Anadromous Fish Conservation Act

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The Connecticut River’s staunch public defense broadens…

Posted by on 02 Jan 2022 | Tagged as: America's best landscaped sewer, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, conservancy, Conte National Fish & Wildlife Refuge, CRC, defense, E-Comments, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Hudson Riverkeeper, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

THE PUBLIC CONTINUES TO STEP UP and defend the Connecticut River against a new half-century of ecosystem destruction.

IN THE LAST TWO WEEKS MORE THAN 40 CITIZENS–and counting, have entered testimony into the Federal Energy Regulatory Commission public record stating that the Northfield Mountain Pumped Storage Project is too destructive to be relicensed.

You can read the latest citizen FERC filings–and get directions for filing your own, further below.

These on-the-record defenses become part of the Federal Energy Regulatory Commission’s input as they ultimately make their “Environmental Assessment” of FirstLight’s full and final license application some months down the road. FERC, too, is mandated to ensure that federal and state environmental laws and statutes are followed when deliberating the issuance of a license.

Will they follow the citizenry and release Northfield’s deadly choke hold on this ecosystem in Massachusetts after 50 years of destruction??

I wish I could promise that will happen. What I can promise is that the MA Division of Fish & Wildlife, the MA DEP, the US Fish & Wildlife Service and National Marine Fisheries Service–all agencies that have failed all these decades to protect and enforce environmental statutes and federal fish passage and protections on the Connecticut this last half century, will CERTAINLY be reading these comments. They will be reading them in the knowledge that people are paying attention as they participate in backroom “final” license negotiations with FirstLight.

WILL THESE AGENCIES, ALL WITH MASSACHUSETTS OFFICES, FINALLY STAND UP for what’s still the Nation’s best landscaped sewer here in the Commonwealth of Massachusetts–AGAINST this deadly, river-reversing scourge crippling an entire ecosystem??

THEY ALL OWE NEW ENGLAND A LIVING CONNECTICUT RIVER!

Why we find ourselves here after half a century is because the river here has been left undefended since the mid-1960s when the Northfield Mountain Pumped Storage Project was first proposed.

The photo above is of a little tourism, chamber-of-commerce Connecticut River promotion paddle that took place in October 2020. That little promo outing left from a site virtually next to the mouth of the Northfield Mountain’s deadly intake tunnels. That’s MA Secretary of Energy and Environmental Affairs Kathleen Theoharides in front of the camera, State Senator Jo Comerford is in the background on the left, and CRC Director Andy Fisk–though not pictured, was also a happy paddling participant that day.

While all were offered turns in front of those cameras and to talk to the print media on FirstLight’s turf–next to the grimmest machine ever installed on the Connecticut, NOT ONE spokesperson or representative took the opportunity to defend a defenseless river; not one made any reference to the grim fate of this ecosystem’s resident and migratory fish…imperiled, just yards away, when they had the opportunity to reach the public through the media.

Rather than green-wash the elephant in the room, any one of them could have offered this truth to the public: This river-reversing machine literally devours millions of eggs and young-of-the year migratory fish produced in a three-state(Vermont, New Hampshire and northern Massachusetts)river reach annually. Instead, they paddled and picnicked.

For comparison, a nearly mirror-image pumped storage proposal was brought up in the mid-1960s by Consolidated Edison for Storm King Mountain on the Hudson River at virtually the same time.

Unlike on the Connecticut, where a “watershed council” had been in business since 1952, the citizens on the Hudson got together and decided to FIGHT against turning Storm King Mountain into their river’s deadly sewer. They fought ConEd in the courts, and defended their Hudson River, openly, in the court-of-public-opinion, for 15 years–and WON. They proudly bragged about their mission, their willingness and duty to investigate, enforce, and prosecute. That’s what bona fide river protection looks like. They forced the state and federal agencies to DO THEIR JOBS! That’s what real watchdogs do.

Do a quick bit of research on Storm King Mountain, the Hudson River Fishermen’s Association, Scenic Hudson, and ultimately, Hudson Riverkeeper, and you’ll see what enforcement and real river defense models–with staff lawyers and enforcement, look like.

HERE, BELOW, you can read a new citizen’s defense–the latest public filings defending our river and it’s ecosystem. Another half century of failure is simply unacceptable:

Document Accession #: 20220103-5007 Filed Date: 01/03/2022
Frank Ribeiro, Bernardston, MA.

Hello
As a concerned citizen of Franklin County, Massachusetts, I have lived in the Connecticut river valley for fifty years. It is truly a wonderful place to live.

In today’s modern world there are many environmental challenges that we face to maintain the balance of nature. The one problem that has been obvious to me over the many years is the constant assault to our beautiful river.

