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Redeem the promise at Great Falls

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

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

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

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

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

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

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

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

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

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

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

Karl Meyer
Greenfield

From the Rutland Herald: Where our fish are trapped

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Connecticut River, Connecticut River migratory fisheries restoration, False attraction, Federal Energy Regulatory Commission, FERC licensing process, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Rutland Herald, shad, shad fishing, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Yankee, Vernon Dam Fishway


The following piece, with edits, appeared in the Rutland Herald on November 12, 2015.

Dear Vermont and New Hampshire:

Sorry, but your fish are down here in Massachusetts. With Vermont Yankee’s heated discharges no longer clouding issues, that’s become clear. We’re talking hundreds of thousands annually. This year a quarter million might’ve reached Vernon and Hinsdale had we not corralled them. A hundred thousand in the Great Eddy at Bellows Falls might’ve been a possibility.

And these aren’t small fry. These are free-swimming American shad straight from the briny Atlantic—wild fish that snap at lures and offer anglers an honest fight. Fresh caught and sweet, they’re a homegrown harvest for anyone taking the time to debone them or put them in the slow roaster. You could’ve been enjoying all that.

Actually you were promised them by the US Fish & Wildlife Service and state fisheries agencies back in 1967. They’d arrive in the 1980s–when much-touted fish passage facilities got built downstream. Each successive dam would pass 75% of the fish passed by the dam below it. Yet only excuses arrived. You weren’t told your fish got caught in a trap—that the Turners fish ladder diversion was a disaster; that your shad run dies in a muck-filled power canal. That’s where your bounty is still driven from the river today—where fish get diverted into a last-chance canal from which few emerge upstream.

We’ve now had the first spring where VY’s discharge has not intercepted spring runs. It appears the nuke played a smaller role than long-rumored concerning dismal fish passage at Turners. Heated effluent ain’t great for any species–but fish deprived of a river are an unending ecosystem disaster.

The 2-1/2 miles below Turners Falls Dam are that disaster. Down here government agencies don’t require anything approaching sustaining nature-like flows in the Connecticut’s bed. It’s either deluge or desert—much of it produced by the mega-flushing and pumping flows Northfield Mountain Pumped Storage Station sends downstream. Part of that blistering regime gets re-diverted into the power canal 5 miles south—a trap each upstream migrant is funneled into.

That canal is where a great migration dies—where fish get delayed; fatigued, entrapped and eviscerated. Not one in ten shad have made it beyond Turners Falls across the decades. It’s not rocket science to understand–in fact, the math just got a little simpler.

The years 2013 and 2014 were the final years Vermont Yankee was heating the river. Of the 393,000 American shad passing Holyoke Dam in 2013, just 9% or 35,000 fish made it past Turners. Yet of those 35,000 fish, 18,000 or 51% swam safely past Vernon–20 miles upstream. Similarly in 2014 of the 371,000 shad passing Holyoke, just 40,000 or 11% were able to get through the canal past TF Dam. But of the 40,000 that made it, a full 28,000 or 69%, swam beyond Vernon toward upstream destinations.

Turners’ fishways opened in 1980; Vernon’s in-river fishway in 1981. Across the decades the annual average of shad passing Holyoke that make it past Turners is 4%. In the same span, Vernon averaged passage of 40% of the shad arriving from Turners. Passage at Turners hovered near 1% for the decade beginning in 2000 when deregulation began allowing Northfield Mountain to pump and profit from the river according to price peaks on the electricity “spot market.” Those peaking pulses decimate river habitats below Turners Falls.

Which is why 2015 proved interesting. This spring, with VY silent, the Federal Energy Regulatory Commission ordered a series of nature-like test flows to be sent through the gates at Turners Falls Dam into the impoverished riverbed–to gauge their impact on the public’s fish runs. It’s part of the 5-year FERC licensing process for Northfield and Turners. At Holyoke 413,000 shad passed upstream, while at Turners just 14% or 58,000 shad passed the dam. Yet 20 miles north, 69% or 40,000 of those fish, swam past Vernon Dam—an all-time record for shad passage there.

