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The curious nucelar history of Northfield Mountain Pumped Storage Station

Posted by on 08 May 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Millstone 1, Montague Nuclear Station, Northfield Mountain, Northfield Mountain Pumped Storage Station, right-to-know, shad, shad larvae, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic

Copyright © 2014, by Karl Meyer

The curious nuclear history of Northfield Mountain’s pumped storage plant

(The following piece first appeared on April 30, 2014 in The Recorder in Greenfield, MA, under: Follow the power currents; How the pumping station once fit)

GDF-Suez FirstLight has applied for a new 30-year license from the Federal Energy Regulatory Commission for its Northfield Mountain Pumped Storage plant on the Connecticut.  In this 5-year relicensing process US Fish & Wildlife Service has requested a study to protect a public resource: they want to know the mortality impacts NMPS has on eggs and larvae of migratory American shad.  But FirstLight wants FERC to substitute data from a 22 year-old Northfield study–their counsel has argued that eggs and larvae aren’t technically migratory, and thus have no right to protection at NMPS. 

Pumped storage is a most inefficient form of generating “hydro” electricity, and NMPS is not what it once was.  When proposed, Northfield was to be a nuclear-charged plant designed to gulp-up massive amounts of the Connecticut River, pushing it uphill to a reservoir carved into a mountain.  This would be done purchasing cheap, otherwise-wasted, night-generated nuclear energy from a fleet of soon-to-be-built local plants–which don’t switch off at night.

Once the net-loss task of pushing water uphill was accomplished via nuclear megawatts and reversing turbines, they’d send that water charging downhill to generate large pulses of energy during peak-use times.  Profits would come from reselling that energy back into the electric grid when demand and prices were highest, with consumers picking up the tab. 

But a river system also bore the hidden costs of NMPS and now USFWS wants to know what they are. FirstLight today doesn’t dispute NMPS kills all adult and juvenile shad drawn into its plant.  But that’s just one species.  FERC itself is mandated to protect federal trust fish, and the public is entitled to information on NMPS’s impacts.  Researchers report it sometimes draws so much river water that boats 5 miles downstream are pulled backward.    

Because of the limits of physics NMPS can only operate for 6 – 8 hours.  Then, water-depleted and power-less—it must again purchase new outside electricity to pump water uphill.  It was new technology when NMPS was proposed–technically “hydro” electricity, but not in the way people commonly understood it. 

During mid-1960s Federal Power Commission hearings, questions arose about the proposed NMPS plant’s impacts on the ecosystem.  One option, never implemented, was that it would cease operating during migration season to avoid slicing up the public’s fish in accordance with goals of the federal Anadromous Fish Conservation Act of 1965.

Back then just one local nuclear plant was operating, Yankee Atomic, 20 miles away in Rowe, MA.  But big, local, nuclear build-out plans were in the offing—the lion’s share of which would come to be owned by Northeast Utilities.  Fifteen miles upstream Vermont Yankee was under construction.  It opened in 1972 in lock-step with the completion of Northfield.  As VY and NMPS began tandem, nuclear-powered operation, plans were already underway for NU to build two reactors at a new Montague Nuclear Station, five miles from Northfield.

By fall of 1973 a 500 foot tower loomed over the Montague Plains, testing humidity, temperature, and prevailing winds in preparation for construction.  That tower was toppled in an act of civil disobedience by Sam Lovejoy the following February, helping bolster opposition to the plants.  But NU rebuilt the tower and collected the mandated data by 1975.  By then however, the playing field was changing.

Environmental questions were raised about the effects of Montague Nuclear Station’s drawing huge amounts of river water and dumping heated effluent back into the Connecticut on the federally-endangered Connecticut River shortnose sturgeon.  Questions also arose about the cumulative effects of entraining various life stages of American shad into the intake systems of two Montague plants and NMPS. 

Meanwhile, NU moved ahead on planned nuclear plants for the heavily-populated I-95 Providence-/New Haven corridor–some 100 and 125 miles distant from Northfield.  Four got built, but just two operate today. Their Haddam nuclear plant on our river was shut permanently in 1996 for safety and equipment failures.  So too in 1998 was Millstone Unit I in Waterford, CT.  In 1999 NU to accepted the largest nuclear fine to that time–$10 million for operational failures at those plants. 

Opposition, environmental impacts, soaring costs, and a partial meltdown at Three Mile Island saw NU abandon Montague Station in 1980.  Thus the Connecticut River basin doesn’t today host a forth, de-facto, nuclear waste dump.  Rowe’s Yankee Atomic closed in 1992—it’s now repository to hundreds of tons of spent nuclear fuel.  Vermont Yankee will close in December.  Entergy Nuclear has yet to fully endow their mandated decommissioning fund. 

Local nuclear power to push a river up Northfield Mountain is today nearly nonexistent.  The net-loss “hydro” generating process now taking place there essentially derives from a non-renewable, climate-warming mix of oil, coal and natural gas, plus some nuclear and even pulses of conventional hydropower purchased from as far away as Quebec. Beyond the yet-to-be-examined costs to the public’s ecosystem and fish, consumers are paying dearly for Northfield’s twice-sold electricity.  A fair relicensing process requires robust public information on the lethal aspects of Northfield’s operations.  FERC will decide the issue by early May.

Greenfield writer and journalist Karl Meyer has contributed written and oral testimony in the FERC relicensing process for the Northfield Mountain and Turners Falls power stations.

DUE DILIGENCE: looking beneath the surface

Posted by on 27 Dec 2013 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, Daily Hampshire Gazette, ecosystem, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC license, FirstLight, hydraulic study, shad, The Greenfield Recorder, Turners Falls power canal, USFWS

Copyright © 2013, by Karl Meyer

NOTE: the following piece appeared recently in Daily Hampshire Gazette, www.gazettenet.com; The Recorder, www.recorder.com; the Montague Reporter, and the Shelburne Falls and West County Independent.

                    DUE DILIGENCE: looking beneath the surface

New England’s Great River is at a critical juncture in the closing days of 2013.  An ecosystem door was slammed shut at Turners Falls 215 years ago when private investors built a dam across the river.  After 1798, migrating fish no longer reached northern Massachusetts, Vermont or New Hampshire.  In a landmark 1872 decision the US Supreme Court reopened the door to an ecosystem restoration via “Holyoke Company vs. Lyman.”  It upheld a Massachusetts law requiring dam owners to provide fish passage as part of the public interest of stakeholders upstream and down. Yet today there’s still no working fish passage at Turners Falls. 

As a stakeholder wishing to see the Connecticut River’s fisheries restoration succeed after decades of failure, I’m participating in the current 5-year Federal Energy Regulatory Commission’s hydro relicensing process.  It will determine conditions in the river for the next 30-40 years.  If you go to www.northfieldrelicensing.com and click on “2013 Documents,” you’ll find FERC’s “Study Plan Determination Letter” dated 9/13/2013.  It’s a 74-page catalogue of studies FERC has determined necessary to protect the public interests as they move to issue new long-range hydro licenses on the river in 2018.  Curiously, if you open that letter and scroll to the last word on the last page (74) you’ll find “Karl Meyer,” listed as “Recommending Entity” for Study 4.2.3, “Hydraulic Study of the Turners Falls Power Canal.”

I was surprised to find my name there, given that each of the 18 studies above it lists Firstlight, owners of the Turners Falls Power Canal, as Recommending Entity.  But this was no accident on FERC’s part.  They’d originally included the canal study as part of Study 3.2.2 in their preliminary judgments on the science needed to define the impacts of FirstLight’s hydro operations on river environments.  I’d agreed with them.  But FirstLight, in all subsequent filings, seemed determined to exclude it.  They simply excised “power canal” from 3.2.2: “Hydraulic Study of Turners Falls Impoundment, Bypassed Reach, power canal and the Connecticut River below Cabot Station.”  Their main argument was that the water surface level in the canal remains relatively stable through the year.  But given that what happens below the surface is what’s critical to the needs of migrating fish, I argued a canal study was a critical consideration. 