We need to stop this assault and abuse. FirstLight MA Hydro LLC license request to continue operation of the Northfield Mountain Pumped Storage must be rejected.

For the sake of company profits OUR river is out of balance. It needs your help to secure its future and the future of ALL things living who are dependent on its survival in a natural, balanced state.

Please reject this application.

Thank You
Frank Ribeiro

Document Accession #: 20220103-5010 Filed Date: 01/03/2022
Andrew Hutchison, Greenfield, MA.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem. This system is clearly harmful to endangered species, such as the shortnose sturgeon. While the facility has been bought and sold numerous times over the years, the attention to preserving the ecosystem has been ignored repeatedly in search of profits. While private businesses have a right to seek profits for their shareholders, that does not supersede the endangered species act or the right of the stakeholders to a healthy river.

Document Accession #: 20220103-5011 Filed Date: 01/03/2022
Mark Russo, Deerfield, MA.

RE: the request of First Light for re-licensing of Northfield, MA pumped storage facility (FERC project number P-2485). I have serious concerns about the damage caused by this facility to the critically important Connecticut River eco-system as graphically detailed in editorials submitted by Karl Meyer and published in the Greenfield Recorder. If your decision is to renew this controversial license, strong environmental safeguards must be required and regularly monitored; and given the current global environmental crisis, the term of the license renewal should be substantially reduced from 50 years to 25 years or less.

Document Accession #: 20220103-5012 Filed Date: 01/03/2022
Judith Phillips, Northfield, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

Dear Commissioners,
I am seeking to comment on First Light’s relicensing bid for the Northfield Mountain Pumped Storage Station on the Connecticut River.

As a Northfield resident I urge FERC in the strongest possible terms to NOT relicense First Light’s Northfield Mountain Pumped Storage facility for another 50 years for the sake of all aquatic life in our beloved Connecticut River ecosystem. The River is in a perilous position with its ecosystem teetering in these “confidential” final license settlement negotiations between Canada-owned First Light and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries that has been taking place during this December. All that has been discussed and ?agreed to? is being done behind closed doors.

I believe these license settlement negations should be moved out into the light of day and into a public forum.

In addition to the pumping station in Northfield adversely impacting our River by wasting energy from fossil fuels that they burn to send water uphill just so it can flow down back into the river which destroys the fish, and more recently First Light is impacting our tax base. Regarding taxes, First Light is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

For me, in the face of the huge environmental crisis we all are in and the current environmental damage that is occurring daily from the Northfield Mountain Pumped Storage Station, for FERC to renew a 50-year license to First Light’s outdated pumping station should be unthinkable! Further I believe this ancient energy provider, is the exact opposite of sustainability both energetically and ecologically and needs to stop now!

Laura Doughty, Wendell, MA summarized it well.
“If we are to have any chance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It isridiculous to let this corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.”

Please DO NOT relicense the Northfield Mountain Pumped Storage facility for the people and the environment upon which we depend for our continuing survival.

Judith Phillips
482 Orange Road
Northfield, MA

Document Accession #: 20220103-5013 Filed Date: 01/03/2022
Priscilla Lynch, Conway, MA.

I am writing to express my strong opposition to the renewal of FirstLight’s license to operate the Northfield Mountain Pumped Storage Station on the Connecticut River in Northfield, Ma. It is way past time to cease this destructive assault on our environment, the river and its ecosystems. As you know I am sure, this facility uses power from the grid to pull the river’s water back and up the mountain to be released at peak times at peak prices. In the process it churns, chops and spits out fish and other essential aquatic life. At a time when our very best efforts should be to heal and preserve our waters and ecosystems as a means to ensure the very survival of life on earth, it is irresponsible to continue operation of this facility. FirstLight does not offer solutions or healing to our environment. It is foreign corporation making a great deal of money on losses to our environment and our well being. Please consider it your duty to act responsibility and do not renew FirstLight’s license to operate the Northfield Mountain Pumped Storage Station. As public servants, doing so will be doing immense good for those you are intended to serve. By not doing so, you will continue unnecessary extreme environmental damage and loss and will continue to feed the pockets of a foreign corporation at the expense of those you are intended to serve.

Priscilla Lynch
Conway, MA.

BE HEARD!! NOW IS THE TIME to enter on-the-record testimony into the Federal Energy Regulatory Commission’s public licensing process.

