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The Connecticut River BUZZ: the NO LICENSE TO KILL podcast with WHMP host Buz Eisenberg, and the LATEST FERC citizen filings

Posted by on 30 Jan 2022 | Tagged as: Andrew Tittler, Buz Eisenberg, CommonWealth Magazine, Connecticut River, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River shortnose sturgeon, CRC, crippled ecosystem, critical habitat, E-Comments, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Jesse Leddick, Kathleen Theoharides, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Mr. Jesse Leddick, Mr. Mark S. Tisa, Nation's best landscaped sewer, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, right-to-know, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS, Wendi Weber, WHMP

The Connecticut River BUZZ: hear the NO LICENSE TO KILL podcast with WHMP host Buz Eisenberg, Greenfield Community College professor and attorney focused on civil liberties and human rights. Eisenberg represented detainees at Guantánamo Bay for 12 years beginning in 2004.

VALLEY CITIZENS CONTINUE TO HOLD OFF FirstLight’s plans in their fight for a living river; see their latest NO NEW NORTHFIELD FERC LICENSE on-the-record testimonies and the WHMP Afternoon Buz podcast link, BELOW:

1/27/2022: FirstLight’s crumbling, manganese-weeping Connecticut River banks adjacent to the Rock Dam river pool–beleaguered spawning and nursery site for the federally-endangered shortnose sturgeon.

* Legitimate watchdogs file INJUNCTIONS the second they find corporate infractions. They don’t look the other way in the face of ecosystem destruction for decades…

https://whmp.com/podcasts/the-afternoon-buzz-1-25-22/

Manganese-laced slurry directly entering critical habitat for the shortnose sturgeon. CRC refused to take water samples at this site, though they want to open it up to kayaks and rafts, and the attendant swimming that occurs here.

Document Accession #: 20220127-5119 Filed Date: 01/27/2022
Cynthia Lawton-Singer, Conway, MA.

“I strongly oppose the relicensing of the Northfield Mountain hydroelectric plant. The system requires more energy input to power itself than the energy that it will create. This contraption regularly disrupts and destroys the ecology of the river as it sucks every living organism out of the river and passes it through turbines. In doing this and then releasing the water from the mountain-top reservoir back into the river, the flow of the Connecticut River is reversed, once again disrupting the living creatures in the mile up and down stream from the outlet. The pump is powered by natural gas. A gas-powered pumping machine that seriously disrupts a MAJOR , four-state river’s ecology ( including endangered species, the Short-nosed Sturgeon), and is a net-energy CONSUMER, has no business calling itself a “green” or “sustainable.”

The damage done, in addition, to the river banks and to the aesthetic appeal of the Connecticut River leaves the Northfield community with a damaged and unappealing natural resource. The River should be an asset that will help the economy of the town bringing in tourists and sports-persons. Because of the disturbances on the river, none of the potential ecological or economic value of the Connecticut River is available to the Town of Northfield Massachusetts or to any of the upstream communities in Vermont and New Hampshire which would benefit from a return of the Short-nosed Sturgeon and a living river. We MUST not continue to make the mistake made 50 years ago and relicense this monstrosity. Another fifty years of this will seal the fates of countless species and deprive communities along the entire course of this river of a living beautiful, healthy Connecticut River. Again, PLEASE DO NOT relicense! Think of future generations. Thank you for your serious consideration of these objections.”
Any credible watchdog would have filed for an INJUNCTION for the deadly, suctioned and reversed river miles at Northfield Mountain, and the grim conditions for endangered sturgeon years ago. It would long-ago have been placed IN-THE-RECORD and prominent–as critical defense in this FERC relicensing. A poser would tell people that its fine to wait until AFTER federal and state agencies sign a secret 50-year settlement deal with FirstLight. A 70 year-old organization without a single staff lawyer would have people believe they can fix these little problems afterward

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.”

HERE ARE THE RESPONSIBLE DEPARTMENT OFFICIALS AND THEIR NEGOTIATION REPRESENTATIVES who are meeting behind closed doors with FirstLight:

wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service; Martin Suuberg, Commissioner of MA Dept. of Environmental Protection; andrew.tittler@sol.doi.gov, lead council at the table for USFWS; melissa_grader@fws.gov, at the table for our migratory fish; julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon); william.mcdavitt@noaa.gov, at the table for our migratory fish; mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife, jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife.

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.

This is THE PUBLIC’S RIVER!

NOTE: River ecosystem protection is inextricably linked to uplands and forests: see this great piece from Commonwealth Magazine:
https://commonwealthmagazine.org/opinion/use-our-forests-to-fight-climate-change/

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.

CONNECTICUT RIVER UPDATE: STAY THE COURSE; KEEP UP THE PRESSURE!

Posted by on 20 Jan 2022 | Tagged as: Anadromous Fish Conservation Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River blog, Connecticut River ecosystem, conservancy, Conte National Fish & Wildlife Refuge, critical habitat, E-Comments, ecosystem, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Comments, FERC license, FirstLight, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service

A Connecticut River deluge of citizens “no License to kill” defense pours into the Federal Energy Regulatory Commission.

READ THOSE DEFENDERS NAMES in the list below…

STAY THE COURSE; KEEP UP THE PRESSURE!

* * Also: On Sunday, January 23 at 10:00 AM, on Occupy the Airwaves, I join Paki Wieland, Bob Gardner and Emikan Sudan, to speak about these critical weeks for the future of the Connecticut River as FirstLight Power tries to nail down secret negotiations to relicense the devastation of the Northfield Mountain Pumped Storage Station for another half century: https://www.facebook.com/VFROccupytheAirwaves/ I hope you can listen and TAKE ACTION! * *

Occupy the Airwaves can be heard every Sunday morning at 10:00 AM on Valley Free Radio, WXOJ-LP, 103.3 FM, in Northampton, MA. Shows are re-broadcast every Friday at 3:00 PM, and can be streamed at www.valleyfreeradio.org.

HERE IS THE LIST OF THE LATEST CITIZEN HEROES of Connecticut River DEFENSE. NOTE: Update continues further below:

Joseph W Stubblefield, Sanjay Arwade, Jonathan S Shefftz, Jamie Rowen, Michael Giles, William H. Pete, Nicholas Reich, James Lowenthal, Katharine Sims, William Daniels, Paige Wilder, Karl Meyer, Shayla G Freeland, Mary J Metzger, Robert Arbib, C Grecsek, Malcolm G Everett, Mike Cournyn, Robert Catlin, Don Ogden, William N. Ryan, Elizabeth Whitcomb, Judith Nietsche, Celt Grant, Susan Olmsted, David B. Keith, Glen Ayers, Virginia Hastings, Annie Chappell, James Seretta, Ron Barto, Robert Dickerman, Pamela Scott, Tanya Dragan, Lin Respess, Rebecca Tippens, Sigurd Nilsen, Peggy Matthews-Nilsen, Amy Rose, Steven Wilkinson, Stephen Kerr, Nancy Obertz, Dorothy McIver, Robert Sweener, Seth Wilpan, Norma Roche, Fergus Marshall, Louise P. Doud, Vicki Citron, John Nelson Jr., Jon Burgess, Robert F Porzio, Garrett D Connelly, Dave Dersham, Betsy Corner, Graham Hayward, Sid Siff, Paul Richmond, Betsy Browning, Rebecca Robbins, James Smethurst, Laura Doughty, Mary Hall, Laura Kaye, Frank Ribeiro, Andrew Hutchison, Mark Russo, Judith Phillips, Priscilla Lynch, Molly Freeland, John Hoffman, Roberta Murphy, Dodi Melnicoff, Ethel S. White.

These folks have gone on the record with FERC in recent weeks and months, stating no new license should be issued for the Northfield Mountain Pumped Storage Station. They are from up and down the Connecticut Valley, from the Bay State’s border with Connecticut, up to Putney VT. I hope I haven’t skipped any of these people who understand ecosystems and have had the courage to defend ours for those who come along after. Many have also made their defense stronger by posting it in the public press. Thank you all, and stay the course!

These River’s defenders have staved off FirstLight’s secret license-to-kill negotiated plans with US Fish & Wildlife, National Marine Fisheries, MA DEP and MA Fisheries & Wildlife. THEY ARE SUCCEEDING: * NO SECRET AGREEMENT has yet been signed!! *

Don’t get sidetracked: STAY THE COURSE; KEEP UP THE PRESSURE!

