June 2021

Monthly Archive

My Response to FERC respecting FirstLight’s response to the Federal Energy Regulatory Commission’s questions and this relicensing process

Posted by on 23 Jun 2021 | Tagged as: Connecticut River, Federal Energy Regulatory Commission, FERC licensing process, FirstLight, Fish and Aquatics Study Team, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Project, PSP Investments, Rock Dam, US Fish & Wildlife Service, Vermont Fish & Game


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer

NOTE: The four photos above were taken of the Connecticut River’s oozing banks and dewatered cobble shoals at the Rock Dam, the sole documented natural spawning site and nursery of the federally-endangered Connecticut River shortnose sturgeon on June 23, 2021.

The following was submitted to the Federal Energy Regulatory Commission on June 23, 2021.

Karl Meyer
91 Smith St., # 203
Greenfield MA 01301
413-773-0006
Karlmeyer1809@verizon.net June 23, 2021

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
Hydro Licensing

RE: This day’s submission by FirstLight’s Operations Manager Nick Hollister respecting FirstLight MA Hydro LLC, Turners Falls Hydroelectric Project (FERC No. 1889)Northfield Mountain LLC, Northfield Mountain Pumped Storage Project (FERC No. 2485). Response #3 to FERC January 14, 2021 Letter Regarding Additional Information Requests

Dear Ms. Bose,

I write to you requesting a rejection of significant and substantial portions of the Additional Information Request filing made this day to FERC by FirstLight MA Hydro LLC and Northfield Mountain LLC. I have been a participating stakeholder, intervener and member of the Fish and Aquatic Studies Team for these projects, FERC P-1889 and P-2485, since 2012.

On January 14, 2021, FERC required updated information and an answer to the following inquiry:

“To enable staff’s evaluation of effects of the proposed project on fish entrainment at the Northfield Mountain Project, please provide estimated weekly and/or monthly pumping flow volumes for both current and proposed operations in a typical year.”

Simply stated, FirstLight has failed to address or provide any new or useful information in response to the requested NFM-AIR#4. What they have provided is decades-old data from the last century that does not reflect in any meaningful way how NMPS operates today, or how it might operate in any future scenarios.

Page 10 of their written response to FERC’s requirement sums up the uselessness of their outdated submission in bold parameters:

“Table NFM AIR#4-1 provides the average monthly volumetric flow rate of water pumped by Northfield Mountain over the 42-year period of record analyzed (i.e. 1962 – 2003).”

Put simply, Northfield Mountain did not exist in 1962, and did not come on-line until 1972. Therefore, a full 10 years of their purported data is null and void. Parent owner PSP Investments is new to this country and to Massachusetts, however that bit of historic information could have been culled in Wikipedia.

Further, their particular data-set ends in 2003, just three years into the timeframe when NMPS began operating under new and loosened pumping and generating parameters after Massachusetts deregulated their energy markets. It too is information representative of the past century.

Wholly absent is information on the first two decades of the 21st century, the one in which PSP purchased these facilities intending to profit from them for generations to come. What is absolutely needed, in order to make any projections on the scope and impact of pumping and generating operations far into the future, are the figures, charts and data from the year 2000 to the present, 2021.

And, as well, FERC surely understands that there have been policy changes at the Federal Energy Regulatory Commission in the current half-decade that now allow NMPS to operate more frequently and benefit from participation as a merchant supplier in the wholesale energy market. In order to begin to understand and project how these changes have impacted NMPS current operations and how they will impact future river conditions, a full comparison of recent operational changes due to these new FERC loosened parameters with the 5 preceding years should be the minimum of data and information required of FL by FERC.

In a relicensing now entering its 9th year, I find FL’s response to the FERC process to be yet another delay tactic at best, and wholly dismissive of all the state and federal agencies and stakeholders long engaged in this process at worst. It simply does not hold water. Please require an immediate and with-all-haste rewrite and resubmission of answers to these critical questions. Any new license offered should be shortened in relation to the accruing years beyond the expiration of their original license, April 30, 2018.

