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The Connecticut River’s staunch public defense broadens…

Posted by on 02 Jan 2022 | Tagged as: America's best landscaped sewer, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, conservancy, Conte National Fish & Wildlife Refuge, CRC, defense, E-Comments, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Hudson Riverkeeper, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

THE PUBLIC CONTINUES TO STEP UP and defend the Connecticut River against a new half-century of ecosystem destruction.

IN THE LAST TWO WEEKS MORE THAN 40 CITIZENS–and counting, have entered testimony into the Federal Energy Regulatory Commission public record stating that the Northfield Mountain Pumped Storage Project is too destructive to be relicensed.

You can read the latest citizen FERC filings–and get directions for filing your own, further below.

These on-the-record defenses become part of the Federal Energy Regulatory Commission’s input as they ultimately make their “Environmental Assessment” of FirstLight’s full and final license application some months down the road. FERC, too, is mandated to ensure that federal and state environmental laws and statutes are followed when deliberating the issuance of a license.

Will they follow the citizenry and release Northfield’s deadly choke hold on this ecosystem in Massachusetts after 50 years of destruction??

I wish I could promise that will happen. What I can promise is that the MA Division of Fish & Wildlife, the MA DEP, the US Fish & Wildlife Service and National Marine Fisheries Service–all agencies that have failed all these decades to protect and enforce environmental statutes and federal fish passage and protections on the Connecticut this last half century, will CERTAINLY be reading these comments. They will be reading them in the knowledge that people are paying attention as they participate in backroom “final” license negotiations with FirstLight.

WILL THESE AGENCIES, ALL WITH MASSACHUSETTS OFFICES, FINALLY STAND UP for what’s still the Nation’s best landscaped sewer here in the Commonwealth of Massachusetts–AGAINST this deadly, river-reversing scourge crippling an entire ecosystem??

THEY ALL OWE NEW ENGLAND A LIVING CONNECTICUT RIVER!

Why we find ourselves here after half a century is because the river here has been left undefended since the mid-1960s when the Northfield Mountain Pumped Storage Project was first proposed.

The photo above is of a little tourism, chamber-of-commerce Connecticut River promotion paddle that took place in October 2020. That little promo outing left from a site virtually next to the mouth of the Northfield Mountain’s deadly intake tunnels. That’s MA Secretary of Energy and Environmental Affairs Kathleen Theoharides in front of the camera, State Senator Jo Comerford is in the background on the left, and CRC Director Andy Fisk–though not pictured, was also a happy paddling participant that day.

While all were offered turns in front of those cameras and to talk to the print media on FirstLight’s turf–next to the grimmest machine ever installed on the Connecticut, NOT ONE spokesperson or representative took the opportunity to defend a defenseless river; not one made any reference to the grim fate of this ecosystem’s resident and migratory fish…imperiled, just yards away, when they had the opportunity to reach the public through the media.

Rather than green-wash the elephant in the room, any one of them could have offered this truth to the public: This river-reversing machine literally devours millions of eggs and young-of-the year migratory fish produced in a three-state(Vermont, New Hampshire and northern Massachusetts)river reach annually. Instead, they paddled and picnicked.

For comparison, a nearly mirror-image pumped storage proposal was brought up in the mid-1960s by Consolidated Edison for Storm King Mountain on the Hudson River at virtually the same time.

Unlike on the Connecticut, where a “watershed council” had been in business since 1952, the citizens on the Hudson got together and decided to FIGHT against turning Storm King Mountain into their river’s deadly sewer. They fought ConEd in the courts, and defended their Hudson River, openly, in the court-of-public-opinion, for 15 years–and WON. They proudly bragged about their mission, their willingness and duty to investigate, enforce, and prosecute. That’s what bona fide river protection looks like. They forced the state and federal agencies to DO THEIR JOBS! That’s what real watchdogs do.

Do a quick bit of research on Storm King Mountain, the Hudson River Fishermen’s Association, Scenic Hudson, and ultimately, Hudson Riverkeeper, and you’ll see what enforcement and real river defense models–with staff lawyers and enforcement, look like.

HERE, BELOW, you can read a new citizen’s defense–the latest public filings defending our river and it’s ecosystem. Another half century of failure is simply unacceptable:

Document Accession #: 20220103-5007 Filed Date: 01/03/2022
Frank Ribeiro, Bernardston, MA.

Hello
As a concerned citizen of Franklin County, Massachusetts, I have lived in the Connecticut river valley for fifty years. It is truly a wonderful place to live.

In today’s modern world there are many environmental challenges that we face to maintain the balance of nature. The one problem that has been obvious to me over the many years is the constant assault to our beautiful river.

We need to stop this assault and abuse. FirstLight MA Hydro LLC license request to continue operation of the Northfield Mountain Pumped Storage must be rejected.

For the sake of company profits OUR river is out of balance. It needs your help to secure its future and the future of ALL things living who are dependent on its survival in a natural, balanced state.

Please reject this application.

Thank You
Frank Ribeiro

Document Accession #: 20220103-5010 Filed Date: 01/03/2022
Andrew Hutchison, Greenfield, MA.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem. This system is clearly harmful to endangered species, such as the shortnose sturgeon. While the facility has been bought and sold numerous times over the years, the attention to preserving the ecosystem has been ignored repeatedly in search of profits. While private businesses have a right to seek profits for their shareholders, that does not supersede the endangered species act or the right of the stakeholders to a healthy river.

Document Accession #: 20220103-5011 Filed Date: 01/03/2022
Mark Russo, Deerfield, MA.

RE: the request of First Light for re-licensing of Northfield, MA pumped storage facility (FERC project number P-2485). I have serious concerns about the damage caused by this facility to the critically important Connecticut River eco-system as graphically detailed in editorials submitted by Karl Meyer and published in the Greenfield Recorder. If your decision is to renew this controversial license, strong environmental safeguards must be required and regularly monitored; and given the current global environmental crisis, the term of the license renewal should be substantially reduced from 50 years to 25 years or less.

Document Accession #: 20220103-5012 Filed Date: 01/03/2022
Judith Phillips, Northfield, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

Dear Commissioners,
I am seeking to comment on First Light’s relicensing bid for the Northfield Mountain Pumped Storage Station on the Connecticut River.

As a Northfield resident I urge FERC in the strongest possible terms to NOT relicense First Light’s Northfield Mountain Pumped Storage facility for another 50 years for the sake of all aquatic life in our beloved Connecticut River ecosystem. The River is in a perilous position with its ecosystem teetering in these “confidential” final license settlement negotiations between Canada-owned First Light and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries that has been taking place during this December. All that has been discussed and ?agreed to? is being done behind closed doors.

I believe these license settlement negations should be moved out into the light of day and into a public forum.

In addition to the pumping station in Northfield adversely impacting our River by wasting energy from fossil fuels that they burn to send water uphill just so it can flow down back into the river which destroys the fish, and more recently First Light is impacting our tax base. Regarding taxes, First Light is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

For me, in the face of the huge environmental crisis we all are in and the current environmental damage that is occurring daily from the Northfield Mountain Pumped Storage Station, for FERC to renew a 50-year license to First Light’s outdated pumping station should be unthinkable! Further I believe this ancient energy provider, is the exact opposite of sustainability both energetically and ecologically and needs to stop now!

Laura Doughty, Wendell, MA summarized it well.
“If we are to have any chance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It isridiculous to let this corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.”

Please DO NOT relicense the Northfield Mountain Pumped Storage facility for the people and the environment upon which we depend for our continuing survival.

Judith Phillips
482 Orange Road
Northfield, MA

Document Accession #: 20220103-5013 Filed Date: 01/03/2022
Priscilla Lynch, Conway, MA.

I am writing to express my strong opposition to the renewal of FirstLight’s license to operate the Northfield Mountain Pumped Storage Station on the Connecticut River in Northfield, Ma. It is way past time to cease this destructive assault on our environment, the river and its ecosystems. As you know I am sure, this facility uses power from the grid to pull the river’s water back and up the mountain to be released at peak times at peak prices. In the process it churns, chops and spits out fish and other essential aquatic life. At a time when our very best efforts should be to heal and preserve our waters and ecosystems as a means to ensure the very survival of life on earth, it is irresponsible to continue operation of this facility. FirstLight does not offer solutions or healing to our environment. It is foreign corporation making a great deal of money on losses to our environment and our well being. Please consider it your duty to act responsibility and do not renew FirstLight’s license to operate the Northfield Mountain Pumped Storage Station. As public servants, doing so will be doing immense good for those you are intended to serve. By not doing so, you will continue unnecessary extreme environmental damage and loss and will continue to feed the pockets of a foreign corporation at the expense of those you are intended to serve.