Two generations back a chance to restore fish runs beyond Turners Falls was squandered when the US Fish & Wildlife Service and four state fisheries agencies agreed to steer migratory fish into the chaos of the privately-owned Turners Falls power canal.  A singular New England opportunity to recoup and expand the river’s biodiversity was lost.  Just as in 1980, at best one-fish-in-ten emerges alive upstream there today.  Some years it’s 1-in-100.  That mistake stemmed from a failed quest to create a hatchery-strain of extinct Atlantic salmon here.  As a result, due diligence wasn’t applied to the needs of growing populations of herring, shad and sea lamprey, who would now have to survive a trip through an industrial canal on their spawning runs.  It also scuttled the only natural spawning grounds of the endangered Connecticut River shortnose sturgeon. 

Merriam-Webster defines due diligence as “the care that a reasonable person exercises to avoid harm to other persons or their property.”  Today, after 14 years of power company-subsidized canal studies that remain unpublished, we know scant little about conditions fish encounter throughout that canal.  Save for a few dozen yards at its entrances and exits, two full miles of watery terra incognita lay in between.  That missing knowledge comprises this ecosystem’s black hole. 

Yet with just tidbits of canal study information leaking into the public sphere, there is evidence that canal conditions–and the weeks-long migratory delays fish experience there, are proving lethal.  “Shad are dying in droves in the canal and we don’t know why,” is how one federal Conte Lab researcher responded to a question about mortality in the canal they’ve repeatedly studied using FirstLight funds.  Since dead fish don’t head back to sea to return as repeat spawners, the canal impoverishes a full 172 miles of river ecosystem up to Bellows Falls, VT. 

Thus, I’m proud to have my name listed next to canal hydraulics study 4.2.3.  I believe it represents FERC’s effort to exercise due diligence in getting the information needed to make the best choices in these proceedings.  It certainly represents my own.  FERC’s Ken Hogan has stated that thorough studies and reliable data are what FERC is aiming for as they decide on conditions hydropower interests will have to adhere to as they operate on our river for generations to come.  Anything less would constitute a failure of their public mandate.

 FERC’s Public Comment Period on any of the 39 studies they may require for the relicensing of Turners Falls and Northfield Mountain projects ends December 31, 2013.  Go to www.ferc.gov , and “filing e-comments.”  P-1889 is the Project # required for Turners Falls dam and canal; P-2485 is for Northfield Mountain.

 Karl Meyer is a member of the Society of Environmental Journalists.

Unconscionable: The Fate of the “Canal Nine”

Posted by on 09 Sep 2013 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Conte, Dead Reach, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, shad, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey's Conte Fish Lab

Note: the following piece appeared this August in Connecticut River Valley publications including: Vermont Digger, www.vtdigger.org; the Daily Hampshire Gazette, www.gazettenet.com, The Montague Reporter and The Shelburne Falls Independent, and at The Recorder www.recorder.com, (edited version).

THE FATE OF THE CANAL NINE

Copyright © 2013, by Karl Meyer     All Rights Reserved

Forty-three years after being chosen as the upstream route for migratory fish, the Turners Falls power canal remains the black hole of fisheries restoration on the Connecticut.  In current filings the US Fish & Wildlife Service is requesting telemetry coverage across the mid-Turners Falls canal to puzzle out the unexplained fate of thousands of fish.  Trout Unlimited wants balloon-tagged shad and more monitors bracketing its powerhouse to study turbine kills and migratory delay.  The Federal Energy Regulatory Commission wants a hydraulics study of that canal, where all migrants must bypass two turbine stations, then negotiate blistering turbulence just to have a shot at spawning in Vermont and New Hampshire.  On August 14, 2013, canal/dam owners GDF-Suez FirsLight rejected those studies as unnecessary in legal filings for a new 30 – 50 year federal operating license.

While every fish attempting to spawn upstream of Turners Falls dam must enter the canal, scores of questions about their fate there remain unanswered.  Basic questions like, do shad spawn in the canal, have never been studied–even though shad spend an average of 25 days there and just one-fish-in-ten that enters emerges beyond the canal.  US Geological Survey Conte Fish Lab researchers have been paid by Northeast Utilities and FirstLight for studies to improve the fish exit from the canal for the past 15 years.  Yet forty-three years after this system was put in place, it’s still one-fish-in-ten.  And canal spawning, germane to the ecosystem restoration puzzle, has never been studied.

Even more basic to success is this: if only one fish in ten makes it through—what’s the fate of the other “canal-nine”?  But you don’t pose that question if you want to keep being paid to study the public’s fish in the company’s private canal.  You study little sections of the canal–fiddle around near the company’s preferred exits and entrances—make big claims for tiny, discreet successes.  A mountain of data is collected, yet never finalized, published; nor peer reviewed.  After 15 years of study and reengineering, it’s still one-fish-in-ten.  Other agency experts wink in this shared belief: most fish entering that canal don’t survive.  Sliced-up in downstream turbines, they flush directly into the river.

“Unconscionable” is the term Dr. Boyd Kynard uses for plans afoot to move hundreds of thousands of shad into that canal via a new lift (as opposed to tens of thousands today.)   He’s an award-winning fish passage expert who logged over 25 years as a federal fish scientist– helping found the Conte Fish Lab while with the US F&WS.  Kynard believes the ineffective ladder system in place there for decades may have actually saved hundreds of thousands of fish from death in Cabot Station turbines, “The Cabot ladder is so bad most fish never reach the canal where most will exit downstream through deadly station turbines.”

Kynard, a fish behavior specialist who studied shad passage and turbine mortality at Holyoke Dam through the 1980s, believes a new lift below Cabot Station could prove the ecosystem’s next 50-year disaster.  He witnessed massive fish kills in Holyoke’s canals in the early 1980s when, starting in 1976, a new lift passed hundreds of thousands of fish upstream to spawn for the first time in 120 years.  It was hugely successful, but no one foresaw what would happen when adults headed back to sea.  While part of the migrants rode over the dam during high flows, others reencountered the dam-and-canal-system.  Tens of thousands got sucked into turbines at Hadley Falls Station or died in the canal–unable to return safely to the river. A stench of rotting fish hung over that city while dump truck after dump truck hauled tens of thousands of dead shad from the canal to the landfill.  (That condition was eventually remediated when dam owners installed a louver system in the canal to divert down-running shad into a pipe and back to the river, thus bypassing all turbines.)

But whereas Holyoke’s lift allowed shad to first spawn upstream in the river before encountering turbines, at Turners two hundred thousand fish could find themselves in a turbine-filled canal before ever getting a chance to spawn in Vermont, New Hampshire or northern Massachusetts.  And this canal’s Frances-type turbines are far more deadly than Holyoke’s.  Stressed, those newly-lifted shad can encounter two discreet turbine sites before meeting the massive canal turbulence near the dam.

This ecosystem can’t absorb another 40-year failure in the Turners Falls canal.  The USFWS, TU, and the Connecticut River Watershed Council are backing a study–adopted from Kynard’s Holyoke work, which would use low-frequency sound to deflect shad from entering the canal.  If deployed correctly it could send migrating fish straight upriver to a lift at the dam, like the one that’s succeeded at Holyoke for decades.  It’s a simple, inexpensive study–one FirstLight is already seeking to limit to a single year, or exclude altogether.  But it’s FERC who’ll decide by September 13th.  And they have a mandate to protect the public’s fish.

Comments sent to FERC Re: Northfield/TF Canal Relicensing

Posted by on 15 Jul 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, New Hampshire, Rock Dam, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont, Vernon Dam Fishway

The following are my formal Stakeholder Comments submitted on July 15, 2013, to the Federal Energy Regulatory Commission concerning GDF-Suez FirstLight’s Updated Proposed Study Plan for gaining relicensing for the Northfield Mountain and Turners Falls/Cabot Power Canal projects.  Please excuse wide line-spacing due to document format.

                                                                                                          

July 14, 2013

 

Karl Meyer, M.S., Environmental Science
Greenfield, MA  01301

 

 

 

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
88 First Street, N.E.
Washington, DC  20426

 

Stakeholder Comments, RE: FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) for Northfield Mountain Pumped Storage Project, FERC Project No. 2485-063; and Turners Falls Hydroelectric Project, FERC Project No. 1889-081

 

Dear Secretary Bose,

 

 

Please consider the following comments, changes and proposed improvements to FirstLight Hydro Generating Company’s Updated Proposed Study Plan (PSP) in order to achieve the best measurable outcomes for the public’s interest in a balanced and functioning Connecticut River ecosystem as you consider new operating licenses for hydropower generation at these two projects.