So here’s some math: Turners passed 9% in 2013; 11% in 2014, and 14% in 2015. Vernon passed 51% of their shad in 2013, 69% in 2014, and 68% in 2015. The difference between a year with VY’s heated effluent, and one without—was insignificant, a 1% change with shad passage actually dropping a fraction with Yankee silenced. Yet they still set a new shad passage record.

It’s noteworthy the 34 year-old Vernon record was broken the first time more in-river flow was required below Turners Falls Dam, supplying a direct route upstream during FERC’s May-June test flows. It clearly spared some fish the energy costs of industrial entrapment and the dangers of weeks in a turbine-lined canal.

The problem is that canal, and a decimated river at Turners Falls. You’ve been owed fish totaling in the millions across the decades–and an ancient connection to the sea all kids should know. They’re not the power company’s fish, they’re yours. Demand federal and state fisheries directors sue for those fish—and for the Connecticut River refuge your grandkids deserve.

With apologies,
Karl Meyer, Greenfield, MA

Writer Karl Meyer is participating in the FERC hydro relicensing studies for MA facilities on the Connecticut River. He is a member of the Society of Environmental Journalists.

FERC Comments as FirstLight seeks unprecedented mid-license power increase

Posted by on 10 Nov 2015 | Tagged as: Federal Energy Regulatory Commission, FERC licensing process, FirstLight, forward market power auction, ISO New England, Mt. Tom Coal Plant, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir

The following are comments submitted to FERC concerning what would be an unvetted and potentially precedent-setting mid-license power uprate for FirstLight’s Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S.
Greenfield, MA, 01301
October 29, 2015

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

PROTEST against the granting of application for Amendment for Minimum and Maximum Reservoir Elevation for P- 2485-070, FirstLight Hydro Generating Company’s Northfield Mountain Pumped Storage Station.: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement, filed September 1, 2015.

Dear Secretary Bose,

In the 43-year operating history of the Northfield Mountain Pumped Storage Project a full assessment of the project’s impacts on the public’s river and terrestrial resources has never occurred. It has long been understood that NMPS significantly impacts some 50 miles of the Connecticut River’s riparian, stream bank, farmland and flood plain habitat from Vernon, VT to Holyoke, MA. The application before FERC requests a major, mid-license expansion of this facility’s storage and generating capacity without a full vetting of its impact on public resources.
If granted, the proposal before FERC represents a license to benefit—unrestricted and at profit, from a full 25% increase in generation capacity from NMPS’s Upper Reservoir for a 120 day period each fall, winter, and early spring, until 2018.

Given that NMPS is in the midst of its first-ever relicensing studies to gauge the impacts of its operations, it is not in the public interest to see this ongoing, 3 year, “temporary” storage amendment granted. Doing so without a full vetting of the emerging science and without the full participation of all stakeholders would amount to an Ex parte ruling—basically a precedent-setting gift to the power company during its run-up to a relicensing decision on April 30 2018.

NMPS has been granted extra cold season storage capacity only four times over its 43 year history. Each of those–save 2014, was restricted to extenuating circumstances where ISO would request NMPS to pump and generate beyond its mandated parameters after a trigger was reached. In requesting and being granted extra-limital storage last year, ISO and FirstLight appear to have entered into a new partnership of open-ended, unrestricted use of the public’s Connecticut River resources. This request is being made without investigation or any recompense to the public’s benefit beyond what both the utility and ISO refer to as “flexibility” in times of limited on-line capacity or restricted generation.

However, neither ISO or FirstLight has supplied any information as to how NMPS was used in any “emergency” capacity last winter—a winter that was prematurely touted as one with a tight energy market. Though a price squeeze was visited upon the public last winter in the form of vastly inflated energy bills, the predicted energy shortage never materialized. Both Northfield and ISO like to tout NMPS’s “black start” capability. However, to my knowledge the plant has only been used in that manner once, during the August 2003 Blackout, and increased storage capacity was not a factor in its use at that time.

ISO has in the past been tagged by FERC Board Members as supporting stilted judgements and sanctioning Foreward Market Capacity auction results that were clearly only in the interest of the power company—costing the public millions. That included 2013, when they sanctioned results from market bids by Energy Capital Partners(former owners of NMPS), who had unloaded their massive Somerset Coal Plant causing a dip in the future winter capacity outlook, sending energy bid prices soaring for ECP.

