By Pass Reach

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AN INSENSITIVITY OF PLACE

Posted by on 29 May 2016 | Tagged as: 5-year FERC licensing process, AMC, American Whitewater, Appalachian Mountain Club, By Pass Reach, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments, Gary Sanderson, Greenfield Recorder, New England FLOW, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, Station 1, The Recorder, Turners Falls, Turners Falls dam, whitewater boating

An Insensitivity of Place

Copyright © 2016 by Karl Meyer (CLICK on any photo to ENLARGE)

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There’s a big difference between theory and practice. So too is there often a huge divide between what is said and what is done—and a giant gap between how you portray your intentions in writing, and how you actually carry yourself in the real world. The difference between those things is what most often turns out to be true.

At the Rock Dam, the endlessly-beleaguered and sole natural spawning site for the state- and federally-endangered shortnose sturgeon in the entire Connecticut River system, that difference came into high resolution last week. While I looked on four people in helmets and safety gear lumbered in a huge blue raft over the tiny, watered notch leading into that self-same shortnose sturgeon spawning pool. Four other decked-out compadres looked on admiringly from atop the low ledge that helped form this little ancient pool thousands of years back.

The “drop” for this joyride might have been a total of 4 feet at best, perhaps a third of the length of the giant boat. For any shortnose sturgeon that might have been using this unique ecological site to accomplish the most basic act of survival—spawning, it would’ve been the equivalent of the Starship Enterprise plopping down atop your kiddy pool party. Basically, party over. But hey, those fish are only the sole federally-endangered migratory species in the entire river. Hope you enjoyed the ridiculously short, half-second rush… Yahoo!

And the real kicker is, they were doing this within the known documented time-window at Rock Dam for shortnose sturgeon to be present and attempting to spawn successfully. This was a Sunday, but the previous Wednesday I’d seen rafts being trailered away from the site in the “Patch” section of Turners Falls. I didn’t quite put it together until Gary Sanderson’s column came out in The Recorder the next day, noting the obtuseness of rafters and kayakers he’d seen repeatedly making the same disrespectful maneuvers at Rock Dam earlier in the week.

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But here’s the theory and practice divide. During the current 5-year Federal Energy Regulatory Commission relicensing hearings for the Turners Falls and Northfield Mountain Pumped Storage projects, these whitewater groups have been at the table advocating for increased flows and access for the public on this short section of river. Chief among these have been American Whitewater and New England FLOW, with the Appalachian Mountain Club partnered with the Connecticut River Watershed Council submitting formal testimony in favor of whitewater boating interests here.

AMC and the Watershed Council in submitted testimony are advocating opening up this most-biologically-damaged stretch of the river for the last half century to increased access at three sites over a tiny reach that is just 2.7 miles long: “Improvements would need to be made to a put-in at the upstream end of the run downstream of Turners Falls dam, the take-out at Poplar Street, and access at No. 1 station and at the Rock Dam.” I wonder how many boats, rafts and cars per mile of river that constitutes.

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All groups in their statements and submitted testimony made reference to their concerns for the protection of aquatic habitats here, as well as adherence to the Clean Water Act in this Dead Reach stretch of the Connecticut that includes the extremely critical spawning habitat of the shortnose sturgeon—which consists solely of the small, semi-circular pool that forms below Rock Dam–along with its tiny little 4 foot drop. Shortnose congregate at Rock Dam for spawning from early April through the end of May. Let’s run giant rafts over them and invite crowds of kayakers to overwhelm the river and rocks here to demonstrate respect and concern for a river struggling for life here these last 50 years.

This is self-interested behavior only a little removed from that of the power companies, and, like the power companies, there is cash waiting in the wings for using the river in this most self-considered way. So, well done, whitewater boating interests! We at least now have a tiny picture of what your practice, rather than theory, might constitute. And, hey, did it ever cross your minds that some people actually consider the Rock Dam a sacred place..?

