Connecticut River ecosystem

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ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

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

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


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

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

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

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

Rivers should not die in the dark.

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

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

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

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

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

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

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

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

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

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

A Tale of Two Salmon, a River Without Fish

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

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

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

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

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

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

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

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

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

A River Run in Reverse

What’s ultimately at issue here is flow.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Run Stops in Massachusetts.

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

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

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

Why the Restoration Failed

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

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

The Prescription

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

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

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

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

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

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

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

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

A RIVER in HEATSTROKE: A Photo Portrait on July’s Hottest Day

Posted by on 21 Jul 2020 | Tagged as: Clean Water Act, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, FirstLight, Great Falls, Peskeomscutt Island, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab, Vermont

A RIVER in HEATSTROKE: A Photo Portrait on July’s Hottest Day
Story and pictures Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

The above photo of the “Great Falls” at Turners Falls was taken at approximately 6:45 am, on July 19, 2020, the hottest day on a boiling-out planet this year. The riverbed below was simply left to bake in this reach until just after 4 pm. (CLICK x 3 to enlarge; BACK ARROW to return)
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

I continued downstream on this, the most critical and imperiled reach in the entire Silvio O. Conte National Fish & Wildlife Refuge, through the two desperate miles of abused river channal, all the way to the Rock Dam, critical spawning site for the federally endangered Connecticut River shortnose sturgeon.

Locked-down river, starved in front of the “tainter gates” on the Gill side of the river. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The stilled-water graveyard, just downstream of the TF Dam on the Gill side of the Connecticut. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Starving, de-oxygenated river on the Turner Falls side, looking downstream, with Peskeomscutt Island–now, no longer an island, de-watered and attached by tilted shales to the land. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


The entire flow of the Connecticut (save for a dribble of 125 cubic feet per second mandated to enter from a chute 100 feet downstream of the dam to keep shortnose sturgeon from stranding and dying in the baking pools) is shunted into the muck and sludge accumulating Turners Falls power canal. Pictured here, the canal downstream adjacent to Cabot Woods, back in 2009, the last time it was mucked out by the heavy machinery pictured. (Click x3)
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


Here is the same area, pictured above, with the shunted Connecticut flow moving listlessly by the sludge-catching silt banks on the morning of July 19, 2020. This is the canal and just part of the grim habitats that ALL migratory fish must must face before emerging upstream of Turners Falls Dam. USGS Conte Fish Lab is visible in the background. Few fish ever manage to survive the puzzled and emerge to spawn in wide open upstream habitats stretching beyond Bellows Falls VT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Another look from a similar vantage with the Fish Lab in the background and a grim canal substituted for a living river. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


View from the opposite side–from the rail trail, July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And, lastly, just some of the Campbell’s Tomato Soup-looking sludge bleeding down FirstLight’s failing riverbanks at Cabot Woods–adjacent to their sludge-choked canal, and into the endangered shortnose sturgeon’s Rock Dam spawning site and nursery for developing young on July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


A closer look, 07/19/2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And another, 07/19/2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED


And, just yards away, the slurry connection–where the grim soup enters the most critically endangered site in the entire river ecosystem: the Rock Dam, on July 19, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

That riverbank soup was already assaulting Rock Dam habitats back in September 2019. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Ten months has passed since this photo was taken. The banks continue to fail, the site continues to be assaulted through pollution, and outright neglect and flaunting a ESA protections.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED

Honoring Peskeomscut

Posted by on 18 May 2020 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Deerfield River, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, fish passage, Holyoke Dam, Narragansett, Nipmuck, Norwottuck, Peskeomscut, Pocumtuck, Relicensing, Riverside, sea lamprey, shad, The Dead Reach, Turners Falls dam, Turners Falls Massacre, Uncategorized

THIS GREAT AND BROKEN RIVER IV

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 4: Honoring Peskeomscut


Peskeomscut, Island?
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge; back arrow to return to text)

At a glance, this could be a photo of a quiet pond in New England. It is not. This is the mid-May, midstream view of an island in the Connecticut River, just 250 yards below the Turners Falls Dam in Massachusetts. With a quick look you might be wondering: where’s the river—and, what island?? This is a chasm and landscape robbed of its water, life and dignity. On any mid-spring day for ages past, thousands of American shad would’ve been pulsing through the rolling froth on both sides of what is a now-erased and bereft island. Today, shad here are not even offered a decent puddle to flop in.

Glancing quickly, you might not have made note of an island. But a closer look reveals a small, tree festooned bump in the center-right background. That site was identified by FirstLight Power as PesKeomscut Island in their initial 2012 application for a new federal hydro license to operate Turners Fall Dam—which is just out of view to the right of this photo. Unfortunately, Turners Falls Dam has been the place where New England’s Great River has died for well over two centuries now.

As far as any real river here?—there’s a just-visible bridge in the upper right, beneath which the mouth of the Fall River is adding a little flow and a tiny bit of froth to the barely-running current in the background. What should be the strong, rolling pulse of the spring Connecticut here should to be pushing downstream from left to right across the entire foreground of this photo. Instead, there’s just a stilled pond. And, yes, that island has been virtually erased. To be an island, you must have water.

On this May 14, 2020, FirstLight has subtracted that main ingredient. At mid-afternoon the Connecticut has been turned off in its own 200 million year-old chasm, robbed of all but a riverlet of dribbling flow. They do that most months out of the year. This spring day all but a tiny percentage of its life-giving current is diverted into FL’s adjacent power canal. The Connecticut is broken here at a place once called Peskeomscut–broken since the first dam stretched across this ancient chasm from Turners Falls to Gill in 1798. That began the 2-1/2 mile reach just downstream that robbed the river of life and flow. It gave rise to a landlocked “island” without a watery moat.

Further out and to the left in the photo, two more humans engage in a leisurely stroll over exposed sand—mid-river at mid-spring, padding over a dry shoal that should be teeming with river life at this season. But not here; not in northern Massachusetts. The place is a desert.

Instead of a life-giving, roaring spring cataract–encircling an inaccessible island, just a salutary wash of water is spilling from the dam above. Peskeomscut Island has been reduced to an abandoned, rocky spit in a parching, emptied chasm.

Looking closely, lower left of center you can make out an angler at the quiet, current-less shore. He might as well be on a pond—migrating American shad won’t find an upstream current deep or strong enough to follow their ancient migratory path toward the lost waterfalls here this day. While downstream, Holyoke Dam had reported 10,000 shad passing there through May 8, Turners Falls Dam had a whopping 38 passing here…

Peskeomscut is an approximate spelling of an Algonquian term used to denote the place where an ancient waterfall, cataract and island anchored the landscape. That place, which teemed with life throughout its annual seasonal cycles back into the mists of time, is today robbed of its soul–deprived of dignity. What, in 2020, should be a restored, thriving, May Connecticut River–full of shad, herring, lamprey eels and frothing currents, is today a drying, emptied bed. Its “island” is simply a rocky spit, easily accessible across the barren, bedrock ledge.


Midstream Peskeomscut 1-1-2018 (Click X 3 to enlarge)
Photo Copyright © 2020 by Karl Meyer

There is more than a little irony to this site being referenced today in Massachusetts as Turners Falls or the Great Falls. Any visitor here would more than likely find this curving, ancient chasm hollowed out at nearly any month of the year. There rarely are falls to see here. This is a broken place, a starved place. There is something raw and enduring about the injuries perpetrated here year in and year out. The once abundant life of this place is merely an afterthought here, if considered at all.