FirstLight has put itself in line to benefit from the same situation. They did not mention in any application that their Mt. Tom Plant was shuttered recently, and they stand to benefit if NMPS is granted open-ended generating privileges on the heels of a planned shutdown of one of their assets.

Further, it should be noted that FirstLight submitted only limited information on water levels in the CT River at their Turners Falls Dam and further downstream at the Montague USGS Gauge. No information was provided on how often, and by how much, the river fluctuated daily in the Turners Falls Pool due to their pumping and generating. They contend they generally strayed little from the average elevations in the TF Pool. Daily up-and-down figures during winter freezing, wetting, thawing, and rewetting, are wholly lacking.

FirstLight offers that it generated less in winter 2014/2015 than in many other years, but that tells only their story. When, and under what circumstances they generated, and at what profit, are really what’s required for a full assessment of the plant’s public good. Offering that “we only used a little” see?—is not any reasonable way to assess what might happen with an open-ended license to benefit from “peaking” spot market fluctuations this winter–or in 2016, 2017, and 2018.

Further, NMPS’s ownership changed hands three times over the last decade. Granting a mid-license capacity uprate to this plant could lead to speculation and instability in the deregulated market, causing a bubble in its asset value. If GDF-Suez decides to sell their NMPS plant in the interim, only merchants will benefit—with the public left in the dark on impacts, price, and profits.

I protest the granting of FirstLight an amendment to increase its minimum and maximum storage capacity for the remainder of its license. Further, FERC should not grant a one-year amendment without requiring a public accounting of how the plant was used in any “emergency” fashion—if any, last winter, and how its increased generation was harvested for profit on a daily basis last winter. If these are not provided, the amendment should be denied. Any amendment granted NMPS should include a capacity trigger from ISO, so as to ensure the public is not being gouged by winter fear-mongering.

Sincerely,
Karl Meyer, M.S.
Greenfield, MA, 01301

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.

On “false attraction” at Turners Falls

Posted by on 24 May 2015 | Tagged as: American shad, canal shad, Connecticut River, Connecticut River ecosystem, False attraction, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, Fish passage results, Holyoke Fish Lift, New Hampshire, Relicensing, Rock Dam, Rock Dam Pool, shad, shad fishing, Station 1, Test flows, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

On “false attraction” at Turners Falls

No, this is not about sex—well OK, maybe a little. But it’s different than how you might see someone 200 yards up the trail and think, “Wow, looking good!”—only to discover on a closer pass that they are a different sex than the one that drives you, or they are decades older or younger than the person you were expecting to see. This is about spawning though—about squashing the spawning efforts of migratory fish.

False Attraction Flow is a phenomenon where migratory fish follow flows upstream that lead them to impassable barriers. These flows are created by flood and head gate releases at dam and canal sites, and they keep wild fish expending precious energy that would otherwise be used to swim to upstream river reaches to spawn.

5/24/2015 Today, FERC Relicensing Study test flow releases to the riverbed at Turners Falls Dam are set at 2,500 cubic feet per second. The weather is clear, warm.
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At 1p.m. I visit the ancient Rock Dam site on the Connecticut, where three people are fishing—a woman and two young men. The woman has just landed a shad. She has not been here long.

One young guy is just upstream. He says he’s been getting some hits, but nothing landed. He notes that he’s also a recent arrival.

I clamber up the cliff that looks down on the Rock Dam Pool. Shad are looping by in a constant stream, visible just to the outer edge of the bubbly rip. The light is so good I can see them almost straight down beneath me, as they are only five feet out from the cliff face at times. What is also apparent is that some turn back after making the approach to the whitewater that would take them through notches they must best to pass this natural falls. I see many turn in the current–cutting back against the school, then milling for a bit in the current.
(Below, is the flow downstream, away from Rock Dam–two people with fish poles are in kayaks)
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All the while, the stream of shad beneath me trying to find a way upstream is constant. Always a run of more fish—ten, twenty–hard to get a count as they spurt along. The spectacle is reminiscent of the old medieval representation of the ocean’s fish in constant circulation around the globe. Here, they simply keep appearing in an endless line. There is no telling if the 2,500 cfs is just too low for them to risk the rough, rocky edges of the Rock Dam’s clefts to move ahead. They get lost from view in the bubbly current. What it appears like, overall, is that these fish are stuck—streaming in, agitated to move upstream, but not finding a clear path forward at this flow.

