FERC licensing process

Archived Posts from this Category

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 secret licensing talks: CITIZENS GOING ON THE RECORD FOR A RAVAGED ECOSYSTEM’S FUTURE

Posted by on 13 Dec 2021 | Tagged as: Connecticut River, Connecticut River ecosystem, E-Comments, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, Greenfield Recorder, Julie Crocker, MA Division of Fish and Wildlife, Massachusetts DEP, Mr. Jesse Leddick, Mr. Mark S. Tisa, National Marine Fisheries Service, net-loss power, NOAA Fisheries Regional Administrator, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Relicensing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Steven Mattocks, US Fish & Wildlife Service, USFWS, Wendi Weber

CONNECTICUT RIVER FINAL SECRET RELICENSING MEETINGS:CITIZENS GOING ON THE RECORD FOR A RAVAGED ECOSYSTEM’S FUTURE

Photo Copyright © 2021 by Karl Meyer

As the closed-door “final” bargaining between FirstLight and government agencies continues this month, more people are going on the record against a new half century of massive annual fish kills, gluttonous power consumption, and rampant ecosystem disruption at the Northfield Mountain Pumped Storage Station. Read further below for new citizen FERC filings and Letters to the Editor highlighting their opposition to issuing a new license for this deadly cash cow.

MA Fish & Wildlife:

HAPPY to manufacture hatchery fish; WRETCHED at protecting the Connecticut River’s ancient migratory fish runs. Photo Copyright © 2021 by Karl Meyer

THERE IS STILL TIME TO GO ON THE RECORD with others who are standing up for a living river!!!

Do you have children, or grandchildren? Or maybe you just understand that licensing a foreign-owned venture capital firm to have virtual control over 23 miles of the Connecticut River for the next 50 years closes off any hint of a participatory democracy for the future generations that will rely on this ecosystem to sustain them. They are looking to us for protection…

The secret dealings with our participating public trust agencies including MA Division of Fisheries & Wildlife, US Fish & Wildlife Service and the MA Department of Environmental Protection are yet to be signed or sanctioned. The agencies will be passing proposals and juicy cash baits incentives back and forth through the end of the month… What’s your price for an ecosystem?

Photo Copyright © 2021 by Karl Meyer

Sending message to FERC, and the media, and your public representatives and agency leaders is the participatory democracy antidote to all the darkness. It takes just a few paragraphs and sends the critical message to leaders: you don’t get to sell off our River’s future. Stand up, stand out, and be heard. HERE’S HOW:

Simply write your remarks in a short document, and include the key FERC project number for Northfield Mountain: P-2485. You can send that letter to your representatives, agency leaders, the media—and lastly, importantly, to FERC to be entered into the public record. 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 go to eComment on the page that opens. Follow the directions for Hydroelectric License/Re-license Proceedings (P – Project Number), use P-2485, and you are part of the public record.

Below are two recent on-the-record entries, to FERC, and the Greenfield Recorder.

Photo Copyright © 2021 by Karl Meyer

Document Accession #: 20211213-5000 Filed Date: 12/13/2021

David B. Keith, Deerfield, MA.
Our local newspaper, The Greenfield Recorder, reported (12/8/21) that a company had agreed to a $1.5 million settlement for a chemical spill leading to the deaths of more than 270,000 fish in a tributary to the Deerfield River, itself a tributary to the Connecticut River.

I am encouraged to see a value put on the fish in the tributary. I cannot, however, understand why one company is (quite rightly) being punished for killing fish in a tributary while another, FirstLight Utilities through its Northfield Mountain Pumped Hydro Storage facility, stands to be very handsomely rewarded for knowingly and persistently grinding up countless fish, including rare species, from the much larger Connecticut River. Please do not grant FirstLight Hydro Generating Company a fifty-year license to deprive us daily of a resource that was just valued at $1.5 million per incident.

And this:

I strongly urge rejection of the application by FirstLight MA Hydro LLC to operate Northfield Mountain Pumped Storage on the Connecticut River in Massachusetts. The pumping station causes an untold number of deaths to aquatic life in the river and extreme disruption of the the river’s natural flow. The natural flows necessary for the life cycles of vertebrates and invertebrates are utterly disrupted, fish and other life forms are shredded going up through the pumps, the flow of the river is reversed during pumping and shallow areas and banks are washed out and eroded as water is later released. No realistic way of preventing this death and disruption exists, even if FirstLight intended to attempt such safeguards.

Firstlight has proven to be a bad neighbor with regard to these abuses and has a record for making false statements with regard to their operation. Furthermore, Northfield Mountain Pumped Storage uses more energy than it creates with its turbines, something that makes no sense in this time of Climate Crisis when energy must be both conserved and non harmful. FirstLight’s license for further operation must be rejected.

