Connecticut River ecosystem

Archived Posts from this Category

DUE DILIGENCE: looking beneath the surface

Posted by on 27 Dec 2013 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, Daily Hampshire Gazette, ecosystem, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC license, FirstLight, hydraulic study, shad, The Greenfield Recorder, Turners Falls power canal, USFWS

Copyright © 2013, by Karl Meyer

NOTE: the following piece appeared recently in Daily Hampshire Gazette, www.gazettenet.com; The Recorder, www.recorder.com; the Montague Reporter, and the Shelburne Falls and West County Independent.

                    DUE DILIGENCE: looking beneath the surface

New England’s Great River is at a critical juncture in the closing days of 2013.  An ecosystem door was slammed shut at Turners Falls 215 years ago when private investors built a dam across the river.  After 1798, migrating fish no longer reached northern Massachusetts, Vermont or New Hampshire.  In a landmark 1872 decision the US Supreme Court reopened the door to an ecosystem restoration via “Holyoke Company vs. Lyman.”  It upheld a Massachusetts law requiring dam owners to provide fish passage as part of the public interest of stakeholders upstream and down. Yet today there’s still no working fish passage at Turners Falls. 

As a stakeholder wishing to see the Connecticut River’s fisheries restoration succeed after decades of failure, I’m participating in the current 5-year Federal Energy Regulatory Commission’s hydro relicensing process.  It will determine conditions in the river for the next 30-40 years.  If you go to www.northfieldrelicensing.com and click on “2013 Documents,” you’ll find FERC’s “Study Plan Determination Letter” dated 9/13/2013.  It’s a 74-page catalogue of studies FERC has determined necessary to protect the public interests as they move to issue new long-range hydro licenses on the river in 2018.  Curiously, if you open that letter and scroll to the last word on the last page (74) you’ll find “Karl Meyer,” listed as “Recommending Entity” for Study 4.2.3, “Hydraulic Study of the Turners Falls Power Canal.”

I was surprised to find my name there, given that each of the 18 studies above it lists Firstlight, owners of the Turners Falls Power Canal, as Recommending Entity.  But this was no accident on FERC’s part.  They’d originally included the canal study as part of Study 3.2.2 in their preliminary judgments on the science needed to define the impacts of FirstLight’s hydro operations on river environments.  I’d agreed with them.  But FirstLight, in all subsequent filings, seemed determined to exclude it.  They simply excised “power canal” from 3.2.2: “Hydraulic Study of Turners Falls Impoundment, Bypassed Reach, power canal and the Connecticut River below Cabot Station.”  Their main argument was that the water surface level in the canal remains relatively stable through the year.  But given that what happens below the surface is what’s critical to the needs of migrating fish, I argued a canal study was a critical consideration. 

Two generations back a chance to restore fish runs beyond Turners Falls was squandered when the US Fish & Wildlife Service and four state fisheries agencies agreed to steer migratory fish into the chaos of the privately-owned Turners Falls power canal.  A singular New England opportunity to recoup and expand the river’s biodiversity was lost.  Just as in 1980, at best one-fish-in-ten emerges alive upstream there today.  Some years it’s 1-in-100.  That mistake stemmed from a failed quest to create a hatchery-strain of extinct Atlantic salmon here.  As a result, due diligence wasn’t applied to the needs of growing populations of herring, shad and sea lamprey, who would now have to survive a trip through an industrial canal on their spawning runs.  It also scuttled the only natural spawning grounds of the endangered Connecticut River shortnose sturgeon. 

Merriam-Webster defines due diligence as “the care that a reasonable person exercises to avoid harm to other persons or their property.”  Today, after 14 years of power company-subsidized canal studies that remain unpublished, we know scant little about conditions fish encounter throughout that canal.  Save for a few dozen yards at its entrances and exits, two full miles of watery terra incognita lay in between.  That missing knowledge comprises this ecosystem’s black hole. 

Yet with just tidbits of canal study information leaking into the public sphere, there is evidence that canal conditions–and the weeks-long migratory delays fish experience there, are proving lethal.  “Shad are dying in droves in the canal and we don’t know why,” is how one federal Conte Lab researcher responded to a question about mortality in the canal they’ve repeatedly studied using FirstLight funds.  Since dead fish don’t head back to sea to return as repeat spawners, the canal impoverishes a full 172 miles of river ecosystem up to Bellows Falls, VT. 

Thus, I’m proud to have my name listed next to canal hydraulics study 4.2.3.  I believe it represents FERC’s effort to exercise due diligence in getting the information needed to make the best choices in these proceedings.  It certainly represents my own.  FERC’s Ken Hogan has stated that thorough studies and reliable data are what FERC is aiming for as they decide on conditions hydropower interests will have to adhere to as they operate on our river for generations to come.  Anything less would constitute a failure of their public mandate.

 FERC’s Public Comment Period on any of the 39 studies they may require for the relicensing of Turners Falls and Northfield Mountain projects ends December 31, 2013.  Go to www.ferc.gov , and “filing e-comments.”  P-1889 is the Project # required for Turners Falls dam and canal; P-2485 is for Northfield Mountain.

 Karl Meyer is a member of the Society of Environmental Journalists.

Unconscionable: The Fate of the “Canal Nine”

Posted by on 09 Sep 2013 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Conte, Dead Reach, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, shad, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab

Note: the following piece appeared this August in Connecticut River Valley publications including: Vermont Digger, www.vtdigger.org; the Daily Hampshire Gazette, www.gazettenet.com, The Montague Reporter and The Shelburne Falls Independent, and at The Recorder www.recorder.com, (edited version).

THE FATE OF THE CANAL NINE

Copyright © 2013, by Karl Meyer     All Rights Reserved

Forty-three years after being chosen as the upstream route for migratory fish, the Turners Falls power canal remains the black hole of fisheries restoration on the Connecticut.  In current filings the US Fish & Wildlife Service is requesting telemetry coverage across the mid-Turners Falls canal to puzzle out the unexplained fate of thousands of fish.  Trout Unlimited wants balloon-tagged shad and more monitors bracketing its powerhouse to study turbine kills and migratory delay.  The Federal Energy Regulatory Commission wants a hydraulics study of that canal, where all migrants must bypass two turbine stations, then negotiate blistering turbulence just to have a shot at spawning in Vermont and New Hampshire.  On August 14, 2013, canal/dam owners GDF-Suez FirsLight rejected those studies as unnecessary in legal filings for a new 30 – 50 year federal operating license.

While every fish attempting to spawn upstream of Turners Falls dam must enter the canal, scores of questions about their fate there remain unanswered.  Basic questions like, do shad spawn in the canal, have never been studied–even though shad spend an average of 25 days there and just one-fish-in-ten that enters emerges beyond the canal.  US Geological Survey Conte Fish Lab researchers have been paid by Northeast Utilities and FirstLight for studies to improve the fish exit from the canal for the past 15 years.  Yet forty-three years after this system was put in place, it’s still one-fish-in-ten.  And canal spawning, germane to the ecosystem restoration puzzle, has never been studied.

Even more basic to success is this: if only one fish in ten makes it through—what’s the fate of the other “canal-nine”?  But you don’t pose that question if you want to keep being paid to study the public’s fish in the company’s private canal.  You study little sections of the canal–fiddle around near the company’s preferred exits and entrances—make big claims for tiny, discreet successes.  A mountain of data is collected, yet never finalized, published; nor peer reviewed.  After 15 years of study and reengineering, it’s still one-fish-in-ten.  Other agency experts wink in this shared belief: most fish entering that canal don’t survive.  Sliced-up in downstream turbines, they flush directly into the river.

“Unconscionable” is the term Dr. Boyd Kynard uses for plans afoot to move hundreds of thousands of shad into that canal via a new lift (as opposed to tens of thousands today.)   He’s an award-winning fish passage expert who logged over 25 years as a federal fish scientist– helping found the Conte Fish Lab while with the US F&WS.  Kynard believes the ineffective ladder system in place there for decades may have actually saved hundreds of thousands of fish from death in Cabot Station turbines, “The Cabot ladder is so bad most fish never reach the canal where most will exit downstream through deadly station turbines.”