I toss a question over to the furthest guy upstream near the headwaters over this basalt rock face. He says he’s seeing plenty of fish, but hasn’t brought in one yet.

On the way out I ask the woman if she’s going to cook up the good-sized shad she has laid out in the shallows. “Will you slow cook it?” I ask, “Or do you know how to dress them?” She is going to cook it up, but describes a method of cutting through center, just to get out some of those hundreds of delicate bones, and then toasting it up. “After it’s done, you can just get in there and get at the meat with a spoon.”

She asks me where my rod and reel are, and I tell her I’m really here to document flows—so that maybe someday we can all count on fish being here. I continue up the beach. “I’m hoping when I open this one there are some eggs in there,” she says, motioning over at her catch. She’d be delighted to fry up some roe. “Yea, that’s a pretty big fish,” I say, “I’m guessing it’s a female.” I bid her good luck for the day.

I get back on my bike and follow the Turners Falls Power Canal all the way upstream through The Patch section of Turners, and then down past Station 1–FirstLight’s small hydro generating site located on a dog-leg off the main canal. There’s a lone car down the paved drive that leads to the fishing access. When I scoot down to look over, the tailrace at Station 1 is charged with current. FirstLight is generating at this site, despite the test flow requirement that water only be released from the Turners Falls Dam at the 2,500 cfs level today. This will corrupt and skew fish passage study results.
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I walk down and meet the young guy fishing just off the edge of Station 1’s frothy spillway. James is from Greenfield, and “yup,” he fishes the site pretty regular. He’s just finished landing one. It’s unceremoniously laid out in the sandy silt. Smallish. “When there’s water here there are always fish,” he notes. I ask him if he wouldn’t mind my snapping a few photos and he’s fine with it, “You’re not in my way.” He points to the water, not a few feet out from where he is, “You see them all there?” I look, but don’t see much but shadowy, sun-dappled water. I stare a bit more, then start snapping pictures of the flows.
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When I come back down from near the tailrace I look again in the current. This time my angle to the sun is better. There are the shad. Dozens of them, stacked up in the current facing upstream into an endless, impassable sheet of water. “Now I see them,” I say, “Too bad they aren’t going anywhere.” “Yea,” James notes, “they are just stuck here.” I snap a photo of his dusty catch and wish him luck for the day.
P1000447
P1000449

As I come up to the road from Station 1 there are two young boys, maybe eleven or twelve years old, walking along with poles and fishing tackle. They appear to be headed further on, to try their luck in the canal dog-leg. “Hey, what are you guys going after, shad?” “Anything!” they both say in concert. “If you head just down there,” I say, pointing, “There’s a guy just caught one. There’s dozens of fish waiting in the current—you can look right down and see them.” A quick glimmer passes between them, and they say thanks, heading down the driveway. “There’s a bit of poison ivy on the path. Watch for it.” I call, riding away.

I continue up to the Turners Falls Dam, where the flow is still at 2,500 cfs, the lowest test flow setting. There were not supposed to be any other intervening flows confounding these tests all the way downstream to the end of the power canal. The only time Station 1 is supposed to be operating during test flows is when dam releases ramp up to 6,300 cfs. The Fisheries and Aquatics Studies Team had worked out the schedule with FERC, and FirstLight agreed to it. This appears to be a clear violation of study protocols, and it throws into question fish passage results here.
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I cross the road on the Turners Falls Bridge, and peer over the side just downstream of the dam. A few people are fishing in the flow next to the Spillway Fish Ladder. I yell down to the closest angler. He’s fairly close to where Bascule Gate 1 is pouring down those 2,500 cfs. He doesn’t hear me over the rush of water. I yell again; he looks all around—then, on the third time, he looks up. I’m maybe 80 feet above him and we can’t really converse. “How is it?” yell, mimicking with the thumbs up/thumbs down gesture. At first he doesn’t pick it up, but when I do it again, he gives the thumbs down.

