November 2015

Monthly Archive

New comments to the Federal Energy Regulatory Commission

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, canal shad, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Extinction, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, FirstLight, GDF-Suez FirstLight, migratory delay, power canal studies, Public Comment period, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

The following comments were submitted to the Federal Energy Regulatory Commission on November 13, 2015, respecting relicensing studies occurring at the Northfield Mountain Pumped Storage Station and at the Turners Falls Dam and Canal. They are designated, respectively as: P-2485; and P-1889.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 November 13, 2014

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

ILP COMMENTS on Updated Study Reports—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. The majority of the fish and aquatics studies remain incomplete at this time. However, having attended the recent study update meetings with FirstLight’s consultants, and as a member of the Fish & Aquatics Studies Team for P-2485 and P-1889, please accept these brief comments on the USR and proposals for modifications and new studies needed in the FERC ILP for these projects. As studies are brought to completion and data and results are shared with Stakeholders I will submit further comments.

3.3.2 Evaluate Upstream and Downstream Passage of American Shad

Needed information from this study: from personal observations I noted many days when Station 1 was in operation. I visited the site, took some photos, and interviewed a fisherman who was busy catching shad at the Station 1 Outflow on 5/24/2015. In good light, and without the advantage of polarizing sunglasses, I observed dozens of shad stacked up like cordwood, treading water there. The gentlemen noted that whenever Station 1 is running “there are always fish here.” The report should include information about tagged fish delayed in this false attraction water. It is also critical to delineate the number of days during testing that Station 1 was in operation.

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 their update the applicant’s team stated that “because minimal shad spawning was observed in the Turners Falls Canal, no spawning areas in the canal were identified for further examination.”

Needed information from this study: at what hour, on what dates, and under what conditions were these “minimal” spawning observations made? Did they return to the site again under different, or more favorable conditions? What was the water temperature? Was it raining? Windy? Cloudy? Was Cabot Station running at the time-and how many units? Was Station 1 in operation on the nights they made their observations?

These are basic questions that require adequate answers as the TF Canal has been the bottleneck for the shad run up through Northern Massachusetts and into Vermont and New Hampshire these last 40 years. The canal appears to be culling off part of the run as a spawning trap. A thorough understanding of why fish are lingering there, and clear assessment of the numbers and delays of fish attempting to spawn in the canal is necessary for informed decision making.

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

Needed information from this study: This study needs to be extended for another year. On October 5, 2015, I took a 20-minute walk through a small segment of the canal at 7:00 a.m. on the morning the canal had drained. On the flats far–from the thalweg where most of the 2014 assessment appears to have taken place, thousands of fish lay struggling, stranded, and dead in the drying pools. These included juvenile American shad, yellow perch, juvenile and “transformer” sea lamprey, one 8-inch chain pickerel, one crayfish, and thousands of tiny, unidentified YOY fish in drying pools and rills that led to nowhere.

These observations were made crossing just a few—out of the many acres, of silt and muck “shoulder habitat” that occurs away from the main channel on both the east and west sides of the TF Canal. A more thorough mortality assessment needs to be made across these habitats to have a full understanding of the impacts of the canal drawdown migrating and resident fish.

REQUEST for New Study: Tagging and Spawning Study of the Connecticut River Shortnose Sturgeon at the Rock Dam Pool in Turners Falls.

The USFWS’s fish passage and dam specialist John Warner reports that both downstream and upstream modifications for fish passage at Holyoke Dam will be completed this winter. New entrances and exits allowing CT River SNS to move upstream beyond that site will be working in spring 2016.

In light of the construction at Holyoke and the 2016 continuation of test flows evaluations on spring migrants in the By-Pass Reach at Turners Falls, testing of spawning success for SNS should be done at their documented natural spawning site–the Rock Dam in Turners Falls, in spring 2016. Regardless of any fine tuning needed at the Holyoke facility, some SNS will return to the Rock Dam pool by the last week of April, and the chance to study their spawning success in light of regulated test flows presents a unique opportunity for the only federally endangered migratory fish on the Connecticut River.

