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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

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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