From Turners Falls Dam downstream to just above the river’s confluence with the Deerfield River, these 2-1/2 miles of the Connecticut are best described as its “Dead Reach.” There is no river in this stretch, just a parching/choking series of on-off flows that alternately starve and inundate what was once a life-filled artery.

In the spring of 2020, this should not be. It should all be the past history of the Great River. The current 52 year-old Federal Energy Regulatory Commission license to operate Turners Falls Dam expired in 2018. But FERC has allowed repeated extensions of that license, in a so-called “5-year” relicensing process that began in 2012. This stilted, corporate-skewed federal process has seen virtually no forward movement for over a year–and will soon be celebrating its 8th birthday. That stale status quo seems to suit FERC and FirstLight–as well as their shareholders, quite nicely. It’s just another abuse in the ongoing nightmare for the central artery of Western New England’s largest ecosystem.

On May 19, 2004, I witnessed a reconciliation ceremony at a park in Montague adjacent to the Connecticut, just above Turners Falls Dam. Local officials, citizens, and representatives from several of the region’s Native American tribes were present. All were there to honor, and attempt to heal the lingering injuries and moldering legacy of a grim injustice committed here in the pre-dawn dark on the morning of May 19, 1676.


Turners Falls Dam and Riverside Massacre Site
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge, back arrow to return to text)

Just across the river in the Riverside flats of Gill, 160 colonial troops swept down a hillside, firing muskets and stabbing bayonets into the tents of sleeping elders, women, and children of the Narragansett, Nipmuck and Pocumtuck and other peoples—encamped there in a hungry and desperate attempt to harvest fish and plant sustaining corn in their ongoing attempt to defend and keep the territories of their ancient homelands. For the colonists, it was a grim and successful slaughter of hundreds of defenseless Indians. For the indigenous tribes, though their surprise counter attack quickly sent the blood-bathed attackers into a chaotic, F-Troop rout, the loss of life ultimately proved a spirit and soul crushing disaster.

On this May 19th, 2020, much of the signaled healing and reconciliation of 16 years back seems to remain orphaned on the 344th anniversary of the Turners Falls Massacre. The wounds of that day are yet present. And, the later and ongoing theft of a river’s life-giving current–begun with that 1798 dam, still remains in place. The Connecticut here is–most days, an emptied and soulless place. It is long past time for the life and lives lost at Peskeomscut–and some of what is still missing as well, to see the beginning of a long overdue restoration. The river belongs to the people. Some of that healing must begin with water. Water is where life begins…

Issue # 3: The River Emptied at Spring

Posted by on 13 May 2020 | Tagged as: American shad, Bellows Falls VT, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight, Greenfield Recorder, Holyoke Dam, Holyoke Fish Lift, migratory fish, Narragansett, Nipmuck, Northfield Mountain, Norwottuck, Pocumtuck, Rock Dam, Rock Dam Pool, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turner Falls Massacre, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Walpole

THIS GREAT AND BROKEN RIVER III

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 3: The River Emptied at Spring

Dismal Mother’s Day flow at Turner’s Falls Dam and Fishway Copyright © 2020 by Karl Meyer (Click X 3 for closeup, click back arrow to return to text)

It was a grim Mother’s Day weekend for the Connecticut River in Massachusetts. The only current left in the riverbed below Turners Falls Dam amounted to little more than a thin, spreading soup winding a shallow path around successive ridges of drying ledge as it threaded together a downstream path along it’s ancient, impoverished bed. Anyone with a pair of rubber boots could’ve easily walked across the Connecticut just a few hundred feet below that dam without much risk of getting wet to the knees–smack in the middle of fish migration and spawning season in the heart of the Silvio O. Conte Connecticut River National Fish and Wildlife Refuge.

There’s something soulless in starving a river of its flow—particularly in the spring when the shadbush is in bloom, the columbine have sprouted, and the fish are in the river. This year, with the corona virus draining spirits and sapping energy during March and April, the presence of a living river in Western New England’s back yard was something to anticipate come May. The light returned, the trees were in flower, birds were making music, and energy use was in its usual seasonal retreat—demand being down ever since a warmer than normal winter.


Days Earlier Flow over Turners Falls Dam May 5, 2020 Copyright © 2020 by Karl Meyer (Click X 3, back arrow to return to text)

This should have been a promising early May on New England’s Great River. But no–not here in northern Massachusetts–not this Mother’s Day weekend. For migrating American shad seeking a route upstream here, the river was literally a road to nowhere. As of Monday, May 11th, though some 18,000 shad had passed upstream at the Holyoke Fishway, 36 river miles to the south, not a single shad had been tallied managing to pass beyond the grim maze of a power canal and several ladders to emerge above Turners Falls Dam. By Monday not a single migrant from the ocean had been tallied passing that dam–thus none were present moving upstream to open Vermont, New Hampshire and northern Massachusetts habitats. The public has no access to the fishway this year, and FirstLight has not provided a simple video feed for people to see their fish. At Turners Falls, the power company alone, is left to monitor itself and report on the public’s fish.


Shad Anglers below Holyoke Dam May 7, 2020 Copyright © 2020 by Karl Meyer

But, most grimly again this May, river conditions on Mother’s Day were altogether devastating for federally-endangered Connecticut River shortnose sturgeon attempting to spawn and nurture young in the currents at their ancient Rock Dam spawning pool–a mile and a half downstream of the dam. Vital river flows at a natural basalt, in-stream formation known as Rock Dam–which had been accommodating for spawning sturgeon just a week before, were shut down to the point where the cobble shoals that shelter eggs and developing young were now visible along a receded shoreline.

Hopeful shad anglers from the adjacent USGS Conte Lab and nearby US Fish & Wildlife Service in Sunderland were present to witness the impacts. This year’s potential progeny–at the sturgeon’s only documented natural spawning site in the ecosystem, were once more left to desiccate–starved of life-giving, oxygenating water as the sun warmed the prematurely exposed, rocky shallows. Though not fishing on this Mother’s Day morning, one of the leaders of the local Nolumbeka Project stopped to inquired of me if the sturgeon had been able to successfully spawn this year. I had to tell him no.

For the second year running FirstLight Power had squeezed the bascule gates closed at Turners Fall Dam, leaving just a curtain of a few hundred cubic feet per second (cfs) of flow entering the starved riverbed below Turners Falls Dam. The Federal Energy Regulatory license for FL’s Turners Falls and Northfield Mountain operations expired two years back on April 30, 2018. . Conditions in a new license would have hopefully increased that dribbling flow at the dam by a factor of 20. Grimly, the starving of this Great River is occurring at the exact site where women, children and elders of the Nipmuck, Pocumtuck, Norwottuck and Narragensett People were set upon and slaughtered in their pre-dawn sleep in the Turners Falls Massacre on May 19, 1676.

But FERC stepped in on FirstLight’s behalf, and has now offered two years of license extensions to this Canadian-owned, Delaware-registered company, allowing these grim impacts to continue. In doing so it has now green-lighted these conditions for three consecutive spawning seasons–allowing crippling industrial practices put in place 52 years back to choke the life out of four-state migratory fish runs, and crushing the spawning prospects for those sturgeon–literally the Connecticut’s only federally endangered migratory fish species. This, in an ecosystem that should have had connected and sustaining flows and fish passage upstream to Bellows Falls VT and Walpole NH long ago.