HERE’S HOW:

Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

CONNECTICUT RIVER: maybe not left for DEAD after all

Posted by on 04 May 2021 | Tagged as: American shad, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, CRC, Daniel McKiernan: Director MA Division of Marine Fisheries, Delaware LLC, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Julie Crocker, Kathleen Theoharides, MA Division of Fish and Wildlife, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Ron Amidon: Commissioner MA Dept. of Fish and Game, Source to Sea Cleanup, State of Delaware, The Greenfield Recorder, Traprock Center for Peace and Justice, US Fish & Wildlife Service, USFWS, Wendi Weber

CONNECTICUT RIVER: maybe not left for DEAD after all

Following the Great Earth Week Walk for River Survival to the Northfield Mountain Pumped Storage Project on April 24th, it’s been inspiring to see people publicly raising their voices to pull the grim, daily carnage of that power-hungry machine out from the shadows. One of particular insight was written by Susan Olmsted and appeared in The Recorder on April 30:
https://www.recorder.com/my-turn-olmsted-NorthfieldHydroStation-40211638 . Later, Ms. Olmsted relayed those same points into the public record of Federal Energy Regulatory Commission’s relicensing comments for the Northfield docket: FERC P-2485. Those are the routes to raising the public profile of our endlessly crippled River—its fate all but buried under confidentiality agreements and generations of inaction by the responsible agencies and so-called protectors. They all continue to lay low in a process that will decide our river’s ultimate viability for decades.


At the NMPS Intake. Photo Copyright © 2021 by James Smethurst

I again must thank the Traprock Center for Peace and Justice and Anna Gyorgy for organizing the event. Having written about this broken river for decades, and now having served on the Fish and Aquatics Study Team in this endless FERC process since 2012, it was an honor to speak up for the river with a caring and determined crowd in attendance. As I’ve noted to several people, last October I witnessed MA Energy Secretary Kathleen Theoharides and Watershed Council/Conservancy Director Andy Fisk launch a PR canoe tour for elected officials–directly upstream of the killer suction pipes of Northfield. In grim, self-serving fashion neither stepped up to the TV cameras or spoke with attendant reporters to proclaim, “This thing is our river’s greatest killer, it should be closed; this company, FirstLight, wholly re-registered these holdings out of state into Delaware as tax shelters two years back—they have no business here.” Shame on them both.

Watershed Council/CRC Director Andy Fisk, in vest, Chairs the Connecticut River Atlantic Salmon Commission 12/10/2018

BTW, we spoke at some depth on the Walk about the NU/Eversource building-of, and current massive connections to NMPS–and also the long-standing financial and Source to Sea greenwashing links between the Watershed Council/Conservancy and Eversource? Well, here’s a little late-breaking Eversource monopoly news: https://www.eenews.net/stories/1063731537

Personally, I would feel I’d failed our Great River, this ecosystem and coming generations had I never stood in front of this killer to bear witness to the truth. NMPS is a killer, and no configuration that leaves its grim sucking mouth open for ANY part of the year will retrieve it from being the most lethal machine ever deployed on the Connecticut. After so many years I am grateful that I had that opportunity–to stand up with other people and keep faith with our river–and link with those who will depend on its living waters in the future.


Revival Walk Crowd April 24, 2021 Photo Copyright © 2021 by David Keith

I don’t think a single person in attendance that day believes the snake-oil logic for continuing NMPS: that wasting massive amounts of energy to actually pull a river backward for miles–sucking 100s of millions of fish to their deaths as it wrenches its deadened water up a mountain, will ever be any kind energy “clean” or “green” solution on a heating-up planet whose ecosystems are unraveling. FirstLight’s will merely continue the laying-waste to our long-crippled river. It has nourished life here for millennia; they want to trade that in for their few hours of peak-priced energy.


MA Secretary of Energy & Environmental Affairs Kathleen Theoharides talks to the media–just yards away from Northfield’s deadly intake on a fluff PR tour on the river, October 2020. Photo Copyright © 2021 by Karl Meyer

It’s important to remember that this machine’s emplacement ran counter to one of the most significant landmark environmental decisions ever from the US Supreme Court, centered right here on the Connecticut River in 1872. In Holyoke Company v. Lyman the Court decided private operators of dams and facilities on the Connecticut—and thence, for all rivers, must provide safe upstream and downstream passage for migratory fish. Nearly 150 years later, this machine continues crushing millions of migratory fish—among them federal trust American shad, blueback herring and American eels. That killing occurs for eggs, larvae, juveniles and adult fish across the many months of their full migratory life cycles.

With the presence of a real watchdog, NMPS’s illegal presence never would have arisen here. There were decades to have sued for its shutdown. Today, neither its operation–nor FirstLight’s thin mitigation proposal to put up a partial, temporary net across its mouth annually that might spare some adult shad and eels from its suction just two months out of their killing year, even remotely passes the smell test for legal operation in a US Fish & Wildlife Refuge.