Shad fishing reported as excellent below Turners Falls

Posted by on 12 May 2015 | Tagged as: 5-year FERC licensing process, American shad, By Pass Reach, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dead Reach, FERC licensing process, Northfield Mountain Pumped Storage Project, Rock Dam, Rock Dam Pool, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized

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After decades of dismal flows and poor fishing, shad anglers immediately below the Turners Falls Dam and downstream at the Rock Dam Pool near the Conte Fish Lab, are reporting some excellent fishing. Federally-mandated test flows to help track migratory fish movement upstream through the Dead Reach of the Connecticut River below Turners Falls Dam commenced last Thursday. By Sunday, three fishermen at the Rock Dam Pool reported excellent catches while the dam was releasing 6,300 CFS (Cubic Feet per Second) the previous few days, though they noted it tailed off slightly when flow from the dam was tamped down to 4,400 CFS on Sunday.

Flow to the Rock Dam Pool, the only documented natural spawning site on the river for the federally-endangered Connecticut River shortnose sturgeon, had been cut to mid-summer levels just a week prior. With the test flows, life-giving water was returned to this abused reach of the river and shad readily followed their ancient river path upstream toward Vermont and New Hampshire spawning waters, without being lured into the treacherous Turners Falls Power Canal at Cabot Station, just downstream.

Those shad, at the current 4,400 CFS test-flow level, are currently being landed just below the Turners Falls Dam, where ecosystem-nourishing flows are being introduced here for the first time in decades as part of the studies for relicensing of the Turners Falls and Northfield Mountain Pumped Storage hydro projects on the public’s river.

The test flows will continue for the next several weeks—which should prove an interesting citizen’s science experiment for anglers who report their catch. Flows at the 4,400 CFS level will continue today, May 12, then will be reduced to 2,500 CFS from Wednesday, May 13, through Friday, and then elevate back up to 6,300 CFS from Saturday, May 16, through Monday, May 18.

New CT River Stakeholder Comments Submitted to FERC

Posted by on 14 Nov 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, FERC, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments/Requests on FERC Projects P-1889 and P-2485, Turners Falls Hydro and Northfield Mountain Pumped Storage were submitted on November 13, 2014 to the Secretary of the Federal Energy Regulatory Commission.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301                                                              November 13, 2014

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

ILP COMMENTS–including: Disagreements/Modifications to Study/Propose New Study on Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process in order to continue plant operations beyond 2018. An Initial Study Report Meeting Summary has been filed by GDF-Suez FirstLight. Please accept these comments on the ISR and my proposals for modifications and new study requirements in the FERC ILP for these projects.

3.3.11 Fish Assemblage Assessment:

Further information/study needed:

FirstLight has declined to undertake any study in the By Pass Reach of the Connecticut River due to stated concerns of interference with spawning and development of embryos of federally endangered shortnose sturgeon in this area. Information from the 2009 EPA study is insufficient to quantify presence and abundance of resident and migratory fish in this reach during critical migration and spawning periods—April through June. That investigation used only 3 sites in the By Pass Reach and was not undertaken to illuminate key species requirements in the current ILP for this critical reach.

NMFS notes that FirstLight has failed to consult with stakeholders on SNS issues here. I am in agreement with USFWS that a dedicated snorkeling, SCUBA, or hookah diving assessment of this critical reach of the four-state CT River be conducted in the riverbed between the Turners Falls Dam and downstream of Cabot Station during the April-June migration and spawning window–and that it continue after FirstLight’s suggested June 30 beginning target date.

I personally snorkeled parts of this reach in May 2013 and found that identification of migrants and resident species was easily attained. An in-situ investigation of this river reach in order to assess species presence and relative abundance is necessary groundwork for making decisions that will impact the 45-year long fisheries restoration on the Connecticut.