Sincerely,
Karl Meyer, MS Environmental Science

Cc: Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Kenneth Sprankle, U.S. Fish and Wildlife Service
Michael Pentony, NOAA Fisheries Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA
Daniel McKiernan: Director MA Division of Marine Fisheries
Louis Porter, Commissioner VT Dept. of Fish & Wildlife
Scott R. Decker, Inland Fisheries Division, NH Fish & Game Dept

Connecticut River: not clean; not healthy–it’s this river refuge’s hall of shame in MA

Posted by on 17 Jun 2021 | Tagged as: Andrew Fisk, climate change, climate-heating, Connecticut River, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, CRC, Dead Reach, Delaware LLC, Dr. Boyd Kynard, ecosystem, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight Power, fish passage, ISO, ISO-NEW ENGLAND, LLC, Micah Kieffer, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Project, Public Sector Pension Investments, pumped storage, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls dam, Turners Falls power canal, Uncategorized, USFWS, Vermont, water lab

Copyright © 2021 by Karl Meyer


June 15, 2021, the baking, dewatered Rock Dam cobbles at the shortnose sturgeon nursery, where early life stage sturgeon should find watery shelter. This is DEAD, critical habitat. Photo Copyright © 2021 by Karl Meyer

For a fourth season beyond the date (4/30/2018)Canada’s Public Sector Pension Investments FERC (Federal Energy Regulatory Commission) license expired to operate their FirstLight Power, river-ravaging Northfield Mountain Pumped Storage project and river-starving Turners Falls/Cabot Station power canal diversions out of the main stem river, conditions for fish and a living river ecosystem have again proven grimly dismal. Conditions last weekend in the 20 mile reach backed up for NMPS’s river-gorging behind TF dam got so ugly there was not even water to launch a boat just a half mile above the dam at the state boat launch. See Ch. 22 link below.

https://www.wwlp.com/news/local-news/franklin-county/low-water-levels-for-parts-of-connecticut-river-in-franklin-county/

Without a watchdog and a lawyer with an injunction at the ready, that’s just what you come to expect here. Insanity is witnessing the same lack of enforcement and leadership languishing, year-in, year-out, and expecting different results.


Migration season spill to the actual riverbed amounts to little more than a pan of dishwater–for fish seeking an upstream route to Vermont and New Hampshire. Photo Copyright © 2021 by Karl Meyer

The most interesting statements on the situation did not come from any of the agencies or the ngo laying claim to safeguarding this massively abused reach, but from PSP’s FirstLight Power–now re-registered out of the Bay State as a Delaware llc. Here, in their press statement they actually felt quite comfortable pointing to ISO-New England in Holyoke–the “electric grid operator,” as the responsible party for choking the life out of the Connecticut in Franklin County–right in the midst of key spring spawning when development of early life stages are critical to restoring beleaguered runs of migratory fish. READ FL statement BELOW:

“Over the weekend water levels in the area of Barton Cove were exceptionally shallow due to several overlapping conditions affecting water levels in the Turners Falls Impoundment.These factors included dispatch of our facility by the electric grid operator at the same time we were spilling water over the Turners Falls dam to meet federally required flows to support fish passage. These conditions are all within the approved and licensed operation of the facilities, however, coupled with lower than usual flows in the river, the water levels dropped to an unusually low level in this instance.”

ISO-New England and PSP/FirstLight are like corporate kissing cousins–in a grim Bermuda Triangle where the river disappears. That triangle goes from Northfield/Turners Falls through Holyoke, thence down to Delaware for tax-dollar cleaning; and then way back north to Canada for profit-taking. OOOPPS, I guess that makes it a Bermuda RECTANGLE!

Anyway, hard to reconcile those grim, pillaging river conditions with any massive requirement for huge amounts of power… It was simply a gorgeous June weekend–no giant peak power use or anything in the way of summer heatwave stuff going on. Could it be that our ecosystem was being massively thrown under the bus purely for profit taking? Or, was ISO-NE exporting our river–ravaged for its megawatts, far outside our region? Did the Connecticut get pillaged for use in the New York power grid? It’s just a scam, wrapped in a riddle, with no media scrutiny permitted.

Here, though, I must extend a prize for BS to FirstLight’s PR people who blame, in part, the fact that they “were spilling water over the Turners Falls dam to meet federally required flows to support fish passage.” Their sole and absurdly “required” offering of spill into the riverbed for migrating fish is 400 cubic feet per second in fish passage season. That’s the equivalent of a dishpan’s worth of water, when a swimming pool’s worth is the minimum required to restore a living ecosystem below the Turners Falls dam. These communications people are high paid, and they are so good when you have an uninformed public.

MEANWHILE, I visited that DEAD REACH below TF Dam on Monday. The Rock Dam, the only documented natural spawning site of the only federally-endangered migratory fish on the Connecticut in Massachusetts. For endangered shortnose sturgeon in Franklin County, just yards away from the Conte Fish Lab, and just across the river from the home of the Connecticut River Conservancy, it was just another de-watered, failing riverbanks day. Baking cobbles, blood-orange sludge drooling down failing banks and entering the Connecticut as slurry. Months back Andy Fisk of CRC–with its own in-house water lab, definitively told the media he would not sample that grim soup. I guess if you sample and find a problem, people would expect action.