OF CRITICAL NOTE:

I’ve been forwarded some posts recently. They appear to be some watershed rhetoric claiming to have discovered a last-minute, secret mechanism that can change the trajectory of this federal process at the state-level–AFTER a negotiated deal has been signed by the big-dog players and forwarded to FERC for approval.

That Cinderella idea seems to be just more window dressing from those who’ve failed to engage openly with the public in this 10 year fight. There have been decades–and numerous opportunities for any bona fide watchdog to file lawsuits on any number of flow, critical habitat and wetlands infractions and flagrant ecosystem damage across half a century.

New England’s River has been left on life-support here in Massachusetts—reversed, comatose and massively-deadly at Northfield for the last half century. There have been no lawsuits; there have been no challenges—under the Clean Water Act, Rivers and Harbors Act, Endangered Species Act, the 1872 Supreme Court ruling in Holyoke Company v. Lyman. None stood up as responsible public trust agencies for decade upon decade as the river was left in ruins as the Nation’s best landscaped deadly sewer in the Commonwealth.

We’ve just never had a real watchdog here. If there had been one it would have sued federal and state agencies and taken on a power company long ago. Defenseless for 50 years… YOU DON’T STAND BY WATCHING THE HORSE LEAVE THE BARN!

At this time, in this top-down federal process where big-time forever decisions are being made beyond the public eye, the key place to put the pressure on the agencies charged with protecting our public trust is straight to the top: GOING ON THE RECORD WITH THE FEDERAL ENERGY REGULATORY COMMISSION. Every FERC entry these defenders made has also been seen and registered in the licensing files by MA DEP, US Fish & Wildlife, MA Fisheries and Wildlife, and National Marine Fisheries. These folks are getting a constituent earful.

wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service; andrew.tittler@sol.doi.gov, lead council at the table for USFWS; melissa_grader@fws.gov, at the table for our migratory fish; julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon); william.mcdavitt@noaa.gov, at the table for our migratory fish; mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife, jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife. Forward them your Letter; then maybe forward it to the MEDIA for broadening the public record!

It is pure fantasy that it will be possible to “save the river” and make key changes to a top-down negotiated federal deal AFTER these key agencies have signed some giant ecosystem compromise with venture capital FirstLight for the next 50 years. It’s pure fantasy, bravado, and soft-pedaling of the critical juncture we are at right NOW.

The only sensible, just and moral position to take with the future of an ecosystem that must be revived to support coming generations is simply: NO LICENSE TO KILL. That’s what’s at stake right now—telling our public agents there can be no deal sanctioning a half century of massive fish kills and river reversals here in Massachusetts, in the heart of the S.O. Conte Connecticut River National Fish & Wildlife Refuge. ONCE it’s signed, there will be little if anything left to re-bargain over. The time is NOW.

There is no sugarcoating what’s at stake RIGHT NOW in secret Connecticut River federal relicensing negotiations occurring behind closed doors between FirstLight and fed/state agencies. It’s no less than the future of a living Connecticut River ecosystem. Critically, what takes place and gets secretly-signed in that backroom closet between FirstLight’s venture capital lawyers, and federal and state environmental trust entities is likely to seal the life-or-death fate of a broken ecosystem here for what ‘s essentially its last chance at revival. There are many examples of terrific testimony and river defense in the other blog posts on this site.

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.

This is THE PUBLIC’S RIVER!

The Connecticut River’s staunch public defense broadens…

Posted by on 02 Jan 2022 | Tagged as: America's best landscaped sewer, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, conservancy, Conte National Fish & Wildlife Refuge, CRC, defense, E-Comments, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Hudson Riverkeeper, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

THE PUBLIC CONTINUES TO STEP UP and defend the Connecticut River against a new half-century of ecosystem destruction.

IN THE LAST TWO WEEKS MORE THAN 40 CITIZENS–and counting, have entered testimony into the Federal Energy Regulatory Commission public record stating that the Northfield Mountain Pumped Storage Project is too destructive to be relicensed.

You can read the latest citizen FERC filings–and get directions for filing your own, further below.

These on-the-record defenses become part of the Federal Energy Regulatory Commission’s input as they ultimately make their “Environmental Assessment” of FirstLight’s full and final license application some months down the road. FERC, too, is mandated to ensure that federal and state environmental laws and statutes are followed when deliberating the issuance of a license.

Will they follow the citizenry and release Northfield’s deadly choke hold on this ecosystem in Massachusetts after 50 years of destruction??

I wish I could promise that will happen. What I can promise is that the MA Division of Fish & Wildlife, the MA DEP, the US Fish & Wildlife Service and National Marine Fisheries Service–all agencies that have failed all these decades to protect and enforce environmental statutes and federal fish passage and protections on the Connecticut this last half century, will CERTAINLY be reading these comments. They will be reading them in the knowledge that people are paying attention as they participate in backroom “final” license negotiations with FirstLight.

WILL THESE AGENCIES, ALL WITH MASSACHUSETTS OFFICES, FINALLY STAND UP for what’s still the Nation’s best landscaped sewer here in the Commonwealth of Massachusetts–AGAINST this deadly, river-reversing scourge crippling an entire ecosystem??

THEY ALL OWE NEW ENGLAND A LIVING CONNECTICUT RIVER!

Why we find ourselves here after half a century is because the river here has been left undefended since the mid-1960s when the Northfield Mountain Pumped Storage Project was first proposed.

The photo above is of a little tourism, chamber-of-commerce Connecticut River promotion paddle that took place in October 2020. That little promo outing left from a site virtually next to the mouth of the Northfield Mountain’s deadly intake tunnels. That’s MA Secretary of Energy and Environmental Affairs Kathleen Theoharides in front of the camera, State Senator Jo Comerford is in the background on the left, and CRC Director Andy Fisk–though not pictured, was also a happy paddling participant that day.

While all were offered turns in front of those cameras and to talk to the print media on FirstLight’s turf–next to the grimmest machine ever installed on the Connecticut, NOT ONE spokesperson or representative took the opportunity to defend a defenseless river; not one made any reference to the grim fate of this ecosystem’s resident and migratory fish…imperiled, just yards away, when they had the opportunity to reach the public through the media.

Rather than green-wash the elephant in the room, any one of them could have offered this truth to the public: This river-reversing machine literally devours millions of eggs and young-of-the year migratory fish produced in a three-state(Vermont, New Hampshire and northern Massachusetts)river reach annually. Instead, they paddled and picnicked.

For comparison, a nearly mirror-image pumped storage proposal was brought up in the mid-1960s by Consolidated Edison for Storm King Mountain on the Hudson River at virtually the same time.

Unlike on the Connecticut, where a “watershed council” had been in business since 1952, the citizens on the Hudson got together and decided to FIGHT against turning Storm King Mountain into their river’s deadly sewer. They fought ConEd in the courts, and defended their Hudson River, openly, in the court-of-public-opinion, for 15 years–and WON. They proudly bragged about their mission, their willingness and duty to investigate, enforce, and prosecute. That’s what bona fide river protection looks like. They forced the state and federal agencies to DO THEIR JOBS! That’s what real watchdogs do.

Do a quick bit of research on Storm King Mountain, the Hudson River Fishermen’s Association, Scenic Hudson, and ultimately, Hudson Riverkeeper, and you’ll see what enforcement and real river defense models–with staff lawyers and enforcement, look like.

HERE, BELOW, you can read a new citizen’s defense–the latest public filings defending our river and it’s ecosystem. Another half century of failure is simply unacceptable:

Document Accession #: 20220103-5007 Filed Date: 01/03/2022
Frank Ribeiro, Bernardston, MA.

Hello
As a concerned citizen of Franklin County, Massachusetts, I have lived in the Connecticut river valley for fifty years. It is truly a wonderful place to live.

In today’s modern world there are many environmental challenges that we face to maintain the balance of nature. The one problem that has been obvious to me over the many years is the constant assault to our beautiful river.

We need to stop this assault and abuse. FirstLight MA Hydro LLC license request to continue operation of the Northfield Mountain Pumped Storage must be rejected.

For the sake of company profits OUR river is out of balance. It needs your help to secure its future and the future of ALL things living who are dependent on its survival in a natural, balanced state.

Please reject this application.

Thank You
Frank Ribeiro

Document Accession #: 20220103-5010 Filed Date: 01/03/2022
Andrew Hutchison, Greenfield, MA.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem. This system is clearly harmful to endangered species, such as the shortnose sturgeon. While the facility has been bought and sold numerous times over the years, the attention to preserving the ecosystem has been ignored repeatedly in search of profits. While private businesses have a right to seek profits for their shareholders, that does not supersede the endangered species act or the right of the stakeholders to a healthy river.

