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“Clean, renewable” labels don’t apply

Posted by on 01 Oct 2018 | Tagged as: Ashuelot River, Bellows Falls, blueback herring, canal shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, crippled ecosystem, Dead Reach, ecosystem, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC Commissioner Neil Chatterjee, FERC license, FirstLight, Fish and Aquatics Study Team, fish counts, fish kill, fish kill on the Connecticut, fish passage, fishway windows, Holyoke Fish Lift, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, nuclear power, PSP Investments, Public Law 98-138, pumped storage, Relicensing, resident river fish, Saxtons River, Scott Pruitt, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vermont Digger, Vermont Yankee

Copyright © 2018 by Karl Meyer All Rights Reserved.

NOTE: the following piece appeared in VTDigger, www.vtdigger.org in September under the heading “Clean, renewable” labels don’t apply when crippling an ecosystem.”

TERMS OF ENTRAINMENT: a Connecticut River History


NOTE:in this photo are over 170 juvenile shad, among the many thousands killed in the recent de-watering of the Turners Falls Power Canal. The power canal is where the bulk of the Connecticut River is diverted into for most months of the year. So, when they drain it, they are killing the river. However, if you look at this photo and multiply that death toll by 10,000 you begin to get some idea of the mortality counts for young-of-the-year shad entrained annually–and un-tallied across nearly five decades, at the Northfield Mountain Pumped Storage Station. (CLICK, then CLICK twice more to enlarge photos.)

At 2:41 p.m. on May 20, 2018, a lone blueback herring appeared in the windows at Turners Falls Dam among a school of larger American shad. It was a small miracle. Barely a foot long, it was the first blueback here since 2005, and there would not be another this spring. Like those shad, its life had already spanned four springs, swimming thousands of ocean miles in shimmering schools. It re-crossed bays and estuaries of seven states and two provinces before reaching this Connecticut River juncture. In doing so it had survived sprawling drift nets and repeated attacks from sharks, bluefish, spiny dogfish, cormorants, seals and striped bass.

All these fish were seeking to spawn and give their young a head start as far upriver as currents, time and temperature would allow. Unfortunately, five miles upstream sat the Northfield Mountain Pumped Storage Station, a river vacuuming machine capable of out-killing all their natural predators. For the next 20 miles they’d be vulnerable to its impacts.

NMPS has inhaled river fish of all species and sizes daily for nearly half a century. Results from a river sampling study Juvenile Shad Assessment in the Connecticut River, were released in June by the US Fish & Wildlife Service and MA Division of Fisheries & Wildlife. They estimated NMPS’s 2017 operations resulted in losses of some 15 million shad eggs and larvae, plus the deaths of between 1 and 2-1/2 million juvenile shad. That’s for just one species.

On April 20, 1967, years before Northfield was built, federal agencies and four states signed the Statement of Intent for a Cooperative Fishery Restoration Program for the Connecticut River, agreeing to restore runs of American shad, salmon and blueback herring upstream to Bellows Falls, Vermont and beyond. The migratory shortnose sturgeon had already been listed as endangered. Continuing today under Public Law 98-138, its mandate requires utilization of “the full potential of the fishery resources of the Connecticut River including both anadromous and resident species,” providing “high quality sport fishing,” and meeting “the long term needs of the population for seafood.”

American shad are still commercially fished today just 60 miles downriver. They’ve provided seafood to this valley for ages, yet most people in Vermont, New Hampshire and Massachusetts don’t know they were promised a “just share of the fishery harvest” back in 1967. All remain without, while shad continue to grace dinner and restaurant tables in Connecticut every spring.

Running on imported power via the buy-low/sell-high model, Northfield can suck the river into reverse for up to a mile downstream. It devours everything captured in that vortex at 15,000 cubic feet per second. Think 15,000 milk crates, for hours, to fill a 5 billion gallon mountain reservoir. The result is 100% mortality for all fish entrained. During peak-use and/or peak-price times—or both, it sends the deadened water back through its turbines as twice-produced electricity.

NOTE: more of the TF Canal kill here in another location–including mostly juvenile shad, but also a bluegill, several mud-puppies, and a young sea lamprey. Again, this is just a whisper of the year round fish kill occurring upstream at Northfield Mountain.

Northfield was built to run off Vermont Yankee’s excess nuclear megawatts. But even after VY closed in 2014, its carnage continued, unchallenged, rather than being relegated to emergency use. Having never produced a watt of its own power, its 46 years of accumulating carnage are yet to be tallied. That herring might have been heading for New Hampshire’s Ashuelot or Vermont’s Saxtons River, and those shad were perhaps steering for the Great Eddy at Bellows Falls. Regardless, any progeny would later face Northfield’s net-loss-power impacts heading downriver come fall.

Currently it pumps mostly at night when Canadian owners PSP Investments can purchase cheap electricity to suction the river uphill. Later it’s released as second-hand juice at peak-of-the-day profits. Promoters claim the benefits of dispersed solar and wind power can’t be realized without first relaying their renewable energy across the region to this lethal storage machine for later resale in markets far beyond the Connecticut Valley. “Clean, renewable” labels don’t apply when crippling an ecosystem.

