Dr. Boyd Kynard

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CRIPPLED ECOSYSTEM interview with Dr. Boyd Kynard

Posted by on 02 Feb 2018 | Tagged as: Bob Flaherty, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, crippled ecosystem, Dr. Boyd Kynard, Federal Energy Regulatory Commission, Federal Recovery Plan, federally-endangered Connecticut River shortnose sturgeion, Northfield Mountain Pumped Storage Station, Rock Dam


(Above:the de-watered Connecticut River at the Rock Dam, December 4, 2017, CLICK, then CLICK again–and again, to enlarge. Photo Copyright by Karl Meyer, 2017, ALL RIGHTS RESERVED)

A CRIPPLED ECOSYSTEM: retired federal sturgeon expert Dr. Boyd Kynard interviewed about Northfield Mountain Pumped Storage Station reversing the flow of the Connecticut River and its impacts, plus prospects for the long-delayed recovery of this ancient, endangered fish. Listen to the podcast “FERC River Report-River Water for Profit” with Bob Flaherty at www.whmp.com

Fish Futures on a Broken River

Posted by on 04 Nov 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Daily Hampshire Gazette, Dr. Boyd Kynard, Endangere Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, fish passage, Holyoke Fish Lift, National Marine Fisheries Service, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, PSP Investments, Rock Dam Pool, Rutland Herald, shad, Shortnose Stout, shortnose sturgeon, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Vermont Digger

Copyright © 2017 by Karl Meyer, All RIGHTS RESERVED

FISH FUTURES ON A BROKEN RIVER

(NOTE: the following appeared in The Rutland Herald, wwww.rutlandherald.com, and on the pages of Vermont Digger, www.vtdigger.org in October)

It’s been decades since migratory fish on New England’s Great River got a break–bleak since deregulation came to federally-licensed electricity plants on the Connecticut beginning in 1998.

Deregulation turned a regional market into a venture capital free-for-all, opening the door to speculators and foreign interests controlling public resources. In less than 20 years the Vernon hydro station changed hands three times. The Vermont Yankee nuclear plant next door is currently courting a third owner. Downstream the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex flipped four times between investors. Further south, the Holyoke hydro station sold only once in 2002.

None of this proved healthy for an ecosystem.

The post-deregulation decade saw a steep slide in American shad passing Holyoke Dam. After two decades of averages well above 300,000 fish, yearly numbers plunged to near half that—a far cry from the 720,000 passed in 1992. Things were even more desperate at Turners Falls Dam. There, impacted by the massive water appetite and violent, peaking flows sent downstream by the Northfield Mountain Pumped Storage Station, passage dropped below 1% some years. For a decade, just 3 or 4 migrating shad in 100 were tallied emerging alive upstream. Today’s numbers languish near 1980s levels.

The federal license signed by Holyoke Gas & Electric in 2002 required they complete lift improvements at Holyoke by 2008 to pass endangered shortnose sturgeon upriver. Sturgeon were literally unable to spawn–blocked at that dam from reaching their only documented natural spawning site, a fail-safe refuge known as the Rock Dam Pool at Turners Falls. Year-in, year-out, that mandate went unenforced. It was finally met last year.

(Note: below, the flow-starved CT in Turners Falls looking downstream toward Rock Dam.CLICK, THEN CLICK AGAIN TO ENLARGE)

In 2004 federal fish biologist Dr. Boyd Kynard handed results of 15 years of Connecticut River shortnose sturgeon research to the National Marine Fisheries Service. He and colleagues had documented that that Rock Dam spawning site for the only federally-endangered migratory fish on the river was being decimated by industrial practices. Yearly gatherings failed for the few dozen spawning-ready sturgeon surviving upstream of Holyoke—as they attempted to continue a tenuous 200 million year-old genetic line. But NMFS didn’t come to their aid; no watchdog intervened.

Ultimately, decades of research by Kynard and company was compiled into Life History and Behaviour of Connecticut River Shortnose and other Sturgeons, published by the World Sturgeon Conservation Society. After experts at the Europe-based WSCS published the book in early 2012, the US Geological Service (where Kynard retired as a federal fish scientist) began making belated objections, halting all publication for a time. Their objections caused a de facto embargo of its sale in the U.S through that spring.

USGS cited editorial and style concerns in “recalling” three chapters on sturgeon biology and spawning—including the data and text showing industrial flows caused spawning failure at Turners Falls. Nearly a dozen state, federal, and university contributors to the book cried foul, citing censorship and the public’s right to government information. In June, concurrent with press inquiries and a letter from Congressman John Olver questioning the withholding of public science, USGS suddenly withdrew all its objections—days before an article highlighting the issues appeared in The Daily Hampshire Gazette. Federal agencies now had the facts. Yet despite the Endangered Species Act, none took action.

In spring of 2014 a popular beer, Shortnose Stout, debuted in the region. Its label displayed Kynard’s website and highlighted spawning conditions at Turners Falls. The Connecticut River Watershed Council soon stepped up to collect donated profits from its sale, yet those sturgeon were left hanging once more. Today conditions at Rock Dam remain as ruinous as when the first 2004 findings were released.