 

 

Comments refer to Updated PSP #s: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; 3.3.3; 3.3.5; 3.3.6; 3.3.7; 3.3.8; and 3.3.19.

 

Comments:

 

 

2.2.1 & 2.3.1: Proposed Changes to Project Operation

 

FL Updated Proposed Study Plan, Numbers 2.2.1 and 2.3.1: Operator is considering additional generation by adding volume, flow and velocity in, 1(p.2-15): the Turners Falls Power Canal at either Station #1 or Cabot Station, or operating Cabot Station at full capacity; and, 2(p-2-35): at the Northfield Mountain Project.  Hydraulic capacity increase at TF/Cabot sites, and at Northfield Mountain would be near 2,000 CFS respectively.

 

Any back-dated decisions in adding generation at these two licensed sites may impact the effectiveness and criteria of studies that will be implemented in the interim, and may prove confounding to the two-year study regimen.  Both would certainly impact downstream habitats and flows.  What criteria is FirstLight looking at when deciding on new generation requests—and when will they reveal their choices?

 

3.2.2: Hydraulic Study of the Turners Falls Impoundment, Bypass Reach, (“power canal”—now omitted by FL) and below Cabot Station

 

 

Note: Hydraulic study of the TF Power Canal is a key need if this is again to be considered an upstream route for migratory American shad.  After 14 years of continuous study and project improvements near the head of the Turners Falls Canal, Gate House fish passage numbers are no more improved–nor consistent, compared to numbers of fish passing Holyoke Fish Lift, than they were a quarter century ago: Holyoke Lift versus the actual percent that were able to pass up through the TF Power Canal and through the Gatehouse: (Figures from the Connecticut River Atlantic Salmon Commission Tech. Committee Meeting, Secretary’s Report: 6/18/2013)

 

Gatehouse passage success: 1989: 2.7%; 1990:7.8%; 1991:10.5%; 1992: 8.3%; 1993:3.0%

 

Gatehouse passage success: 2009: 2.4%; 2010:10.0%; 2011:6.9%; 2012:5.4%; 2013: 9.2%.

 

 

 

(p. 3-50) “FERC has requested that FirstLight develop an unsteady state HEC-RAS model in the Turners Falls Impoundment, bypass reach, power canal, and below Cabot Station to the upper limit of the Holyoke Impoundment.”

 

 

FirstLight states that a hydraulic study of the TF power canal is unnecessary, as surface (WSEL) elevations fluctuate very little.  “Given the power canal’s limited WSEL fluctuations, FirstLight does not believe a hydraulic model of the power canal is warranted.”

 

 

FERC is correct.  A full hydraulics study of the TF Canal is needed.  It is necessary as baseline information if migratory fish continue to be diverted into the power canal.  It will also be critical information if generating capacity in the TF Canal and upstream at the Northfield Project is increased by 2,000 cfs, respectively(2.2.1 & 2.3.1).  This would certainly impact hydraulics at the head gates and downstream in the power canal.

 

There are 14 head gates at the TF Gatehouse flushing directly into the TF Power Canal.  Surface level elevations have very little to say about actual flow hydraulics at this site.  Those head gate openings and the fluctuating head-levels from the TF Impoundment behind the dam create a region of extreme turbulence in the canal running some 500 feet downstream from Gatehouse.  This is one of the bottlenecks in the power canal route that has not been overcome after 43 years of study and structural changes in this upstream route.

 

 

When the agencies and the public were taken on FERC site visits, only one group in three was given a tour of this side of the TF Gatehouse.  At that time, only 4 head gates were open.  The canal appeared a relatively calm place.  When all head gates are open—as the Northfield Project and Cabot are run in peaking modes, or the TF Canal is run at baseload capacity through the day, this region is a boiling-roll of water.  Surface speeds reach nearly 10 mph (as monitored by cyclists on the canal path).  We need to know how this affects velocity and turbulence throughout the water column

 

 

Given recent fish passage increases at Holyoke Dam, it is feasible that building a facility to lift migratory fish out of the CT River and into the TF Canal below Cabot Station could divert as many as 100,000 fish into the canal over a period of a few days.  Recent work by USGS Conte Anadromous Fish Research Center showed American shad spending an average of 25 days in the power canal.  Researchers did not investigate whether this was a signature of fish mortality, spawning, or milling. Nor has the TF canal ever been investigated as spawning habitat—which would have been logical, given those lengths of stopover.  American shad notably do not do well with stress.  Piling up the population in a power canal will likely result in major migratory delays and increased mortality—which needs a full investigation if this path remains an option.

 

This should be a two-year effort, to control for differences in flow years, fish tagging and handling, and to assure that full acoustic coverage is gained through proper array deployment.

 

American shad have not been able to negotiate this region of high turbulence since this canal route was chosen for them in 1980.  At Holyoke, as well as at Vernon Dam, fish follow attraction water that leads them directly upstream to the dams.  Rates of passage at both are within the acceptable range of 40-60% that the agencies have set as targets.  When the Connecticut River above Cabot Station—aka, the Bypass Reach, was allowed to be de-watered in deference to this power canal route, shad and herring were expected to locate and negotiate a series ladders, turns, turbines, and turbulence at a half dozen canal sites in order to reach upriver spawning areas.  It’s a migratory knot; created by humans.

 

The Connecticut River migratory fisheries restoration effort risks repeating four new decades of failure if it again ignores logic.  The TF Power Canal is in need of a full hydraulic study.

 

Hydraulic modeling must be done here in order to avoid another migratory fisheries restoration disaster at Turners Falls.  Northern Massachusetts, Vermont and New Hampshire have yet to see their guaranteed shares of the targeted shad and herring runs, nor has the program achieved anything near its stated goals:  “The intent of this program is to provide the public with high quality sport fishing opportunities in a highly urbanized area as well as to provide for the long term needs of the population for food,” as stated in the New England Cooperative Fisheries Statement of Intent in 1967.

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Please ADD to Existing Information: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu.  Chapter 3-Migrations, Effect of River Regulation documents over a decade of highly relevant studies.

 

 

FirstLight’s Water Level Recorders (River Stage)”The Water Level Recorders deployed by FL in 2010 that supplied “limited data” from the By Pass Reach and below Station 1 should be removed from “existing information” status.  WSEL monitoring in this reach needs to be redone.  Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Add to information list for specific information on this reach: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.

 

Additional WSEL monitors needed. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

3.3.1 Conduct Instream Flow Habitat Assessments in the Bypass Reach and below Cabot Station 

 

If migratory fish are again to be diverted into the TF Power Canal via a new lift in the river near Cabot outflows (proposed), special consideration needs to be made when considering siting the lift facility.

 

Federally-endangered shortnose sturgeon will likely enter the lift, and there exists the risk of putting them into the power canal where there is potential for turbine mortality.

 

Migratory delay: another reason for special care in considering diversion is migratory delay for American shad and blueback herring at this site.  If a lift gets built at Cabot, there will be a need for full-time monitoring personnel in order not to risk sending SNS into the canal.  Just as at Holyoke, with Atlantic salmon monitoring, the lift would then have to shut down—sometimes for weeks at a time, due to turbidity and the risk of NOT identifying a migrant salmon(or in this case, a federally endangered SNS).  This type of migratory delay would not likely be acceptable to the agencies, or FL (see FL’s added text about “without delay” under 3.3.19 : “Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.”

 

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

The IFIM Study needs to be conducted with increased WSEL monitors given FL’s stated intent to potentially increase generation and flow at the Northfield Project, Station 1, and Cabot Station.

 

Several more monitors at key sites are needed to protect resident and migratory fish, as well as the federally-endangered shortnose sturgeon, which gathers for pre-spawning in the pool immediately below the Rock Dam, and–when flows allow, chooses to spawn there.

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.” (Refer to chapters 1 & 3, Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

 

Need for Additional Information (3-53):  Where, exactly, did FL locate WSEL monitors in the By Pass Reach?  How do they intend to guard against “vandalism” ruining further data collections?