NMPS boosters include (now-former) EPA Director Scott Pruitt, who made a sweetheart visit there last Valentine’s Day along with Federal Energy Regulatory Commissioner Neil Chatterjee. That occurred as PSP was requesting to suction yet more water from the Connecticut and applying for a new long-term FERC license. The next day FERC announced a major policy shift, potentially increasing both Northfield’s daytime use and its profits.

Since an 1872 landmark Supreme Court ruling indemnifying Holyoke Dam, all hydro facilities have been required to safely pass the public’s fish, upstream and down. But that 1967 agreement had this warning: “Based on the present fragmentary data available on the Northfield Mountain Pumped Storage Project, it appears that this project poses definite limitations to an anadromous fish restoration program. These limitations involve the physical loss of eggs, larvae and young fish of both resident and anadromous species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water.” Today the 20 mile reach hosting Northfield remains a migration minefield—while some 30 miles of open Vermont/New Hampshire spawning habitat above Vernon Dam sits essentially empty.

Holyoke Dam has annually lifted hundreds of thousands of shad and herring upstream since the 1970s. In 2017 it recorded its second highest shad numbers ever, 537,000 fish. Each spring, half or more of those shad attempt to pass Turners Falls. Less than 10-in-100 will succeed. Of those, some 50% drop from tallies and are never re-counted at Vernon Dam after entering the 20 miles impacted by Northfield. The blueback herring record at Turners Falls was 9,600 in 1986, out of the 517,000 counted 36 miles downstream at Holyoke that year. Of those 9,600 Turners herrings, just 94 reached Vernon Dam. Turners Falls saw another 7,500 blueback herring in 1991; just 383 reappeared upstream at Vernon.

Any new long-term FERC license must comply with federal and state law protecting endangered and public-trust fish. In seeking a new license, PSP’s main proposal for limiting Northfield’s massive carnage has been the test-anchoring of a few yards of Kevlar netting in the riverbed in front of the plant’s suction-and-surge tunnel. Those flag-sized yards of mesh, after a few months deployment, are supposed to effectively model how a 1,000 foot-long “exclusion net”–deployed seasonally in the river over the next decades, might halt the entrainment deaths of out-migrating adult–and millions of juvenile young-of-the year fish, heading back to the sea. Presumably, Northfield’s mouth would remain wide open to the ecosystem’s fish throughout the rest of the year.

In light of longstanding research the US Fish & Wildlife Service, Atlantic States Marine Fisheries Commission and Connecticut River Atlantic Salmon Commission have set shad passage goals requiring that a minimum of 397,000 pass Turners Falls; and a minimum of 226,000 pass Vernon Dam. It’s a certainty that a new fish lift will be required at Turners Falls under any new license, modeled on the long-term success of Holyoke’s lifts. But the ultimate question is this: can Northfield comply with federal and state law protecting the four-state ecosystem’s fish in order to be granted a new FERC license?

END

Karl Meyer has been a stakeholder and member of the Fish and Aquatics Study Team in the current FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2012. He is a member of the Society of Environmental Journalists.

Connecticut River shortnose sturgeon: Mother’s Day miseries at Rock Dam

Posted by on 13 May 2018 | Tagged as: Connecticut River ecosystem, Connecticut River shortnose sturgeon, ecosystem, endangerd shortnose sturgeon, FirstLight, Rock Dam, Rock Dam Pool, shortnose sturgeon, Turners Falls, Turners Falls dam

Copyright © 2018 by Karl Meyer. All rights reserved.

MOTHER’S DAY MISERIES AT ROCK DAM

The federally-endangered Connecticut River shortnose sturgeon has just a single, documented natural spawning site in the four-state river ecosystem: the Rock Dam in Turners Falls, MA.

Given the unique structure, depth, and flow characteristics of this ancient rock formation and spawning pool, shortnose have likely returned here for millenia, using it as a fail-safe nursery where they can choose depth, flow, and areas above sand, pebble-and-cobble substrate for spawning that will ultimately come to protect and nurture their young.


(Click, then Click again, THEN AGAIN, to enlarge)
MOTHER’S DAY MISERY AT ROCK DAM: listless flows and exposed cobble shoals where young would develop in safety.

However, this Rock Dam site is assailed annually during sturgeon spawning periods with ramping, see-sawing, and de-pauperizing flows that cause spawning failure for these embattled fish. This year was no different. On Mother’s Day, May 13, 2018, in what is virtually their peak spawning time, flow manipulations just upstream at FirstLight’s Turners Falls dam left the river roaring at Rock Dam one day, and bereft of nourishing flows and watered nursery habitat the next. No mercy on Mother’s Day here…

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

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

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

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

Copyright © 2017 by Karl Meyer

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

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

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

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

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

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

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

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

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

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

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

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

END

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

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

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

Copyright © 2017 by Karl Meyer

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

End

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

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

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

Rolling over on a River: the real cost of pumped storage energy

Posted by on 26 Oct 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River ecosystem, Connecticut River Watershed Council, Daily Hampshire Gazette, ecosystem, Entrainment, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, federally-endangered shortnose sturgeon, FERC, fossil fuels, Greenfield Recorder, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, nuclear power, Public Comment period, public trust, pumped storage, Relicensing, shad, shortnose sturgeon, Society of Environmental Journalists, The Recorder, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vermont Digger, Vermont Yankee

Copyright © 2016 by Karl Meyer

(Note: this essay appeared in September and October in these MA and VT media and newspaper outlets: Vermont Digger, www.vtdigger.org ; The Daily Hampshire Gazette; and The Recorder.)

besttfemptybed

The de-watered CT below Turners Falls Dam that few people see. (Click, then click again to enlarge.)