In 2015 the controversial chapters from Kynard’s book got entered into the public record in the current Federal Energy Regulatory Commission’s relicensing process for Northfield Mountain and Turners Falls. With that science on the record, things changed at federal proceedings. Sturgeon spawning became a key factor in flow discussions for future FERC licenses there mandating river conditions. This June, new restoration targets to meet failed 50 year-old federal Anadramous Fish Conservation Act requirements were released by the US Fish & Wildlife Service. With passage failed for half a century at Turners Falls, new shad targets mandate 397,000 fish passing annually. New owner, Canada Public Pension Investments, will be on the hook to build lifts and safeguard sturgeon spawning.

In August a fisherman near Vernon landed an endangered shortnose sturgeon–a fish thought not to exist above Turners Falls. He took a photo and released the fish, sending the picture to officials who confirmed it; then forwarded it to the National Marine Fisheries Service. There is reason to believe that landing may not be an isolated occurrence. NMFS is taking the confirmed capture seriously. Is a remnant shortnose population clinging to life in Vermont and New Hampshire waters? Did someone release them there? Either way, federal law requires owners at Vernon Dam, VT Yankee and Northfield Mountain to protect the migratory fish of the United States as a public trust. After decades of speculation, it’s high time our fish had their day.

NOTE: author Karl Meyer was the idea-creator and author of the beer brand Shortnose Stout. He neither requested or received any compensation or recognition for his work, which was solely aimed at getting important information to the public.

Shortnose Sturgeon Revival Celebration

Posted by on 20 Apr 2017 | Tagged as: Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, Rock Dam, Rock Dam Pool, Shortnose Stout, shortnose sturgeon, Turners Falls, Turners Falls power canal

Shortnose Sturgeon Revival Celebration, Sunday, April 23, 10:30 am – 12:30 pm
(Click, then click again to enlarge.)

Spring 2017 marks this species’ first free-swimming access from below the 1849 Holyoke Dam to its ancient, upstream Rock Dam spawning site in Turners Falls in 168 years! Join Amherst sturgeon expert and author Dr. Boyd Kynard and environmental journalist Karl Meyer for a visit to the Rock Dam in Turners Falls. The Rock Dam is the only documented natural spawning site for the federally-endangered shortnose in the Connecticut River ecosystem. Kynard covers this ancient creature’s life history and biology. Meyer covers the human and natural history of the spectacular Rock Dam site. Involves a short walk; steep dirt paths. Wear sturdy shoes.

Sunday, April 23rd, 10:30 a.m.–12:30 p.m. Rain or shine; no pre-registration required.
Directions: Cross the 11th St. Bridge in Turners Falls; at first stop sign turn left down G Street. Meet at public lot at end of G Street, just before the entrance sign for the US Conte Fish Lab.

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Posted by on 17 Mar 2017 | Tagged as: Alex Haro, American Whitewater, Andrew Fisk, Bob Nasdor, Caleb Slater, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRWC, Dr. Boyd Kynard, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Holyoke Gas & Electric, John Warner, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Station, PSP Investments, public trust, Relicensing, Sean McDermott, Society of Environmental Journalists, The Nature Conservancy, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey

(Note: the following piece appeared in The Recorder, www.recorder.com, on March 11, 2017 under the heading: “Who will protect Connecticut River?”)

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Copyright © 2017 by Karl Meyer

Canadian investors are looking to purchase the Connecticut River for a few decades, cheap and quick. Canada’s Public Sector Pension Investment Board bought up the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex last year as part of PSP Investments. Their New England power play comes in the middle of the 5-year relicensing process for both facilities. That Federal Energy Regulatory Commission process will decide future conditions impacting this four-state ecosystem for decades.

The long-failed Cabot Station Fish Ladder on the Connecticut and competing flows flushing down the Turners Falls Power Canal’s Emergency Spillway. (Note:CLICK, THEN CLICK AGAIN TO ENLARGE.)

Thus, PSP may soon hold sway over what’s long been the most desolate 10-mile stretch of the entire Connecticut. It includes 2.1 miles of riverbed sitting empty for months at a time below Turners Falls Dam. It also includes the reach where, nearly 20 years back, federal fisheries expert Dr. Boyd Kynard found his boat being yanked backward—the Connecticut pulled into reverse by the suction of the Northfield Mountain Pumped Storage Station while he was drifting for bass a mile downstream near the French King Bridge. Looked at fully, it encompasses the entire reach where a 50 year federal migratory fisheries restoration program has long foundered.

On March 7th, after four years of meetings, thousands of pages of reports–and with volumes of study information incomplete and disputed, owners of these FirstLight-branded facilities are hoping select interests agree to take licensing talks underground. They’ll be fishing for backroom deals at a Boston area hotel well before this process has had a full public vetting. FL wants to take this little party private, fast. They’re asking invitees to agree to an embargo on public information about settlement talks, positions and decisions.

The key phrase in their invitation reads: “Because this meeting is intended to initiate confidential settlement discussions, it will not be open to the press or general public.” That’s FirstLight’s Director of Massachusetts Hydro Gus Bakas. His selected invitees include the National Oceanographic and Atmospheric Administration(Sean McDermott), US Fish & Wildlife Service(John Warner), US Geological Survey(Alex Haro), MA Fish & Wildlife(Caleb Slater), towns including Erving, Gill, Northfield, Montague, the Franklin Regional Council of Governments, The Nature Conservancy(Katie Kennedy), the Connecticut River Watershed Council(Andrew Fisk), and American Whitewater(Bob Nasdor).

That FirstLight stipulation is part of the quick-bait to get stakeholders thinking the time is right to cut deals. Sign-up, shut up; then we’ll talk. Cash out with what you can get for your agency, town, non-profit; or your fun-time rafting interests. Promises from this venture capitalist firm–in what’s become an ownership merry-go-round for these facilities, will surely all come true.