I’m not surprised. With all the false attraction flow at the Rock Dam Pool from the added water released by FirstLight at Station 1, there is little flow here in the broad reach of the Connecticut that would temp fish away from treading water at those sites into these thin upstream currents. The fish are basically being tricked; they are expending precious energy that could be used to get upstream to Vermont and New Hampshire just running down their batteries downstream. Imagine treading water on an aquatic, industrial treadmill that’s trying to lure them into a power canal. If you are a Vermont or New Hampshire angler, just understand that these swam their little fins off trying to spawn up on your stretch of river. The lure of false attraction just got the better of them.
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When I take a look at the head gates at the head of the Turners Falls Canal they appear all but quiet, save for the bubbling attraction currents that help lead fish into the Gatehouse Fishway —the place where the public will see them passing. The main and only place where these fish are getting a substantial upstream current that leads to this site is…yup!—2-1/2 miles downstream at the tail end of the power canal at Cabot Station. That’s likely where these fish are really being attracted–and tallied, as some that are actually radio-tagged for these studies are being registered. Humn! That would certainly skew study results toward fish “preferring” the canal…

There’s a long tradition among American shad themselves–and the fisheries biologists that have studied fish passage at Turners Falls over the decades. Study results sometimes show a remarkable uptick in fish passage at the Turners Falls Fishway on holiday weekends when the public is most likely to visit. The fish just seem to just know exactly when it’s Memorial Day Weekend. Even in those years when passage is poor for most of the month of May, those shad seem to just love to appear in the fishway windows at the holiday weekend. It’s uncanny how the fish know. Ironic, really. Not like they are being manipulated…

What would also be uncanny would be if FirstLight had their “most successful canal passage year” ever–right at the time when the studies that impact relicensing flows are taking place. Last year, when 370,000 shad were lifted past Holyoke Dam, just 39,914 made it out of the canal and upstream past Turners Falls Dam. Not a great number. In 2013, when 381,436 shad were passed upstream at Holyoke, just 35,124 made it out of the canal and upstream past Turners Falls. A slightly worse number.

For the last 15 years the canal route for migratory fish has been studied and “improved” for fish passage. Today’s numbers are still pretty much junk.

As a final testament to the lack of progress let’s go back almost a quarter century: in 1991 the Holyoke Fish Lift passed 520,000 American shad upstream. Of those, 54,656 shad managed to emerge, alive, upstream of the Turners Falls Canal and dam, to swim toward Vermont and New Hampshire spawning site.

Thus, a quarter-century later, migrating American shad here are still “partying like its 1991.” False attraction–and false solutions, are very closely related here at Turners Falls. Study results are compromised.

Vermont, New Hampshire, sorry but as an ecosystem, we are still broken up. Just know this: “It’s not you, it’s US!”

Spawning run ride from to Vernon; back to Turners Falls, Rock Dam and Cabot: May 17, 2015

Posted by on 17 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Cabot Station, Connecticut River, Conte, Dead Reach, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC license, FirstLight, Holyoke Fish Lift, New Hampshire, power canal studies, Rock Dam, Rock Dam Pool, sea lamprey, shad, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont, Vernon Dam Fishway

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The Headgates at Turners Falls Dam sending flow into the power canal were as quiet as I’ve ever seen them this Sunday. There seemed to just be a bit of attraction water for fish looking to get upstream, but no usual frothing rip that is usual with power generation.
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Downstream at the end of the power canal there was a nearly lake-like stillness as Cabot hydro station seemed to be producing little power.
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Looking upstream at Cabot hydro station from the bridge at Montague City, there was just a small run of whitewater coming down the spillway at Cabot. Data about these flow manipulations should be available for investigations and study results for the re-licensing
inquiries currently taking place under Federal Energy Regulatory Commission purview. They have significant impacts on fish passage.
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Three of the lucky anglers fishing Rock Dam today–two are in the boat in background.
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Rock Dam rocking with anglers and 6,300 cfs of flow.
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Letting a Rock Dam shad off the hook.

LASTLY, here’s today’s full POST:

Spawning run ride from to Vernon; back to Turners Fall, Rock Dam and Cabot: May 17, 2015

After cycling up Rt. 5 to Brattleboro early today, I headed south along the Connecticut. I was shocked to actually find the gates to Vernon Fishway OPEN! This is something that should be guaranteed to the public—regular, posted hours where the public can view their fish. Let John Rangonese of TransCanada know. There is always at least one pickup parked at the Vernon hydro station, all that’s needed is someone to walk over and open the gate; then close it upon leaving. Self-serve site, no cost involved. Public’s fish; public’s river.