The flows present in the river on Mother’s Day are flows that force endangered sturgeon to default downstream to attempt spawning in the pulsing industrial flows churning out of the Cabot Station powerhouse a half mile downstream. There, any spawned and developing young-of-the-year will have no defense against the scouring-out hydro surges pulsing canal water back into the riverbed below once fertilized young are dispersed in the flows to shelter in rocky shallows .

Those tamped-down Mother’s Day flows from the dam also create conditions that keep American shad in an endless Groundhog Day cycling at Rock Dam–circling and re-circling in the depleted currents at a pool where depths become too shallow to find a flow offering a negotiable upstream path. Anglers sometimes do quite well at this migratory cull-de-sac where agitated, circling shad snap at darts while wasting hours and energy in this suspended-migration.

But those same tamped down flows diverted at TF Dam also cause just-arriving American shad from Holyoke to be led directly to the false upstream currents exiting the power canal at Cabot Station. Sensing that upstream attraction flow, those unlucky fish get drawn into a ponderous and exhausting fish ladder there. There they are diverted entirely out of the riverbed and into a concrete chute where they must attempt to better an impossible series of steps, twists, and turns that will ultimately dump them into the alien and un-river-like environs of the Turners Falls power canal. Once they enter that industrial habitat, many end their upstream migrations altogether, spending weeks in the labyrinth of that walled corridor without finding a way out and upstream.

Grimly, this year was nearly a carbon copy of the brutal conditions visited below Turners Falls the week of Mother’s Day 2019. Last year at this time researchers tallied the largest-ever catch of spawning-run endangered sturgeon gathered at their Rock Dam nursery pool, corralling 48 fish in a morning survey of a biologist’s net. Days later, at the height of shortnose spawning season, FirstLight abruptly cut off life giving flows to the site. Those same banks and cobbles were exposed, and the spawning run sturgeon were sent packing—forced to abandon the site, with any embryos and young that might have proved viable left withering in the shallows.


FL’s Locked Entrance at Cabot Woods & Rock Dam mid-afternoon May 5, 2020 Copyright © 2020 by Karl Meyer

You might have expected more from FirstLight this year. This is a Canadian shareholder company seeking a new federal license to operate these facilities on the Connecticut River in Massachusetts after recently re-registering them in Delaware as tax shelters. But, now that FERC continues to allow them to profit off the grim and antiquated tenets of a license written under the Federal Power Commission 52 years ago, they seem in no particular hurry to become relicensed neighbors operating for profit on a four-state US river that is the centerpiece of a National Fish and Wildlife Refuge.

These ongoing grim flow regimes fly in the face of mandates long-ago included in the Endangered Species Act and the Anadramous Fish Conservation Act, here, in the most biologically important and critical habitat in the entire Connecticut River ecosystem. They also feel like a thumbing of the nose at Massachusetts taxpayers—as well as all the deserving citizens in the three states from Montague MA to Walpole NH, who also pay taxes and are certainly entitled to a living river. It is a form of public theft.

As the Connecticut River is left starved, its ancient fish runs foundering, there is no movement to bring to a close the Federal Energy Regulatory Commission’s “5-year” relicensing process—begun here in 2012 and lingering on, laughably unfinished. The power company continues to pocket profits, while the FERC is led by a stilted and hand-picked majority happy to feed the corporations what they want, to the benefit of foreign shareholders far from New England. Sadly, there is no state or federal environmental agency that appears willing to challenge this endless delay. And, as noted here before—this four-state river lacks a true NGO watchdog with a mission-mandate and staff lawyers protecting it. See The Greenfield Recorder: https://www.recorder.com/New-England-s-great-river-without-a-watchdog-33291778

THIS GREAT AND BROKEN RIVER

Posted by on 28 Apr 2020 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls VT, blueback herring, Canada, climate-heating, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, FirstLight Power, Holyoke Dam, Holyoke Fish Lift, Holyoke Gas & Electric, Massachusetts Division of Fish & Wildlife, Micah Kieffer, migratory fish, National Marine Fisheries Service, New Hampshire, Northfield Mountain, Northfield Mountain Pumped Storage Project, pumped storage, Rock Dam, Rock Dam Pool, shad, shortnose sturgeon, State of Delaware, The Great Eddy, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Vermont, Vermont Yankee

THIS GREAT AND BROKEN RIVER

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 1, First Daylight for an Embattled Run

The tiniest spark of life reentered New England’s Great River on Tuesday, April 21, 2020. According to Ken Sprankle, Connecticut River Project Leader for the US Fish & Wildlife Service, the fish lifts began operating that morning at the Holyoke Dam, 82 miles from the sea. And on that day the first two migrating American shad of the spawning season were lifted upstream.


Holyoke Dam. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

I got that fragile bit of good news on Earth Day, and it was truly a bright spot in what seems a very distant and fragile time for people, ecosystems, and our beleaguered planet. And during this Covid pandemic, while our warming atmosphere is experiencing a brief respite from the particulate pummeling of jets and cars, the Connecticut is being brutalized as catch basin for all the chemicals, chlorine and antibiotics that are currently being flushing out into–and right through, our sewage treatment plants to the River… As such, the Connecticut had little to celebrate on the 50th Anniversary of Earth Day.

Nonetheless those two fish meant there would at least be some vestige of the spring run that once fed river communities for hundreds of miles along this central artery for untold centuries into the past.

It’s the public’s river, and these are the public’s fish. Those are the facts that I always keep in mind whenever I write or speak about the Connecticut. But there’s also this basic tenet for me: a river is a living system; it exists of its own right and its right to survive and thrive should thus be an unquestioned part of its existence. We humans have a moral obligation to protect the life of rivers, just as they have nourished, protected and supported the very ecosystems we’ve relied on for time immemorial.

For me, to kill a river is an immoral act. To flaunt any part of the legal framework that federal and state law has put in place protecting them is both criminal and repugnant. But maybe that’s just me…

Holyoke Dam looking toward Fish Lifts. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

Now two shad aren’t much in many minds, I’ll admit. But what those two shad—likely early males meant, was that the Connecticut had actually become a living river once more. At least a part of it. That tenuous little reconnection was completed when one fat, industrial bucket of river water was pulled from the downstream side of Holyoke Dam and dumped on the upstream side. Two living, blue-green American shad swam out into 35 miles of upstream river that all downstream fish are denied access to for some six months out of every year. That’s way less than a half-living river.

But what that tiny spark meant, more than symbolically was that—on the most basic level, the Connecticut was reopened along a tiny stretch as a true river–a TWO-WAY highway where migrating and resident fish can move both upstream and down as part of this ancient ecosystem highway.

The Holyoke Dam is historic for two reasons: First, it is the barrier at the center of the 1872 landmark US Supreme Court decision in Holyoke Company v. Lyman that established that dam owners and operators must provide passage for migratory fish—both upstream, and downstream, of their barriers. Second, though imperfect and of the simplest most basic design—i.e. upstream, in-river attraction flows leading migrating fish to be corralled in a closeable, industrial bucket and lifted over the dam–those Holyoke Fish lifts have remained the most successful fish passage on the entire East Coast since 1955.