Document Accession #: 20220103-5011 Filed Date: 01/03/2022
Mark Russo, Deerfield, MA.

RE: the request of First Light for re-licensing of Northfield, MA pumped storage facility (FERC project number P-2485). I have serious concerns about the damage caused by this facility to the critically important Connecticut River eco-system as graphically detailed in editorials submitted by Karl Meyer and published in the Greenfield Recorder. If your decision is to renew this controversial license, strong environmental safeguards must be required and regularly monitored; and given the current global environmental crisis, the term of the license renewal should be substantially reduced from 50 years to 25 years or less.

Document Accession #: 20220103-5012 Filed Date: 01/03/2022
Judith Phillips, Northfield, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

Dear Commissioners,
I am seeking to comment on First Light’s relicensing bid for the Northfield Mountain Pumped Storage Station on the Connecticut River.

As a Northfield resident I urge FERC in the strongest possible terms to NOT relicense First Light’s Northfield Mountain Pumped Storage facility for another 50 years for the sake of all aquatic life in our beloved Connecticut River ecosystem. The River is in a perilous position with its ecosystem teetering in these “confidential” final license settlement negotiations between Canada-owned First Light and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries that has been taking place during this December. All that has been discussed and ?agreed to? is being done behind closed doors.

I believe these license settlement negations should be moved out into the light of day and into a public forum.

In addition to the pumping station in Northfield adversely impacting our River by wasting energy from fossil fuels that they burn to send water uphill just so it can flow down back into the river which destroys the fish, and more recently First Light is impacting our tax base. Regarding taxes, First Light is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

For me, in the face of the huge environmental crisis we all are in and the current environmental damage that is occurring daily from the Northfield Mountain Pumped Storage Station, for FERC to renew a 50-year license to First Light’s outdated pumping station should be unthinkable! Further I believe this ancient energy provider, is the exact opposite of sustainability both energetically and ecologically and needs to stop now!

Laura Doughty, Wendell, MA summarized it well.
“If we are to have any chance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It isridiculous to let this corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.”

Please DO NOT relicense the Northfield Mountain Pumped Storage facility for the people and the environment upon which we depend for our continuing survival.

Judith Phillips
482 Orange Road
Northfield, MA

Document Accession #: 20220103-5013 Filed Date: 01/03/2022
Priscilla Lynch, Conway, MA.

I am writing to express my strong opposition to the renewal of FirstLight’s license to operate the Northfield Mountain Pumped Storage Station on the Connecticut River in Northfield, Ma. It is way past time to cease this destructive assault on our environment, the river and its ecosystems. As you know I am sure, this facility uses power from the grid to pull the river’s water back and up the mountain to be released at peak times at peak prices. In the process it churns, chops and spits out fish and other essential aquatic life. At a time when our very best efforts should be to heal and preserve our waters and ecosystems as a means to ensure the very survival of life on earth, it is irresponsible to continue operation of this facility. FirstLight does not offer solutions or healing to our environment. It is foreign corporation making a great deal of money on losses to our environment and our well being. Please consider it your duty to act responsibility and do not renew FirstLight’s license to operate the Northfield Mountain Pumped Storage Station. As public servants, doing so will be doing immense good for those you are intended to serve. By not doing so, you will continue unnecessary extreme environmental damage and loss and will continue to feed the pockets of a foreign corporation at the expense of those you are intended to serve.

Priscilla Lynch
Conway, MA.

BE HEARD!! NOW IS THE TIME to enter on-the-record testimony into the Federal Energy Regulatory Commission’s public licensing process.

HERE’S HOW:

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.

A Connecticut River extinction rebellion

Posted by on 30 Dec 2021 | Tagged as: American shad, blueback herring, Clean Water Act, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Death-Sewer, Delaware LLC, E-Comments, Environmental Protection Agency, EPA, Extinction Rebellion, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC licensing process, FirstLight, FISH and Wildlife Refuge??, Holyoke Co. v Lyman, 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, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, nuclear power, P-2485, pumped storage, right-to-know, shad larvae, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, USFWS

A VIRTUAL CONNECTICUT RIVER extinction rebellion has been taking place in the region over the last 10 days. Since December 20, 2021, over three dozen people have gone on the record with the Federal Energy Regulatory Commission stating, unequivocally–and in the clearest terms, that NO new license should be issued for the continued operation of the Northfield Mountain Pumped Storage Station by FirstLight. You can read testimony from the latest thirteen people in the text that follows.

Many have taken this action upon being apprised of some of the most basic information about the high stakes games for the Connecticut’s four-state ecosystem being played out behind closed doors right now. Many learned of this through my Opinion piece, “Last light for New England’s Great River” that appeared in the Daily Hampshire Gazette and The Recorder on December 2oth and 21sth, https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152 .

It outlined the perilous place our ecosystem is teetering in as “confidential” final license settlement negotiations between Canada-owned FirstLight and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries have been taking place during this month.

This citizen action has galvanized amidst the great void of leadership and wholesale lack of enforcement of any and all state and federal environmental statutes on the Connecticut River in Massachusetts these last 49 years. It’s been a half century of predation on a Connecticut River wholly lacking in a watchdog–in a state where a devastated 23 mile-long ecosystem reach literally flows backwards for miles at times, and virtually millions of resident and migratory fish are been obliterated, annually by the massive, daily, energy-squandering suction of Northfield Mountain’s turbines in their venture capital electricity resale boondoggle.

juvenile Connecticut River shad, dead

* *and this killing is NOTHING compared to the millions of juvenile fish extinguished at Northfield annually. Shad a just one species out of two dozen inhaled and obliterated there–an annual extirpation of literally hundreds of millions of juvenile and adult fish, eggs, and aquatic creatures each year.

Today in Massachusetts the Connecticut River at Northfield remains the deadliest “Nation’s best landscaped sewer”–far more drop-dead-deadly for fish and aquatic life than in the decades prior to the Clean Water Act.

I’m certain, if this river had a voice it would be raising it now to say thank you to the folks below, and the many others, who are taking a stand to save the soul of this ancient ecosystem. To read their words, please follow down.

* * ALSO, as we are at the holiday break, there is STILL time to enter your own on-the-record testimony to FERC. This ecosystem does not belong to FirstLight, or the Commonwealth, or the “environmental” agencies that have so long failed to protect it. It belongs to the children of the future. HERE’S HOW TO ENTER YOUR TESTIMONY: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.

THIS is the giant mess in 2010 made when Northfield operators failed at flushing out the accumulated muck, detritus, and death that had been sucked up from the river into their 4 billion gallon reservoir for years. They clogged their mile-long suction tunnels with several feet of mud, and later got caught and ordered to CEASE AND DESIST by the EPA, after dumping truck-load after truck-load of polluting muck directly into the river for over 90 days straight. In direct violation of the CLEAN WATER ACT. This is the MASSIVE RIVER DREDGING OPERATION the EPA ordered. Northfield went down for over HALF a year, yet everyone’s lights stayed on…

* AND HERE ARE THOSE WORDS OF SOME OF THE OTHER FOLKS CURRENTLY TAKING A STAND:


Document Accession #: 20220103-5000 Filed Date: 01/03/2022
Laura Kaye, Northfield, MA.

Dear Commissioners,
I would like to add my voice to those of my neighbors and fellow citizens of Massachusetts, who have written many thousands of words to you in support of our great Connecticut River, which has been so adversely impacted by the pumping station in Northfield – from the waste of energy from fossil fuels burned to send water uphill just so it can flow down back into the river, to the destruction of fish, and more recently impacting our tax base. Please read the detailed comments that so many people have sent to you and DO NOT approve the re licensing of the Northfield Mountain Pumping Station. For the people and the environment upon which we depend for our continuing survival.

Document Accession #: 20211230-5080 Filed Date: 12/30/2021
Mary Hall, South Hadley, MA.

I am seeking to comment on FirstLight’s relicensing bid for the NorthfieldMountain Pumped Storage Station on the Connecticut River.

I consider it is past time for that Pumping Storage Station to cease operation. The ecological costs of operation, as detailed by Karl Meyer of Greenfield, Mary J. Metzger of Westfield, and others is far too great for continued use of this facility to be justifiable.

Mr. Meyer explains how, in order to continue operations, FirstLight has undertaken to avoid tax payments for its use. In the event the facility was economically viable, it would not be necessary to obtain a tax shelter for it to continue to operate.