Ironically, many of these invitees descend directly from those who failed to step in and step up for the decimated river here decades back. They’re agencies and so-called watchdogs who failed to enforce laws and conditions negotiated when they were signatories to settlement talks for NMPS and Turners Falls nearly 40 years back–and for the 1999 FERC license negotiated for Holyoke Dam as well. At that site, Holyoke Gas & Electric just finally completed required improvements for endangered shortnose sturgeon last spring. Their license had mandated they be completed in 2008. Eight years, nine–no suits, no injunctions; no action.

Maybe that’s because the Watershed Council’s board chair works for HG & E, or because a significant number of board members are retirees from the region’s legacy power companies. Or, might it be because CRWC receives grant monies from National Marine Fisheries, US Fish & Wildlife, and MA Division of Fisheries, that these agencies were never taken to court for the withering spawning conditions and crippling flows experienced by federal trust American shad and federally endangered sturgeon in the reaches from Turners Falls to Northfield?

So who can our river look to for environmental protections under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act in the future?

Fourteen months remain in this relicensing. Key reports won’t be available until April, while other critical study information won’t be out until July. Some studies may need repeating. The best future for New England’s River will not be well served by quick-and-dirty agreements made in the shadows. Remember, Dear Stakeholders, it’s your names that will be forever associated with the conditions on a future Connecticut River—the river your grandchildren will be relying on. This is no time to sell the Connecticut short. What’s your price for a river’s soul?

Karl Meyer of Greenfield is on the Fish and Aquatics Study Team in the FERC relicensing for the Northfield Mountain and Turners Falls hydro facilities. He is a member of the Society of Environmental Journalists.

(Note: Bob Nasdor is former director of the Massachusetts Commission on Open Government.)

END

CAN NEW ENGLAND’S GREAT RIVER SURVIVE MORE DECADES OF PUMPED STORAGE GENERATION?

Posted by on 12 Mar 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Dr. Boyd Kynard, ecosystem, endangerd shortnose sturgeon, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Montague Reporter, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Vermont Digger, vtdigger.org, WBUR

NOTE: The following piece first appeared on the website of vtdigger.org in late February. It also appeared in print in the Montague Reporter, montaguereporter.org in early March.

Copyright © 2017 by Karl Meyer

Can New England’s Great River survive more decades of pumped storage generation? Long-term FERC licensing could lock out new river-sparing energy storage choices.

Dr. Boyd Kynard, retired federal expert on the Connecticut River’s migratory fish and endangered shortnose sturgeon, tells a story about bass fishing in Massachusetts around 1990. He was drifting near the French King Bridge, a mile downstream of the Northfield Mountain Pumped Storage Station’s subsurface tunnels when he glanced up and realized his boat had switched directions. It was being pulled upstream, “And at a pretty good clip.” Turbines at that Northfield MA plant had sucked New England’s river into reverse for at least a mile. This was nothing new, save that in this instance there was a daytime witness.

October 2, 2010, EPA ordered dredging at the site of Northfield Mountain Pumped Storage Station’s underground suction tunnels on the Connecticut.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

In December a radio feature from Boson’s WBUR entitled “New England’s Largest Battery is Hidden Inside a Mass. Mountain” was rebroadcast widely in the Northeast. Referencing Ben Franklin, James Bond, even the Bat Cave, it painted a rosy future for the 1200 quick-start megawatts stored in a reservoir at the Northfield Mountain Pumped Storage Station. Roaring turbines were noted as company spokespeople staked claim to the plant’s “green” future as they bid to lock-in a new 50 year Federal Energy Regulatory Commission license. The occasional ring of an old phone connected directly to ISO New England–the grid’s “independent system operator,” was described as “the sound of money.”

Altogether missing in that story was NMPS’s violent mining of the Connecticut River. That ecosystem artery was never identified as the sole water source enabling it to regenerate electricity. Prior to Northfield construction the Connecticut had forever run seaward from the Canadian border to the tidal zone near today’s Hartford, CT. But 12,000 years of New England natural history changed in 1972, on the day NMPS came on line.

On January 22, 1974, two years after it began operation using overproduced nuclear megawatts then available on the grid at night to fill a 5 billion gallon reservoir, the Federal Power Commission (today’s FERC) notified Western Massachusetts Electric Company it required their “earliest response” on Northfield’s impacts for a Draft Environmental Impact Statement: “Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows?” WMECO’s lawyers belatedly replied on October 16, 1974, they didn’t have the information. Questions about environmental impacts and reversing rivers went unanswered.

In 1967 a federal Connecticut River migratory fisheries program to restore American shad to historic upstream reaches in Vermont and New Hampshire got underway. That same year the embattled Connecticut River shortnose sturgeon was listed under the Endangered Species Act. Exactly fifty years later recovery goals for hundreds of thousands of spawning shad and thousands of shortnose sturgeon remain utterly unfulfilled. Spawning habitat access for both are impacted by Northfield’s suck and surge flows, which also create daily bank-eroding 4-foot “tides” along this reach, sometimes reaching to 10 feet.

Pictured in a less glowing light, NMPS is a 45 year-old dinosaur–a formerly nuclear-powered, net-loss energy transfer machine hacked out of the bowels of a mountain. With the region’s nukes now shuttered, it runs daily on imported electricity and has never produced a watt of virgin power. Today it’s a quick-start, high-profit operation relying on boatloads of fossil-fueled megawatts purchased in bulk on the wholesale market. Suctioning the river uphill, it later releases those waters down through its turbines in dense pulses—pumping out 25 percent less juice than the virgin power it consumes.