If this fish is ever to benefit from new genetic input, a full understanding of suitable flows at Rock Dam to accommodate spawning is necessary information going forward for a fish that has been decades on the cusp of extinction. It’s an opportunity to restore a part of the public trust.

For further information on longstanding research at this site without required test flows, see Kynard, B. and Kieffer, M.C., et al: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society, ISBN 978-3-8448-2801-6.

Thank you for the opportunity to comment on the USR for these projects.

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

Redeem the promise at Great Falls

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, bald eagle, canal shad, Captain William Turner, Connecticut River, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, Conte, Conte National Fish & Wildlife Refuge, Daily Hampshire Gazette, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, Greenfield Recorder, Holyoke Fish Lift, New Hampshire, Northfield Mountain Pumped Storage Station, Relicensing, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, The Greenfield Recorder, The Recorder, Turners Falls, Turners Falls dam, Turners Falls power canal, USFWS, Vermont, Vermont Yankee, wildlife refuge

The following piece, with edits, appeared in the Daily Hampshire Gazette and The Recorder on November 12, 2015 as: “Federal wildlife service must preserve the promise at Great Falls,” and “River restoration retreat”

The US Fish & Wildlife Service’s recent abandonment of their flagship Conte National Fish & Wildlife Refuge Visitor Center at Turners Falls defies all logic. In August they abruptly withdrew their on-site interpreter and funding for The Great Falls Discover Center. That center was located above the falls two decades back precisely because of the site’s importance as an ecological refuge—perched at a river crossroads critical to the success of their new “watershed-based” refuge.

Back then bald eagles had just returned to Turners Falls; it was once again the place that hundreds of thousands of migrating American shad surged to each spring. And just downstream was the sole natural site where the only federally-endangered migratory fish in the watershed–the ancient Connecticut River shortnose sturgeon, attempted to spawn each May. Known as the Rock Dam, its an ancient geological formation that remains a premiere retreat for spring shad anglers. For its biological and historic importance alone, Rock Dam should have long ago been offered the Refuge’s first “in-river” sanctuary designation.

Yet today, USFWS seems ready to walk away from its core mission and long history on the river at Turners Falls. Doing so would be no less an historic retreat than that of Captain Turner and his battalion after their pre-dawn attack on hundreds of Native American women, children and old men seeking refuge at that very site nearly 340 years ago. On May 19, 1676–having accomplished their grizzly goal with the loss of just one man, they were sent in reeling retreat when the first counter-attacking Native warriors arrived from a downstream island encampment opposite today’s Rock Dam. They’d been stationed there to intercept the teeming May shad runs to help feed their people. Turner and 37 of his troops died in the ensuing rout.

Today, Turners Falls remains the site of the US Fish & Wildlife’s biggest regional blunder in a mission to protect a nation’s fish and wildlife resources on New England’s Great River. In the late 1970s they signed off on the plan resulting in a series of fish ladders being built there. It forced all migratory fish out of the river and into the Turners Falls Power Canal. That resulted in a half century of failed fisheries and habitat restoration—largely drawing the curtain down on a spring ocean-connection for riverine habitats in Vermont, New Hampshire, and northern Massachusetts. That 1967 USFWS/four-state migratory fisheries restoration compact for the Connecticut River still founders at Turners Falls today.

That is why the recent USFW’s retreat from their ecologically and historically unique flagship perch remains inexplicable. Currently federal hydro-relicensing studies of dam and canal operations at Turners Falls are taking place. Their outcomes will determine environmental conditions governing the Connecticut River in this reach for two generations to come. The USFWS is playing a key role in these studies as the lead agency empowered to define and require changes at Turners respecting the protection and restoration of the public’s federal-trust and federally-endangered fish species there. In short, they’re at a crossroads. They are the key player able to restore past mistakes and make the Conte Connecticut River Watershed National Fish and Wildlife Refuge a true refuge for annual migrants passing from Connecticut to Massachusetts; then Vermont and New Hampshire.