The Northfield Mountain Pumped Storage Station is a giant counterbalance to all of our efforts to maintain and restore our Connecticut River ecosystem. There is nothing anyone can do in advocacy for fish and other aquatic life that can remedy the harm that the Storage Station produces. To say again: The fact that FirstLight thought they needed a tax shelter for the Storage Station testifies to the fact that, even as a business, it is not economically viable.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem.

Document Accession #: 20211230-5007 Filed Date: 12/30/2021
Laura Doughty, Wendell, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

I urge FERC in the strongest possible terms: Please do NOT relicense First Light’s Northfield Mountain Pumped Storage facility. If we are to have anychance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It is ridiculous to let this
corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.

Document Accession #: 20211230-5000 Filed Date: 12/30/2021
James Smethurst, Deerfield, MA.

I am writing to oppose the relicensing of the Northfield Mountain Pumped Storage. It has had a devastating impact on aquatic species in the Connecticut River, some of which, like the shortnose sturgeon, are endangered. It serves no useful purpose other than to provide profits for out of state investors. It is not a renewable energy source, but actually an energy drain, given the power required to pump water from the river uphill. The nuclear power plant whose excess energy Northfield Mountain was supposed to repurpose is no more. It is time to close it down.

James Smethurst
5 Pleasant Avenue
Deerfield, MA

Document Accession #: 20211229-5002 Filed Date: 12/29/2021
Rebecca Robbins, Williamsburg, MA.
Dear FERC,

I am concerned about the fish and other aquatic life that get ground to bits at the Northfield Mountain Pumped Storage Station. Please do not relicense this facility without ensuring the health of the river and the creatures that live in it.

Thank you,
Rebecca Robbins
Williamsburg, MA

Document Accession #: 20211229-5000 Filed Date: 12/29/2021
Betsy Browning, Colrain, MA.

I am writing to voice my opposition to the relicensing of the Northfield Mountain Pump Storage facility. I have learned so much by reading the other letters that I feel morally obligated to add my voice. I grew up within a mile of the French King Bridge and remember the Northfield Mountain project being built. Both Northfield and Erving had great enthusiasm for the bountiful tax money they grew to rely on.

For 49 years the pump storage process has been decimating fish and wildlife along the Connecticut River. Amidst our climate crisis and the threats to species, this living river deserves our protection. Ironically this area is part of the Silvio Conte Fish and Wildlife protected area.

That FirstLight is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

I understand its original plan was to use the excess power from the nuclear plant at Vernon which is now defunct. So using power generated by other means to pump water uphill is now wasteful of resources, outdated, and
impractical.

Someone voiced the brilliant idea that the mountain could be converted to a vast solar site.

Renewing a 50-year license should be unthinkable knowing both the environmental crisis in our midst and the current environmental damage that is occurring daily from the pump storage process.

Document Accession #: 20211229-5084 Filed Date: 12/29/2021
Paul Richmond, WENDELL, MA.

I have a questions why is First Light Power going to sign a new contract
which allows them to continue to use an old technology, which is destroying
the CT River and all life in it. I am speaking of the pumping stations, which sucks up everything in the river and kills it to be pumped out when energy is needed. Storage has been an age old question since we started producing energy. When you have access how to store it. When there was access Nuclear electricity at night when it is consider cheap, they would pump up the water to then release it when they needed electricity at peek times for more money. A reasonable idea if you are an energy company trying to make a profit. Then there is the method you use to do that. Today there are much better batteries being spurred on by alternative energy to address when the sun is shining or the wind is blowing. So why isn’t First Light being asked to stop the old method which was and is destroying the river and store the access energy in batteries, or compressed air storage in the new contract they are about to sign with the state. Please do not sign a new agreement with this in it.

Document Accession #: 20211228-5069 Filed Date: 12/28/2021
Sid Siff, Amherst, MA.

I am writing to oppose the rel icensing of FirstLight’s Northfield Mountain Pumped Storage facility on the Connecticut River. At the time of its inception in 1972, it was considered a renewable energy resource, and in 1975 I visited the site on a field trip for a Natural Resource class I was taking at UMass. There was much banter about the benefits of taking ‘extra’ energy from the nearby Vermont Yankee Power Plant in Vernon, and using it to pump water out of the Connecticut River and up to the top of Northfield Mountain, where it was stored and released to spin giant turbines, thereby creating ‘clean’ energy at times of peak demand. Since that time, not only has the nuclear plant been decommissioned, requiring fossil fuel based energy to operate the pumps, but it is well documented that the effect on the ecosystem of the river has been devastating. Multiple species of aquatic life are sucked out of the river in large numbers and killed, on a daily basis. The river acts as a narrow tidal basin, causing extreme bank erosion. The flow of the river is disrupted, leading to inadequate water levels downstream, and a resulting inability of fish to reach critical spawning habitat. Add to this the fact that the facility uses more energy than it creates, it is clearly not, and never was, a source of renewable energy.

Furthermore, FirstLight has demonstrated a clear disregard for not only every living species in the river ecosytem, but also for the people of Massachusetts, by registering Northfield Mountain and Turner’s Falls hydroelectric facilities into Delaware tax shelters, depriving Massachusetts of any tax revenue.

Perhaps by creating a closed loop system, with a reservoir at the bottom of the mountain that is completely separated from the river, and using any excess offshore wind energy to operate the pumps, Northfield Mountain could be a viable energy source going forward. But in its current state, it’s an outdated, dangerous and extremely harmful and wasteful behemoth that should be put to rest.

Document Accession #: 20211228-5066 Filed Date: 12/28/2021
Graham Hayward, NORTHFIELD, MA.

I do not want First Light’s bid for re-licensing to be approved. All they’ve done behind benefit of closed doors must be moved out into the light of day and a public forum.

This is one of many matters that won’t “fly” anymore and all those involved will be dealt with, these days of theft are over.
Thank you,
Graham Hayward

Document Accession #: 20211228-5065 Filed Date: 12/28/2021
Betsy Corner, Shelburne Falls, MA.
Concerning P-2485 for Northfield Mountain

For the past 50 years I’ve witnessed and read about the damage that the Northfield Mountain Pump Storage facility has caused to the Connecticut River and its inhabitants. Certainly common sense tells us that the kind of system that uses more energy than it produces is antiquated and foolish. It’s clear that relicensing this facility would be done in the financial interests of the owner of the corporation that seems to have power over those who are involved in granting another 50 year long license. Residents of the Connecticut Valley must have a transparent licensing process, not the closed door one that has been on-going. It’s high time to protect the river’s ecology and to look at the big picture of money and politics as it affects all of us in this decision.

Document Accession #: 20211228-5058 Filed Date: 12/28/2021
Dave Dersham, Northampton, MA.

I write to you concerning project number P-2485:
The kinetic energy that FirstLight consumes to push the Connecticut river
backwards and up Northfield Mountain, exceeds the potential energy eventually gained.

Simultaneously, 10s of thousands of small fry become pulverized by being
sucked into the hydro electric turbines placed at the midpoint of this
convoluted design. The result is essentially an aquatic Rube Goldberg killing machine, despite the substandard netting placed in the river meant to divert the inexorable fate of the baby fish.

This procedure, which has been going on for decades, is the exact opposite of sustainability both energetically and ecologically ” and needs to
finally stop.

FirstLight does not deserve to be granted another 50 year license.
Thank you for your attention,
Dave Dersham

Document Accession #: 20211228-5048 Filed Date: 12/28/2021
Garrett D Connelly, Greenfield, MA.

Hello,
I am writing this request that you revoke First Light’s operation permit for the Northfield Mountain Pumped Storage Facility so that you know one more person stands against United States policies that disregard life on Earth and serve only short term profit. And in this case it is a false profit.

FERC employees know short-term profits are small relative to the economic
benefits of a clean and free flowing Connecticut river as well as I do,
probably much better. For this reason I won’t try to fit a list of economic
and environmental benefits from a clean and free flowing river and simply
describe what clear thinking people in the future might do instead.

Visualize a line of pollution sensors across a free flowing river that is so clean it has become a world renowned tourist destination. One of the sensors registers a trace of some cancer inducing chemical and enlightened employees of a future country that cares about life spring into action. Chemical sensors follow the pollution to its source and the activity causing it is stopped and cleaned up.

We all know the energy used by consumer societies is leading to extinction of human life on Earth. The wealth generated by free flowing clean rivers can only happen when energy regulators know how much energy is required by a modern and healthy nation. FERC knows far better than I that the real economy does not require a fake enterprise destroying river life for unreal paper profits so I stop here.

