Extinction

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Stakeholder PROTEST of FERC Revised Study Plan finding endangering Connecticut River shortnose sturgeon

Posted by on 07 Mar 2016 | Tagged as: Connecticut River shortnose sturgeon, Dead Reach, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Secretary Kimberly Bose, US Fish & Wildlife Service, USFWS

(The following Stakeholder testimony was submitted to FERC on March 4, 2016)

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 March 4, 2016

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

RE: P-1889 and P-2485, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

I protest the FERC finding issued on February 25, 2016 for P-2485 and P-1889 specifically because it sanctions test flows that are documented to cause spawning failure for the federally-endangered Connecticut River shortnose sturgeon (Acipenser brevirostrum) at its only documented natural spawning site, the Rock Dam, in the Connecticut River. FirstLight has proposed and FERC has accepted Study Plan test flows of 1500 cubic feet per second in the CT River’s By Pass Reach for April, May and June 2016. That low level of flow will displace and wipe out a full season’s spawning and rearing of Young of Year life stage SNS at their ancient Rock Dam nursery site.

Though my FERC Stakeholder comments of January 28, 2016 specifically addressed this ESA issue, FirstLight did not respond to the endangerment issue in its RSP revisions. Further, I had made this issue clear to FirstLight and its agents, FERC staff, and key stakeholder agencies in an email delivered on January 20, 2016. I again reiterated the endangered species impacts to those same parties in an email delivered on February 24, 2016. Madam Secretary, I again made my concerns about spawning interference and failure to you and for the FERC record in a letter delivered February 26, 2016. All are available for perusal in the FERC record for P-2485 and P-1889.

Shortnose sturgeon gather at this spawning and nursery site annually between April 22 and May 25 for pre-spawning and spawning. Further, the complex of key biological characteristics of flow, varying depths, and cobble/sand habitat provide SNS with protective options that nurture developing Young of the Year throughout June into July.

According to 17 years of published studies at that site documented by Dr. Boyd Kynard and research colleagues, a continuous minimum flow of 2500 cfs is required to protect sturgeon spawning and rearing at this site. Therefore, I PROTEST the findings of the FERC Revised Study Plan determination issued by FERC on February 25, 2016, and request that only continuous protective minimum flows of 2500 cfs be allowed in this study, and throughout the 2016 SNS spawning and rearing season, as well as all ensuing springs.

The following publication has been referenced in the FERC ILP for these projects by both federal and state stakeholder agencies, FERC, as well as FirstLight and their agents.

“LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4

“Effect of hydroelectric operations on spawning”

Page 101, bottom: “During the 11 yr spawning failed (excluding the failed migration in 2002), when discharge levels were too low for 5 yr and too high for 4 yr. During one yr (2007), discharge during April was both to low and too high. When spawning failed at RockD due to low discharge during 4 yr (1995, 1998, 1999, and 2006)m discharge decreased to <70 m3 s-1 for at least 4 d by 30 April (Fig. 14), the earlier period of low discharge likely marked a threshold making the RockD unattractive to spawning fish.”

Further published data, tables, and required flows necessary in this reach appear on pages 101-102 of LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEIONS.

I would welcome a FERC hearing on this critical ESA issue and would make myself available for testimony. Thank you for your attention to this pressing matter.

Sincerely,
Karl Meyer
Fish and Aquatics Study Team, P-2485 and P-1889

Cc’d via email to:
Brandon Cherry, FERC
James Donohue, FirstLight
Julie Crocker, NOAA
John Warner, USFWS
Caleb Slater, MA Division of Fisheries & Wildlife

New comments to the Federal Energy Regulatory Commission

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, canal shad, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Extinction, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, FirstLight, GDF-Suez FirstLight, migratory delay, power canal studies, Public Comment period, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

The following comments were submitted to the Federal Energy Regulatory Commission on November 13, 2015, respecting relicensing studies occurring at the Northfield Mountain Pumped Storage Station and at the Turners Falls Dam and Canal. They are designated, respectively as: P-2485; and P-1889.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 November 13, 2014

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

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

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process. The majority of the fish and aquatics studies remain incomplete at this time. However, having attended the recent study update meetings with FirstLight’s consultants, and as a member of the Fish & Aquatics Studies Team for P-2485 and P-1889, please accept these brief comments on the USR and proposals for modifications and new studies needed in the FERC ILP for these projects. As studies are brought to completion and data and results are shared with Stakeholders I will submit further comments.