That long-awaited success would occur at the doorstep of the Great Falls Discovery Center–replete with its life-sized displays of watershed fish and wildlife, and its accessible public auditorium. It’s a huge opportunity at a site virtually on the river, easily reachable by visitors from a broad swath of southern New England travelling the I-91/Route 2 Corridor. Great Falls is the only brick and mortar place for the public to regularly interact with USFW staff and a diversity of displays of characterizing watershed habitats for 80 miles in any direction. What’s more it’s the only publicly-funded flagship Refuge site where admission is free.

Without a touchstone site in this populous reach of the watershed, most citizens will remain unaware of the restoration and conservation work of the USFWS. They’ll be left to surmise instead that Conte is more a theoretical Refuge—a concept and an amorphous jumble of disparate parts lacking any true core.

In practice and in theory, Turners Falls and the Discovery Center site represent the best of opportunities for the US Fish & Wildlife Service to succeed in their core missions of conservation, restoration, public access and education. A second retreat at Turners Falls would be an historic failure. This fabulously rich reach of the Connecticut is uniquely situated to showcase the Service’s long-awaited success in river restoration on the public’s behalf. Many mistakes could be redeemed with the right decisions at this time. Don’t abandon the Great River at the Great Falls.

Public comments are being accepted through November 13th on the USFWS’s plans for Conte Refuge priorities for the next 15 years at: www.fws.gov/refuge/silvio_o_conte/

Karl Meyer
Greenfield

From the Rutland Herald: Where our fish are trapped

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Connecticut River, Connecticut River migratory fisheries restoration, False attraction, Federal Energy Regulatory Commission, FERC licensing process, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Rutland Herald, shad, shad fishing, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Yankee, Vernon Dam Fishway


The following piece, with edits, appeared in the Rutland Herald on November 12, 2015.

Dear Vermont and New Hampshire:

Sorry, but your fish are down here in Massachusetts. With Vermont Yankee’s heated discharges no longer clouding issues, that’s become clear. We’re talking hundreds of thousands annually. This year a quarter million might’ve reached Vernon and Hinsdale had we not corralled them. A hundred thousand in the Great Eddy at Bellows Falls might’ve been a possibility.

And these aren’t small fry. These are free-swimming American shad straight from the briny Atlantic—wild fish that snap at lures and offer anglers an honest fight. Fresh caught and sweet, they’re a homegrown harvest for anyone taking the time to debone them or put them in the slow roaster. You could’ve been enjoying all that.

Actually you were promised them by the US Fish & Wildlife Service and state fisheries agencies back in 1967. They’d arrive in the 1980s–when much-touted fish passage facilities got built downstream. Each successive dam would pass 75% of the fish passed by the dam below it. Yet only excuses arrived. You weren’t told your fish got caught in a trap—that the Turners fish ladder diversion was a disaster; that your shad run dies in a muck-filled power canal. That’s where your bounty is still driven from the river today—where fish get diverted into a last-chance canal from which few emerge upstream.

We’ve now had the first spring where VY’s discharge has not intercepted spring runs. It appears the nuke played a smaller role than long-rumored concerning dismal fish passage at Turners. Heated effluent ain’t great for any species–but fish deprived of a river are an unending ecosystem disaster.

The 2-1/2 miles below Turners Falls Dam are that disaster. Down here government agencies don’t require anything approaching sustaining nature-like flows in the Connecticut’s bed. It’s either deluge or desert—much of it produced by the mega-flushing and pumping flows Northfield Mountain Pumped Storage Station sends downstream. Part of that blistering regime gets re-diverted into the power canal 5 miles south—a trap each upstream migrant is funneled into.

That canal is where a great migration dies—where fish get delayed; fatigued, entrapped and eviscerated. Not one in ten shad have made it beyond Turners Falls across the decades. It’s not rocket science to understand–in fact, the math just got a little simpler.