Please think about it from a pro-life perspective and then deny the permit to operate a fake business that destroys real life. Deny the permit that allows operation of the Northfield Mountain Pumped Storage Facility.
Sincerely,
Garrett Connelly

Document Accession #: 20211227-5224 Filed Date: 12/27/2021
Robert F Porzio, Putney, VT.
Bob Porzio, Putney VT

Dear Federal Energy Regulatory Commission,
Please do not grant a new federal license for the Northfield Mountain Pumped Storage Station, P-2485. This plant has done huge damage to the river for the last half century, reversing flows and killing fish while squandering massive
amount of energy. As a Vermont resident it is unacceptable to allow this machine to kill migrating fish that should be reaching our section of river, but are swallowed by this deadly plant on their upstream and downstream travels. We folks upstream are entitled to a thriving river and a share of its migratory fish.

Thank you,
Robert Porzio
Putney VT

The wave of Connecticut River public testimony against Northfield Mountain continues to build

Posted by on 27 Dec 2021 | Tagged as: American shad, Connecticut River ecosystem, Connecticut River Refuge, conservancy, Conte National Fish & Wildlife Refuge, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC licensing process, FirstLight, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, shad, shad larvae, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, US Supreme Court, USFWS

THE WAVE of Connecticut River public FERC testimony against Northfield Mountain continues building…

AMID the time when secret “final” settlement negotiations– initiated by FirstLight, are taking place out of sight with the US Fish & Wildlife Service, MA Fish & Wildlife, MA DEP, National Marine Fisheries, and others, MEMBERS OF THE PUBLIC are the ones standing up for a living future for the River and this four-state New England ecosystem.

They are not waiting for scripted guidelines from councils and conservancies that have failed to take on this profligate devastation for the last half century. They are going ON-THE-RECORD now–shining a light for the Connecticut River BEFORE any grim compromises get inked.

PLEASE READ DOWN to see the LATEST 8 entries into the public record. Though the “date of entry” is recorded as 12/27/2021, six of these eight testimonies were filed on Christmas Day and Boxing Day(the day after Christmas).

NOW IS THE TIME to enter on-the-record testimony into the Federal Energy Regulatory Commission’s public licensing process.

HERE’S HOW:

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.

THE LASTEST PUBLIC TESTIMONY STARTS HERE:

Document Accession #: 20211227-5019 Filed Date: 12/27/2021
Jon Burgess, Northfield, MA.

Northfield pump storage project constructed as direct adjunct to Vernon nuke power plant, to utilize what would be ‘wasted’ energy, as nuke plants can’t shut down easily. Vernon nuke plant is now dead. No more wasted energy to utilize.

The environmental damage done by the hydro storage plant far exceeds any ’emergency backup power’ justification. Their motive is simple & straightforward: Buy low, sell high, make profit.

I enjoy the tidbit benefits (boat ramp….) First Light offers. But it still can’t offset fish death, bank erosion, & other damages.

On a side note, it was a struggle to navigate the maze to get this message to you. I wish there were an easier way for the rest of Northfield to chime in on this issue, as there would be no doubt about the sentiment here. Thank you, JB

Document Accession #: 20211227-5009 Filed Date: 12/27/2021
John Nelson Jr., Plainfield, MA.

Regarding FirstLight Relicensing of the Northfield, MA, Pump Storage Facility:

This facility should not be relicensed; it is not a renewable energy source for peak electricity demand because pumping water uphill generates greenhouse gas. It has been also documented that the biota of the Connecticut River are harmed in the process. If, and despite these concerns, relicensing is to proceed, an environmental impact statement should be required. A solar installation with battery storage on top of the mountain would be a
much more suitable source of energy.
John Nelson

Document Accession #: 20211227-5008 Filed Date: 12/27/2021
Vicki Citron, Colrain, MA.

I am a concerned Massachusetts individual who lives near the Connecticut river. I drive over it every day on my way to work. It is appalling to me how low the river is and how high the adjacent canal is. FirstLight drains the river of all possibility of the river being a healthy and supportive environment for the fish and other wildlife that inhabit it.

To add insult to injury, FirstLight’s parent-owner, Canada’s PSP Investments, registered their Nothfield Mountain and Turners Falls hydro units into Delaware tax shelters. In addition to depriving aquatic life of its natural benefits, FirstLight is depriving Massachusetts of its due in tax revenue.

They are literally sucking river and the residents of Massachusetts dry.
Please do the right thing and deny a license renewal to FirstLight.

Thank you.

Document Accession #: 20211227-5007 Filed Date: 12/27/2021
Louise P. Doud, Warwick, MA.

The Northfield Mountain Pumping Storage Station has got to go. It does not make sense in this day and age. It needs to be closed forthwith. To expend electricity generated by fossil fuels from the regional electrical grid to pump water uphill just so the electricity generated from dropping tons of water back downhill into the river is made available for peak demand times is wasteful and foolish. Then there is the issue of its deadly effect on the
wildlife in the Connecticut River and erosion of its riverbanks over a span of 23 miles. Over the years of the Pumping Storage Station’s operation, the sucking up of tons of water, fish, aquatic animals and plant life has resulted in killing millions, and then their dead bodies get dumped back into the river. This is devastating to the ecology of the great Connecticut River.

On top of all this, First Light, the relatively new for-profit owner of the Northfield Mountain Pumped Storage Station, secretly moved its corporate assets for the station and their Turners Falls hydroelectric facility to Delaware – to dodge Massachusetts taxes. There is no excuse for this. FirstLight’s attempts to keep the public from understanding their abandonment of supporting local school and government infrastructures by spreading around donations here and there and garnering publicity from doing so is nothing
short of a betrayal. Whitewashing the truth. Greenwashing its corporate greed.Because, this is all about money. Not about our communities, not about caring for our regional natural environment, not about local charity. You have plenty of reasons to cite First Light’s behavior and the pumped storage station itself as deleterious to the state and the region and violating its agreements with the Massachusetts Fish and Wildlife and the
Massachusetts Department of Environmental Protection. Stop this madness and deny the re-licensing of the Northfield Mountain Pumped Storage Station.Now. Please. Do the Right Thing.

Document Accession #: 20211227-5006 Filed Date: 12/27/2021
Fergus Marshall, Chicopee, MA.

Dear members of the FERC e comment board,
My name is Fergus Marshall a lifelong resident of Chicopee Massachusetts. I have long enjoyed and respected the immense beauty of the river that my river, the Chicopee, flows into, the Connecticut.

I have been made aware just recently about a little known fact that has me very concerned. For many years I have been known of the project at Northfield Mountain, the pumped storage project which takes water from the river pumps it uphill to a reservoir during offpeak demand for electricity,stores it until there is peak load on the grid, then releases it to generate electricity, thereby creatingprofit an reliability.

This appears to have been successful for many decades but the terrible toll on aquatic life has been enormous. This facility actually causes the river to flow backwards, and in the process sucks the aquatic organisms through pumps and then through turbines killing everything. The Supreme Court ruling of 1872 mandates the safe passage for migratory fish so how is it that this is allowed?

I understand that this has, in the past, been a successful method of energy storage, however now its become an antiquated method that only makes profit for a foreign corporation, First Light of Canada.

This is almost the year 2022, are we not capable of a much better solution. Worldwide, innovators have been putting in place real solutions such as battery storage.

I am very concerned that First Lights profit making schemes are siphoning much needed money that could be used for real energy solutions for the twenty-first century.

Respectfully,
Fergus Marshall
55 Gaylord St
Chicopee Ma
01013

Document Accession #: 20211227-5005 Filed Date: 12/27/2021
Norma Roche, Northampton, MA.

I am writing to urge you to consider the health of the Connecticut River ecosystem and fishery before all else as you consider the conditions for relicensing of the Northfield Mountain Pumped Storage Station. I’ve been reading Karl Meyer’s columns on the state of the river in the Daily Hampshire Gazette with growing alarm, particulary his latest one (12/22/21) about the licensing process, as well the column of 6/2/21 about the operations of the pumping station leaving hatchling sturgeon high and dry.

I have little technical knowledge of fisheries or river regulations, but I would ask, as Mr. Meyer does, why those responsible for negotiationg the conditions of First Light’s license aren’t bound by the 1972 US Supreme Court mandate that all migratory fish have safe passage up and down all rivers. If the pumping station is sucking up and killing shortnose sturgeon (already endangered), shad (whose populations are plummeting), and other fish and aquatic animals, that’s far too high a price to pay for electricity. It sounds like the shad, in particular, have nourished people not only in our region’s past, but right up to this summer. They’re popular with fishermen, and those who catch them eat them. Such a supplemental food source, in these times of economic and and climate uncertainty, isn’tsomething we can afford to lose.

