Cabot Station

Archived Posts from this Category

FERC Stakeholder comments: Turner Falls Canal ultrasound study

Posted by on 06 Feb 2016 | Tagged as: American shad, Cabot Station, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, Northfield Mountain Pumped Storage Station, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shad, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
January 28, 2016

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

RE: P-1889 and P-2485, ILP for Turners Falls/Cabot Station and the Northfield Mountain Pumped Storage Project

Dear Secretary Bose,

The following comments pertain to an RSP and failures on the part of FirstLight Hydro Generating Company in following FERC’s SDL on Study 3.3.19 and Study 3.3.2. They were shared with FirstLight’s team and FERC’s Brandon Cherry on January 20, 2016:

As one of the requesters for an ultrasound study at Cabot Station, here are my comments, suggestions and observations for ways to gain the best applicable results from Study 3.3.19-Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.

Unfortunately, FirstLight has not provided Stakeholders with any preliminary findings from the telemetry data gathered in Study 3.3.2, which would be a great help in addressing any changes or improvements needed for a successful 3.3.19 Ultrasound Study.

As stated in their Study Determination Letter under Discussion and Staff Recommendations, FERC was very clear that 3.3.2 information on: (1) “delay,” (2) “bypass flows,” and (3) “effects of Station 1 operations on upstream shad migrations,” be brought over and included in the design recommendations for 3.3.19:

“These evaluation data can be used to inform the methods and design of this study (e.g., ultrasound array design, layout, and placement; array testing at appropriate bypass flows) (section 5.9(b)(6)).”

FERC further stated in their SD Letter to FirstLight, “The amended study 3.3.19 should address stakeholder comments and recommendations. If FirstLight does not adopt a recommendation, FirstLight should provide its reasoning based on project-specific circumstances (e.g. Study 3.3.2 results).”

Revised Study Plan 3.3.19 ignores FERC’s guidance on the inclusion and application of “bypass flows” and “effects of Station 1 operations on upstream shad migrations” in its design. Neither key issue is addressed in their proposal. Bypass flows, which are key to any application of acoustic guidance to keep shad moving upstream in the Bypass, are not included at all. Stakeholders originally requested this Study be done for two years, with bypass flows tested throughout.

Further, the only mention of Station 1 is in a footnote, without any reference to testing its effects “on upstream shad migration operations.” FirstLight merely notes that hourly data on discharges at that site will be included—with no insight on how that data would be applicable if fish are not monitored for migratory delay, with and without flows, emanating from that site.

Since the thrust of the Study is aimed at getting fish up through the Bypass, I question why just three monitoring sites are suggested to be deployed upstream of Cabot Station itself.

• Sonic guidance at Cabot should be deployed in such a way that it encourages upstream movement as much as possible—and avoids biasing fish movements toward downstream retreat. It should also be deployed in a way that, when in ON mode, it also ensonnifies the entrance to Cabot Ladder, as the thrust of the study is to have fish avoid the power canal.

• Ensonification should NOT be engaged in two hour increments, as this would likely be a source of stress and disorientation for fish. Employ the tests in 24 hour cyles, one full day on, one full day off.

• Data should also be provided on the hourly operation and number of gates open at the Emergency Spill Gates off the Canal at Cabot.

• I’d suggest removing the monitor upstream of the mouth of the Deerfield and placing it at the Rock Dam pool, a site where shad–and anglers have a historic presence in the Bypass. The agencies, as well as the anglers, are concerned with finding out where fish gather and stall in this reach on their way northern MA, VT, and NH.

• Another monitor needs to be placed at Station 1, another known fishing site. I interviewed a fisherman there last year with Station 1 running. There were scores of fish visible, treading water in the outflow. He flatly said there are “always shad here” when Station 1 is generating.

• Station 1 should be monitored and switched On and Off in tandem with the Cabot ensonification to highlight impacts, false attraction, drop-backs to Rock Dam and elsewhere, and delays.

• Flow data, hours and number of units in operation, and any interruptions in flow at Station 1 should be included in the Study.

• Several more monitors need to be deployed at the Dam and the Spillway entrance to capture the early, freshet aggregation of fish there—as this is what’s at the core of this study.

• Given that this study will only have one sampling season, it is vitally important that it has enough reach to be applicable for informing a hydro-relicensing that may remain in place for two decades. One month testing and data collection is needed at minimum.

• Further, given the “drop out” rate for handled fish, the number of tagged fish included from FirstLight’s consultants should be doubled to 200, in order to have an acceptable sample entering the project reach.

• Test flows from May 15th through mid-June: two weeks at 5,000 CFS; third week at 4,000 CFS. The final week should be at a minimum of 2,500 CFS—which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 – May 22, in order to not interfere with the spawning of a federally endangered species and be subject to court action. In their response, FL cited “Kynard” et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required throughout the month of June.

Thank you,
Karl Meyer, Fish & Aquatics Study Team

The Great Eddy at Bellows Falls

Posted by on 27 May 2015 | Tagged as: American shad, Bellows Falls, Bellows Falls Fishway, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, GDF-Suez FirstLight, migratory delay, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, power canal studies, Rock Dam, Rock Dam Pool, shad, shad fishing, Station 1, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole

BFallsdam
May, 27, 2015. I happened to be at Bellows Falls High School yesterday, and I took a walk into town and over to the Connecticut River at the now-closed Vilas Bridge. Just downstream of here and pictured above is a place formerly known as the Great Eddy. Here, prior to the completion of the Turners Falls Dam in 1798–the first dam to span the entire Connecticut, historic accounts recall 1,200 shad being pulled from the river at a single haul of the net. This picture was taken a few years ago, my batteries proved exhausted as I stood looking downstream yesterday.

There were two young guys far below, fishing in the shadow of the bridge, just downstream of the Bellows Falls Dam. When I hollered down they said yes, the fishing was good, “A rainbow and some bass.” Thus, today, it is rare for a single shad to reach Bellows Falls, the upstream limit of their historic reach. It is harder still to imagine that this place was once a key part of an ecosystem connected to the OCEAN.

I got a note from John Howard, GDF-Suez FirstLight’s Director of Hydro Compliance on Monday. He assured me that those scores of American shad stalled by false attraction flows roaring down from Station 1 had been worked out and agreed to by the USFWS as part of a flexible test flow grid due to an absence of rain. He’d neglected to forward the new test flow schedule to the Fish and Aquatics Studies Team. I imagine those shad burning up their energies would’ve liked to have had a heads-up as well. Their destination–as is the professed destination of the Connecticut River anadromous fisheries restoration these last 48 years, has been to REACH Bellows Falls, VT, and Walpole, NH.

Head gate flow at the TF Dam today, Wednesday, was again lamb-gentle. Of all the years I’ve witnessed flows pouring out of those head gates in the midst of fish passage season, this is the quietest I’ve ever seen them. Canal head gate flow and power generation from the canal at Station 1 and Cabot Station will all need to be looked at carefully in these studies to tease out any biases. (Click to enlarge photo).P1000457

Meanwhile, there were still shad being taken at The Rock Dam Pool this afternoon. I was headed down the path about 3:30 pm and a guy was walking out with a pole and his two energetic labs. He cautioned the wet dogs to give me a wide birth and I asked how it had been. “Not bad,” he said, “Better this morning.” I took a second look at the gentlemen and said, “Hi Jake, how are you?” “Doing OK, how about you?” Jake was part of the maintenance and grounds crew up at Northfield Mountain under Northeast Utilities when I was working at the Visitor Center some dozen years back.

“You still writing letters?” he asked. “I’m doing what I can.” “Good,” Jake replied, “Give it to ’em. Good luck!” Funny, but I bump into many folks who used to work there and there seems to be little sympathy for the company–or lingering loyalty.

P1000460
When I get down to the Rock Dam Pool three people are angling. The guy here has a shad on the line. Another guy, just a bit upstream toward the dam hooks one two or three minutes later. I head out, continuing downstream by bike. (Click to enlarge)
P1000466
Looking upstream from the deck of the General Pierce Bridge in Montague City, much of the riverbed is exposed due to the low flows. At top, far right, is the outfall and attraction flow at Cabot Station, which is likely to be attracting and capturing a good slug of the migrating fish–steering them out of the river to the ladder that will dump them into the power canal. (Click to enlarge)

Spawning run ride from to Vernon; back to Turners Falls, Rock Dam and Cabot: May 17, 2015

Posted by on 17 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Cabot Station, Connecticut River, Conte, Dead Reach, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC license, FirstLight, Holyoke Fish Lift, New Hampshire, power canal studies, Rock Dam, Rock Dam Pool, sea lamprey, shad, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont, Vernon Dam Fishway

P1000388
The Headgates at Turners Falls Dam sending flow into the power canal were as quiet as I’ve ever seen them this Sunday. There seemed to just be a bit of attraction water for fish looking to get upstream, but no usual frothing rip that is usual with power generation.
P1000401
Downstream at the end of the power canal there was a nearly lake-like stillness as Cabot hydro station seemed to be producing little power.
P1000407
Looking upstream at Cabot hydro station from the bridge at Montague City, there was just a small run of whitewater coming down the spillway at Cabot. Data about these flow manipulations should be available for investigations and study results for the re-licensing
inquiries currently taking place under Federal Energy Regulatory Commission purview. They have significant impacts on fish passage.
P1000395
Three of the lucky anglers fishing Rock Dam today–two are in the boat in background.
P1000397
Rock Dam rocking with anglers and 6,300 cfs of flow.
P1000398
Letting a Rock Dam shad off the hook.

LASTLY, here’s today’s full POST:

Spawning run ride from to Vernon; back to Turners Fall, Rock Dam and Cabot: May 17, 2015

After cycling up Rt. 5 to Brattleboro early today, I headed south along the Connecticut. I was shocked to actually find the gates to Vernon Fishway OPEN! This is something that should be guaranteed to the public—regular, posted hours where the public can view their fish. Let John Rangonese of TransCanada know. There is always at least one pickup parked at the Vernon hydro station, all that’s needed is someone to walk over and open the gate; then close it upon leaving. Self-serve site, no cost involved. Public’s fish; public’s river.

Anyway, in the riot of effervescing current in the Vernon Fishway windows today were literally streams of American shad. They were running upstream like there was romance in the offing. Here, like at Holyoke, fish come directly upriver to the base of the dam. There, attracted by flows released down the short fish ladder at this modest falls, shad quickly find their way past the dam toward Brattleboro, Putney, Bellows Falls, and Walpole, NH. Today they were passing in pods at around 10:00 a.m. There were also a couple of smallmouths lower in the current, as well as one ropey sea lamprey flashing through the bubbles.
P1000387
USFWS tank truck used to transport tagged shad

Here, also, I ran into Steve Leach and his crew, from Normandeau Associates. Using the borrowed US Fish & Wildlife Service tank truck, they were preparing to tag fish and truck them a-ways upstream for fish passage studies connected to TransCanada’s hydro relicensing at Vernon, Bellows Falls, and Wilder. They’d done some previous tagging at Holyoke as well. We chatted a bit about test flows downstream, and the lack of rainfall, and the river’s temperature profile that is rising a bit early. I bid them luck, noting a few anglers fishing below Vernon Fishway—along with a perched bald eagle and a circling osprey.

After stopping to visit friends in Gill, MA, I was on the Turners Falls Bridge just a few minutes after noon. The test flow current is at 6,300 cfs (cubic feet per second) today, and the Connecticut is alive with frothy water across the wide, curving expanse formerly known as Peskeomscut. I look down at four people fishing the quick current along the Spillway Fish Ladder, just downstream of the bascule gate that’s pouring down current. In ten minutes time I watch five shad get hooked—four of them are landed, and one is lost near the waterline.

I get back on my bike and tuck in to the Canalside Rail Trail, scooting under the Turners Falls Bridge. As I come alongside the canal at the Turners Falls Gatehouse I notice that the canal is nearly quiet—almost like a still pond. This rivals the quietest flows I’ve ever seen passing through this site. FirstLight controls the headgates here–and with so few open, the fish coming up through their power canal can get a better shot at passage.