Kynard, a fish behavior specialist who studied shad passage and turbine mortality at Holyoke Dam through the 1980s, believes a new lift below Cabot Station could prove the ecosystem’s next 50-year disaster.  He witnessed massive fish kills in Holyoke’s canals in the early 1980s when, starting in 1976, a new lift passed hundreds of thousands of fish upstream to spawn for the first time in 120 years.  It was hugely successful, but no one foresaw what would happen when adults headed back to sea.  While part of the migrants rode over the dam during high flows, others reencountered the dam-and-canal-system.  Tens of thousands got sucked into turbines at Hadley Falls Station or died in the canal–unable to return safely to the river. A stench of rotting fish hung over that city while dump truck after dump truck hauled tens of thousands of dead shad from the canal to the landfill.  (That condition was eventually remediated when dam owners installed a louver system in the canal to divert down-running shad into a pipe and back to the river, thus bypassing all turbines.)

But whereas Holyoke’s lift allowed shad to first spawn upstream in the river before encountering turbines, at Turners two hundred thousand fish could find themselves in a turbine-filled canal before ever getting a chance to spawn in Vermont, New Hampshire or northern Massachusetts.  And this canal’s Frances-type turbines are far more deadly than Holyoke’s.  Stressed, those newly-lifted shad can encounter two discreet turbine sites before meeting the massive canal turbulence near the dam.

This ecosystem can’t absorb another 40-year failure in the Turners Falls canal.  The USFWS, TU, and the Connecticut River Watershed Council are backing a study–adopted from Kynard’s Holyoke work, which would use low-frequency sound to deflect shad from entering the canal.  If deployed correctly it could send migrating fish straight upriver to a lift at the dam, like the one that’s succeeded at Holyoke for decades.  It’s a simple, inexpensive study–one FirstLight is already seeking to limit to a single year, or exclude altogether.  But it’s FERC who’ll decide by September 13th.  And they have a mandate to protect the public’s fish.

Comments sent to FERC Re: Northfield/TF Canal Relicensing

Posted by on 15 Jul 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, New Hampshire, Rock Dam, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont, Vernon Dam Fishway

The following are my formal Stakeholder Comments submitted on July 15, 2013, to the Federal Energy Regulatory Commission concerning GDF-Suez FirstLight’s Updated Proposed Study Plan for gaining relicensing for the Northfield Mountain and Turners Falls/Cabot Power Canal projects.  Please excuse wide line-spacing due to document format.

                                                                                                          

July 14, 2013

 

Karl Meyer, M.S., Environmental Science
Greenfield, MA  01301

 

 

 

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

 

Stakeholder Comments, RE: FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) for Northfield Mountain Pumped Storage Project, FERC Project No. 2485-063; and Turners Falls Hydroelectric Project, FERC Project No. 1889-081

 

Dear Secretary Bose,

 

 

Please consider the following comments, changes and proposed improvements to FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) in order to achieve the best measurable outcomes for the public’s interest in a balanced and functioning Connecticut River ecosystem as you consider new operating licenses for hydropower generation at these two projects.

 

 

Comments refer to Updated PSP #s: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; 3.3.3; 3.3.5; 3.3.6; 3.3.7; 3.3.8; and 3.3.19.

 

Comments:

 

 

2.2.1 & 2.3.1: Proposed Changes to Project Operation

 

FL Updated Proposed Study Plan, Numbers 2.2.1 and 2.3.1: Operator is considering additional generation by adding volume, flow and velocity in, 1(p.2-15): the Turners Falls Power Canal at either Station #1 or Cabot Station, or operating Cabot Station at full capacity; and, 2(p-2-35): at the Northfield Mountain Project.  Hydraulic capacity increase at TF/Cabot sites, and at Northfield Mountain would be near 2,000 CFS respectively.

 

Any back-dated decisions in adding generation at these two licensed sites may impact the effectiveness and criteria of studies that will be implemented in the interim, and may prove confounding to the two-year study regimen.  Both would certainly impact downstream habitats and flows.  What criteria is FirstLight looking at when deciding on new generation requests—and when will they reveal their choices?

 

3.2.2: Hydraulic Study of the Turners Falls Impoundment, Bypass Reach, (“power canal”—now omitted by FL) and below Cabot Station

 

 

Note: Hydraulic study of the TF Power Canal is a key need if this is again to be considered an upstream route for migratory American shad.  After 14 years of continuous study and project improvements near the head of the Turners Falls Canal, Gate House fish passage numbers are no more improved–nor consistent, compared to numbers of fish passing Holyoke Fish Lift, than they were a quarter century ago: Holyoke Lift versus the actual percent that were able to pass up through the TF Power Canal and through the Gatehouse: (Figures from the Connecticut River Atlantic Salmon Commission Tech. Committee Meeting, Secretary’s Report: 6/18/2013)

 

Gatehouse passage success: 1989: 2.7%; 1990:7.8%; 1991:10.5%; 1992: 8.3%; 1993:3.0%

 

Gatehouse passage success: 2009: 2.4%; 2010:10.0%; 2011:6.9%; 2012:5.4%; 2013: 9.2%.

 

 

 

(p. 3-50) “FERC has requested that FirstLight develop an unsteady state HEC-RAS model in the Turners Falls Impoundment, bypass reach, power canal, and below Cabot Station to the upper limit of the Holyoke Impoundment.”

 

 

FirstLight states that a hydraulic study of the TF power canal is unnecessary, as surface (WSEL) elevations fluctuate very little.  “Given the power canal’s limited WSEL fluctuations, FirstLight does not believe a hydraulic model of the power canal is warranted.”

 

 

FERC is correct.  A full hydraulics study of the TF Canal is needed.  It is necessary as baseline information if migratory fish continue to be diverted into the power canal.  It will also be critical information if generating capacity in the TF Canal and upstream at the Northfield Project is increased by 2,000 cfs, respectively(2.2.1 & 2.3.1).  This would certainly impact hydraulics at the head gates and downstream in the power canal.

 

There are 14 head gates at the TF Gatehouse flushing directly into the TF Power Canal.  Surface level elevations have very little to say about actual flow hydraulics at this site.  Those head gate openings and the fluctuating head-levels from the TF Impoundment behind the dam create a region of extreme turbulence in the canal running some 500 feet downstream from Gatehouse.  This is one of the bottlenecks in the power canal route that has not been overcome after 43 years of study and structural changes in this upstream route.

 

 

When the agencies and the public were taken on FERC site visits, only one group in three was given a tour of this side of the TF Gatehouse.  At that time, only 4 head gates were open.  The canal appeared a relatively calm place.  When all head gates are open—as the Northfield Project and Cabot are run in peaking modes, or the TF Canal is run at baseload capacity through the day, this region is a boiling-roll of water.  Surface speeds reach nearly 10 mph (as monitored by cyclists on the canal path).  We need to know how this affects velocity and turbulence throughout the water column

 

 

Given recent fish passage increases at Holyoke Dam, it is feasible that building a facility to lift migratory fish out of the CT River and into the TF Canal below Cabot Station could divert as many as 100,000 fish into the canal over a period of a few days.  Recent work by USGS Conte Anadromous Fish Research Center showed American shad spending an average of 25 days in the power canal.  Researchers did not investigate whether this was a signature of fish mortality, spawning, or milling. Nor has the TF canal ever been investigated as spawning habitat—which would have been logical, given those lengths of stopover.  American shad notably do not do well with stress.  Piling up the population in a power canal will likely result in major migratory delays and increased mortality—which needs a full investigation if this path remains an option.

 

This should be a two-year effort, to control for differences in flow years, fish tagging and handling, and to assure that full acoustic coverage is gained through proper array deployment.

 

American shad have not been able to negotiate this region of high turbulence since this canal route was chosen for them in 1980.  At Holyoke, as well as at Vernon Dam, fish follow attraction water that leads them directly upstream to the dams.  Rates of passage at both are within the acceptable range of 40-60% that the agencies have set as targets.  When the Connecticut River above Cabot Station—aka, the Bypass Reach, was allowed to be de-watered in deference to this power canal route, shad and herring were expected to locate and negotiate a series ladders, turns, turbines, and turbulence at a half dozen canal sites in order to reach upriver spawning areas.  It’s a migratory knot; created by humans.

 

The Connecticut River migratory fisheries restoration effort risks repeating four new decades of failure if it again ignores logic.  The TF Power Canal is in need of a full hydraulic study.

