Commonwealth of Massachusetts

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More Connecticut River citizens’ defense

Posted by on 13 Jan 2022 | Tagged as: America's best landscaped sewer, American shad, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River blog, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, fish kill, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northeast Utilities, Northfield Mountain, Northfield Mountain Pumped Storage Station, NU/WMECO, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Fish & Wildlife Service

THE CONNECTICUT RIVER’S CITIZEN DEFENSE continues:
While FirstLight’s secret January license “settlement” talks continue–centered around leaky net ideas and spit-and-glue window dressing at Northfield Mountain, the public is demanding that its 50 years of devastation cease.

https://www.youtube.com/watch?v=ybwy8MBiy9I
* * NOTE: ABOVE is a link to a Wilbraham Public Library ecology lecture series I was asked to take part in last November. The title of my presentation was: “LIVING RIVERS FLOW DOWNSTREAM.” IT IS A KEY HISTORIC PERSPECTIVE to understanding why we live in a broken ecosystem… * *

https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152

FirstLight led closed-door bargaining with state and federal fish and environment agencies are continuing here in MA, while an ongoing flood of citizen testimony to end Northfield Mountain’s license to kill continues at the Federal Energy Regulatory Commission.

THOSE DEMANDS–from no less than 77 people since November 13th, are also sending a very clear signal to the MA Division of Fish & Wildlife, MA DEP, the US Fish & Wildlife, and National Marine Fisheries Service:

DON’T SELL OUT New England’s Great River for another half-century!

* Read the latest public testimony targeting Northfield lethal ecosystem destruction entered into the FERC record further below.*

BUT FOR THE LONG VIEW, HERE’S A LITTLE ILLUMINATING HISTORY:

Only living rivers flow downstream. But that’s not what you find on the Connecticut River in the Commonwealth of Massachusetts. Here, 150 years after the US Supreme Court guaranteed safe upstream and downstream passage of migratory fish to and from New Hampshire and Vermont—and a full half century after the enacting of the Clean Water Act and Endangered Species Act, the Northfield Mountain Pumped Storage Station continues to chew-through, reverse and obliterate the key living ecosystem functions of New England’s critical central artery here in northern Massachusetts.

The grim prospects of allowing Northfield to be built were widely known by federal and state agencies half a decade before it began its deadly, net-power loss, river-reversing ecosystem damage. Here, from the same agencies that are today’s MA Fish & Wildlife, US Fish & Wildlife Service, and the National Marine Fisheries Service (the entities still publicly responsible for environmental enforcement and river fish protection), are their words from a key, signed, 1967 document:

“Statement of Intent for a Cooperative Fishery Restoration Program for the Connecticut River Basin”

“Based on the present fragmentary data available on the Northfield Pump Storage Project, it appears that this project poses definite limitations to an anadromous fish restoration program. These limitations involve the physical loss of eggs, larvae, and young fish of both anadromous and resident species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water. Studies, designed to minimize the potential adverse effects to fishery resources, should be undertaken in development of the design for the Northfield Pump Storage Project. In related studies, fish screens, barriers and deflectors, and flow regimen must be thoroughly investigated.”

Those agencies’ inaction, their failure to protect–while instead indulging in a massive frenzy to recreate an extirpated salmon hybrid in place of a fish not seen here since 1809, proved disastrous for the river’s still-living fish runs and species in this four-state ecosystem. Today, absurdly, a deadly Northfield Mountain soldiers on, while—50 years later those same agencies dicker with foreign owners over emplacing a new band-aid of a barrier net—one full of holes, upstream of that deadly, river-reversing suction.

In the “library” at the Connecticut River Watershed Council—today’s “Conservancy”, there is a boxed, mid-1960s promotional document from WMECO/Northeast Utilities. NU is today does business as Eversource, the perennial chief sponsor of the Conservancy’s Source to Sea Cleanup. That half-century old box contains a glossy booklet promoting the future construction of a Northfield Mountain Pumped Storage Station. The booklet includes several scenarios and options to premise how of its net-loss power pumping operations might be deployed.

One of them was a glaring red flag for the river, its fish, and an entire ecosystem…

The Watershed Council HQ has a private library within…

THAT SHUTDOWN OPTION, never implemented, was that Northfield’s impacts would be so detrimental to the river and life cycles of its migratory fish that it would have to be shut it down during fish migration season. But here again, no watchdog ever emerged to stand up and fight for a living Connecticut River in Massachusetts. Basically, the only protection ever offered was a net to protect their mythical, teeny, hatchery-bred baby salmon, leaving all the river’s other species to fend for themselves.

Thus Northfield’s gargantuan and lethal water and fish appetite still strangles New England’s four-state ecosystem today. And, half a century later, those same public agencies are allowing a power company to dangle the grim bait of temporary fish barrier net before them once more.