Priscilla Lynch
Conway, MA.

BE HEARD!! NOW IS THE TIME to enter on-the-record testimony into the Federal Energy Regulatory Commission’s public licensing process.

HERE’S HOW:

Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

A Connecticut River extinction rebellion

Posted by on 30 Dec 2021 | Tagged as: American shad, blueback herring, Clean Water Act, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Death-Sewer, Delaware LLC, E-Comments, Environmental Protection Agency, EPA, Extinction Rebellion, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC licensing process, FirstLight, FISH and Wildlife Refuge??, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, nuclear power, P-2485, pumped storage, right-to-know, shad larvae, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, USFWS

A VIRTUAL CONNECTICUT RIVER extinction rebellion has been taking place in the region over the last 10 days. Since December 20, 2021, over three dozen people have gone on the record with the Federal Energy Regulatory Commission stating, unequivocally–and in the clearest terms, that NO new license should be issued for the continued operation of the Northfield Mountain Pumped Storage Station by FirstLight. You can read testimony from the latest thirteen people in the text that follows.

Many have taken this action upon being apprised of some of the most basic information about the high stakes games for the Connecticut’s four-state ecosystem being played out behind closed doors right now. Many learned of this through my Opinion piece, “Last light for New England’s Great River” that appeared in the Daily Hampshire Gazette and The Recorder on December 2oth and 21sth, https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152 .

It outlined the perilous place our ecosystem is teetering in as “confidential” final license settlement negotiations between Canada-owned FirstLight and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries have been taking place during this month.

This citizen action has galvanized amidst the great void of leadership and wholesale lack of enforcement of any and all state and federal environmental statutes on the Connecticut River in Massachusetts these last 49 years. It’s been a half century of predation on a Connecticut River wholly lacking in a watchdog–in a state where a devastated 23 mile-long ecosystem reach literally flows backwards for miles at times, and virtually millions of resident and migratory fish are been obliterated, annually by the massive, daily, energy-squandering suction of Northfield Mountain’s turbines in their venture capital electricity resale boondoggle.

juvenile Connecticut River shad, dead

* *and this killing is NOTHING compared to the millions of juvenile fish extinguished at Northfield annually. Shad a just one species out of two dozen inhaled and obliterated there–an annual extirpation of literally hundreds of millions of juvenile and adult fish, eggs, and aquatic creatures each year.

Today in Massachusetts the Connecticut River at Northfield remains the deadliest “Nation’s best landscaped sewer”–far more drop-dead-deadly for fish and aquatic life than in the decades prior to the Clean Water Act.

I’m certain, if this river had a voice it would be raising it now to say thank you to the folks below, and the many others, who are taking a stand to save the soul of this ancient ecosystem. To read their words, please follow down.

* * ALSO, as we are at the holiday break, there is STILL time to enter your own on-the-record testimony to FERC. This ecosystem does not belong to FirstLight, or the Commonwealth, or the “environmental” agencies that have so long failed to protect it. It belongs to the children of the future. HERE’S HOW TO ENTER YOUR TESTIMONY:Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

THIS is the giant mess in 2010 made when Northfield operators failed at flushing out the accumulated muck, detritus, and death that had been sucked up from the river into their 4 billion gallon reservoir for years. They clogged their mile-long suction tunnels with several feet of mud, and later got caught and ordered to CEASE AND DESIST by the EPA, after dumping truck-load after truck-load of polluting muck directly into the river for over 90 days straight. In direct violation of the CLEAN WATER ACT. This is the MASSIVE RIVER DREDGING OPERATION the EPA ordered. Northfield went down for over HALF a year, yet everyone’s lights stayed on…

* AND HERE ARE THOSE WORDS OF SOME OF THE OTHER FOLKS CURRENTLY TAKING A STAND:


Document Accession #: 20220103-5000 Filed Date: 01/03/2022
Laura Kaye, Northfield, MA.

Dear Commissioners,
I would like to add my voice to those of my neighbors and fellow citizens of Massachusetts, who have written many thousands of words to you in support of our great Connecticut River, which has been so adversely impacted by the pumping station in Northfield – from the waste of energy from fossil fuels burned to send water uphill just so it can flow down back into the river, to the destruction of fish, and more recently impacting our tax base. Please read the detailed comments that so many people have sent to you and DO NOT approve the re licensing of the Northfield Mountain Pumping Station. For the people and the environment upon which we depend for our continuing survival.

Document Accession #: 20211230-5080 Filed Date: 12/30/2021
Mary Hall, South Hadley, MA.

I am seeking to comment on FirstLight’s relicensing bid for the NorthfieldMountain Pumped Storage Station on the Connecticut River.

I consider it is past time for that Pumping Storage Station to cease operation. The ecological costs of operation, as detailed by Karl Meyer of Greenfield, Mary J. Metzger of Westfield, and others is far too great for continued use of this facility to be justifiable.

Mr. Meyer explains how, in order to continue operations, FirstLight has undertaken to avoid tax payments for its use. In the event the facility was economically viable, it would not be necessary to obtain a tax shelter for it to continue to operate.

The Northfield Mountain Pumped Storage Station is a giant counterbalance to all of our efforts to maintain and restore our Connecticut River ecosystem. There is nothing anyone can do in advocacy for fish and other aquatic life that can remedy the harm that the Storage Station produces. To say again: The fact that FirstLight thought they needed a tax shelter for the Storage Station testifies to the fact that, even as a business, it is not economically viable.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem.

Document Accession #: 20211230-5007 Filed Date: 12/30/2021
Laura Doughty, Wendell, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

I urge FERC in the strongest possible terms: Please do NOT relicense First Light’s Northfield Mountain Pumped Storage facility. If we are to have anychance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It is ridiculous to let this
corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.

Document Accession #: 20211230-5000 Filed Date: 12/30/2021
James Smethurst, Deerfield, MA.

I am writing to oppose the relicensing of the Northfield Mountain Pumped Storage. It has had a devastating impact on aquatic species in the Connecticut River, some of which, like the shortnose sturgeon, are endangered. It serves no useful purpose other than to provide profits for out of state investors. It is not a renewable energy source, but actually an energy drain, given the power required to pump water from the river uphill. The nuclear power plant whose excess energy Northfield Mountain was supposed to repurpose is no more. It is time to close it down.

James Smethurst
5 Pleasant Avenue
Deerfield, MA

Document Accession #: 20211229-5002 Filed Date: 12/29/2021
Rebecca Robbins, Williamsburg, MA.
Dear FERC,

I am concerned about the fish and other aquatic life that get ground to bits at the Northfield Mountain Pumped Storage Station. Please do not relicense this facility without ensuring the health of the river and the creatures that live in it.

Thank you,
Rebecca Robbins
Williamsburg, MA

Document Accession #: 20211229-5000 Filed Date: 12/29/2021
Betsy Browning, Colrain, MA.

I am writing to voice my opposition to the relicensing of the Northfield Mountain Pump Storage facility. I have learned so much by reading the other letters that I feel morally obligated to add my voice. I grew up within a mile of the French King Bridge and remember the Northfield Mountain project being built. Both Northfield and Erving had great enthusiasm for the bountiful tax money they grew to rely on.

For 49 years the pump storage process has been decimating fish and wildlife along the Connecticut River. Amidst our climate crisis and the threats to species, this living river deserves our protection. Ironically this area is part of the Silvio Conte Fish and Wildlife protected area.

That FirstLight is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

I understand its original plan was to use the excess power from the nuclear plant at Vernon which is now defunct. So using power generated by other means to pump water uphill is now wasteful of resources, outdated, and
impractical.

Someone voiced the brilliant idea that the mountain could be converted to a vast solar site.

Renewing a 50-year license should be unthinkable knowing both the environmental crisis in our midst and the current environmental damage that is occurring daily from the pump storage process.

Document Accession #: 20211229-5084 Filed Date: 12/29/2021
Paul Richmond, WENDELL, MA.

I have a questions why is First Light Power going to sign a new contract
which allows them to continue to use an old technology, which is destroying
the CT River and all life in it. I am speaking of the pumping stations, which sucks up everything in the river and kills it to be pumped out when energy is needed. Storage has been an age old question since we started producing energy. When you have access how to store it. When there was access Nuclear electricity at night when it is consider cheap, they would pump up the water to then release it when they needed electricity at peek times for more money. A reasonable idea if you are an energy company trying to make a profit. Then there is the method you use to do that. Today there are much better batteries being spurred on by alternative energy to address when the sun is shining or the wind is blowing. So why isn’t First Light being asked to stop the old method which was and is destroying the river and store the access energy in batteries, or compressed air storage in the new contract they are about to sign with the state. Please do not sign a new agreement with this in it.