June 15, 2021: here are the blood-orange, buckling Connecticut River banks sloughing directly into the Rock Dam pool. Photo Copyright © 2021 by Karl Meyer


The sludge outlet into Rock Dam. The sturgeon bakery-beach cobbles are in the background, right–that little tongue of dead water is the CT River’s “flow”. Photo Copyright © 2021 by Karl Meyer

The Rock Dam pool, as some of this river’s most critically endangered habitat, was exhaustively investigated by Conte Lab’s Dr. Boyd Kynard and his assistant Micah Kieffer, for 17 straight seasons. Yet today, in the midst of critical relicensing times, Conte Lab does not even set out a basic water-level data loggers–which would at the very least, offer annual data during the critical spawning months of April through June on flows, depth and temperature. That would at least tell you on what particular date and time. and at what water temperature the dam and headgate operators upstream inside FirstLight’s Northfield Mountain shut off the spigot at Turners Falls dam, sending their grim pumped storage surges sideways into their canal and screwing another sturgeon spawning season at this ancient nursery site for endangered fish trying to hold their place in the ecosystem.

I personally paid for and installed a data logger at Rock Dam a half decade back–though I could not have got it done without the quiet and prodigious help and expertise of a leading sturgeon biologist and investigator. The results were incontrovertible and damning. They got forwarded to the National Marine Fisheries Service, the lead agency on sturgeon protection, and USFWS. No action was ever taken.

I also intervened with FERC vs. FirstLight for dewatering Rock Dam three spawning seasons back–citing violation of the ESA in the face of the KNOWN presence of spawning sturgeon there. My argument, which did result in a FERC hearing in Washington DC, was made on the basis that FirstLight violated their license requirement to coordinate operations of their Northfield and TF facilities, which also includes adherence to the tenets of “takings” under the Endangered Species Act. FERC tossed out the my arguments on inscrutable grounds, but I at least stood up.

If I had a federal lab this season–or for ten seasons past, I would have protected that shortnose nursery just 300 yards away and right under my nose at my federal lab. That’s “Science for a Changing World.” And if I had a water testing lab at my facility, the first thing I would have done is take that water sample–just to be sure. This year, or last year–because that’s what real river protection means.

Clean water;healthy habitats in Franklin County Massachusetts? I think not. Massachusetts is where the Connecticut River ecosystem dies; and the profits fly out of the region. Special thanks to PSP Investments, your neighbor since 2016, and ISO-New England, your bulk power corporate facilitator.

OHHHHH, OOOOHHH! And please don’t forget, every time Len Greene from FirstLight, or Alicia Barton leaves you walking away from some press release somehow thinking that Northfield Mountain is producing ‘clean’, ‘carbon free’ energy?–do note that Northfield is a huge energy CONSUMER that has never produced a single watt of virgin power. In reality it is running off the massive slugs of carbon gorging/planet warming natural gas that today powers the ISO-New England Power grid. In recent days, without any heat wave in sight, their energy “mix” that is massively pulled on for NMPS’s river killing has exceeded 60% natural gas at times. There is everything deadly, and little benign, about what Northfield has done to the Connecticut these last 49 years–or what it will do in the future.

Finally, the thing to note and remember about the Connecticut River across all these decades:

WHERE THERE IS NO WATCHDOG, THERE IS NO ENFORCEMENT.

There is no watchdog protecting this river.

Rock Dam: the Connecticut River’s shortnose sturgeon “bakery”

Posted by on 03 Jun 2021 | Tagged as: Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, Rock Dam, The Recorder, vtdigger.org

The first link below is from an interview I did with Don Ogden(d.o.) and Glen Ayers on the EnviroShow, which aired this week.

Further down are links to The Recorder, vtdigger, and the Daily Hampshire Gazette, where a satirical piece on the abandonment of the most critical biological habitat in this river ecosystem, which also ran this past week.

This is a model that has failed, dismally.

https://archive.org/details/the-rock-dam-enviro-show-6-1-21


The Rock Dam’s drained and baking cobbles: killing field for the eggs and Early Life Stages (ELS) of the federally endangered Connecticut River shortnose sturgeon. Photo Copyright © 2021 by Karl Meyer

Sometimes you have to laugh to keep from crying… See links below:

https://archive.org/details/the-rock-dam-enviro-show-6-1-21https://www.recorder.com/my-turn-meyer-LocalDelicacy-40676082

https://vtdigger.org/2021/06/02/karl-meyer-rare-downstream-dining-baby-baked-endangered-sturgeon/

https://www.gazettenet.com/my-turn-meyer-LocalDelicacy-40767302