For the next few months Holyoke’s industrial buckets will facilitate a stuttering recreation of the former Connecticut as a living, 2-way river while American shad, sea lamprey, shortnose sturgeon and blueback herring attempt to access ancient spawning grounds. For many that open habitat reaches all the way to the dam between Bellows Falls VT and Walpole NH–nearly 90 miles upriver. That ancient destination, however, remains a cruel impossibility for all but a fortunate few migrants…

The Great Eddy at Bellows Falls Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

Once again this spring the vast majority of those hundreds of thousands of fish passing upstream at Holyoke will be thwarted from reaching the wide open spawning habitat anywhere above the Turners Falls Dam. That dam sits just 35 miles upstream of the Holyoke lifts. It’s an easy swim for most– just a day, maybe two.

But once they approach that river reach and barrier there won’t be accommodating riverbed flows or any lifts offering suitable passage upstream. They’ll encounter vacillating, confused flows and a series of obstacle-filled fish ladders that funnel all migrants into the grim habitats of the Turners Falls power canal before any get an outside chance to squeeze past the dam itself. Most never do. Perhaps one fish in ten will succeed–leaving the next 68 miles of Connecticut River habitat impoverished and all but empty of its ancient migrants.

And for shortnose sturgeon, one of this river’s most ancient species and the only federally-endangered migrant in this ecosystem, prospects are yet more dire. With the actual riverbed in the 2 miles below Turners Falls Dam sporadically deluged and emptied of suitable natural current, these fish are all vulnerable to being again robbed of what should be an annual, slam-dunk spawning aggregation at their only documented natural spawning site in the ecosystem–the Rock Dam in Turners Falls. Another season will go by without life-giving mandated flows to this critical habitat due an absence of enforcement protection and license requirements.

Of course, that was to have changed two years back.

The Federal Energy Regulatory Commission licenses for operation of the Turners Falls/Cabot Station hydro sites and the Northfield Mountain Pumped Storage Project expired two years back on April 30, 2018. New flows and fish passage requirements should have been re-nourishing the endlessly pummeled and impoverished river in the beleaguered miles above and below Turners Falls Dam since that time. However, for the crippled run here, there is literally nothing new. Fish at Turners Falls today are almost as effectively blocked from moving upstream into Vermont, New Hampshire and northern Massachusetts waters as they were when the first dam across the Connecticut there blocked these runs beginning in 1798.

Today, the crushing suck-and-surge impacts of Northfield Mountain’s net-energy-loss, peak-price/peak-demand operations continue brutalizing the grimmest 10 miles in the entire ecosystem–cannibalizing the river’s fish runs and chewing through young-of-the-year. Pumped storage is not renewable energy, nor is it anything like the conventional river hydropower much of the public thinks it generates. Northfield Mountain consume vast amounts of virgin electricity from the grid here—most if it generated through imported natural gas, to pump the Connecticut backwards and a mile uphill. NMPS is in reality an energy consumer. It’s massive pull off the grid gets tallied in negative megawatts.

Today, the revival and protection of those long-ago, lawfully mandated runs remains stuck at Turners Falls and Northfield Mountain. The so-called FERC 5-year Integrated Licensing Process(ILP) that should have given them their two basic necessities for survival—water, and a safe, timely route upstream and down, actually began in the fall of 2012. It drags on to this day.

The day after FirstLight at long-last submits its final license application for examination to FERC–and the federal fisheries agencies with conditioning authority on the Connecticut, it will be September. September signals the beginning of the 9th year this supposed stream-lined FERC ILP has been malingering on this river system. FirstLight left off negotiations over a year ago with the US Fish & Wildlife Service, National Marine Fisheries Service, and the Massachusetts Division of Fisheries & Wildlife for required new river conditions and construction of fish lifts. There has been no movement since that time.

Any delay in the construction of a fish lift at Turners Falls, and the requirement for real, life-sustaining flows in the riverbed, benefits this recently-arrived power company. Their interest is in stakeholder and corporate profit—and this is a Canadian-owned outfit that re-registered all of these assets out of Massachusetts, chopping them into a series of tax sheltered Delaware LLCs in late-2018. FERC continues to allow FL “extensions of time” to make their license-required filings, delaying what have long-been federally required mandates for river and migratory fish protections.


The de-watered Rock Dam Pool where shortnose sturgeon attempt to spawn, just after 6:00 a.m., May 17, 2019. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

FL is now citing that restructuring as another reason for delay in submitting their “final license application” until August 31, 2020—that’s two years and four months of operating and profiting from a destructive and river de- pauperizing extended license. The current extension still requires only 400 cubic feet per second to be released into the Connecticut River bed in the spring migration season through which shad attempt to move upstream in—and embattled,federally-endangered shortnose sturgeon attempt to spawn in. That’s the equivalent of substituting a small brook for a river. Sturgeon spawning fails at the Rock Dam site most years, often caused by the abrupt ratcheting of those spring flows down to little more than that trickle.

Studies and investigations by the federal fish agencies show that a massive increase in sustained spring flows are baseline requirements for a living river here. Last year n the first week of May spring flows of some 10,000 cubit feet per second were coursing down the Connecticut’s “dead reach” here–and right through the Rock Dam pool. Shad anglers were landing fish by the dozen. On May 10, 2019, USGS Conte Lab researcher Micah Kieffer put out a research net overnight in that pool. Then next morning he found 48 federally-endangered shortnose sturgeon weighing it down—the largest aggregation ever recorded there. Kieffer continued his successful sturgeon netting through the following week, until coming up empty on Friday, May 17, 2019. He got “skunked” that day after flows through the Rock Dam reach were abruptly cut by FL to a relative trickle, exposing the cobble-lined shores of that pool where embryos and young develop.

Clearly, those 10,000 cfs flows are what are necessary to restore life to this river. They are required and long overdue—at a season when electricity demand is at some of its lowest points in the year.

The first year license extension by FERC was allowed because of the shuttering of the Vermont Yankee nuclear plant upstream. VY’s excessive, night nuclear megawatts were the grim, 40 year engine that enabled Northfield Mountain to suck the river into reverse and pump it up into a 4 billion gallon reservoir to later re-create second-hand electricity at high prices.

Now restructured, FL appears in no hurry to move ahead with new licenses. Their study results have often been delayed in being handed over to the federal fisheries agencies and study teams in this relicensing–or handed in on the very last day the process requires. They seem happy to tread water and realize profits–while NMPS’s fish-eating, net-energy loss operations continue running along, largely fueled via the imported, climate-scorching, natural gas generated electricity now bloating the grid.

The longer you don’t have to put a shovel in the ground or give this US River its flows for federally-required fish passage, the more money you keep. It’s time FERC stopped letting them off the hook. Stop stringing this process along. It’s time this river was brought into compliance with 1872’s Holyoke Company v. Lyman; it’s time to comply with the federal Endangered Species Act of 1973. It is the public’s river; these are the public’s fish.