 

Hydraulic modeling must be done here in order to avoid another migratory fisheries restoration disaster at Turners Falls.  Northern Massachusetts, Vermont and New Hampshire have yet to see their guaranteed shares of the targeted shad and herring runs, nor has the program achieved anything near its stated goals:  “The intent of this program is to provide the public with high quality sport fishing opportunities in a highly urbanized area as well as to provide for the long term needs of the population for food,” as stated in the New England Cooperative Fisheries Statement of Intent in 1967.

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Please ADD to Existing Information: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu.  Chapter 3-Migrations, Effect of River Regulation documents over a decade of highly relevant studies.

 

 

FirstLight’s Water Level Recorders (River Stage)”The Water Level Recorders deployed by FL in 2010 that supplied “limited data” from the By Pass Reach and below Station 1 should be removed from “existing information” status.  WSEL monitoring in this reach needs to be redone.  Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Add to information list for specific information on this reach: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.

 

Additional WSEL monitors needed. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

3.3.1 Conduct Instream Flow Habitat Assessments in the Bypass Reach and below Cabot Station 

 

If migratory fish are again to be diverted into the TF Power Canal via a new lift in the river near Cabot outflows (proposed), special consideration needs to be made when considering siting the lift facility.

 

Federally-endangered shortnose sturgeon will likely enter the lift, and there exists the risk of putting them into the power canal where there is potential for turbine mortality.

 

Migratory delay: another reason for special care in considering diversion is migratory delay for American shad and blueback herring at this site.  If a lift gets built at Cabot, there will be a need for full-time monitoring personnel in order not to risk sending SNS into the canal.  Just as at Holyoke, with Atlantic salmon monitoring, the lift would then have to shut down—sometimes for weeks at a time, due to turbidity and the risk of NOT identifying a migrant salmon(or in this case, a federally endangered SNS).  This type of migratory delay would not likely be acceptable to the agencies, or FL (see FL’s added text about “without delay” under 3.3.19 : “Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.”

 

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

The IFIM Study needs to be conducted with increased WSEL monitors given FL’s stated intent to potentially increase generation and flow at the Northfield Project, Station 1, and Cabot Station.

 

Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Information list for specific information on this reach, ADD: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

Additional WSEL monitors needed to capture fuller By Pass flows profile. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

Table 3.3.1-1: Target Species and Life Stages Proposed for the IFIM Study Reaches.

 

Under Reach 1 & 2: blueback herring: add “spawning”—as New England Cooperative Fisheries Research Studies document BBH spawning in this reach, at the mouth of the Fall River.

 

 

Under Reach 1 & 2: shortnose sturgeon: add “pre-spawning.”

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.”

 

 

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

 

Study Goals and Objectives (18 CFR § 5.11(d)(1))

 

“The goal of this study is to identify the effects of the Turners Falls and Northfield Mountain Projects on adult shad migration. The study objectives are to:”

 

 

Add: “Determine route selection, behavior and migratory delays of upstream migrating American shad through the entire Turners Falls Power Canal.”

 

Add to “Describe the effectiveness of the gatehouse entrances;” …

 

 

ADD IN: “and describe the behavior of migratory American in the Turners Falls Power Canal within 500 feet of the gatehouse entrances.”

 

ADD IN: “Evaluate attraction for shad reaching the dam spillway under a range of spill conditions.” 

Note:  Since a lift is being considered at this site, evaluating spillway attraction is most important.

 

 

 “Evaluate attraction, entrance efficiency and internal efficiency of the spillway ladder for shad reaching the dam spillway, under a range of spill conditions;”  see immediately below.

 

Footnote 35 “This may be achieved with existing information; FirstLight is awaiting data from the USGS Conte Laboratory.”

 

 

NOTE: USGS has done 6 years (2008 – present) of study and data collection at Spillway and Gate House.  All of it remains “preliminary”—hence never finalized, or peer-reviewed.  Only “finalized” study data and findings should be included in FERC study plan design, and made available to all stakeholders for review.  All studies are partially FirstLight funded.

 

The Need for Additional Information

 

Under  Task 1: “Review existing information:”

Only finalized USGS study information should be considered.

Task 2: Develop Study Design:

As per FERC request, a radio and PIT tag study of the entire Turners Falls Power Canal should be included in this study.

 

 

Task 3: Evaluation of Route Selection and Delay

 

             Under: Radio Telemetry Tracking: Add in:

 

“Tagged fish will be tracked throughout the Turners Falls Power Canal during bothupstream and downstream migration with fixed antennae and mobile tracking; usingPIT tags in addition to radio telemetry tags.”

 

“Additional tagged individuals may need to be released farther upstream (Turners Falls power canal, * (ADD IN: “top of Cabot Station Ladder,”) upstream of Turners Falls Dam), to ensure that enough tagged individuals encounter project dams on both upstream and downstream migrations, that these individuals are exposed to a sufficient range of turbine and operational conditions to test for project effects, and to provide adequate samples sizes in order to address the objectives.”

 

Under: Video Monitoring

 

 

Video monitoring at the Spillway Ladder is insufficient.

 

Note: Video monitoring is insufficient in determining the number of fish attracted to the spillway.  It will only register fish that can FIND the Spillway Ladder Entrance.  This in confounded by a range of competing flows, water levels present in the By Pass, and spill from the dam.  A full range of telemetry tracking needs to be employed at the TF Spillway—not simply at the Spillway Ladder and SL Entrance.

 

Task 4: Evaluation of Mortality

 

Note: Preliminary USGS TF Canal studies have suggested uninvestigated data indicating mortality within the Turner Falls Power Canal.  Mortality tagged fish and data should be collected throughout the entire TF Power Canal, to correct for overall mortality.

 

 

The number of fish suggested to be fitted with mortality tags is insufficient in all these studies, and should be increased by a factor of two.

 

Table 3.3.2-1: Proposed locations and types of monitoring and telemetry equipment proposed for the upstream and downstream passage of adult shad study.

 

 

ADD in: (to identify migration routes and delays):

 

After “Cabot Ladder”, add new location: Eleventh Street Canal Bridge: PIT Tag Reader

 

Before “Rawson Island”, add new location: TF Power Canal, 400 feet downstream of Gate House.  PIT Tag Reader and Lotek SRX.

 

 

Also before “Rawson Island”, add new location: “Rock Dam Pool, immediately downstream of Rock Dam.”  Lotek SRX.

 

 

After “Turners Falls Spillway Ladder,” add: Turners Falls Spillway, Montague Dam.  Lotek SRX;  followed by a new location, add in: Turners Falls Spillway, Gill Dam.  Lotek SRX.

 

QUESTION: What is the exact location considered for “Below Turners Falls Dam” ?

 

 

3.3.3 Evaluate Downstream Passage of Juvenile American Shad

 

Task 3: Turbine Survival

 

Evaluations should be done for all turbines, with all turbines operating, at both Cabot and Station 1, to capture the broadest range of conditions at these sites.

 

 

3.3.5  Evaluate Downstream Passage of American Eel

 

Level of Effort and Cost (18 CFR § 5.11(d)(6))

 

Study ticket price is too expensive.

 

 

“The estimated cost for this study is approximately between $350,000 and $450,000.”

 

Note: Costs of this American Eel Study are prohibitive, particularly since there is no benchmark data on the ecosystem importance of eels above Mile 122, TF Dam.

 

This rivals the costs of all studies supported to assess migration and mortality of American shad, a restoration target species to Vermont and New Hampshire for 46 years.

 

 

 A significant proportion of that money could best be used to increase the scope of study: 3.3.2, and 3.3.7: Evaluate Upstream and Downstream Passage of Adult American Shad; and 3.3.7 Fish Entrainment and Turbine Passage Mortality Study.  These could then include a full study of the Turners Falls Power Canal–and increasing the number of mortality-tagged fish.

 

Cost effectively, a literature survey, and results from Holyoke Dam studies and Cabot data collection should suffice to gauge survival of American eel at Turners Falls/Cabot/Northfield.  A portion of the funding could be used to construct an eel-way at TF Dam—a relatively inexpensive structure.

 

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

 

 

Under: Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Information as American spawning and spawning habitat is missing for the pool where shortnose sturgeon spawn, the Rock Dam Pool, immediately downstream of that notched ledge in the river.