NMPS is not renewable energy, nor anything resembling the public’s idea of hydropower. It reproduces just a fraction of New England’s power at peak times, and peak prices, but can only generate for eight hours maximum. After that it is literally dead, its reserves spent. The Canadian-owned plant must then start consuming juice by reversing its turbines anew, yanking the river backward, sideways, and a mile uphill for hours into its reservoir.

That pumping occurs nightly at rates of up to 15,000 cubic feet per second. Picture 15,000 milk crates filled with a living river–every second for hours at a time. For more than two-thirds of the year the Connecticut’s “natural routed flow”—the water moving into and through this reach, is less than 15,000 cfs. Thus this plant is consuming more water than is entering the river. That’s how to turn an ecosystem on its head. The result is the evisceration of all manner of aquatic life, juiced twice through those turbines—tens of thousands of resident and migrating fish, millions of developing eggs, and their young. There’s nothing more violent you can do to a river.

Now the Canada Public Pension Investment Fund—latest in the decade’s revolving door of four different venture-capital owners of the FirstLight Power Resources-branded plant, is angling to lock those ecosystem assaults in place for another half century through the Federal Energy Regulatory Commission’s 5-year hydro relicensing process.

In its planning stages one model would’ve required Northfield to shut down during fish migration season due to impacts. That didn’t happen. Still, a chance experiment in 2010 gave a belated glimpse of those potential benefits. For half a year, from mid-spring through a hot summer into early November, NMPS sat broken, sanctioned and off-line. But seven miles downstream the migrating shad normally impacted by its violent suck-and-flush flows made great and unexpected gains in tandem with that spring break. Having languished for decades, the federal program to move American shad upstream into Vermont and New Hampshire saw a stunning boost at Turners Falls Dam. Shad passage jumped over 700 percent above the previous ten year average–16,440 shad swam past the dam in 2010, compared to the 2,260 annually over the previous ten years. Though meager, it was by far the best result since MA energy deregulation came to the NMPS reach of river in 1999.

The 5 billion gallon Northfield Mountain Pumped Storage Reservoir, as it sat emptied and idle from May 1st through early November 2010.
(CLICK TO ENLARGE, THEN CLICK AGAIN.)

On that May 1, 2010, NMPS had choked on the tons of silt and eroded riverbanks it constantly sucks into its reservoir. In attempting to clear that mucked-in lake a mile of mud-slumped tunnels resulted. Desperate, they began dumping it directly into the Connecticut at a rate equaling 30-40 dump truck loads a day. FirstLight’s sludge turned a mile of river brown for weeks. A contractor died when a suction hose broke loose.

One of thousands of dump truck loads of sludge the EPA ordered FirstLight to dredge back out of the Connecticut River. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Severe thunderstorms on May 27, 2010 resulted in tens of thousands of western New England power outages, many lasting for days. Yet as a back-up energy plant, Northfield’s sole output that week was more of the 45,000 cubic square yards of muck they’d eventually dump directly into the river. They succeeded for over 90 days, until they got caught. On August 10, 2010, the EPA issued a cease-and-desist order citing FirstLight for “polluting the navigable waters of the United States” under the Clean Water Act.

Major dredging operations continued for months at Northfield where FirstLight had dumped their sludge in the Connecticut for 90 straight days.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

Throughout NMPS’s half-year off-line–and record-breaking summer heat in the Northeast, the purportedly ever-hungry, ever-fragile grid ISO New England claims makes Northfield’s dense, quick-start functions so indispensible, never faltered or failed—not even when the nearby( now closed) Vermont Yankee nuclear plant went down in June to refuel.

NMPS’s main claim to its indispensability came 14 years ago during the 2003 August Blackout. Its quick start power was employed by ISO New England to smooth out Massachusetts’ reconnection to the New York sector of the Northeast’s mega-grid—which had failed due to a computer glitch in Ohio. That sprawling network would have been reenergized regardless, but Northfield’s dense energy provided a convenient assist and made ISO’s job easier. But are rare-hour emergencies enough to justify more decades of NMPS daily destructive use? In truth–what would amount to virtual energy storage monopoly, need not be locked-in, de facto, by FERC as this region’s energy future for decades to come. There are other options.

“Pumped hydro is the most cost-effective way to store electricity,” that story stated flatly. But in September of 2016 the MA Department of Energy Resources and the MA Clean Energy Center released a study: “Massachusetts Energy Storage Initiative: State of Charge.” It noted the Bay State lags behind in innovation and deployed energy storage, ranking 23rd nationally. However, comparing new storage technologies now available to the costs of pumped storage, it noted three that will all readily out-compete pumped storage costs by 2018: Lithium Ion, Flow Battery and Compressed Air Storage.

These local/regional storage solutions are already coming into use in New England. They create distributed generation and safer, more reliable micro-grids—less vulnerable to mass outages and mega-grid cyber attack and failure. They also create jobs. Certainly they are more attractive to consumers than sending local solar and wind across New England to recharge a river-crippling machine—and repurchase that juice later at inflated consumer prices.