Addendum: on Friday, April 24th, USFWS’s Ken Sprankle sent a note that the Holyoke Gas & Electric had shut down its fish lifts due to accumulating debris in its assembly. They would not operate through the weekend, and a fix would be attempted on Monday. Thus, the Connecticut became a one-way stream again anywhere above South Hadley Falls, leaving the next 88 empty miles of river still in midst of an endless vigil–awaiting the migratory runs guaranteed by the Supreme Court 148 years ago. Hopefully, for those migrating shad—and perhaps other early migrants wasting another week’s precious spawning-energy reserves while knocking on Holyoke’s door, those lifts are again operating and in full motion today.

FERC orders Canada’s FirstLight to investigate ITSELF on ESA impacts

Posted by on 27 Feb 2020 | Tagged as: Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC Secretary Kimberly D. Bose, FirstLight, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS

Photo Copyright © 2020, by Karl Meyer.
NOTE: the above photo was taken on 2/25/20 at the Rock Dam pool in Turners Falls. This is the ONLY documented natural spawning site for the federally endangered shortnose sturgeon on the Connecticut River. NOTICE: the Connecticut River shortnose sturgeon is the ONLY federally-endangered migratory fish in the entire ecosystem. Shortnose sturgeon will be returning to the grim conditions in this ancient spawning pool in just 7 weeks.(Click, then click twice more to enlarge)

I sent the Federal Energy Regulatory Commission the following letter in October of 2019.

Karl Meyer, M.S. Environmental Science October 9, 2019
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

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

ILP COMMENTS re: Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

These comments are made with respect to immediate concerns respecting P-1889 and operations of the Turners Falls Dam and power canal impacting the riverbanks and the spawning habitat of the federally-endangered Connecticut River shortnose sturgeon at the Rock Dam, this species’ only documented natural spawning site in the Connecticut River ecosystem. I have been a participating Stakeholder in the FERC relicensing process for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both these projects.

In recent weeks I have noted increasingly steady water leakage in the riverbanks above the Rock Dam site, leading to constant water flow intrusions along these banks. Less than 400 feet away sits the downstream, outer-right banking curve of the Turners Falls power canal, which is the apparent source of these increasing water intrusions.

In a visit to the Rock Dam site on October 8, 2019, I noted the dramatic collapses of a long section of riverbank adjacent to the Rock Dam. This collapse, of some 25 feet in width and dropping down between 5 – 10 feet toward the river, is apparent in my attached photo. Please note that the draped yellow jacket in the foreground is approximately 3-1/2 feet across. This new bank collapse is just south, by perhaps 30 feet, from an earlier recent collapse of a smaller scale of some 6 feet across, occurring at approximately the same bank level. At both of these sites there has been a serious leaching of manganese, the red colored flow toward the river and the sand and cobbles that constitute the shortnose sturgeon spawning site and egg/embryo nursery unique to this reach.

Of most import in the licensing and management of this critical habitat is the damaging, new eroded channel flowing around the Rock Dam site on river left that has grown from a trickle in the mostly rain-free months of this year’s late summer and early fall—until, by yesterday, October 8, 2019, it had grown to torrent of new water coursing through a new channel adjacent to those collapsing river banks. The corresponding connection to this dramatically increasing damage appears to stem from the increased flows currently being released from Turners Falls dam to facilitate the week-long dewatering of the Turners Falls canal, currently in progress. See attached photo of TF dam release on that day. This new channel presents an immediate threat, through deposition and erosion and pollution, to the spawning and early life stage development of shortnose sturgeon in the rock, sand, and cobble habitats at the Rock Dam pool, immediately downstream and adjacent.

Immediate action appears to be necessitated by these developments. This riverbank and traditional fishing access has been neglected and poorly maintained through the last decade. A cursory look would find neglected concrete pilings where steps were to be built, as well as literal sink holes in at least two sites in areas above these collapsed banks, where small hemlock trees are now sunk to the depth of 4 feet.

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.

Thank you for your careful review of these matters; they are of immediate import.

Sincerely,
Karl Meyer

Cc:
Doug Bennett, FirstLight
Julie Crocker, NMFS/NOAA
Ken Spankle, USFWS
Melissa Grader, USFWS
Caleb Slater, MA Div. of Fish & Wildlife,
Rich Holschuh, Elnu-Abenaki”

Photo Copyright © 2020, by Karl Meyer.

Just one small section of FirstLight’s collapsing riverbank and the pollution that runs into the Rock Dam pool just 40 feet away. This is just 250 yards away from the USGS S.O. Conte Anadromous Fish Research Center. (NOTE: Click, then click x2 to enlarge)

NOTE: Over 4 months later the Federal Energy Regulatory Commission finally took the bold action to order Canadian-owned, Delaware-registered FirstLight to investigate and report on their own impacts on this critical endangered species habitat on the Connecticut River. THE ORDERS ARE BELOW:

FEDERAL ENERGY REGULATORY COMMISSION
Washington, D. C. 20426
OFFICE OF ENERGY PROJECTS
Project No. 1889-090 – Massachusetts
Turners Falls Hydroelectric Project
FirstLight Hydro Generating Company
VIA FERC Service
February 21, 2020

Mr. Donald E. Traester
Manager, Regulatory Compliance
FirstLight Power Services, LLC
99 Millers Falls Road
Northfield, MA 01360
Subject: Complaint – Erosion

Dear Mr. Traester:
On October 9, 2019, we received a complaint regarding erosion in the bypassed
reach of the Turners Falls Project No. 1889. According to the complaint, releases fromthe dam caused erosion in the area known as the Rock Dam in the project’s bypassed reach. For us to complete our review of the of the complaint, please file the following information within 30 days of the date of this letter:

1. Photographs and the location(s) and an estimate of the extent(s) (e.g., height,
width, depth) of the erosion in the bypassed reach identified in the October 9, 2019complaint.

2. The dates and timing of the Turners Falls power canal drawdown, why it was
performed during this time, whether it was typical of past drawdowns, and what
measures you took to protect downstream resources and the public.

3. Flow data for the entire period identified in item 2, including releases from the Turners Falls dam.

4. A comparison of the flow releases into the bypassed reach during this drawdown
to historical releases into the bypassed reach (e.g., for maintenance purposes,
naturally occurring high flows, etc.)

5. Any additional information you believe is pertinent to the allegations raised in the October 9, 2019 complaint.

20200221-3033 FERC PDF (Unofficial) 02/21/2020
Project No. 1889-090 – 2 –

The Commission strongly encourages electronic filing. Please file the requested
information using the Commission’s eFiling system at http://www.ferc.gov/docsfiling/efiling.asp. For assistance, please contact FERC Online Support at
FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY). In
lieu of electronic filing, please send a paper copy to: Secretary, Federal Energy
Regulatory Commission, 888 First Street NE, Washington, D.C. 20426. The first page of any filing related to this letter should include docket number P-1889-090.
If you have any questions regarding this letter, please contact me at (202) 502-
6778 or Christopher.Chaney@ferc.gov.

Sincerely,
Christopher Chaney, P.E.
Engineering Resources Branch
Division of Hydropower Administration
and Compliance

My FERC finding…

Posted by on 21 Jan 2020 | Tagged as: "environmental" species act?, Amherst Bulletin, Connecticut River, Connecticut River ecosystem, Federal Energy Regulatory Commission, FERC Chairman Neil Chatterjee, FERC Commissioner Bernard McNamee, FERC Commissioner Richard Glick, FERC Secretary Kimberly D. Bose, The Recorder, Vermont Digger, VT Digger, vtdigger.org

Photo credit: USGS Conte Lab

Copyright © 2019 by Karl Meyer. All Rights Reserved.