Rolling over on a river

Since time began rivers have been the Earth’s arteries—the foundation of its ecosystems. Here in New England it’s “last chance” time for our Great River. On April 30, 2018 the fate of the long-foundered Connecticut River migratory fisheries restoration—and the survival of a four-state river ecosystem, will be decided for what’s essentially forever. New Federal Energy Regulatory Commission hydro licenses are expected to be signed then by government agencies and the Canada Pension Plan Investment Board–latest purchaser of the Turners Falls and Northfield Mountain projects. That company’s stated investor mandate is “to maximize investment returns without undue risk of loss.”

Over two generations ago public-trust mistakes were made favoring power companies, fish hatcheries, and high-end salmon-fishing interests that rendered eight miles of the Connecticut in Massachusetts a massively-suctioned, partially-dewatered flush sink. Sanctioned by fisheries agencies and non-profits, those decisions, severed an ecosystem in two. They forced all migrating fish into a deadly power canal, leaving three emptied miles of riverbed below Turners Falls Dam, while four turbines at the Northfield Mountain Pumped Storage Station five miles upstream consumed massive amounts of nuclear energy to suck a river backward and uphill to a mountaintop reservoir.

Those turbines were built to run on the promised endless supply of overproduced juice generated nightly at the local, now-closed, Vermont Yankee nuke, 15 miles away. Today, running on giant slugs of imported fossil fuel, they continue to spin, sucking the river up in endless gulps into a 4 billion gallon pool a mile up Northfield Mountain. That daily suctioning creates riverbank eroding “tides” higher than those at Hyannisport, MA—with some rivaling the ten-foot fluctuations of Fundy Bay.

Back then, predecessors of today’s National Marine Fisheries Service, the US Fish & Wildlife Service, Massachusetts’ Fish & Wildlife and the Connecticut River Watershed Council signed off on an agreement with the Federal Power Commission and Western Massachusetts Electric that strangled the river in northern Massachusetts. It resulted in the failure of migratory fish passage and a promised renewal of the river’s ancient seafood resources upstream to Vermont, New Hampshire, and northern Mass. Few American shad emerged alive after diversion into that canal. It also failed the shortnose sturgeon—this river’s only federally endangered migratory fish, leaving it without flow or monitoring at its only documented natural spawning site.

Upstream at Northfield the destruction was yet more complete. The suck and gush appetite of that nuclear-charged contraption virtually disassembled the river. It gulped flow at a rate of 15,000 cubic feet per second, often for hours at a time—drawing on the river pool above Turners Falls Dam where, 70% of the time, the Connecticut’s natural routed flow is less than 15,000 cfs. Boaters a mile downstream could find themselves drifting upriver via Northfield’s unearthly pull. All fish and organisms drawn up through the sphere of that suction were deemed “functionally extirpated”–dead to the ecosystem by virtue of being sieved twice through the turbines. It was evolution in reverse, a river ripped away from its eternal run to the sea.

Today, climate-blind FERC labels Northfield as a source of “renewable clean” energy—but there’s nothing clean, renewable or sustainable about its imported, twice-produced, peak-priced electricity crippling this river. ISO New England, FERC’s Northfield-cheering, ever-energy-hungry cousin, also ignores climate and its environmental dismemberment. “Pumped storage” is not hydropower—not even by the industry’s own technical terminology. Northfield-produced power in fact represents the heavy planetary burden of fossil fuel used to push a mountain of water uphill, merely as a weight to produce high-cost, second hand electricity. It cares nothing of rivers, fish or ecosystems.

If bureaucrats again fail the public trust and don’t demand critical habitat protections, flows, and the day-to-day monitoring needed to fulfill U.S. environmental statutes, Canadian pension speculators will be left as the de facto controlling interests on our river. The new owners have asked FERC to merge two separate licenses for Northfield and Turners Falls into a single new license dubbed the “Northfield Project.” What’s represented as mere bureaucratic streamlining would actually enshrine, by precedent–next time and forever, river-killing pumped storage.

Any responsible environmental agency should deny this single-license merger, and seek to have Northfield kept in use as emergency infrastructure only—with the ultimate remedy it’s dismantling in tandem with a move to a decentralized, far less vulnerable system than today’s expanding mega-grid. Massachusetts legislators are currently signing onto backroom energy deals for a glut of future hydropower from Quebec. Some 1,200 megawatts of those penciled-in imports could easily replace the few hours of daily juice Northfield puts out–while keeping it available for rare emergencies. Though the new Canadian power imports largely ignore conservation and innovation, they could be employed to end the river carnage here and begin restoring a future for a critical New England ecosystem.

(Note: timely public comment on licensing issues is carefully considered by FERC. Go to: http://ferc.gov/docs-filing/ecomment.asp and use “E-Comment.” Check “Hydro” and address to Secretary Kimberly D. Bose, using the required identifiers “P-2485” and “P-1889” for Northfield and Turners Falls.)

Karl Meyer lives in Greenfield MA. He is participating in the FERC relicensing process and is a member of the Society of Environmental Journalists.