 

Task 2: Examination of Known Spawning Areas Downstream of Turners Falls Dam

 

Note: The Turners Falls Power Canal needs to be investigated as a spawning location for American shad.  USGS studies have registered migratory shad remaining in the TF Canal for and average of 25 days.  Adult shad, which do not feed during spawning migration, must complete their salt-to-river-to salt spawning runs within 44 days in order to survive.  A critical need is to know whether these fish are spawning in the TF Power Canal, milling in the canal, or whether they have expired.

 

3.3.7 Fish Entrainment and Turbine Passage Mortality Study

 

Increase the number of mortality-tagged fish; run tests for all turbines at Station 1 and Cabot, with all turbines operating.

 

3.3.8 Computational Fluid Dynamics Modeling in the Vicinity of the Fishway Entrances and Powerhouse Forebays

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

 

Note: Three-dimensional CFD Modeling needs to extend 500 feet downstream of the Gate House in the Turner Falls Power Canal to capture the influence of the 14 head gates at the dam on migratory fish behavior and delay.

 

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

 

 

General Description of Proposed Study

 

FirstLight’s added language: “This study will be conducted in 2015 pending the results of Study No 3.3.1 and Study No. 3.3.2, which include analysis of historic fish passage data.”

 

Note: This study should be conducted for two seasons, the same time span accorded to American eel. 

 

Historic fish passage data likely has only minimal importance, as early spring freshet flows over the TF Spillway generally out-compete Cabot Station flows and send fish treading water at the base of TF dam—often for weeks.  Those freshet flows at the dam typically overwhelm any flow from the Spillway Ladder, and the shad essentially run down their engines treading water until the freshet subsides.  At that point, flows over the Spillway are allowed to be cut to 400 cfs, which sends the shad downstream to fight their way into the spill of the canal system. For this reason, historic data has limited value as the quantified presence of shad at the base of TF Dam is missing, and data on the effectiveness of Spillway attraction flow does not exist.

 

Resource Management Goals of Agencies/Tribes with Jurisdiction over Resource (18 CFR § 5.11(d)(2)) 

 

“• American shad must be able to locate and enter the passage facility with little effort and without stress.”

 

“• Where appropriate, improve upstream fish passage effectiveness through operational or structural modifications at impediments to migration.”

 

 

“• Fish that have ascended the passage facility should be guided/routed to an appropriate area so that they can continue upstream migration, and avoid being swept back downstream below the obstruction.”

 

Note: This study should not be contingent on results of other studies, and should be conducted for two seasons. 

1.    Its effectiveness at another Connecticut River bottleneck has been tested.

 

2.    It addresses the need to avoid migratory delay and failure for two key species that have topped the CT River fisheries restoration since 1967: American shad and blueback herring.

 

3.    It keeps the fish migrating in the Connecticut River.

 

4.    If it proves effective, it would simplify fish passage mechanisms and cut by millions of dollars the cost required for passing TF Dam.  A single set of lifts at the dam would pass fish, as it has at Holyoke for decades.

 

5.    It would avoid the expense and pitfalls of requiring fish to negotiate two mechanisms at Cabot Station, another out of the canal, and a final grid through Gate House. 

 

6.    It presents the opportunity to avoid the stress required of migratory fish when they are driven into the TF Power Canal, then must find their way through turbulence and fight a path through several more untried, built mechanisms.

 

7.    USGS studies have found the average passage time through the TF Canal is 25 days; whereas transit times in the actual river—from Holyoke to TF Dam, or from TF Dam to Vernon Dam, are generally accomplished in a matter of 2 – 3 days.

 

8.    This would avoid the problem of shortnose sturgeon being picked up in a lift at Cabot Station, which would be a cause for further migratory delay as lifts would have to stop to retrieve fish—and also might have to be shut for days during times of high turbidity. 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3)) 

Information from Proposed Project Changes, Flow, Hydraulics, Habitat, and Telemetry studies: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; should be used to inform the implementation of this study. 

 

FirstLight’s added-in text:

 

“however, simply repelling shad from the Cabot tailrace is not a satisfactory result, for this behavioral barrier to be successful the fish would also have to keep going upstream, without delay, as opposed to dropping down below Cabot.”

 

Note: this caveat does not present a satisfactory argument.  In order to be proven ineffective, delays caused by sonics repelling fish from the Cabot entrance would have to out-compete any delays American shad and blueback herring encounter by being drawn to the Spillway during spring freshet and not find a readable upstream flow or passage at the dam. To this must be added the delay and stress of having river attraction and Spillway flow cut to 400 cfs, thus sending them DOWNSTREAM to fight their way into the TF Power Canal. 

Question: Should FL be deciding what constitutes delay?  Shouldn’t American shad dropping back two miles downstream from the TF Spillway to Cabot Station be considered an “unsatisfactory result”? 

 

Methodology (18 CFR § 5.11(b)(1), (d)(5)-(6))

 

Note: Ensonification coverage may need to be deployed far enough out into the main stem so as to lead fish out to the thalweg/main flows on the west side of Rawson Island.  Simply steering fish out of the Cabot entrance, but then only allowing them the choice of the minimal flows coming down through Rock Dam at the time paltry 400 cfs release would likely keep the fish milling and confused below Station # 1. 

Study Schedule (18 CFR § 5.11(b)(2) and (c))

 

FirstLight’s Added text: “ 

“If performed, the study is anticipated to conclude by mid-July 2015.”

 

Note: This should not be a contingent study. 

                                                End of Formal Comments 

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

Sincerely,
Karl Meyer, M.S.

Double Standard on the Connecticut

Posted by on 09 Jul 2013 | Tagged as: American shad, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Riverkeeper, Rutland Herald, shortnose sturgeon, Times Argus, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Rutland Herald and the Barre-Montpelier Times-Argus during the first week of July.

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

On June 28, 2013, Federal Energy Regulatory Commission Director of Energy Projects Jeff C. Wright ruled against the US Fish & Wildlife Service as it sought two extra weeks to review hundreds of pages of just-released Proposed Study Plans for the relicensing of five Connecticut River hydro projects. “The request for a 15-day EOT to file comments on the licensee’s proposed study plans is denied.”  EOT is FERC-speak for “extension of time.”  Those studies will impact this four-state river for the next 20-40 years. Agencies joining that request included the National Marine Fisheries Service, MA Div. of Fish & Wildlife, The Connecticut River Watershed Council, The Nature Conservancy, Trout Unlimited, the Franklin Regional Council of Governments, NH Dept. of Environmental Service and The Vermont Agency of Natural Resources.

One big reason for that request was the difficulties in evaluating the impacts of FirstLight’s Northfield Mountain/Turners Falls hydro operations on the entire Connecticut River ecosystem.  Beginning last fall, FERC began deviating from its standardized relicensing model when it scheduled public site visits to FirstLight sites weeks before the company released a publicly-required 500-page Pre-Application Document describing its complex pumped storage operations and machinery.

This spring FERC also supported FirstLight’s expedited-request to conduct a series of complicated river flow studies this summer—an allowance falling well outside FERC’s strict licensing timelines.  In doing so they let the company schedule three days of river visits by fed/state agencies smack in the middle of their deadline to comment on FirstLight’s 434-page Updated Proposed Study Plan.  FirstLight released that document June 28th; comments to FERC are due July 15, 2013.  Even after nine meetings with the power company and FERC, many agency representatives continued to decry the lack of critical scientific detail provided in FirstLight documents.  Those were put together by its team of five consulting firms.  Ironically, those handpicked FirstLight firms will conduct the next two years of river studies—the ones meant to protect the river.  A fox and chicken coop analogy applies.

FERC is employing a legal double standard here on the Connecticut.  If you a public agency or citizen seeking protections for the ecosystem—well, even little rules are THE RULES.  At the same time it appears corporations can continuously and sometimes massively ignore federal license requirements with impunity.

In FERC’s own words, the Commission “enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”  Yet today Holyoke Gas & Electric is half a decade–and counting, in violation of its 2002 agreement to construct facilities to end the evisceration of federally endangered shortnose sturgeon and other “federal trust” fish migrating downstream at their Holyoke Dam facility.  So, why have a license at all? 

Upstream in 2010 GDF-Suez FirstLight dumped some of 45,000 cubic square yards of reservoir sludge directly into the Connecticut at Northfield Mountain over a 90-day period—the equivalent of 40 dump truck loads of muck per day, smack in the middle of fish migration season. Yet in current documents FERC states their inspections have never found FirstLight in violation of its license.