Document Accession #: 20211228-5069 Filed Date: 12/28/2021
Sid Siff, Amherst, MA.

I am writing to oppose the rel icensing of FirstLight’s Northfield Mountain Pumped Storage facility on the Connecticut River. At the time of its inception in 1972, it was considered a renewable energy resource, and in 1975 I visited the site on a field trip for a Natural Resource class I was taking at UMass. There was much banter about the benefits of taking ‘extra’ energy from the nearby Vermont Yankee Power Plant in Vernon, and using it to pump water out of the Connecticut River and up to the top of Northfield Mountain, where it was stored and released to spin giant turbines, thereby creating ‘clean’ energy at times of peak demand. Since that time, not only has the nuclear plant been decommissioned, requiring fossil fuel based energy to operate the pumps, but it is well documented that the effect on the ecosystem of the river has been devastating. Multiple species of aquatic life are sucked out of the river in large numbers and killed, on a daily basis. The river acts as a narrow tidal basin, causing extreme bank erosion. The flow of the river is disrupted, leading to inadequate water levels downstream, and a resulting inability of fish to reach critical spawning habitat. Add to this the fact that the facility uses more energy than it creates, it is clearly not, and never was, a source of renewable energy.

Furthermore, FirstLight has demonstrated a clear disregard for not only every living species in the river ecosytem, but also for the people of Massachusetts, by registering Northfield Mountain and Turner’s Falls hydroelectric facilities into Delaware tax shelters, depriving Massachusetts of any tax revenue.

Perhaps by creating a closed loop system, with a reservoir at the bottom of the mountain that is completely separated from the river, and using any excess offshore wind energy to operate the pumps, Northfield Mountain could be a viable energy source going forward. But in its current state, it’s an outdated, dangerous and extremely harmful and wasteful behemoth that should be put to rest.

Document Accession #: 20211228-5066 Filed Date: 12/28/2021
Graham Hayward, NORTHFIELD, MA.

I do not want First Light’s bid for re-licensing to be approved. All they’ve done behind benefit of closed doors must be moved out into the light of day and a public forum.

This is one of many matters that won’t “fly” anymore and all those involved will be dealt with, these days of theft are over.
Thank you,
Graham Hayward

Document Accession #: 20211228-5065 Filed Date: 12/28/2021
Betsy Corner, Shelburne Falls, MA.
Concerning P-2485 for Northfield Mountain

For the past 50 years I’ve witnessed and read about the damage that the Northfield Mountain Pump Storage facility has caused to the Connecticut River and its inhabitants. Certainly common sense tells us that the kind of system that uses more energy than it produces is antiquated and foolish. It’s clear that relicensing this facility would be done in the financial interests of the owner of the corporation that seems to have power over those who are involved in granting another 50 year long license. Residents of the Connecticut Valley must have a transparent licensing process, not the closed door one that has been on-going. It’s high time to protect the river’s ecology and to look at the big picture of money and politics as it affects all of us in this decision.

Document Accession #: 20211228-5058 Filed Date: 12/28/2021
Dave Dersham, Northampton, MA.

I write to you concerning project number P-2485:
The kinetic energy that FirstLight consumes to push the Connecticut river
backwards and up Northfield Mountain, exceeds the potential energy eventually gained.

Simultaneously, 10s of thousands of small fry become pulverized by being
sucked into the hydro electric turbines placed at the midpoint of this
convoluted design. The result is essentially an aquatic Rube Goldberg killing machine, despite the substandard netting placed in the river meant to divert the inexorable fate of the baby fish.

This procedure, which has been going on for decades, is the exact opposite of sustainability both energetically and ecologically ” and needs to
finally stop.

FirstLight does not deserve to be granted another 50 year license.
Thank you for your attention,
Dave Dersham

Document Accession #: 20211228-5048 Filed Date: 12/28/2021
Garrett D Connelly, Greenfield, MA.

Hello,
I am writing this request that you revoke First Light’s operation permit for the Northfield Mountain Pumped Storage Facility so that you know one more person stands against United States policies that disregard life on Earth and serve only short term profit. And in this case it is a false profit.

FERC employees know short-term profits are small relative to the economic
benefits of a clean and free flowing Connecticut river as well as I do,
probably much better. For this reason I won’t try to fit a list of economic
and environmental benefits from a clean and free flowing river and simply
describe what clear thinking people in the future might do instead.

Visualize a line of pollution sensors across a free flowing river that is so clean it has become a world renowned tourist destination. One of the sensors registers a trace of some cancer inducing chemical and enlightened employees of a future country that cares about life spring into action. Chemical sensors follow the pollution to its source and the activity causing it is stopped and cleaned up.

We all know the energy used by consumer societies is leading to extinction of human life on Earth. The wealth generated by free flowing clean rivers can only happen when energy regulators know how much energy is required by a modern and healthy nation. FERC knows far better than I that the real economy does not require a fake enterprise destroying river life for unreal paper profits so I stop here.

Please think about it from a pro-life perspective and then deny the permit to operate a fake business that destroys real life. Deny the permit that allows operation of the Northfield Mountain Pumped Storage Facility.
Sincerely,
Garrett Connelly

Document Accession #: 20211227-5224 Filed Date: 12/27/2021
Robert F Porzio, Putney, VT.
Bob Porzio, Putney VT

Dear Federal Energy Regulatory Commission,
Please do not grant a new federal license for the Northfield Mountain Pumped Storage Station, P-2485. This plant has done huge damage to the river for the last half century, reversing flows and killing fish while squandering massive
amount of energy. As a Vermont resident it is unacceptable to allow this machine to kill migrating fish that should be reaching our section of river, but are swallowed by this deadly plant on their upstream and downstream travels. We folks upstream are entitled to a thriving river and a share of its migratory fish.

Thank you,
Robert Porzio
Putney VT

Public rejecting new Connecticut River license bid for Northfield Mtn: 49 years of ecosystem predation and waste is enough.

Posted by on 24 Dec 2021 | Tagged as: Connecticut River, Connecticut River ecosystem, E-Comments, Federal Energy Regulatory Commission, FERC, FirstLight, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

Public rejecting new Connecticut River license bid for Northfield Mtn: 49 years of ecosystem predation and waste is enough.

Even at the holiday break a belatedly-informed citizenry is going on the record, while secret talks between FirstLight and US Fish & Wildlife, NOAA Fisheries, MA Fish & Wildlife and MA DEP loom in a shadowy background. Below are the latest citizen filing with the Federal Energy Regulatory Commission. All state that no license should be issued for Northfield Mountain. It is time the devastation ceased.

These were all accepted into the FERC public record on Christmas Eve, people taking a stand for the river that is the lifeblood and soul of this New England ecosystem. SEE BELOW:

(* * NOTE:if you would like to add your voice into the public record concerning the Connecticut River and relicensing, you’ll find simple instructions at the end of this post.)

Document Accession #: 20211227-5000 Filed Date: 12/27/2021
Stephen Kerr, Greenfield, MA.

To whom it ma concern, I am looking to voice my disapproval of thee FirstLight power plant’s usage of the Connecticut river. I believe the damage it causes the river ecosystem (and by extension, the local ocean ecosystem which uses the river as a breeding ground) is not worth the electrical power it’s converted into.

I hope that my concern is taken seriously, as it is also representative of many people I know. Please contact me if you’re able to put this concern into action, or if you know of any further action I can take to help make a change in this system.

Thanks and happy holidays,
Stephen

Nancy Obertz, Westhampton, MA.

Please refuse to relicense this company as they are using my river for their gain. Millions of species are dying from the intense pull of their turbines and they do not help the environment. They dodge tax responsibilities (sheltering in Delaware) and hand out pittance amounts to locals in the guise of “good community partners”. STOP this now. We are not going to sacrifice our beautiful Connecticut river for many more decades of their unchecked degradation.

I have grown up on this river (Ox-Bow in Easthampton) and am sickened by what First Light is doing. I have watched the shad and herring disappear. Yet, this company touts all the good they do for the local fish. This is your chance to have a very long-lasting impact. PLEASE refuse to re-license First Light! History will tell our children of your impact here. Please make that impact a positive one.

Thank you!
Nancy Obertz
Westhampton Mass.

Document Accession #: 20211227-5002 Filed Date: 12/27/2021
Dorothy McIver, Greenfield, MA, MA.