Raising public voices and flushing the buried dealings in this race-to-the-bottom FERC relicensing process is now the key to having some real impact in saving the Connecticut.

This Great River still feeds bodies and souls. It’s been struggling for well over half a century without an entity taking on the necessary mandate to “enforce” and take on the employ of a day-to-day legal team worthy of facing down predator corporations. This is an ecosystem destined to failure if citizens stay on the sidelines. But people are getting it; and standing up. Maybe this critical life-line of a river can be revived for the coming half century, to again nourish those of the future.

WORTH NOTING: Massachusetts and federal agency officials responsible for securing a living Connecticut River for your great, great, grand kids–upstream and down, through to Vermont and New Hampshire:

Kathleen Theoharides: Sec. of MA Energy & Environmental Affairs
Martin Suuberg: Commissioner MA Department of Environmental Protection
Ron Amidon: Commissioner MA Dept. of Fish & Game
Daniel McKiernan: Director MA Division of Marine Fisheries
Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA (endangered CT River shortnose sturgeon habitat)

ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

Posted by on 10 Sep 2020 | Tagged as: American shad, Anadromous Fish Conservation Act, Atlantic salmon, blueback herring, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power Resources, Fish and Aquatics Study Team, GHG, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, right-to-know, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Revelator, The Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

Endgame Looms for England’s Great River Copyright © 2020 by Karl Meyer


The impoverished Connecticut River looking downstream to Turners Falls Dam. The run stops here. Photo Copyright © 2020 by Karl Meyer All Rights Reserved. (CLICK x 3 to enlarge)

NOTE: The following piece first appeared as an Op-Ed in The Revelator, an initiative of the Center for Biological Diversity on August 26, 2020. www.therevelator.org

FURTHER NOTE: * On September 1, 2020, after this piece first appeared, FirstLight petitioned FERC for an open-ended date to extend the filing of their Final License Applications citing a need for new test data to respond to the USF&WS. If FERC agrees, that would add another 4 months and possibly another full year, to this endless process–without any long-awaited relief for a flow starved Connecticut River. It’s time for FERC to wrap this up.

After a half-century of failures, the recovery of the Connecticut River ecosystem hangs in the balance. Will authorities finally act to save it?

Rivers should not die in the dark.

On Aug. 31 FirstLight Power Resources is expected to file its final license applications with the Federal Energy Regulatory Commission to continue operating three hydro facilities profiting off massive water diversions from the Connecticut River in Massachusetts. The conditions written into FERC licenses can last up to 50 years.

These applications signal the beginning of the final chapter in determining the future of the four-state river at the heart of the Silvio O. Conte National Fish and Wildlife Refuge, founded to protect a 7.2-million-acre watershed. Their rendering will decide the future of migratory fish, river flows and a host of embattled ecosystem conditions on New England’s longest river, some running counter to laws in place since 1872.

When decisions affecting a river for decades are being made, the public has a right to know of the stakes, the players and the key decision makers. In this case the public knows little of issues potentially affecting 2.4 million people in a sprawling watershed.

One of the failed fish ladders sending all spring migrants into the Turners Falls power canal maize. Across 45 years just 5 shad in 100 have succeeded in passing the Turners Falls Dam–leaving 50 miles of spawning habitat in 3 states largely empty. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife have been at the table in this FERC license-determining process since 2012. But three years back, all parties signed nondisclosure agreements with FirstLight — ostensibly to facilitate settlement discussions on flows, habitat, dismal fish passage and endless mortality cycles at these Massachusetts hydro sites. Those NDAs have kept these issues largely out of the media, even as initial settlement talks broke off a year and a half ago.

*Since 2012 I’ve been a FERC-recognized intervener in the relicensing process. I chose not to sign the company’s confidentiality agreement in order to preserve the right to address and highlight the critical, long-term decisions being made about the Connecticut River in a process that remains largely out of public view.

FirstLight is part of the giant Canadian investment outfit PSP Investments, which arrived in Massachusetts four years back to buy up these facilities from GDF Suez. In 2018 it quickly reregistered the facilities as limited liability tax shelters in Delaware. Regardless of their state of incorporation, the licenses they now vie for will each be subject to current federal and state environmental laws, under terms mandated by the fish agencies and FERC.

Entranceway to the “Great Falls Discovery Center” where, most days out of the year, there are literally no great falls running here at all… The sprawling rocky riverbed is an emptied bowl. Photo Copyright © 2020 by Karl Meyer.

