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The Connecticut River NOW! Defenders are taking their case directly to FERC; here’s why!

Posted by on 23 Jan 2022 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, CRC, CRWC, Delaware LLC, Extinction, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Jo Comerford, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Natalie Blais, Nation's best landscaped sewer, National Marine Fisheries Service, net-loss power, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Environmental Protection Agency, US Fish & Wildlife Service, USFWS

DON’T BE DIVERTED: The Connecticut River NOW! Defenders taking their case directly to FERC; here’s why!

* * * POST UPDATE: letter from today’s (Tues. 1/25/22) Greenfield Recorder. It nicely outlines FirstLight/Northfield’s massive impacts on a SINGLE town: https://www.recorder.com/ltr-field-ConcernsAboutPumpingStation-44673061


Federal and state agency reps, plus CRC’s Andy Fisk at a meeting of the Connecticut River Atlantic Salmon Commission. The US Fish & Wildlife Service, MA Fisheries & Wildlife, and the Connecticut River Conservancy have all signed in FirstLight’s non-disclosure agreement as they meet in secret.

With scores of citizens stepping up to defend our ecosystem, FirstLight’s secret January deal plans for the river have been thwarted. And more are writing in… These are folks who understand that–while many of the planet’s ecosystems seem to be foundering, if you are offered ONE CHANCE to turn the light’s BACK ON after a half-century of a massively broken Connecticut River ecosystem at Northfield Massachusetts, you DO NOT SQUANDER THE OPPORTUNITY. Certainly not for those who come after…

* * * ALSO UPDATED: Please see the TWO latest FERC testimonies sent directly–and on-the-record to FERC, at the end of this post. * *

ALSO, tomorrow, TUESDAY, at 4 p.m., I speak with attorney Buz Eisenberg on: The Afternoon Buzz | Shows | WHMP 101.5 / 1240 & 1400 AM.


Some of my personal river heroes…

DON’T BE DIVERTED! A new, out-of-the-box, save our river “opportunity” is today being pedaled to the public by two non-profits–one of which has signed FirstLight’s non-disclosure agreement. It’s a vague, dangerous idea at this critical juncture–belatedly promising that a sleek state legal angle can magically be employed over the next year to rescue the Connecticut River at Northfield from another 50 years of ecosystem strangulation AFTER a FirstLight federal settlement deal has been sent along to FERC with state agency signatures.

Right now, the US Fish & Wildlife Service, Massachusetts Dept. of Environmental Protection, the National Marine Fisheries Service, and MA Div. Fisheries & Wildlife are meeting in secret negotiating sessions with Canadian-owned, Delaware LLC-registered FirstLight Power to try an ink a grizzly “settlment” agreement to relicense the deadly operation of the Northfield Mountain Pumped Storage Station for the next 50 years. They’d wanted to have a signed deal by now that they could forward to the Federal Energy Regulatory Commission for approval. But strident public protest to FERC appears to be keeping state and federal agents from caving-in to another half century of a strangled Connecticut River.

The people are denying FirstLight from getting its way here.

This just-launched, last minute, state-pressure ploy comes off as both ridiculous and self-serving. THIS HAS BEEN A DECADE-LONG FEDERAL PROCESS–the tail won’t be wagging the dog here in Massachusetts on this four-state river system.

Once the SECRET DEAL in this slogging 10 year FERC process is inked at the highest levels–there will be NO magic mechanism at the MA wetlands level that has a snowballs-prayer-in hell to retrieve this crippled river from another half century of venture-capital devastation at Northfield. New England’s Great River will continue on as the “nation’s best landscaped” DEADLY sewer” here in Massachusetts. MA Dept. of Environmental Protection is at the backroom table in this process! Let’s be honest here…

Believing the brutal disruption, chaos and massive aquatic killing by FirstLight’s Northfield Mountain can be legislated ONCE a closed-door settlement deal is signed with the federal/state agencies meeting with Firstlight, is irresponsible MAGICAL THINKING. Some are even clinging to the notion that FERC will make a ruling ordering that BILLIONS AND BILLIONS of dollars must be spent to site, engineer and build a whole new Northfield reservoir that would exclude the use of river water. Think about that! Who would do it? Who would pay? It’s just not possible–or true.