 

Information list for specific information on this reach, ADD: Life history and behaviour of Connecticut River shortnose and other sturgeons, 2012, Kynard et al, World Sturgeon Conservation Society, publications, ISBN: 978-3-8448-2801-6.  Available through the North American Sturgeon and Paddlefish Society at: www.nasps-sturgeon.org/#!publications , or directly from Dr. Kynard at: kynard@eco.umass.edu

 

Additional WSEL monitors needed to capture fuller By Pass flows profile. In order to protect pre-spawning and spawning of shortnose sturgeon in this reach of river additional WSEL monitors should also be placed at: 1. In the pool immediately below Rock Dam, 2. on the west side of the river, in the main stem channel, upstream of Rawson Island which is adjacent to, and just west of the Rock Dam.  That Rock Dam ledge continues through the island and reemerges as part of the thalweg near the river’s west bank.

 

Table 3.3.1-1: Target Species and Life Stages Proposed for the IFIM Study Reaches.

 

Under Reach 1 & 2: blueback herring: add “spawning”—as New England Cooperative Fisheries Research Studies document BBH spawning in this reach, at the mouth of the Fall River.

 

 

Under Reach 1 & 2: shortnose sturgeon: add “pre-spawning.”

 

Note *: personal communication from Dr. Boyd Kynard, fish behaviorist and CT River shortnose sturgeon expert:

 

“For 10 years between 1993 and 2007, adult sns were present at Rock Dam for 5 years prior to spawning occurring anywhere ( Rock Dam or Cabot Station). During the 5 years they were present, the mean number of adults present was 10.4 (range, 3-25). Thus, many adults moved to the Rock Dam spawning site before any spawning occurred at Cabot Station suggesting they preferred to spawn at Rock Dam.”

 

 

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

 

Study Goals and Objectives (18 CFR § 5.11(d)(1))

 

“The goal of this study is to identify the effects of the Turners Falls and Northfield Mountain Projects on adult shad migration. The study objectives are to:”

 

 

Add: “Determine route selection, behavior and migratory delays of upstream migrating American shad through the entire Turners Falls Power Canal.”

 

Add to “Describe the effectiveness of the gatehouse entrances;” …

 

 

ADD IN: “and describe the behavior of migratory American in the Turners Falls Power Canal within 500 feet of the gatehouse entrances.”

 

ADD IN: “Evaluate attraction for shad reaching the dam spillway under a range of spill conditions.” 

Note:  Since a lift is being considered at this site, evaluating spillway attraction is most important.

 

 

 “Evaluate attraction, entrance efficiency and internal efficiency of the spillway ladder for shad reaching the dam spillway, under a range of spill conditions;”  see immediately below.

 

Footnote 35 “This may be achieved with existing information; FirstLight is awaiting data from the USGS Conte Laboratory.”

 

 

NOTE: USGS has done 6 years (2008 – present) of study and data collection at Spillway and Gate House.  All of it remains “preliminary”—hence never finalized, or peer-reviewed.  Only “finalized” study data and findings should be included in FERC study plan design, and made available to all stakeholders for review.  All studies are partially FirstLight funded.

 

The Need for Additional Information

 

Under  Task 1: “Review existing information:”

Only finalized USGS study information should be considered.

Task 2: Develop Study Design:

As per FERC request, a radio and PIT tag study of the entire Turners Falls Power Canal should be included in this study.

 

 

Task 3: Evaluation of Route Selection and Delay

 

             Under: Radio Telemetry Tracking: Add in:

 

“Tagged fish will be tracked throughout the Turners Falls Power Canal during bothupstream and downstream migration with fixed antennae and mobile tracking; usingPIT tags in addition to radio telemetry tags.”

 

“Additional tagged individuals may need to be released farther upstream (Turners Falls power canal, * (ADD IN: “top of Cabot Station Ladder,”) upstream of Turners Falls Dam), to ensure that enough tagged individuals encounter project dams on both upstream and downstream migrations, that these individuals are exposed to a sufficient range of turbine and operational conditions to test for project effects, and to provide adequate samples sizes in order to address the objectives.”

 

Under: Video Monitoring

 

 

Video monitoring at the Spillway Ladder is insufficient.

 

Note: Video monitoring is insufficient in determining the number of fish attracted to the spillway.  It will only register fish that can FIND the Spillway Ladder Entrance.  This in confounded by a range of competing flows, water levels present in the By Pass, and spill from the dam.  A full range of telemetry tracking needs to be employed at the TF Spillway—not simply at the Spillway Ladder and SL Entrance.

 

Task 4: Evaluation of Mortality

 

Note: Preliminary USGS TF Canal studies have suggested uninvestigated data indicating mortality within the Turner Falls Power Canal.  Mortality tagged fish and data should be collected throughout the entire TF Power Canal, to correct for overall mortality.

 

 

The number of fish suggested to be fitted with mortality tags is insufficient in all these studies, and should be increased by a factor of two.

 

Table 3.3.2-1: Proposed locations and types of monitoring and telemetry equipment proposed for the upstream and downstream passage of adult shad study.

 

 

ADD in: (to identify migration routes and delays):

 

After “Cabot Ladder”, add new location: Eleventh Street Canal Bridge: PIT Tag Reader

 

Before “Rawson Island”, add new location: TF Power Canal, 400 feet downstream of Gate House.  PIT Tag Reader and Lotek SRX.

 

 

Also before “Rawson Island”, add new location: “Rock Dam Pool, immediately downstream of Rock Dam.”  Lotek SRX.

 

 

After “Turners Falls Spillway Ladder,” add: Turners Falls Spillway, Montague Dam.  Lotek SRX;  followed by a new location, add in: Turners Falls Spillway, Gill Dam.  Lotek SRX.

 

QUESTION: What is the exact location considered for “Below Turners Falls Dam” ?

 

 

3.3.3 Evaluate Downstream Passage of Juvenile American Shad

 

Task 3: Turbine Survival

 

Evaluations should be done for all turbines, with all turbines operating, at both Cabot and Station 1, to capture the broadest range of conditions at these sites.

 

 

3.3.5  Evaluate Downstream Passage of American Eel

 

Level of Effort and Cost (18 CFR § 5.11(d)(6))

 

Study ticket price is too expensive.

 

 

“The estimated cost for this study is approximately between $350,000 and $450,000.”

 

Note: Costs of this American Eel Study are prohibitive, particularly since there is no benchmark data on the ecosystem importance of eels above Mile 122, TF Dam.

 

This rivals the costs of all studies supported to assess migration and mortality of American shad, a restoration target species to Vermont and New Hampshire for 46 years.

 

 

 A significant proportion of that money could best be used to increase the scope of study: 3.3.2, and 3.3.7: Evaluate Upstream and Downstream Passage of Adult American Shad; and 3.3.7 Fish Entrainment and Turbine Passage Mortality Study.  These could then include a full study of the Turners Falls Power Canal–and increasing the number of mortality-tagged fish.

 

Cost effectively, a literature survey, and results from Holyoke Dam studies and Cabot data collection should suffice to gauge survival of American eel at Turners Falls/Cabot/Northfield.  A portion of the funding could be used to construct an eel-way at TF Dam—a relatively inexpensive structure.

 

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

 

 

Under: Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

Information as American spawning and spawning habitat is missing for the pool where shortnose sturgeon spawn, the Rock Dam Pool, immediately downstream of that notched ledge in the river.

 

Task 2: Examination of Known Spawning Areas Downstream of Turners Falls Dam

 

Note: The Turners Falls Power Canal needs to be investigated as a spawning location for American shad.  USGS studies have registered migratory shad remaining in the TF Canal for and average of 25 days.  Adult shad, which do not feed during spawning migration, must complete their salt-to-river-to salt spawning runs within 44 days in order to survive.  A critical need is to know whether these fish are spawning in the TF Power Canal, milling in the canal, or whether they have expired.

 

3.3.7 Fish Entrainment and Turbine Passage Mortality Study

 

Increase the number of mortality-tagged fish; run tests for all turbines at Station 1 and Cabot, with all turbines operating.

 

3.3.8 Computational Fluid Dynamics Modeling in the Vicinity of the Fishway Entrances and Powerhouse Forebays

 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3))

 

 

Note: Three-dimensional CFD Modeling needs to extend 500 feet downstream of the Gate House in the Turner Falls Power Canal to capture the influence of the 14 head gates at the dam on migratory fish behavior and delay.

 

3.3.19 Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace  

 

 

General Description of Proposed Study

 

FirstLight’s added language: “This study will be conducted in 2015 pending the results of Study No 3.3.1 and Study No. 3.3.2, which include analysis of historic fish passage data.”