AN INSENSITIVITY OF PLACE

Posted by on 29 May 2016 | Tagged as: 5-year FERC licensing process, AMC, American Whitewater, Appalachian Mountain Club, By Pass Reach, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments, Gary Sanderson, Greenfield Recorder, New England FLOW, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, Station 1, The Recorder, Turners Falls, Turners Falls dam, whitewater boating

An Insensitivity of Place

Copyright © 2016 by Karl Meyer (CLICK on any photo to ENLARGE)

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There’s a big difference between theory and practice. So too is there often a huge divide between what is said and what is done—and a giant gap between how you portray your intentions in writing, and how you actually carry yourself in the real world. The difference between those things is what most often turns out to be true.

At the Rock Dam, the endlessly-beleaguered and sole natural spawning site for the state- and federally-endangered shortnose sturgeon in the entire Connecticut River system, that difference came into high resolution last week. While I looked on four people in helmets and safety gear lumbered in a huge blue raft over the tiny, watered notch leading into that self-same shortnose sturgeon spawning pool. Four other decked-out compadres looked on admiringly from atop the low ledge that helped form this little ancient pool thousands of years back.

The “drop” for this joyride might have been a total of 4 feet at best, perhaps a third of the length of the giant boat. For any shortnose sturgeon that might have been using this unique ecological site to accomplish the most basic act of survival—spawning, it would’ve been the equivalent of the Starship Enterprise plopping down atop your kiddy pool party. Basically, party over. But hey, those fish are only the sole federally-endangered migratory species in the entire river. Hope you enjoyed the ridiculously short, half-second rush… Yahoo!

And the real kicker is, they were doing this within the known documented time-window at Rock Dam for shortnose sturgeon to be present and attempting to spawn successfully. This was a Sunday, but the previous Wednesday I’d seen rafts being trailered away from the site in the “Patch” section of Turners Falls. I didn’t quite put it together until Gary Sanderson’s column came out in The Recorder the next day, noting the obtuseness of rafters and kayakers he’d seen repeatedly making the same disrespectful maneuvers at Rock Dam earlier in the week.

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But here’s the theory and practice divide. During the current 5-year Federal Energy Regulatory Commission relicensing hearings for the Turners Falls and Northfield Mountain Pumped Storage projects, these whitewater groups have been at the table advocating for increased flows and access for the public on this short section of river. Chief among these have been American Whitewater and New England FLOW, with the Appalachian Mountain Club partnered with the Connecticut River Watershed Council submitting formal testimony in favor of whitewater boating interests here.

AMC and the Watershed Council in submitted testimony are advocating opening up this most-biologically-damaged stretch of the river for the last half century to increased access at three sites over a tiny reach that is just 2.7 miles long: “Improvements would need to be made to a put-in at the upstream end of the run downstream of Turners Falls dam, the take-out at Poplar Street, and access at No. 1 station and at the Rock Dam.” I wonder how many boats, rafts and cars per mile of river that constitutes.

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All groups in their statements and submitted testimony made reference to their concerns for the protection of aquatic habitats here, as well as adherence to the Clean Water Act in this Dead Reach stretch of the Connecticut that includes the extremely critical spawning habitat of the shortnose sturgeon—which consists solely of the small, semi-circular pool that forms below Rock Dam–along with its tiny little 4 foot drop. Shortnose congregate at Rock Dam for spawning from early April through the end of May. Let’s run giant rafts over them and invite crowds of kayakers to overwhelm the river and rocks here to demonstrate respect and concern for a river struggling for life here these last 50 years.

This is self-interested behavior only a little removed from that of the power companies, and, like the power companies, there is cash waiting in the wings for using the river in this most self-considered way. So, well done, whitewater boating interests! We at least now have a tiny picture of what your practice, rather than theory, might constitute. And, hey, did it ever cross your minds that some people actually consider the Rock Dam a sacred place..?

The Hidden Costs of Northfield Mountain Pumped Storage

Posted by on 01 Sep 2014 | Tagged as: Connecticut River, Connecticut River ecosystem, ecosystem, Entrainment, Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Ludington Pumped Storage Plant, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, resident river fish, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic, Yankee Rowe Nuclear Plant

Copyright © 2014 by Karl Meyer

The hidden costs of Northfield Mountain Pumped Storage: after Vermont Yankee closes, FirstLight wants to ramp up pumping and profits

(a version of this piece first appeared in the Greenfield Recorder, August 23, 2014)

Vermont Yankee, the last of the region’s nuclear plants, will close in December. In response, GDF-Suez FirstLight’s Northfield Mountain Pumped Storage plant is looking to change its stripes. On June 27th it applied to the Federal Energy Regulatory Commission for a “temporary” license amendment to allow it broad new freedoms to consume unprecedented amounts of the Connecticut River from December 1, 2014 through March 31, 2015. That plan would add an additional 22 feet of pumping capacity to its 5-billion gallon reservoir, sucked directly from the river. More pumping is certain to create more riverbank erosion and draw more silt into that reservoir. It will also kill untold thousands of the public’s resident river fish.