Dr. Boyd Kynard, who FirstLight cites in their argument and who spent decades investigating shortnose sturgeon on this reach of the Connecticut told me (personal communication 11/12/2014) that this study method can be accomplished without impacting SNS from the pool below the Rock Dam upstream to the base of Turners Falls Dam.

3.3.12 Evaluate Frequency and Impact of Emergency Water Control Gate Discharge Events and Bypass Flume Events on Shortnose Sturgeon Spawning and Rearing Habitat in the Tailrace and Downstream from Cabot Station.

Further information/study needed: FirstLight has supplied a grid of information for emergency gate and by pass flume openings for the years 2005 – 2012, though 2010 is missing, and we have no information on gate openings and placement for 2011 and 2012 in some instances, other than that there were no instances when greater than 4 emergency flume gates were open.

This study information should be updated with full information for years 2011, 2012—as well as 2013 and 2014 gate opening numbers, placements and CFS information.

Study findings from Kynard and Keiffer, as well as the long-term study of SNS in this reach catalogued in Life History and Behaviour of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Society, 2012, specifically delineate emergency and canal flume gate spill as having a profound and deleterious impact on shortnose sturgeon spawning and early life stage development.

As was stated recently by sturgeon biologist Micah Kieffer at a fall 2014 meeting of the Connecticut River Atlantic Salmon Commission, “one instance” of ramped-up or ramped-down flow from TF dam or emergency spill gate and flume operation can abruptly terminate or abort spawning attempts at Rock Dam and below Cabot Station by federally-endangered SNS for the entire year. Operations of emergency and by pass flume gates on the TF canal also can have deadly parching or burying impacts SNS embryos.

FirstLight contends that its operations of Bypass flume gates above Cabot Station are aimed at either emergency load rejection at Cabot Station, or opened to flush debris. They also contend that it is rare to have more than one flume spill gate open, though most of the numbers belie this statement–and the number of days when 4 or more gates have been open during SNS spawning window is highly significant and impactful. Opening of 4 flume gates needlessly diverts flows approaching 4,000 CFS out of the Connecticut’s By Pass Reach at TF Dam, and sends it into the canal to be needlessly flushed back into the river in a configuration that impacts migratory species and imperils annual spawning attempts of the federally-endangered CT River shortnose sturgeon.

In May 2014, I personally witnessed 3 consecutive days when two or more spill gates were open at the TF canal bypass above Cabot—all at the same time of day: 12:25 pm. These openings occurred while both Station 1 and Cabot were generating, which would appear to indicate that the spill gates had been left in this position for hours, or perhaps days, as part of flow regulation in the canal–rather than emergency or debris clearing. I have sent this information to both FERC and the federal and state fisheries agencies.

It is clear to anyone who examines the TF power canal that it is mostly a lake-like, slow-water habitat, save for the thalweg. It is rare to see debris of any significant size floating in the canal. It gets culled off at the trash racks in front of the TF Gatehouse, or at racks on the canal that dog-leg off to Station 1, or it simply settles out in the lake section of the TF Canal.

The minor amount of small, floating debris that enters the fat part of the canal is culled off by the trash rack skirt above Cabot that steers it to the east side of the canal where a bascule gate can be operated to pass anything of significant size.

The continuous openings of two or more bypass gates, up to six and seven gates open on a “non-emergency” basis on the TF canal above Cabot Station during SNS spawning and early life stage periods threatens the recovery of the Connecticut River’s only federally endangered migratory species.

As I have witnessed, multiple gates open on the canal while both Station 1 and Cabot were in operation indicates that canal flow is at times being regulated at this site, rather than at the TF Gatehouse, where excess flow could be delivered to the river in the Bypass Reach, which would nourish, rather than destroy SNS chances for successful spawning at Rock Dam and below Cabot. During SNS spawning season, mid-April – June 30th, endangered species protections dictate that all flow, save for documented, specific emergency situations, by controlled at the Head Gates of the Turners Falls Dam.

