from the canal to the ByPass.

I would also like to FERC to have FirstLight include information for 2010, as the May 4 time of 8-gate emergency spill operation occurred exactly at the time frame when Northfield Mountain had burped up a massive sediment spill into its intake, and was trying to flush that pollution downstream. It would be helpful to know the position of both the Bypass flume gates and the positions of TF Dam headgates and bascule and tainter gates at that juncture—as it most definitely impacted SNS present for spawning that year. This would again offer data on whether the TF canal flows were being regulated via emergency by pass flume operation.

3.3.14 Aquatic Mapping of Turners Falls Impoundment:

Further information/study needed:

If migratory fish targeted for restoration in Northern Massachusetts and Vermont and New Hampshire are to continue to be diverted into the TF Power Canal, where few emerge upstream, then an addition to this study should be conducted: Aquatic Mapping of the Turners Falls Power Canal—as it is technically an extension of the Turners Falls Impoundment, and the public has a right to understand the habitat where their fish get privatized.

3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms

Further information/study needed:

The 2014 Canal Drawdown study was flawed as it occurred over the course of two days, due to an error in spill gate function. Since this is a study of live and dead fish and organisms, as well as the presence of dissolved oxygen, a two-day study time frame represents a flawed evaluation. A night of drying, predation, and fluctuating oxygen presence confounds the results of this work. FirstLight does an annual drawdown of the canal—has down so for decades, thus a mistake at the time of a critical habitat study should corrected by conducting a second year of study.

Further, since FERC has ordered that FL conduct a study of American shad spawning in the TF Canal, it is important to note another anomaly in their canal drawdown work. At five-year intervals the TF Canal receives a full canal muck-out during drawdown. The last one occurred in 2009. This would have been the fifth year—a time when the major muck-out would occur. It did not happen. What occurred was canal “light”, with a large snafu in the middle of the one day study, making it a two day effort. Whether FL agrees that this should have occurred in 2014 or not, a big-dig in the canal is needed regularly, as the sludge, silt and muck settles out and fills in the wide part of the basin.

This must be figured into the “impacts” of the drawdown, as it has profound implications for forcing migratory fish into this habitat, as well as the survival of resident fish and aquatics.

Please see attached photo of the canal muck-out that I took in 2009.

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

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

 

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

Further information/study needed: the need for this 2016 study will be fully realized if planned studies of American shad movement and spawning in the canal confirm that these fish are experiencing significant migratory delay, and are being coralled into a migratory spawning trap by confused and insurmountable flows or pre-mature warming in artificial habitat that induces spawning in the canal—preventing fisheries restoration on the river in Northern Massachusetts, New Hampshire and Vermont.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Further information/study needed: I concur with FERC’s requirements of an intensive array of radio and telemetry receivers throughout the TF Power Canal to track migrating shad in the canal.

However, I request that FERC require FirstLight, in consultation with stakeholders, add an array temperature monitors calibrated to the radio and telemetry sites to understand whether canal delays for American shad–lingering for an average of 8 days in the TF Canal, are forcing these fish to spawn in this privatized, lake-like habitat because of warmed, shallow, and slow water conditions.

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

Further information/study needed:
I concur with FERC that a full spawning study of the Turners Falls Power Canal be conducted in 2015, undertaken in consultation with stakeholders. Temperature monitors should be deployed to assess impact on migratory delay and spawning on-set; and cumulative impacts of head gate and by pass use of spill gates should be factored into the study to determine the impact of silt deposits on spawning success.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

Further information/study needed: In the Initial Study Report Study Meeting Summary for stakeholder in October 2014, a request was made that FirstLight provide vector maps with arrows and indication of directional flow around the Intake and Tailrace Channel at the Northfield Mountain Pumped Storage Project. This is critical information for flow, erosion, and sediment displacement and needs inclusion.

This is information that has been missing on Northfield Mountain Pumped Storage Impacts since at least 1974. See attached at end of document.

Thank you for this opportunity to comment on these critical relicensing issues.

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

1974 attached file below.