BUT ALAS! FL is being thwarted in their plans by citizen input sent directly to FERC, with new, on-the-record statements demanding no new license be issued for deadly operations at Northfield, not another half century wasting massive amounts of energy to pull our river into reverse–literally for miles, in a buy-low/sell high 50 year profit scheme here in the Massachusetts.

AGAIN, if you haven’t yet submitted testimony–or know of others who want to defend our River’s right to survive as a living system, here’s the FERC formula to share:

Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

* * * HERE IS JUST THE LATEST citizen testimony entered into the record at the Federal Energy Regulatory Commission:

Document Accession #: 20220125-5000 Filed Date: 01/25/2022
Andy Rothschild, Greenfield, MA.

Given the environmental challenges that our planet and its inhabitants face today and the increasing challenges that it will face over the next fifty years, it doesn’t make any sense to me to relicense the Northfield Station. The system requires more energy input to power itself than the energy that it will create. All the while, doing damage to the Connecticut River, its banks, and the fish within it. Please think long and hard about the damage
that would be done in the present and for the next crucial fifty years of our planet’s existence. Thank you.

Document Accession #: 20220124-5001 Filed Date: 01/24/2022
Anna, Arlington, MA.

I strongly oppose the relicensing of the Northfield Mountain hydroelectric plant. While shifting energy production to renewables is a pertinent step in battling the climate crisis, such a transition must be done in a manner that takes necessary precautions. This hydro plant reverses river flow and disrupts essential ecosystems of the Connecticut River. It is powered by
natural gas. These two facts alone are reason enough to reconsider calling this project “green” or, even remotely sustainable. The Connecticut River, home to globally significant tidelands and 10 federally threatened aquatic species, is a watershed that spans four different states: VT, NH, MA, and CT. An estimated 2 million people live in the CR watershed. It is with utmost importance that we protect the river, not further degrade it’s well-being. The Northfield Mountain hydro plant should therefore be denied
recertification.
Thank you.

Document Accession #: 20220121-5069 Filed Date: 01/21/2022
Christopher “Monte” Belmonte, Turners Falls, MA.

I live between the mighty Connecticut River and the Turners Falls Power Canal in a little island neighborhood called “The Patch.” The canal runs right past my backyard. I am a big believer in creating clean, fossil-fuel-free energy and I know that some of what First Light is doing is toward that end.
But it is unconscionable how much water is drawn from the river to keep the canal flush. I watch it go from a gorgeous raging river to a trickle from one day to the next, creating an ecological disaster for the aquatic life in that river. Specifically, the federally endangered shortnose sturgeon. Down the street from my house on the river at the so-called â€oeRock Dam†is one of
the best known, if not only, spawning locations of this endangered fish. And yet First Light continues to interfere with the flow of the river, even during spawning season. They might wipe out an entire species. And yet there is little to no acknowledgement of their risking ruining spawning year after year.

And no clear plan to stop under the new proposed license.
Further, the ecological disaster known as the Northfield Pump Storage station, which literally sucks the river flow backwards up to a mile away as it pumps, is also decimating what fish do manage to make it over their currently ineffective Fish Ladder in Turners Falls. While I’m pleased there will be a new way for fish to pass over the dam, until Northfield Mountain’s facility becomes a closed circuit, rather than a river sucking, fish massacring machine, First Light should not be granted a new license.
We have one chance left to save the shortnose sturgeon. If First Light is granted this license, as it is written, it’s game over for that federally endangered fish. This is a federal license. There is a fundamental disconnect in not doing our utmost to protect a federally endangered fish. And the disconnect between what good Northfield claims it provides, contrasted with
the uncountable millions of fish it is killing there each year is more than we who love our river can bear. Please reconsider this current license. Please make sure First Light is held to account and changes course before it changes the course of our river and its watershed.

As Connecticut River secrecy-shrouded talks continue, citizens demand an end to Northfield’s half century of devastation

Posted by on 22 Dec 2021 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Daily Hampshire Gazette, Deerfield MA, E-Comments, Extinction, Federal Energy Regulatory Commission, FERC, FERC license, FirstLight, Greenfield Recorder, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Massachusetts DEP, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, pumped storage, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Daily Hampshire Gazette, The Greenfield Recorder, The Recorder, US Fish & Wildlife Service, USFWS

As secrecy-shrouded Connecticut River licensing talks continue, citizens are standing up to demand an end Northfield’s half century of ecosystem devastation

IN THE PAST THREE DAYS a steady drumbeat of on-the-record calls to end Northfield Mountain’s half century of aquatic carnage, energy waste and ecosystem disruption have been filed with the Federal Energy Regulatory Commission. This speaks volumes about democracy vs. secrecy–and the massive void in leadership, information and environmental enforcement that has been the status quo on this great river for the last 50 years. When there is no watchdog; there is no enforcement.