Information for years 2013 and 2014 should further be included, and a Study and study season for 2015 should be implemented that documents both the reason and instances when emergency gates were open—and any flume gates above 1 that were open to vent flow from the canal to the ByPass.

I would also like to FERC to have FirstLight include information for 2010, as the May 4 time of 8-gate emergency spill operation occurred exactly at the time frame when Northfield Mountain had burped up a massive sediment spill into its intake, and was trying to flush that pollution downstream. It would be helpful to know the position of both the Bypass flume gates and the positions of TF Dam headgates and bascule and tainter gates at that juncture—as it most definitely impacted SNS present for spawning that year. This would again offer data on whether the TF canal flows were being regulated via emergency by pass flume operation.

3.3.14 Aquatic Mapping of Turners Falls Impoundment:

Further information/study needed:

If migratory fish targeted for restoration in Northern Massachusetts and Vermont and New Hampshire are to continue to be diverted into the TF Power Canal, where few emerge upstream, then an addition to this study should be conducted: Aquatic Mapping of the Turners Falls Power Canal—as it is technically an extension of the Turners Falls Impoundment, and the public has a right to understand the habitat where their fish get privatized.

3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms

Further information/study needed:

The 2014 Canal Drawdown study was flawed as it occurred over the course of two days, due to an error in spill gate function. Since this is a study of live and dead fish and organisms, as well as the presence of dissolved oxygen, a two-day study time frame represents a flawed evaluation. A night of drying, predation, and fluctuating oxygen presence confounds the results of this work. FirstLight does an annual drawdown of the canal—has down so for decades, thus a mistake at the time of a critical habitat study should corrected by conducting a second year of study.

Further, since FERC has ordered that FL conduct a study of American shad spawning in the TF Canal, it is important to note another anomaly in their canal drawdown work. At five-year intervals the TF Canal receives a full canal muck-out during drawdown. The last one occurred in 2009. This would have been the fifth year—a time when the major muck-out would occur. It did not happen. What occurred was canal “light”, with a large snafu in the middle of the one day study, making it a two day effort. Whether FL agrees that this should have occurred in 2014 or not, a big-dig in the canal is needed regularly, as the sludge, silt and muck settles out and fills in the wide part of the basin.

This must be figured into the “impacts” of the drawdown, as it has profound implications for forcing migratory fish into this habitat, as well as the survival of resident fish and aquatics.

Please see attached photo of the canal muck-out that I took in 2009.

This is the habitat all upstream migrants are diverted into at Turner Falls

This is the habitat all upstream migrants are diverted into at Turner Falls

 

3.3.19 Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement of Migratory Fish to Turners Falls Dam by Avoiding Cabot Station Tailrace

Further information/study needed: the need for this 2016 study will be fully realized if planned studies of American shad movement and spawning in the canal confirm that these fish are experiencing significant migratory delay, and are being coralled into a migratory spawning trap by confused and insurmountable flows or pre-mature warming in artificial habitat that induces spawning in the canal—preventing fisheries restoration on the river in Northern Massachusetts, New Hampshire and Vermont.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Further information/study needed: I concur with FERC’s requirements of an intensive array of radio and telemetry receivers throughout the TF Power Canal to track migrating shad in the canal.

However, I request that FERC require FirstLight, in consultation with stakeholders, add an array temperature monitors calibrated to the radio and telemetry sites to understand whether canal delays for American shad–lingering for an average of 8 days in the TF Canal, are forcing these fish to spawn in this privatized, lake-like habitat because of warmed, shallow, and slow water conditions.

3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of Northfield Mountain and Turners Falls Projects

Further information/study needed:
I concur with FERC that a full spawning study of the Turners Falls Power Canal be conducted in 2015, undertaken in consultation with stakeholders. Temperature monitors should be deployed to assess impact on migratory delay and spawning on-set; and cumulative impacts of head gate and by pass use of spill gates should be factored into the study to determine the impact of silt deposits on spawning success.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

Further information/study needed: In the Initial Study Report Study Meeting Summary for stakeholder in October 2014, a request was made that FirstLight provide vector maps with arrows and indication of directional flow around the Intake and Tailrace Channel at the Northfield Mountain Pumped Storage Project. This is critical information for flow, erosion, and sediment displacement and needs inclusion.