Anyway, in the riot of effervescing current in the Vernon Fishway windows today were literally streams of American shad. They were running upstream like there was romance in the offing. Here, like at Holyoke, fish come directly upriver to the base of the dam. There, attracted by flows released down the short fish ladder at this modest falls, shad quickly find their way past the dam toward Brattleboro, Putney, Bellows Falls, and Walpole, NH. Today they were passing in pods at around 10:00 a.m. There were also a couple of smallmouths lower in the current, as well as one ropey sea lamprey flashing through the bubbles.
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USFWS tank truck used to transport tagged shad

Here, also, I ran into Steve Leach and his crew, from Normandeau Associates. Using the borrowed US Fish & Wildlife Service tank truck, they were preparing to tag fish and truck them a-ways upstream for fish passage studies connected to TransCanada’s hydro relicensing at Vernon, Bellows Falls, and Wilder. They’d done some previous tagging at Holyoke as well. We chatted a bit about test flows downstream, and the lack of rainfall, and the river’s temperature profile that is rising a bit early. I bid them luck, noting a few anglers fishing below Vernon Fishway—along with a perched bald eagle and a circling osprey.

After stopping to visit friends in Gill, MA, I was on the Turners Falls Bridge just a few minutes after noon. The test flow current is at 6,300 cfs (cubic feet per second) today, and the Connecticut is alive with frothy water across the wide, curving expanse formerly known as Peskeomscut. I look down at four people fishing the quick current along the Spillway Fish Ladder, just downstream of the bascule gate that’s pouring down current. In ten minutes time I watch five shad get hooked—four of them are landed, and one is lost near the waterline.

I get back on my bike and tuck in to the Canalside Rail Trail, scooting under the Turners Falls Bridge. As I come alongside the canal at the Turners Falls Gatehouse I notice that the canal is nearly quiet—almost like a still pond. This rivals the quietest flows I’ve ever seen passing through this site. FirstLight controls the headgates here–and with so few open, the fish coming up through their power canal can get a better shot at passage.

A cynical person might think they were manipulating the canal to make it look like a good industrial conduit for wild fish—especially during tagged-fish tracking surveys during test flows. One also might think this could be done to punch up fish passage numbers for weekend visitors to the TF Fishway—something that has shown up in fish passage tallies there for years. You’d think fish were only interested in migrating on weekends… Nonetheless, after well over a decade of subsidizing federal Conte Lab employees for fish passage studies and structural changes in the Turners Falls Power Canal, they have yet to succeed in passing more shad upstream than passed this site in the 1980s…

Curiously, when I head all the way downstream along the canal to Cabot Hydro Station, and then out on the deck of the General Pierce Bridge in Montague City—it is absolutely true that the TF Canal appears lake-like in its absence of flow, with just a small bit of whitewater bubbling down from its tailrace. Operators have certainly quieted the whole canal system this day.

In between I make a stop at the Rock Dam Pool, where the 6,300 cfs flows have the rocks roiling with lively current, and the anglers reeling in fish, seemingly at will. For the first time ever here I see two men standing and fishing below the Rock Dam’s fall in a motorized Zodiac type craft. Between the boat, the fishers wading out in the Rock Dam Pool, and the people tossing darts from the ledge over the pool, there are nine anglers fishing the site—eight men and a woman.

And the shad are streaming in. In the fifteen minutes I spend there, five fish are brought to shore. When I ask one guy to pause with his catch for a minute while I shoot a photo, he obliges. “How’s it been for you?” I ask. “I can’t seem to make a mistake today—I’ve had two dozen,” he tells me. “Well, I guess you know what you’re doing.” “Hey, I ran the Turners Falls Dam for 8-1/2 years,” he says. I nod, adding, “I guess then you know exactly when it’s time to come down here for shad.”
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The other great thing that has happened for anglers with these actual flows in the river: almost nobody is relegated to tossing lines in the stillness of the power canal. The anglers and the fish are all in the river.

Spawning shortnose sturgeon denied flow at Rock Dam Pool

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

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

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

A RIVER PRESERVED IN PLASTIC Copyright © 2015 by Karl Meyer

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

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

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

Nothing could be further from the truth.