I am writing to voice my opposition to the re-licensing of the Northfield Mountain Pumped Storage Facility. It is not needed to generate electricity with all the new advances in technology and it has had a devastating effect on the fish and other aquatic life who are killed when it is in operation. The river needs to be allowed to heal, and continuing this harmful operation for another 50 years is an affront to all of us who want this shut down, and
a benefit only to those who profit from their own greed and lack of concern for this delicate ecosystem and are in denial of the harm they have done for the past 50 years. Please do the right thing and set our river free to flow where it it will with a revitalization of the life it is meant to sustain.
Dorothy McIver

* * HERE’S HOW TO MAKE YOU VOICE HEARD: Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and use Northfield’s FERC project number, P-2485, to enter your comments.

As Connecticut River secrecy-shrouded talks continue, citizens demand an end to Northfield’s half century of devastation

Posted by on 22 Dec 2021 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Daily Hampshire Gazette, Deerfield MA, E-Comments, Extinction, Federal Energy Regulatory Commission, FERC, FERC license, FirstLight, Greenfield Recorder, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Massachusetts DEP, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, pumped storage, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Daily Hampshire Gazette, The Greenfield Recorder, The Recorder, US Fish & Wildlife Service, USFWS

As secrecy-shrouded Connecticut River licensing talks continue, citizens are standing up to demand an end Northfield’s half century of ecosystem devastation

IN THE PAST THREE DAYS a steady drumbeat of on-the-record calls to end Northfield Mountain’s half century of aquatic carnage, energy waste and ecosystem disruption have been filed with the Federal Energy Regulatory Commission. This speaks volumes about democracy vs. secrecy–and the massive void in leadership, information and environmental enforcement that has been the status quo on this great river for the last 50 years. When there is no watchdog; there is no enforcement.

IN THE FOLLOWING ENTRIES you will find the latest 10 filings by citizens from Foxboro to Amherst, and Northampton, Leeds and Northfield, as well as from Greenfield and Deerfield to Colrain, into the FERC record. All are demanding that no new license be issued allowing the Northfield Mountain Pumped Storage Station to continue savaging our ecosystem.

AFTER reading through that last entry you will find directions for entering on-the-record testimony with the Federal Energy Regulatory Commission. It is important that this is done now, as state and federal fish and environmental agencies are currently in FINAL “settlement” negotiations with foreign-registered FirstLight through the end of this month. THEY NEED TO KNOW exactly where you–their constituents, stand on any selling out of our Great River and its aquatic legacy.

* * The following piece, “Last light for New England’s Great River?” appeared in the Daily Hampshire Gazette on 12/22/2021, after originally running in The Greenfield Recorder on Tuesday, 12/21/2021. https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152

BELOW please find the latest citizen filings with FERC:

UPDATE! This is the ELEVENTH filing, submitted from Stoughton MA early this morning:

Document Accession #: 20211223-5001 Filed Date: 12/23/2021
Steven Wilkinson, Stoughton, MA.

It’s time for F.E.R.C. to fulfill government by, of and for the people, and not the corporations, by stopping the mis-use of our public resources. Restore the Connecticut River’s integrity by ending Northfield’s activities. You owe it to future generations, whose environment and food supply are being adversely impacted by your past decisions. Make it right. Stop this backward company from hurting New England.

Document Accession #: 20211223-5000 Filed Date: 12/23/2021
Amy Rose, Amherst, MA.

Comments on Northfield Hydroelectric License/Re-license Proceedings P-2485
I stand firmly in favor of terminating the license of the Northfield Mountain Pumped Storage Station. It is an experiment that has failed miserably, and it is time to close it down. In addition to killing 100s of millions of aquatic animals in the CT River every year, this illogical project squanders a massive amount of energy pumping water to the top of a mountain. How
absurd! Protect our beautiful CT River and stop this ridiculous project ASAP.Redirect this energy towards investing in solar arrays on developed areas: rooftops, roads and parking lots.

Document Accession #: 20211222-5071 Filed Date: 12/22/2021
Peggy Matthews-Nilsen, Amherst, MA.

Please protect the Connecticut River from the environmental damage that FirstLight’s project will create for decades to come. Please DO NOT relicense FirstLight! Thank you.

Document Accession #: 20211222-5067 Filed Date: 12/22/2021
Sigurd Nilsen, Amherst, MA.

Please do not renew FirstLight’s license due to the ecological devastation to the Connecticut River.

Document Accession #: 20211222-5057 Filed Date: 12/22/2021
Rebecca Tippens, colrain, MA.

Hydroelectric License/Re-license Proceedings
I am quite upset that the process for deciding whether to renew the license for First Light to renew permission for pumped storage has been less than fully transparent. The Connecticut RIVER is a common resource and it is our obligation to insure its health as well as the beings who live in it. We know we are facing an extinction crisis and the pumped storage method, despite assurances to the contrary, kills millions of fish. First Light’s parent owner has been using all the tricks in the book to hide from both regulators and the public, their financial sleuthing that includes relocating their business to tax havens while, green washing their actions to give donations to local non-profits that represent but fractions of their profits but which they use to bolster their argument that they are indeed a green company.

In fact the process of sucking out water to later drop it to create energy (& dead fish), is massively energy intensive. That they want to continue this killing project for the next twenty plus years is beyond abhorrent. It is a moral and ecological travesty that no one should be supporting.

Document Accession #: 20211222-5050 Filed Date: 12/22/2021
Lin Respess, Northampton, MA.

I am writing to encourage you to reject the relicensing of FirstLight’s Northfield Mountain Pumped Storage station on the Connecticut River. For years, it has been destroying migratory fishes on the river in direct violation of the U.S, Fish & Wildlife Service’s published goals for the river, and to restore passage for migratory American shad, blueback herring, and other species, and requiring providing 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 seafood. Please protect this New England ecosystem for future generations by denying relicensing for FirstLight’s Northfield Mountain Pumped Storage Station.

With thanks,
Lin & Tucker Respess, Northampton, Massachusetts

Document Accession #: 20211222-5040 Filed Date: 12/22/2021
Tanya Dragan, LEEDS, MA.

Hello,
I am gravely concerned about FirstLight and the damage caused by the Northfield Mountain Pumped Storage Station on the Connecticut River.

Please do not allow this to continue. Nor continue with the negative impacts they’ve gotten away with for decades. We need to protect future generations.

Do not let their PR/lobbying machine work to ruin the environment.

Regards,
Tanya Dragan
Leeds, MA

Document Accession #: 20211222-5039 Filed Date: 12/22/2021
Pamela Scott, Deerfield, MA.

To whom it concerns.. I read with dismay the plans for this hydro electric project to continue. As a concerned citizen, I urge you to reconsider. These activities will have lasting effects that we can’t even comprehend and will affect us far into the future. Please discontinue this project and stop the senseless slaughter of precious wildlife. Thank you very much for your attention to this email.

Document Accession #: 20211221-5154 Filed Date: 12/21/2021
Ron Bartos, FOXBORO, MA.

The operation of the Northfield Mountain Pumped Storage Station facility is highly detrimental to all life in and around the Connecticut River. It kills millions of the river’s aquatic creatures whenever it operates, and causes an unnatural rise and fall, and reverse current, in the river. The license for the project must not be renewed. There are other more economical and ecological ways to generate electricity.

Document Accession #: 20211221-5127 Filed Date: 12/21/2021
James Seretta, Greenfield, MA.

It makes NO SENSE to allow any company to control a resource that in doing so allows them to make money while killing off the ecosystem of the resource. It would be different if there was no harm right?

What’s most bothersome is how it looks like you’re in bed with these guys. What’s in it for you?? Have you bothered to watch these guys sneak around with their shell companies covering their tracks? Did you ever try to figure out why?? Why sell out to a foreign company that has no interest but to make a profit while pilfering the resource of the home community??

It’s time for you guys to do your job and stand up for this incredible resource. Do you hear an outcry that says these corporate folks are doing great things, we love them, sign them up for another 50 years? Of course not because no one wants it. THE HARM OUTWEIGHS THE GOOD!!! DO YOUR JOB!

Document Accession #: 20211220-5002 Filed Date: 12/20/2021
Glen Ayers, Greenfield, MA.

The Northfield Mountain pump-storage facility should be completely decommissioned and the river restored to allow natural flows. No connectionbetween the Northfield Mountain facility and the CT River should be allowed. This river-killing contraption must be eliminated from the river ecosystem. This continuous destruction has been happening for 50-years and it cannot be allowed to kill the river’s aquatic life for another 50.

The time has come to pull the plug on Northfield Mountain, an outdated, obsolete technology that wastes energy, kills fish and other aquatic organisms, and is only operated to enhance the profit of a corporate investment entity that simply does not care about ecology or the river. The people demand that the Government stop this abuse at once. After 50-years of raping the river on a daily basis, it is time to say enough is enough! DO NOT RELICENSE NORTHFIELD MOUNTAIN PUMP STORAGE!!