The US EPA found FirstLight in violation of the Clean Water Act in August of 2010 and ordered a massive clean-up, though the ecosystem damage was already done.  In an August 4, 2010 letter EPA sanctioned FirstLight for violating “FERC License No. 2485” and polluting the “navigable waters of the United States.”  A subsequent letter dated August 10, 2013 from FERC’s Biological Resources Branch Chief Steve Hocking to FirstLight Manager John Howard specifically referenced the EPA’s sanctions, directing him to “article 20 of your license.”  Yet there is virtually no FERC mention of that egregious violation in current relicensing documents.

That’s the standard that for-profit companies are held to here.  It rivals the Pirate Code.  Currently there is no watchdog entity on this river willing to go to the mat to protect the ecosystem.  If, like on the Hudson, there was an organization like Riverkeeper—which cites “enforcement” as one of its main responsibilities, these egregious injuries to the Connecticut would not likely stand.  Holyoke Gas & Electric would have been in court long ago for killing endangered sturgeon; and the full range of FirstLight’s lethal impacts on the Connecticut’s migratory fish when all are diverted into their turbine-filled power canal would’ve been fully investigated.  FERC’s inaction is a disgrace.

FERC Director Wright requested that questions regarding that EOT denial go to Ken Hogan at: 202-502-8434, or Kenneth.Hogan@ferc.gov. Ken has presided over the CT River relicensing hearings.  Also, you can find FirstLight’s 434-page “Updated Proposed Study Plan” at: www.northfieldrelicensing.com under Documents.  The public has until July 15, 2013 to send comments on that plan to FERC.  You do that at: www.ferc.gov/docs-filing/efiling.asp .  You must cite FirstLight’s project numbers, P-2485 and P-1889, and be sure to note that you are commenting on the “Updated Proposed Study Plan.”

Karl Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield, MA. Read more at: www.karlmeyerwriting.com

Crunch Time for the Connecticut River: you snooze; you lose…

Posted by on 30 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, ecosystem, federally-endangered shortnose sturgeon, FirstLight, National Marine Fisheries Service, Rock Dam, US Fish & Wildlife Service

Copyright © 2013, by Karl Meyer

Crunch Time for the Connecticut River: you snooze; you lose

(Note: the following piece appeared earlier this month in the Rutland Herald, www.rutlandherald.com, and Times-Argus in Montpelier, www.timesargus.com, as “Fish Future Hangs in Balance”) 

On May 7th the Holyoke Fish Lift passed 21,608 American shad upstream.  The next day they lifted 44,456—the all-time, single-day record for the Connecticut River.  In two days they’d passed over 66,000 shad–6,000 more than the highest number ever to pass upstream through the Turners Falls power and beyond its dam in a single season.  That occurred back 1992.  Sadly, upstream denizens may never see but a shadow of the ecosystem’s annual run of fish.  Here’s why:

 As April ended, GDF-Suez FirstLight Power cut off flow to the Connecticut below Turners Falls Dam.  Essentially the river died, reduced to a drool of 400 CFS (cubic feet per second) of flow leaking through a wide, 200 million year-old chasm of cobble, bedrock and shale.  In order to remain a working migratory system, 3,000 CFS of flow would’ve been needed to nourish the river below that dam.  Pinching off the flow there ensured that the fittest, early-arriving American shad and any remaining blueback herring (currently candidates for federal endangered species listing) would be forced from the river and into that power canal 2-1/2 miles downstream.

Right at the cusp of spawning season FirstLight diverted at least 97% of river’s flow.  It sent some 16,000 CFS through the dam head gates into the power canal to supply a portion of the region’s base-load electricity.  But beyond that, a still-undisclosed percentage of the Connecticut was gobbled-up to serve the massive pumping and generating operations of the Northfield Mountain Pumped Storage Station, five miles upriver.  Tumultuous, tide-like effects created by those operations create a whole different animal.  There, using river water amassed in a five billion-gallon mountaintop reservoir, FL generates electricity via massive surges into- and out-of the riverbed either when demand peaks—or, when prices spike instantly on the electricity “spot market”.  So, while habitats are being deeply impacted by flow manipulations at the dam for Northfield, FirstLight harvest profits form a crippled riverbed.

One result this year is that an unknown number of the last 300 federally-endangered shortnose sturgeon surviving here were forced from their ancient river spawning pool to attempt their spring rite elsewhere.  The overwhelming yearly result is, in retreat from a de-watered river, nearly all upstream migrating fish here are left with no choice but to swim into the flows exiting the Turners Falls canal and turbines 2-1/2 miles downstream.

To successfully get upstream there, fish must move through two miles of alien flows and habitat.  Then they must thread their way through brutal currents, blinding turbulence and tangled cross-currents while approaching the dam’s head gates, where–unknowingly, they are required to locate a tiny canal exit.  If they get this far, all shad and herring must punch through more quickened flow, a final series of steps, and yet another narrow opening through fluctuating water levels at that gatehouse in order to emerge above the dam.  In the best of years less than 1-in-10 shad succeeds.  For most adult fish, any trip through that canal will prove fatal.

If, this year–like at Holyoke, two fish elevators had been installed at the base of Turners Falls Dam, and–if ample flow nourished the river bed, as it does below Holyoke, some 33,000 of those 66,000 Holyoke shad would’ve passed Turners Falls a few days later.  A couple of days after that—say May 13 – 15, some 16,000 shad would’ve begun wriggling their way up the Vernon ladder past Brattleboro and Hinsdale on their way to Walpole and Bellows Falls.  And thousands more would’ve followed.  But with a deadly canal intervening, that just wont’ be happening.

Connecticut River fans anywhere from Turners Falls and Northfield, MA, to Chesterfield, NH and Bellows Falls, VT are currently hoping this ecosystem will be revived through improvements via the federal relicensing of dams at Vernon, Bellows Falls, and Wilder.  But two federal hydro licenses here in Massachusetts for the Northfield Mountain and Turners Falls hydro complex are also up for 2018 renewal.  The hard truth is, if they don’t get it right down here, there won’t be more than a whiff of a renewed ecosystem upstream.  Forget any connection to the sea.  Turners Falls/Northfield really is the ballgame.  An ugly compromise that uses that power canal as an upstream migration route will ensure a functioning river ecosystem and ancient runs of shad and blueback herring to Bellows Falls and Walpole won’t ever materialize.

Public relicensing meetings are taking place at 9 a.m. at the Northfield Mountain Visitor Center, 99 Millers Falls Rd. (Rt. 63), Northfield, MA, on Tues. and Weds., June 4 & 5.  Those ecosystem-shaping decisions will be made by those who participate.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists.

Dam Relicensing: Diving into the Dead Reach

Posted by on 28 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, federally-endangered shortnose sturgeon, FERC license, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Rock Dam, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab

Watch Diving into the Dead Reach on LOCAL-BIAS: Learn why information about fish mortality in the the deadly Turners Falls Power Canal has been kept from the public these last 14 years.

Tune-in Greenfield Community Television’s (GCTV) Local-Bias Host Drew Hutchison and guest Karl Meyer, and find out what happened when he went snorkeling in this critical segment of the Connecticut–which should be deemed a spawning sanctuary for shortnose sturgeon and migrating American shad.

The program airs Weds. May 29th at 5 pm, and again on Thursday, May 30, at 9 pm; then again on Saturday, June 1, at 9 pm.  The series repeats at those time the f0llowing week.

Go to:  http://www.gctv.org/node/5264

See also: http://www.gctv.org/schedule

The Connecticut River shortnose sturgeon

Posted by on 21 Apr 2013 | Tagged as: American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, shortnose sturgeon, US Fish & Wildlife Service, USFWS

 

Copyright © 2013, by Karl Meyer

The following piece appeared earlier this April in the Rutland Herald, Vtdigger.org, The Recorder, Daily Hampshire Gazette, Shelburne Falls Independent, and on other sites.