I understand that the pumping station is used for peak power generation. Given the problems associated with that practice, I’m trying to do my part. I have solar panels on my roof, and I’ve signed up with a Shave the Peak program, which alerts me when high power consumption is anticipated so that I can turn off things in my house. I’d much rather do that than contribute to fish kills. Can’t we “shave the peak” on a larger scale and do without the pumping station? Many federal agencies, as well as state governments in our region, are working hard to develop new sources of electricity. None of these will be free of problems, of course. But given that the relicensing period is 50 years, I have trouble imagining that we will need the pumping station for anything like that long.

I’m also an avid whitewater kayaker and member of American Whitewater, and I’ve sent you comments in the past urging you to incorporate water releases into dam relicensing agreements. I sincerely appreciate those releases, as I do the improvements First Light and its predecessors have made to boating access spots and other recreational facilities. But I hope, and believe, that
my comments have always added, as long as it doesn’t hurt the fish.
Of course fish die in the course of many recreational activities such as fishing!but never at the scale at which we’re losing them to the pumping station. My entertainment is certainly not worth these losses.

I hope you will insist that if the pumping station is to continue its operations, it must no longer kill fish. I’m sure that modifications to keep the fish safe could be costly, but it’s not economical to make them,then the station should not be operating.
Thanks very much,

Document Accession #: 20211227-5004 Filed Date: 12/27/2021
Seth Wilpan, FLORENCE, MA.

I am writing to urge you to NOT re-license the Northfield Mountain Pumped Storage Project. In the words of Karl Meyer, participating stakeholder and intervener in these Federal Energy Regulatory Commission licensing proceedings since 2012, this project is “the grimmest electric appliance ever installed on our river. Just like an electric toilet, Northfield squanders massive amounts of grid electricity to literally pull a river backward and uphill” flushing it and all its fish back out, dead, while reselling the secondhand juice as twice-produced watts to distant markets at peak prices.”

The stated goals of the U.S. Fish and Wildlife Service include the
restoration of safe passage of a number of fish species and to protect the river for future generations, which is in response to and in accordance with the U.S. Supreme Court mandate. The agency has failed utterly to live up to this mission. At the same time, the Canadian company PSP Investments, which is the parent company of FirstLight which current owns and operates the project, has set itself up to evade local taxes. They are making millions destroying our river.

The only impact of refusing to renew the license will be decreased profits for the companies that run it. Can you in good conscience authorize the continued destruction of this vital and irreplaceable facet of the natural world?

Document Accession #: 20211227-5003 Filed Date: 12/27/2021
Robert Sweener, Westhampton, MA.

Regarding the re-licensing of FirstLIght Hydro on the Connecticut River, I unequivocally say NO to this proceeding. Local communities and wildlife will not profit from this project. No amount of mega-profits justify this environmental degradation. We’ve seen enough damage from what they can do.
Thank you,
Bob Sweener
Westhampton Massachusetts

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future

Posted by on 21 Jul 2021 | Tagged as: 5-year FERC licensing process, Brian Harrington, Catherine Carlson, climate change, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, CRASC, Daniel McKiernan, David Cameron, Donna Wieting, E-Comments, Environmental Protection Agency, EPA, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Comments, FERC Commissioner Richard Glick, FERC Secretary Kimberly D. Bose, FirstLight, FirstLight Power, Gordon van Welie, Holyoke Co. v Lyman, ISO-NEW ENGLAND, Jesse Leddick, Julie Crocker, Kathleen Theoharides, Kimberly D. Bose, Landmark Supreme Court Decision 1872, Local Bias, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, Northfield Mountain Pumped Storage Project, P-1889, P-2485, Peter Brandien, Public Comment period, Public Sector Pension Investments, Rock Dam, Sam Lovejoy, Sean McDermott, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Steven Mattocks, Timothy L. Timmermann, Turners Falls, US Fish & Wildlife Service, Vermont, Wendi Weber

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future Copyright © 2021 by Karl Meyer

Kathleen Theoharides, Massachuetts’ Secretary of the Executive Office of Energy & Environmental Affairs before launching on a PR kayak tour of the river at FirstLight’s dock next to the intake of the Northfield Mountain Pumped Storage Project, October 2020. Photo Copyright © 2020 by Karl Meyer

NOTE: as a journalist and citizen I’ve been a participating stakeholder for nearly a decade in the ongoing Federal Energy Regulatory Commission relicensing process for the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot hydro operations. In that light, I encourage people to first view the half-hour segment of Local Bias, linked below. Then, return to this post and its resource list below for ways to participate in the critical decisions now being made about the Connecticut River. They will impact its currently crippled ecosystem for generations to come.

LOCAL BIAS link: https://youtu.be/IX2Rv2NYq3s

Since 1872 the US Supreme Court has made it the law of the land that migratory fish on US Rivers are guaranteed safe upstream and downstream passage at dams and industrial river sites. That decision was centered on a Massachusetts case at the Holyoke Dam. One hundred forty-nine years later that law remains essentially unfulfilled at an endangered species’ critical spawning and nursery site on the Connecticut River at Montague, MA, as well as at the Turners Falls Dam in that town.

Further, that law remains glaringly unenforced and unimplemented at the Northfield Mountain Pumped Storage Project in Northfield MA, where the river is literally sucked into reverse, and millions of eggs and downstream running juvenile American shad are pulled to their “functional extirpation”(vacuumed to their deaths) yearly, on their way to the ocean from Vermont and New Hampshire spawning reaches. The Commonwealth of Massachusetts has now owed Vermont and New Hampshire—and really all of New England, a living river for almost exactly a century and a half.

Warning sign announcing the dangers of Northfield’s massive intake suction. Photo Copyright © 2021 by Karl Meyer

The current Canadian parent-owners of that net-loss power regeneration/resale site are proposing only an ineffective, seasonal “barrier net” at the vacuum mouth of this facility, the very ‘solution’ that leaves this monstrous sucking in place to kill all those Vermont and New Hampshire produced eggs and baby shad, crippling the prospects for returning adult shad to those states from the Atlantic four years in the future.

The donuts and coffee were on FirstLight for the state officials and representatives taking part in last October’s little PR kayak tour. Photo Copyright © 2020 by Karl Meyer

Northfield Mountain’s net-power-loss energy consumption literally swallows and squanders the entire annual energy equivalents of whole cities and counties as it ravages the Connecticut River, using it as a crushing and deadly energy relay switch.

FirstLight is applying to FERC—backed up by a power-hungry, ecosystem-and-climate-indifferent ISO-New England, for a license to kill for decades to come. Northfield Mountain wastes monstrous amounts of grid energy, while ravaging New England’s critical main ocean connection and planetary cooling artery…

Below are resources available to the public for interacting and participating with the Federal Energy Regulatory Commission in licensing decisions, and government agency officials charged with implementing the public trust on the Connecticut River.

www.karlmeyerwriting.com/blog

NOTE: the landmark US Supreme Court environmental decision centered on the Connecticut River came back in 1872 in Holyoke Company v. Lyman, requiring safe up- and down-stream protection for migratory fish.

Send public comments on relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot Hydro Stations to the Federal Energy Regulatory Commission. The “project numbers” must be included, as well as your name and address, in order to become part of the public record. They should be concise, citing specifics in a paragraph or two, noting Northfield Mountain P-2485 and Turners Falls/Cabot P-1889.

Send via www.ferc.gov, usingE-comment, with the salutation going to: “Kimberly D. Bowles, Secretary.” Those comments can also include a cc to the current chair of the Federal Energy Regulatory Commission: Richard Glick.

Decisions concerning foreign interests and use of the Connecticut River are happening at this time, and the river in Massachusetts has sat largely emptied or dead here for half a century—a situation enabled by the Commonwealth and its officials’ enduring, ugly and pointed environmental neglect.

To gain effect, letters can be cc’d to federal-and-state officials who are the vested stakeholders representing the public in the protection of the river and resources. Those publicly recorded FERC entries can also be forwarded to local newspapers and media outlets.

LIST of executives–plus officials from federal and state agencies who represent the public in protecting the Connecticut, its migratory fish, aquatic animals and habitats through their “conditioning authority” powers:

ENERGY executives in the private/quasi-public sphere:

Mr. Gordon van Welie, President and CEO, ISO-New England, the “independent” system operator:
Phone (413) 540-4220

Mr. Peter Brandien, Vice President of System Operations, ISO-New England:

E-mail: pbrandien@iso-ne.com .