 

Note: This study should be conducted for two seasons, the same time span accorded to American eel. 

 

Historic fish passage data likely has only minimal importance, as early spring freshet flows over the TF Spillway generally out-compete Cabot Station flows and send fish treading water at the base of TF dam—often for weeks.  Those freshet flows at the dam typically overwhelm any flow from the Spillway Ladder, and the shad essentially run down their engines treading water until the freshet subsides.  At that point, flows over the Spillway are allowed to be cut to 400 cfs, which sends the shad downstream to fight their way into the spill of the canal system. For this reason, historic data has limited value as the quantified presence of shad at the base of TF Dam is missing, and data on the effectiveness of Spillway attraction flow does not exist.

 

Resource Management Goals of Agencies/Tribes with Jurisdiction over Resource (18 CFR § 5.11(d)(2)) 

 

“• American shad must be able to locate and enter the passage facility with little effort and without stress.”

 

“• Where appropriate, improve upstream fish passage effectiveness through operational or structural modifications at impediments to migration.”

 

 

“• Fish that have ascended the passage facility should be guided/routed to an appropriate area so that they can continue upstream migration, and avoid being swept back downstream below the obstruction.”

 

Note: This study should not be contingent on results of other studies, and should be conducted for two seasons. 

1.    Its effectiveness at another Connecticut River bottleneck has been tested.

 

2.    It addresses the need to avoid migratory delay and failure for two key species that have topped the CT River fisheries restoration since 1967: American shad and blueback herring.

 

3.    It keeps the fish migrating in the Connecticut River.

 

4.    If it proves effective, it would simplify fish passage mechanisms and cut by millions of dollars the cost required for passing TF Dam.  A single set of lifts at the dam would pass fish, as it has at Holyoke for decades.

 

5.    It would avoid the expense and pitfalls of requiring fish to negotiate two mechanisms at Cabot Station, another out of the canal, and a final grid through Gate House. 

 

6.    It presents the opportunity to avoid the stress required of migratory fish when they are driven into the TF Power Canal, then must find their way through turbulence and fight a path through several more untried, built mechanisms.

 

7.    USGS studies have found the average passage time through the TF Canal is 25 days; whereas transit times in the actual river—from Holyoke to TF Dam, or from TF Dam to Vernon Dam, are generally accomplished in a matter of 2 – 3 days.

 

8.    This would avoid the problem of shortnose sturgeon being picked up in a lift at Cabot Station, which would be a cause for further migratory delay as lifts would have to stop to retrieve fish—and also might have to be shut for days during times of high turbidity. 

Existing Information and Need for Additional Information (18 CFR § 5.11(d)(3)) 

Information from Proposed Project Changes, Flow, Hydraulics, Habitat, and Telemetry studies: 2.2.1; 2.3.1; 3.2.2; 3.3.1; 3.3.2; should be used to inform the implementation of this study. 

 

FirstLight’s added-in text:

 

“however, simply repelling shad from the Cabot tailrace is not a satisfactory result, for this behavioral barrier to be successful the fish would also have to keep going upstream, without delay, as opposed to dropping down below Cabot.”

 

Note: this caveat does not present a satisfactory argument.  In order to be proven ineffective, delays caused by sonics repelling fish from the Cabot entrance would have to out-compete any delays American shad and blueback herring encounter by being drawn to the Spillway during spring freshet and not find a readable upstream flow or passage at the dam. To this must be added the delay and stress of having river attraction and Spillway flow cut to 400 cfs, thus sending them DOWNSTREAM to fight their way into the TF Power Canal. 

Question: Should FL be deciding what constitutes delay?  Shouldn’t American shad dropping back two miles downstream from the TF Spillway to Cabot Station be considered an “unsatisfactory result”? 

 

Methodology (18 CFR § 5.11(b)(1), (d)(5)-(6))

 

Note: Ensonification coverage may need to be deployed far enough out into the main stem so as to lead fish out to the thalweg/main flows on the west side of Rawson Island.  Simply steering fish out of the Cabot entrance, but then only allowing them the choice of the minimal flows coming down through Rock Dam at the time paltry 400 cfs release would likely keep the fish milling and confused below Station # 1. 

Study Schedule (18 CFR § 5.11(b)(2) and (c))

 

FirstLight’s Added text: “ 

“If performed, the study is anticipated to conclude by mid-July 2015.”

 

Note: This should not be a contingent study. 

                                                End of Formal Comments 

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

Sincerely,
Karl Meyer, M.S.

Double Standard on the Connecticut

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

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

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

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

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

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

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

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

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

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

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

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

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

Dam Relicensing: Diving into the Dead Reach

Posted by on 28 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, federally-endangered shortnose sturgeon, FERC license, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Rock Dam, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab

Watch Diving into the Dead Reach on LOCAL-BIAS: Learn why information about fish mortality in the the deadly Turners Falls Power Canal has been kept from the public these last 14 years.

Tune-in Greenfield Community Television’s (GCTV) Local-Bias Host Drew Hutchison and guest Karl Meyer, and find out what happened when he went snorkeling in this critical segment of the Connecticut–which should be deemed a spawning sanctuary for shortnose sturgeon and migrating American shad.

The program airs Weds. May 29th at 5 pm, and again on Thursday, May 30, at 9 pm; then again on Saturday, June 1, at 9 pm.  The series repeats at those time the f0llowing week.

Go to:  http://www.gctv.org/node/5264

See also: http://www.gctv.org/schedule

Hydropower Licensing: Northfield Mtn/Turners Falls Power Canal–Get Involved

Posted by on 23 Oct 2012 | Tagged as: FERC license, Northfield Mountain Pumped Storage Reservoir, Turners Falls power canal

The Federal Energy Regulatory Commission’s Role: in their own words: “The Commission does not propose, construct, operate, or own such projects. But it does issue preliminary permits and licenses for hydropower projects, enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”

You can sign up to receive information about the GDF-Suez FirstLight Northfield Mountain-Turners Falls Dam relicensing from the Federal Energy Regulatory Commission. This enables you to get all the federal filings and documents from the legal process. From here, you can become a public “commenter” on the license, or and “intervener.” Or, you can simply keep up to date on the process.

Go to: www.ferc.gov/docs-filing/esubscription.asp and follow the steps for registration. For the fullest information, sign up for both the Commission’s Service List and Mailing List for the to relicensing projects.

You will need the following Project Numbers to get information specific to Northfield/Turners Falls:

Northfield Mountain Pumped Storage Project: FERC No. P-2485; Turners Falls Hydroelectric Project: FERC No. P-1889.

You can also visit GDF-Suez FirstLight’s own website for their information on the relicensing and sign up for their mailing list at: www.northfieldrelicensing.com
You can

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

Posted by on 24 Sep 2012 | Tagged as: Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey

Copyright © 2012 by Karl Meyer.  All rights reserved.

The Connecticut River for the next Half-Century: a federal hydro relicensing process already leaving the public behind.

The only public site visits scheduled in the Federal Energy Regulatory Commission (FERC) relicensing process for five giant hydro-power facilities and dams operating on the Connecticut River are taking place in less than two weeks.  In Massachusetts few members of the public appear to have been apprized of the opportunity to attend federally-mandated public site tours to GDF-Suez-FirstLight’s Northfield Mountain Pumped Storage Station and their Turners Falls Dam and Canal generating facilities.  A few news items appeared in the local media about the visits, published less than 48 hours before the deadline to sign up for tours.

Thus, few members of the public registered in time to tour the complex of facilities GDF-Suez operates on a seven-mile long stretch of the Connecticut that profoundly hamper upstream migratory fish runs, and directly impact the annual spawning success of the federally endangered Shortnose sturgeon. The shortnose sturgeon’s Connecticut River spawning grounds are on a short stretch riverbed a mile below the Turners Falls Dam, adjacent to the US Geological Survey’s Silvio O. Conte Anadromous Fish Research Center.

The next chance for the public to visit and judge the impacts these facilities have on New England’s Great River may not come around again for two generations. These site visits are the critical beginnings to a six-year process that will dictate whether or not the Connecticut River is a restored and functioning ecosystem through at least the year 2058.  FERC licenses are issued to corporations for up to 40 years. The Connecticut belongs to the public, but licenses allow the leasing of a certain amount of flow to corporations to produce power, while dictating conditions that will protect the public’s interest in a restored and functioning ecosystem–including migratory and resident fish, and other riverine species and critical habitats.