Of more than 500 U.S. refuges, Conte is one of just three with “fish” in its name. Today hopes for the long-term protections of its fish and the river comprising its central artery rest heavily in the hands of the U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife. They have “conditioning authority” in these relicensings — mandates to protect the life in this river system. FERC, the ultimate relicensing umpire here, is also mandated to ensure compliance with environmental laws. For the fish agencies this is their one chance to redeem some far-reaching mistakes made by their predecessors.

Forty-five years ago these agencies — operating on limited information and pursuing dreams of reprising a salmon not seen on this river since 1809 — signed agreements with different owners of these facilities. That hobbled, for generations, a four-state migratory fisheries restoration for American shad and river herring and a recovery for federally endangered shortnose sturgeon. They sanctioned the daily use of the massive river-reversing pumped storage facility still chewing through generations of migratory and resident fish today. Concurrently they left two miles of the river emptied downstream, its flow diverted into a turbine-lined power canal that all migrants must negotiate in order to access the next 50 miles of open spawning habitat. Just 5 shad in 100 have ever succeeded. Perhaps worse, the river’s only documented natural spawning habitat for the endangered shortnose sturgeon was left without life-sustaining flow.

A Tale of Two Salmon, a River Without Fish

The last wild salmon run on the Connecticut River was recorded in 1809.

Science later revealed the salmons’ end was likely a combination of warming temperatures following the unusually cold period known as the Little Ice Age coupled with modern dam building.

For 165 years there were no salmon. Then, in 1974, a single fish arrived at Holyoke Dam. Far from being a native of the Connecticut River, this was a new hybrid — a returning fish produced at one of several federal hatcheries completed five years prior. This salmon’s genes, like the genes of all the fish that would return in subsequent years, were cobbled together using salmon from several still-surviving runs in northern New England.

This past June 30 marked a different milestone on the river. It ended the first season in 46 years when not a single hatchery-derived Atlantic salmon returned past Massachusetts’ Holyoke Dam.

That unnatural history event passed with little fanfare. Its silent-spring absence marked the end of a half-century-old program that consumed hundreds of millions of dollars and ate up far too much room in a badly broken ecosystem. The U.S. Fish and Wildlife Service abandoned its hatchery program at the end of the 2012 migration season, but across its 43 years — which saw the annual release of millions of fry and smolts to tributaries in Connecticut, Massachusetts, Vermont and New Hampshire — so few adults returned that no one was ever allowed to catch one.

This second salmon ending highlights the fish agencies’ last shot at returning ancient ocean connections to the river’s still-viable, age-old runs of American shad, blueback herring and federally endangered shortnose sturgeon in three states.

All these species have been guaranteed safe passage on U.S. rivers, going back to the landmark Supreme Court decision in Holyoke Company v. Lyman in 1872. That finding centered on the dam in Holyoke, Massachusetts and held that private dam owners operating on U.S. rivers must provide for the free movement, upstream and down, of migratory fish past their facilities.

Looking west across the CT to the Holyoke Dam fish lift complex. Since 1955 it is one of the East Coast’s few fish passage successes. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Its implementation on New England’s river is now 148 years overdue.

A River Run in Reverse

What’s ultimately at issue here is flow.

Having taken a back seat for generations, wild runs of shad, herring and sturgeon remain in desperate need of passage and consistent, exponentially increased river flow in FirstLight’s hydro-complex dominated reach. It’s literally the weight of water that matters most to FirstLight. It’s money in the bank. And where flow diversion is concerned, it’s been pretty much a free ride for companies here for the past 50 years.

The 20 miles of river backed up into Vermont and New Hampshire behind Turners Falls Dam are massively suctioned for hours at up to 15,000 cubic feet per second to fill the 4-billion-gallon reservoir above the Northfield Mountain Pumped Storage Station.

Northfield’s suction is so violent it literally reverses the Connecticut’s current for up to a mile downstream at times, erasing the essence of a living river system. The station kills everything it sucks in, from tiny fish eggs to full-size eels. In pumping mode it suctions the equivalent of 3,600 seven-bedroom mansions, each filled with the aquatic life of a river, vaporized every hour, for hours on end. Agency studies on America shad show tens of millions of eggs and larvae extinguished at Northfield annually, plus the deaths of over 2 million juvenile shad sucked in on migrations back to the sea. Five migrant species are subjected to Northfield. In all 24 species live here, most unstudied.

