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