Photo Copyright © 2020, by Karl Meyer.
NOTE: the above photo was taken on 2/25/20 at the Rock Dam pool in Turners Falls. This is the ONLY documented natural spawning site for the federally endangered shortnose sturgeon on the Connecticut River. NOTICE: the Connecticut River shortnose sturgeon is the ONLY federally-endangered migratory fish in the entire ecosystem. Shortnose sturgeon will be returning to the grim conditions in this ancient spawning pool in just 7 weeks.(Click, then click twice more to enlarge)

I sent the Federal Energy Regulatory Commission the following letter in October of 2019.

Karl Meyer, M.S. Environmental Science October 9, 2019
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

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

ILP COMMENTS re: Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

These comments are made with respect to immediate concerns respecting P-1889 and operations of the Turners Falls Dam and power canal impacting the riverbanks and the spawning habitat of the federally-endangered Connecticut River shortnose sturgeon at the Rock Dam, this species’ only documented natural spawning site in the Connecticut River ecosystem. I have been a participating Stakeholder in the FERC relicensing process for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both these projects.

In recent weeks I have noted increasingly steady water leakage in the riverbanks above the Rock Dam site, leading to constant water flow intrusions along these banks. Less than 400 feet away sits the downstream, outer-right banking curve of the Turners Falls power canal, which is the apparent source of these increasing water intrusions.

In a visit to the Rock Dam site on October 8, 2019, I noted the dramatic collapses of a long section of riverbank adjacent to the Rock Dam. This collapse, of some 25 feet in width and dropping down between 5 – 10 feet toward the river, is apparent in my attached photo. Please note that the draped yellow jacket in the foreground is approximately 3-1/2 feet across. This new bank collapse is just south, by perhaps 30 feet, from an earlier recent collapse of a smaller scale of some 6 feet across, occurring at approximately the same bank level. At both of these sites there has been a serious leaching of manganese, the red colored flow toward the river and the sand and cobbles that constitute the shortnose sturgeon spawning site and egg/embryo nursery unique to this reach.

Of most import in the licensing and management of this critical habitat is the damaging, new eroded channel flowing around the Rock Dam site on river left that has grown from a trickle in the mostly rain-free months of this year’s late summer and early fall—until, by yesterday, October 8, 2019, it had grown to torrent of new water coursing through a new channel adjacent to those collapsing river banks. The corresponding connection to this dramatically increasing damage appears to stem from the increased flows currently being released from Turners Falls dam to facilitate the week-long dewatering of the Turners Falls canal, currently in progress. See attached photo of TF dam release on that day. This new channel presents an immediate threat, through deposition and erosion and pollution, to the spawning and early life stage development of shortnose sturgeon in the rock, sand, and cobble habitats at the Rock Dam pool, immediately downstream and adjacent.

Immediate action appears to be necessitated by these developments. This riverbank and traditional fishing access has been neglected and poorly maintained through the last decade. A cursory look would find neglected concrete pilings where steps were to be built, as well as literal sink holes in at least two sites in areas above these collapsed banks, where small hemlock trees are now sunk to the depth of 4 feet.

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.

Thank you for your careful review of these matters; they are of immediate import.

Sincerely,
Karl Meyer

Cc:
Doug Bennett, FirstLight
Julie Crocker, NMFS/NOAA
Ken Spankle, USFWS
Melissa Grader, USFWS
Caleb Slater, MA Div. of Fish & Wildlife,
Rich Holschuh, Elnu-Abenaki”

Photo Copyright © 2020, by Karl Meyer.

Just one small section of FirstLight’s collapsing riverbank and the pollution that runs into the Rock Dam pool just 40 feet away. This is just 250 yards away from the USGS S.O. Conte Anadromous Fish Research Center. (NOTE: Click, then click x2 to enlarge)

NOTE: Over 4 months later the Federal Energy Regulatory Commission finally took the bold action to order Canadian-owned, Delaware-registered FirstLight to investigate and report on their own impacts on this critical endangered species habitat on the Connecticut River. THE ORDERS ARE BELOW:

FEDERAL ENERGY REGULATORY COMMISSION
Washington, D. C. 20426
OFFICE OF ENERGY PROJECTS
Project No. 1889-090 – Massachusetts
Turners Falls Hydroelectric Project
FirstLight Hydro Generating Company
VIA FERC Service
February 21, 2020

Mr. Donald E. Traester
Manager, Regulatory Compliance
FirstLight Power Services, LLC
99 Millers Falls Road
Northfield, MA 01360
Subject: Complaint – Erosion

Dear Mr. Traester:
On October 9, 2019, we received a complaint regarding erosion in the bypassed
reach of the Turners Falls Project No. 1889. According to the complaint, releases fromthe dam caused erosion in the area known as the Rock Dam in the project’s bypassed reach. For us to complete our review of the of the complaint, please file the following information within 30 days of the date of this letter:

1. Photographs and the location(s) and an estimate of the extent(s) (e.g., height,
width, depth) of the erosion in the bypassed reach identified in the October 9, 2019complaint.

2. The dates and timing of the Turners Falls power canal drawdown, why it was
performed during this time, whether it was typical of past drawdowns, and what
measures you took to protect downstream resources and the public.

3. Flow data for the entire period identified in item 2, including releases from the Turners Falls dam.

4. A comparison of the flow releases into the bypassed reach during this drawdown
to historical releases into the bypassed reach (e.g., for maintenance purposes,
naturally occurring high flows, etc.)

5. Any additional information you believe is pertinent to the allegations raised in the October 9, 2019 complaint.

20200221-3033 FERC PDF (Unofficial) 02/21/2020
Project No. 1889-090 – 2 –

The Commission strongly encourages electronic filing. Please file the requested
information using the Commission’s eFiling system at http://www.ferc.gov/docsfiling/efiling.asp. 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, D.C. 20426. The first page of any filing related to this letter should include docket number P-1889-090.
If you have any questions regarding this letter, please contact me at (202) 502-
6778 or Christopher.Chaney@ferc.gov.

Sincerely,
Christopher Chaney, P.E.
Engineering Resources Branch
Division of Hydropower Administration
and Compliance