Warning floats on the CT at the entranceway to Northfield Mountain Pumped Storage Station’s massive subsurface suctioning site. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Northfield’s operations are nothing like classic hydro, operating to produce virgin electricity via a dam in or adjacent to a river. It’s actually an electric appliance, built to take advantage of excess, unused megawatts produced nightly at the nearby Vermont Yankee nuclear station. Northfield burns electricity to pump water from the river a mile uphill to into its reservoir tank, which was created by blasting off the top of a mountain. The company’s original owners would buy up Vermont Yankee’s cheap electricity to power its giant, reversible turbines. Later, during peak energy times, that now-lifeless river water would get sent back through the turbines to generate hours-long pulses of energy at peak market prices.

It’s a buy-low, sell-high operation, still running at the expense of a river system six years after Vermont Yankee shut down.

Idle bulldozers sit in the emptied bed of the giant NMPS reservoir on June 27, 2010–the year they broke their giant appliance by fouling the pumps with muck and silt. Sanctioned by the EPA for a cover-up and massively dumping the muck from their mile-long intake tunnel directly into the river, Northfield didn’t operate for over half a year. Photo Copyright © 2020 by Karl Meyer. All Rights Reserved. (Click x3 to enlarge.)

Northfield is a net-loss energy machine — a giant underground appliance consuming massive amounts of grid electricity, half of it now generated by the climate-scorching natural gas that dominates New England’s power grid today. The station consumes 25% to 33% more juice than the secondhand megawatts it sends back by dumping deadened river water back through its turbines. It and a smaller pumped storage station in Connecticut are responsible for gobbling up 1.4% percent of the region’s energy in order to reproduce the few hours of secondhand juice they regenerate. According to grid operator ISO-New England, they are the only facilities whose operations flush out as negative input in the regional power mix.

Northfield has never generated a single watt of its own electricity. And though it may be fine as blunt instrument for use during the occasional power grid slump or rare emergency blackout, its endless, river-crippling, pump-and-purge cycle of regenerated megawatts is unnecessary for the daily operation of the New England grid. While its owners brag of being able to power a million homes for a few hours, they never mention having already burned through the energy of 1.25 million homes to do so. After its daily flush, Northfield is virtually dead in the water and must begin pulling from the grid and sucking life from the river all over.

Past mistakes not only allowed for this massive upstream disruption, they sanctioned diversion of nearly all flow, as well as all migrating fish, into a downstream power canal that on average just 5% of shad have ever successfully negotiated. That left another two miles of New England’s river dysfunctional, with the company providing just a dribble flow of 400 cubic feet per second in the riverbed in spring, when fish are moving upriver. That riverbed remains emptied of all flow more than half the other days of the year.

The most critical time for sustaining flows and the river’s migrants is April through June, when New England’s energy consumption is at its low annual ebb. But federal and state studies and in-river findings show that spring flows will need to be increased by a factor of 20, supplying 8,000 cfs rather than the current brook-like drizzle of 400 cfs. That’s what it will take to guide shad and blueback herring upstream in the river past Turners Falls Dam. That will also provide this river’s only endangered migrant the consistent flows required to successfully allow the shortnose sturgeon to spawn and ensure its larvae can develop in the cobbles at an ancient river pool in that impoverished reach.

Flow starved Connecticut River at the Rock Dam–critical shortnose sturgeon spawning and rearing site, May 13, 2018. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Back in 1967, when four New England states and these agencies signed the “Statement of Intent for the Cooperative Fishery Restoration Program for the Connecticut River Basin,” they projected some 38,000 salmon would return annually to this four-state ecosystem. For salmon, a pinnacle of sorts was reached in 1981, when 592 were tallied passing Holyoke. But for a hybrid fish whose wild prototype disappeared 160 years prior, it was downhill from there. Most years fewer than 100 salmon returned to the river.

That 1967 agreement also set annual run targets of one million American shad heading upstream, with 850,000 shad passing Turners Falls and 750,000 entering Vermont and New Hampshire habitats above Vernon Dam. The highest shad return saw 720,000 passing Holyoke in 1992. Sadly, they’ve never made it much farther.

The Run Stops in Massachusetts.

Just 36 miles upstream of Holyoke, all semblance of a successful restoration ends when the annual shad run reaches Turners Falls Dam. Of the 537,000 shad that passed Holyoke in 2017, just 48,000 — a mere 9% — squeezed back into the river beyond Turners Falls.

Vernon Dam between Vernon VT and Hinsdale NH, March 2020. Photo Copyright © 2020 by Karl Meyer

The annual inversion at the next upstream dam in Vermont illustrates the perils on this broken river. In 2017 29,000 or 59% of the shad that survived the miseries of Turners Falls were subsequently counted passing Vernon Dam, 20 miles upriver. That inverted interstate ratio has been the case since 1975, with few shad managing to break out beyond the brutal ecosystem conditions in Massachusetts.

