Turners Falls Dam with Spill on the Right Emanating from Two Bascule Gates. Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. CLICK, then CLICK again.

(NOTE: the following Stakeholder Comments were accepted by the Federal Energy Regulatory Commission on April 18, 2019)

Karl Meyer, M.S. Environmental Science
Greenfield, MA, 01301 April 18,2019

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

RE: P-1889 and P-2485, Stakeholder Comments on Study 3.3.19, Evaluate Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding the Cabot Tailrace; and the Study Addendum Plan to extend the results of 3.3.19, presented by FirstLight at the March 29, 2019 meeting at Northfield.

Dear Secretary Bose,

I have been a participating Stakeholder in the FERC ILP relicensing proceedings for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both projects and have been in attendance with fellow Stakeholders at all relevant FERC ILP meetings and consultations since that time.

On March 29, 2019, FirstLight held a meeting with federal and state agencies and stakeholders to present their Study Plan Addendum to continue investigations under Study 3.3.19. The new 2019 Study treatments will again involve manipulating flows from the Turners Falls Dam and Station 1 to understand the necessary conditions for bringing American shad through the By Pass and up to the TF Dam.

Need: the need for 3.3.19 has already been demonstrated; and the necessity of gaining further information has become obvious—results have shown that shad move through the By Pass directly to the dam when signaling flows are present. Thus, FL intends to do a new series of test flows through the By Pass Reach beginning in May, involving various flow treatments implemented at the TF Dam bascule gates, and through Station 1.

Need for Additional Information: any Study that informs decisions on License Conditions needs to be repeatable, with parameters that are verifiable. During the March 29, 2019 meeting FL Manager Doug Bennett stated that gauging flow releases at Turners Falls Dam was rather imprecise, involving guesswork and incremental, 1-foot adjustments to the Bascule Gates at TF Dam. This situation adds too much imprecision to a study meant to lead to repeatable flow conditions and an understanding of how shad respond to stepped flows.

Further Information Needed: Without precision or benchmarks to accurately gauge the flows entering the By Pass, it will be impossible to understand the precise settings impacting the movements of shad toward TF Dam as releases are made at the Bascules and through the Station 1 Canal Extension.

Recommendation: The need for an accurate and repeatable metric for testing and implementing flow conditions is obvious. It is a necessity for the future judicious sharing of water through these Projects.

This demonstrated necessity can be accomplished quickly, simply, elegantly, and with little expense for Study 3.3.19, with the installation of Staff Gauges at Turners Falls Dam and
Station 1.

At Turners Falls Dam, Staff Gauges can be braced and installed on the Support Stays between Bascule 1 and Bascule 2, extending upward from the base of the dam. A gauge will also be needed on the upstream side of the dam. There may yet be a gauge near the Old Red Bridge abutment just upstream of TF Dam, but this may need updating or replacement.

At Station 1, Staff Gauges can be installed at the outflow tunnels, and a gauge just inside the Station 1 Canal Extension at the defunct rail crossing would be sufficient.

(NOTE: if spring conditions do not allow for installation of hardware or permanent staff gauges for the upcoming study, painted benchmarks can easily suffice for this season in order to gain the required information.)

Thank you.

Sincerely,
Karl Meyer, M.S.