endangerd shortnose sturgeon

Archived Posts from this Category

FERC sanctions crippling flows for federally-endangered Connecticut River shortnose sturgeon

Posted by on 01 Mar 2016 | Tagged as: 5-year FERC licensing process, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NOAA, US Fish & Wildlife Service

The following Stakeholder Comments concerning proposed study flows that will wipe out this season’s spawning for federally-endangered Connecticut River shortnose sturgeon at their only documented natural spawning site in the river system were submitted to FERC Secretary Cheryl on Friday, February 26, 2016. They include comments submitted on Wednesday, February 24, 2016 to FERC staff, federal and state fisheries agents responsible for endangered species protection, and FirstLight–who proposed to include the crippling 1500 cfs(cubic feet per second) flows in FERC-ordered Study 3.3.19.

On Thursday, February 24, 2016, Vince E. Yearik, FERC Director of the Division of Hydropower directed FirstLight’s James Donohue that the ruinous 1500 cfs flows will be allowed at the Connecticut River shortnose sturgeon’s only documented natural spawning site in the spring of 2016.

My Stakeholder Comment letter, on the FERC official record for P-2485 and P-1889, is directly below.

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 February 26, 2016

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

RE: P-1889 and P-2485

Dear Secretary Bose,

The comments below respecting federally-endangered Connecticut River shortnose sturgeon and Study 3.3.19 were delivered via email to GDF-Suez FirstLight�s James Donohue, FERC staff including Brandon Cherry, and Caleb Slater(MA), Julie Crocker(NOAA), and John Warner(USFWS) on 2/24/2016.

Thank you,
Karl Meyer

Dear Chris et al,
I commented to you and in the FERC record on your RSP for Study 3.3.19, the Ultrasound Study in P-2485 and P-1889, to repel fish from Cabot Tailrace. Since I was somehow left off the email list in the �call for comments� that went out on 2/11/2016, I will take the opportunity to comment at this time.
In your newly-revised RSP you failed to reply to this comment of mine in particular:

�The final week should be at a minimum of 2,500 CFS�which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 � May 22, in order to not interfere with the spawning of a federally endangered species at Rock Dam. In their response, FL cited �Kynard� et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required there throughout the month of June.�

FirstLight has now indicated it intends to use test flows including 1500 cfs in its Ultrasound Study. This is unacceptable, as data shows this will harm a federally endangered species, the Connecticut River shortnose sturgeon. FirstLight has cited Kynard, Kieffer et al; Life History and Behaviour of the Connecticut River shortnose and other sturgeons, in their official FERC comments. Both FERC and the agencies are in possession of the scientific study data contained therein. An examination of Chapter 3 and the �Effects of hydroelectric operations on spawning� makes it quite clear that 2500 cfs is the minimum continuous flow needed to allow females to sustain a presence at the site and complete successful spawning. Flows go below that level�and 1500 cfs is far below that required threshold, will cause sturgeon spawning to fail.

A continuous flow of 2500 cfs is the only protective flow that should be allowed in the Ultrasound Study�it is also necessary throughout the month of June to protect the Early Life Stages of shortnose sturgeon. Please make the required modifications, as I�m certain the agencies and FERC will not give you license to run afoul of the federal Endangered Species Act, as well as similar state statutes.
A review of the FERC record, as well as your proposed Revisions for 3.3.19 are included below. Thanks.
Best,
Karl Meyer,
Fish and Aquatics Study Team

In 2015, FERC agreed with FirstLight and rejected requested snorkeling studies to determine the fish assemblage in the By Pass Reach out of an abundance of caution for impacts they might have on federally-endangered shortnose sturgeon whose only documented natural spawning site is the Rock Dam Pool in that reach.
Though the record clearly misstates that that snorkeling survey request was for the By Pass Reach downstream of Turners Falls Dam�written as �downstream of Cabot Station�, the protected status and determination to �do no harm� was quite clear in FERC�s reply. Excerpts from FERC Staff directly below.
From 01/22/2015, FERC Study Modifications Determination Letter

Study 3.3.11 – Fish Assemblage Assessment
�Requested Study Modifications

The U.S. Fish and Wildlife Service (Interior) proposes modifying the study to require FirstLight to conduct snorkeling surveys in the reach downstream of Cabot Station, in order to avoid all effects on shortnose sturgeon during the spawning season. The Nature Conservancy and Karl Meyer support Interior�s proposed study modification.

Comments on Requested Study Modifications

To avoid all effects on shortnose sturgeon during the April-June period in the reach downstream of Cabot Station, FirstLight states that it will rely on sampling from the project impoundment, sampling of the reach downstream of Cabot Station during other times of the year (after June 30), and existing data from a 2009 electrofishing survey of the area downstream of Cabot Station.

Discussion and Staff Recommendation

The goal of this study is to provide general information on fish species that are present in the impoundment and in the river downstream of the dam and Cabot Station. Based on the description in the modified study plan, FirstLight�s proposed method will provide information on species occurrence, species distribution, relative abundance, and habitat associations that will adequately describe the existing fish community. Because FirstLight�s proposed methods would achieve the goals of the study while avoiding effects on spawning sturgeon, we conclude that snorkeling is not necessary and the study plan filed with the ISR should be approved without modification.�

And�FirstLight�s current revised flow plan for 3.3.19:

�This study would establish a high frequency sound (ultrasound) array across the entire Cabot Station tailrace and determine the effect of the ensonified field on upstream migrating shad moving by Cabot Station. Bypass reach test flows during the study will include flows of 1,500 cfs, 2,500 cfs and 4,400 cfs. These flows will be released depending on river flow conditions. When possible, flows will alternate with the array on for one day then off for one day at 1,500 cfs, followed by one day on and one day off at 2,500 cfs, then one day on and one day off at 4,400 cfs. This sequence will be repeated throughout the study depending on river flow. The field study will include two components: a) DIDSON count of shad entering the Cabot fish ladder and b) detection of telemetered adult shad to determine their movements after they encounter the sound field.�

FERC Stakeholder comments: Turner Falls Canal ultrasound study

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

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you,
Karl Meyer, Fish & Aquatics Study Team

CASHING IN ON A CASH COW

Posted by on 15 Jan 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, endangerd shortnose sturgeon, Endangered Species Act, Energy Capital Partners, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, fossil plant, GDF-Suez FirstLight, ISO, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, non-renewable, Northfield Mountain, Northfield Mountain Pumped Storage Station, Rock Dam, shortnose sturgeon, The Greenfield Recorder, The Pioneer, The Recorder, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Daily Hampshire Gazette(www.gazettenet.com) and the Recorder(www.recorder.com) in the first week of January 2016.

CASHING IN ON A CASH COW

Copyright © 2015 by Karl Meyer

Ever dreamed of owning your own bank? I got a deal for you! Northfield Mountain Pumped Storage Project is for sale again, along with the Turners Falls canal and dam—and a string of little assets down in Connecticut. But Northfield’s the cash cow. Fourth time in a decade they’re unloading this golden calf–always at a tidy chunk of change. A quickie corporate win-win! It’s really like an A.T.M., run at the expense of the Connecticut River ecosystem.

Place works like a giant toilet–suck huge amounts of the river backward and uphill, then flush it all back and—viola, money spews out the other end. Could be ours! They’re holding bidder tours as we speak. I just need a few partners with ready credit. We go in on short-money and cash-in on the no-brainer electricity “spot market” for a few years. Then, with inflated power-price futures in play, we offload this puppy for a final cash-out of 30%–maybe 50%!

Here’s how it goes down. With the cheerleading of Northfield’s not-so-silent partner, ISO New England–the “independent” system operator (created by the Federal Energy Regulatory Commission), we simply slow dance this darlin’ past the banks, the FTC and FERC. Then, in 2016, its sweet business-as-usual—maybe with new shirts for employees.