My FERC finding…

On August 11, 2019 I sent FERC Secretary Kimberly D. Bose a request for a rehearing of FERC’s allowance of several transfers of licenses for the Northfield Mountain and Turners Falls Projects. My evidence-based objections were based on the federal Endangered Species Act, specifically under the takings and interference prohibitions in that 1973 law.

Exactly two months ago, on November 21, 2019, FERC made its finding: ORDER REJECTING REQUEST FOR REHEARING. I will note here that I have not updated my blog notes as promised just prior to that time. My sole excuse, which may sound flimsy, is simply this: that finding, issued among a rote list of perhaps 20 others simply noted by project and number, came at a regular meeting of the Federal Energy Regulatory Commission in Washington DC.

I watched the FERC meeting, live, and found the proceedings wholly absurd, insular, insulting to the idea of democracy and fact-based decision-making in a time when planetary systems are failing and a climate emergency is breathing down the neck of this and all future generations.

Perhaps it is no surprise that FERC Chair Neil Chatterjee is a former aide to Mitch McConnell. The Chair seems to run the agency like a kid given the keys to the candy store. Though my decision and a score of others were not mentioned in any specific way, Mr. Chatterjee gleefully boasted of FERC’s sanctioning of two massive LNG EXPORT facilities in Texas. This at a time when–out of the other side of its mouth FERC is bragging that it is a big proponent of energy STORAGE. This is climate denial incarnate.

In my particular case, my request was rejected on technical grounds: “Under Rule 713(c)(2) of the Commission’s Rules of Practice and Procedure, a request for rehearing must include a separate section entitled “Statement of Issues” listing each issue presented to the Commission in a separately enumerated paragraph.20 Any issue not so listed will be deemed waived.21 Mr. Meyer’s rehearing request does not include a “Statement of Issues” and is, therefore, rejected.”

FERC also dismissed my submission of further evidence corroborating ongoing impacts on a federally endangered species—again, not on fact-based findings, but on grounds that my furthering evidence, discovered later, had not been included in my first objections. Apparently, FERC does not allow the interference of witness-based evidence as they hone the narrow logic of their un-vetted decrees. In my case though, it seems my submission presented substantial enough arguments that they at least spent several pages in lame rebuttal after noting that my further submissions were inadmissible:

“In addition, the facts identified by Mr. Meyer in support of his arguments were not raised in his comments in the transfer proceedings, but rather provided after issuance of the Turners Falls and Northfield Transfer Orders. We have previously rejected parties’ attempts to submit new facts and allegations at the rehearing stage because doing so “presents a moving target and frustrates needed finality.”22 Therefore, we also reject Mr. Meyer’s request for rehearing for improperly seeking to enlarge the scope of this proceeding, which is inappropriate at the rehearing stage.”

As far as my finding of these proceedings to be objectionable to the very idea of democracy—and to justice for future generations concerning climate, I must note that FERC Commissioner Bernard McNamee actually referred specifically to the “‘ENVIRONMENTAL’ Species Act” during the proceeding. I wasn’t aware of this new act—but it was actually scrolled, verbatim, across the text feed–on-screen. This is your federal agency, safeguarding and enforcing the laws that will protect future generations. Embarrassed??

One long-standing note on the current make-up of FERC, of the usual 5 commissioners, there are currently only three as of late last year. And, even at this dog-and-pony celebration of burning up yet more ecosystems and draining planetary veins, Commissioner Richard Glick did speak out and decry FERC’s long-standing dereliction of duty in not including the evaluation of climate impacts and green house gas GHG emissions in their greedy corporate math in sanctioning massive new energy projects. At least from a lip-service angle, young people seem to have an ally in Glick.

As with the Impeachment Hearings–beginning this very day, facts and witness evidence seem to have little in common with FERC proceedings and their own version of “just” findings. This is not an agency of the people…

NOTE: directly below is a piece that appeared in The Recorder, Vermont Digger, the Amherst Bulletin, and elsewhere in recent weeks.

Copyright © 2019 by Karl Meyer

The Grinching of the Great River

Each Winter Solstice a few friends and I gather on a quiet bridge to offer a toast honoring New England’s Great River. Lingering above its cold December waters, we send along hopes for the River’s coming year.

As central artery to a 4-state ecosystem and the Conte National Fish and Wildlife Refuge, the Connecticut needs all the help it can get. Just upstream are the grimmest 10 miles of habitat in its entire 410-mile run. Worst are the suctioning turbines of FirstLight’s Northfield Mountain Pumped Storage Project, eviscerating millions of migratory and resident fish year round. Nearer-by are the starkly-dewatered 2-1/2 miles of riverbed dubbed the “By Pass Reach”—ground zero as the sole documented natural spawning site for federally-endangered shortnose sturgeon.

Rinse, kill; repeat has been the daily routine at Northfield since 1972. Formerly running off Vermont Yankee’s excess nuclear electricity, it now operates via massive amounts of imported electricity–basically functioning like a nightmare giant electric toilet. Sucking the river up to its 4 billion gallon reservoir-tank for hours at rates of up to 15,000 cubic feet per second, it kills all life vacuumed up in its vortex. Later, at peak times and peak prices, operators flush that dead water back through turbines, producing a few hours of expensive second-hand juice.

To picture one second of 15,000 cfs suction imagine a 3-story mansion with 7 bedrooms and 8 full bathrooms—filled to the rafters with aquatic life. Now watch it wrenched backward and sucked to oblivion: all fish, eggs, animals and insects destroyed by reversing blades on a twice-through Northfield sleigh ride. Now picture 60 grim implosions each minute, 600 every 10 minutes–3,600 mansions obliterated every hour for hours on end.

A FL consultant’s 2016 study estimated NMPS’s operations resulted in the loss of just 2,200 juvenile American shad. Yet results from a study released in 2018 by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated that carnage from those same operations actually resulted in the loss of 1,029,865 juvenile shad. Other imperiled migrants include American eel, sea lamprey and blueback herring. Largely unstudied are lethal impacts on 2 dozen resident species. The more it runs, the more it kills.

NMPS has never produced a single watt of its own power. Nor will owners–after bragging to be able to power a million homes for 7 hours, point out they must actually consume the megawatts of some 1.25 – 1.33 million homes in order to do so. It’s a net-loss system, an electric toilet filled by chewing through the core of the S. O. Conte National Fish and Wildlife Refuge.

FirstLight now wants to run NMPS even more—attempting to rebrand its second-hand electric output as clean, renewable energy. And the Federal Energy Regulatory Commission and ISO-New England are doing their best to keep FL’s unholy new vision afloat. It marries ecosystem-destruction with renewable ocean-energy in a corporate-shareholder package to service unprecedented, climate-warming, construction booms in metro Boston, Providence, Worcester and elsewhere. Massachusetts, host to this plant–and as the largest energy-consuming state in New England, ought to be ashamed and brought to task for the climate- and ecosystem-futures of its children.

In the 1980s a grim proposal arose to employ NMPS to suck up more of the river and pipe it to Quabbin Reservoir for use as reserve metro-Boston water. But citizens, states and towns rebelled under leadership from the likes of the late-Terry Blunt of the Connecticut River Watershed Council and Hadley’s Alexandra Dawson of the Conservation Law Foundation. The result was the 1984 MA Interbasin Transfer Act, forbidding the out-of-basin export of river resources until all conservation efforts are first exhausted. Such leadership is sorely missed today.