NOTE: Mr. Brandien writes the annual support letter that facilitates the daily commercial damage to the Connecticut wrought by the Northfield Mountain Pumped Storage Project. ISO has never acknowledged to the public that NMPS is NOT essential to the DAILY functioning of the power grid. Instead it encourages and shackles the public to those peak-priced, daily ravages as NMPS is handsomely paid to hold back several hours of reserve emergency-function megawatts for ISO’s 20th Century bulk power grid in case of a rare blackout (like the one in 2003), and also for occasional use–at scattered intervals, in controlling grid fluctuations.

ISO should have ago been curtailed as a functionary for private mega power interests. Today’s grid should already be based on distributed generation and micro-grid functions in this time of climate chaos and cyber crime. Energy and storage should be located nearest to where it is produced and used. Future linking of river-ravaging NMPS to 200-mile-distant wind turbines is wholly criminal when compressed air storage can be located close to metro/industrial coastal centers—including implementation at sites like Everett, Somerset, New Bedford, and elsewhere. That would render the system resilient, local and detachable–and rescue New England’s Connecticut River ecosystem to support generations to come across the next half century.

But, today and into the future, counter to Holyoke Co. v. Lyman, , ISO will happily sell off a US ecosystem’s daily life to foreign venture capital interests, keeping NMPS in lucrative daily play for decades into the future. The bottom line function of ISO-New England—forget ecosystems and climate, is apparently commercial first, and foremost. In their own words: to “protect the health of the region’s economy and the well-being of its people by ensuring the constant availability of competitively-priced wholesale electricity—today and for future generations.” They love to employ the term “clean”, but never elaborate on glaring incongruities, fallacies or impacts. Future generations apparently will have no need of living ecosystems, just an endless stream of “competitively-priced” energy. They NEVER mention energy CONSERVATION…

FEDERAL PUBLIC officials:

For endangered Connecticut River shortnose sturgeon, freshwater mussels, as well as American shad, blueback herring and American eel:
Donna Wieting, Director of Protected Resources, National Marine Fisheries Service, NOAA Fisheries:
Phone: 301-427-8400

Also, for endangered shortnose sturgeon, as well as American shad, blueback herring and American eels: Mr. Sean Mcdermott, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Sean.mcdermott@noaa.gov

Also at NMFS, protecting shortnose sturgeon and their habitat: Ms. Julie Crocker, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Julie.crocker@noaa.gov

For federal protection and enforcement of the Clean Water Act on the Connecticut River: Mr. Timothy L. Timmermann Office of Environmental Review, EPA New England Region 1, Boston MA 02109-3912:

E-mail: timmermann.timothy@epa.gov

For all migratory fish and safe passage on the Connecticut including American shad, herring, and endangered sturgeon: Wendi Weber, US Fish & Wildlife Service Region 5, Hadley MA 01035:

E-mail: wendi_weber@usfws.gov

MASSACHUSETTS state officials:

Kathleen Theoharides, Secretary of the MA Executive Office of Energy & Environmental Affairs 100 Cambridge St., Suite 900, Boston, MA 02114:
Main Phone at (617) 626-1000

For Massachusetts clean water and wetland habitat protections on the Connecticut: Mr. Brian Harrington, Bureau of Water Resources Deputy Regional Director, Massachusetts Department of Environmental Protection, 436 Dwight Street, Springfield MA 01103:

E-mail: Brian.d.harrington@state.ma.us

Also from MA DEP: Mr. David Cameron, PWS Section Chief, Massachusetts Department of Environmental Protection, 436 Dwight St., Springfield, MA 01103:

E-mail: David.cameron@state.ma.us

For state-endangered shortnose sturgeon and all Connecticut River migratory fish in MA: Mr. Jesse Leddick, Chief of Regulatory Review, Massachusetts Division of Fisheries and Wildlife, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: Jesse.Leddick@mass.gov

Also at MA Div. of Fish & Wildlife: Mr. Steven Mattocks, Massachusetts Division of Fisheries and Wildlife, Fisheries, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: steven.mattocks.@mass.gov

AN INSENSITIVITY OF PLACE

Posted by on 29 May 2016 | Tagged as: 5-year FERC licensing process, AMC, American Whitewater, Appalachian Mountain Club, By Pass Reach, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, CRWC, Dead Reach, ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments, Gary Sanderson, Greenfield Recorder, New England FLOW, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, Station 1, The Recorder, Turners Falls, Turners Falls dam, whitewater boating

An Insensitivity of Place

Copyright © 2016 by Karl Meyer (CLICK on any photo to ENLARGE)

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There’s a big difference between theory and practice. So too is there often a huge divide between what is said and what is done—and a giant gap between how you portray your intentions in writing, and how you actually carry yourself in the real world. The difference between those things is what most often turns out to be true.

At the Rock Dam, the endlessly-beleaguered and sole natural spawning site for the state- and federally-endangered shortnose sturgeon in the entire Connecticut River system, that difference came into high resolution last week. While I looked on four people in helmets and safety gear lumbered in a huge blue raft over the tiny, watered notch leading into that self-same shortnose sturgeon spawning pool. Four other decked-out compadres looked on admiringly from atop the low ledge that helped form this little ancient pool thousands of years back.

The “drop” for this joyride might have been a total of 4 feet at best, perhaps a third of the length of the giant boat. For any shortnose sturgeon that might have been using this unique ecological site to accomplish the most basic act of survival—spawning, it would’ve been the equivalent of the Starship Enterprise plopping down atop your kiddy pool party. Basically, party over. But hey, those fish are only the sole federally-endangered migratory species in the entire river. Hope you enjoyed the ridiculously short, half-second rush… Yahoo!

And the real kicker is, they were doing this within the known documented time-window at Rock Dam for shortnose sturgeon to be present and attempting to spawn successfully. This was a Sunday, but the previous Wednesday I’d seen rafts being trailered away from the site in the “Patch” section of Turners Falls. I didn’t quite put it together until Gary Sanderson’s column came out in The Recorder the next day, noting the obtuseness of rafters and kayakers he’d seen repeatedly making the same disrespectful maneuvers at Rock Dam earlier in the week.

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But here’s the theory and practice divide. During the current 5-year Federal Energy Regulatory Commission relicensing hearings for the Turners Falls and Northfield Mountain Pumped Storage projects, these whitewater groups have been at the table advocating for increased flows and access for the public on this short section of river. Chief among these have been American Whitewater and New England FLOW, with the Appalachian Mountain Club partnered with the Connecticut River Watershed Council submitting formal testimony in favor of whitewater boating interests here.

AMC and the Watershed Council in submitted testimony are advocating opening up this most-biologically-damaged stretch of the river for the last half century to increased access at three sites over a tiny reach that is just 2.7 miles long: “Improvements would need to be made to a put-in at the upstream end of the run downstream of Turners Falls dam, the take-out at Poplar Street, and access at No. 1 station and at the Rock Dam.” I wonder how many boats, rafts and cars per mile of river that constitutes.

DSCF8476

All groups in their statements and submitted testimony made reference to their concerns for the protection of aquatic habitats here, as well as adherence to the Clean Water Act in this Dead Reach stretch of the Connecticut that includes the extremely critical spawning habitat of the shortnose sturgeon—which consists solely of the small, semi-circular pool that forms below Rock Dam–along with its tiny little 4 foot drop. Shortnose congregate at Rock Dam for spawning from early April through the end of May. Let’s run giant rafts over them and invite crowds of kayakers to overwhelm the river and rocks here to demonstrate respect and concern for a river struggling for life here these last 50 years.

This is self-interested behavior only a little removed from that of the power companies, and, like the power companies, there is cash waiting in the wings for using the river in this most self-considered way. So, well done, whitewater boating interests! We at least now have a tiny picture of what your practice, rather than theory, might constitute. And, hey, did it ever cross your minds that some people actually consider the Rock Dam a sacred place..?

Shortnose sturgeon: ignoring published research

Posted by on 04 Apr 2016 | Tagged as: Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC Comments, Jack Buckley, John Bullard, Julie Crocker, Kimberly D. Bose, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shortnose sturgeon, US Fish & Wildlife Service, USFWS, Vince E. Yearick, Wendi Weber

KM-Rock Dam program 4-23-16P1000433

TOP: Rock Dam program, 4-23-16 (click to enlarge)

Bottom: The ROCK DAM: shortnose sturgeon spawning site (click to enlarge)

The following testimony was submitted on March 18, 2016, to the Federal Energy Regulatory Commission on behalf of the biological needs of the federally-endangered Connecticut River shortnose sturgeon at its sole documented natural spawning site in the Connecticut River ecosystem.