IN THE FOLLOWING ENTRIES you will find the latest 10 filings by citizens from Foxboro to Amherst, and Northampton, Leeds and Northfield, as well as from Greenfield and Deerfield to Colrain, into the FERC record. All are demanding that no new license be issued allowing the Northfield Mountain Pumped Storage Station to continue savaging our ecosystem.

AFTER reading through that last entry you will find directions for entering on-the-record testimony with the Federal Energy Regulatory Commission. It is important that this is done now, as state and federal fish and environmental agencies are currently in FINAL “settlement” negotiations with foreign-registered FirstLight through the end of this month. THEY NEED TO KNOW exactly where you–their constituents, stand on any selling out of our Great River and its aquatic legacy.

* * The following piece, “Last light for New England’s Great River?” appeared in the Daily Hampshire Gazette on 12/22/2021, after originally running in The Greenfield Recorder on Tuesday, 12/21/2021. https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152

BELOW please find the latest citizen filings with FERC:

UPDATE! This is the ELEVENTH filing, submitted from Stoughton MA early this morning:

Document Accession #: 20211223-5001 Filed Date: 12/23/2021
Steven Wilkinson, Stoughton, MA.

It’s time for F.E.R.C. to fulfill government by, of and for the people, and not the corporations, by stopping the mis-use of our public resources. Restore the Connecticut River’s integrity by ending Northfield’s activities. You owe it to future generations, whose environment and food supply are being adversely impacted by your past decisions. Make it right. Stop this backward company from hurting New England.

Document Accession #: 20211223-5000 Filed Date: 12/23/2021
Amy Rose, Amherst, MA.

Comments on Northfield Hydroelectric License/Re-license Proceedings P-2485
I stand firmly in favor of terminating the license of the Northfield Mountain Pumped Storage Station. It is an experiment that has failed miserably, and it is time to close it down. In addition to killing 100s of millions of aquatic animals in the CT River every year, this illogical project squanders a massive amount of energy pumping water to the top of a mountain. How
absurd! Protect our beautiful CT River and stop this ridiculous project ASAP.Redirect this energy towards investing in solar arrays on developed areas: rooftops, roads and parking lots.

Document Accession #: 20211222-5071 Filed Date: 12/22/2021
Peggy Matthews-Nilsen, Amherst, MA.

Please protect the Connecticut River from the environmental damage that FirstLight’s project will create for decades to come. Please DO NOT relicense FirstLight! Thank you.

Document Accession #: 20211222-5067 Filed Date: 12/22/2021
Sigurd Nilsen, Amherst, MA.

Please do not renew FirstLight’s license due to the ecological devastation to the Connecticut River.

Document Accession #: 20211222-5057 Filed Date: 12/22/2021
Rebecca Tippens, colrain, MA.

Hydroelectric License/Re-license Proceedings
I am quite upset that the process for deciding whether to renew the license for First Light to renew permission for pumped storage has been less than fully transparent. The Connecticut RIVER is a common resource and it is our obligation to insure its health as well as the beings who live in it. We know we are facing an extinction crisis and the pumped storage method, despite assurances to the contrary, kills millions of fish. First Light’s parent owner has been using all the tricks in the book to hide from both regulators and the public, their financial sleuthing that includes relocating their business to tax havens while, green washing their actions to give donations to local non-profits that represent but fractions of their profits but which they use to bolster their argument that they are indeed a green company.

In fact the process of sucking out water to later drop it to create energy (& dead fish), is massively energy intensive. That they want to continue this killing project for the next twenty plus years is beyond abhorrent. It is a moral and ecological travesty that no one should be supporting.

Document Accession #: 20211222-5050 Filed Date: 12/22/2021
Lin Respess, Northampton, MA.