This is information that has been missing on Northfield Mountain Pumped Storage Impacts since at least 1974. See attached at end of document.

Thank you for this opportunity to comment on these critical relicensing issues.

Sincerely,
Karl Meyer, M.S. Environmental Science
Greenfield, MA

1974 attached file below.

 

Kynard,Part II: Fisheries restoration, or a new half-century of death in the TF Power Canal?

Posted by on 06 Aug 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, Dr. Boyd Kynard, ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Station, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

Tune in to Local Bias on Greenfield Community Television, GCTV.org, for Part II of a wide ranging interview with fisheries biologist and US Fish & Wildlife Service Conte Anadromous Fish Research Center founder Dr. Boyd Kynard. He gives direct answers to questions about the fate of the millions of American shad that have been tricked out of the Connecticut River into the deadly and alien habitats of the private Turners Falls Power Canal for the last 35 years.

Dr. Boyd Kynard Part II; a Deadly Canal or a River Migration Solution?

http://mfi.re/watch/pdx5yqvqv7ygzdk/Local_Bias_147.mpg

The current Federal Energy Regulatory Commission Re-licensing process for FirstLight Power’s Turners Fall/Cabot Station and Northfield Mountain Pumped Storage Stations represents the last chance the Connecticut River gets to recover some of its biodiversity, fecundity and ecosystem functions for many decades to come. A second failure by the public agencies charged with protecting the public’s fisheries resources and endangered species will likely close off–forever, the last, best chance to restore New England’s Great River.

Will the federal and state agencies responsible for protecting and guiding the migratory fisheries restoration since 1967 (USFWS, National Marine Fisheries Service, VT, NH, and MA Division of Fish & Wildlife), again steer migratory fish headed upstream to northern MA, VT and NH spawning habitats into a private “roach motel” of deadly hydro blades and muck? Or, will they bring them directly upstream to a fish elevator at the Turners Falls and redeem decades of failure? Get the low-down, and hear about viable alternatives in this half-hour interview.

Tune in to Local Bias this Thursday, August 7 at 9 pm, or on Saturday, August 9th, at 9 pm. The shows repeat at those scheduled times the following week.

New Stakeholder Comments submitted to FERC, re: Shad Spawning Habitat Studies and Fish Assemblage Assessment

Posted by on 19 Jun 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River ecosystem, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, shad, Station 1

The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on June 16, 2014, re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

Karl Meyer, M.S., Environmental Science
85 School Street, # 3
Greenfield, MA 01301 June 16, 2014

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, N.E.
Washington, DC 20426

Stakeholder Comments RE: FERC P-2485-063, and P-1889-081:

These comments pertain to Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

My comments are specific to a Study Plan Determination meeting and consultation that took place at Northfield Mountain on June 3, 2014, to determine proper Study Plan parameters and procedures.

As a Stakeholder who has contributed to these fisheries discussions throughout the FERC process, I was dismayed that notification of this Stakeholder meeting was not sent out until the day before it was to take place. Along with Katie Kennedy, Andrea Donlon, and Don Pugh, I did not receive an email-invitation from FirstLight consultant Chris Tomichek to continue participating in the discussions until 9:15 a.m. on the morning of June 2, 2014—for a meeting that was to take place at 9:00 a.m., June 3, 2014. This is an abrogation of the FERC relicensing process for Stakeholder participation, and once again leaves these legal proceedings open to question. As I was on vacation when the less-than-24-hour-notice was sent, I was not aware that a meeting had taken place until the day after. With notice, I could have participated via teleconference.

I trust that the Notes and Transcript of this June 3rd meeting will be posted on both the FERC and Northfield Mountain relicensing web sites as part of the public record.