The unprecedented request defies logic. Northfield was built specifically to use energy from local nuclear plants to push water up to its reservoir. In its request FirstLight also cited the closing of the 330 megawatt Salem Harbor coal plant as rationale for why it should be allowed to pump more, and grow larger. FirstLight Hydro Compliance Director John Howard stated, “The requested increase in operational flexibility is needed to provide ISO-New England with additional resources to deal with a potential shortage of energy in the Northeast this winter.” However Andrea Donlon of the Connecticut River Watershed Council found that ISO-New England, the grid’s Independent System Operator, had made no requests concerning Northfield, stating it expected to have adequate energy supply this winter.

FirstLight’s application failed to mention is that it is shutting down its own 135 megawatt Mt. Tom Coal Plant this October. Rather than the “peaking energy” and “emergency resource” plant it’s been since coming on-line in 1972, Northfield seems to be implying it will somehow serve as a replacement for those 24/7 “baseload” energy plants. The other logic-defying reality is that it would be consuming more baseload energy to create more brief pulses of high-priced energy to re-sell to us at “spot” market prices.

Northfield was fashioned during the nuclear build-out in the late 1960s to use the excess power generated at night from nuclear plants in Rowe, Vernon, VT and Haddam, CT to gulp giant slugs of the Connecticut up to its reservoir. When demand “peaked” during mornings or late afternoons it would release that stored nuclear energy—our river, back to its bed through massive turbines. It could produce some 1,000 megawatts in just minutes, great for short-term needs and emergencies. But it could only store enough water to produce 6-8 hours of electricity, total. Depleted, it then waited to re-start the process.

In her book “Inventing Niagara” Ginger Strand described the inefficiencies and rationale behind selling pumped storage electricity to the public as a textbook case of corporate capitalism: buy low, sell high. Northfield has never been a renewable hydro source. It is inefficient and operates at a net-energy loss. While its impacts on the river ecosystem are profound, its brief, staggering pulses of violent, high-volume output are no more efficient than that of legacy electric producers, just more short-term profitable.

Northfield only makes sense while it operates as a designated nuclear adjunct, run on the excesses of the region’s short-lived and now-shuttered nuclear fleet. But now it wants to soldier on, utilizing imported power and climate-changing resources. Meanwhile the river pays an as-yet unstudied price–as the public is asked to accept yet more “peak” energy, repackaged and re-sold at “peak” prices culled from bidding boards on the “spot” market.

FirstLight’s FERC request sparked official replies from entities involved in the current 5-year relicensing of Northfield. The National Marine Fisheries Service’s William McDavitt noted to John Howard “the timing of this temporary amendment application is a bit unfortunate as the proposed change could bear some impact on proposed 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability. Were the proposed changes to go into effect, it seems as though the duration that NMPS pumps or generates could be changed.”

MA Fish and Wildlife made no objections to the up-rate, but the Watershed Council noted that fish kills there–known as “entrainment”, are worrisome, “Currently the entrainment impact of the NMPS facility during the winter is not well understood, which the pending appeal by USFWS regarding the sufficiency of FirstLight’s proposed entrainment study well illustrates,” further noting, “So until such time as we have a much better understanding of the entrainment impacts of NMPS, it seems inappropriate to request additional pumping capacity.”

In 1995 the owners of the Ludington(MI) Pumped Storage Plant agreed to a $172 million dollar settlement for its killing of the public’s fish across the previous two decades. There, according to the Ludington Daily News, they at least had the benefit of a one-time study showing LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

Since 1972 it’s been a free ride up at Northfield.

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

Kynard,Part II: Fisheries restoration, or a new half-century of death in the TF Power Canal?

Posted by on 06 Aug 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, Dr. Boyd Kynard, ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Station, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

Tune in to Local Bias on Greenfield Community Television, GCTV.org, for Part II of a wide ranging interview with fisheries biologist and US Fish & Wildlife Service Conte Anadromous Fish Research Center founder Dr. Boyd Kynard. He gives direct answers to questions about the fate of the millions of American shad that have been tricked out of the Connecticut River into the deadly and alien habitats of the private Turners Falls Power Canal for the last 35 years.

Dr. Boyd Kynard Part II; a Deadly Canal or a River Migration Solution?

http://mfi.re/watch/pdx5yqvqv7ygzdk/Local_Bias_147.mpg

The current Federal Energy Regulatory Commission Re-licensing process for FirstLight Power’s Turners Fall/Cabot Station and Northfield Mountain Pumped Storage Stations represents the last chance the Connecticut River gets to recover some of its biodiversity, fecundity and ecosystem functions for many decades to come. A second failure by the public agencies charged with protecting the public’s fisheries resources and endangered species will likely close off–forever, the last, best chance to restore New England’s Great River.

Will the federal and state agencies responsible for protecting and guiding the migratory fisheries restoration since 1967 (USFWS, National Marine Fisheries Service, VT, NH, and MA Division of Fish & Wildlife), again steer migratory fish headed upstream to northern MA, VT and NH spawning habitats into a private “roach motel” of deadly hydro blades and muck? Or, will they bring them directly upstream to a fish elevator at the Turners Falls and redeem decades of failure? Get the low-down, and hear about viable alternatives in this half-hour interview.

Tune in to Local Bias this Thursday, August 7 at 9 pm, or on Saturday, August 9th, at 9 pm. The shows repeat at those scheduled times the following week.

THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

Posted by on 08 Jul 2014 | Tagged as: Atlantic salmon, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, ecosystem, Endangered Species Act, Extinction, federally-endangered shortnose sturgeon, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Turners Falls, US Fish & Wildlife Service, USFWS

Click on the link above for: Part one of Local Bias interview between Karl Meyer and Dr. Boyd Kynard, produced by Drew Hutchison of Greenfield Community Television.