On December 20, 2018 FirstLight’s Canadian parent-owners quietly spirited their assets out of New England–re-registering them as separate, limited liability corporate tax shelters in Delaware. It was slick timing. Federal fish negotiators were to undergo a government shutdown the next day. Meanwhile FL remained in the middle of a bid to keep operating their US facilities for decades here under new FERC licensing.

Stakeholders didn’t learn of their move until January 8, 2019. Nearly all cried foul to FERC.

Huge concerns included the loss of access to information used for valuations and information assuring FirstLight can and will be held accountable to supply the construction and funds necessary to meet US and state environmental laws–including the Anadromous Fish Conservation Act, the Endangered Species Act and the Clean Water Act under new licensing.

One year later at the Solstice New England’s Great River remains without courageous leadership and in desperate need of a new NGO–one with a fiery legal department.

Karl Meyer’s “River Report” is broadcast regularly on WHMP. He’s been on the Fish and Aquatics Study Team in the “5-year” FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield.

Intervening for the Connecticut River Ecosystem

Posted by on 13 Nov 2019 | Tagged as: Connecticut River ecosystem, Connecticut River shortnose sturgeon, Douglas Bennett, Dr. Boyd Kynard, Endangere Species Act, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, Federal Recovery Plan, federally-endangered Connecticut River shortnose sturgeion, FirstLight Power Resources, Kleinschmidt Associates, Micah Kieffer, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, Northfield Control Room, Northfield Mountain Pumped Storage Project, P-1889, P-2485, Recovery Plan for the Shortnose Sturgeon (Acipenser brevirostrum), Rock Dam, Secretary, Section 9–Prohibition of Take Section 9(a)(1), Steven Leach, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, US Fish and Wildlife Coordination Act

NOTE: below, find photographic evidence and the text of my Request for Rehearing delivered to Federal Energy Regulatory Commission Secretary Kimberly D. Bose on August 11, 2019. My request was granted. I will update this posting when FERC delivers its decision on whether FirstLight can be approved for several Transfer of License applications while being out of compliance with current license requirements that have impacted the critical habitat and spawning of a federally-endangered migratory fish. Text begins below photos.

ALSO here: https://www.youtube.com/watch?v=WZVyFgoFYyA is a link to Episode 187 of Local Bias that I recorded with host Drew Hutchison at the studios of Greenfield Community Television. It is running throughout November on GCTV, and has been broadcast in Hadley, MA, HQ home of Region 5, US Fish & Wildlife Service.


PHOTO: dewatered shortnose sturgeon spawning pool at the Rock Dam in the early hours of May 17, 2019. (Click x3 to enlarge)
Photo Copyright © 2019 by Karl Meyer All rights reserved.


PHOTO: Closed bascule gates and cut-off flow to the main stem Connecticut River on the morning of May 17, 2019. (Click x3 to enlarge)
Photo Copyright © 2019 by Karl Meyer All rights reserved.

Karl Meyer, M.S. Environmental Science
91 Smith Street
Greenfield, MA, 01301
karlmeyer1809@verizon.net

August 11, 2019

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

Request for a Rehearing of Commission’s July 11, 2019 Order Approving Transfer of License and Substitution of Relicensing Applicant for P-2485-077, FirstLight Hydro Generating Company to Northfield Mountain LLC; and P-1889-088, FirstLight Hydro Generating Company to FirstLightMA Hydro LLC.

Specifically: the FirstLight Hydro Generating Company, Project No. 2485-077 Northfield Mountain LLC) APPLICATION FOR APPROVAL OF TRANSFER OF LICENSE, SUBSTITUTION OF APPLICANT, AND REQUEST FOR EXPEDITED CONSIDERATION; and FirstLight Hydro Generating Company, Project No. 1889-088, FirstLight MA Hydro LLC ) APPLICATION FOR APPROVAL OF TRANSFER OF LICENSE, SUBSTITUTION OF APPLICANT, AND REQUEST FOR EXPEDITED CONSIDERATION

Dear Secretary Bose,

I request that the Commission rehear and review its expedited decision regarding P-2485 and P-1889. This request is being made in part because I believe the Commission erred when it stated in its approvals of the transfers under the Section D headings that “The Transferer is in Compliance with the License.”

FERC’s decision that FirstLight, in its Section 12 Discussion statements, “demonstrated this transfer is in the public Interest,” was made in error—particularly with respect to its Section 16 statements that, “Our review of the compliance history of the project shows that the licensee has been in compliance.” And further, in FERC’s Section 17 Discussion statements that, “In conclusion, we find that Northfield’s transfer application demonstrates that it is qualified to be the licensee for the project. In this case, the transferee has provided documentation showing its fitness to comply with the terms and conditions of the license.”

My request for a rehearing and withdrawal of the Commission’s July 11, 2019 decision granting these license transfers is that FirstLight was not in compliance of the terms and conditions of its license on May 17, 2019 respecting the federal Endangered Species Act, Section 9.(ESA section 9 makes it unlawful to take (harass, harm, kill, etc.) any endangered species.), as well as Article 45: “The operating of Project No. 2485 shall be coordinated with the operation of Project No. 1889.”

Section 9–Prohibition of Take Section 9(a)(1) makes it illegal to take²² an endangered species of fish or wildlife. The take prohibition has been applied to most threatened species by regulation. ²² *: Take–to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any such conduct (section 3 of the ESA–definitions). Harm means an act that actually kills or injures wildlife, and may include significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding, or sheltering (50 CFR § 17.3, § 222.102).

On May 9, 2019, US Geological Services Micah Kieffer, Research Fishery Biologist at the LSC Conte Anadromous Fish Laboratory detected a signal from a radio-tagged shortnose sturgeon at the Rock Dam, a documented natural SNS spawning site on the Connecticut River. Kieffer, a sturgeon specialist, set two nets in the river overnight, and returned early on the morning of May 10, 2019, to find 48 federally endangered shortnose sturgeon in those nets.

In turn, on May 13, 2019, Kieffer emailed a report of this finding in his ongoing work to biologists and various interested parties and SNS stakeholders, noting: “This past Thursday evening we dropped two gill-nets in the Rock Dam pool. Expecting to capture only a few fish, on Friday morning we instead landed 48 individuals: four females (two pre-spawning, one running, one spent) and 44 males (all running sperm) (pers. comm.)” Duly apprised of the presence and apparent spawning activity of that federal endangered species were two biologists working for FirstLight Power Resources–Steven Leach, Senior Fishery Biologist, FirstLight Power Resources, Inc., and Chris Tomichek, Senior Manager, Kleinschmidt Associates, working as a FL consultant.

In an updating May 22, 2019 email that again included fishery and agency biologists and stakeholders, including myself and FL’s Steven Leach and Chris Tomichek, Kieffer noted:

“Greetings to all SNS stakeholders:
Here is an update on the monitoring of SNS spawning at Montague for 2019. Following the May 13 report, we set additional nets on three days (May 14, 16, and 17), mostly at Rock Dam, but a few at Cabot and the Deerfield River, all day-sets to avoid excessive captures like that we experienced on 5/10. These efforts resulted in the additional capture of 11 fish on 5/14 and another 11 on 5/16 (we got skunked on the 17th). Within these efforts, we captured an additional female running eggs that received an external tag, and we also internally tagged three males, two that we PIT-tagged 25 years ago!”