                       The Shortnose Sturgeon and Spring’s Teachable Moment 

There’s a watershed opportunity for teachers investigating migratory fish this spring.  It’s the final season classrooms will raise Atlantic salmon eggs from a massive federal hatchery program, dismantled after 46 years.  It’s a chance to teach kids that “extinct,” in evolutionary biology terms, means exactly that: gone, forever.  It’s a profoundly simple lesson, with ramifications that can be fully grasped in a week.  I’m hoping teachers will put a living dinosaur of a fish in that salmon’s place—one still here, though teetering on the edge of extinction these 46 years: the federally endangered Connecticut River shortnose sturgeon.  As teachable as T. Rex, this marvelously adapted, 3-4 foot fish has survived for 100 million years. 

On April 20, 1967, two federal agencies and four states signed the Cooperative Fisheries Restoration Compact for the Connecticut River.  It specifically targeted American shad and blueback herring, plus salmon–extinct here since Darwin’s birth in 1809. Within two years its emphasis had overwhelmingly veered to conjuring up a new salmon.  Still, with a little help shad and herring populations blossomed.  Combined runs reached 1,000,000 fish in the 1980s; then dropped precipitously.  Bluebacks are now rare as hen’s teeth. 

By 1975, what was then the Federal Power Commission had heard testimony that Long Island Sound had warmed to a point that might prevent cold-water salmon from entering rivers in its basin.  The climate had changed.  Still, in 1980 MA and US Fish and Wildlife Service officials insisted a series of salmon ladders be built, leading all migrants into a power canal at Turners Falls.  It failed instantly; yet skewed logic continued.  In 1983 Congress renamed the restoration The Connecticut River Atlantic Salmon Commission.  It continues today. 

Those extinct salmon had only visited here–the southern tip of their range, for a few centuries.  Importing eggs from Canada and Maine, the program proved futile, costing millions annually.  It left the real problem for native shad, herring and endangered sturgeon—a broken Connecticut River, quietly untended.  Those species had returned here for thousands of years.  Bony-plated sturgeon had been vacuuming-up freshwater mussels eons before the present valley took shape. 

On March 11, 1967, the shortnose was listed as “endangered” in the original Endangered Species Preservation Act.  No one knew how they’d survived, or how many remained.  Shortnose were sometimes landed downstream of the 1849 Holyoke Dam; and a few were recorded upstream below Turners Falls.  By 1980, researchers discovered embryos and larvae upstream–proof shortnose spawned somewhere below Turners Falls.

Beginning in 1990, Dr. Boyd Kynard and colleagues began 17 years of continuous federal and state-funded sturgeon research.  Kynard ultimately uncovered the structure of the population, its migratory patterns, and ancient spawning grounds.  A key finding established that all shortnose head upstream to an ancient spawning pool between Greenfield and Turners Falls known as Rock Dam.  Less than 2,000 survive today.  They exist in two groups of a single genetic population, separated over 150 years ago by the raising of Holyoke Dam—which luckily had left some adults upstream with access to spawning.  Fish trapped downstream were out of luck.  

Today, the bulk of the population lives in the river below Holyoke Dam.  Known as “reproductive nulls,” some 1,500 sturgeon linger in a forced limbo created by agencies charged with protecting them.  If one manages to slip into Holyoke Gas & Electric’s fish lift for a spawning ride upstream, it is trapped and pointedly dropped downstream—per orders of the National Marine Fisheries Service and the MA Natural Heritage and Endangered Species Program.  Surviving for 40 years or more, adults will repeatedly attempt to pass the dam until, genetically unfulfilled, they expire.

NMFS, MA NHESP and USFWS claim this protects sturgeon from being sliced up in HG&E’s turbines, if they return downstream after spawning.  All the while HG&E is 5 years in violation of license agreements mandating construction of safe downstream fish passage.  The Federal Energy Regulatory Commission has done nothing to enforce environmental statutes that were key to Holyoke receiving a new hydro license in 1999.

Today, some 300 sturgeon cling to life upstream of Holyoke.  An unknown number are adults.  Some attempt to spawn near Rock Dam each spring (females spawn once every 5 yrs).   According to Kynard et al, success is far from guaranteed.  Unregulated flows emanating from FirstLight’s Northfield Mountain and Turners Falls dam and canal imperil that endangered process.  Annually, spawning fails 79% of the time at Rock Dam; and 29% of the time at a default site just downstream.  Fertilized embryos are also killed when waffling flows flush them out, or leave them parching on river banks.  Many years, no young are produced.

Laws ignored; habitats decimated, river groups mum: it’s a blueprint for extinction.  Yet, amazingly, our dinosaurs persist. It’s this spring’s teachable moment.  Anyone up to a challenge? 

Karl Meyer’s Wild Animals of North America won a 2008 Teachers Choice Award for Children’s Books.  He lives in Greenfield, MA.

March 1st Deadline: Comments to FERC on Northfield/Turners Falls Hydro Relicensing

Posted by on 25 Feb 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Conte, endangerd shortnose sturgeon, EPA, ESA, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Reservoir, Rock Dam, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab

Last Call to send comments and study recommendations to the Federal Energy Regulatory Commission to guide the Connecticut River conditions mandated in the 2018 relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  The licenses will the river ecosystem for decades to come.

To file any comments on the relicensing of the Northfield Mountain Pumped Storage Project and the Turners Falls Hydroelectric Project you will need to register at: www.ferc.gov/docs-filing/efiling.asp

You must include the following project numbers for Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project respectively, with any comments: P-2485-063, and P-1889-081.

All comments are due before MARCH 1, 2013.  Be sure to include your full mailing address, phone number, and email address in your comments. (I’ve attached my comments, which are now registered with FERC, below.)

Karl Meyer, M.S. Environmental Science

Greenfield, MA, 01301                                                             February 25, 2013

To: Federal Energy Regulatory Commission

RE: Comments on FERC Relicensing Projects: No. P- 2485-063 (Northfield Mountain Pumped Storage Project) and No. P-1889-081 (Turners Falls Hydroelectric Project)

Dear Commissioners,

Please carefully adhere to the standard FERC relicensing processes and deadlines as you relicense these two projects.  Holding public and agency site visits in early October 2012 may have been deemed convenient for circumventing winter weather that might have affected visits, however it placed invested parties in the difficult position of having to view and judge hydro operations and configurations at both facilities without the benefit of knowing what operational changes and information FirstLight Power Resources was including in its PAD.

Further, of the three FERC group tours at Northfield/Turners Falls, only one group, mine, was able to view the area of the By-Pass Reach and the Turners Falls Canal and head gates from the downstream side of the Turners Falls gate house.  This is a critical area to view, and the excuse being given was that there was construction happening on the Turners Falls Bridge.  However, unrestricted access to view these sites was available to any passing citizen just yards away via a bike and walking path, open to the public.  My group only received access because I made a direct request to FirstLight’s John Howard, who was my former boss.

The two other tour groups did not get to see the confused flows created by the 14 head gates at the upstream end of the Turners Falls Canal.  The canal has been a major disappointment as the upstream conduit for all migratory fish these last 34 years.  Those head gates are open at full bore during much of the upstream fish migration season; they should have been a key component of the tour.  Nor did interested parties get to view the exposed rock bed and de-pauperizing flow regimes created by flood gate manipulations at the Turners Falls Dam that renders the By-Pass Reach a non-river.  FERC should place particular emphasis on any studies that redirect upstream migrating fish away from the confused and failed conditions experienced in the Turners Falls Power Canal, and send them directly upstream to a lift at TF Dam.  That configuration has worked quite effectively at Holyoke Dam these last 58 years.

In late January 2013, GDF-Suez FirstLight Power Resource representatives noted at public hearings that it intends to apply to FERC with a Proposed Study Plan to begin its own investigations of flows in the reach below Turners Falls Dam this April 2013, rather than the 2014 and 2015 study seasons noted in the FERC Relicensing Process.  No study in this critical segment of river known as the By-pass Reach should be undertaken without a full vetting of the proposals.  This section of river is critical spawning habitat for the federally-endangered Connecticut River shortnose sturgeon, also listed as endangered under the Commonwealth of Massachusetts Natural Heritage and Endangered Species Act.  It is also the age-old upstream route for spawning federal-trust American shad and blueback herring.  It is noteworthy that in their expedited study application that FirstLight cites the area below Cabot Station as a key shortnose sturgeon spawning location, while the critical site for these fish—used for likely thousands of years, is the natural escarpment in the riverbed known as Rock Dam, a half mile upstream of Cabot Station.