I am writing to encourage you to reject the relicensing of FirstLight’s Northfield Mountain Pumped Storage station on the Connecticut River. For years, it has been destroying migratory fishes on the river in direct violation of the U.S, Fish & Wildlife Service’s published goals for the river, and to restore passage for migratory American shad, blueback herring, and other species, and requiring providing the public with high quality sport fishing opportunities in a highly urbanized area, as well as to provide for the long-term needs of the population for seafood. Please protect this New England ecosystem for future generations by denying relicensing for FirstLight’s Northfield Mountain Pumped Storage Station.

With thanks,
Lin & Tucker Respess, Northampton, Massachusetts

Document Accession #: 20211222-5040 Filed Date: 12/22/2021
Tanya Dragan, LEEDS, MA.

Hello,
I am gravely concerned about FirstLight and the damage caused by the Northfield Mountain Pumped Storage Station on the Connecticut River.

Please do not allow this to continue. Nor continue with the negative impacts they’ve gotten away with for decades. We need to protect future generations.

Do not let their PR/lobbying machine work to ruin the environment.

Regards,
Tanya Dragan
Leeds, MA

Document Accession #: 20211222-5039 Filed Date: 12/22/2021
Pamela Scott, Deerfield, MA.

To whom it concerns.. I read with dismay the plans for this hydro electric project to continue. As a concerned citizen, I urge you to reconsider. These activities will have lasting effects that we can’t even comprehend and will affect us far into the future. Please discontinue this project and stop the senseless slaughter of precious wildlife. Thank you very much for your attention to this email.

Document Accession #: 20211221-5154 Filed Date: 12/21/2021
Ron Bartos, FOXBORO, MA.

The operation of the Northfield Mountain Pumped Storage Station facility is highly detrimental to all life in and around the Connecticut River. It kills millions of the river’s aquatic creatures whenever it operates, and causes an unnatural rise and fall, and reverse current, in the river. The license for the project must not be renewed. There are other more economical and ecological ways to generate electricity.

Document Accession #: 20211221-5127 Filed Date: 12/21/2021
James Seretta, Greenfield, MA.

It makes NO SENSE to allow any company to control a resource that in doing so allows them to make money while killing off the ecosystem of the resource. It would be different if there was no harm right?

What’s most bothersome is how it looks like you’re in bed with these guys. What’s in it for you?? Have you bothered to watch these guys sneak around with their shell companies covering their tracks? Did you ever try to figure out why?? Why sell out to a foreign company that has no interest but to make a profit while pilfering the resource of the home community??

It’s time for you guys to do your job and stand up for this incredible resource. Do you hear an outcry that says these corporate folks are doing great things, we love them, sign them up for another 50 years? Of course not because no one wants it. THE HARM OUTWEIGHS THE GOOD!!! DO YOUR JOB!

Document Accession #: 20211220-5002 Filed Date: 12/20/2021
Glen Ayers, Greenfield, MA.

The Northfield Mountain pump-storage facility should be completely decommissioned and the river restored to allow natural flows. No connectionbetween the Northfield Mountain facility and the CT River should be allowed. This river-killing contraption must be eliminated from the river ecosystem. This continuous destruction has been happening for 50-years and it cannot be allowed to kill the river’s aquatic life for another 50.

The time has come to pull the plug on Northfield Mountain, an outdated, obsolete technology that wastes energy, kills fish and other aquatic organisms, and is only operated to enhance the profit of a corporate investment entity that simply does not care about ecology or the river. The people demand that the Government stop this abuse at once. After 50-years of raping the river on a daily basis, it is time to say enough is enough! DO NOT RELICENSE NORTHFIELD MOUNTAIN PUMP STORAGE!!

Fifty years ago this now-obsolete contraption was foisted upon the river aspart of the Vermont Yankee Atomic Nuke Facility in Vernon, VT. That polluting monstrosity has finally been shut down, but is still contaminating the river ecosystem. Northfield Mountain is no longer connected to the Nuke and it should have been shut down at the same time, but the license has expired and it finally must be shuttered so that the river can begin to recover from 50-years of abuse. Ecological science has developed greatly in the past 50-years, and technological advances have replaced this sort of monstrosity with systems that are more efficient, far less harmful, and have barely a fraction of the footprint that the river destroying Northfield Mountain has on the local ecology. This antique belongs in a museum, as an exhibit on bad ideas that were finally eliminated, like DDT, Thalidomide, and Teflon. There is nothing good about Northfield Mountain, it is a curse on the region, and the damage it has done to the river will take decades to heal. River recovery is not possible until this beast is shut down. The river demands that it be freed from the death grip that has been strangling the life out of the CT River for half a century. The abuse must be stopped. NOW!