The years 2013 and 2014 were the final years Vermont Yankee was heating the river. Of the 393,000 American shad passing Holyoke Dam in 2013, just 9% or 35,000 fish made it past Turners. Yet of those 35,000 fish, 18,000 or 51% swam safely past Vernon–20 miles upstream. Similarly in 2014 of the 371,000 shad passing Holyoke, just 40,000 or 11% were able to get through the canal past TF Dam. But of the 40,000 that made it, a full 28,000 or 69%, swam beyond Vernon toward upstream destinations.

Turners’ fishways opened in 1980; Vernon’s in-river fishway in 1981. Across the decades the annual average of shad passing Holyoke that make it past Turners is 4%. In the same span, Vernon averaged passage of 40% of the shad arriving from Turners. Passage at Turners hovered near 1% for the decade beginning in 2000 when deregulation began allowing Northfield Mountain to pump and profit from the river according to price peaks on the electricity “spot market.” Those peaking pulses decimate river habitats below Turners Falls.

Which is why 2015 proved interesting. This spring, with VY silent, the Federal Energy Regulatory Commission ordered a series of nature-like test flows to be sent through the gates at Turners Falls Dam into the impoverished riverbed–to gauge their impact on the public’s fish runs. It’s part of the 5-year FERC licensing process for Northfield and Turners. At Holyoke 413,000 shad passed upstream, while at Turners just 14% or 58,000 shad passed the dam. Yet 20 miles north, 69% or 40,000 of those fish, swam past Vernon Dam—an all-time record for shad passage there.

So here’s some math: Turners passed 9% in 2013; 11% in 2014, and 14% in 2015. Vernon passed 51% of their shad in 2013, 69% in 2014, and 68% in 2015. The difference between a year with VY’s heated effluent, and one without—was insignificant, a 1% change with shad passage actually dropping a fraction with Yankee silenced. Yet they still set a new shad passage record.

It’s noteworthy the 34 year-old Vernon record was broken the first time more in-river flow was required below Turners Falls Dam, supplying a direct route upstream during FERC’s May-June test flows. It clearly spared some fish the energy costs of industrial entrapment and the dangers of weeks in a turbine-lined canal.

The problem is that canal, and a decimated river at Turners Falls. You’ve been owed fish totaling in the millions across the decades–and an ancient connection to the sea all kids should know. They’re not the power company’s fish, they’re yours. Demand federal and state fisheries directors sue for those fish—and for the Connecticut River refuge your grandkids deserve.

With apologies,
Karl Meyer, Greenfield, MA

Writer Karl Meyer is participating in the FERC hydro relicensing studies for MA facilities on the Connecticut River. He is a member of the Society of Environmental Journalists.

FERC Comments as FirstLight seeks unprecedented mid-license power increase

Posted by on 10 Nov 2015 | Tagged as: Federal Energy Regulatory Commission, FERC licensing process, FirstLight, forward market power auction, ISO New England, Mt. Tom Coal Plant, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir

The following are comments submitted to FERC concerning what would be an unvetted and potentially precedent-setting mid-license power uprate for FirstLight’s Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S.
Greenfield, MA, 01301
October 29, 2015

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

PROTEST against the granting of application for Amendment for Minimum and Maximum Reservoir Elevation for P- 2485-070, FirstLight Hydro Generating Company’s Northfield Mountain Pumped Storage Station.: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement, filed September 1, 2015.

Dear Secretary Bose,

In the 43-year operating history of the Northfield Mountain Pumped Storage Project a full assessment of the project’s impacts on the public’s river and terrestrial resources has never occurred. It has long been understood that NMPS significantly impacts some 50 miles of the Connecticut River’s riparian, stream bank, farmland and flood plain habitat from Vernon, VT to Holyoke, MA. The application before FERC requests a major, mid-license expansion of this facility’s storage and generating capacity without a full vetting of its impact on public resources.
If granted, the proposal before FERC represents a license to benefit—unrestricted and at profit, from a full 25% increase in generation capacity from NMPS’s Upper Reservoir for a 120 day period each fall, winter, and early spring, until 2018.