That story mentioned Northfield’s 18,000 panel solar array–enough for a few hundred homes. But that tax-deductable FirstLight solar field actually covers the huge scar leftover from acres of EPA-mandated settling ponds—sludge pools required in 2010 when they had to dredge their mountain of muck back out of the river. Also not mentioned were handsome payments NMPS collects when it chooses not to generate any power. They accrue through a FERC mechanism known as “capacity fees.” If “spot market” prices aren’t sweet enough, FirstLight can simply sit their plant idle, collecting ratepayer cash just for their “capacity” to potentially generate. With NMPS as its chief hydro asset, former owner GDF-Suez once told investors 40% of its annual profits had been realized through capacity fees.

FirstLight’s EPA-ordered sludge settling pools and drying pile at the Rt. 63 site covered by a solar panel installation today. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Gus Bakas, FirstLight’s Massachusetts operations director, stated his goal for the 45 year-old plant is to someday see it running wholly on “green” power–solar and wind relayed to it from legions of regional rooftop panels and turbines. That would align with Massachusetts’ new “Energy Storage Initiative,” a 10-year effort purportedly aimed at saving ratepayers “hundreds of millions of dollars” while making the grid more reliable and reducing greenhouse gasses. But wind runs strongest at night and is not plentiful in western New England, while all solar is generated by day. With NMPS’s peak-demand profit model based on sucking up bulk power and the river at night, something seems missing from the equation. Unless there are now plans to again run the river backward by day, when migrating fish are most vulnerable to entrainment.

The Federal Energy Regulatory Commission is charged with supplying reliable electricity at fair costs to the public, while fostering competition and protecting against energy monopolies. All licensing decisions from FERC must also comply with federal law including conditions set under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act. The operation of NMPS continues to prove a stumbling block to the successful execution of these federal acts and policies.

In the near-term, for rare big-grid emergencies, a summer heat-wave or winter cold snap, NMPS remains a credible back-up tool. But Northfield otherwise continues today as an expensive, profoundly-damaging energy relay device whose net-loss operations chew apart a critical four-state artery daily. Given its violent year-round ecosystem impacts, its drag on federal trust and endangered species restoration programs–and the market’s current and emerging alternative energy storage solutions, FERC should not sanction NMPS long-term, as its dominant, de facto, New England energy storage monopoly.

End

Writer and journalist Karl Meyer lives in Greenfield, MA. He has been participating as a stakeholder and member of the Fish and Aquatics Study Team in the five-year FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. He is a member of the Society of Environmental Journalists.

Karl Meyer: Connecticut River power storage plant is an ecological, economic and energy disaster

http://www.wbur.org/bostonomix/2016/12/02/northfield-mountain-hydroelectric-station

NOAA has once-in-a-lifetime Recovery Plan opportunity for sturgeon

Posted by on 17 Jan 2017 | Tagged as: Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, ESA, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeon, Jack Buckley, MA Natural Heritage and Endangered Species Program, Mr. John Bullard, National Marine Fisheries Service, NOAA, NOAA Fisheries Regional Administrator, Regional Director of the National Marine Fisheries Service, Rock Dam, US Fish & Wildlife Service, USFWS, Wendi Weber

KM-Rock Dam program 4-23-16
(Above:crowd attending shortnose sturgeon program at the Rock Dam spawning site, April 2016. Presenters were Dr. Boyd Kynard and me. CLICK and click again to ENLARGE.)

Below is a letter to Regional NOAA Fisheries Director John Bullard requesting immediate action to gather small funds to take advantage of a unique Recovery Plan Step that has literally been waiting in the wings for 167 years. Small Recovery Plan funds are needed to monitor newly-returning endangered shortnose sturgeon as they regain upstream access to their natural spawning reach in the Connecticut River for the FIRST TIME SINCE 1849! Recovery Plan opportunities and low-cost, critical federal science in the public interest come around but once in a Blue Moon.

Please feel free to copy the text of this letter, paste in your own information noting your concerns, and forward to Mr. Bullard and the two other fisheries directors cc’d here. Help these newly-arriving federally endangered Connecticut River shortnose sturgeon successfully SPAWN on their ancient home grounds for the first time in over a century and a half!

Karl Meyer
Greenfield, MA
413-773-0006

Mr. John K. Bullard, NOAA Fisheries Regional Administrator January 16, 2017
Greater Atlantic Regional Fisheries Office
55 Republic Drive
Gloucester, MA 01930
john.bullard@noaa.gov

Dear Mr. Bullard,

I’m one of many New Englanders anxious to see the Connecticut River shortnose sturgeon begin its long-belated recovery here by finally having a chance to regain its documented natural spawning habitat in Turners Falls–and experiencing conditions where it can successfully reproduce. Nine years late license agreements at Holyoke Dam have finally been met allowing SNS to pass upstream in significant numbers. This is literally the first progress made in this species’ name here since it was placed on the original federal Endangered Species List in 1967. And this is the first time since 1849 that these fish will have a real chance at increasing their genetic diversity, as well as their numbers. This is their chance at recovery.

It’s come to my attention that a unique opportunity exists to track SNS in the By Pass Reach of the Connecticut River in Turners Falls this spring. The USGS Conte Lab has proposed a straightforward, acceptable, and verifiable study plan. Apparently all that is needed for this simple study to go forward is $20,000. This is an extremely modest expenditure for your agency. This unique opportunity to collect information in the first season in 167 years that SNS have been able to return upstream to this site will never come around again. This study will document whether these fish are successfully arriving and accessing their chosen age-old spawning habitats. Critical, baseline information.