Fifty years ago this now-obsolete contraption was foisted upon the river aspart of the Vermont Yankee Atomic Nuke Facility in Vernon, VT. That polluting monstrosity has finally been shut down, but is still contaminating the river ecosystem. Northfield Mountain is no longer connected to the Nuke and it should have been shut down at the same time, but the license has expired and it finally must be shuttered so that the river can begin to recover from 50-years of abuse. Ecological science has developed greatly in the past 50-years, and technological advances have replaced this sort of monstrosity with systems that are more efficient, far less harmful, and have barely a fraction of the footprint that the river destroying Northfield Mountain has on the local ecology. This antique belongs in a museum, as an exhibit on bad ideas that were finally eliminated, like DDT, Thalidomide, and Teflon. There is nothing good about Northfield Mountain, it is a curse on the region, and the damage it has done to the river will take decades to heal. River recovery is not possible until this beast is shut down. The river demands that it be freed from the death grip that has been strangling the life out of the CT River for half a century. The abuse must be stopped. NOW!

I implore you to do your job, and find the spine necessary to shut downNorthfield Mountain. To do otherwise would be inhuman and a gross violation of the public trust doctrine. I ask that you reject the application from First Light Power, deny the relicensing, and require that the owner of Northfield Mountain restore the river ecosystem and functioning that has been ruined by their mistreatment of a living system for these past 50-years. The public has spoken loud and clear, we do not consent to treating our river as a pumping machine for the next half century. We Do Not Consent! Shut Down Northfield Mountain! Shut it down.

HELP RESCUE OUR ECOSYSTEM: Here’s how…

Citizens can still get on the public record before any grim deal is signed. Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and use Northfield’s FERC project number, P-2485, to enter your comments.

Connecticut River secret licensing talks: CITIZENS GOING ON THE RECORD FOR A RAVAGED ECOSYSTEM’S FUTURE

Posted by on 13 Dec 2021 | Tagged as: Connecticut River, Connecticut River ecosystem, E-Comments, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, Greenfield Recorder, Julie Crocker, MA Division of Fish and Wildlife, Massachusetts DEP, Mr. Jesse Leddick, Mr. Mark S. Tisa, National Marine Fisheries Service, net-loss power, NOAA Fisheries Regional Administrator, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Relicensing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Steven Mattocks, US Fish & Wildlife Service, USFWS, Wendi Weber

CONNECTICUT RIVER FINAL SECRET RELICENSING MEETINGS:CITIZENS GOING ON THE RECORD FOR A RAVAGED ECOSYSTEM’S FUTURE

Photo Copyright © 2021 by Karl Meyer

As the closed-door “final” bargaining between FirstLight and government agencies continues this month, more people are going on the record against a new half century of massive annual fish kills, gluttonous power consumption, and rampant ecosystem disruption at the Northfield Mountain Pumped Storage Station. Read further below for new citizen FERC filings and Letters to the Editor highlighting their opposition to issuing a new license for this deadly cash cow.

MA Fish & Wildlife:

HAPPY to manufacture hatchery fish; WRETCHED at protecting the Connecticut River’s ancient migratory fish runs. Photo Copyright © 2021 by Karl Meyer

THERE IS STILL TIME TO GO ON THE RECORD with others who are standing up for a living river!!!

Do you have children, or grandchildren? Or maybe you just understand that licensing a foreign-owned venture capital firm to have virtual control over 23 miles of the Connecticut River for the next 50 years closes off any hint of a participatory democracy for the future generations that will rely on this ecosystem to sustain them. They are looking to us for protection…

The secret dealings with our participating public trust agencies including MA Division of Fisheries & Wildlife, US Fish & Wildlife Service and the MA Department of Environmental Protection are yet to be signed or sanctioned. The agencies will be passing proposals and juicy cash baits incentives back and forth through the end of the month… What’s your price for an ecosystem?

Photo Copyright © 2021 by Karl Meyer

Sending message to FERC, and the media, and your public representatives and agency leaders is the participatory democracy antidote to all the darkness. It takes just a few paragraphs and sends the critical message to leaders: you don’t get to sell off our River’s future. Stand up, stand out, and be heard. HERE’S HOW:

Simply write your remarks in a short document, and include the key FERC project number for Northfield Mountain: P-2485. You can send that letter to your representatives, agency leaders, the media—and lastly, importantly, to FERC to be entered into the public record. GO TO:

www.ferc.gov; then to Documents and Filings; then click on the Quick Links tab for FERC Online on the right; and then go to eComment on the page that opens. Follow the directions for Hydroelectric License/Re-license Proceedings (P – Project Number), use P-2485, and you are part of the public record.

Below are two recent on-the-record entries, to FERC, and the Greenfield Recorder.

Photo Copyright © 2021 by Karl Meyer

Document Accession #: 20211213-5000 Filed Date: 12/13/2021

David B. Keith, Deerfield, MA.
Our local newspaper, The Greenfield Recorder, reported (12/8/21) that a company had agreed to a $1.5 million settlement for a chemical spill leading to the deaths of more than 270,000 fish in a tributary to the Deerfield River, itself a tributary to the Connecticut River.

I am encouraged to see a value put on the fish in the tributary. I cannot, however, understand why one company is (quite rightly) being punished for killing fish in a tributary while another, FirstLight Utilities through its Northfield Mountain Pumped Hydro Storage facility, stands to be very handsomely rewarded for knowingly and persistently grinding up countless fish, including rare species, from the much larger Connecticut River. Please do not grant FirstLight Hydro Generating Company a fifty-year license to deprive us daily of a resource that was just valued at $1.5 million per incident.

And this:

I strongly urge rejection of the application by FirstLight MA Hydro LLC to operate Northfield Mountain Pumped Storage on the Connecticut River in Massachusetts. The pumping station causes an untold number of deaths to aquatic life in the river and extreme disruption of the the river’s natural flow. The natural flows necessary for the life cycles of vertebrates and invertebrates are utterly disrupted, fish and other life forms are shredded going up through the pumps, the flow of the river is reversed during pumping and shallow areas and banks are washed out and eroded as water is later released. No realistic way of preventing this death and disruption exists, even if FirstLight intended to attempt such safeguards.

Firstlight has proven to be a bad neighbor with regard to these abuses and has a record for making false statements with regard to their operation. Furthermore, Northfield Mountain Pumped Storage uses more energy than it creates with its turbines, something that makes no sense in this time of Climate Crisis when energy must be both conserved and non harmful. FirstLight’s license for further operation must be rejected.

Don Ogden
The Envirom Show
WXOJ/WMCB/WMNB
140 Pine Street
Florence, MA 01062

CONSENSUS BUILDS AGAINST RELICENSING NORTHFIELD MTN: YOU CAN STILL BE HEARD!!!

Posted by on 06 Dec 2021 | Tagged as: Andrew Tittler, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, E-Comments, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Secretary Kimberly D. Bose, FirstLight Power, Greenfield Recorder, Julie Crocker, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Mr. Jesse Leddick, Mr. Mark S. Tisa, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, PSP Investments, public trust, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Daily Hampshire Gazette, US Fish & Wildlife Service, Wendi Weber


GREENFIELD MA. November 30, 5:58 am: River protector Dave Dersham of Northampton MA sets out on a 20 mile hike from Greenfield to deliver a “No License to Kill” message to the US Fish & Wildlife Service at their Hadley HQ. Photo Copyright © 2021 by Karl Meyer

YOU CAN STILL BE HEARD!!!!!

*BE PART OF THE “SAVE OUR RIVER” HOLIDAY CAMPAIGN: READ BELOW!*

Public demonstrations, public comments to the Federal Energy Regulatory Commission, and opinion pieces in the media all point to a gelling opposition to any FERC relicensing of FirstLight’s Northfield Mountain Pumped Storage Station. The coalescing opinions cite Northfield’s lethal impact on fish, it’s massive river-reversing ecosystem destruction–plus the profit motives of its Canadian venture capital owners. (* *See the 3 new public comment letters posted by FERC today, 12/06/2021, at the end of this message.)

Last Thursday, December 2, FirstLight gathered behind closed doors with the US Fish and Wildlife Service, National Marine Fisheries, MA Division of Fish and Wildlife, MA Department of Environmental Protection and American Whitewater in what the Canadian-owned company termed “final” settlement negotiations. There was no daylight for the public to bear witness, and no way to know how far they reached toward a final signing agreement on relicensing this disaster or ending heart-stopping ecosystem flow reversals and inhalation of 100s of millions of fish.