Trust me, this works every time. Everyone walks away with full pockets—without the public knowing what hit them. Northfield got wholesaled in 2006 by Northeast Generations Services(formerly WMECO—formerly of Northeast Utilities, now Eversource—you follow?) They grabbed a quick $1.34 billion for the package, slipping it to a trio of Jersey venture capitalists, Energy Capital Partners. ECP renamed their little project FirstLight Energy. Those smartest-guys-in-the-room hung-in and grabbed Northfield’s peaking spot-market profits for two years, before off-loading it for a nifty $1.89 billion in that crazy year, 2008.

With that, GDF-Suez, third owner in four years, swept in–the world’s largest private energy corporation, based in France. They’ve been gobbling up contracts to run water systems across the US under the name Suez United Water. But GDF-Suez recently did a clever name-change to Engie, keeping the public totally confused. They got game! The true costs of these premium-priced plant sales get buried in the list of acronyms on electric bills. It’s like owning a 25-mile stretch the Connecticut River to dip into for cash any time you please.

This is a turn-key operation–with us, the new guys, pushing the buttons. The joke is that the public thinks Northfield is a hydropower operation, while this baby has never produced a single watt of its own energy. It’s imported!–huge swatches of bulk electricity now run-in from outside the region to suck a mountain’s worth of flow from the Connecticut up to a reservoir. Then, dump it out on the power lines when prices peak. It’s hugely inefficient, now largely carbon-based—and massively damaging to the river. But amazingly profitable!

That’s where we come in. Sure it was built as a sister to the region’s nukes to gobble up their monstrous stream of unused electricity–because nukes can’t shut down their feverish output at night. That’s how you get to put in a giant straw and suck the Connecticut uphill at a rate of 15,000 cubic feet per second–more than enough to pull the river backward for a mile downstream under low flow conditions. But who’s watching? When the region’s last nuke shut down, nobody said ‘boo!’ with Northfield going fossil. What climate change?

And when it became clear years back that Northfield operations were imperiling spawning success for the federally-endangered shortnose sturgeon at the Rock Dam in Turners Falls–their singular natural spawning site going back into pre-history, again, nobody came forward. Not the US Fish & Wildlife Service, the National Marine Fisheries Service or the MA Division of Fish & Wildlife—or any river protection group. No bureaucrats, no suits–nobody. At Turners Falls—instead of 70% of migratory fish heading upstream toward Vermont and New Hampshire, they squeeze out 4%. We have it made!

Still skeptical? ISO and FERC are addicted to Northfield—even though its power-flush characteristics might come into play maybe a handful of times a year, if at all. For this they let owners cash in on the river whenever y they want. In 2012, the owners of this “asset” collection of 1500 megawatts(of which over 1100 MW derived from Northfield alone) told investors a full 40% of their profits were realized from “Capacity Fees.” What that means is you get paid for holding back the Connecticut! They’re not required to use it at all if they don’t want to—just flush when prices are high. Paid for being you! Of course another 50% of profit comes from generating, though the public doesn’t know it only operates a few hours a day when prices are highest.

Here’s the kicker: in 2014, after a cry-wolf energy deficit winter that never materialized, FERC–with ISO as cheerleader, sanctioned the doubling of those “capacity fees”. Plants are now collecting 2X the amount they were two years back, for having the potential to dump some power on the lines—not for actually generating. Paid for being you! With 1100 potential megawatts at Northfield, how quick can you say “windfall at the public’s expense?” Lastly, Northfield petitioned FERC the last two winters to increase its reservoir storage by a full 25%, with ISO their biggest cheerleader. FERC agreed, twice. Double-dip with a cherry, anyone?

This thing’s a cinch! Even with all the nukes shut—when this should have been moth-balled to emergency use as more climate-warming, spent nuclear junk, it soldiers on as a virtual river monopoly with the blessings of FERC and ISO. Trust me, no one goes to court. Ecosystem damage, costs to the public? Fuggetaboutit!

Got credit? Give a call!

Redeem the promise at Great Falls

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, bald eagle, canal shad, Captain William Turner, Connecticut River, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, Conte, Conte National Fish & Wildlife Refuge, Daily Hampshire Gazette, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, Greenfield Recorder, Holyoke Fish Lift, New Hampshire, Northfield Mountain Pumped Storage Station, Relicensing, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, The Greenfield Recorder, The Recorder, Turners Falls, Turners Falls dam, Turners Falls power canal, USFWS, Vermont, Vermont Yankee, wildlife refuge

The following piece, with edits, appeared in the Daily Hampshire Gazette and The Recorder on November 12, 2015 as: “Federal wildlife service must preserve the promise at Great Falls,” and “River restoration retreat”

The US Fish & Wildlife Service’s recent abandonment of their flagship Conte National Fish & Wildlife Refuge Visitor Center at Turners Falls defies all logic. In August they abruptly withdrew their on-site interpreter and funding for The Great Falls Discover Center. That center was located above the falls two decades back precisely because of the site’s importance as an ecological refuge—perched at a river crossroads critical to the success of their new “watershed-based” refuge.

Back then bald eagles had just returned to Turners Falls; it was once again the place that hundreds of thousands of migrating American shad surged to each spring. And just downstream was the sole natural site where the only federally-endangered migratory fish in the watershed–the ancient Connecticut River shortnose sturgeon, attempted to spawn each May. Known as the Rock Dam, its an ancient geological formation that remains a premiere retreat for spring shad anglers. For its biological and historic importance alone, Rock Dam should have long ago been offered the Refuge’s first “in-river” sanctuary designation.

Yet today, USFWS seems ready to walk away from its core mission and long history on the river at Turners Falls. Doing so would be no less an historic retreat than that of Captain Turner and his battalion after their pre-dawn attack on hundreds of Native American women, children and old men seeking refuge at that very site nearly 340 years ago. On May 19, 1676–having accomplished their grizzly goal with the loss of just one man, they were sent in reeling retreat when the first counter-attacking Native warriors arrived from a downstream island encampment opposite today’s Rock Dam. They’d been stationed there to intercept the teeming May shad runs to help feed their people. Turner and 37 of his troops died in the ensuing rout.

Today, Turners Falls remains the site of the US Fish & Wildlife’s biggest regional blunder in a mission to protect a nation’s fish and wildlife resources on New England’s Great River. In the late 1970s they signed off on the plan resulting in a series of fish ladders being built there. It forced all migratory fish out of the river and into the Turners Falls Power Canal. That resulted in a half century of failed fisheries and habitat restoration—largely drawing the curtain down on a spring ocean-connection for riverine habitats in Vermont, New Hampshire, and northern Massachusetts. That 1967 USFWS/four-state migratory fisheries restoration compact for the Connecticut River still founders at Turners Falls today.

That is why the recent USFW’s retreat from their ecologically and historically unique flagship perch remains inexplicable. Currently federal hydro-relicensing studies of dam and canal operations at Turners Falls are taking place. Their outcomes will determine environmental conditions governing the Connecticut River in this reach for two generations to come. The USFWS is playing a key role in these studies as the lead agency empowered to define and require changes at Turners respecting the protection and restoration of the public’s federal-trust and federally-endangered fish species there. In short, they’re at a crossroads. They are the key player able to restore past mistakes and make the Conte Connecticut River Watershed National Fish and Wildlife Refuge a true refuge for annual migrants passing from Connecticut to Massachusetts; then Vermont and New Hampshire.

That long-awaited success would occur at the doorstep of the Great Falls Discovery Center–replete with its life-sized displays of watershed fish and wildlife, and its accessible public auditorium. It’s a huge opportunity at a site virtually on the river, easily reachable by visitors from a broad swath of southern New England travelling the I-91/Route 2 Corridor. Great Falls is the only brick and mortar place for the public to regularly interact with USFW staff and a diversity of displays of characterizing watershed habitats for 80 miles in any direction. What’s more it’s the only publicly-funded flagship Refuge site where admission is free.

Without a touchstone site in this populous reach of the watershed, most citizens will remain unaware of the restoration and conservation work of the USFWS. They’ll be left to surmise instead that Conte is more a theoretical Refuge—a concept and an amorphous jumble of disparate parts lacking any true core.

In practice and in theory, Turners Falls and the Discovery Center site represent the best of opportunities for the US Fish & Wildlife Service to succeed in their core missions of conservation, restoration, public access and education. A second retreat at Turners Falls would be an historic failure. This fabulously rich reach of the Connecticut is uniquely situated to showcase the Service’s long-awaited success in river restoration on the public’s behalf. Many mistakes could be redeemed with the right decisions at this time. Don’t abandon the Great River at the Great Falls.

Public comments are being accepted through November 13th on the USFWS’s plans for Conte Refuge priorities for the next 15 years at: www.fws.gov/refuge/silvio_o_conte/

Karl Meyer
Greenfield

Shad anglers help ground-truth test flow impacts at Turners Falls

Posted by on 13 May 2015 | Tagged as: American shad, Connecticut River, Conte, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Conte Anadromous Fish Research Center, federally-endangered shortnose sturgeon, Holyoke Fish Lift, Northfield Mountain, Rock Dam, Rock Dam Pool, shad, shad fishing, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab

P1000360 - CopyP1000358 - Copy
The above photos were taken at the Rock Dam Pool today, May 13, 2015. Many shad could be seen with the naked eye fidgeting and milling through the pool. Two anglers were enjoying plucking a few out of the drink. (CLICK ON PHOTO FOR LARGER IMAGE)

Shad anglers help ground-truth test flow impacts at Turners Falls

Federally mandated test flow releases from Turners Falls Dam continued today, with flows reduced to 2,500 CFS (cubic feet per second). That drop, from 4,400 CFS the day prior, produced some interesting results for shad anglers fishing the 2-1/2 mile long Dead Reach below the dam.

At 12:20 p.m. I stopped by the Connecticut River’s Rock Dam Pool, off G Street and “Migratory” Way in Turners, basically just a few hundred yards upstream of the Conte Fish Lab. Curiously, with the tamped-down flows, the Rock Dam Pool was a-bustle with milling shad—perhaps defaulted to this site when flow got cut at the dam. What’s clear is that 2,500 CFS is not a flow level that moves migratory fish upstream in the river through this site toward the TF Dam. When I spoke to three anglers at the base of the dam just 20 minutes later, they said the shad had run out with the decreasing flow.

The river levels today at the Rock Dam though, would at least likely have sustained the presence of the annual spawning gathering of federally endangered shortnose sturgeon in the Rock Dam Pool. They were many levels above the mid-summer conditions created by dam operations at this site on May 3, 2015, which basically scuttled a year’s reproduction there. But hey, who’s enforcing the Endangered Species Act these days??

I did meet a young angler at the Rock Dam who was having a blast pulling in shad. He will graduate Westfield State this coming weekend, and noted that his dad—President Elect for the American Fisheries Society, works in fisheries for the US Fish and Wildlife Service in Hadley.
He’d been tossing in shad darts at the Rock Dam Pool for maybe an hour, and had landed and released 7 shad. Big ones, he noted. I explained a bit about the test flows, and we both stood for a bit marveling at the pods of shad turning quick laps around the pool—ten, then a run of a few, then a line of several more—all darting into shadows beneath the high, mid-spring sun.

Hopefully, he’ll carry news to his dad that these fish are here because there’s flow being released to the river. A well-kept secret in these parts is that USGS Conte Lab fisheries biologists who like to get in a little fishing on lunch break always make their way down to the Rock Dam Pool when there’s flow in the Connecticut—cause that’s where the fish want to be.
You won’t find them flicking darts into the power canal just out their front gate.

When I debriefed a trio of 20-somethings fishing below Turners Falls Dam just 20 minutes later, they reported the fishing had turned to dust once the flows were tamped down to 2,500 CFS. One of the guys said that yesterday—Tuesday, all he had to do was just cast and reel in. “I probably caught a hundred.” OK, that’s fish talk, but I’ve seen these guys before. They are shad people. When I told them the Rock Dam was rocking, one said to the woman angler with them, “Wanna go down there?” “Hell yeah!” was the response.

Lastly, I drove Greenfield High Girl’s Softball down to South Hadley later in the afternoon. It’s only a mile or so hike down to South Hadley Falls Dam from there. I took the stroll. There were maybe two dozen anglers strung out along the edge of Slim Shad Point at around 4:30 p.m., but things looked fairly quiet. I didn’t have much time, but I did a little de-briefing to two hefty Latino guys I’ve seen fishing from the Veterans Memorial Bridge before. “Shad are done!” one said of the days fishing. “There’s no water.”

Interesting, since its possible this could be equated to the cut-off of nearly 4,000 CFS up at TF Dam earlier. It’s known to take 6 – 8 hours for the impacts of flow manipulations at Northfield Mountain and Turners Falls Dam to be experienced 36 miles downstream at Holyoke. Thus, these guys may have been experiencing the impacts of test flows, which temporarily quieted the upstream run of fish. Be interesting to try and tease out the correlations. Test flows at Turners will bump up again to 6,300 CFS this Saturday through Monday.

The Greenfield Varsity Girls won at South Hadley.

As of Tuesday, Holyoke had lifted 181,000 shad.

Spawning shortnose sturgeon denied flow at Rock Dam Pool

Posted by on 08 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rutland Herald, shortnose sturgeon, The Greenfield Recorder, University of Massachusetts, US Fish & Wildlife Service, Vermont Digger

PRockDamPoolDewatered (2)
(to view lager image, click on photo).

NOTE: the photo above documents conditions found at the Rock Dam Pool on the Connecticut River on May 3, 2015. Seventeen years of published studies conducted by federal and University of Massachusetts fisheries researchers at the adjacent Conte Anadromous Fish Research Center show that these river conditions cause spawning failure for federally-endangered Connecticut River shortnose sturgeon at the Rock Dam Pool, their only documented natural spawning site. The May 3rd river conditions found at Rock Dam mimicked mid-summer flows on the Connecticut–conditions that research shows drives spawning-ready females from the site, and de-waters the cobble-strewn pool where eggs and embryos attach and develop. April 25 to May 22 is the documented spawning window for the shortnose sturgeon on the Connecticut. It is a crime to kill, injure or interfere with endangered Connecticut River shortnose sturgeon under federal and state law. The Federal Energy Regulatory Commission, the National Marine Fisheries Service, the US Fish & Wildlife Service, and the MA Division of Fisheries & Wildlife are responsible for the protection of the Connecticut River’s only federally-endangered fish under the Endangered Species Act(ESA). GDF-Suez FirstLight controls river flows to this site via spill gate operations at the Turners Falls Dam, just upstream.

A RIVER PRESERVED IN PLASTIC Copyright © 2015 by Karl Meyer

(The following essay–with minor variation in each, appeared recently in The Recorder, The Rutland Herald, and at Vtdigger.org)

A lifeless, three-foot long Connecticut River shortnose sturgeon sits on display at the Great Falls Discovery Center in Turners Falls, MA. The shortnose has been this river’s only federally-endangered fish since 1967. That plastic sturgeon has sat amidst other replica fish for a dozen years now—a plastic American shad, a blueback herring, a trophy-size Atlantic salmon. They’re framed beneath a slightly-ruffled acrylic surface representing the Connecticut River at this flagship site of the Silvio Conte National Fish & Wildlife Refuge.

That display is the basic message offered to visitors here: ‘This is a river with congenial flows supporting populations of shad and herring, big native salmon, and federally-protected sturgeon.’

Nothing could be further from the truth.

Few upstream migrants reach Vermont and New Hampshire today. That’s part of the legacy of failure of federal and state fish agencies and watchdog groups claiming to safeguard an ecosystem and its native migratory fish. That legacy will remain intact until they confront ongoing conditions in Massachusetts that have been crippling the river here for decades.

That Discovery Center depiction falls apart if visitors simply walk outside onto the deck of the Turners Falls Bridge, adjacent to Turners Falls Dam. There, often for months on end, what they’ll see is the hollowed-out heart of New England’s Great River–a waterless chasm, or one teased by just a trickle from the power company’s dam. Conversely, when rain or snow send more river downstream than can be profitably sent through FirstLight’s power canal or stored upstream for their Northfield Mountain Pumped Storage Station, those spill gates open wide–producing violent, see-sawing flows few fish can fight or follow.

Meanwhile a 200 million year-old evolutionary gem, the Connecticut River shortnose sturgeon, remains all but abandoned just downstream–teetering on the verge of extinction for decades. Likewise, American shad can’t move upstream in the river here at all. They’re forced into that turbine-lined power canal where less than 1-in-10 will emerge alive beyond the dam. And those blueback herring–protected on paper as a “federal trust” species, have not been counted here in almost a decade. Just 20 years back they passed by the thousands.

That plastic salmon, showcased for decades as the darling of this river’s fisheries restoration, has been extinct here since 1809. It should not be presented as a living native fish. In science, extinct isn’t subject to interpretation.

That trophy-sized model derives from a massive hybrid hatchery program created by cross-breeding salmon imported from Canadian and northern New England rivers. For 43 years federal and state fish farms produced the millions of tiny fry dumped into the river each spring. Those fish factories repeatedly proved vectors for the potential spread of disease throughout the river system. Though those tiny fish proved great for public relations, no spawning population of engineered salmon ever took hold.

Hybrid salmon became the red herring that masked the massively broken ecosystem that exists on an eight-mile stretch of New England’s Great River from the Northfield Mountain Pumped Storage Station to the tailrace of the Turners Falls Power Canal. Those salmon were the stand-ins for agencies including the National Marine Fisheries Service, the USFWS, and MA Division of Fish & Wildlife that had failed to protect living migratory species here–and an ecosystem suffocating right in their backyard.

The plight of the only state- and federally endangered fish here represents the ultimate failure of responsibilities. Dr. Boyd Kynard spent decades studying the shortnose and documented it’s only natural spawning site–the Rock Dam Pool, less than two miles downstream of Turners Falls Dam. Dam operations there were annually creating conditions that crippled spawning success for the remaining 300 sturgeon still able to reach their ancient rendezvous site.

Kynard’s federal- and state-funded findings were given to fish agencies a decade back. Each bore legal responsibility for that sturgeon. Yet no agency or non-profit stepped-in to monitor and enforce Endangered Species Act protections. None intervened to halt the trickle-and-torrent flows preventing reproduction. That step alone would’ve put living waters back into the river here–aiding the shad and herring attempting to reach Vermont and New Hampshire. Likewise in 2012, when Kynard published a book on the shortnose–documenting its life history and the river conditions necessary for its recovery, again, no one went to court to protect this public legacy.

Had agencies and watchdog groups taken responsibility years back for protecting spawning sturgeon at that Rock Dam Pool below FirstLight’s dam, native migratory fish and the river ecosystem would be in a far better place today. Instead, that work was left to become part of the current studies in the Federal Energy Regulatory Commission’s 5-year relicensing process for the Turners Falls and Northfield hydro sites, where I’m on the Fisheries and Aquatic Studies Team.

Sturgeon spawning is not monitored today. It’s unconscionable to have waited for a 40 year relicensing process to come around before broaching concerns for an endangered fish and broken ecosystem. Hopefully it won’t prove the difference between a living river, and one merely depicted in a museum model.

Greenfield, MA journalist Karl Meyer is participating in the Federal Energy Regulatory Commission’s relicensing process for the Northfield Mountain and Turners Falls hydro sites.

New Comments to FERC, RE: Turners Falls Fisheries Studies

Posted by on 08 Apr 2015 | Tagged as: 5-year FERC licensing process, American shad, Cabot Station, Connecticut River, Connecticut River shortnose sturgeon, Conte, Dr. Castro-Santos, Dr. Haro, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, MA Division of Fish and Wildlife, Mr. Colton Bridges, New Hampshire, Northfield Mountain Pumped Storage Project, Revised Study Plan, Secretary Kimberly Bose, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont

NOTE: the following comments were submitted to Federal Energy Regulatory Commission Secretary Kimberly Bose respecting FirstLight’s withdrawal from its stated position of using video-monitoring equipment at the Turners Falls Dam’s Spillway Ladder to compile study data and information on aggregations of migrating American shad.

This is information that has been the fisheries restoration’s Black Hole these last forty years. It can only be gathered at this site. However, with the withdrawal of these tools, fisheries agencies and the public will be relying on just a few hundred radio-tagged and tracked fish as substitutes for on-site, real time monitoring of aggregations of what are understood to be perhaps hundreds of thousands of migratory shad. (Comments to FERC were slightly abbreviated due space limits in E-filing.)

Karl Meyer, MS
Greenfield, MA 01301 April 8, 2015

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

Re: P-1889; P-2485

Dear Secretary Bose:

Please accept the following comments in the matter of the hydro-power licensing studies for P-1889, the Turners Falls Project; and P-2485, the Northfield Mountain Pumped Storage Project. These comments focus on changes FirstLight made to the Revised Study Plan. I first aired my objections to these RSP changes at a meeting on March 24, 2015–as a member of the Fisheries and Aquatics Study Team. They highlight a lack of Existing Information and a Need for Additional Information that FirstLight’s RSP revisions will not satisfy.

FirstLight has summarily excised all video monitoring in the vicinity of the Spillway Fishway at the base of Turners Falls Dam—a technique they’d agreed was needed in the initial RSP.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

Study Goals and Objectives: (18CFR; 5.11(d)(1)

“Evaluate attraction, entrance efficiency and internal efficiency of the Spillway Ladder for shad reaching the dam spillway, under a range of conditions.”

FirstLight stated the following in their initial RSP response: (bolded italics below, mine

“Video monitoring will be used for specific study areas such as the Spillway Fishway. Use of video monitoring of the Spillway fishway will provide data on fishway efficiency; shad attempting to pass would be monitored versus only those shad that have been tagged.”

Task 2: Study Design and Methods:

FirstLight then wholly eliminated that key video information gathering technique that would help inform these studies with aggregate numbers of shad reaching the Spillway Entrance, versus only those few tagged fish approaching and passing the Spillway entrance.

From FirstLight’s March 14, 2015 RSP changes distributed to the Fisheries and Aquatics Study Team:

“The study will monitor shad migration within the study area using a combination of active and passive radio techniques and video surveillance.”

This needed information gathering was eliminated by FirstLight despite their description in the initial RSP that this was a proven and inexpensive technology:

“FirstLight proposes to conduct video monitoring using the Delta System commercial series of underwater video camera and lighting manufactured by Ocean Systems Inc. This system was recommended by A. Haro (Conte Lab) and has proven effective at other facilities. Video data will be recorded on a dedicated video recorder (DVR).”

“Video monitoring of the Spillway would add a modest cost to this study.”

As to why gathering information about aggregations of American shad at the Spillway adjacent to Turners Falls Dam is needed at this time–that need was stated in FirstLight’s initial RSP response as well:

“In general, the numbers of tagged fish passing through the Spillway Fishway were too low for vigorous evaluation (Haro and Castro-Santos 2005).”

Information about aggregations of migratory fish moving upstream to the base of Turners Falls Dam and the Spillway has been paltry to nonexistent these last 40 years. In the last 15 years, Dr. Haro and Dr. Castro-Santos of the USGS Conte Lab have focused nearly all their work in FirstLight’s power canal, while the Connecticut River passage route for these federal trust fish has been almost wholly ignored.

As to the huge gap in the information for American shad aggregations at this site, I herein cite expert testimony delivered before Commission members four decades back:

On August 21, 1975, in hearings before the United States Federal Power Commission in Boston, Mr. Colton Bridges, Deputy Director of the Massachusetts Division of Fisheries and Wildlife delivered the following expert testimony on the need for Spillway Fish Passage at the Turners Falls Dam:

To Mr. Bridges: Question: “Would either the Cabot power house fishway or the gatehouse fishway be effective in passing those early arriving shad?”

Answer from Mr. Bridges: “No, because with spill conditions at Turner Falls the major source of attraction water will be coming down river from the Turners Falls Dam and emanating from Cabot Station. Consequently, the conditions that existed at Holyoke with spillway flows limiting fishlift efficiency will prevail at Turners Falls Dam with only a Cabot Station fish passage facility in operation.”

Question: “What, in your opinion, would be the effect of the construction of the proposed fish passage facilities at Turners Falls Dam without the inclusion of the spillway fishway?”

Answer from Mr. Bridges: “Without a spillway fish passage facility, fish approaching Turners Falls during periods of spill will be attracted to the base of the dam and those isolated pools located immediately below it, and be subject to the same conditions that exist below Holyoke without the spillway fish collecting facility, i.e., migration delay and mortality due to lack of flow, increased water temperatures, and decreasing oxygen content.”

Given that, as of this date, FERC is refusing to allow the USFWS any in-situ access for snorkeling to get a general assessment of fish using this passage route to Turners Falls Dam during migration season–and that FERC is further disallowing any seining for fish or shad eggs in this reach due to concerns for endangered shortnose sturgeon, this is the only key place where any new information about Spillway aggregations of shad can be gained. This was stated as a result of FERC internal policy, though NMFS indicated a willingness to consult—and NMFS is the ultimate key-holder in decisions concerning Connecticut River shortnose sturgeon.

Hence, denying the gathering of this needed information at the Spillway effectively limits the public’s understanding of what is happening at this site. Though overall successful fish passage through the Spillway Ladder has proven ineffective these past 30 years, it should not limit the Entranceway as the key place to collect long-absent information on aggregating shad.

These are the early arriving fish that have long been known to be the key migrants–most likely to move upstream to Northern Massachusetts, Vermont and New Hampshire spawning sites on the Connecticut. As of this date, 40 years after Deputy Director Colton Bridges testimony, those fish are still not making it past Turners Falls Dam, and we don’t have the information about their numbers and when, where, and in what flow conditions they gather at the Spillway site.

For these reasons I respectfully request that Spillway video monitoring be returned to the Revised Study Plan for this season–to gather the data that cannot be gained simply by monitoring a few hundred radio-tagged fish.

Thank you.

Sincerely,
Karl Meyer, MS, Member, Fisheries and Aquatics Study Team for P-1889; P-2485

New CT River Stakeholder Comments Submitted to FERC

Posted by on 14 Nov 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, FERC, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments/Requests on FERC Projects P-1889 and P-2485, Turners Falls Hydro and Northfield Mountain Pumped Storage were submitted on November 13, 2014 to the Secretary of the Federal Energy Regulatory Commission.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301                                                              November 13, 2014

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

ILP COMMENTS–including: Disagreements/Modifications to Study/Propose New Study on Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process in order to continue plant operations beyond 2018. An Initial Study Report Meeting Summary has been filed by GDF-Suez FirstLight. Please accept these comments on the ISR and my proposals for modifications and new study requirements in the FERC ILP for these projects.

3.3.11 Fish Assemblage Assessment:

Further information/study needed:

FirstLight has declined to undertake any study in the By Pass Reach of the Connecticut River due to stated concerns of interference with spawning and development of embryos of federally endangered shortnose sturgeon in this area. Information from the 2009 EPA study is insufficient to quantify presence and abundance of resident and migratory fish in this reach during critical migration and spawning periods—April through June. That investigation used only 3 sites in the By Pass Reach and was not undertaken to illuminate key species requirements in the current ILP for this critical reach.

NMFS notes that FirstLight has failed to consult with stakeholders on SNS issues here. I am in agreement with USFWS that a dedicated snorkeling, SCUBA, or hookah diving assessment of this critical reach of the four-state CT River be conducted in the riverbed between the Turners Falls Dam and downstream of Cabot Station during the April-June migration and spawning window–and that it continue after FirstLight’s suggested June 30 beginning target date.

I personally snorkeled parts of this reach in May 2013 and found that identification of migrants and resident species was easily attained. An in-situ investigation of this river reach in order to assess species presence and relative abundance is necessary groundwork for making decisions that will impact the 45-year long fisheries restoration on the Connecticut.

Dr. Boyd Kynard, who FirstLight cites in their argument and who spent decades investigating shortnose sturgeon on this reach of the Connecticut told me (personal communication 11/12/2014) that this study method can be accomplished without impacting SNS from the pool below the Rock Dam upstream to the base of Turners Falls Dam.

3.3.12 Evaluate Frequency and Impact of Emergency Water Control Gate Discharge Events and Bypass Flume Events on Shortnose Sturgeon Spawning and Rearing Habitat in the Tailrace and Downstream from Cabot Station.

Further information/study needed: FirstLight has supplied a grid of information for emergency gate and by pass flume openings for the years 2005 – 2012, though 2010 is missing, and we have no information on gate openings and placement for 2011 and 2012 in some instances, other than that there were no instances when greater than 4 emergency flume gates were open.

This study information should be updated with full information for years 2011, 2012—as well as 2013 and 2014 gate opening numbers, placements and CFS information.

Study findings from Kynard and Keiffer, as well as the long-term study of SNS in this reach catalogued in Life History and Behaviour of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Society, 2012, specifically delineate emergency and canal flume gate spill as having a profound and deleterious impact on shortnose sturgeon spawning and early life stage development.

As was stated recently by sturgeon biologist Micah Kieffer at a fall 2014 meeting of the Connecticut River Atlantic Salmon Commission, “one instance” of ramped-up or ramped-down flow from TF dam or emergency spill gate and flume operation can abruptly terminate or abort spawning attempts at Rock Dam and below Cabot Station by federally-endangered SNS for the entire year. Operations of emergency and by pass flume gates on the TF canal also can have deadly parching or burying impacts SNS embryos.

FirstLight contends that its operations of Bypass flume gates above Cabot Station are aimed at either emergency load rejection at Cabot Station, or opened to flush debris. They also contend that it is rare to have more than one flume spill gate open, though most of the numbers belie this statement–and the number of days when 4 or more gates have been open during SNS spawning window is highly significant and impactful. Opening of 4 flume gates needlessly diverts flows approaching 4,000 CFS out of the Connecticut’s By Pass Reach at TF Dam, and sends it into the canal to be needlessly flushed back into the river in a configuration that impacts migratory species and imperils annual spawning attempts of the federally-endangered CT River shortnose sturgeon.

In May 2014, I personally witnessed 3 consecutive days when two or more spill gates were open at the TF canal bypass above Cabot—all at the same time of day: 12:25 pm. These openings occurred while both Station 1 and Cabot were generating, which would appear to indicate that the spill gates had been left in this position for hours, or perhaps days, as part of flow regulation in the canal–rather than emergency or debris clearing. I have sent this information to both FERC and the federal and state fisheries agencies.

It is clear to anyone who examines the TF power canal that it is mostly a lake-like, slow-water habitat, save for the thalweg. It is rare to see debris of any significant size floating in the canal. It gets culled off at the trash racks in front of the TF Gatehouse, or at racks on the canal that dog-leg off to Station 1, or it simply settles out in the lake section of the TF Canal.

The minor amount of small, floating debris that enters the fat part of the canal is culled off by the trash rack skirt above Cabot that steers it to the east side of the canal where a bascule gate can be operated to pass anything of significant size.

The continuous openings of two or more bypass gates, up to six and seven gates open on a “non-emergency” basis on the TF canal above Cabot Station during SNS spawning and early life stage periods threatens the recovery of the Connecticut River’s only federally endangered migratory species.

As I have witnessed, multiple gates open on the canal while both Station 1 and Cabot were in operation indicates that canal flow is at times being regulated at this site, rather than at the TF Gatehouse, where excess flow could be delivered to the river in the Bypass Reach, which would nourish, rather than destroy SNS chances for successful spawning at Rock Dam and below Cabot. During SNS spawning season, mid-April – June 30th, endangered species protections dictate that all flow, save for documented, specific emergency situations, by controlled at the Head Gates of the Turners Falls Dam.

Information for years 2013 and 2014 should further be included, and a Study and study season for 2015 should be implemented that documents both the reason and instances when emergency gates were open—and any flume gates above 1 that were open to vent flow from the canal to the ByPass.

I would also like to FERC to have FirstLight include information for 2010, as the May 4 time of 8-gate emergency spill operation occurred exactly at the time frame when Northfield Mountain had burped up a massive sediment spill into its intake, and was trying to flush that pollution downstream. It would be helpful to know the position of both the Bypass flume gates and the positions of TF Dam headgates and bascule and tainter gates at that juncture—as it most definitely impacted SNS present for spawning that year. This would again offer data on whether the TF canal flows were being regulated via emergency by pass flume operation.

3.3.14 Aquatic Mapping of Turners Falls Impoundment:

Further information/study needed:

If migratory fish targeted for restoration in Northern Massachusetts and Vermont and New Hampshire are to continue to be diverted into the TF Power Canal, where few emerge upstream, then an addition to this study should be conducted: Aquatic Mapping of the Turners Falls Power Canal—as it is technically an extension of the Turners Falls Impoundment, and the public has a right to understand the habitat where their fish get privatized.

3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms

Further information/study needed:

The 2014 Canal Drawdown study was flawed as it occurred over the course of two days, due to an error in spill gate function. Since this is a study of live and dead fish and organisms, as well as the presence of dissolved oxygen, a two-day study time frame represents a flawed evaluation. A night of drying, predation, and fluctuating oxygen presence confounds the results of this work. FirstLight does an annual drawdown of the canal—has down so for decades, thus a mistake at the time of a critical habitat study should corrected by conducting a second year of study.

Further, since FERC has ordered that FL conduct a study of American shad spawning in the TF Canal, it is important to note another anomaly in their canal drawdown work. At five-year intervals the TF Canal receives a full canal muck-out during drawdown. The last one occurred in 2009. This would have been the fifth year—a time when the major muck-out would occur. It did not happen. What occurred was canal “light”, with a large snafu in the middle of the one day study, making it a two day effort. Whether FL agrees that this should have occurred in 2014 or not, a big-dig in the canal is needed regularly, as the sludge, silt and muck settles out and fills in the wide part of the basin.

This must be figured into the “impacts” of the drawdown, as it has profound implications for forcing migratory fish into this habitat, as well as the survival of resident fish and aquatics.

Please see attached photo of the canal muck-out that I took in 2009.

This is the habitat all upstream migrants are diverted into at Turner Falls

This is the habitat all upstream migrants are diverted into at Turner Falls

 

3.3.19 Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement of Migratory Fish to Turners Falls Dam by Avoiding Cabot Station Tailrace

Further information/study needed: the need for this 2016 study will be fully realized if planned studies of American shad movement and spawning in the canal confirm that these fish are experiencing significant migratory delay, and are being coralled into a migratory spawning trap by confused and insurmountable flows or pre-mature warming in artificial habitat that induces spawning in the canal—preventing fisheries restoration on the river in Northern Massachusetts, New Hampshire and Vermont.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Further information/study needed: I concur with FERC’s requirements of an intensive array of radio and telemetry receivers throughout the TF Power Canal to track migrating shad in the canal.

However, I request that FERC require FirstLight, in consultation with stakeholders, add an array temperature monitors calibrated to the radio and telemetry sites to understand whether canal delays for American shad–lingering for an average of 8 days in the TF Canal, are forcing these fish to spawn in this privatized, lake-like habitat because of warmed, shallow, and slow water conditions.

3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of Northfield Mountain and Turners Falls Projects

Further information/study needed:
I concur with FERC that a full spawning study of the Turners Falls Power Canal be conducted in 2015, undertaken in consultation with stakeholders. Temperature monitors should be deployed to assess impact on migratory delay and spawning on-set; and cumulative impacts of head gate and by pass use of spill gates should be factored into the study to determine the impact of silt deposits on spawning success.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

Further information/study needed: In the Initial Study Report Study Meeting Summary for stakeholder in October 2014, a request was made that FirstLight provide vector maps with arrows and indication of directional flow around the Intake and Tailrace Channel at the Northfield Mountain Pumped Storage Project. This is critical information for flow, erosion, and sediment displacement and needs inclusion.

This is information that has been missing on Northfield Mountain Pumped Storage Impacts since at least 1974. See attached at end of document.

Thank you for this opportunity to comment on these critical relicensing issues.

Sincerely,
Karl Meyer, M.S. Environmental Science
Greenfield, MA

1974 attached file below.

 

March 1st Deadline: Comments to FERC on Northfield/Turners Falls Hydro Relicensing

Posted by on 25 Feb 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Conte, endangerd shortnose sturgeon, EPA, ESA, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Reservoir, Rock Dam, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab

Last Call to send comments and study recommendations to the Federal Energy Regulatory Commission to guide the Connecticut River conditions mandated in the 2018 relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  The licenses will the river ecosystem for decades to come.

To file any comments on the relicensing of the Northfield Mountain Pumped Storage Project and the Turners Falls Hydroelectric Project you will need to register at: www.ferc.gov/docs-filing/efiling.asp

You must include the following project numbers for Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project respectively, with any comments: P-2485-063, and P-1889-081.

All comments are due before MARCH 1, 2013.  Be sure to include your full mailing address, phone number, and email address in your comments. (I’ve attached my comments, which are now registered with FERC, below.)

Karl Meyer, M.S. Environmental Science

Greenfield, MA, 01301                                                             February 25, 2013

To: Federal Energy Regulatory Commission

RE: Comments on FERC Relicensing Projects: No. P- 2485-063 (Northfield Mountain Pumped Storage Project) and No. P-1889-081 (Turners Falls Hydroelectric Project)

Dear Commissioners,

Please carefully adhere to the standard FERC relicensing processes and deadlines as you relicense these two projects.  Holding public and agency site visits in early October 2012 may have been deemed convenient for circumventing winter weather that might have affected visits, however it placed invested parties in the difficult position of having to view and judge hydro operations and configurations at both facilities without the benefit of knowing what operational changes and information FirstLight Power Resources was including in its PAD.

Further, of the three FERC group tours at Northfield/Turners Falls, only one group, mine, was able to view the area of the By-Pass Reach and the Turners Falls Canal and head gates from the downstream side of the Turners Falls gate house.  This is a critical area to view, and the excuse being given was that there was construction happening on the Turners Falls Bridge.  However, unrestricted access to view these sites was available to any passing citizen just yards away via a bike and walking path, open to the public.  My group only received access because I made a direct request to FirstLight’s John Howard, who was my former boss.

The two other tour groups did not get to see the confused flows created by the 14 head gates at the upstream end of the Turners Falls Canal.  The canal has been a major disappointment as the upstream conduit for all migratory fish these last 34 years.  Those head gates are open at full bore during much of the upstream fish migration season; they should have been a key component of the tour.  Nor did interested parties get to view the exposed rock bed and de-pauperizing flow regimes created by flood gate manipulations at the Turners Falls Dam that renders the By-Pass Reach a non-river.  FERC should place particular emphasis on any studies that redirect upstream migrating fish away from the confused and failed conditions experienced in the Turners Falls Power Canal, and send them directly upstream to a lift at TF Dam.  That configuration has worked quite effectively at Holyoke Dam these last 58 years.

In late January 2013, GDF-Suez FirstLight Power Resource representatives noted at public hearings that it intends to apply to FERC with a Proposed Study Plan to begin its own investigations of flows in the reach below Turners Falls Dam this April 2013, rather than the 2014 and 2015 study seasons noted in the FERC Relicensing Process.  No study in this critical segment of river known as the By-pass Reach should be undertaken without a full vetting of the proposals.  This section of river is critical spawning habitat for the federally-endangered Connecticut River shortnose sturgeon, also listed as endangered under the Commonwealth of Massachusetts Natural Heritage and Endangered Species Act.  It is also the age-old upstream route for spawning federal-trust American shad and blueback herring.  It is noteworthy that in their expedited study application that FirstLight cites the area below Cabot Station as a key shortnose sturgeon spawning location, while the critical site for these fish—used for likely thousands of years, is the natural escarpment in the riverbed known as Rock Dam, a half mile upstream of Cabot Station.

In a letter from FERC to Mr. John Howard of FirstLight Power Resources dated March 12, 2010, the Commission noted that FirstLight had failed to comply with Article 34 of the license for the Turners Falls Project, releasing just 120 cubic feet per second to this segment of the river to protect shortnose sturgeon from the effects of low flows.  The minimum requirement is 125 CFS.

With respect to measured, in-depth, long-term investigations on flow and river regulation in this reach I would direct you to the 17 years of research done by Dr. Boyd Kynard and colleagues at the Conte Anadromous Fish Research Center adjacent to this river segment in Turners Falls, MA.  The work was largely conducted via the federal Conte Lab under the US Fish & Wildlife Service and later, under the US Geological Survey, when it took over responsibilities for Conte Lab after 1999.  These investigations were also supplemented by funds, research and personnel from the University of Massachusetts at Amherst.

This research is documented in: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society and produced by Books on Demand, GmbH, Norderstedt, Germany: ISBN 978-3-8448-2801-6.  Copies can be obtained from the North American Sturgeon and Paddlefish Society:

www.nasps-sturgeon.org/#!publications  Chapter 3 concerns the long-term study of flows and river regulation on spawning success of the last 300, spawning-capable, federally endangered shortnose sturgeon in this river system—covering the period of 1993 – 2005.  This is critical, long-term research that includes seven years of findings from the time before Northfield Mountain Pumped Storage and Turners Falls Hydroelectric Project operated as a regulated utility, and the seven years when Northfield’s pumping was unconstrained by regulations and operated to profit from price spikes and drops in the energy spot market using the public’s river.  Deregulation was fully implemented here in 2000 or thereabouts.  All of these issues need careful consideration before sanctioning a rushed study plan in such a critical river reach.

When considering a new license for these facilities, careful consideration of the public’s interest should be made respecting the changes and power generation, flows, and operational practices from the commencement of the current licenses down to the present.  In 2012, Northfield Mountain Station added 40 megawatts of power to its generating facilities through retooling two of its turbines.  This increase nearly equals the total power generated at HG&E’s Holyoke Dam, the next downstream project licensed by FERC.  Two remaining turbines await power up-rates, which is a considerable addition to the generation at this plant, originally proposed and installed at 1,000 megawatts.  Currently, due to mid-license changes, it now produces 1,119 megawatts of power in an unregulated power market. noteworthy and important to be considered in weighing the public’s right to a living ecosystem, upstream fish passage, and protection of endangered species, is that Northfield Mountain’s original license was for a plant used to create “peaking power, and as a reserve unit.”  It can only produce 6-8 hours of stored power before it is spent and needs to purchase replacement power on the open market.  Its stated intention was to peak twice daily in high-demand winter and summer months, and once a day during shoulder months in spring and fall when energy demand is low.  Northfield now generates when demand is present, or—when energy prices will make the greatest profit for investors.  The river and the states have been impoverished by this profound change.

The building of Northfield was based on the availability of current and proposed power from collected regional nuclear sources (New England Power Pool) that included Maine Yankee (closed 1997); Yankee Rowe (closed 1992) Connecticut Yankee’s Haddam Neck (closed 1994), as well as two proposed nuclear plants at Montague, MA (never built.)  Vermont Yankee is currently the only “local” nuclear plant still operating, and its 40 year operating license expired March 21, 2012.  Its continued operation is contingent on findings in the courts.  It is currently operated at a loss by Entergy, and has a failing condenser system which could force its closure.  In short, Northfield is now operated well beyond the bounds of its originally stated purpose.  The public’s river is paying a high price for power, much of it now imported to pump river reserves uphill to Northfield’s reservoir from sources outside the region.  The ecological impacts to fish runs and the damaging flow regimes imperiling endangered species in the river are apparent.

As a facility with great ecological impacts that cannot produce any of its own power–one totally dependent on outside sources for power, one proposal for using this stored power source put before the Federal Power Commission in the 1960s was that Northfield not operate during the spring fish migration due to its impacts on the runs.  It is time to revisit the option of silencing the effects of Northfield Mountain so that towns and cities including Greenfield, Montague, Gill, Turners Falls, and Northfield, MA; and all the towns north to Vernon, Brattleboro and Bellows Falls, VT, and Hinsdale and Walpole, NH receive their share of the river’s ecological bounty.

Northfield does serve a function as an emergency “reserve unit” for ISO New England (Independent Systems Operator) during times of severe heat waves, or high winter demand, to deliver a high volume of power on short notice to accommodate spikes in the power grid.  Northfield could be taken off-line and kept in reserve to be operated by ISO New England solely for that purpose during the low-demand spring energy months when fish are migrating.  This would greatly benefit river ecology, species, and all upstream stakeholders.  New England’s power grid resources are currently rated at 15% above demand.  Removing the damaging effects of these operations on river ecology during critical months is a simple, equitable solution.

Northfield and Turners Falls have greatly profited by incremental power increases and operational changes over the past 34 years, while the public has watched flows, regulation, and conditions in the By-pass Reach wither to a brutal, feast-or-famine regime that denies spawning for endangered fish, and passage for upstream migrants.  This situation has effectively privatized the 2-1/2 miles of river, depriving my town, Greenfield, as well as Gill, of its share of fish and a river.  This de-pauperization has impacted all the towns upstream of Cabot Station and Turners Falls dam into central Vermont and New Hampshire.  None of these municipalities have received compensation, though in many states the loss and damage to these fish populations would be considered “take” under state statutes.  Damage in the By-Pass Reach to the Connecticut River’s last 300, spawning-capable Connecticut River shortnose sturgeon carries a significant federal fine, as well as possible imprisonment.

FirstLight’s new requests for more generation at both licensed sites should be rejected, and the damaging mid-license flow and power increases should be reversed in any new license.  Indeed, since there have now been no less than FIVE different owner/operators of this facility in the last 14 years, it would be prudent to grant only the shortest license possible in order to help track and minimize damage to the ecosystem due to operational/managerial changes, and protect the public’s interest in a living river.

Northfield’s impacts have never been fully measured with respect to flows in the By-pass Reach, but it is clear that fish passage is now at, or below, the paltry levels of the 1980s, and just a fraction of the 40 – 60% passage upstream long-targeted by the US Fish & Wildlife Service of fish that had been passed at the Holyoke Fish Lift.  Regulated, continuously monitored flows should be returned to the By-pass Reach at this time, and continuous monitoring should be included in any new licenses issued.  FirstLight has noted that in-stream data loggers for river levels and flow have been subject to vandalism.  Continuous camera monitoring of river levels and open and closed gate positions at the Turners Falls Dam would go a long way toward insuring compliance with any new license conditions.  This is an inexpensive solution that could easily include a back-up system.