ABOVE IS AN EPA-ORDERED “silt barrier” mandated to be kept in place at FirstLight’s Northfield intake after they were caught flagrantly and clandestinely dumping a mountain of muck directly into the river for over 90 days straight in gross violation of the Clean Water Act. Looking closely, you can see it has FAILED, its anchors useless, and its floats flapping in the breeze along the shoreline downstream of Northfield’s sucking intake. Photo taken 10/2/2010.

Even two years after Northfield came on-line the Federal Power Commission–today’s FERC, still had not been given answers to information they’ requested of WMECO–today’s Eversource, including describing flows on a reversing river. This is a Xeroxed document from FERC:

20010120-0656 FERC PDF (Unofficial) 09/10/2014: January 22, 1974, from the Federal Power Commission to WMECO:

Robert E. Barrett, Jr.,President.
Western Massachusetts Electric Company
West Springfield, Massachusetts 01089

Dear Mr. Barrett:
The Commission staff is presently preparing the Draft Environmental Impact Statement for the Turners Falls Project (No. 1889) and requests the following information:
(1) In the revised Fxhibit W of the application (page 43, second paragraph), reference is made to the continuing resident fish study being conducted in Turners Falls Reservoir. Please provide a copy of the results obtained since the last Progress Report. If the study has not been completed, please indicate the date you expect a report to be available.

(2) In Exhibit W (pages 19, 20, and Figure 5), the conditions expected to produce flow reversals in the Turners Falls ‘Reservoir as a result of Northfield operation were set forth. Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows? Based on operational experience, are there any observed or anticipated changes in the patterns, durations, or velocities of the flows described therein? Your early response in providing this information would be appreciated.
Very truly yours,
Secretary

On October 16, 1974, WMECO’s lawyers finally replied in the negative to the Federal Power Commission’s questions, stating they still had not implemented the required study which would offer answers to questions about the impacts of reversing the flow of the Connecticut:

“Staff also inquired whether the Company had a study on the effect of hydrology caused by the pumping of Northfield Mountain project this year. The Northfield Licensees have not made a formal study but are accumulating data with respect to Pond elevations, flows and other operating data.”

EVERYBODY KNEW 50 YEARS AGO: yet nobody came to the Connecticut’s rescue…

BUT TODAY CITIZENS are standing up for the living river owed future generations. SEE BELOW for the latest entries into the FERC public record…

BUT FIRST, here’s how it can be done:
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.

HERE ARE THE LATEST:

Document Accession #: 20220111-5033 Filed Date: 01/11/2022
Elizabeth J Erickson, Colrain, MA.

As a long time resident of Franklin County I have for a long time been very concerned about the environmental and ecosystem destruction at Northfield mountain because of the power generating plant there. I have been following the research about the decline in fish populations in the Connecticut River nearby because of the turbines and am strongly opposed to the reicensing of the First Light hydropower plant there. I’m actually shocked that the relicensing is even being considered given all that is now known about how destructive the plant is. Please deny any future license of power generation of Northfield Mountain.

thank you,
Elizabeth Erickson
Colrain, Massachusetts

Document Accession #: 20220111-5005 Filed Date: 01/11/2022
John Hoffman, Shelburne Falls, MA.

I am writing to ask that you deny a continuation of the license for FirstLight Hydro Generating Company. The project began as a way to make use of excess power from the Vernon Nuclear Power Plant. That plant is now closed. This license is now simply a vehicle for FirstLight to use its capitol to make a profit.

That profit comes at the expense of the Connecticut River, one of the glories of New England, and the source of outstanding agricultural soils in the Connecticut River valley. Now that we possess a vastly more sophisticated understanding of river ecology, the damage to the river is elaborately documented.

By sucking large volumes of water out of the river and then disgorging them back, the company erodes the river banks which in turn damages water quality. The turbines through which water is sucked destroy aquatic life, from adult fish, to their young and down to their eggs.

This is a primitive way to treat a river. No company in our present era should be allowed to inflict such damage. This river is a part of the commonwealth of Massachusetts. We the citizens ask you to protect the invaluable ecosystem of our preeminent river and deny FirstLight its license.
Future generations will thank you.

Document Accession #: 20220111-5004 Filed Date: 01/11/2022
Molly Freeland, Gill, MA.

To whom it may concern,
I am a resident of Gill Massachusetts and I request that you do not let Northfield Mountain Pump Station renew their license. The pump station is killing all life it sucks up from the river. Millions of fish are dyeing every year, including endangered short nose sturgeon. The pump station causes major erosion in the river banks which then spreads pollution. The pump station is escalating climate change when we need to be looking to renewable energy sources. Please say no to the pump station for our children, grandchildren, all life and the planet.
Sincerely,
Molly Freeland

Document Accession #: 20220111-5002 Filed Date: 01/11/2022
Irma Lorraine Pearson, Greenfield, MA.

If we, residing in the Democratic heart of our country, cannot save the only large river we have, and all the life in it, we are putting our imprimature on the destruction of our planet for the sake of building private fortunes.

The cautionary tale of Midas and his gold works very well here.
Let’s try another path, of freeing the rivers of dams and reversals, and saving 50% of our ecosystem as wilderness.