3.3.2 Evaluate Upstream and Downstream Passage of American Shad

Needed information from this study: from personal observations I noted many days when Station 1 was in operation. I visited the site, took some photos, and interviewed a fisherman who was busy catching shad at the Station 1 Outflow on 5/24/2015. In good light, and without the advantage of polarizing sunglasses, I observed dozens of shad stacked up like cordwood, treading water there. The gentlemen noted that whenever Station 1 is running “there are always fish here.” The report should include information about tagged fish delayed in this false attraction water. It is also critical to delineate the number of days during testing that Station 1 was in operation.

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

In their update the applicant’s team stated that “because minimal shad spawning was observed in the Turners Falls Canal, no spawning areas in the canal were identified for further examination.”

Needed information from this study: at what hour, on what dates, and under what conditions were these “minimal” spawning observations made? Did they return to the site again under different, or more favorable conditions? What was the water temperature? Was it raining? Windy? Cloudy? Was Cabot Station running at the time-and how many units? Was Station 1 in operation on the nights they made their observations?

These are basic questions that require adequate answers as the TF Canal has been the bottleneck for the shad run up through Northern Massachusetts and into Vermont and New Hampshire these last 40 years. The canal appears to be culling off part of the run as a spawning trap. A thorough understanding of why fish are lingering there, and clear assessment of the numbers and delays of fish attempting to spawn in the canal is necessary for informed decision making.

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

Needed information from this study: This study needs to be extended for another year. On October 5, 2015, I took a 20-minute walk through a small segment of the canal at 7:00 a.m. on the morning the canal had drained. On the flats far–from the thalweg where most of the 2014 assessment appears to have taken place, thousands of fish lay struggling, stranded, and dead in the drying pools. These included juvenile American shad, yellow perch, juvenile and “transformer” sea lamprey, one 8-inch chain pickerel, one crayfish, and thousands of tiny, unidentified YOY fish in drying pools and rills that led to nowhere.

These observations were made crossing just a few—out of the many acres, of silt and muck “shoulder habitat” that occurs away from the main channel on both the east and west sides of the TF Canal. A more thorough mortality assessment needs to be made across these habitats to have a full understanding of the impacts of the canal drawdown migrating and resident fish.

REQUEST for New Study: Tagging and Spawning Study of the Connecticut River Shortnose Sturgeon at the Rock Dam Pool in Turners Falls.

The USFWS’s fish passage and dam specialist John Warner reports that both downstream and upstream modifications for fish passage at Holyoke Dam will be completed this winter. New entrances and exits allowing CT River SNS to move upstream beyond that site will be working in spring 2016.

In light of the construction at Holyoke and the 2016 continuation of test flows evaluations on spring migrants in the By-Pass Reach at Turners Falls, testing of spawning success for SNS should be done at their documented natural spawning site–the Rock Dam in Turners Falls, in spring 2016. Regardless of any fine tuning needed at the Holyoke facility, some SNS will return to the Rock Dam pool by the last week of April, and the chance to study their spawning success in light of regulated test flows presents a unique opportunity for the only federally endangered migratory fish on the Connecticut River.

If this fish is ever to benefit from new genetic input, a full understanding of suitable flows at Rock Dam to accommodate spawning is necessary information going forward for a fish that has been decades on the cusp of extinction. It’s an opportunity to restore a part of the public trust.

For further information on longstanding research at this site without required test flows, see Kynard, B. and Kieffer, M.C., et al: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society, ISBN 978-3-8448-2801-6.

Thank you for the opportunity to comment on the USR for these projects.

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

Spawning shortnose sturgeon denied flow at Rock Dam Pool

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

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

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

A RIVER PRESERVED IN PLASTIC Copyright © 2015 by Karl Meyer

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

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

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

Nothing could be further from the truth.

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

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

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

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

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

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

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

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

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

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

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

THE CONNECTICUT RIVER SHORTNOSE STURGEON: A PLANNED EXTINCTION?

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

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

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

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

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

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