A cynical person might think they were manipulating the canal to make it look like a good industrial conduit for wild fish—especially during tagged-fish tracking surveys during test flows. One also might think this could be done to punch up fish passage numbers for weekend visitors to the TF Fishway—something that has shown up in fish passage tallies there for years. You’d think fish were only interested in migrating on weekends… Nonetheless, after well over a decade of subsidizing federal Conte Lab employees for fish passage studies and structural changes in the Turners Falls Power Canal, they have yet to succeed in passing more shad upstream than passed this site in the 1980s…

Curiously, when I head all the way downstream along the canal to Cabot Hydro Station, and then out on the deck of the General Pierce Bridge in Montague City—it is absolutely true that the TF Canal appears lake-like in its absence of flow, with just a small bit of whitewater bubbling down from its tailrace. Operators have certainly quieted the whole canal system this day.

In between I make a stop at the Rock Dam Pool, where the 6,300 cfs flows have the rocks roiling with lively current, and the anglers reeling in fish, seemingly at will. For the first time ever here I see two men standing and fishing below the Rock Dam’s fall in a motorized Zodiac type craft. Between the boat, the fishers wading out in the Rock Dam Pool, and the people tossing darts from the ledge over the pool, there are nine anglers fishing the site—eight men and a woman.

And the shad are streaming in. In the fifteen minutes I spend there, five fish are brought to shore. When I ask one guy to pause with his catch for a minute while I shoot a photo, he obliges. “How’s it been for you?” I ask. “I can’t seem to make a mistake today—I’ve had two dozen,” he tells me. “Well, I guess you know what you’re doing.” “Hey, I ran the Turners Falls Dam for 8-1/2 years,” he says. I nod, adding, “I guess then you know exactly when it’s time to come down here for shad.”
P1000394

The other great thing that has happened for anglers with these actual flows in the river: almost nobody is relegated to tossing lines in the stillness of the power canal. The anglers and the fish are all in the river.

New Comments to FERC, RE: Turners Falls Fisheries Studies

Posted by on 08 Apr 2015 | Tagged as: 5-year FERC licensing process, American shad, Cabot Station, Connecticut River, Connecticut River shortnose sturgeon, Conte, Dr. Castro-Santos, Dr. Haro, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, MA Division of Fish and Wildlife, Mr. Colton Bridges, New Hampshire, Northfield Mountain Pumped Storage Project, Revised Study Plan, Secretary Kimberly Bose, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont

NOTE: the following comments were submitted to Federal Energy Regulatory Commission Secretary Kimberly Bose respecting FirstLight’s withdrawal from its stated position of using video-monitoring equipment at the Turners Falls Dam’s Spillway Ladder to compile study data and information on aggregations of migrating American shad.

This is information that has been the fisheries restoration’s Black Hole these last forty years. It can only be gathered at this site. However, with the withdrawal of these tools, fisheries agencies and the public will be relying on just a few hundred radio-tagged and tracked fish as substitutes for on-site, real time monitoring of aggregations of what are understood to be perhaps hundreds of thousands of migratory shad. (Comments to FERC were slightly abbreviated due space limits in E-filing.)

Karl Meyer, MS
Greenfield, MA 01301 April 8, 2015

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

Re: P-1889; P-2485

Dear Secretary Bose:

Please accept the following comments in the matter of the hydro-power licensing studies for P-1889, the Turners Falls Project; and P-2485, the Northfield Mountain Pumped Storage Project. These comments focus on changes FirstLight made to the Revised Study Plan. I first aired my objections to these RSP changes at a meeting on March 24, 2015–as a member of the Fisheries and Aquatics Study Team. They highlight a lack of Existing Information and a Need for Additional Information that FirstLight’s RSP revisions will not satisfy.

FirstLight has summarily excised all video monitoring in the vicinity of the Spillway Fishway at the base of Turners Falls Dam—a technique they’d agreed was needed in the initial RSP.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

Study Goals and Objectives: (18CFR; 5.11(d)(1)

“Evaluate attraction, entrance efficiency and internal efficiency of the Spillway Ladder for shad reaching the dam spillway, under a range of conditions.”

FirstLight stated the following in their initial RSP response: (bolded italics below, mine

“Video monitoring will be used for specific study areas such as the Spillway Fishway. Use of video monitoring of the Spillway fishway will provide data on fishway efficiency; shad attempting to pass would be monitored versus only those shad that have been tagged.”

Task 2: Study Design and Methods:

FirstLight then wholly eliminated that key video information gathering technique that would help inform these studies with aggregate numbers of shad reaching the Spillway Entrance, versus only those few tagged fish approaching and passing the Spillway entrance.