I implore you to do your job, and find the spine necessary to shut downNorthfield Mountain. To do otherwise would be inhuman and a gross violation of the public trust doctrine. I ask that you reject the application from First Light Power, deny the relicensing, and require that the owner of Northfield Mountain restore the river ecosystem and functioning that has been ruined by their mistreatment of a living system for these past 50-years. The public has spoken loud and clear, we do not consent to treating our river as a pumping machine for the next half century. We Do Not Consent! Shut Down Northfield Mountain! Shut it down.

HELP RESCUE OUR ECOSYSTEM: Here’s how…

Citizens can still get on the public record before any grim deal is signed. Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and use Northfield’s FERC project number, P-2485, to enter your comments.

The Connecticut River, Extinction Rebellion and its local connections…

Posted by on 03 Nov 2021 | Tagged as: cleanup, climate change, climate-scorching, Connecticut River, Connecticut River Conservancy, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, Eversource, Extinction, Extinction Rebellion, Federal Energy Regulatory Commission, FERC license, FirstLight, Greenfield, ISO-NEW ENGLAND, Natural Gas, New Hampshire, Northeast Utilities, Northfield Mountain, Northfield Mountain Pumped Storage Station, NU/WMECO, pumped storage, river cleanup, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Fish & Wildlife Service, Vermont, Vermont Yankee

The Connecticut River, Extinction Rebellion and its local connections…

Photo Copyright © 2021 by Karl Meyer

…to EXTINCTION, EVERSOURCE, CLIMATE, FIRSTLIGHT, CO-2 and the “CONSERVANCY”

ON SATURDAY, NOVEMBER 6, AT 11:OO a.m., Extinction Rebellion demonstrators will take to the Greenfield Town Common to rally against the ravaging of the climate and the extinction of species through massive extraction and burning of fossil fuels. This comes exactly two weeks after the NO LICENSE TO KILL rally on the Common. That rally demanded FirstLight’s Northfield Mountain Pumped Storage Station not be issued a new decades-long license to continue killing hundreds of millions of fish and aquatic animals annually–while erasing all natural characteristics of a living river and functioning ecosystem in Massachusetts.

Counter to all common sense–and wildly contrary to popular belief, Northfield Mountain is an electricity consumer. It has been running primarily on climate scorching natural gas since its original electric power source–the Vermont Yankee nuclear plant, shut down in 2014.

In fact, looking at the sources powering the ISO-New England power grid this morning, November 3, 2021, Northfield has been laying waste to the river on 72% natural gas, another 11% imported nuclear from the CT and NH coasts, and 8% actual hydro (imported from Canada), plus another 8% from actual renewable sources. Thus, for the last SEVEN years since VY closed, this deadly electric machine has been a major source of CO-2 planetary waste and invisible climate destruction.

Northfield is a river-vacuuming electric toilet, parasitically-powering itself directly off the New England power grid to suck the life out of a 20 mile reach of the Connecticut daily, pulling it backward and uphill to a 4 billion gallon reservoir. That lifeless water is later released in thundering morning and afternoon pulses to become brief, peak-priced, second-hand electricity sold to us ratepayers as their deadly-profitable river offering.

Northfield is not what any thinking person would ever define as HYDRO POWER. Even the industry keeps it in a separate category–as it is actually a net-loss electric glutton that appears in negative percentages on the daily power grid. Nor can its deadly output ever be labeled “clean” or “renewable” energy, despite clever industry marketing.

So, when Extinction Rebellion appears on the Greenfield Common on Saturday–two weeks after the No License to Kill rally against FirstLight-Northfield, it bears pointing out that they will be assembling just yards away from the Connecticut River Watershed Council, today doing business as the Connecticut River Conservancy.