Watch an interview with fisheries biologist Dr. Boyd Kynard who has made a career of researching migratory fish behavior and fish passage at dams in large rivers across four continents. Kynard is the long-standing research expert on the federally-endangered Connecticut River shortnose sturgeon.

For 45 years federal and state fisheries agencies plowed $100s-of-millions into a program targeting “restoration” of a strain of Connecticut River salmon extinct since 1809. Failing to understand the concept of extinction, that project failed.

For those same 45 years agencies including NOAA’s National Marine Fisheries Service, the US Fish & Wildlife Service, and Massachusetts and Connecticut fish and wildlife departments ignored, dismissed, and failed to provide the protections, outreach, and funding needed to rescue a native, four foot-long, living fossil: the federally-endangered Connecticut River shortnose sturgeon.

Listed among just 22 fish species in the original 1967 federal Endangered Species Act, these agencies–as well as regional non-profits, have failed to protect the 2-mile stretch of river decimated by industrial flows containing the only known natural spawning grounds of this pre- Dinosaur-Age fish: the pool below a natural rocky cleft in the river known as the Rock Dam, in Turners Falls, MA. Just 300 Connecticut River shortnose sturgeon can access the Rock Dam site today–where industrial flows cripple their spawning attempts, and endangered species protections are ignored.

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by on 21 May 2014 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, ecosystem, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, GDF-Suez FirstLight, Ludington Pumped Storage Plant, New Hampshire, Northfield Mountain Pumped Storage Station, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments were filed today, 5/21/2014, with the Federal Energy Regulatory Commission respecting Connecticut River fish mortality investigations at Northfield Mountain Pumped Storage station (NMPS)

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301

 

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments, RE: FERC P-2485-063, and P-2680-108: relevance of FirstLight Hydro Generating Company’s document submission issued by FERC as “Conference/Meeting Transcript issued in FERC P-2485-063, et al” on May 9, 2014 for Northfield Mountain Pumped Storage project (NMPS).  The inclusion of “Transcript of the April 17, 2014 FERC Scoping Meeting held in Pentwater, Michigan re Consumers Energy Company’s et al Ludington Pumped Storage Project under P-2680-108” offers an incomplete, unsubstantiated and confusing picture of its applicable connection to the relicensing of NMPS on the main stem of a four-state river system in Massachusetts.

Dear Secretary Bose,

Please consider the following comments respecting the relevance of FirstLight Hydro Generating Company’s recent document filing as it seeks a new license for the Northfield Mountain Pumped Storage station.  I testified as a Stakeholder in the NMPS Study Dispute Panel Technical Conference along with officials from the USFWS and Trout UnLimited on Tuesday, April 8, 2014.  The Dispute Panel was convened out of concerns that no study of the entrainment of eggs and larvae of migratory American shad was being required as part of a relicensing bid from GDF-Suez FirstLight Power for NMPS.  I find no clear context provided by FirstLight for the inclusion of a transcript for the April 17, 2014 FERC Scoping Meeting for the Ludington Pumped Storage Plant–a lakeside Michigan-based facility, as part of the NMPS relicensing proceedings. 

NMPS’s pumping/generating impacts are known to reach downstream to Holyoke Dam at river-mile 86 and affect spawning-run migratory fish that utilize Massachusetts, New Hampshire and Vermont habitats upstream to Bellows Falls Dam at river-mile 172.  It is critical to the relicensing of any pumped storage generation on this four-state river to have robust studies with measurable outcomes to protect the public’s interest in a balanced and functioning Connecticut River ecosystem. 

NMPS impacts migrating and spawning anadromous fish in a four-state ecosystem that has been the focus of a federal fisheries restoration program begun in 1967, “to provide the public with high quality sport fishing opportunities in a highly urbanized area, as well as provide for the long term needs of the population for seafood.”  NMPS, completed in 1972, has been shown to have direct impacts on migratory fish entrainment and fish passage from northern Massachusetts to central Vermont and New Hampshire.

The US Fish & Wildlife Service, National Marine Fisheries Service, and fisheries directors in MA, NH, VT, and CT are all charged with protecting these resources for the public.  Federal and state laws, licenses and statutes governing these mandated protections include the federal Clean Water Act, Endangered Species Act, and federal-trust fish protections beginning with the Anadromous Fish Conservation Act of 1965.  FERC authority also mandates licensee compliance and protections for the public’s fisheries resources and restoration projects.  FERC itself is mandated to comply with federal environmental law. 

The Ludington Pumped Storage Plant is a FERC licensed facility sited and operating within a single state on a lakeshore well over 100 miles from it closest bordering state—and situated with 118 miles of open water at its back.  Northfield Mountain Pumped Storage, situated adjacent to the Connecticut River, operates on the Navigable Waters of the United States in Massachusetts just 10 miles from where the Connecticut River passes out of Vermont and New Hampshire.  NMPS pumps and generates from a narrow ribbon of river that is less than 1,000 feet wide—during warm seasons can draws more water than the river’s natural output. 

In short, these are two very different animals, operating in very different habitats. 