NOAA’s own banner states it provides science based conservation and management for sustainable fisheries and aquaculture, marine mammals, endangered species, and their habitats. There is no better belated-opportunity to fulfill that mandate vis-à-vis the Connecticut River shortnose sturgeon than to provide the small funding this study requires. Members of your endangered species team are aware of this, and have expressed enthusiasm for this study to go forward. Further, your fisheries colleagues from other federal and state agencies share a common mandate and concern for the SNS’s protection and recovery. This modest study will help to further that end, particularly given that in just 15 months a new federal license will be signed with the new Canadian owners of these hydro installation and facilities whose operation will directly impact the recovery and spawning success of SNS.

This time-sensitive request for small funding can demonstrate due diligence by NOAA in its migratory fisheries and habitat protections mandate here. Please make us proud of NOAA’s shortnose sturgeon Recovery Plan efforts and make these funds available immediately so that this key spring work can go forward. Your colleagues, state and regional directors at USFWS and MA Division of Fish & Wildlife may be able contribute as well as both Ms. Weber and Mr. Buckley have hands-on experience with endangered SNS research. They are being cc’d here. Thank you.

Sincerely,
Karl Meyer
Cc: Wendi_Weber@fws.gov; jack.buckley@state.ma.us

(BELOW: the Rock Dam and its adjacent pool to the left–the sole documented natural spawning site for shortnose sturgeon on the Connecticut River. USGS Conte Fish Lab is a few hundred yards southeast of this site. CLICK to enlarge; then click again.)
P1000433

ONE WILDLY ILL-ADVISED RIDE

Posted by on 31 Jul 2016 | Tagged as: AMC, American Whitewater, Appalachian Mountain Club, Connecticut River Atlantic Salmon Commission, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, Dr. Boyd Kynard, EOEEA, Executive Office of Energy and Environmental Affairs, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, Fish and Aquatics Study Team, GDF-Suez FirstLight, Jack Buckley, John Bullard, MA Division of Fish and Wildlife, NMFS, NOAA, Regional Director of the National Marine Fisheries Service, Secretary Matthew Beaton, Society of Environmental Journalists, University of Massachusetts, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Wendi Weber

The following piece appeared in The Recorder, www.recorder.com on July 30, 2016, under the heading, “Rafting over prime sturgeon habitat unwise; State officials need to be smarter.”

Copyright © 2016 by Karl Meyer

ONE WILDLY ILL-ADVISED RIDE

A photo from May 25, 2016 posted on American Whitewater’s website shows Massachusetts’ Secretary of the Executive Office of Energy and Environmental Affairs Matthew Beaton and his staff lumbering across a small run of Connecticut River whitewater on a large raft. The short rapid they just surfed over is at a place called Rock Dam. It drops directly into a small, crescent-shaped pool–the sole natural spawning and nursery site for the federally-endangered Connecticut River shortnose sturgeon.

That Turners Falls site is the last place you’d want to see the Commonwealth’s highest environmental official rafting in May. Rock Dam is critical habitat for survival of the river’s most endangered migratory fish. There’s no other place like it in the ecosystem. It’s also where the state-endangered yellow lamp mussel was last recorded in this reach. Ecological protection is key to preserving the natural heritage there for future generations.

Why Secretary Beaton was at Rock Dam on the heels of the state’s failure to protect endangered timber rattlesnakes in their remaining habitat is a puzzlement. That site is literally where the Connecticut has long been left for dead. Each spring it is alternately starved and inundated—making spawning and survival of young for shortnose sturgeon nearly impossible. Rapid pumped storage hydro fluctuations also help make successful upstream passage for wild American shad, sea lamprey, and blueback herring a 1-in-10 proposition above Turners Falls.

The EOEEA was joyriding on “test” flows returned there specifically for environmental protection. They were meant to allow wild fish to reenter critical habitats where they might successfully gather; then spawn—in a natural pool that would subsequently nurture developing young in critical weeks lasting through mid-June. Those flows were delineated by John Bullard, Regional Director of the National Marine Fisheries Service, to not drop below minimum thresholds that would drive spawning sturgeon out. NMFS mandated the higher limits through June 3rd to ensure sturgeon had sufficient time there. That meant healing water for the most impoverished 2.7 miles of habitat on the entire 410 mile Connecticut.

The shortnose is a dinosaur-age fish—a yard-long creature with a shark-like tail and toughened leathery “scutes” instead of spindly scales. It’s the second species listed under the Massachusetts Endangered Species Act, and the most exhaustively studied endangered migratory fish in the river. It has long had a federal recovery plan, one now including the boatload of science documenting building blocks necessary for its survival. None call for boaters bashing over them during spawning gatherings, or beaching in shallows where developing embryos shelter. If this iconic fish is ever to begin the road back from the brink of extinction, mandated protections and uninterrupted flows are critical at Rock Dam.

Dr. Boyd Kynard, formerly of the US Fish & Wildlife Service, the USGS Conte Lab and UMass, led the 17 years of studies that documented Rock Dam as the species’ sole natural spawning site in the ecosystem. He recently stated, “As to protection of the pre-spawning, spawning, and rearing area at Rock Dam, exclusion dates for boating should be the same as the dates for water flow, 15 March to 15 June.”

A “watered” Rock Dam had long-offered sturgeons a wide choice of depths and flow levels they could selectively adjust, and readjust to, when natural surface flow or river temperatures fluctuated beyond optimal conditions for spawning. And that cobble and sand pool was ideal for dispersing tiny eggs and young. Only when flow is present does Rock Dam regain its function as an ancient species shelter, protecting early life stages in currents circulating through cobbled shoals.