Karl Meyer, M.S.

85 School Street # 3

Greenfield, MA  01301                                       March 18, 2016

 

The Honorable Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, NE

Washington, DC  20426

 

SUPPLEMENTAL INFORMATION: RE: P-1889-081 and P-2485-063, and federally-endangered Connecticut River shortnose sturgeon, (Acipenser brevirostrum)

Attach to: 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,

This additional information is being submitted subsequent to my receipt of a March 15, 2016 letter from Mr. Vince Yearick, Director, Division of Hydropower Licensing, restating FERC’s intention to sanction spring 2016 test flows that are documented to result in spawning failure and displacement of federally-endangered Connecticut River shortnose sturgeon(SNS), at their sole natural spawning site in this river system. Those findings come from 20 years of research conducted by government scientists from both the US Fish & Wildlife Service and the US Geological Survey.

I am submitting an index and key chapters from this exhaustive body of shortnose sturgeon research published in 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. Chapter 3 directly addresses SNS spawning failure and displacement at the Rock Dam in the Connecticut’s By Passed Reach, and clearly indicates that test flows of 1500 cfs will not be protective of a species listed since 1967 under the federal Endangered Species Act.

From P. 107 (PDF-page numbers and numbers in the actual text are the same), “Spawning failure in unregulated rivers likely occurs, but it should be rare because females have adapted to natural fluctuations in the river discharge. Spawning failure (when fish were present) occurred at MontSR due to river regulation, but spawning did not fail due to peaking operations. Regulation created bottom velocities that were too low or exceeded the preference of females or created a low discharge that either prevented female access to the RockD or failed to attract them.”

Findings and data from pages 101 and 102 should provide further guidance to FERC in reexamining this decision. In his response Mr. Yearick argues that the low test flow of 1500 cfs put forth for Study 3.3.19 is somehow key in making correlations to last year’s American shad passage tests from Study 3.3.2. However, that is by no means clear (note–the 3.3.2 results have yet to be made available to Stakeholders) as that study also included tests flows of 1000 cfs and 6300 cfs—flows also not being included in order to make any useful correlation with Study 3.3.19.

Further, in regard to the failure or oversight in the protective responsibilities of the National Marine Fisheries Service to submit objections in this instance (as well as the USFWS and MA Division of Fisheries and Wildlife, who also have federal and state ESA mandates), those failures in no way release the FERC from its own responsibilities under the federal Endangered Species Act. In FERC’s own words, from: Hydropower Relicensing-Get Involved, A GUIDE FOR THE PUBLIC: “Is the Commission subject to other federal laws? Yes. The Commission must comply with a variety of federal laws, such as the Clean Water Act (to protect water quality), the Endangered Species Act (to protect threatened and endangered plant and animal species) and the National Historic Preservation Act (to protect culturally significant places and historic properties).”

Regarding Mr. Yearick’s citing of Article 34 as permitting the harming of protected species in the current license, he fails to note the following tenets included in that self-same Article regarding continuous minimum flows and modifications thereof: “These flows may be modified temporarily: (1) during and to the extent required by operating emergencies beyond the control of the Licensee; and (2) in the interest of recreation and protection of the fisheries resources, upon mutual agreement of the Licensees for Projects 1889 and 2485 and the Massachusetts Division of Fisheries and Wildlife.”

Please also note that, with the marked improvements shown in American shad passage at Turners Falls in 2015 which appear to correlate well with the significant increases in flow through the By Passed Reach, it is highly unlikely that any of the Stakeholder Agencies would consider requesting a Licensed flow of 1500 cfs when the biological needs and passage of both federal-trust and federally-endangered migratory fish require significantly more volume to fulfill their spawning requirements.

Lastly, 8 years in arrears of its license agreement signed in 2002 for FERC P-2004–to have completed upstream access for federally endangered Connecticut River shortnose sturgeon by 2008, Holyoke Gas & Electric has completed modifications to its fishway. That should allow SNS their first access and reintroduction to their natural spawning grounds in 168 years. In my mind, it would be patently criminal to greet these endangered fish on their first spawning trip upstream since 1849 with sanctioned flows guaranteed to displace them and cause spawning failure.

Thank you for your careful attention to this critical matter.

Sincerely,

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

Please see attached chapters in PDF format, as well as included index and book cover.

Cc’d via email to:

Brandon Cherry, FERC

William Connelly, FERC

James Donohue, FirstLight

Julie Crocker, NOAA

Bjorn Lake, NOAA

John Warner, USFWS

Caleb Slater, MA Division of Fisheries & Wildlife

John Bullard, Regional Administrator, NOAA Fisheries Greater Atlantic Region

Wendi Weber, Director, USFWS Region 7

Jack Buckley, Director, Massachusetts Division of Fisheries & Wildlife

Dr. Boyd Kynard

How to Submit Comments to the Federal Energy Regulatory Commission (FERC)

Posted by on 16 Mar 2016 | Tagged as: E-Comments, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC Comments

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PICTURED: The Rock Dam in Turners Falls; the sole documented natural spawning site for the Connecticut River shortnose sturgeon in this ecosystem. (Click to enlarge.)

SUBMITTING INDIVIDUAL COMMENTS TO FERC: This example is from my own recent E-Comments

Write up your Comments in Letter form, FIRST

Compose comments in a Word doc, simple and direct, you are allowed up to 6000 characters in a FERC E-Comment, which leaves room for 3 or 4, concise paragraphs, sample letter at bottom:

Include DATE, your name, address, and phone

Send them care of:

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

You must include Project numbers in your submission: in this case P-2485 and P-1889 (P-2485 is Northfield Mountain; P-1889 is Turners Falls Dam and Power Canal. You can do this after your salutation!) See next two lines.

Dear Secretary Bose,

RE: P-2485 and P-1889, protecting federally-endangered Connecticut River shortnose sturgeon

This is the opening paragraph from my Stakeholder Comment:

“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.”

Complete your Word Doc, end with your “Thank you” name, and town

Below that: indicate any individuals, agency heads or representatives you are cc-ing:

Then …..

It is not required, but you might want to register for a FERC E-Subscription for you chosen Projects, in my case, P-2485 and P-1889: Register as an individual, no affiliation. This will take a little more time, and you may choose not to. But, this way you will be Notified, with a Link to all other’s new Stakeholder Comments as they get posted.

** Also, if you get hung up anywhere along the way call the FERC 800 phone #. They are very nice!
Somewhere along the way you will have had to click on HYDRO Projects. OK, to continue…

Go to: www.ferc.gov
Go to: Documents and Filings
Go to: E-Comment
Click on: E-Comment Bar (“Does not require e-Registration”)
Fill out on-line form: All required fields
Type in the googly characters: in the field at bottom
Hit the “Authorize” button

Then: Go to your email, where you will soon receive a FERC email
Click the link that takes you to your FERC e-Comment file
Your filled-in data: will appear in the boxes

Down below is: the empty TEXT Box–your name and town will appear at the top
(Again, somewhere along you will have had to choose HYDRO Projects, not Oil or Nuclear)
In the Text Box under Docket you will see: Hydro Project Search
Below that is the Box: Enter Docket Number
Type in full project number such as: P-2485, and hit Search
P-2485 comes up, saying Northfield—Tap Plus-Bar at right to SELECT; Plus disappears
Go back in THAT SAME text box and over-write: P-1889, HIT plus-Bar again, and SELECT

NOW: Simply scroll down to the empty TEXT BOX, paste in your comments and HIT: SEND COMMENT

You will pretty quick get a FERC email thanking you for Commenting.
You’ll pretty quick get an email saying it has been received.
If you have signed up for an e-Subscription to “hydro” projects P-2485 and P-1889, within an hour a notice of your comments being entered into the FERC record will appear in your mailbox. Voila!

Click on the link to them, and you can review them. This is pretty satisfying. After which, you will get yours and all everyone else’s Comments and Protests to view. They are now part of the public record, read and reviewed by FERC, the utility, and all other fed/state Stakeholders, as well as available to the public and media.

(NOTE: the full example Comment letter below came in at 4,263 characters, with spaces—so you have some room)

** DON’T forget to copy your letter and forward to any CCs you’ve noted via email.

Pat yourself on the back–your comments are now in the Public Files for these FERC decisions.

(Here is my full comment letter, as example)

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