RECEPTION at USFWS HQ, Hadley MA, November 30, 4 pm. Photo Copyright © 2021 by Karl Meyer

What’s certain is the big horse-trading was on the table–with our public trust agencies holding our cards in the form of standing up for long-established environmental law and the ecosystem defense that future generations are counting on. Our River, our Refuge, OUR FISH!

Well it ain’t over till it’s over folks! Certainly there are issues not yet fully vetted, emails being exchanged, and last minute changes in the works from the agencies and FirstLight/PSP Investments’ big lawyers.

IN SHORT, nothing has been signed yet!

There remains time to get your comments in to the media, your public trust federal/state agency representatives (emails below), to FERC (address below), and cc’ed to your representatives—all of which are impactful.

HERE IS WHY: in FirstLight’s own words & schedule, filed with FERC November 12, 2021.

“FirstLight MA Hydro LLC submits request for FERC to delay issuance of Ready for Environmental Assessment Notice under P-1889, et al.”

AND, word-for-word, FirstLight’s Timeline to FERC:

“December 2021/January 2022 – parties schedule meeting or meetings of combined groups (fish/flows and recreation/cultural) to discuss overlapping issues. Parties provide status update to the Commission no later than December 31, 2021.

January 2022 – parties work toward achieving a conceptual agreement that can be filed with the Commission on or about January 31, 2022.”


At US Fish & Wildlife HQ, Hadley MA. Photo Copyright © 2021 by Karl Meyer

WHICH is to note FirstLight’s sending the settlement outline “to the Commission no later than DECEMBER 31, 2021.”

THUS, if you make your public statement NOW–ahead of when everyone heads home for the holiday break, you can impact this secret, looming train wreck and help make a difference for future generations. Northfield Mountain has been a half century long disaster. You have the information. Short, concise comments—-to the media, cc’ed to your public trust agency officials, and sent as comments to FERC is what matters NOW. There are 3 new public comments shared below.

Directly below are the federal and state department heads and the public trust officials with long-term seats at the negotiating table:

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

SEND them your Letter; forward it to the MEDIA for the public record—and…

THEN, file it with FERC for the OFFICIAL LICENSE RECORD.
Here’s the final step: TO FERC:

Go to www.ferc.gov . Go to Documents and Filings, or simply find the “file E-Comment” link if you see it. Once there, make sure you have this official number for Northfield Mountain Pumped Storage Station, and USE IT. “P-2485.” In E-Comment you are filing comments under Hydro, in the Washington DC office, c/o FERC Secretary Kimberly D. Boles–and that FERC Project number, again is P-2485. Write in your comments and then hit send. DONE!

THIS ONE IS NEW TODAY! Followed by the 3 filed over the weekend:

Document Accession #: 20211207-5027 Filed Date: 12/07/2021

Mike Cournyn, Sudbury, MA.
Please reject the application for this license. It is hard to express how wrong this system is on so many levels. It is even harder to try and justify usefulness. More power is USED than is CREATED. The death and disruption of the ecosystem for a few dollars profit. I am amazed it was even allowed inthe first place. Please do the right thing.

Document Accession #: 20211206-5059 Filed Date: 12/06/2021

Malcolm G Everett, NORTHAMPTON, MA.
I am writing to express my deep concern about the impact of the Northfield Mountain Pumped Storage Facility on the ecosystem of the Connecticut River. I believe the damage this system causes to species native to the river justifies the non-renewal of its license to operate. I understand it is viewed as a way to meet peak electricity demand, but I think there are better
ways being developed to solve this problem without causing damage to the life forms in the river. The owner of this facility has no right to cause such damage to the delicate systems of life that have evolved long before the facility existed. Thank you for considering my concern.

Document Accession #: 20211206-5009 Filed Date: 12/06/2021

C Grecsek, SUNDERLAND, MA.
I am writing to express my opposition to the re-licensing of the Northfield Mountain Pumped Storage facility. The system costs in energy, and especially in ecological damage, are too high.

The Connecticut River flows backward when the pumps are engaged, an unnatural and harmful process. In addition, the turbines kill countless fish and other river dwellers. The generation of electricity should not need to use so much energy to operate nor should it result in such senseless destruction of an ecosystem.

We have made great strides in the improvement of the Connecticut River from when it was essentially an open sewer, but there is more work to do to repair the harm we have caused, including the cessation of this damaging system.

Thank you

Document Accession #: 20211206-5008 Filed Date: 12/06/2021

robert arbib, cummington, MA.
Please reject the application of Firstlight to operate Northfield Mt.for another 50 years.This pumping station causes terrible disruption of the natural flow of the Connecticut River.I know as I canoe on this section of the river. Natural flows necessary for the life cycles of various vertebrates and invertebrates are disrupted, fish and other animals are shredded going up
through the pumps,the flow of the river is reversed during pumping and shallow areas are washed out and eroded as water is released.Firstlight will say they are addressing these concerns but they will promise anything to get a renewal. Please don’t believe their B.S,

Their model is to use massive amounts of power to pump water up. only to profit through ‘generation’ when rates are higher, It is not worth the damage to the river to generate not really new power but only profits for this Canadian company.

Photo Copyright © 2021 by Karl Meyer

THIS CONNECTICUT RIVER DEFENSE IS SPOT-ON!

Posted by on 18 Nov 2021 | Tagged as: Connecticut River, Connecticut River Conservancy, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, E-Comments, Federal Energy Regulatory Commission, FERC, FirstLight, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-1889, P-2485, Relicensing, State of Delaware, The Nature Conservancy, US Fish & Wildlife Service, USFWS, wildlife refuge

THIS NOTEWORTHY and pointed river defense was sent into the Federal Energy Regulatory Commission on 11/17/2021 and entered into the public record–summarizing the 49 years of ecosystem devastation wrought by the Northfield Mountain Pumped Storage Station. PLEASE READ SHAYLA FREELAND’S FULL FERC FILING FURTHER BELOW.

FirstLight–running the licensing show, has scheduled confidential, endgame license “settlement” talks with the US Fish & Wildlife, National Marine Fisheries, and MA Division of Fish & Wildlife and the MA DEP for this December 2.

IF THERE WAS EVER A MORE IMPORTANT TIME for the public to make its case for a living future for this river ecosystem, THAT TIME IS NOW.

Comments can be written, then copied and pasted into the FERC record by going to www.ferc.gov; then find E-Comment in documents and filings–then be sure to know and INCLUDE in your filing the FERC “project number” for both Northfield Mountain Pumped Storage: P-2485, and Turners Falls dam and hydro operations: P-1889. Note that other people have taken simple further steps by publishing their comments on-line, on web pages, and, importantly, sending out to enter the record in the PUBLIC media.

Shayla’s strong, thoughtful and personal summary puts any filing or public statement made by either the Connecticut River Conservancy or The Nature Conservancy about Northfield’s massive river destruction in Massachusetts to shame. Further, it leaves our public trust agencies–including the US Fish & Wildlife Service, National Marine Fisheries Service, MA Division of Fisheries and Wildlife and MA DEP cowardly silent and liable for a river that’s now staring at a full CENTURY-LONG death sentence in Massachusetts.

By not stepping up, they collaborate on a broken ecosystem and the collapse of one of the Earth’s key cooling arteries. These entities have had 49 years to stand up, to speak out against this deadly machine, to end its killing–to intervene at any number of junctures. None did. Thus, the lethal, heart-stopping pumping at Northfield continues, chewing through the lives of hundreds of millions of eggs, larvae and juvenile migrant and resident fish alike every year.

In a just world this endless, massive fish kill would have been prosecuted decades ago. But not here–not in Massachusetts, where all these entities will meet in secret with FirstLight on December 2nd to decide a river’s fate. Silence and secrecy in a democratic society bear a very close resemblance to complicity and their 49 years of a failure to protect…

In stark contrast, here is a brave person is speaking for future generations–and their right to have a living planet. Thank you Shayla!

“My name is Shayla Freeland and I live in Gill. As some of you might know there is a power plant in Northfield called the Northfield Pump Station. There have been many people trying to prevent Firstlight, the owner of the pump station, from renewing their 50 year license to continue making electricity at the expense of our river. On the bridge over the Connecticut river, crossing into Turners Falls, there have been two protests against this license. Many people have invested their time and energy to try and convey how bad this process is for the environment. Personally I agree with everyone who is trying to prevent this. I live in Gill right next to the river and the dam (Firstlight also owns) so I can see first hand the destruction the station is causing. I am able to see and smell the problems.

The stench that comes from that part of the river can be absolutely horrendous. The turbines of the pump station suck in life and throw out death. When they put up the dam the other side gets very low in water and the sun fries up the bits of fish creating the horrible smell. Below the Turners Falls dam there is also an ancient Shortnose Sturgeon spawning ground and the same thing happens to them as the bits of fish. They fry. They rote. They go rancid. As you can probably tell this is not a naturally occurring problem, it’s a problem caused by Firstlight.