Having been apprised of SNS spawning activity having been observed at Rock Dam on May 10, 2019, I found the Rock Dam spawning and rearing site had had its flows cut and its banks dewatered just a week later, on the morning of Friday, May 17, 2019. That is the same morning when Kieffer later recorded getting “skunked” at Rock Dam. Upstream, FL had shut bascule gates 2, 3, and 4, while pinching down Bascule 1 to just a few hundred CFS. See photos attached. Flow at the Rock Dam had been ramped down to a shallow lick of whitewater, while robust flows have been documented as necessities for females to remain on that spawning ground. Further, the cobble banks had been dewatered, habitat where embryos shelter and develop. The practice is lethal.

In short, FL’s actions at the dam, controlled from upstream at the Northfield Mountain Pumped Storage Station, directly interfered and imperiled SNS spawning. They did this at a time when they were apprised of SNS presence and should have executed the utmost diligence—FL, of its own volition, was in the process of implementing its own test flows for the By Pass reach.

The presence and spawning activity requirements of shortnose sturgeon in the project areas–and within the influences of P-1889 and P-2485 has been known by the license holders for decades. Indeed, several studies were referenced in the PAD, before the beginning of the current relicensing:

From the Northfield Mountain/Turners Falls Pre-Application Document, October 2012, Section 6:

LITERATURE AND INFORMATION SOURCES CITED IN THE DESCRIPTIONS AND SUMMARIES OF EXISTING RESOURCE DATA (18 C.F.R. § 5.6 (c)(2)), pp. 297. – 301
Fish and Aquatic Resources, Sections 6-3, 6-4, 6-5.

Kieffer, Micah & Boyd Kynard. (2007). Effects of Water Manipulations by Turners Falls Dam Hydroelectric Complex Rearing Conditions for Connecticut River Shortnose Sturgeon Early Life Stages. S.O. Turners Falls. MA: Conte Anadromous Fish Research Center.

National Marine Fisheries Service (NMFS). (1998). Recovery Plan for the Shortnose Sturgeon (Acipenser brevirostrum). Prepared by the Shortnose Sturgeon Recovery Team for the National Marine Fisheries Service, Silver Spring, Maryland. 104 pages.

In an email to SNS stakeholders from FirstLight Manager Douglas Bennett, responding to an inquiry from US Fish & Wildlife Biologist Melissa Grader about see-sawing flows and bascule gate settings, Bennett noted that the FL settings impacting SNS spawning and habitat in the By Pass at Rock Dam in the P-1889 Project area had been implemented in the control room of NMPS, P-2485:

“On Friday morning at approximate 1000 the flows receded enough so that the 6500 cfs by-pass flows were initiated by discharging 4400 cfs over Bascules 1 and 4 and 2100 cfs at TF #1 Station.

The 6500 cfs by-pass flows were maintained until 2400 on Saturday evening when by-pass flows were dropped to 4400 cfs, discharging 2400over Bascule gate 1 and 2100 at TF #1 Station. This was an error on our part due to misinterpretation of conflicting schedules in the Northfield Control Room. Corrective actions have been taken to prevent this going forward.”

I witnessed the Rock Dam water-starved and bank-exposed at 5:30 a.m., and my photo of the listless spill with ONLY Bascule 1 open, was taken at 7:30 a.m. Mr. Bennett’s note states that flows had not come down enough to implement FL-initiated test flows until 1000 hrs. He did not mention the setting hours earlier that I documented. Thus, apparently, there had been a ramping down of the bascule from within the NMPS control room sometime in the early morning hours, with the result of further impacts on spawning SNS through a jumble of see-sawing gate settings.

The Commission notes in its granting of these Transfers that “Section 8 of the FPA requires “any successor or assign of the rights of such licensee . . . shall be subject to all the conditions of the license under which such rights are held by such licensee and also subject to all the provisions and conditions of [the FPA] to the same extent as though such successor as assign were the original licensee.”24. FirstLight, at a time when it was apprised of the presence of a federally endangered species did not meet its license requirements here—regarding the ESA Section 9, and the only federally-endangered migratory fish in the Connecticut River

The Commission further stated that, “Northfield is affiliated with companies in the operation and maintenance of hydroelectric projects and will have access to their expertise.” Their actions clearly demonstrate there was no expertise shown or relayed between P-2485 and P-1889 at this critical time.

The Commission noted, in their decision: “In conclusion, we find that Northfield’s transfer application demonstrates that it is qualified to be the licensee for the project. In this case, the transferee has provided documentation showing its fitness to comply with the terms and conditions of the license.”

Their actions clearly call the company’s fitness to operate these plants into question. Is FERC’s finding that these transfers are “in the public’s interest” valid? FL clearly did not coordinate operations between P-2485 and P-1889 at this critical time, which is clearly spelled out in Article 45 of their license. Those actions should have been updated with the Commission and investigated before a Transfer finding was granted. An investigation and exploration of impacts and penalties under Section 9 of the ESA should be undertaken by the Commission before these transfers are validated.

I therefore request that the Commission undertake a rehearing of these license transfers. The grantor and grantee need to demonstrate they can comply with federal regulations to operate these facilities. Please see attachments.

Thank you for your careful review of these matters.

Sincerely,
Karl Meyer

Justice for New England’s Embattled River

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


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

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

Copyright © 2019 by Karl Meyer. All Rights Reserved.

Justice for New England’s Embattled River

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

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

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

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

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

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

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

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

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

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

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

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

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

Karl Meyer: Connecticut River dam owners pulling a fast one

CONNECTICUT RIVER ALERT: FERC deadline looms

Posted by on 24 Jan 2019 | Tagged as: Canada, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, Conservation Law Foundation, Endangere Species Act, Federal Energy Regulatory Commission, Federal Recovery Plan, federal trust fish, FERC, FERC Commissioner Neil Chatterjee, FERC licensing process, First Light Hydro Generating Company, FirstLight, Greenfield Community Television, ISO New England, MA Division of Fish and Wildlife, Maura Healey, Natalie Blais, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Paul Mark, Public Comment period, public trust, Rock Dam, shad, Treasury Board of Canada, Turners Falls dam, USFWS, Vermont, Vermont Yankee, Yankee Rowe Nuclear Plant

While federal fisheries stakeholders from the US Fish & Wildlife Service and National Marine Fisheries Service are shut out of the FERC relicensing process by the government shutdown, Canada-owned FirstLight Hydro Generating Company has maneuvered to split its assets on the Connecticut River. This is a slick move, and a punch in the gut to all that have been working in good faith on the understanding throughout–since 2012,that these long-co-run plants were to be covered by a single new license: per the power company’s standing, 5 year-old request.

Copy and paste link directly below to see a half hour on this suspect 12th hour maneuver, filmed for later airing on Greenfield Community Television.

NOTE: FERC has extended the COMMENT, PROTEST, and INTERVENTION deadline for Stakeholder to file Motions with them until February 8, 2019. Go back to www.karlmeyerwriting.com/blog and see second blog post following this on this one on how to submit at FERC.gov on Ecomments.

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