Connecticut River Conservancy’s HQ, adjacent to the Greenfield Common. Photo Copyright © 2021 by Karl Meyer

Just six weeks back the “Conservancy” had their 25th Source to Sea Cleanup—majorly and annually funded by none other than WMECO/Northeast Utilities–today doing business as Eversource. It was WMECO/NU that actually built FirstLight’s Northfield Mountain–the drop-dead, deadliest machine that continues operating today on an extended Federal Energy Regulatory Commission license (one that expired in 2018), right in the midst of the Connecticut River S.O. Conte Connecticut River National Fish & Wildlife Refuge and the platitudinous Connecticut River National Blueway here in Massachusetts. Lacking a real river watchdog and any enforcement of existing environmental law…those designations mean absolutely NOTHING.

Yesterday, November 2nd at polling booths in East Boston, citizens overwhelmingly voted to prevent Eversource from building a new natural gas pipeline in their city, citing climate impacts and lack of necessity. You see Eversource–the Conservancy/Watershed Council’s BFF for ages, is today a major natural gas company, having taken over Columbia Gas—famous for their pipeline explosions in Lawrence, and, just a few years back in Springfield MA, with its own major gas explosion, right downtown.

The Conservancy/Council’s ole buddy Eversource/WMECO/NU–through its long history of deep-pockets-funding and CRC Board memberships, is now planning to build a new natural gas pipeline extension through Longmeadow and into Springfield. It is another grim push toward a critically baking planet—one that Eversource expects to charge ratepayers $33 million to put in place. Currently, the City of Springfield has demands out for the accruing years and some $44 million in back taxes it says Eversource has not paid. Springfield citizens are now pushing back on the giving Eversource yet another free pass through town. Both East Boston and Springfield have long histories of community racial, economic and environmental injustice. This new natural gas monopoly angling appears to continue that legacy.


Photo Copyright © 2021 by Karl Meyer

So, No License to Kill, Extinction Rebellion, and a whole lot of people in Western Massachusetts and New England have plenty of reason to gather on the Greenfield Common on Saturday. There is injustice aplenty, green-washed and collaborated on between Eversource-NU-WMECO, FirstLight, the Conservancy, the Commonwealth of Massachusetts and the byzantine natural gas consortium… all of which all circle back to Eversource and its green-washing “friends”…

Did you help with CRC’s (EVER)Source to Sea Cleanup this September?? The Conservancy and FirstLight employees actually made a clever video together…
Now that’s collaboration!

A 2021 Brown University study named Eversource as MA’s largest energy spender against clean energy and climate legislation: https://ibes.brown.edu/sites/g/files/dprerj831/files/MA-CSSN-Report-1.20.2021-Corrected-text.pdf

Still with headquarters in Hartford, below is a CT list of their largely invisible holding and affiliate companies, etc–though their Columbia Gas ownership does not show up here:

The following companies operate as “wholly owned subsidiaries” of Eversource:
Connecticut Light & Power, Public Service Company of New Hampshire, PSNH Funding LLC 3, NSTAR Electric Company, Harbor Electric Energy Company, Yankee Energy System, Inc., Yankee Gas Service, NSTAR Gas Company of Mass.(EGMA), Hopkinton LNG Corp., Eversource Gas Transmission II LLC, Eversource Holdco Corporation, Eversource Investment LLC, Eversouce Investment Service Company LLC, Aquarion Company, Aquarion Water Company, Aquarion Water Company of Connecticut, Aquarion Water Company of Massachusetts, Inc., Aquarion Water Capital of Massachusetts, Inc., Aquarion Water Company of New Hampshire, Inc., NU Enterprises, Inc., IP Strategy LLC, Eversource Energy Service Company, The Rocky River Realty Company, Holyoke Water Power Company. Eversource has residual interest in nuclear plants they’ve sold: Seabrook NH and Millstone CT.

Part ownership in: Alps to Berkshires LLC, 50% in transmission line to NY State, 15% ownership in Algonquin Gas Transmission LLC, BSW Holdco LLC, BSW ProjectCo LLC, Bay State Holdco LLC, Bay State Wind LLC, Northeast Wind Energy LLC, North East Offshore, LLC, New England Hydro-Transmission Electric Company, New England Hydro-Transmission Corp. Eversource also has interest and ownership in companies that own and manage decommissioned nuclear plants they once owned, including: Connecticut Yankee Atomic Power Company, 65%, Maine Yankee Atomic Power Company, 24%, Yankee Atomic Electric Company, 52%. SOURCE: https://www.eversource.com/content/wma/about/about-us/doing-business-with-us/affiliates/list-of-affiliates

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.