Today, the Connecticut River ecosystem restoration fails profoundly at approximately river-mile 120, where most of the river’s flow and its upstream migratory fish have been shunted out of the riverbed and into the Turners Falls Power Canal.  Most migrants never emerge upstream of the punishing currents, upwellings, slicing turbines and silt-laden habitats found in the power canal.  The Connecticut River above the Northfield Mountain/Turners Falls hydro facilities has never been restored to anything resembling a functioning ecosystem.

In 1975 hearings before the Federal Power Commission (today’s FERC) that established the fish passage facilities that have failed for decades at Turners Falls, Colton Bridges, then Deputy Director of Massachusetts Fisheries and Wildlife, appeared as a member of the federal/state Connecticut River Fishery Program (established in 1967, and today known as the Connecticut River Atlantic Salmon Commission).  Bridges was asked, on the record, about the specific goals of the program:

“The program was designed to establish a run of a million American shad at the river’s mouth and extend their range to historic spawning and nursery grounds near Bellows Falls, Vermont.”

Thirty-seven years later, after Commissioners from four New England States and federally fisheries directors from what is today’s US Fish and Wildlife chose a complex series of Pacific salmon-based fish ladders and the Turners Falls Power Canal as the primary upstream route for migratory fish on the Connecticut, nothing resembling restored fish runs or an ocean-connected ecosystem exists above Turners Falls.

Simply put, those officials chose wrong—and the hangover has impacted this river for decades.

They get just one chance to do it right this time; for all of us.  But again, their silent stance seems to exclude bringing the public in on the process.  No messages or notices on state and federal public websites were posted about site tours and input.  Little or nothing on non-profit, river group sites, either. Once again it’s: “Don’t worry, we’ll take care of this.”  That’s a pretty dangerous position, considering the track record.  State and federal agencies have failed to demand operational changes that should have provided protection of federal-trust American shad, and federally endangered Shortnose sturgeon all these decades.  They have simply kept mum about their little mistake at Turners Falls back in 1975.  It has served no one well, save the power companies.

Dr. Boyd Kynard, an expert on migratory fish behavior and fish passage at large dams who helped established the federal Conte Fish Lab under the US Fish and Wildlife Service in 1990, led studies of the federally endangered Shortnose sturgeon in the Connecticut River at Turners Falls for 17 years.  It’s the fish fisheries officials don’t talk about in public.  Dr. Kynard spent over a decade compiling his work and that of nearly a dozen co-authoring scientists into a book entitled Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Conservation Society in Germany last February.  Intervention by the US Geological Survey delayed distribution of the book in the US for several months, and it continues to be difficult to purchase.

However, Dr. Kynard, with permission from the World Sturgeon Conservation Society, released a chapter of the book to me for citation while it was “in-press” back in August of 2011.  Since so few members of the public will get a chance to visit these sites, and since the book is currently only easily available through its chief author, Boyd Kynard, (contact Dr. Boyd Kynard at BK Riverfish, LLC, kynard@eco.umass.edu), I’m printing the abstract from the chapter on spawning and the effects of power company regulation of downstream flows at Turners Falls Dam.  The chapter’s science was done at the federal Conte Lab using funds from UMass, along with federal funding from US Fish & Wildlife Service and USGS.  Kynard’s co-author on this chapter is Micah Keiffer.  Note that the “Rock Dam” is not a conventional dam, but an ancient stone formation in the riverbed, creating a natural spawning pool that Shortnose sturgeon have used for centuries.

Abstract: “During 17 years, we studied the spring spawning migration and spawning of adult Shortnose Sturgeon Acipenser brevirostrum in the Connecticut River, Massachusetts.  Increasing day length (13.4−14.2 h), not increasing temperature (7.0–9.7°C) or river flow during 13 April–2 May likely triggered pre-and non-spawning adults to leave wintering areas and migrate.  Females initiated pre-spawning migration later than males, during lower flows and higher water temperatures, a strategy that conserved energy after wintering.  The pre-spawning migration failed one year (2002), an event probably related to reduced energetic resources of wintering fish caused by high temperatures and low flows during the previous summer foraging and wintering periods.  Pre-spawning adults homed each year to the same 1.4-kilometer-long spawning reach at Montague, Massachusetts, where river current likely determined where spawning occurred: either the Cabot Hydroelectric Station tailrace (area, 2.7 ha) or the Rock Dam, a natural mainstem fast run (area, 0.4 ha).  Spawning occurred when three spawning suitability windows were simultaneously open: (1) day length = 13.9−14.9 h (27 April–22 May), (2) mean daily water temperature = 6.5–15.9°C, and (3) mean daily river discharge = 121–901 m3s-1.  Annual spawning periods were short (3–17 d), which may be typical when only a few females are present.  Spawning periodicity was 1–5 years (mean 1.4 years) for males and 2−10 years (mean 4.5 years) for females.  Peaking operations at Cabot Station did not prevent females from spawning in the tailrace, but likely displaced and stranded early life stages.  During 14 years, spawning at Cabot Station succeeded 10 years and failed 4 years (28.6% failure); while spawning at Rock Dam succeeded 3 years and failed 11 years (78.6% failure).  Spawning failures at Rock Dam were due to river regulation.  Females spawned in a wide range of water velocities (0.2−1.3 m/s); however, the flow regimes created by river regulation and peaking operations exceeded even their broad adaptation for acceptable water velocities.”

* It should also be noted here that not a single representative from the National Marine Fisheries Service the agency federally mandated by Congress to protect the shortnose sturgeon, signed up to tour FirstLight’s power facilities.

 

A Failure to Protect

Posted by on 02 Aug 2012 | Tagged as: American shad, Bellows Falls Fishway, Connecticut River, Connecticut River ecosystem, Conservation Law Foundation, Conte, endangerd shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, National Marine Fisheries Service, NOAA, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey, US Geological Survey's Conte Fish Lab, USFWS

Copyright © 2012, by Karl Meyer      All Rights Reserved

The following essay appeared in July in the Vermont Digger (www.vtdigger.org); the Rutland Herald (www.rutlandherald.com), and other Valley venues.

A Failure to Protect

This Valley lost a lion of environmental defense when former Conservation Law Foundation Attorney and Antioch University Professor Alexandra Dawson of Hadley, MA died last December.  Quietly today, time grows desperately short for the ecosystem’s only federally-endangered migratory fish–the Connecticut River Shortnose sturgeon.  Alive since the dinosaurs, they arrived shortly after the glaciers left.  They are clinging to life by a thread–with perhaps 300 attempting to spawn annually in miserable conditions created in the 2-mile stretch of river below Turners Falls Dam.  NOAA’s National Marine Fisheries Service is responsible for protecting them; NMFS has known fully of those conditions since 2004.

FirstLight-GDF-Suez creates those conditions, right next to the US Fish & Wildlife’s Great Falls Discovery Center.  Yet the public is taught nothing of them.  Abandoned by federal agencies, the Shortnose is one industrial disaster or spill from extinction.  Your grandkids wouldn’t have been interested anyway…

But just in case, describe something that was a cross between a dinosaur, a catfish, and a shark.  At 3 – 4 feet long, Shortnose have bony plates instead of scales, with shark-like tails at one end, and suctioning, toothless mouths below cat-like feelers at the other.  They scarf down freshwater mussels whole; then grind them up in gizzards.  Shortnoses can live over 40 years: one alive today might’ve witnessed Richard Nixon signing the Endangered Species Act in 1973.  They had other priorities though, like survival.  But for how much longer?

Conditions most-imperiling the Shortnose are overwhelmingly the result of FirstLight-GDF-Suez’s floodgate manipulations and punishing water pulses sent to the riverbed and coursing down their two-mile long Turners Falls Power Canal via their dam, and operations at their giant 1,080 megawatt (now 1102 MW) Northfield Mountain Pumped Storage Station upstream.  Below the dam you won’t find anything like a river.  For a fish its manipulated chaos–a feast or famine flow regime run largely to maximize the day-trader profit margins of today’s deregulated energy spot-market.  And things may have just gotten worse.