With a federally endangered species present in the By-pass Reach, as well as federal-trust migrating American shad and blueback herring, FERC would do well to consider enforcing regulated flows in this stretch in accordance with law and statutes in the current license.  NOAA’s National Marine Fisheries Service has had the USGS Conte Lab findings from studies in the By-Pass reach by Kynard et al, in their possession since 2007.  This agency—as well as the MA Division of Fisheries and Wildlife, could intervene at any time.  These impacts are also affecting the success of the federal/state Connecticut River Migratory Fisheries Restoration, begun in 1967, which stipulates that all the states share equally in the bounty of migratory fish—as both a recreational and seafood resource.  In several studies by the Massachusetts Cooperative Fisheries Unit at UMass/Amherst from the 1980s it is noted that blueback herring, (Alosa aestivalis) were noted gathering at the base of Turners Falls Dam, and were also noted spawning in the mouth of the Fall River–just 300 feet downstream of the dam, by then Conte Lab Director Steve Rideout.

Further, in the late 1980s, in another mid-license power up-rate, up to 5,000 CFS was redirected out of the By-pass Reach and into the Turners Falls Power Canal for use by Cabot Station and a refurbished Unit # 1, some 1-1/2 miles upstream of Cabot.  This was undoubtedly another blow to the shortnose sturgeon attempting to spawn at their ancient grounds at the Rock Dam, though sturgeon spawning in the Connecticut here was not confirmed until 1993.

In the PAD, it is noted that FERC had not found any compliance issues during its inspections of these two projects.  However, as well as a failure to release minimum flows for sturgeon in 2009, I would direct you the US Environmental Protection Agency’s August 3, 2010 letter and Administrative Order Docket No. 10-016, sent to Mr. James Ginnetti, FirstLight Vice President, noting violations of the federal Clean Water Act.  FirstLight knowingly dumped up to 45,000 cubic square yards of silt into the Connecticut River below its fouled pumped storage plant in an attempt to clear its tunnels and intake.  This illegal enterprise was undertaken by FirstLight after failing to conduct silt removal in a manner consistent with the “due diligence” stated in its operating license.  This dumping took place throughout upstream fish migration season, May 1, 2010, or thereabouts, and continued until the EPA Cease and Desist Order of August 2010.  At that time, FERC then became involved in this egregious license violation, requesting a full report from Mr. John Howard, Plant Manager, in a FERC letter dated August 10, 2010.

In a subsequent fall meeting with agency and non-profit river interests, a FirstLight representative stated that they did not know how to remove silt from their upper reservoir, and that it had never been done successfully.  That admission came after 40 years of operating their plant.  Hence, the public, and FERC are being asked to grant a new license to operators who have not shown they can successfully maintain their facility without profoundly affecting a navigable four-state waterway and a migratory fish highway.  FirstLight has now asked for deadline relief, and is promising to have a study of siltation completed in 2014.  Perhaps all study decisions should be held in abeyance until that time, 2014—which would comply with FERC Licensing Guidelines.

 

Sincerely,

Karl Meyer

Greenfield, MA

THE RIVER FIX FOR FATAL ATTRACTION

Posted by on 12 Dec 2012 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, ecosystem, endangerd shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, salmon hatchery, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab, USFWS

NOTE: The following piece, slightly edited, appeared earlier this month in Connecticut River Valley publications and outlets in CT, MA, and VT. The original version is below.

http://www.rutlandherald.com/article/20121206/OPINION04/712069975/1018/OPINION

http://www.recorder.com/home/3161519-95/falls-shad-fish-canal

Copyright © 2012, by Karl Meyer

The River Fix for Fatal Attraction

With a salmon hatchery program no longer clouding issues, the US Fish & Wildlife Service, National Marine Fisheries Service, and directors from MA, VT, NH and CT have a singular opportunity to redeem the Connecticut River restoration. They’re currently making choices for restoring migratory fish north to Bellows Falls, VT, begun under the 45 year-old New England Cooperative Fisheries Compact. The decisions stem from the 1965 Anadromous Fish Conservation Act. They’ll seal this ecosystem’s fate at four federally-licensed dams and the Northfield Mountain Pumped Storage Station until 2058.

US F&WS’s Region 5 Director Wendi Weber, John Warner, and Ken Sprankle will join National Marine Fisheries’ Daniel Morris, Julie Crocker, and MA Fish & Wildlife’s Caleb Slater in making the decisions—with input from state directors. Their 1967 mandate is restoration of shad and herring runs to offer the public “high quality sport fishing opportunities” and provide “for the long-term needs of the population for seafood.”

Sadly, in 1980 their predecessors abandoned two miles of the Connecticut to the power company operating at Turners Falls and Northfield Mountain. By allowing privatization of the river at mile 120, they killed chances of passage success for millions of American shad barred from spawning at Greenfield, Gill and Northfield, MA, right to the foot of Bellows Falls at Walpole, NH at mile 172. Unwittingly, they also continued the decimation of the ancient spawning grounds of the river’s last, 300, viable federally-endangered shortnose sturgeon.

Instead of mandating river flows and a direct route upstream to a lift at the dam, they acquiesced to diverting migrants into a power canal. That Rube Goldberg–a three-trick knot of currents and ladders, proved an utter failure to the hundreds of thousands of shad moving upstream annually through elevators at Holyoke Dam. There, via a lift built in 1955, 380,000 American shad streamed north in 1980. It’s the East Coast’s most successful fish passage; it by-passes the city’s canals.

Half or more of those shad swam upstream; but foundered in the treacherous Turners Falls complex. At the dam, just as today, some depleted their energies by treading water for weeks—washed back and forth by a power company’s deluge-and-trickle releases, finding no elevator or upstream entrance. Many eventually turned back, only to be tempted by spill from their power canal. Fish unlucky enough to ascend the ladder there found a desperate compromise. Over 90% wouldn’t exit alive. Just as today, alien habitat and extreme turbulence overwhelmed them. Only 1-in-100 emerged upstream. For the rest, a turnaround spelled almost certain death in turbines. Others lingered for weeks in an alien canal environment, until they expired. Just as today.

This year over 490,000 shad passed Holyoke. Half or more attempted to pass Turners Falls. Just 26,000, or 1-in-10, swam beyond the dam–a percentage consistently reached in the 1980s. This is described as “success” by US Geological Survey Conte Lab scientists, Dr. Alex Haro and Dr. Ted Castro-Santos, after fourteen seasons of canal study. In work garnering annual power company subsidies, they’ve attempted to model that canal is a viable migration path.

I interviewed Dr. Haro in 2007, subsequent to a 1999-2005 study finding shad passage at Turners Falls had plummeted to “one percent or less” directly on the heals of Massachusetts 1999 energy deregulation for the Northfield Mountain-Turners Falls’ complex. I asked why passage had failed there, “I wouldn’t call it failure,” Haro replied. Fish passage saw no significant rebound until 2010, when the effects of GDF-Suez’s Northfield Mountain plant were stopped cold for 6 months—sanctioned by the EPA for massive silt dumping. Likewise, Dr. Castro-Santos’s claims to passage of one-in-ten fish as progress seem deeply troubling when his findings, after 14 years, are just now revealing shad dying “in droves” in that canal, “We don’t know why.”

In 1865, James Hooper, aged 86, of Walpole, NH reported: (from The Historical Society of Cheshire County (NH) “The area just below Bellows Falls was a famous place for catching shad because they gathered there but did not go up over the falls. The fish were caught with scoop nets. One spring Hooper helped to haul out 1300 shad and 20 salmon with one pull of the net.”

Citizens upstream of the 1798 Turners Falls Dam need not accept the dead shad runs and severed ocean-ecosystem of the last 214 years at a dam operated to cull price-spikes from the electricity “spot market.” An 1872 US Supreme Court decision against owners of Holyoke Dam mandates passage of the public’s fish. Nor do citizens from Old Saybrook, CT to Bellows Falls have to accept endangered sturgeon, a lethal canal, and a dead river at mile 120. After 32 years of fatal attraction at Turners Falls, its time to stop steering fish into a canal death trap. Holyoke proves that’s possible.

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

« Previous PageNext Page »