In a letter from FERC to Mr. John Howard of FirstLight Power Resources dated March 12, 2010, the Commission noted that FirstLight had failed to comply with Article 34 of the license for the Turners Falls Project, releasing just 120 cubic feet per second to this segment of the river to protect shortnose sturgeon from the effects of low flows.  The minimum requirement is 125 CFS.

With respect to measured, in-depth, long-term investigations on flow and river regulation in this reach I would direct you to the 17 years of research done by Dr. Boyd Kynard and colleagues at the Conte Anadromous Fish Research Center adjacent to this river segment in Turners Falls, MA.  The work was largely conducted via the federal Conte Lab under the US Fish & Wildlife Service and later, under the US Geological Survey, when it took over responsibilities for Conte Lab after 1999.  These investigations were also supplemented by funds, research and personnel from the University of Massachusetts at Amherst.

This research is documented in: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society and produced by Books on Demand, GmbH, Norderstedt, Germany: ISBN 978-3-8448-2801-6.  Copies can be obtained from the North American Sturgeon and Paddlefish Society:

www.nasps-sturgeon.org/#!publications  Chapter 3 concerns the long-term study of flows and river regulation on spawning success of the last 300, spawning-capable, federally endangered shortnose sturgeon in this river system—covering the period of 1993 – 2005.  This is critical, long-term research that includes seven years of findings from the time before Northfield Mountain Pumped Storage and Turners Falls Hydroelectric Project operated as a regulated utility, and the seven years when Northfield’s pumping was unconstrained by regulations and operated to profit from price spikes and drops in the energy spot market using the public’s river.  Deregulation was fully implemented here in 2000 or thereabouts.  All of these issues need careful consideration before sanctioning a rushed study plan in such a critical river reach.

When considering a new license for these facilities, careful consideration of the public’s interest should be made respecting the changes and power generation, flows, and operational practices from the commencement of the current licenses down to the present.  In 2012, Northfield Mountain Station added 40 megawatts of power to its generating facilities through retooling two of its turbines.  This increase nearly equals the total power generated at HG&E’s Holyoke Dam, the next downstream project licensed by FERC.  Two remaining turbines await power up-rates, which is a considerable addition to the generation at this plant, originally proposed and installed at 1,000 megawatts.  Currently, due to mid-license changes, it now produces 1,119 megawatts of power in an unregulated power market. noteworthy and important to be considered in weighing the public’s right to a living ecosystem, upstream fish passage, and protection of endangered species, is that Northfield Mountain’s original license was for a plant used to create “peaking power, and as a reserve unit.”  It can only produce 6-8 hours of stored power before it is spent and needs to purchase replacement power on the open market.  Its stated intention was to peak twice daily in high-demand winter and summer months, and once a day during shoulder months in spring and fall when energy demand is low.  Northfield now generates when demand is present, or—when energy prices will make the greatest profit for investors.  The river and the states have been impoverished by this profound change.

The building of Northfield was based on the availability of current and proposed power from collected regional nuclear sources (New England Power Pool) that included Maine Yankee (closed 1997); Yankee Rowe (closed 1992) Connecticut Yankee’s Haddam Neck (closed 1994), as well as two proposed nuclear plants at Montague, MA (never built.)  Vermont Yankee is currently the only “local” nuclear plant still operating, and its 40 year operating license expired March 21, 2012.  Its continued operation is contingent on findings in the courts.  It is currently operated at a loss by Entergy, and has a failing condenser system which could force its closure.  In short, Northfield is now operated well beyond the bounds of its originally stated purpose.  The public’s river is paying a high price for power, much of it now imported to pump river reserves uphill to Northfield’s reservoir from sources outside the region.  The ecological impacts to fish runs and the damaging flow regimes imperiling endangered species in the river are apparent.

As a facility with great ecological impacts that cannot produce any of its own power–one totally dependent on outside sources for power, one proposal for using this stored power source put before the Federal Power Commission in the 1960s was that Northfield not operate during the spring fish migration due to its impacts on the runs.  It is time to revisit the option of silencing the effects of Northfield Mountain so that towns and cities including Greenfield, Montague, Gill, Turners Falls, and Northfield, MA; and all the towns north to Vernon, Brattleboro and Bellows Falls, VT, and Hinsdale and Walpole, NH receive their share of the river’s ecological bounty.

Northfield does serve a function as an emergency “reserve unit” for ISO New England (Independent Systems Operator) during times of severe heat waves, or high winter demand, to deliver a high volume of power on short notice to accommodate spikes in the power grid.  Northfield could be taken off-line and kept in reserve to be operated by ISO New England solely for that purpose during the low-demand spring energy months when fish are migrating.  This would greatly benefit river ecology, species, and all upstream stakeholders.  New England’s power grid resources are currently rated at 15% above demand.  Removing the damaging effects of these operations on river ecology during critical months is a simple, equitable solution.

Northfield and Turners Falls have greatly profited by incremental power increases and operational changes over the past 34 years, while the public has watched flows, regulation, and conditions in the By-pass Reach wither to a brutal, feast-or-famine regime that denies spawning for endangered fish, and passage for upstream migrants.  This situation has effectively privatized the 2-1/2 miles of river, depriving my town, Greenfield, as well as Gill, of its share of fish and a river.  This de-pauperization has impacted all the towns upstream of Cabot Station and Turners Falls dam into central Vermont and New Hampshire.  None of these municipalities have received compensation, though in many states the loss and damage to these fish populations would be considered “take” under state statutes.  Damage in the By-Pass Reach to the Connecticut River’s last 300, spawning-capable Connecticut River shortnose sturgeon carries a significant federal fine, as well as possible imprisonment.

FirstLight’s new requests for more generation at both licensed sites should be rejected, and the damaging mid-license flow and power increases should be reversed in any new license.  Indeed, since there have now been no less than FIVE different owner/operators of this facility in the last 14 years, it would be prudent to grant only the shortest license possible in order to help track and minimize damage to the ecosystem due to operational/managerial changes, and protect the public’s interest in a living river.

Northfield’s impacts have never been fully measured with respect to flows in the By-pass Reach, but it is clear that fish passage is now at, or below, the paltry levels of the 1980s, and just a fraction of the 40 – 60% passage upstream long-targeted by the US Fish & Wildlife Service of fish that had been passed at the Holyoke Fish Lift.  Regulated, continuously monitored flows should be returned to the By-pass Reach at this time, and continuous monitoring should be included in any new licenses issued.  FirstLight has noted that in-stream data loggers for river levels and flow have been subject to vandalism.  Continuous camera monitoring of river levels and open and closed gate positions at the Turners Falls Dam would go a long way toward insuring compliance with any new license conditions.  This is an inexpensive solution that could easily include a back-up system.

With a federally endangered species present in the By-pass Reach, as well as federal-trust migrating American shad and blueback herring, FERC would do well to consider enforcing regulated flows in this stretch in accordance with law and statutes in the current license.  NOAA’s National Marine Fisheries Service has had the USGS Conte Lab findings from studies in the By-Pass reach by Kynard et al, in their possession since 2007.  This agency—as well as the MA Division of Fisheries and Wildlife, could intervene at any time.  These impacts are also affecting the success of the federal/state Connecticut River Migratory Fisheries Restoration, begun in 1967, which stipulates that all the states share equally in the bounty of migratory fish—as both a recreational and seafood resource.  In several studies by the Massachusetts Cooperative Fisheries Unit at UMass/Amherst from the 1980s it is noted that blueback herring, (Alosa aestivalis) were noted gathering at the base of Turners Falls Dam, and were also noted spawning in the mouth of the Fall River–just 300 feet downstream of the dam, by then Conte Lab Director Steve Rideout.

Further, in the late 1980s, in another mid-license power up-rate, up to 5,000 CFS was redirected out of the By-pass Reach and into the Turners Falls Power Canal for use by Cabot Station and a refurbished Unit # 1, some 1-1/2 miles upstream of Cabot.  This was undoubtedly another blow to the shortnose sturgeon attempting to spawn at their ancient grounds at the Rock Dam, though sturgeon spawning in the Connecticut here was not confirmed until 1993.