FirstLight’s pumping and dam operations are the biggest disruptor to this ecosystem for a 7 mile stretch–affecting migratory fish restoration failures upstream to Bellows Falls, VT, and down to the Sound.  Instead of shad and other migrants moving up natural river habitat to the dam, they are funneled into a deathtrap: the turbine-riddled bottleneck of the Turners Falls Power Canal.  Barely one shad in ten emerges upstream alive–while crowded-in fish turning back out of that canal are diced-up in its blades.  US Conte Fish Lab researchers dubbed last year’s power canal shad passage a “success.”  FirstLight helped fund their study.  The dismal 16,000 shad they tallied mirrored “success” from 1987, a quarter century back.

And, if you are a spawning-age Shortnose wholly-dependent on spring riverbed flows resembling a natural system below that dam: you’re out of luck.  Annually, attempts at spawning fail in an ancient pool near Conte Lab.  Or, as conditions deteriorate, they default downstream to try spawning below the canal’s outflow.  Here again reproductive failure is common.  Dam-deflected surges deluge their gatherings; or flows get cut-off in minutes, causing mating-stage fish to abandon spawning.  Even when eggs get fertilized, embryos get silted-over or washed away by floodgate surges–or left to die on de-pauperized banks when flow is cut.  Most years no young are produced.  That’s extinction’s fast-track.

FirstLight’s Northfield Mountain offers tours of its 2 megawatt solar installation, but none to its reservoir and pumped-storage plant where, during fish migration in 2010, they dumped 45,000 cubic square yards of sludge directly in the river over 92 days.  This winter they quietly added 22 megawatts to those giant turbines: more than half all the power generated by HG&E’s Holyoke Dam.  This occurred despite their failure last July to have an EPA-mandated plan in place to prevent “polluting the navigable waters of the United States” with a mountain of pumped-storage silt.  Where are the public Federal Energy Regulatory Commission hearings on this license change?  Where is the Environmental Impact Assessment for endangered Shortnose sturgeon?

Northfield, dependent on nuclear power to pump its water, opened in 1970.  Its legally-stated purpose was as a “reserve” power source—to operate a few hours mornings and afternoons during peak energy use.  It can generate just 8-1/2 hours; then its reserve is depleted. Originally it was proposed they’d shut during fish migration.  Today, wildly outside its stated intent, those giant pumps are switched on like a coin-op laundry–day, night, with turnaround intervals of as little as 15 minutes.

Time is running out for the Shortnose; corporate fines for harming one start at $200,000. Our region’s electric capacity now exceeds 15% of demand.  Except for emergency power grid situations, why is this plant allowed to cripple an ecosystem?  Alexandra Dawson would surely cheer if her old Conservation Law colleagues sued National Marine Fisheries Service: for failure to protect a New England biological gem.

Environmental journalist Karl Meyer writes about the Connecticut River from Greenfield, MA and holds an MS in Environmental Science from Antioch University.

THE “BIG GAME” PROSECUTION of RYAN MCCULLOUGH: another red herring in a failing Connecticut River restoration

Posted by on 19 Jan 2012 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Conte, CRASC, Dead Reach, didymo, endangerd shortnose sturgeon, Endangered Species Act, ESA, federal trust fish, FERC license, FirstLight, Northfield Mountain Pumped Storage Reservoir, Pioneer Valley News, Rock Dam, salmon, salmon hatchery, shad, shortnose sturgeon, The Pioneer, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Walpole

© Copyright 2012 by Karl Meyer    All Rights Reserved

The “big game” prosecution of Ryan McCulough: another red herring in a failing Connecticut River restoration

(NOTE: the following article first appeared in The Pioneer, January 5, 2012, available now on free newsstands from Springfield, MA to Bellows Falls, VT.   Find it online at: www.pioneervalleynews.com )

Legend has it a reporter once asked career criminal Willy Sutton, aka Slick Willie, to explain his long history of thefts, “Willy, why do you rob banks?”  Sutton, a master of disguise, purportedly answered in terms as honest as a crisp January day: “Because that’s where the money is.”

At criminal proceedings in a jtrial scheduled for January 12, 2012 in State Superior Court at Windsor, VT, accused Atlantic salmon poacher Ryan McCullough will likely be asked why he was fishing downstream of the US Fish & Wildlife Service’s White River National Fish Hatchery(WRNFH) last July 25th.  With the Connecticut River and a failed migratory fish restoration looming as backdrop, I’m hoping McCullough replies with a similar bit of direct irony: “Because that’s where they make the fish.”

Last August a hatchery-bred Atlantic salmon created in controlled environs at the White River hatchery in Bethel, VT, was traced via a receiver to a radio-tag blipping away in the freezer of a nearby home.  That tag, hidden inside a 31-inch, 9-1/2 lb. salmon, landed the 22 year-old fisherman in hot water.  McCullough, an aspiring fishing guide, contended he mistook the fish for a huge brown trout.  He’s now charged with taking a “big game species” under Vermont fish and wildlife statutes.  Conviction carries a $1,500 fine and a possible 3-year suspension of his hunting and fishing license.

That big game fish McCullough caught was not even remotely connected to a healthy river system.  It was homing back from the sea to an artificial environment only a factory fish would recognize as habitat—the climate-controlled conduits of WRNFH.  That aqua-culture facility is part of a 19th century industrial idea: factory production substituted for a working ecosystem under the 44-year old banner of the Connecticut River Atlantic Salmon Commission (CRACS)’s Connecticut River migratory fish “restoration.”

The fly-fishing community was abuzz about this incident.  Yet the only “wild” thing about that salmon was its public perception.  It had been conceived at the hands of humans.  The egg and milt (sperm) that spawned it had been matched up by computer models, those genetic fluids were mingled together in plastic tubs, swirled by human hands.  In that immaculately-sterile conception a tiny fish was produced—one of ten million “fry” that were later flushed into Connecticut River tributaries to swim to the ocean.  Every tiny fish produced and released that year along with the one McCullough was to catch two years later was at least two generations removed from any salmon that had ever tasted the salt sea.

In the months just prior to McCullough’s apprehension fisheries personnel at the Holyoke, MA, fish lift on the Connecticut had intercepted the entire spring salmon “run” from the decades-old, half-billion-dollar-plus effort—still politely referred to as a “restoration.”  They trapped all 107 returning fish.  Of those, all but nine were put in trucks and rushed to sterile, hatchery-lab settings where they were weighed, genetically profiled, vaccinated, quarantined, had their fins clipped, and tissue samples taken.  All would ultimately be needed as breeding “stock” for next years dump of millions of “state-farmed” salmon babies into Connecticut River tributaries.

However, ensuing developments at White River will make it interesting to see if Vermont Fish & Wildlife continues in its attempt to make an example of Ryan McCullough.  Tragically and ironically, WRNFH was all but washed away by Tropical Storm Irene just weeks after he was brought up on poaching charges.  A storm surge of White River water entered pools, conduits, wells and buildings throughout the facility—overwhelming well-water fed fish ponds and carrying in the seeds of didymo, aka Rock Snot.  Didymo is an easily-spread invasive alga that was discovered upstream of the hatchery 3 years back.  It smothers river bottom habitats.

Suddenly, tiny salmon fry and over a half-million surviving hatchery fish had become potential carriers of a Rock Snot plague–if they were to be spread in the annual truck-and-dispersal system into Connecticut tributaries and the lakes and streams of four New England states.  Annual production costs alone for five salmon hatcheries around New England can reach a million bucks per facility.  Mistakes and the necessity for new “bio-security” protocols and upgrades repeatedly send costs skyrocketing.  And, after 44 years of trying to create a new strain of cold-loving salmon on the southern-most river it ever colonized, the number of hybrid salmon returning to a warming Connecticut River averages between 40 -100 fish.

A quick damage estimate by USFWS for White River was put at between $10 – 14 million.  But the hatchery would have to be “depopulated;” then sterilized, before any rebuilding could start.  They’d likely have to kill and landfill half a million fish, including hatchery trout and salmon.  Desperate to put a good spin on this second million-dollar disaster at WRNFH in 3 years, USFWS and CRASC scrambled to find a feel-good PR angle.

Ultimately they “reached out” to federally-recognized Native American tribes, inquiring if they would like a “gift” of expensive hatchery salmon—some 8,000 of the table-sized fish were still swimming on site.  Some tribes immediately accepted.  CRASC convened quickly to take a unanimous vote legalizing the “donation.”  They then began killing, gutted and icing the largest salmon, happy to pass them along to indigenous peoples of the Northeast.  Within hours of that vote, CRASC’s feel-good ‘fish-to-the-Indians’ story hit the media via the Associated Press.