However, there are similarities in the long-term environmental impacts of these far-flung pumped storage facilities.  They both kill large quantities of the public’s fish.  Unfortunately, those impacts were not cited or included in FirstLight’s submission to FERC in either Dispute Resolution Panel documents or its license application documents.  In 1995 the owners of the Ludinton Plant agreed to a $172 million dollar settlement for its killing o fish during the previous two decades.  The public there at least had the minor benefit of one-time study that showed LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

Unfortunately, to date, we have no such data from a study of NMPS, nor any compensation for the long-term damage to a public resource and a long-term fisheries restoration project.  In Michigan, a US-based entity was required to pay restitution and undertake remedial action.  Here at NMPS the plant operator is a transnational corporation, based outside the United States, that is “taking” an unknown quantity of a public resource without compensation or required analysis.  If a US Citizen were to do this they would be subject to legal action.  

 

Please see below: Ludington Daily News, August 13, 1987: “Federal agency rules on fish kill, Ludington hydro plant must comply within 60-90 days.” 

The Ludington plant had begun operations in 1973, and had been the subject of legal proceedings from that time forward.  The State of Michigan had filed a suit in Ingham County Circuit Court seeking more than $147 million in damages, and the National Wildlife Federation had won a federal court order that Consumers needed a pollution discharge permit for the plant. 

In summary here are several excerpts from that article defining the impacts at that time including references to a single study that found the plant killed millions of native fish in a single year, species that are today disappearing, or have essentially disappeared, in Lake Michigan waters: 

 “Environmentalists and state officials Wednesday hailed a federal ruling designed to end the fish kills at the Ludington Pumped Storage Facility operated by Consumers Power Co.”  (Co-owned with Detroit Edison Co.) 

“Finally, after 14 years of negotiations and litigation, and the destruction of millions of Lake Michigan sports fish, we’re going to see an end to this needless waste of an important resource,” said Thomas Washington, executive director of the Michigan United Conservation Clubs. 

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”

“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators.  In the pumping process, it kills millions of fish.” 

“The MUCC said that a study commissioned by Consumers Power showed the plant, in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.” 

However, it took another eight years of environmental damage and drawn-out court proceedings before a settlement—totaling $172 million, was finally reached in 1995.  See: Ludington Daily News, March 7, 1995: “Local groups urged to begin working on projects for fish kill settlement plan.” 

“While 12 to 18 months more may pass before the settlement, valued at $172 million, becomes final state officials urged local groups not to wait to prepare proposals for enhancing local fishing.” 

“Many audience questions fielded by the five-person panel concerned the perception the settlement doesn’t do much for Ludington area fishing specifically—the fishing most affected by the fish kill at the plant.” 

It was only after 1995 that some of the large-scale impacts of Ludington Pumped Storage Plant began to be addressed.  Ultimately, a FERC-sanctioned 2-1/2 mile long (12,850 ft) barrier net was deployed across hundreds and hundreds of acres of riverbed and bank. 

Sadly, it seems that net did not mitigate or resolve the loss of local fisheries in the Ludington region.  Its deployment was either ineffective or far too late for a regionally- and culturally-important sustained harvest of local- sourced and eaten native yellow perch and lake trout.  Those perch have now essentially disappeared in the Ludington-Manistee region—which is noted in Stakeholder Testimony supplied for the Ludington Scoping Meeting on April 17, 2014 where Mr. Richard Underwood testified that past Michigan DNR creel surveys had found: “close to a quarter million perch” in Ludington habitats.  “In the last few years, four years, we have had a total of zero count of perch in Ludington, and that’s how it has affected.” 

The giant Ludington barrier net appears to be one key player in the puzzle of the missing perch. It appears to act as a fish trap.  According to Mr. Underwood that net, along with an artificial reef constructed nearby, attracts a giant collection of cormorants that feed on the fish trapped within the confines of the net, “There were so many birds on the reef and inside the barrier net you couldn’t count them.  I estimated there were 3,500.”  

Ironically too, in recent years, federal hatcheries in the Connecticut River basin have been producing lake trout to supplement the now-crippled and dwindling native population of lake trout on Lake Michigan. 

Another similarity in these two relicensing proceedings is that FERC’s Scoping Site Visits at both the NMPS plant and LPSP were scheduled either before the PAD had been given to Stakeholders, as it was NMPS, or—as noted in state fisheries testimony at Ludington, the Site Visits are not scheduled to take place until well after Study Requests and Stakeholder Comments are due. 

Both of these processes deprived the public and officials the ability to visit, witness, and develop an understanding of the complex impacts of these pumped storage plants before submitting testimony, comments, and informed study requests. 

Similarly, both plants have deployed barrier nets as a means of diminishing their fish kills and entrainment/mortality impacts.  And, at both sites the fishing is poor and with stocks deteriorating. 

The difference on the Connecticut River is that migratory fish here are forced to encounter two entrainment opportunities through FirstLight facilities.  The first occurs seven miles downstream, when they are deflected by attraction flows into the Turners Falls Power Canal, with Cabot Station turbines operating on the downstream end.   The small percentage of fish that manage to survive the 2-1/2-mile, 8-day (average) transit to the head of that canal—and the even smaller number that actually exit upstream(1-10%), then get the chance to be culled by NMPS turbines, just five miles further upstream.        