Given that NMPS is in the midst of its first-ever relicensing studies to gauge the impacts of its operations, it is not in the public interest to see this ongoing, 3 year, “temporary” storage amendment granted. Doing so without a full vetting of the emerging science and without the full participation of all stakeholders would amount to an Ex parte ruling—basically a precedent-setting gift to the power company during its run-up to a relicensing decision on April 30 2018.

NMPS has been granted extra cold season storage capacity only four times over its 43 year history. Each of those–save 2014, was restricted to extenuating circumstances where ISO would request NMPS to pump and generate beyond its mandated parameters after a trigger was reached. In requesting and being granted extra-limital storage last year, ISO and FirstLight appear to have entered into a new partnership of open-ended, unrestricted use of the public’s Connecticut River resources. This request is being made without investigation or any recompense to the public’s benefit beyond what both the utility and ISO refer to as “flexibility” in times of limited on-line capacity or restricted generation.

However, neither ISO or FirstLight has supplied any information as to how NMPS was used in any “emergency” capacity last winter—a winter that was prematurely touted as one with a tight energy market. Though a price squeeze was visited upon the public last winter in the form of vastly inflated energy bills, the predicted energy shortage never materialized. Both Northfield and ISO like to tout NMPS’s “black start” capability. However, to my knowledge the plant has only been used in that manner once, during the August 2003 Blackout, and increased storage capacity was not a factor in its use at that time.

ISO has in the past been tagged by FERC Board Members as supporting stilted judgements and sanctioning Foreward Market Capacity auction results that were clearly only in the interest of the power company—costing the public millions. That included 2013, when they sanctioned results from market bids by Energy Capital Partners(former owners of NMPS), who had unloaded their massive Somerset Coal Plant causing a dip in the future winter capacity outlook, sending energy bid prices soaring for ECP.

FirstLight has put itself in line to benefit from the same situation. They did not mention in any application that their Mt. Tom Plant was shuttered recently, and they stand to benefit if NMPS is granted open-ended generating privileges on the heels of a planned shutdown of one of their assets.

Further, it should be noted that FirstLight submitted only limited information on water levels in the CT River at their Turners Falls Dam and further downstream at the Montague USGS Gauge. No information was provided on how often, and by how much, the river fluctuated daily in the Turners Falls Pool due to their pumping and generating. They contend they generally strayed little from the average elevations in the TF Pool. Daily up-and-down figures during winter freezing, wetting, thawing, and rewetting, are wholly lacking.

FirstLight offers that it generated less in winter 2014/2015 than in many other years, but that tells only their story. When, and under what circumstances they generated, and at what profit, are really what’s required for a full assessment of the plant’s public good. Offering that “we only used a little” see?—is not any reasonable way to assess what might happen with an open-ended license to benefit from “peaking” spot market fluctuations this winter–or in 2016, 2017, and 2018.

Further, NMPS’s ownership changed hands three times over the last decade. Granting a mid-license capacity uprate to this plant could lead to speculation and instability in the deregulated market, causing a bubble in its asset value. If GDF-Suez decides to sell their NMPS plant in the interim, only merchants will benefit—with the public left in the dark on impacts, price, and profits.

I protest the granting of FirstLight an amendment to increase its minimum and maximum storage capacity for the remainder of its license. Further, FERC should not grant a one-year amendment without requiring a public accounting of how the plant was used in any “emergency” fashion—if any, last winter, and how its increased generation was harvested for profit on a daily basis last winter. If these are not provided, the amendment should be denied. Any amendment granted NMPS should include a capacity trigger from ISO, so as to ensure the public is not being gouged by winter fear-mongering.

Sincerely,
Karl Meyer, M.S.
Greenfield, MA, 01301