In the night they suck water from the Connecticut River up the Northfield Mountain when electricity is cheap. To get the water up the mountain they have to burn fossil fuels to power the pumps. Not only are they polluting the earth with this dwindling resource (because they made a choice between easy money and protecting our home) they are completely killing and destroying our rivers ecosystem. During the day when demand is high they let the water back down the mountain. As it does this it is going through turbines (which creates the electricity)chopping and killing animals. Twenty-four species have the wonderful chance to meet the
deadly blades of the turbines.Now Firstlight is about to renew their fifty year license.

So they pollute the earth, kill the animals and the river’s ecosystem, but hey they’re making easy money and we’re getting electricity so it’s okay right? No, it’s not. And the electricity they are making doesn’t even get used by the people in this area. It’s getting stored as backup for some city. Not only is the electricity not being used by the local population, but Firstlight is not paying any taxes to the town. They are an LLC based in Delaware so they are not obligated to pay us taxes.

This pump station has no benefit to the people living in this area. We are not getting electricity or taxes. It’s deadly turbines are killing fish and preventing them from helping our river prospure. Firstlight should not be allowed to get their license renewed because all they do is
pollute the planet, kill animals and destroy the Connecticut’s ecosystem, which in turn will affect us too.

HERE, is one citizen taking responsibility for a living river system, and for those who come after us…

The Connecticut River’s MASS. Killer is Northfield Mountain Pumped Storage

Posted by on 23 Oct 2021 | Tagged as: Andrew Fisk, Atlantic salmon, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River clean up, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Death-Sewer, E-Comments, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Gordon van Welie, ISO-NEW ENGLAND, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts Division of Fish & Wildlife, Mr. Caleb Slater, Mr. Charles Baker, Mr. Gordon van Welie, Mr. Jesse Leddick, Mr. Mark S. Tisa, Ms. Donna Wieting, National Marine Fisheries Service, net-loss power, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, source to sea, Uncategorized, US Fish & Wildlife Service, US Supreme Court, Vermont Fish & Game, Wendi Weber

The Connecticut River’s MASS. Killer is Northfield Mountain Pumped Storage, a law-breaking ecosystem disaster

READ Bill Stubblefield’s great river defense to the Federal Energy Regulatory Commission and to those responsible for protecting the public’s Connecticut River for future generations here: BillStubblefield20211022-5051-1

WATCH, HEAR my Friends of the Greenfield Public Library presentation: “LIVING RIVERS FLOW DOWNSTREAM,” a 50 year history of Northfield Mountain’s killing and the officials responsible for stopping its license to kill here:
https://www.youtube.com/watch?v=qs4LHjrjtsc

Below is a list of those responsible for ending this illegal license to kill.

Do share it with your local leaders and representatives. Will they step up and end this ecosystem slaughter for coming generations? Where do they stand? What will they do to stop this killing NOW?

The FOLLOWING OFFICIALS have NO RIGHT to bargain away the life of OUR CHILDREN’s ECOSYSTEM. This is THEIR WATCH. They have a PUBLIC TRUST to defend against Connecticut River Extinction and a 40 year Connecticut River death sentence in Massachusetts:

Ms.Kathleen Theoharides, Secretary, MA Executive Office of Energy & Environmental Affairs
Mr. Charles Baker, Governor of the Commonwealth of Massachusetts
Mr. Andy Fisk, MA Public Representative, Connecticut River Atlantic Salmon Commission, Dir. Connecticut River Conservancy
Mr. Gordon van Welie, President and CEO, ISO-New England
Ms. Wendi Weber, US Fish & Wildlife Service Northeast Regional Director
Ms. Donna Wieting Director of Protected Resources, National Marine Fisheries Service
Mr. Mark S. Tisa, Director of the MA Division of Fisheries and Wildlife
Mr. Caleb Slater, MA Div. of Fish & Wildlife, Anadromous Fish Project Leader CRASC
Mr. Jesse Leddick, Chief of Regulatory Review
MA Division of Fisheries & Wildlife

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future

Posted by on 21 Jul 2021 | Tagged as: 5-year FERC licensing process, Brian Harrington, Catherine Carlson, climate change, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, CRASC, Daniel McKiernan, David Cameron, Donna Wieting, E-Comments, Environmental Protection Agency, EPA, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Comments, FERC Commissioner Richard Glick, FERC Secretary Kimberly D. Bose, FirstLight, FirstLight Power, Gordon van Welie, Holyoke Co. v Lyman, ISO-NEW ENGLAND, Jesse Leddick, Julie Crocker, Kathleen Theoharides, Kimberly D. Bose, Landmark Supreme Court Decision 1872, Local Bias, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, Northfield Mountain Pumped Storage Project, P-1889, P-2485, Peter Brandien, Public Comment period, Public Sector Pension Investments, Rock Dam, Sam Lovejoy, Sean McDermott, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Steven Mattocks, Timothy L. Timmermann, Turners Falls, US Fish & Wildlife Service, Vermont, Wendi Weber

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future Copyright © 2021 by Karl Meyer

Kathleen Theoharides, Massachuetts’ Secretary of the Executive Office of Energy & Environmental Affairs before launching on a PR kayak tour of the river at FirstLight’s dock next to the intake of the Northfield Mountain Pumped Storage Project, October 2020. Photo Copyright © 2020 by Karl Meyer

NOTE: as a journalist and citizen I’ve been a participating stakeholder for nearly a decade in the ongoing Federal Energy Regulatory Commission relicensing process for the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot hydro operations. In that light, I encourage people to first view the half-hour segment of Local Bias, linked below. Then, return to this post and its resource list below for ways to participate in the critical decisions now being made about the Connecticut River. They will impact its currently crippled ecosystem for generations to come.

LOCAL BIAS link: https://youtu.be/IX2Rv2NYq3s

Since 1872 the US Supreme Court has made it the law of the land that migratory fish on US Rivers are guaranteed safe upstream and downstream passage at dams and industrial river sites. That decision was centered on a Massachusetts case at the Holyoke Dam. One hundred forty-nine years later that law remains essentially unfulfilled at an endangered species’ critical spawning and nursery site on the Connecticut River at Montague, MA, as well as at the Turners Falls Dam in that town.

Further, that law remains glaringly unenforced and unimplemented at the Northfield Mountain Pumped Storage Project in Northfield MA, where the river is literally sucked into reverse, and millions of eggs and downstream running juvenile American shad are pulled to their “functional extirpation”(vacuumed to their deaths) yearly, on their way to the ocean from Vermont and New Hampshire spawning reaches. The Commonwealth of Massachusetts has now owed Vermont and New Hampshire—and really all of New England, a living river for almost exactly a century and a half.

Warning sign announcing the dangers of Northfield’s massive intake suction. Photo Copyright © 2021 by Karl Meyer

The current Canadian parent-owners of that net-loss power regeneration/resale site are proposing only an ineffective, seasonal “barrier net” at the vacuum mouth of this facility, the very ‘solution’ that leaves this monstrous sucking in place to kill all those Vermont and New Hampshire produced eggs and baby shad, crippling the prospects for returning adult shad to those states from the Atlantic four years in the future.

The donuts and coffee were on FirstLight for the state officials and representatives taking part in last October’s little PR kayak tour. Photo Copyright © 2020 by Karl Meyer

Northfield Mountain’s net-power-loss energy consumption literally swallows and squanders the entire annual energy equivalents of whole cities and counties as it ravages the Connecticut River, using it as a crushing and deadly energy relay switch.

FirstLight is applying to FERC—backed up by a power-hungry, ecosystem-and-climate-indifferent ISO-New England, for a license to kill for decades to come. Northfield Mountain wastes monstrous amounts of grid energy, while ravaging New England’s critical main ocean connection and planetary cooling artery…

Below are resources available to the public for interacting and participating with the Federal Energy Regulatory Commission in licensing decisions, and government agency officials charged with implementing the public trust on the Connecticut River.

www.karlmeyerwriting.com/blog

NOTE: the landmark US Supreme Court environmental decision centered on the Connecticut River came back in 1872 in Holyoke Company v. Lyman, requiring safe up- and down-stream protection for migratory fish.

Send public comments on relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot Hydro Stations to the Federal Energy Regulatory Commission. The “project numbers” must be included, as well as your name and address, in order to become part of the public record. They should be concise, citing specifics in a paragraph or two, noting Northfield Mountain P-2485 and Turners Falls/Cabot P-1889.