Ironically, the 600 largest of those choice “gift” salmon were near replicas–in size and weight (30 inches, 9 lbs), to the fish Ryan McCullough sits accused of poaching months earlier.  But at this point it appears the angler can mount a pretty decent defense.  Back in July he’d actually let a local paper photograph him holding his prize “brown trout” prior to placing it in that freezer.  Though the photo showed a fish appearing to have the slightly hooked lower jaw of a “cock” salmon–that PR move would have been a hugely naïve bit of bravado, something a knowing, and aspiring, fishing guide would never do.  His supporters, including fish and game people, contend he simply may have made a rookie mistake.

Curiously, if he’d purchased a MA fishing license and landed a tagged salmon there, the Bay State penalty would have been akin to a parking ticket: $50 – $100.  Why??  MA doesn’t have a hard classification for exactly what these hybrid fish are.  They aren’t considered a native Connecticut River migratory fish in MA, where the Connecticut’s minor salmon strain has also been extinct for over 200 years.  This is also likely the reason there isn’t a federal prosecution looming for McCullough.  Connecticut River Atlantic salmon are officially classified as “extirpated” by the US Fish & Wildlife Service.  To prosecute him they’d have to hold a monkey trial with a hybrid fish at its center, a spectacle Darwin himself would shake his head at. Considering the fish give-away status at the WRNFH–and the endlessly-failed Connecticut River salmon restoration program, Vermont is going to look foolish if they don’t let young Ryan McCullough off the hook.

But the Green Mountain State has long had a blind spot about all other native migratory fish on the Connecticut save for extinct salmon.  Fisheries officials there long-ago staked Vermont’s idea of pristine environments and elite sport fishing on the creation of a new salmon strain to replace one not seen since 1809.  Decades later, Vermont anglers, as well as those just across the river in New Hampshire, are left without a nifty shad run anglers could be tapping into all the way to Bellows Falls and Walpole.  They get no fish at all, save spawned-out hatchery lunkers dumped into local lakes as salmon program PR (*USFWS Region 5 put out an official advisory on consuming hatchery salmon way back in 2004).  Meanwhile, their rivers and tributaries face the ongoing specter of new and potentially-catastrophic emerging fish diseases being spread through hatchery operations in a time of warming climates.

The full ironies of last summer’s comedy of errors become even more apparent looking just south of the Vermont/New Hampshire border to the federal Conte Fish Lab where CRASC meetings are held beside the dead stretch of Connecticut River in Turners Falls, MA.  CRASC and USFWS are responsible for all the “federal trust” migratory fish on the Connecticut including blueback herring, American shad, and federally endangered shortnose sturgeon.  Yet there, state and federal fish guardians continue to ignore the river’s most-critical 2-1/2 mile chasm—one that’s been key to migratory fish restoration to Vermont and New Hampshire for decades.

Thirty years ago VT and NH should’ve begun crying foul due to the lack of accommodating flows and a fish elevator (still yet to be built) directly upstream at Turners Falls dam.  Implementing those proven remedies–required under federal and state license regulations for migratory fish to reach upstream waters, would long ago have revived those “dead reach” flows during spawning season—concurrently providing easy upstream passage for very fishable runs of American shad all the way to Walpole, NH and Bellows Falls, VT.  Today, the Connecticut’s federal trust run of American shad expires in the dead reach below Turners Falls dam, deflected into the treacherous environs of a power canal.  For decades now VT and NH anglers have been denied fishing for what would’ve amounted to millions of 3 – 6 lb. shad, a tasty catch that makes for excellent fishing in anyone’s book.

Today, funded in part by FirstLight-GDF-Suez, (the global power company manipulating pulses sent downriver from their Northfield Mountain Pumped Storage Station, and flows diverted into their Turners Falls Power Canal) USFWS, CRASC, and federal Conte lab researchers continue ignoring the devastation to migrating and spawning river fish from company flow regimes.  In deference to FirstLight’s preferences, annual agency studies continue emphasizing sending migrating fish into miserable habitats, cross currents, and slicing turbines of the Turners Falls Power Canal.  Meanwhile, virtually next door to the federal Conte Fish Lab, federal trust American shad runs and whole season’s production of eggs and young from the river’s only spawning population of federally-endangered shortnose whither in a dying reach of river annually.

Perhaps most shameful of all is that there is virtually no federal enforcement or prosecution for the year-in, year-out, damage to those federally endangered sturgeon.  US Endangered Species Act protections are wholly ignored for this population, which measures only in the hundreds.  The beleaguered two-mile reach behind the federal Conte Lab has served as their historic mating ground for untold centuries.

Annually, successful shortnose sturgeon spawning in this reach occurs less than half of the time.  Much of the loss is preventable, and could be stemmed in large part by enforcing environmental statutes that would quell the punishing effects of the water pulses and parching trickles sent downstream by Northfield Mountain/Turners Falls dam operators toward an ancient, low escarpment in the river known as the Rock Dam.  Shortnose sturgeon have spawned at this site since before well before Columbus sailed.

More losses arise from the company’s spawning-season water diversions into—and out of, the Turner Falls Power Canal.  That flow can be, alternately, either so strong, or so halting, that it can stop an entire season’s worth of sturgeon mating dead in its tracks.  Or, those same vacillating pulses will either wash downstream, or strand, a season’s worth of tiny sturgeon embryos–leaving them to decay beneath the silt, or desiccate on barren riverbanks.  Either way, a year’s worth of endangered shortnose sturgeon production regularly gets sideswiped to oblivion.

The penalty to an individual for catching, killing or interfering with a federally endangered shortnose sturgeon is up to a year in jail, and a $100,000 dollar fine per instance.  That penalty is increased to $200,000 for corporations, which seems a bit out of balance.  Right at Turners Falls–adjacent to the US Geological Service’s Silvio O. Conte Anadromous Fish Lab and just downstream from the US Fish & Wildlife Service’s Great Falls Discovery Center, there is documented evidence of annual damage to the Connecticut River’s only spawning population of endangered shortnose sturgeon, yet here no one is being dragged into court…

At the November 10, 2011 CRASC meeting in Turners Falls, USFWS’s Connecticut River Coordinator Ken Sprankle announced the outlines and some preliminary observations from a multi-year American shad migration study he’s begun.  With assistance, Sprankle caught and radio-tagged over a hundred shad, some at the mouth of the Connecticut, some at the Holyoke fish lift.  This allowed him to track their movements via receivers placed along the river as they made their upstream runs.  Partly funded by FirstLight Power, federal Conte Lab researcher Dr. Ted Castro-Santos partnered on the Sprankle study.  Castro-Santos was the point person responsible for siting receivers along the river from downstream of the Turners Falls Power Canal up to the Vernon dam in Vermont.

Sprankle termed the undertaking a “whole river study for shad,” one that would help in understanding how they use the river in migration.  He further noted that Dr. Castro-Santos had placed radio receivers throughout FirstLight’s Turners Falls Power Canal.  At that point I asked how many receivers had been set up in the “actual river bed”—referring to the Connecticut’s embattled, 2-mile “dead reach” just beyond Conte Labs west windows.  As expected, he answered that none were in place to monitor that section or river.  It’s remains the river’s missing link.

Thus, from the foot of the Turners Falls canal to the base of Turners Falls dam, Sprankle and Castro-Santos will have no data on shad movement in a critical river reach.  I pointed out to Sprankle that the undertaking could not then be considered a bona fide “whole river study for shad.”  This is decidedly a broken river study—missing the miles of streambed where a river’s ocean-connected ecosystem dies.  I further observed that the section Castro-Santos has chosen to monitor promotes a power “canal restoration”—a configuration that has failed for the past 40 years, and one that let’s the power company wholly off the hook in terms of sustainable flows for federally-endangered shortnose sturgeon and working, direct, upstream fish passage for federal trust American shad.

Ryan McCullough is scheduled to appear on Thursday, January 12, 2011, in Room 1 of Vermont Superior Court in Windsor at 9:00 a.m.  He is pleading not guilty to the charge of knowingly taking a “big game species” and has chosen to be tried by jury, represented by attorny Jordanna Levine.

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