From FirstLight’s March 14, 2015 RSP changes distributed to the Fisheries and Aquatics Study Team:

“The study will monitor shad migration within the study area using a combination of active and passive radio techniques and video surveillance.”

This needed information gathering was eliminated by FirstLight despite their description in the initial RSP that this was a proven and inexpensive technology:

“FirstLight proposes to conduct video monitoring using the Delta System commercial series of underwater video camera and lighting manufactured by Ocean Systems Inc. This system was recommended by A. Haro (Conte Lab) and has proven effective at other facilities. Video data will be recorded on a dedicated video recorder (DVR).”

“Video monitoring of the Spillway would add a modest cost to this study.”

As to why gathering information about aggregations of American shad at the Spillway adjacent to Turners Falls Dam is needed at this time–that need was stated in FirstLight’s initial RSP response as well:

“In general, the numbers of tagged fish passing through the Spillway Fishway were too low for vigorous evaluation (Haro and Castro-Santos 2005).”

Information about aggregations of migratory fish moving upstream to the base of Turners Falls Dam and the Spillway has been paltry to nonexistent these last 40 years. In the last 15 years, Dr. Haro and Dr. Castro-Santos of the USGS Conte Lab have focused nearly all their work in FirstLight’s power canal, while the Connecticut River passage route for these federal trust fish has been almost wholly ignored.

As to the huge gap in the information for American shad aggregations at this site, I herein cite expert testimony delivered before Commission members four decades back:

On August 21, 1975, in hearings before the United States Federal Power Commission in Boston, Mr. Colton Bridges, Deputy Director of the Massachusetts Division of Fisheries and Wildlife delivered the following expert testimony on the need for Spillway Fish Passage at the Turners Falls Dam:

To Mr. Bridges: Question: “Would either the Cabot power house fishway or the gatehouse fishway be effective in passing those early arriving shad?”

Answer from Mr. Bridges: “No, because with spill conditions at Turner Falls the major source of attraction water will be coming down river from the Turners Falls Dam and emanating from Cabot Station. Consequently, the conditions that existed at Holyoke with spillway flows limiting fishlift efficiency will prevail at Turners Falls Dam with only a Cabot Station fish passage facility in operation.”

Question: “What, in your opinion, would be the effect of the construction of the proposed fish passage facilities at Turners Falls Dam without the inclusion of the spillway fishway?”

Answer from Mr. Bridges: “Without a spillway fish passage facility, fish approaching Turners Falls during periods of spill will be attracted to the base of the dam and those isolated pools located immediately below it, and be subject to the same conditions that exist below Holyoke without the spillway fish collecting facility, i.e., migration delay and mortality due to lack of flow, increased water temperatures, and decreasing oxygen content.”

Given that, as of this date, FERC is refusing to allow the USFWS any in-situ access for snorkeling to get a general assessment of fish using this passage route to Turners Falls Dam during migration season–and that FERC is further disallowing any seining for fish or shad eggs in this reach due to concerns for endangered shortnose sturgeon, this is the only key place where any new information about Spillway aggregations of shad can be gained. This was stated as a result of FERC internal policy, though NMFS indicated a willingness to consult—and NMFS is the ultimate key-holder in decisions concerning Connecticut River shortnose sturgeon.

Hence, denying the gathering of this needed information at the Spillway effectively limits the public’s understanding of what is happening at this site. Though overall successful fish passage through the Spillway Ladder has proven ineffective these past 30 years, it should not limit the Entranceway as the key place to collect long-absent information on aggregating shad.

These are the early arriving fish that have long been known to be the key migrants–most likely to move upstream to Northern Massachusetts, Vermont and New Hampshire spawning sites on the Connecticut. As of this date, 40 years after Deputy Director Colton Bridges testimony, those fish are still not making it past Turners Falls Dam, and we don’t have the information about their numbers and when, where, and in what flow conditions they gather at the Spillway site.

For these reasons I respectfully request that Spillway video monitoring be returned to the Revised Study Plan for this season–to gather the data that cannot be gained simply by monitoring a few hundred radio-tagged fish.

Thank you.

Sincerely,
Karl Meyer, MS, Member, Fisheries and Aquatics Study Team for P-1889; P-2485

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.