NO DEAL: amid public opposition FirstLight’s secret Northfield Mountain settlement plans stumble.

Posted by on 10 Jan 2022 | Tagged as: America's best landscaped sewer, American shad, Canada, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Endangered Species Act, EPA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, Nation's best landscaped sewer, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Public Comment period, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, USFWS


NO DEAL: amid public opposition FirstLight’s secret Northfield Mountain settlement plans stumble.

Failing in December to secure a secrecy-shrouded agreement, foreign-owned FL petitions FERC again for what’s now an open-ended “Delay of Action/Extension of Time” request. Thus the opportunity for critical public testimony in FL’s Federal Energy Regulatory relicense bid for Northfield remains WIDE OPEN. (**SEE simple FERC filing instructions at end of post)

As scores of public testimony to end Northfield Mountain’s devastation has poured into the Federal Energy Regulatory Commission of late, secret license deals with federal and state fish and agencies here in Massachusetts continue to elude FirstLight Power. The MA Division of Fish & Wildlife, US Fish & Wildlife, MA DEP and the National Marine Fisheries Service–responsible to the public for protecting the Connecticut’s migratory and resident fish, flows, and water quality under established law, are legally empowered with “conditioning authority” to end the half century of slaughter wrought by Northfield’s deadly suctioning. They currently hold the keys to determining if the Commonwealth hosts New England’s river-reversing, ecosystem grim reaper for more decades to come.

Democracy for coming generations means not leaving our river in the hands of a private corporation for ANOTHER half century.

FirstLight filed their latest FERC delay bid on January 4, 2022, the same day as Ethel White of Easthampton filed her FERC testimony stating, “I write concerning the Northfield, MA hydroelectric plant application for recertification. I strongly request that recertification be denied,” Meanwhile, FirstLight, that same day filed a “Continued Request to Defer Issuance of Notice of Acceptance / Ready for Environmental Analysis” with FERC for their Delaware tax-sheltered MA facilities here. Yet, with this latest delay request it appears they’ve discovered their venture capital plans for the Connecticut River are not being swallowed whole here in New England.

Parent-owned by Canadian venture capital giant PSP Investments, FirstLight has once again punted on deadlines in what has now become a decade long slog to continue the massive predation of the region’s key ecosystem artery, after a full half century. In its own January 4, 2022 filing FirstLight again begged FERC for relief of its own previously promised deadlines: “FirstLight requests that the Commission continue to defer issuance of the REA Notice until after January 31, 2022, to allow the parties to focus on the agreement in principle. If the parties are able to reach an agreement in principle by that time, they will then request that the Commission further defer issuance of the REA Notice to allow for negotiation of a fully developed, binding settlement agreement that the parties would submit to the Commission as an offer of settlement pursuant to 18 C.F.R. § 385.602.” An “REA” is FERC-speak for “ready for environmental analysis.”

In its Final License Application FirstLight’s big bid as a concession for the massive sucking fish kill annually at Northfield was a temporary 1,000 foot net, with ¾ inch mesh, to be deployed from upstream, and angled to near its suction tunnels to deflect some of the 24 species of adult fish from its giant, river-reversing vortex. That is literally a year round open door to the obliteration of 100s of millions of eggs and tiny young of developing migratory American shad and the two dozen resident and migrant species of the river—but in particular the key spawning, rearing and out-migrating months between late May and mid-October…

Importantly in that regard, the window for DEMOCRACY on our Connecticut River remains wide open for citizen to go on the public with FERC, and as well in the region’s media. Of late, literally scores of citizens have done just that, in FERC testimony that Northfield’s devastation must end and no new license be offered to FirstLight.

Below is Ethel White’s full January 4th on-the-record testimony, from the same day FL requested more FERC time for their venture capital plans for New England’s Great River, its life, and the future generations who are all entitled to a living ecosystem.

* * But first, here’s how you can stand up, on-the-record, in this critical time for the Connecticut River’s future:

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.

Document Accession #: 20220104-5000 Filed Date: 01/04/2022
Ethel S. White, Easthampton, MA.

I write concerning the Northfield, MA hydroelectric plant application for recertification. I strongly request that recertification be denied. Your commission’s decisions are key to how we deal with climate change. The vast majority of Americans believe that climate change is one of the top issues of today, if not THE top issue. We are on the brink of losing our planet’s ability to sustain human life, and large hydroelectric plants are not beneficial to rivers, aquatic life, or human existence. The Connecticut River is a vital artery in New England, and losing it to environmental degradation would be a tragedy. I hope the Commission will regulate this particular energy source in the proper way, by closing it down.
Sincerely, Ethel S. White

* * Agency heads and personnel representing the public trust:

wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service; andrew.tittler@sol.doi.gov, lead council at the table for USFWS; melissa_grader@fws.gov, at the table for our migratory fish; julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon); william.mcdavitt@noaa.gov, at the table for our migratory fish; mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife, jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife.