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REIMAGINING A RIVER, Part 2: Not Nearly Hydro Power; Not Renewable Energy

Posted by on 17 Jun 2020 | Tagged as: American shad, B. D. Taubert, Clean Water Act, climate-destroying, Connecticut River, Connecticut River Conservancy, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Environmental Protection Agency, EPA, Federal Energy Regulatory Commission, FERC, FirstLight, Fracked Gas, GHG, Hudson Riverkeeper, ISO New England, ISO-NEW ENGLAND, Mike Dadswell, Natural Gas, Nepool, Nepool, Phil Glick, Sam Lovejoy, Turners Falls dam, Turners Falls power canal, Uncategorized, Waterkeeper Alliance

THIS GREAT AND BROKEN RIVER VII

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 7, Part 2, REIMAGINING A RIVER: Not Nearly Hydro Power; Not Renewable Energy, Northfield Mountain’s Transition from Nuclear-fueled Net-loss Energy to Natural and Fracked Gas Net-loss Energy.

Author’s Notes: It is impossible to write at this time without mentioning the obvious. The country is in a moral crisis right now and it is time to stand up for the rights of Black people, and for the survival–and revival, of our democracy. This is a precious opportunity, one that we squander at our peril.

In the river-keeping world, there is also an opportunity for change that must be grasped now. The relicensing of MA CT River hydro and pumped storage projects is quietly moving toward its end game. A new model for protecting the ecosystem for coming generations is imperative. These licenses will govern conditions on the mainstem river for decades to come, and there is not a credible organization on the ground here that’s up to the task. The link below was forwarded to me. This is what’s called for. It will take hard work, money, and organizing. I hope there are those out there ready to contribute for the love of New England’s Great River.

https://waterkeeper.org/news/waterkeeper-alliance-to-appear-in-the-visionaries-series-on-pbs/


9-6-2010: Northfield Mountain Pumped Storage Station under EPA Sanction for violations of the Clean Water Act forced to dredge the hundreds of tons of muck they dumped into the River over a 3 month span.Photo-Copyright-©-2020-by-Karl-Meyer All Rights Reserved. (Click X3 to enlarge, use back arrows to return to text)

The Connecticut River has been running in reverse in northern Massachusetts for nearly half a century now. Daily at Northfield—125 miles from Long Island Sound, New England’s Great River is strangled away from its ancient gravitational course and literally forced to run counter to its nature. It’s not some bizarre phenomena related to distant tides, nor even some twisted water park trick. It’s caused by the lethal, ecosystem choking mechanisms of the Northfield Mountain Pumped Storage Station.

That river suction and reversal is the by-product of a massive, net-energy-loss, power re-generation scheme begun in the early 1970s. Originally running on the profligate excesses of nuclear power, today NMPS plugs in daily to suck giant streams of climate heating, natural-gas- produced megawatts from a bloated New England power grid. By yanking the river backward, Northfield’s huge energy and water appetite results in damage across parts of three states. Just a fraction of its ecosystem impacts have ever been fully measured and understood.

Since 1972 there’s been just seven months out of one year where those impacts were silenced. Beginning in May of 2010–and for the first time in the decade after Massachusetts implemented electricity deregulation, American shad passage at the Turners Falls Dam showed dramatically, exponentially, renewed signs of life. The big mystery was: why?

EPA-ordered Dredge Spoil Dump Site Mountain on Rt. 63 site after NMPS choked on its own silt and shut down for 7 months. Today that scar is covered by a friendly looking solar array. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge, back arrows to return)

By June of that spring, with the abrupt silencing of grim river conditions created by Northfield’s massive sucking and surging, 5 miles upstream of Turners Falls Dam, the rising shad passage results could not be ignored. Fish passage in the river and up through the power canal past that dam was already known to be sorely impacted by the annual deluge-and-dearth flows that Northfield visited on the Connecticut. Without its suck and surge, ecosystem conditions changed immediately. Shad passage at Turners Falls soared to more than 500% above the average for the prior decade. And, no surprise, the New England power grid worked just fine without the daily addition of Northfield’s costly peak inputs.

The Northfield Mountain Pumped Storage Project was designed as a net-power-loss, buy-low/sell-high, money-making cousin to the now-closed Vermont Yankee nuclear plant. It was built to profit by piggy-backing on VY’s nightly over-bloat of cheap, excess megawatts. With VY as its engine, Northfield started massively twisting the Connecticut into a broken, reversing knot in northern Massachusetts, 125 miles from the sea.

When it came on-line in 1972, NMPS corralled for its use a full 20 miles of river—slowed and stilled behind the Turners Falls Dam all the way into southern Vermont and New Hampshire at Vernon Dam. Since that time it’s been yanking the Connecticut’s currents into reverse and sideways daily, ultimately sucking them a mile uphill into their 4 billion gallon reservoir via net-loss grid megawatts. But with Vermont Yankee closed in 2014, Northfield is today juicing an ecosystem by gorging on climate changing, natural gas produced megawatts–which is what now powers half of all New England’s energy consumption. And, ironically, the bulk of traditional hydropower consumed in this six-state region is actually produced hundreds of miles away in Canada.

Plugged-in to run via four giant, reversible turbines, the Federal Power Commission in 1972 sanctioned NMPS to operate as a net-loss emergency back-up and peak demand regeneration appliance. It would do so by consuming 25% percent—or at times over 30% more, electricity than it would ever later re-feed into the power grid as peak-priced megawatts. After Northfield’s dumping in of its 6 hours of peak-priced, net-loss energy, it would then be completely dead-in-the-water and have to begin its daily cycle of gobbling up virgin grid juice to suction the river uphill again. Consumers would pay for Northfield’s privileged permission.

Upon start-up NMPS’s daily net-loss operations became the most disruptive and efficient fish killing machine in a four-state ecosystem. Northfield kills virtually everything it sucks into its turbines for hours at a time, drawing in at up to 15,000 cubic feet per second everything from tiny fish eggs to full-size American eels. That deadly draw is known as entrainment, with the result being all fish disappearing through its pumping turbines termed “functionally extirpated.” The daily carnage continues down to this day.


7-20-2010: Clouds of Silt Plume around a nearly-invisible French King Rock in the Connecticut River from FirstLight’s illegal silt dumping. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge)

A 2016 FirstLight consultant’s study estimated NMPS’s operations resulted in the loss of just 2,200 juvenile American shad. Yet study results released in 2018 by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated the carnage from a year of Northfield’s operations was massively higher. Their study estimated a single year loss of 1,029,865 juvenile shad. And that’s for just one of four migratory fish species subject to its suction annually—the others are American eel, blueback herring and sea lamprey. Consider then, that there are another 20 resident fish species sharing that same Northfield reach of the Connecticut, plus recent findings that federally endangered shortnose sturgeon may also be present. The more NMPS runs, the more life it kills.

As far as Northfield’s massive energy consumption impact goes, here are a few recent statistics: In 2018 FirstLight reported to the Federal Energy Regulatory Commission that NMPS consumed 1.205 billion Gross Kilowatt Hours pumping the river backward and uphill to its reservoir. After doing so, it later reproducing just 907 million GKH of peak-priced power. In the following year, 2019, NMPS consumed 1.114 billion GKHs, while only actually regenerating just 828 million GKHs to send back through the wires.

The tritium-leaking Vermont Yankee Nuclear Station closed in 2014, putting an end to its 42 year run of heating up the Connecticut River—but leaving in its wake a deadly thousand-year legacy of high-level radioactive waste. Since that time NMPS’s net-loss megawatts have transitioned from running on nuclear to being the ugly by-product of sucking in the climate-changing megawatts from a New England grid largely run via natural gas. Natural and fracked-gas today supply nearly half of all New England’s electric power. And Massachusetts, living far beyond its means, is the grid’s biggest customer.

The bloated power grid all that juice is relayed over is today run, supported and marketed by the likes of the Federal Energy Regulatory Commission, ISO-New England, Nepool, and a host of private corporate interests. The public is essentially shut out of both ISO-New England and Nepool decision making, as is the media. That is living proof of the failure of energy deregulation here. We’re failing our kids.

In that vein, there is another way to examine the absurdity of NMPS’s benefits vs. ecosystem impacts. FirstLight’s Northfield Mountain Pumped Storage Station’s annual net-loss-energy consumption largely erases the output of traditional, locally-produced Connecticut River hydropower from FirstLight’s own Turners Falls power canal and Cabot Station just downriver.
FirstLight’s 2018 actual hydropower operations 5 miles downstream at their power canal and Cabot Station reported generating 316 million Gross Kilowatt Hours of electricity. In 2019 FirstLight again reported on those hydro operations, which totaled 357 million GKHs. There was a 398 million GKH deficit produced by Northfield pumping the river uphill in 2018—used to later regenerate second-hand juice. That deficit erased nearly all 316 million GKH of the hydropower FirstLight produced downstream. In 2019, Northfield’s deficit of 286 million GKHs whittled the contribution of all Turners Falls hydro operations down to just 71 million GKH of the 357 it produced. The river and consumers pay dearly.

FERC, today, is comprised of just four commissioners, three of them Trump appointees who consistently vote to sanction big, climate-heating GHG extraction and export schemes for giant corporations. The lone Democrat, Phil Glick, is the sole voice calling on the Commission to consider climate impacts. Piggy-backing net-loss, river-killing power on top of imported, climate-destroying GHG generation is a grim business. FERC and ISO-New England have fashioned a huge, consumptive system where the public never has to give a thought to its unseen, climate-killing energy sources. Their scheme has blithely conditioned the public to always having at its fingertips a seemingly-limitless energy supply—deceptively cheap, always on hand, and available at a moment’s notice. By design here’s no thought process involved; no downside visible. That, in itself, is a crime against future generations.

In its current, over-bloated, over-subscribed power configuration, the New England power grid could run just fine without the daily depredations of NMPS’s peak use. Solar proliferation has recently resulted in the addition of 3400 megawatts of locally-produced renewable energy, nearly tripling the imported, 1100 MW of brief, peak, second-hand output from NMPS. Particularly in spring–when energy use is lowest and fish are migrating, spawning and a river is regenerating its life, Northfield’s deadly use should be limited to emergency output only. The carnage needs to stop.


9-3-2010: The Mountain of NMPS Dredged Sludge Growing along Rt. 63 after EPA’s Clean Water Act sanctions. Photo Copyright © 2020 by Karl Meyer (Click X3 to enlarge, back arrow to return)

Ironically, while Northfield Mountain was being proposed and ultimately built, a new coalition of anglers and environmentalists over on the Hudson River fought off plans for a similar pumped storage station proposed by energy giant Consolidated Edison in the late 1960s. That very public and consolidated action by citizens saved both the Hudson River and the top of scenic Storm King Mountain from becoming cogs in a killer machine like the one here. The on-the-ground result was ultimately an organization now known as Hudson Riverkeeper. Sadly, a similar battle wasn’t waged here to save the Connecticut. The top of Northfield Mountain was blasted to oblivion to create a 4 billion gallon reservoir and two massive, mile-long water shafts were sunk through rock to begin sucking up a river.

That failure to thwart Western Mass Electric/Northeast Utilities’ pumped storage scheme occurred even though the Connecticut River Watershed Council would be 20 years old in 1972 when NMPS finally plugged itself in. However, since that battle for the Hudson, the Hudson Riverkeeper and WaterKeeper alliances have blossomed into key organizations in ecosystem protection, proliferating and thriving via a very public investigation, enforcement and litigation model. They are upfront and vocal about consistently taking offending corporations to task and prosecuting them.

The only solace in the River’s history here in Northern Massachusetts is that the public got wise to the environment–and to the unending downsides of nuclear waste and building fleets of reactors and river diversions. In the early 1970s Northeast Utilities proposed another two nuclear plants, twins, both to be built on the Montague Plains. Their hot wastewater would be flushed into the nearby Connecticut River. They never got built.

On February 22, 1974, Sam Lovejoy of Montague Massachusetts set about loosening the bolts and toppling a Northeast Utilities weather testing tower, installed there to monitor winds to inform the planning layout for nuclear emergency evacuations—just in case there might be a little meltdown at the twin nuke site. That act of courage and civil disobedience, undertaken with deliberation and with an understanding of its potential civil consequences, bolstered a gathering opposition to the project. It ultimately helped galvanize a growing opposition to dozens of proposed reactors across the country.

It was a combination of that direct public opposition, Lovejoy’s protest and the subsequent discovery of larval shortnose sturgeon by research biologists Mike Dadswell and B.D.Taubert that ended what would today be yet another sprawling nuclear waste dump sitting above the Connecticut River. Again, a strong leadership role was not played by the Watershed Council. What ultimately made the difference was concise action, public engagement, and legal action in the courts. This was a victory for those who take full responsibility for the public turf they lay claim to.

The Connecticut River Watershed Council just recently became the Connecticut River Conservancy, but it still remains an organization laying claim to protecting the mainstem Connecticut across four states while not employing a single staff lawyer. Nor has it adopted a mission mandate to enforce and prosecute–continuing the model of a CRWC legacy dating back to 1952. The Connecticut River has long deserved better.

REIMAGINING A RIVER: The Year without Northfield Mountain

Posted by on 01 Jun 2020 | Tagged as: American shad, Clean Water Act, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River Coordinator, Connecticut River pollution, Connecticut River Watershed Council, CRASC, Daily Hampshire Gazette, EPA, Federal Energy Regulatory Commission, FirstLight, fish passage, Gary Sanderson, Greenfield, hatchery, Holyoke Dam, ISO New England, Larry Parnass, MA Division of Fish and Wildlife, migratory fish, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Old Saybrook CT, pumped storage, Riverkeeper, salmon, salmon hatchery, The Daily Hampshire Gazette, The Greenfield Recorder, The Recorder, Turners Falls dam, Turners Falls power canal, US Environmental Protection Agency, USFWS

THIS GREAT AND BROKEN RIVER VII

Copyright © 2020 by Karl Meyer. ALL RIGHTS RESERVED.

Issue # 7, Part 1, REIMAGINING A RIVER: The Year without Northfield Mountain


Sunderland Bridge over the Connecticut. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

AUTHOR’S NOTE: I have found it difficult to write these past days. I am heartsick for my country. Are we to be a fair, generous and courageous people, or just a collection of frightened, soulless bystanders? What world do we want our children to grow up into? I have not been without a few tears at times over the past week. But, I know that good work and living rivers benefit all; they do not hate, judge, murder, or discriminate. So, noting that all of us have some heart-work to do, I continue here, with this also…

On May 1, 2010, I began a 5-day cycling trip from Greenfield MA, downstream to Long Island Sound and back again along the Connecticut River. I set out by bike to highlight and blog about the massively wasteful and misplaced emphasis on the forever-failed, hatchery-produced, 40 year-old salmon program for the river. Meanwhile, across the preceding decade, the formerly growing and robust American shad runs had concurrently experienced precipitous declines in fish passage returns at Holyoke Dam. More importantly, the shad run was literally flirting with extinguishment upstream of the Turners Falls Dam.


Miserable shad tally board at TF Fishway, 2007. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

The plunge at Turners Falls had taken hold pretty much simultaneously with the implementation of newly-legislated electricity deregulation in Massachusetts. It gave owners of the Northfield Mountain Pumped Storage Station a license to unleash new, lucrative and disruptive flow regimes in the river—just 5 miles upstream of Turners Falls Dam. Ironically, that same May Day when I left for the mouth of the river, was the day that Northfield Mountain was scheduled to shut down to begin mucking out the decade’s worth of silt and muck they’d inhaled up into their 4-billion gallon mountaintop reservoir.


Cyclist’s Shad Dinner, Saybrook CT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Unbeknownst to me–and to NMPS management, once they shut down and started draining their reservoir that net energy loss contraption would not suction the river again for over half a year. They broke their regenerating plant; their muck half-filling the mile-long tunnels connecting it to the river. FirstLight then tried to hide their plight and the evidence as they turned around and massively polluted the river for months. That came to an abrupt halt when the EPA(remember them?) issued a “Cease and Desist” order against them extensive violations of the Clean Water Act.

But, a great upshot benefit soon came into focus: with the river not suctioned and ramping up-and-down at Northfield, successful fish passage at Turners Falls Dam jumped back to well over 400% over 2009 totals–leaping to 16,422 shad passing in 2010(though likely significantly more, since FirstLight’s fish counting software was curiously ‘inoperable’ on 17 different days that spring), while just 3,813 shad squeezed past Turners Falls in 2009. Overall, that 2010 rise peaked at over 500% above that decade’s previous passage averages there. I returned to Greenfield on May 5, 2010, and learned of NMPS’s disastrous de-watering that same afternoon. It was of great interest, but its significance wouldn’t be understood for weeks until the unusual and increasing shad tallies passing Turners began coming in.

Just 3 years earlier, after spending over half a decade working at the Northfield Mountain Recreation Center (where I’d even for a time been secretary for the Safety Committee up inside the pumped storage power plant), I quit. The dismal shad runs, just downstream, were chewing on my soul.


Lynde Pt. Light at the River’s Mouth, Old Saybrook CT. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

By that May of 2010, I’d been doing part-time work for the Connecticut River Watershed Council for a few years. I immediately informed the Council of Northfield’s predicament when I got back. Sadly, I then had to watch their back-seat, kid-gloves handling of an opportunity to prosecute and hold the power company responsible for massive pollution. They stayed quietly in the background, letting the Massachusetts DEP and MA Div. of Fish & Wildlife take charge of holding FirstLight’s feet to the fire. It was a massive opportunity to begin taking on the gross daily river depredations of Northfield Mountain, but it was mostly just squandered here in Massachusetts.

The Commonwealth and MA Fish & Wildlife did little, though some effort by MA DEP and Natural Heritage ultimately bargained for a study of erosion effects on endangered dragonflies as some sort of restitution. I later felt compelled to quit the Watershed Council, which I did five months later. They weren’t players, likely because their board was full of former power company managers and folks still working as consultants, who might see some power company contract work in the future. It was just wrong that–as one of the oldest river organizations on the East Coast, they didn’t have a single lawyer on staff, nor have a mission that mandated enforcement. This was no Riverkeeper.

It wasn’t really until early that June that I began to realize the full ramifications of Northfield’s shutdown. Fish passage numbers just began creeping higher and higher at Turners Falls. I attended a June 22nd meeting of the Connecticut River Atlantic Salmon Commission (CRASC)—the Congressionally-authorized fed/state fisheries organization charged with managing and protecting migratory fish on the Connecticut. I asked the agency reps if they’d noticed the numbers and whether they’d been doing any studies on the relationship between the big shad passage at Turners and the turbine disaster upstream at Northfield. “We haven’t looked at it,” said a relatively new USFWS Connecticut River Coordinator Ken Sprankle.


Jilted American shad flashes CRASC attendees at the TF Power Canal. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Even then, I was as yet unaware that NMPS was STILL not operating. But I got a curious look from FirstLight’s Bob Stira, also in attendance, when I posed that question. That look–and the immediate notice of the shutdown of Northfield Mountain’s reservoir trails that same afternoon, is what soon sent me on a recon trip with a camera up to that reservoir. I started crunching numbers and writing. On a Sunday morning one week later I found an unposted back woods trail up to the reservoir, and there was the whole story.

Days earlier, I’d independently handed over some initial fish passage numbers and gave a few pointed quotes in an email to Gary Sanderson, sports and outdoors editor at The Recorder. Gary enthusiastically included them in his column along with his own comments. The following week, after FirstLight’s sudden and inexplicable closure of trails leading to the reservoir–plus immediately moving their riverboat tour boarding site from Northfield down to Barton Cove in Gill, I snuck up and took a photo of that emptied reservoir with two fat earth movers sitting silent in the silt-filled bed.


Emptied Northfield Mountain Reservoir. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

Their riverboat got moved downriver to hide from the public the chocolate colored river that Northfield’s dumping was creating at intake tunnels next to the Riverview dock site. The silt cloud reached all the way down to the French King Bridge.


Muck-plagued Connecticut River beneath the French King Bridge. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrows to return to text)

In late June, Daily Hampshire Gazette Editor Larry Parnass ran my rather telling Northfield Reservoir photo above my expository OpEd bringing to light the disaster there–and the surprise fish passage bonanza occurring at Turners Falls Dam. It wasn’t until the first week of August that the EPA finally stepped in to order FirstLight to cease and desist. They’d been dumping the equivalent of 40-50 dump truck loads of reservoir muck directly into the Connecticut for over 90 straight days. That EPA order would keep Northfield shutdown well into November.

Despite Northfield’s claims of the usefullness of its daily input, and the touted critical emergency readiness of their net-energy loss machine to the grid, no one in New England went without electricity in the long months their river-strangling contraption was lifeless. The only mourners during its 7 month coma appeared to be two climate-change cheerleaders: ISO-New England and the Federal Energy Regulatory Commission. Yet even during a long hot summer–one in which Vermont Yankee shut down for a week to refuel, everyone had essential power. The public didn’t miss Northfield, the shad run blossomed, and a river came back to life.

The Broken Connecticut

Posted by on 09 Oct 2018 | Tagged as: American shad, Clean Water Act, Connecticut River, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, pumped storage, Relicensing, shad, Uncategorized


Copyright © 2018 by Karl Meyer. All Rights Reserved

Eight years ago, almost to the day, this is how the Connecticut River in front of the Northfield Mountain Pumped Storage intake looked. (Click, then Click twice more)

The owners were under sanction from the EPA and had been scrambling for months to suction the mountain of reservoir silt they’d illegally dumped directly into the Connecticut after massively botching their reservoir de-watering and clean-out.Northfield remained inoperable from May 1st through early November. To minimize the reactivation of silt they’d already fouled the river with, they set up a ponderously long silt curtain–supposed to keep their gunk in place. Below, is how their silt-safety set-up looked on July 20, 2010 (Click, the Click twice more)

However, if you look at how effectively that sanctioned-solution was when employed-by–and deployed by the company, you would have to look at this photo below from October 2, 2010. (Click, then Click twice)

The sole solution FirstLight has proposed in these FERC proceedings to prevent the suctioning deaths of millions of juvenile shad–and that’s disregarding their round-the-year evisceration of adult and young fish of dozens of species, is to place a barrier net across the mouth of their giant suction and slice pumped storage contraption. This, for the next several decades, would be like putting a band-aid on a massively severed artery. If they couldn’t keep a net in place in the river when Northfield was sanctioned NOT pumping at all, what gives anyone the idea that this bit of window dressing will be of any service to a broken river system at all.

Since FirstLight is proposing to suck more water out of the river to suck into that reservoir, why not trade that money-making scheme for having NFMT shut down at key seasons to comply with the law and protect the Public Trust.

In delivering the 1872 Supreme Court’s decision in Holyoke Company vs. Lyman, Justice Nathan Clifford entered the following into his decision:

“Ownership of the banks and bed of the stream, as before remarked, gives to the proprietor the exclusive right of fishery, opposite his land, as well as the right to use the water to create power to operate mills, but neither the one nor the other right nor both combined confer any right to erect obstructions in the river to prevent the free passage of the fish up and down the river at their accustomed seasons.”

In deciding against the dam owners who had repeatedly refused to construct fish passage at their dam as settled law in the Commonwealth had long required, the Court made upstream and downstream passage of the public’s fish a precedent and legal right in rivers throughout the United States.

“Fish rights below a dam, constructed without passageways for the fish, are liable to be injured by such a structure as well as those owned above the dam, as the migratory fish, if they cannot ascend to the head waters of the stream at their accustomed seasons will soon cease to frequent the stream at all, or in greatly diminished numbers.”

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

Sucking out the river’s life

Posted by on 11 Aug 2015 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, EPA, Federal Energy Regulatory Commission, FERC, FERC license, GDF-Suez FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Relicensing, The Recorder, Turners Falls dam, Turners Falls power canal, US Environmental Protection Agency, US Fish & Wildlife Service

The following piece appeared in The Recorder in Greenfield, MA in the first week of August.

Sucking out the river’s life

Copyright © 2015 by Karl Meyer

Whether it’s Federal Energy Regulatory Commission licensing for a sprawling gas pipeline or a cluster of power projects on the Connecticut, the public isn’t getting the accountability and voice its entitled to. That hit me after contacting Tobey Stover from the US EPA’s Region 1 Offices about GDF-Suez FirstLight’s Northfield Mountain Pumped Storage Station. I called EPA because FirstLight had just given notice they were cancelling part of an ongoing sediment-testing program to gauge the impacts of their giant Northfield station on the Connecticut’s ecosystem.

EPA mandated that long-term testing after FirstLight massively violated the Clean Water Act by “polluting the navigable waters of the United States” in August 2010. To wit: they’d dumped the equivalent of 30 – 40 truckloads of sludge directly into the river at Northfield—each day for over 90 days straight, until getting caught. In the largest case of profligate dumping in decades, miles of river bathed in over 45,000 cubic square yards of sludge—smack in the middle of fish spawning time. Continuous testing was being required, in part, for inclusion in GDF-Suez FirstLight’s application for a new FERC license to continue sucking giant gulps of river to generate secondhand electricity.

Despite what many think, Northfield is not a hydropower plant. It’s a double-energy-loss, net-cash-gain contraption. It’s an energy transfer, storage and resale operation—offering twice-generated electricity back to the grid at peak-demand, peak market prices. Northfield was conceived as a giant, nuclear-powered pump. It technically qualifies on the books as a 1,200 megawatt unit —the output of TWO Vermont Yankees, but it supplies just a sliver of peak-priced electricity to our market while creating the most ecosystem havoc. This is a power-consuming operation, run on imported juice. On its own it can’t produce a single watt of electricity—nothing clean or renewable about it.

Northfield was built to profit from pumping the river backward via cheap, excess electricity produced at night at regional nuclear plants. With the nukes closed, it continues slicing through a river’s aquatic life on a diet of climate-warming fossil fuels. To do so it must purchases giant blocks of wholesale electricity so it can spend hours slurping endless gulps of river uphill through slicing turbines. When reversed those turbines spit our river back out as expensive, twice-produced juice. Sadly, Northfield can only offer 6 – 8 hours of peak-priced energy to the electricity “spot market”—because after that its 5 billion gallon reservoir is spent, rendering it unable to light your nite light. Then they start buying up “virgin” electricity to suck the river backward again.

If those daily pulses of destruction were silenced, an ecosystem would begin to heal. Though they fancy themselves as a key component of the grid, Northfield Mountain’s own sludge so-fouled its turbines in 2010 that it was instantly, unexpectedly, shut down for half a year. Yet nobody noticed, no one went without power—not even when Vermont Yankee went off-line to refuel. Instead of customers paying the high cost of a ruined river–sold back to them less than half-alive at peak prices, they received once-produced electricity without the collateral damage.

Mr. Stover at EPA was pleasant and helpful. He confirmed the world’s largest private energy purveyor would be let off their continuous-sampling-hook–because equipment they’d purchased had experienced repeated problems. They’d further petitioned EPA, whining about difficulties supplying electricity to their samplers. Hummn… GDF-Suez offered to instead use its own consulting firm to build a model of the plant’s operations, substituting simulations for real-time federal data. EPA was leaning toward accepting that too. Really?

It appears Northfield’s massive impacts are simply too violent to be directly calculated—perhaps too costly to allow to cripple an ecosystem? Why not order GDF-Suez to buy new equipment and start over? And isn’t it time EPA did their own study of the impacts of the massive sucking and juicing of all that aquatic life—fish, plants, insect larvae, twice through the turbines, for hours on end, at upwards of 15,000 cubic feet per second? Think 15,000 bowling balls a second, for hours—first up, then back through again.

Northfield creates such crushing impacts it shouldn’t have been built. Once Vermont Yankee closed, its damages should’ve been sidelined as well—used only as back-up to provide brief, dense pulses of juice during emergencies. Yet today it continues to operate, even during spring-summer fish migration season. Its voracious water appetite plays a key role in the failure of the half-century old, four-state Connecticut River migratory fisheries restoration program, Congressionally-authorized in 1967 under the US Fish & Wildlife and National Marine Fisheries.

This corporate “self-determination” is the grim legacy of the Bush-Cheney Administration’s secret energy policies. With huge gas, hydro, and pumped storage proposals on the docket, public accountability has gone AWOL. In the Holy Grail of “corporate citizenship” industry is now its own watchdog–“self-reporting” to agencies on the impacts of its own energy production and pollution. Both concepts belong in the Oxymoron Hall of Fame. Giant companies are running the table on climate, pollution, impacts and price–as our regulatory agencies fail to act on behalf of the public’s long-term interests.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists. He is participating in the FERC hydro relicensing process for power plants on the Connecticut River.

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.

New Stakeholder Comments filed with FERC

Posted by on 31 Mar 2014 | Tagged as: American shad, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, FirstLight, Northfield Mountain, US Fish & Wildlife Service, USFWS

The following Public Stakeholder Comments were filed today with the Federal Energy Regulatory Commission and Dispute Resolution Proceedings concerning Relicensing Studies to be conducted at the Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301                                                                        March 31, 2014

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments for: FERC Project No. 2485-063, the Northfield Mountain Pumped Storage Project; and FERC Project No. 1889-081, the Turners Falls Hydroelectric Project.

 RE: US. Fish and Wildlife Service’s Notice of Study Dispute, filed March 13, 2014; and FirstLight’s response filed March 28, 2014, as Information Relevant to the US Fish & Wildlife Service Notice of Study Dispute.

Dear Secretary Bose,

Please consider the following comments concerning the necessity of robust study information being required of the license applicant in order for the US Fish and Wildlife Service and stakeholders to be fairly represented in this process.  The requested full Study on impingement and entrainment and data arising from examination of Northfield Mountain Pumped Storage Station’s operational effects on all life stages of American shad is new information that will also assist FERC in fully considering public resources and the public’s interest in a balanced and functioning Connecticut River ecosystem.

On March 13, 2014, the U.S. Fish and Wildlife Service (USFWS) filed a Notice of Study Dispute with the Federal Energy Regulatory Commission (Commission) stating that the Study Plan Determination issued by Commission staff would not elicit adequate information specific to “the effects of Northfield Mountain Pumped Storage Project (NMPS) on certain migratory fish species.”  FirstLight argued that information from a 1992 entrainment study would be sufficient to stand-in for current relicensing information.

The USFWS’s information request was made to fulfill responsibilities in determining the impact of NMPS pumping operations on American shad mortality, from eggs and early-life stages, to juvenile and adult fish.  USFWS noted that a “failure to provide this information will compromise the Commission’s ability to establish license conditions and the Service’s ability to set mandatory conditions under Section 18 of the Federal Power Act (FPA).”

The USFWS further stated:

“A new study of NMPS is needed because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation that could increase the potential for entrainment at NMPS. With anticipated improvements to fish passage facilities as part of the relicensing process for the Turners Falls Project, those numbers could increase into the hundreds of thousands.”

Under Goals and Objectives USFWS stated: “The goal of the Service’s original study request (Appendix A) was to determine the impact of NMPS pumping cycle on entrainment of American shad (including early life stages.)”

Pursuant to a March 26, 2014 teleconference between USFWS, FirstLight, and Commission staff, FirstLight formally responded on March 28, 2014, by supplying a portion of six years of seasonal pumping information from NMPS.  FirstLight submitted it as being representative of an overall decrease in plant pumping operations since the original 1992 mortality/entrainment study.  FirstLight supplied monthly and daily pumping data for the bracketed years of 1991 – 1993; and then again for 2011 – 2013.  In its filing FirstLight stated that, aside from the 1992 study-year data included, the other five years “were arbitrarily selected.”

A preponderance of accepted data shows NMPS operations impacting reaches of river at least as far downstream as Holyoke Dam, 36 miles distant, as well as throughout the Turners Falls Impoundment nearly to Vernon Dam, 20 miles upstream. In the months of June and July NMPS’s unrestricted pumping output of up to 15,000 CFS actually outstrips the Connecticut’s natural flow volume. Studies confirm that entrainment of eggs, juveniles, and adult fish have significant impacts on ensuing year-class strength.  They can impact whole-river populations.

Given this understanding, the “arbitrary” pumping years FirstLight has submitted to support limiting the scope of this study appear selective, rather than “arbitrary.” They coincide exactly with the all-time peak years of fish migration on the Connecticut during the early 1990s, and again, with the only shallow bit of improvement for shad migrating into the Turners Falls Impoundment since deregulation in 2000–the years 2011, 2012, and 2013, leading directly into a relicensing application. It should be noted that “arbitrary” is not synonymous with “random.”  Random is an accepted scientific parameter.

It is noteworthy that FirstLight selected as its first grouping the years 1991 – 1993 for pumping information.  Those years selected can be characterized as skewed, rather than arbitrary or random, in that two of them represent the highest years of fish passage ever recorded (1991, 1992) through Turner Falls Gatehouse.  These were record years along the entire river. However, the slight fall-off starting in 1993, began the first extended period where shad returns along the Connecticut River began a steady downward spiral.

The other data set FirstLight offers as “arbitrary” are from the years 2011 – 2013.  What is interesting about this “arbitrary” FirstLight data is that it excludes the entire decade–beginning in 2000, when NMPS began operating as a deregulated entity. Then, as today, NMPS could draw, and release—unrestricted, up to 15,000 CFS into the TF Pool, according to market prices and demand.  What is powerfully obvious about the years not included in their study data is that 2000 – 2009 represent the worst decade of fish passage at Turners Falls Gatehouse ever, with passage counts dropping to 1% or less some years. Some might describe this as cherry picking data.  They arbitrarily picked the only two minor peaks of any note across a very dismal quarter-century of poor upstream shad recruitment.

Good science requires, at minimum, randomly selected figures when data samples are too large. That is not the case here.  We are only considering 25 years of data, and only three months from each year.  A complete data set should be provided—especially when it is small, as in the present case.  Given such a brief span of time, and considering that a FERC license may be in place for 30 or 40 years—data from years 1991 to 2013 should be presented to better understand entrainment, mortality and recruitment of all life stages.

Significantly, as history, in 2010, FirstLight entrained its own turbines at NMPS plant while attempting to clear silt from its upper reservoir. NMPS operations came to an abrupt halt; the US EPA sanctioned them for “polluting the navigable waters of the United States,” and no pumping occurred at NMPS from May 1st, until November.

Fish passage at TF Gatehouse in 2010 saw a 400-500% increase over averages for the previous decade that year NMPS remained inoperable.  However significant that increase was, it merely represented a return to disappointing fish passage and recruitment levels regularly reached there in the 1980s.  The following year, Holyoke Dam saw a 30% increase in fish passage, yet no corresponding increase in shad passage was tallied at TF Gatehouse in 2011. 

However Gatehouse fish passage did continue–across the “arbitrary” 3-year data set FirstLight submitted for 2011 – 2013, to show a level of fish passage comparable to the returns achieved in the mid-1980s.  By not including pumping files from 2000 – 2009, FirstLight offers just three years of data during which improved fish passage numbers could be shown—but only if passage and recruitment targets are scaled back to the disappointing results of the 1980s.

As “arbitrary” as those selected years of data may be, they only give a snapshot of three “good” years of fish movements and recruitment above Gatehouse toward Northfield and VT/NH habitats. Certainly it’s possible that pumping operations get skewed over some years for various reasons.  But three years of data–just prior to a relicensing bid, is no substitute for the full set of pumping files.  Pumping data beginning from the year of deregulation—2000, to the present, will shed light on the impacts of pumping on entrainment and recruitment across the time frame necessary to help make decisions on issuing a decades-long license.

Ample decision-making studies and data—beyond just the most recent years FirstLight wants to supply, is what are called for in this instance.  The remaining pumping data, monthly, daily, along with standard deviations for the years 2000 – 2009, should be supplied in order to protect public resources.

Stakeholders should have an understanding of the plant’s potential pumping impacts and a fuller knowledge of the spectrum of its operating regimes since becoming a deregulated entity across three different owners—as there is no guarantee of single, long-term ownership over the term of license.

It is also critical to note that an overall “decrease” in pumping across selective years is just a single factor and may not be as significant to various life-stages of fish survival as the actual days, dates, and times when pumping and entrainment is occurring.  This is why the full USFWS entrainment study and a full report of pumping operations are necessary.  This is information that is sorely lacking.

Under Existing Information the USFWS states: “In its original study request, the Service noted that, while a number of studies had been conducted over the years, only one study attempted to quantify the number of shad entrained at NMPS.”

USFWS further stated that information from a single study conducted in 1992 would be insufficient for determining new protective licensing requirements: “The ichthyoplankton sampling requested by the Service would follow the methodology used in the 1992 study.”  USFWS further argues: “Existing information is not sufficient to use in the relicensing proceedings because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation as part of relicensing and that could increase the potential for entrainment at NMPS.”

Nexus to project operation and Effects: “Both the previous licensee (Northeast Utilities Service Company) and FirstLight assume that all fish entrained are lost to the Connecticut River system (i.e., 100% mortality). Without quantification of entrainment of all life stages of American shad, it is not possible to determine what the overall impact of that entrainment is on the shad population. This information relates both directly and indirectly to the Service’s statutory responsibilities under Section 18 of the FPA;”

Cost: The US Fish and Wildlife Service notes that a suitable entrainment study that includes early life stages can be conducted at NMPS for well under $50,000.  This is a modest expense to attain critical information that is not available elsewhere.  Not gathering such information would amount to a failure of due diligence in the current relicensing.  A single, 22 year old study is inadequate science on which to base conditions for a license that could impact the Connecticut River ecosystem until 2048—at which time the last data collected will be 60 years old.

I urge you to require the full study of NMPS entrainment on all life stages American shad. The information gathered will enrich and inform decision-making gathered from related shad studies occurring under relicensing, including 3.3.2; 3.3.3; 3.3.6; and 3.3.7. Further, please require that the full spectrum of May, June, and July, pumping files for the years 1991 – present, be released as information critical to making decisions on NMPS’s long-term impact on the entire Connecticut River ecosystem.

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.

Cc: John Nagle, U.S. Environmental Protection Agency

USFWS Designee: Dispute Resolution Panel

Double Standard on the Connecticut

Posted by on 09 Jul 2013 | Tagged as: American shad, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Riverkeeper, Rutland Herald, shortnose sturgeon, Times Argus, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Rutland Herald and the Barre-Montpelier Times-Argus during the first week of July.

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

On June 28, 2013, Federal Energy Regulatory Commission Director of Energy Projects Jeff C. Wright ruled against the US Fish & Wildlife Service as it sought two extra weeks to review hundreds of pages of just-released Proposed Study Plans for the relicensing of five Connecticut River hydro projects. “The request for a 15-day EOT to file comments on the licensee’s proposed study plans is denied.”  EOT is FERC-speak for “extension of time.”  Those studies will impact this four-state river for the next 20-40 years. Agencies joining that request included the National Marine Fisheries Service, MA Div. of Fish & Wildlife, The Connecticut River Watershed Council, The Nature Conservancy, Trout Unlimited, the Franklin Regional Council of Governments, NH Dept. of Environmental Service and The Vermont Agency of Natural Resources.

One big reason for that request was the difficulties in evaluating the impacts of FirstLight’s Northfield Mountain/Turners Falls hydro operations on the entire Connecticut River ecosystem.  Beginning last fall, FERC began deviating from its standardized relicensing model when it scheduled public site visits to FirstLight sites weeks before the company released a publicly-required 500-page Pre-Application Document describing its complex pumped storage operations and machinery.

This spring FERC also supported FirstLight’s expedited-request to conduct a series of complicated river flow studies this summer—an allowance falling well outside FERC’s strict licensing timelines.  In doing so they let the company schedule three days of river visits by fed/state agencies smack in the middle of their deadline to comment on FirstLight’s 434-page Updated Proposed Study Plan.  FirstLight released that document June 28th; comments to FERC are due July 15, 2013.  Even after nine meetings with the power company and FERC, many agency representatives continued to decry the lack of critical scientific detail provided in FirstLight documents.  Those were put together by its team of five consulting firms.  Ironically, those handpicked FirstLight firms will conduct the next two years of river studies—the ones meant to protect the river.  A fox and chicken coop analogy applies.

FERC is employing a legal double standard here on the Connecticut.  If you a public agency or citizen seeking protections for the ecosystem—well, even little rules are THE RULES.  At the same time it appears corporations can continuously and sometimes massively ignore federal license requirements with impunity.

In FERC’s own words, the Commission “enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”  Yet today Holyoke Gas & Electric is half a decade–and counting, in violation of its 2002 agreement to construct facilities to end the evisceration of federally endangered shortnose sturgeon and other “federal trust” fish migrating downstream at their Holyoke Dam facility.  So, why have a license at all? 

Upstream in 2010 GDF-Suez FirstLight dumped some of 45,000 cubic square yards of reservoir sludge directly into the Connecticut at Northfield Mountain over a 90-day period—the equivalent of 40 dump truck loads of muck per day, smack in the middle of fish migration season. Yet in current documents FERC states their inspections have never found FirstLight in violation of its license.

The US EPA found FirstLight in violation of the Clean Water Act in August of 2010 and ordered a massive clean-up, though the ecosystem damage was already done.  In an August 4, 2010 letter EPA sanctioned FirstLight for violating “FERC License No. 2485” and polluting the “navigable waters of the United States.”  A subsequent letter dated August 10, 2013 from FERC’s Biological Resources Branch Chief Steve Hocking to FirstLight Manager John Howard specifically referenced the EPA’s sanctions, directing him to “article 20 of your license.”  Yet there is virtually no FERC mention of that egregious violation in current relicensing documents.

That’s the standard that for-profit companies are held to here.  It rivals the Pirate Code.  Currently there is no watchdog entity on this river willing to go to the mat to protect the ecosystem.  If, like on the Hudson, there was an organization like Riverkeeper—which cites “enforcement” as one of its main responsibilities, these egregious injuries to the Connecticut would not likely stand.  Holyoke Gas & Electric would have been in court long ago for killing endangered sturgeon; and the full range of FirstLight’s lethal impacts on the Connecticut’s migratory fish when all are diverted into their turbine-filled power canal would’ve been fully investigated.  FERC’s inaction is a disgrace.

FERC Director Wright requested that questions regarding that EOT denial go to Ken Hogan at: 202-502-8434, or Kenneth.Hogan@ferc.gov. Ken has presided over the CT River relicensing hearings.  Also, you can find FirstLight’s 434-page “Updated Proposed Study Plan” at: www.northfieldrelicensing.com under Documents.  The public has until July 15, 2013 to send comments on that plan to FERC.  You do that at: www.ferc.gov/docs-filing/efiling.asp .  You must cite FirstLight’s project numbers, P-2485 and P-1889, and be sure to note that you are commenting on the “Updated Proposed Study Plan.”

Karl Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield, MA. Read more at: www.karlmeyerwriting.com

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

A New Ecosystem Gamble: know when to hold ’em; know when to run…

Posted by on 22 Sep 2011 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, CRASC, EPA, FERC license, FirstLight, MA Division of Fish and Wildlife, New Hampshire, salmon, shortnose sturgeon, Turners Falls power canal, USFWS

© Copyright 2011, by Karl Meyer

(the following OpEd, appeared in the Greenfield Recorder, www.recorder.com , on 8/31/11)

A new Ecosystem Gamble: know when to hold’em; know when to run…

Some deals just smell fishy—like one for the Connecticut River being cooked up by global giant FirstLight/GDF-Suez and the US Fish & Wildlife Service and the Connecticut River Atlantic Salmon Commission (CRASC.)   Today CRASC, US F&WS and MA Div. of Fish & Wildlife are pushing a deal ignoring ongoing damage to federally-endangered shortnose sturgeon and federal-trust American shad.  It prioritizes retrenching the river’s migrating fish in FirstLight’s Turners Falls power canal—filled with slicing turbines, stress-filled currents and silt.  It’s this ecosystem’s black hole, crippling fisheries restoration here for decades–literally at the doorstep of the federal Conte Fish Lab in Turners Falls, MA where CRASC meets.

CRASC meetings can be Orwellian. The USFWS’s John Warner all but stated at an August 3rd meeting that the river’s only spawning population of federally-endangered shortnose sturgeon were immaterial to talks he’s leading.  Their ancient spawning grounds, just beyond Conte Lab’s west window, weren’t documented when the Federal Energy Regulatory Commission (FERC) license currently governing Northfield MT-Turners Falls hydro operations was signed in 1978.  So Endangered Species Act be damned, those fish don’t count.

UMass professor Dr. Boyd Kynard, an expert on many of the world’s endangered sturgeons who consults on fish passage behavior at large river dams including the Yangtze and upper Amazon, might disagree.  In a book on 20 years of sturgeon research slated for December publication, Kynard and colleagues cite manipulated hydro flows in a 2 mile stretch below the Turners Falls dam and canal as contributing to significant breeding failure for shortnose sturgeon.  Sentences from adjoining paragraphs fall out like this: “Flow regulation at Rock Dam makes spawning for shortnose sturgeon impossible during most years.” And, “Peaking operation of Cabot Station causes discharge shifts that have deleterious effects on spawning success of shortnose sturgeon.”  On March 12, 2010, FERC notified FirstLight they’d failed to comply with licensed provisions for “minimum flow” for those sturgeon during fall 2009.

When I asked Mr. Warner about any existing notes from talks with FirstLight, he wouldn’t give a direct answer.  Make no mistake, what’s being cooked up is a de-facto reopening of the current 40 year FERC hydro license governing conditions and flows from FirstLight’s Northfield Mt.-Turners Falls operations–only it sidesteps details like public input, endangered species, and disclosure.  Until caught last year, FirstLight used the river as its flush-sink for 65,000 tons of silt at its Northfield MT plant during peak migration and spawning season. Clean Water Act, be damned.

CRASC is the protector-of-record for the river’s ocean migrants and ecosystem, our federal trust.  They’re excited FirstLight is now interested in negotiating migratory fish passage—though river, fish, and fish passage protection and enhancements are mandated under federal law, and included in the current license.  CRASC’s never demanded them.  Instead of negotiating critical flows for shad–and spawning shortnose sturgeon documented since 1993 on Conte Lab’s doorstep, they’re again blithely substituting a canal restoration for a river restoration.

“Trust us,” say USFWS and CRASC, “We’ll protect the river–we just have to wait until the next full 40-year FERC license negotiation in 2018.”  But they’ve failed for 40 years now, emphasizing their salmon “restoration” which returned 107 fish this year; and its hundred million dollar federal (genetic hybrid)salmon hatchery system—essentially a jobs-program that’s never produced  a single, fishable-fish for this river.  It’s been CRASC–formerly “The New England Cooperative Fisheries,” that’s repeatedly abetted channeling 90% of the river’s migratory fish into a meat grinder: Turners Falls canal.  Fish don’t emerge from the other side.

Hydro companies like to use a river like there’s tomorrow–like they own it.  Their interests are profit; the weight of water shunted through turbines.  Ecosystem-protections don’t maximize profit.  USFWS’s John Warner, negotiating with FirstLight, admits any new river help from a 2018 license may take “until 2025” to be implemented by a foot-dragging company.  Yet everyone’s lining up with FirstLight’s “canal-first” idea—when they should be prosecuting for sustaining river flows, and prioritizing direct fish passage up the Connecticut’s currently-crippled reach to a lift at Turners Falls dam.  Several CRASC’s partnering scientists at Conte Lab are being paid by FirstLight—for ongoing fish passage studies in the TF canal.  With federal scientists on your payroll, how can you lose?

New England’s River can’t survive another losing hand.  Unlinking ecosystem-sustaining flows and fish-lift passage at Turners Falls dam from the current canal-restoration scheme is a recipe for disaster that could set a failed restoration back another half century.  Negotiate a sustainable river first.  If CRASC and USFWS allow themselves to be slow-danced into repeating a dead-end canal configuration for the Connecticut, its renewed use will be cited by the power company as an endorsement of its suitability as the best upstream route for migratory runs when a new 40-year license is negotiated in 2018.  Nothing is further from the truth.  Today, 44 years and three states shy of CRASC’s 1967 MA, VT and NH restoration goals, ecosystem fish runs choke to a halt in the Turners Falls power canal.

(* note: the Connecticut River Atlantic Salmon Commission is holding an emergency Tech Committee Meeting, tomorrow, Sept. 23, at 10:00 a.m., at 1 Migratory Way, in Turners Falls at the Conte Lab.  Use the 11th Street Bridge to cross the Canal, then take a left.  ALSO, the full CRASC meets on Sept. 29th, same time, same place.  Though not publicized, these are PUBLIC meetings with your public officials calling the shots.  There is currently NO Massachusetts “public representative on CRASC, the seat has sat empty for 3 -plus years.)

Writer Karl Meyer of Greenfield, MA, has served on the boards of two watershed associations and is former member of the Northfield Mountain Pumped Storage Safety Committee.  Reach him and read more at: www.karlmeyerwriting.com

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