In the current 5-year Federal Energy Regulatory Commission relicensing process that will govern hydro operations and ecological conditions here for decades, the Connecticut River Watershed Council and Appalachian Mountain Club are jointly advocating new access points into this delicate habitat for whitewater interests. Both have sat at FERC hearings where Rock Dam has been delineated as critical habitat. In joint AMC-CRWC testimony to FERC they’ve argued their interests in increased flows stem from aquatic habitat concerns, as well as recreation desires. Yet it was AMC that posted dates of those ecological study flows to their website, urging whitewater enthusiasts to exploit them: “Fish Study to Provide Paddling Opportunities: May – June 2016”

Secretary Beaton needs better advice.

Several expert appointees represent the Commonwealth on the Connecticut River Atlantic Salmon Commission. Jack Buckley, Director of MA Fisheries and Wildlife studied Connecticut River shortnose sturgeon at UMass. Mr. Buckley’s Anadromous Fish Project Leader Caleb Slater is also well versed on critical Rock Dam habitat. And the US Fish & Wildlife’s Region 5 Director Wendi Weber also sits at that CRASC table. Dr. Weber studied shortnose sturgeon in Georgia’s rivers. Ultimately, turning a failing Connecticut River migratory fisheries restoration in Massachusetts into a success story will require government leaders embracing solid government science.

Karl Meyer is on the Fish and Aquatics Study Team for FERC hydro-relicensing studies of the Turners Falls and Northfield Mountain Pumped Storage projects. He is a member of the Society of Environmental Journalists.

Shortnose sturgeon: ignoring published research

Posted by on 04 Apr 2016 | Tagged as: Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC Comments, Jack Buckley, John Bullard, Julie Crocker, Kimberly D. Bose, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, US Fish & Wildlife Service, USFWS, Vince E. Yearick, Wendi Weber

KM-Rock Dam program 4-23-16P1000433

TOP: Rock Dam program, 4-23-16 (click to enlarge)

Bottom: The ROCK DAM: shortnose sturgeon spawning site (click to enlarge)

The following testimony was submitted on March 18, 2016, to the Federal Energy Regulatory Commission on behalf of the biological needs of the federally-endangered Connecticut River shortnose sturgeon at its sole documented natural spawning site in the Connecticut River ecosystem.

Karl Meyer, M.S.

85 School Street # 3

Greenfield, MA  01301                                       March 18, 2016

 

The Honorable Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, NE

Washington, DC  20426

 

SUPPLEMENTAL INFORMATION: RE: P-1889-081 and P-2485-063, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

Attach to: PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

This additional information is being submitted subsequent to my receipt of a March 15, 2016 letter from Mr. Vince Yearick, Director, Division of Hydropower Licensing, restating FERC’s intention to sanction spring 2016 test flows that are documented to result in spawning failure and displacement of federally-endangered Connecticut River shortnose sturgeon(SNS), at their sole natural spawning site in this river system. Those findings come from 20 years of research conducted by government scientists from both the US Fish & Wildlife Service and the US Geological Survey.

I am submitting an index and key chapters from this exhaustive body of shortnose sturgeon research published in LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4. Chapter 3 directly addresses SNS spawning failure and displacement at the Rock Dam in the Connecticut’s By Passed Reach, and clearly indicates that test flows of 1500 cfs will not be protective of a species listed since 1967 under the federal Endangered Species Act.

From P. 107 (PDF-page numbers and numbers in the actual text are the same), “Spawning failure in unregulated rivers likely occurs, but it should be rare because females have adapted to natural fluctuations in the river discharge. Spawning failure (when fish were present) occurred at MontSR due to river regulation, but spawning did not fail due to peaking operations. Regulation created bottom velocities that were too low or exceeded the preference of females or created a low discharge that either prevented female access to the RockD or failed to attract them.”

Findings and data from pages 101 and 102 should provide further guidance to FERC in reexamining this decision. In his response Mr. Yearick argues that the low test flow of 1500 cfs put forth for Study 3.3.19 is somehow key in making correlations to last year’s American shad passage tests from Study 3.3.2. However, that is by no means clear (note–the 3.3.2 results have yet to be made available to Stakeholders) as that study also included tests flows of 1000 cfs and 6300 cfs—flows also not being included in order to make any useful correlation with Study 3.3.19.

Further, in regard to the failure or oversight in the protective responsibilities of the National Marine Fisheries Service to submit objections in this instance (as well as the USFWS and MA Division of Fisheries and Wildlife, who also have federal and state ESA mandates), those failures in no way release the FERC from its own responsibilities under the federal Endangered Species Act. In FERC’s own words, from: Hydropower Relicensing-Get Involved, A GUIDE FOR THE PUBLIC: “Is the Commission subject to other federal laws? Yes. The Commission must comply with a variety of federal laws, such as the Clean Water Act (to protect water quality), the Endangered Species Act (to protect threatened and endangered plant and animal species) and the National Historic Preservation Act (to protect culturally significant places and historic properties).”

Regarding Mr. Yearick’s citing of Article 34 as permitting the harming of protected species in the current license, he fails to note the following tenets included in that self-same Article regarding continuous minimum flows and modifications thereof: “These flows may be modified temporarily: (1) during and to the extent required by operating emergencies beyond the control of the Licensee; and (2) in the interest of recreation and protection of the fisheries resources, upon mutual agreement of the Licensees for Projects 1889 and 2485 and the Massachusetts Division of Fisheries and Wildlife.”