Send via www.ferc.gov, usingE-comment, with the salutation going to: “Kimberly D. Bowles, Secretary.” Those comments can also include a cc to the current chair of the Federal Energy Regulatory Commission: Richard Glick.

Decisions concerning foreign interests and use of the Connecticut River are happening at this time, and the river in Massachusetts has sat largely emptied or dead here for half a century—a situation enabled by the Commonwealth and its officials’ enduring, ugly and pointed environmental neglect.

To gain effect, letters can be cc’d to federal-and-state officials who are the vested stakeholders representing the public in the protection of the river and resources. Those publicly recorded FERC entries can also be forwarded to local newspapers and media outlets.

LIST of executives–plus officials from federal and state agencies who represent the public in protecting the Connecticut, its migratory fish, aquatic animals and habitats through their “conditioning authority” powers:

ENERGY executives in the private/quasi-public sphere:

Mr. Gordon van Welie, President and CEO, ISO-New England, the “independent” system operator:
Phone (413) 540-4220

Mr. Peter Brandien, Vice President of System Operations, ISO-New England:

E-mail: pbrandien@iso-ne.com .

NOTE: Mr. Brandien writes the annual support letter that facilitates the daily commercial damage to the Connecticut wrought by the Northfield Mountain Pumped Storage Project. ISO has never acknowledged to the public that NMPS is NOT essential to the DAILY functioning of the power grid. Instead it encourages and shackles the public to those peak-priced, daily ravages as NMPS is handsomely paid to hold back several hours of reserve emergency-function megawatts for ISO’s 20th Century bulk power grid in case of a rare blackout (like the one in 2003), and also for occasional use–at scattered intervals, in controlling grid fluctuations.

ISO should have ago been curtailed as a functionary for private mega power interests. Today’s grid should already be based on distributed generation and micro-grid functions in this time of climate chaos and cyber crime. Energy and storage should be located nearest to where it is produced and used. Future linking of river-ravaging NMPS to 200-mile-distant wind turbines is wholly criminal when compressed air storage can be located close to metro/industrial coastal centers—including implementation at sites like Everett, Somerset, New Bedford, and elsewhere. That would render the system resilient, local and detachable–and rescue New England’s Connecticut River ecosystem to support generations to come across the next half century.

But, today and into the future, counter to Holyoke Co. v. Lyman, , ISO will happily sell off a US ecosystem’s daily life to foreign venture capital interests, keeping NMPS in lucrative daily play for decades into the future. The bottom line function of ISO-New England—forget ecosystems and climate, is apparently commercial first, and foremost. In their own words: to “protect the health of the region’s economy and the well-being of its people by ensuring the constant availability of competitively-priced wholesale electricity—today and for future generations.” They love to employ the term “clean”, but never elaborate on glaring incongruities, fallacies or impacts. Future generations apparently will have no need of living ecosystems, just an endless stream of “competitively-priced” energy. They NEVER mention energy CONSERVATION…

FEDERAL PUBLIC officials:

For endangered Connecticut River shortnose sturgeon, freshwater mussels, as well as American shad, blueback herring and American eel:
Donna Wieting, Director of Protected Resources, National Marine Fisheries Service, NOAA Fisheries:
Phone: 301-427-8400

Also, for endangered shortnose sturgeon, as well as American shad, blueback herring and American eels: Mr. Sean Mcdermott, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Sean.mcdermott@noaa.gov

Also at NMFS, protecting shortnose sturgeon and their habitat: Ms. Julie Crocker, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Julie.crocker@noaa.gov

For federal protection and enforcement of the Clean Water Act on the Connecticut River: Mr. Timothy L. Timmermann Office of Environmental Review, EPA New England Region 1, Boston MA 02109-3912:

E-mail: timmermann.timothy@epa.gov

For all migratory fish and safe passage on the Connecticut including American shad, herring, and endangered sturgeon: Wendi Weber, US Fish & Wildlife Service Region 5, Hadley MA 01035:

E-mail: wendi_weber@usfws.gov

MASSACHUSETTS state officials:

Kathleen Theoharides, Secretary of the MA Executive Office of Energy & Environmental Affairs 100 Cambridge St., Suite 900, Boston, MA 02114:
Main Phone at (617) 626-1000

For Massachusetts clean water and wetland habitat protections on the Connecticut: Mr. Brian Harrington, Bureau of Water Resources Deputy Regional Director, Massachusetts Department of Environmental Protection, 436 Dwight Street, Springfield MA 01103:

E-mail: Brian.d.harrington@state.ma.us

Also from MA DEP: Mr. David Cameron, PWS Section Chief, Massachusetts Department of Environmental Protection, 436 Dwight St., Springfield, MA 01103:

E-mail: David.cameron@state.ma.us

For state-endangered shortnose sturgeon and all Connecticut River migratory fish in MA: Mr. Jesse Leddick, Chief of Regulatory Review, Massachusetts Division of Fisheries and Wildlife, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: Jesse.Leddick@mass.gov

Also at MA Div. of Fish & Wildlife: Mr. Steven Mattocks, Massachusetts Division of Fisheries and Wildlife, Fisheries, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: steven.mattocks.@mass.gov

How to Submit Comments to the Federal Energy Regulatory Commission (FERC)

Posted by on 16 Mar 2016 | Tagged as: E-Comments, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments

P1000433

PICTURED: The Rock Dam in Turners Falls; the sole documented natural spawning site for the Connecticut River shortnose sturgeon in this ecosystem. (Click to enlarge.)

SUBMITTING INDIVIDUAL COMMENTS TO FERC: This example is from my own recent E-Comments

Write up your Comments in Letter form, FIRST

Compose comments in a Word doc, simple and direct, you are allowed up to 6000 characters in a FERC E-Comment, which leaves room for 3 or 4, concise paragraphs, sample letter at bottom:

Include DATE, your name, address, and phone

Send them care of:

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

You must include Project numbers in your submission: in this case P-2485 and P-1889 (P-2485 is Northfield Mountain; P-1889 is Turners Falls Dam and Power Canal. You can do this after your salutation!) See next two lines.

Dear Secretary Bose,

RE: P-2485 and P-1889, protecting federally-endangered Connecticut River shortnose sturgeon

This is the opening paragraph from my Stakeholder Comment:

“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.”

Complete your Word Doc, end with your “Thank you” name, and town

Below that: indicate any individuals, agency heads or representatives you are cc-ing:

Then …..

It is not required, but you might want to register for a FERC E-Subscription for you chosen Projects, in my case, P-2485 and P-1889: Register as an individual, no affiliation. This will take a little more time, and you may choose not to. But, this way you will be Notified, with a Link to all other’s new Stakeholder Comments as they get posted.

** Also, if you get hung up anywhere along the way call the FERC 800 phone #. They are very nice!
Somewhere along the way you will have had to click on HYDRO Projects. OK, to continue…

Go to: www.ferc.gov
Go to: Documents and Filings
Go to: E-Comment
Click on: E-Comment Bar (“Does not require e-Registration”)
Fill out on-line form: All required fields
Type in the googly characters: in the field at bottom
Hit the “Authorize” button

Then: Go to your email, where you will soon receive a FERC email
Click the link that takes you to your FERC e-Comment file
Your filled-in data: will appear in the boxes

Down below is: the empty TEXT Box–your name and town will appear at the top
(Again, somewhere along you will have had to choose HYDRO Projects, not Oil or Nuclear)
In the Text Box under Docket you will see: Hydro Project Search
Below that is the Box: Enter Docket Number
Type in full project number such as: P-2485, and hit Search
P-2485 comes up, saying Northfield—Tap Plus-Bar at right to SELECT; Plus disappears
Go back in THAT SAME text box and over-write: P-1889, HIT plus-Bar again, and SELECT

NOW: Simply scroll down to the empty TEXT BOX, paste in your comments and HIT: SEND COMMENT

You will pretty quick get a FERC email thanking you for Commenting.
You’ll pretty quick get an email saying it has been received.
If you have signed up for an e-Subscription to “hydro” projects P-2485 and P-1889, within an hour a notice of your comments being entered into the FERC record will appear in your mailbox. Voila!

Click on the link to them, and you can review them. This is pretty satisfying. After which, you will get yours and all everyone else’s Comments and Protests to view. They are now part of the public record, read and reviewed by FERC, the utility, and all other fed/state Stakeholders, as well as available to the public and media.

(NOTE: the full example Comment letter below came in at 4,263 characters, with spaces—so you have some room)

** DON’T forget to copy your letter and forward to any CCs you’ve noted via email.

Pat yourself on the back–your comments are now in the Public Files for these FERC decisions.

(Here is my full comment letter, as example)

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