Why the Restoration Failed

The current restoration, congressionally authorized in 1967 and still operating today under the moniker of the Connecticut River Atlantic Salmon Commission, made their biggest blunder in 1975 when they signed off on new license requirements for upstream fish passage. They ultimately chose a design based on hydro project fish ladders on Washington State’s giant Columbia River, known for huge Pacific salmon runs. What got built was a three-ladder fish passage that forced all migrants out of their ancient river highway and into the byzantine maze of the company’s power canal, while leaving two miles of riverbed all but emptied of flow.

Scaled down and put in place at Turners Falls, it worked fine for the program’s few successfully returning hybrid salmon but failed immediately for 95% of the hundreds of thousands of migrating shad. No big run has ever passed that site, leaving three states without their promised bounties. Vermont and New Hampshire remain this river’s shad deserts today.

The Prescription

It’s now 2020. At this late date, corporate re-registrations can’t hide what’s legally required and a half-century overdue on New England’s river. The last opportunity to undo those festering mistakes for the Connecticut now rest in the hands of the National Marine Fisheries Service, U.S. Fish and Wildlife Service and Massachusetts Division of Fish and Wildlife. They are the people’s gatekeepers, mandated to guard the public trust — agencies with the authority to change to the generations-old crippling conditions here in Massachusetts.

Across 45 years of tracking fish runs passing upstream at successive dams on the Connecticut, shad counts have averaged 315,369 at Holyoke, 17,579 at Turners Falls, and just 9,299 at the Vernon Dam in Vermont. But recently long-term federal and state studies on passage and juvenile survival for American shad have led to new minimum benchmarks for fish passage at each dam to ensure the long-term survival of the river’s runs.

Using those findings, the Atlantic States Marine Fisheries Commission, National Marine Fisheries Service, U.S. Fish and Wildlife Service and the four states have formally adopted new Connecticut River fish passage goals. They include annual minimums of 687,000 shad passing Holyoke, 297,000 passing Turners Falls, and 227,000 at Vernon Dam annually. Those federal and state targets are now part of the public record in the current FERC relicensings. Their implementation would also ensure the endangered shortnose sturgeon gets the flows needed to begin its recovery here.

It’s time to return flow to the Connecticut River below Turners Falls. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The time has come for facilities operating and profiting off the life of New England’s river to come into compliance with the laws of the land, including the Supreme Court’s 1872 finding in Holyoke Company v. Lyman, the Anadromous Fish Conservation Act of 1965, the Endangered Species Act of 1973 and a host of others. For the fisheries agencies charged with protecting a river’s bounty, standing up for their implementation is the sole prescription for success in a four-state restoration undertaken when back Lyndon Johnson was president.

By law, by right and by the public trust, the Connecticut River’s time has come.

Karl Meyer has been a member of the Fish & Aquatics Studies Team and an intervener in the Federal Energy Regulatory Commission relicensing process for three Massachusetts facilities on the Connecticut River since 2012. He lives in Greenfield, Massachusetts. Meyer is a member of The Society of Environmental Journalists.

* * FINAL NOTE from the author: if all this history is new and troubling to you it must be considered that: this is the only river in the Northeast with several federal designations that has remained the only major waterway without an independent and effective watchdog–one with a full legal team on staff, and a mandate to investigate, enforce, and go to court. The generations-long mistakes and brutal conditions that have existed here would’ve long ago been challenged in court had there been an effective organization protecting the integrity of this river system. If the Connecticut River is to have a future as a living ecosystem, a new model will have to come into being.

Justice for New England’s Embattled River

Posted by on 22 Mar 2019 | Tagged as: American shad, Anadromous Fish Conservation Act, Bellows Falls, Bellows Falls VT, Cabot Station, Canada, Connecticut River, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, Endangered Species Act, Federal Energy Regulatory Commission, FERC, First Light Hydro Generating Company, FirstLight, Greenfield Recorder, Holyoke Dam, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, PSP Investments, Public Sector Pension Investments, shad, shad fishing, Society of Environmental Journalists, Treasury Board of Canada, Turners Falls, Turners Falls dam, United State Supreme Court, US Fish & Wildlife Service, US Fish and Wildlife Coordination Act, Vermont


Above: FirstLight’s sign along Greenfield Road in Turners Falls MA highlighting their historically combined operations with the Northfield Mountain Pumped Storage Station. Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (CLICK, then click again to enlarge).

NOTE: an edited version of this piece appeared in The Greenfield Recorder on March 20, 2019, www.recorder.com .

Copyright © 2019 by Karl Meyer. All Rights Reserved.

