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Page 10 of their written response to FERC’s requirement sums up the uselessness of their outdated submission in bold parameters: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