In its filing of the Ludington Scoping Meeting documents, GDF-Suez FirstLight seems to be suggesting some link between the large-scale wind power facilities built by LPSP owners Consumers and DTE, and a key, future role for renewables here in sucking the Connecticut River backward and pulling it uphill into the Northfield Mountain Pumped Storage reservoir. 

That connection is tenuous, at best.  Consumers and its partner DTE now own and operate a large-scale wind farm consisting of some 56 turbines.  Its deployment required the purchase or easement rights to 16,000 acres of Michigan property, most of it to trench-out underground power lines to reach back to their grid and pumped-storage plant.  Their large-scale wind operations are due to the presence of 118 miles of open Lake Michigan at their back, as well as a flat, open, prairie landscape to site giant turbines on. 

FirstLight seems to be implying that NMPS will be similarly employed at some future date—its ecosystem impacts ignored because of the huge amount of surplus, cheap, local, renewable energy available to pump a river uphill at night.  But solar doesn’t generate at night; and available local hydro here is modest and run-of-river—it would not constitute a “renewable” source to be tapped to pump water uphill.  And, wind power opportunities here are spotty, small scale, and generally available on isolated ridge tops. 

Clearly the Connecticut River Valley has none of the necessary features that might facilitate the large-scale wind renewables/pumped storage relationship found at LPSP.  Nor, has FirstLight proposed plans for any large-scale wind projects in the region.  No other entity has either.  Cape Wind, whose large scale deployment will be installed miles off the Atlantic shore, is not proposing a pumped storage plant be built above the Truro Cliffs in order for its renewable energy megawatts to be consumed.  Here, there just aren’t flatland mega-farm acres available, and only a few ridge tops here have proven suitable for siting isolated turbines.

GDF-Suez Manager John Howard stated at the Dispute Resolution Panel: “We can manage fluctuations in energy schedules with wind, solar, and imports from Canada and New York, primarily.  And then the ability to respond very quickly to energy and operating reserve needs of the power system, any time of the day or calendar year.”  He states that “We can manage…”  But there is nothing backing up the statement.  Nothing that proves there is a surplus amount of renewable energy reaching NMPS to state clearly that “We do manage…” or “We will be managing…”   The implication is that NMPS is a necessity here in order to implement renewable energy in the region.  Where is the science to back that up?  Solar is not around at night.  And the region is sub-marginal for large-scale wind, as well as lacking in opportunities for securing thousands of acres of right-of-way here. So, where is the implied connection between these two facilities—beyond fisheries destruction? 

Michigan, with its open face to the winds—which do blow at night, apparently ignores the to damage to its Great Lake ecosystem and fish, and tallies the wind-energy driving Lake Michigan waters and uphill to its pumped-storage plant as “renewable.”  We don’t have that wind here, and solar power generation is a whole different animal–not in any way the high-octane source needed to push a river uphill at NMPS.  FirstLight has built a 2 MW solar installation atop the 11 acres of land it was mandated to construct for silt-settling ponds by the EPA in 2010 after being sanctioned for massive infractions of the federal Clean Water Act by dumping up to 45,000 tons of pumped storage reservoir silt and sludge into the Connecticut River , the company has not included any information on how that solar facility connects to, and interacts with, and powers its pumped storage operations.  Unlike large-scale wind, solar does not deliver its energy at night–when NMPS asserts that it will do most of its pumping.

Pumped storage can only be deemed “renewable” energy in a generating environment where ecosystem impacts are not considered.  Pumped-storage itself was a net-loss bargain that was ill-considered even back when there was actually surplus nuclear available in the region.  Now this taking-of-a-river is mostly accomplished at NMPS by climate-warming, non-renewable fossil fuels.  This is a lose-lose situation for renewable energy use–and for an ecosystem. 

GDF-Suez FirstLight’s NMPS plant does feature “black-start” capabilities, and does offer FERC and ISO the ability to accomplish load-leveling at certain critical times.  However, these attributes must be balanced against long-standing federal and state efforts to complete a forty-seven year old migratory fisheries restoration on the Connecticut, and the public’s long-term need to have a sustainable Connecticut River ecosystem.  NMPS operations also need to adhere to federal and state environmental law.

In 1995, Consumers and DTE paid the public $172 million for their past fish kills of the previous decades.  Thus far, the public has not been compensated for the on-going taking of fish at NMPS on the Navigable Waters of the United States, nor have citizens in MA, VT, NH and CT been able to reap the benefits of anything near the stated goals of a four-state fisheries restoration program targeting recreation fishing and harvestable seafood. 

Studies with measurable results are required for a fair relicensing process.  Stated steps in the FERC relicensing process should be followed to allow the public a contextual look at the operations before the need to suggest studies or prepare testimony.  To facilitate a fair process, FERC should require context and full disclosure of all submitted documentation on the part of the applicant, as well as phone conference transcripts to allow an understanding of the ongoing dispute procedure. 

Placing a net in front of LPSP and NMPS has not stopped the fish kills at either plant.  A band-aid should not be applied to a gaping wound.  Complete and proper studies of all life stages of fish mortality are needed for NMPS relicensing.  Regulatory pumping and generating restrictions that protect the public resources of US citizens are overdue and necessary there.  The studies needed to accomplish this should take place before any new license allows this ongoing “take” to continue through 2048.     

                                                End of Formal Comments

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

Sincerely,

Karl Meyer, M.S.

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