Please also note that, with the marked improvements shown in American shad passage at Turners Falls in 2015 which appear to correlate well with the significant increases in flow through the By Passed Reach, it is highly unlikely that any of the Stakeholder Agencies would consider requesting a Licensed flow of 1500 cfs when the biological needs and passage of both federal-trust and federally-endangered migratory fish require significantly more volume to fulfill their spawning requirements.

Lastly, 8 years in arrears of its license agreement signed in 2002 for FERC P-2004–to have completed upstream access for federally endangered Connecticut River shortnose sturgeon by 2008, Holyoke Gas & Electric has completed modifications to its fishway. That should allow SNS their first access and reintroduction to their natural spawning grounds in 168 years. In my mind, it would be patently criminal to greet these endangered fish on their first spawning trip upstream since 1849 with sanctioned flows guaranteed to displace them and cause spawning failure.

Thank you for your careful attention to this critical matter.

Sincerely,

Karl Meyer, Fish and Aquatics Study Team, P-2485 and P-1889

Please see attached chapters in PDF format, as well as included index and book cover.

Cc’d via email to:

Brandon Cherry, FERC

William Connelly, FERC

James Donohue, FirstLight

Julie Crocker, NOAA

Bjorn Lake, NOAA

John Warner, USFWS

Caleb Slater, MA Division of Fisheries & Wildlife

John Bullard, Regional Administrator, NOAA Fisheries Greater Atlantic Region

Wendi Weber, Director, USFWS Region 7

Jack Buckley, Director, Massachusetts Division of Fisheries & Wildlife

Dr. Boyd Kynard

Stakeholder PROTEST of FERC Revised Study Plan finding endangering Connecticut River shortnose sturgeon

Posted by on 07 Mar 2016 | Tagged as: Connecticut River shortnose sturgeon, Dead Reach, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Secretary Kimberly Bose, US Fish & Wildlife Service, USFWS

(The following Stakeholder testimony was submitted to FERC on March 4, 2016)

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 March 4, 2016

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

RE: P-1889 and P-2485, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

I protest the FERC finding issued on February 25, 2016 for P-2485 and P-1889 specifically because it sanctions test flows that are documented to cause spawning failure for the federally-endangered Connecticut River shortnose sturgeon (Acipenser brevirostrum) at its only documented natural spawning site, the Rock Dam, in the Connecticut River. FirstLight has proposed and FERC has accepted Study Plan test flows of 1500 cubic feet per second in the CT River’s By Pass Reach for April, May and June 2016. That low level of flow will displace and wipe out a full season’s spawning and rearing of Young of Year life stage SNS at their ancient Rock Dam nursery site.

Though my FERC Stakeholder comments of January 28, 2016 specifically addressed this ESA issue, FirstLight did not respond to the endangerment issue in its RSP revisions. Further, I had made this issue clear to FirstLight and its agents, FERC staff, and key stakeholder agencies in an email delivered on January 20, 2016. I again reiterated the endangered species impacts to those same parties in an email delivered on February 24, 2016. Madam Secretary, I again made my concerns about spawning interference and failure to you and for the FERC record in a letter delivered February 26, 2016. All are available for perusal in the FERC record for P-2485 and P-1889.

Shortnose sturgeon gather at this spawning and nursery site annually between April 22 and May 25 for pre-spawning and spawning. Further, the complex of key biological characteristics of flow, varying depths, and cobble/sand habitat provide SNS with protective options that nurture developing Young of the Year throughout June into July.

According to 17 years of published studies at that site documented by Dr. Boyd Kynard and research colleagues, a continuous minimum flow of 2500 cfs is required to protect sturgeon spawning and rearing at this site. Therefore, I PROTEST the findings of the FERC Revised Study Plan determination issued by FERC on February 25, 2016, and request that only continuous protective minimum flows of 2500 cfs be allowed in this study, and throughout the 2016 SNS spawning and rearing season, as well as all ensuing springs.

The following publication has been referenced in the FERC ILP for these projects by both federal and state stakeholder agencies, FERC, as well as FirstLight and their agents.

“LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4

“Effect of hydroelectric operations on spawning”

Page 101, bottom: “During the 11 yr spawning failed (excluding the failed migration in 2002), when discharge levels were too low for 5 yr and too high for 4 yr. During one yr (2007), discharge during April was both to low and too high. When spawning failed at RockD due to low discharge during 4 yr (1995, 1998, 1999, and 2006)m discharge decreased to <70 m3 s-1 for at least 4 d by 30 April (Fig. 14), the earlier period of low discharge likely marked a threshold making the RockD unattractive to spawning fish.”

Further published data, tables, and required flows necessary in this reach appear on pages 101-102 of LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEIONS.

I would welcome a FERC hearing on this critical ESA issue and would make myself available for testimony. Thank you for your attention to this pressing matter.

Sincerely,
Karl Meyer
Fish and Aquatics Study Team, P-2485 and P-1889

Cc’d via email to:
Brandon Cherry, FERC
James Donohue, FirstLight
Julie Crocker, NOAA
John Warner, USFWS
Caleb Slater, MA Division of Fisheries & Wildlife

FERC Stakeholder comments: Turner Falls Canal ultrasound study

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

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you,
Karl Meyer, Fish & Aquatics Study Team

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