Justice for New England’s Embattled River

In a shockingly-belated move on December 20, 2018, Canada’s FirstLight Hydro Generating Company petitioned the Federal Energy Regulatory Commission for “expedited consideration” of their last minute request to transfer the licenses of its Northfield Mountain and Turners Falls Projects on the Connecticut River into separate LLC holding companies. They further requested the just-minted corporations be substituted as the new license applicants in the ongoing federal hydro relicensing process, begun here in September 2012. FirstLight is wholly owned under the Treasury Board of Canada as Public Sector Pension Investments, a venture capital corporation.

For over half a decade stakeholders including the US Fish & Wildlife Service, the National Marine Fisheries Service, MA Division of Fish & Wildlife, and nearly a dozen assorted stakeholders and town governments have been meeting and negotiating with a single entity, FirstLight Hydro. All have been working toward a FL-requested single new license—one mandating river protections for the synchronized generating operations of Northfield Mountain and Turners Falls/Cabot Station along 10 miles of the Connecticut.

FL’s petition arrived just eight days after they’d quietly reregistered their conjoined operations in the State of Delaware as two separate, new, “limited liability” corporations—asking FERC to substitute their new LLCs as applicants for separate licenses.

FirstLight’s “expedited” request came just two days before stakeholders including the USFWS and National Marine Fisheries Service–agencies with “conditioning authority” in this relicensing, were sidelined by the government shutdown. FL wanted a decision no later than February 28th. Fortunately FERC extended the deadline. A decision is now expected by March 28th.

Turners Falls Dam crippled this ecosystem the day it was completed way back in 1798. Controlled for decades from a room inside the Northfield Mountain, it continues enabling crushing impacts on this four-state ecosystem artery, namesake of the Silvio O. Conte Connecticut River National Fish & Wildlife Refuge. New Englanders have long-awaited their rights to their River. Yet Massachusetts, Vermont and New Hampshire all remain essentially without upstream and downstream fish passage and protections at Northfield and Turners Falls—required of owners of all federally-licensed dams in the United States since the landmark Supreme Court decision in Holyoke Company vs. Lyman since 1872.

That landmark ruling should have dramatically changed conditions here beginning on April 30, 2018, when the current license for the NMPS—controller of Turners Falls dam, expired. But a new license has yet to be signed; and FERC has since extended the current license. Still, any corporation–foreign or domestic, must comply-with protections under the Anadromous Fish Conservation Act, the Endangered Species Act, the US Fish and Wildlife Coordination Act and Clean Water Act, among others.

Results from a Connecticut River study released last June by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated that NMPS’s 2017 operations resulted in losses of some 15 million shad eggs and larvae, plus the deaths of between 1 and 2-1/2 million juvenile shad. That’s for just one species.

NMPS sucks the river’s aquatic life into its turbines for hours at a time at 15,000 cubic feet per second–killing virtually everything it inhales. For two years running, NMPS consumed 33% more virgin power from the grid than it later returned in peak-priced, second-hand bursts. Though it can regenerate pulses of up to 1,100 megawatts for 6-8 hours—once emptied of its deadened reservoir waters, Northfield is virtually dead itself, and must begin sucking new virgin power from the grid, shredding more life.

Recent studies find that 80% percent of the shad tagged in the lower river and later recorded passing Holyoke Dam were again recorded reaching the Turners Falls project, some 35 miles upriver. They were still heading upstream. Holyoke has passed an average of 316,000 shad upstream annually since 1976. During that time, just 1-in-10 shad ever swam beyond the miseries created via Turners Falls Dam. Over 250,000 of this ecosystem’s shad are likely turned away annually on the doorstep to Greenfield, Montague, Gill, Millers Falls, Erving and Northfield—barred from the rest of New England all the way Bellows Falls VT as well.

In 2017, the 2nd biggest shad run ever passed Holyoke Dam: 537,000 edible, catchable fish. Fewer than 49,000 passed Turners Falls.

So perhaps it’s time to remind our Canadian-FirstLight guests—recently reregistered in Delaware, that when they purchased some hardware and hydro assets in Massachusetts nearly three years back, they didn’t purchase New England’s great river. They merely bought rights to lease some of our river’s water until the current federal license expired on April 30, 2018. After that time, how much, how often–and at what cost they might continue to operate via a new leased portion of some our river’s flow would be subject to all the laws and regulations of the United States and those of the Commonwealth of Massachusetts.

Karl Meyer has been a stakeholder and member of the Fish and Aquatics Study Team in the current FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2012. He is a member of the Society of Environmental Journalists.

NOTE: the piece below appeared at www.vtdigger.org in January.

Karl Meyer: Connecticut River dam owners pulling a fast one