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

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

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

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

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

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

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

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

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

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

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

New Comments to FERC, RE: Turners Falls Fisheries Studies

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

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

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

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

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

Re: P-1889; P-2485

Dear Secretary Bose:

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

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

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

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

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

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

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

Task 2: Study Design and Methods:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you.

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

A look inside the FERC licensing process

Posted by on 06 Jan 2015 | Tagged as: 5-year FERC licensing process, Drew Huthchison, Federal Energy Regulatory Commission, FERC, FERC license, FERC licensing process, fracked gas licensing, GDF-Suez FirstLight, ISO New England, Kinder Morgan, Kinder Morgan pipeline, Mt. Tom Coal Plant, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Project, shad, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont Yankee, Yankee Rowe Nuclear Plant

In mid-December I was interviewed on Greenfield Community Television’s Local Bias feature by Mark Wisniewski, former Greenfield City Council President. In a wide-ranging talk we discussed my experiences with the ongoing Federal Energy Regulatory Commission licensing process as both a journalist and stakeholder in the hydro projects at Northfield Mountain and the Turners Falls Power Canal on the Connecticut River. The FERC licensing process is a cumbersome and lengthy ordeal–transpiring over a 5- year swatch of time.

Anyone interested in–or involved as a citizen in, the deluge of FERC projects currently affecting our region, might gain some insight by tuning in: from fracked-gas pipelines, to hydro, nuclear, climate and ecosystem impacts.

Local Bias airs beginning Wednesday, at 5:30 pm, and repeats on Thursday and Saturday nights at 9 pm throughout the month of January 2015.

Local Bias is produced and directed by Drew Hutchison.

Try the link below,.. or go to look up GCTV, Local Bias to connect to a copy of the show.

http://gctv.org/videos/local-bias-karl-meyer-121514

FERC grants Northfield “temporary” Power Up-rate: the downside impacts of a studied pumped storage operation, re-posted.

Posted by on 04 Dec 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, GDF-Suez FirstLight, ISO New England, Mt. Tom Coal Plant, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, USFWS

On November 26, 2014, FERC issued an “Order Granting a Temporary Amendment” for P-2485, the Northfield Mountain Pumped Storage Station to increase its storage capacity by 25%, and generate electricity during times of peak demand–or peak prices on the electricity “spot” market, without restriction.

In its power uprate application GDF-Suez FirstLight stated that this extra capacity was necessary due to power plant closures in Vermont and coastal Massachusetts and a predicted cold winter–a forecast for the Northeast that has now been re-evaluated, with a warmer winter now predicted.  GDF-Suez FirstLight did not mention in its application that it was shuttering its own 130 megawatt Mt. Tom plant in Holyoke in October. Another factor that may have played a part in the power uprate bid: GDF-Suez North America Hydro had had its bond rating downgraded in the prior fiscal year.

Given the unprecedented power hike granted Northfield, with ISO-New England formally jumping in the middle and cheering on the process with a formal letter to FERC, I thought I might republish testimony I sent to FERC last spring, when FirstLight submitted–then subsequently retracted as a “mistake,” testimony it posted on behalf of their plant’s storage flexibility cited the wind and solar benefits of a pumped storage plant in Ludington, Michigan.

If you read through the testimony you’ll see how devastating to the ecosystem and fisheries that Ludington Pumped Storage Plant has been.  That plant, though significantly larger, has a similar timeline–first started in the early 1970s, and currently undergoing relicensing. The big difference has been that local non-profits and agencies didn’t let them off the hook for the massive habitat destruction during their first licensing period–actually winning a $172 million dollar settlement from the owners some 20 years back.  Sadly, it was too late to shield their ecosystem or save their fisheries.

So, Northfield will pump more this winter.  It seemed a good time to re-post what the STUDIED damages were at another pumped storage plant over a similar time frame.  Sadly, we can’t know what we’ve lost across the decades here on the Connecticut River.

Read below:

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by karlmeyer 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 Edit This

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 it sometimes draws more water than the river’s natural output.

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

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

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

 

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

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

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

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

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

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”
“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators. In the pumping process, it kills millions of fish.”

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

End of Formal Comments

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

Sincerely,

Karl Meyer, M.S.

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