In the PAD, it is noted that FERC had not found any compliance issues during its inspections of these two projects.  However, as well as a failure to release minimum flows for sturgeon in 2009, I would direct you the US Environmental Protection Agency’s August 3, 2010 letter and Administrative Order Docket No. 10-016, sent to Mr. James Ginnetti, FirstLight Vice President, noting violations of the federal Clean Water Act.  FirstLight knowingly dumped up to 45,000 cubic square yards of silt into the Connecticut River below its fouled pumped storage plant in an attempt to clear its tunnels and intake.  This illegal enterprise was undertaken by FirstLight after failing to conduct silt removal in a manner consistent with the “due diligence” stated in its operating license.  This dumping took place throughout upstream fish migration season, May 1, 2010, or thereabouts, and continued until the EPA Cease and Desist Order of August 2010.  At that time, FERC then became involved in this egregious license violation, requesting a full report from Mr. John Howard, Plant Manager, in a FERC letter dated August 10, 2010.

In a subsequent fall meeting with agency and non-profit river interests, a FirstLight representative stated that they did not know how to remove silt from their upper reservoir, and that it had never been done successfully.  That admission came after 40 years of operating their plant.  Hence, the public, and FERC are being asked to grant a new license to operators who have not shown they can successfully maintain their facility without profoundly affecting a navigable four-state waterway and a migratory fish highway.  FirstLight has now asked for deadline relief, and is promising to have a study of siltation completed in 2014.  Perhaps all study decisions should be held in abeyance until that time, 2014—which would comply with FERC Licensing Guidelines.

 

Sincerely,

Karl Meyer

Greenfield, MA

THE RIVER FIX FOR FATAL ATTRACTION

Posted by on 12 Dec 2012 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, ecosystem, endangerd shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, salmon hatchery, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab, USFWS

NOTE: The following piece, slightly edited, appeared earlier this month in Connecticut River Valley publications and outlets in CT, MA, and VT. The original version is below.

http://www.rutlandherald.com/article/20121206/OPINION04/712069975/1018/OPINION

http://www.recorder.com/home/3161519-95/falls-shad-fish-canal

Copyright © 2012, by Karl Meyer

The River Fix for Fatal Attraction

With a salmon hatchery program no longer clouding issues, the US Fish & Wildlife Service, National Marine Fisheries Service, and directors from MA, VT, NH and CT have a singular opportunity to redeem the Connecticut River restoration. They’re currently making choices for restoring migratory fish north to Bellows Falls, VT, begun under the 45 year-old New England Cooperative Fisheries Compact. The decisions stem from the 1965 Anadromous Fish Conservation Act. They’ll seal this ecosystem’s fate at four federally-licensed dams and the Northfield Mountain Pumped Storage Station until 2058.

US F&WS’s Region 5 Director Wendi Weber, John Warner, and Ken Sprankle will join National Marine Fisheries’ Daniel Morris, Julie Crocker, and MA Fish & Wildlife’s Caleb Slater in making the decisions—with input from state directors. Their 1967 mandate is restoration of shad and herring runs to offer the public “high quality sport fishing opportunities” and provide “for the long-term needs of the population for seafood.”

Sadly, in 1980 their predecessors abandoned two miles of the Connecticut to the power company operating at Turners Falls and Northfield Mountain. By allowing privatization of the river at mile 120, they killed chances of passage success for millions of American shad barred from spawning at Greenfield, Gill and Northfield, MA, right to the foot of Bellows Falls at Walpole, NH at mile 172. Unwittingly, they also continued the decimation of the ancient spawning grounds of the river’s last, 300, viable federally-endangered shortnose sturgeon.

Instead of mandating river flows and a direct route upstream to a lift at the dam, they acquiesced to diverting migrants into a power canal. That Rube Goldberg–a three-trick knot of currents and ladders, proved an utter failure to the hundreds of thousands of shad moving upstream annually through elevators at Holyoke Dam. There, via a lift built in 1955, 380,000 American shad streamed north in 1980. It’s the East Coast’s most successful fish passage; it by-passes the city’s canals.

Half or more of those shad swam upstream; but foundered in the treacherous Turners Falls complex. At the dam, just as today, some depleted their energies by treading water for weeks—washed back and forth by a power company’s deluge-and-trickle releases, finding no elevator or upstream entrance. Many eventually turned back, only to be tempted by spill from their power canal. Fish unlucky enough to ascend the ladder there found a desperate compromise. Over 90% wouldn’t exit alive. Just as today, alien habitat and extreme turbulence overwhelmed them. Only 1-in-100 emerged upstream. For the rest, a turnaround spelled almost certain death in turbines. Others lingered for weeks in an alien canal environment, until they expired. Just as today.

This year over 490,000 shad passed Holyoke. Half or more attempted to pass Turners Falls. Just 26,000, or 1-in-10, swam beyond the dam–a percentage consistently reached in the 1980s. This is described as “success” by US Geological Survey Conte Lab scientists, Dr. Alex Haro and Dr. Ted Castro-Santos, after fourteen seasons of canal study. In work garnering annual power company subsidies, they’ve attempted to model that canal is a viable migration path.

I interviewed Dr. Haro in 2007, subsequent to a 1999-2005 study finding shad passage at Turners Falls had plummeted to “one percent or less” directly on the heals of Massachusetts 1999 energy deregulation for the Northfield Mountain-Turners Falls’ complex. I asked why passage had failed there, “I wouldn’t call it failure,” Haro replied. Fish passage saw no significant rebound until 2010, when the effects of GDF-Suez’s Northfield Mountain plant were stopped cold for 6 months—sanctioned by the EPA for massive silt dumping. Likewise, Dr. Castro-Santos’s claims to passage of one-in-ten fish as progress seem deeply troubling when his findings, after 14 years, are just now revealing shad dying “in droves” in that canal, “We don’t know why.”

In 1865, James Hooper, aged 86, of Walpole, NH reported: (from The Historical Society of Cheshire County (NH) “The area just below Bellows Falls was a famous place for catching shad because they gathered there but did not go up over the falls. The fish were caught with scoop nets. One spring Hooper helped to haul out 1300 shad and 20 salmon with one pull of the net.”

Citizens upstream of the 1798 Turners Falls Dam need not accept the dead shad runs and severed ocean-ecosystem of the last 214 years at a dam operated to cull price-spikes from the electricity “spot market.” An 1872 US Supreme Court decision against owners of Holyoke Dam mandates passage of the public’s fish. Nor do citizens from Old Saybrook, CT to Bellows Falls have to accept endangered sturgeon, a lethal canal, and a dead river at mile 120. After 32 years of fatal attraction at Turners Falls, its time to stop steering fish into a canal death trap. Holyoke proves that’s possible.

Karl Meyer is a member of the Society of Environmental Journalists.

The Last, BEST Hope for the CT River: GET INVOLVED!

Posted by on 06 Nov 2012 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, USFWS

The Federal Energy Regulatory Commission re-licensing process for GFD_Suez FirstLight Power’s Northfield Mountain and Turners Falls Power Canal Projects on the CT River officially began with FirstLight’s Notice of Intent to file for two new operating licenses to use our river to make electricity for the next four decades.  Over the next four months–until the end of February 2013, officials from the US Fish & Wildlife Service, National Marine Fisheries Service, and directors of fish & wildlife programs will be meeting to decide the critical studies needed to restore and safeguard the Connecticut River through the year 2058.

FirstLight is anxious to see that the main studies guiding the “restoration” of migratory fish is based on moving migratory fish upstream through their power canal, NOT upstream through the ACTUAL Connecticut River, sitting directly adjacent to their canal.  The Power Canal route has proven a disaster, patently deadly for any river restoration.  After 32 years, and study after study, “improvements” enable ONE fish in TEN, to emerge alive, upstream of the Turners Falls Power Canal passage.  It is a death sentence for any true restoration of the river.

To learn more, tune into a broadcast of Greenfield Community Television’s LOCAL BIAS, with host Drew Hutchinson.  In the program I attempt to explain how complexity is clouding the thinking and priorities of our wildlife officials, and h0w simply requiring the Connecticut River to be allowed to flow through its own bed at critical times is the key to having a working ecosystem for the next three generations to come.

Here’s how you can tune in:

Episode (# 127) will be cablecast Wednesday 5:30pm, and Thursday and Saturday 9pm starting November 7th for two weeks. It will also be available via video on demand at gctv.org sometime next week.

« Previous PageNext Page »