As I do not know the content of Stakeholder remarks or positions stated at the June 3, 2014 meeting, it’s possible that some of my comments may reiterate those of others. I will try to be brief, and address areas of my expertise.

My Comments re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects

In response to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard filed a response with FERC on January 28, 2014, stating, “Kieffer and Kynard (2012) have documented a spawning period of 5-17 days during the same 26 day period each year (April 27-May 22). Early life history stages (eggs and larvae) are present in the project area for 20 to 30 days after spawning (Kynard et al. 2012a). So the period when shortnose sturgeon eggs and larvae are present overlaps with the proposed sampling period for shad egg collection. Consequently, the collection of shad eggs may have the potential to impact shortnose sturgeon, and NMFS recommended in its December 2 letter that the study be revised.”

“To address this potential concern, FirstLight proposes to replace shad egg collection efforts, which studies have shown are duplicative of visual observations of shad spawning, with enhanced visual observations and splash counts.”

The best way to determine the presence of shad spawning, habitat and egg deposition in the By Pass Reach is to use both recommended efforts: egg collection and splash counts Using plankton nets to capture eggs and larvae should be employed to determine shad reproduction in the 2 miles of the By Pass Reach. NMFS did not at any time state that this method should not be employed. They merely noted the presence of SNS and their spawning period and egg/larvae deposition schedule.

Dr. Boyd Kynard states that there is no reason that plankton nets cannot be deployed in the channels opposite the islands on the west side of the river while SNS are present at their east-side ancestral Rock Dam spawning site, or the default site adjacent to Cabot Station if inadequate flows at Rock Dam have chased them downstream. Kynard states that this seining can take place all the way up to TF dam without impacting SNS spawning or egg deposition and larvae development. (Personal communication, 6/14/2014) Kynard is available if FL or Kleinschmidt would like to consult with him.

It is noteworthy that my own observations found FirstLight dumping water back into the river from its canal bypass flume above Cabot Station on three consecutive days at 12;25 pm: May 13, 14, and 15—all dates when SNS are potentially in spawning mode in the Connecticut River section known as the By Pass Reach. Station 1 was also operating off the canal at all these times, and the flows emanating from each were similar—though the whitewater flume-dumping off the canal appeared slightly less rigorous than the generation at the Station 1 outfall.

It is obvious from their notes that FL understands the requirements of SNS for successful reproduction. This canal-dumping practice has been noted by Kynard et al, as a flow regime that can abruptly end spawning efforts and bury or strand SNS eggs and larvae.

As suggested, splash counts should be also be done throughout the By Pass Reach. However, river regulation by FirstLight has a profound impact on whether and when shad are present in the By Pass Reach—River Segments 1 – 4 in the Study Plan—just as it impacts SNS.

FirstLight’s proposal to use splash counts to determine spawning should be carefully calibrated with river flows throughout the By Pass Reach. In order to have get a “clean” picture of when and where American shad may use this reach of river for spawning and egg deposition, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace federal trust fish from this river segment.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass from noon on the day the study is to commence until after midnight when spawning tapers off.

It is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flows, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

My Comments re: Study No. 3.3.11 Fish Assemblage Assessment

In his letter responding to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard formally responded to FERC on January 28, 2014, stating: “To avoid any potential impacts to sturgeon, FirstLight proposes to conduct all sampling in the bypass reach after June 30, and in the reach below the Deerfield River, FirstLight proposes to use both existing data and the data it obtains in the Turners Falls Impoundment.”

I will restrict my comments to fish assemblage sampling in the By Pass Reach:

Again, in order for electro-fishing sampling to be effective and get a “clean” picture of when and where resident and migratory fish may use this By Pass Reach of river, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace fish from this reach.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass for a full 24 hour cycle before this study is to commence.

And, again, it is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flow, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

End of Formal Comments

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,
Karl Meyer, M.S.