Don Ogden
The Envirom Show
WXOJ/WMCB/WMNB
140 Pine Street
Florence, MA 01062

Police action threatened at US Fish & Wildlife HQ as constituents try to deliver letters

Posted by on 01 Dec 2021 | Tagged as: Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Refuge, Conte National Fish & Wildlife Refuge, FERC licensing process, FirstLight, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, migratory fish, National Marine Fisheries Service, net-loss power, Northfield Mountain Pumped Storage Station, P-2485, Public Sector Pension Investments, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Recorder, US Fish & Wildlife Service, Wendi Weber, WWLP TV Channel 22 News

Police action threatened at US Fish & Wildlife HQ as constituents tried to deliver letters on Tuesday, November 30, 2021

A cold, socially-distanced public welcome at USFWS Headquaters in Hadley for visiting citizens as security guard reaches to phone police. Photo Copyright © 2021 by Karl Meyer

SEE also, this Recorder article by Chris Larabee, here also featured in the Gazette: https://www.gazettenet.com/Two-make-20-mile-hike-to-protest-FirstLight-s-potential-relicensing-43803954

HADLEY MA. A security guard at Hadley’s US Fish and Wildlife Headquarters threatened to call police on Karl Meyer of Greenfield and Dave Dersham of Northampton and a handful of their supporters after completing a 20 mile protest walk to the facility at around 4 pm Tuesday. The two were interviewed by the Recorder and WWLP TV Channel 22 News along the route. Their trek from Greenfield to Hadley was made to call attention to a final, closed-door license “settlement” negotiation scheduled by Canada-owned FirstLight with the US Fish and Wildlife, National Marine Fisheries, and MA Division of Fish and Wildlife for Thursday, December 2nd. FirstLight wants the agencies to sign-off on a final deal in the 9 year-old Federal Energy Regulatory Commission process relicensing the massive suctioning of the Connecticut River at their 49 year old Northfield Mountain Pumped Storage Station.

Banner on federal relicensing of Northfield Mountain displayed at USFWS HQ. Photo Copyright © 2021 by Karl Meyer

The duo and three other citizens including a 14 year-old and an infant, were quickly denied entrance during regular business hours as they attempted to deliver notes and letters to USFWS Regional Director Wendi Weber. A security guard sitting behind a front lobby window tersely told them their letters, in an open manila envelope, would not be accepted at the public HQ. When they made further inquiry the guard became defensive, without offering alternatives, and then escalated the situation by demanding no picture taking was allowed and they leave the lobby or “I will call the police.” Asking why, the guard offered no further discussion, instead repeating the police threat and then dialing a phone where visitors heard her request that Hadley police cruiser be dispatched.

One of the messages constituents wanted to convey to USFWS Director Wendi Weber. Photo Copyright © 2021 by Karl Meyer

At that point the visitors left the lobby with their letters, and continued their discussions in front of the unwelcoming Headquarters building. The group, also supported earlier in the day by a dozen protesters who’d met the two walkers on the Sunderland Bridge, were completing trip by collecting handwritten messages for Weber from the public. All were being sent to highlight the obliteration the 100’s of millions of eggs and young-of-the year migratory and resident fish killed by Northfield giant turbines annually. They are asking USFWS representatives to deny FirstLight’s license proposal of placing a temporary “barrier” net, with ¾ inch mesh, in front of NMPS for a few months each year. They say FL’s “safety net” will be patently ineffectual in preventing the long-standing annual carnage to Connecticut River fish populations in the heart of the ecosystem and S.O. Conte National Fish and Wildlife Refuge.

Supporters standing, post-ejection, in front of USFWS Headquarter. Photo Copyright © 2021 by Karl Meyer

After several more minutes standing in the cold and talking in front of the headquarters Anne Sittauer, a USFWS Refuge Supervisor, was sent outside to speak to the group, now totaling eight. Sittauer stated the Region 5 Director was busy, but she would accept the letters on Weber’s behalf, giving assurances they’d reach her. No squad car ever arrived and no arrests took place among the peaceful visitors, after being threatened, denied entrance and receiving a patently-shabby un welcome at the facility. Surely it was an eye-opening public interaction for the teenager, the grandmother, and the handful of other citizens asking federal representatives to honor their public trust by protecting the public’s fish—fish being annually obliterated for the last 49 years in the heart of today’s S.O. Conte National Fish and Wildlife Refuge—one of only two of 568 national refuge’s with “fish” specifically in its title.

TODAY! Our RIVER, Our REFUGE; OUR FISH! * Last Standout: 10 am, Sunderland Bridge or ** 4 pm US Fish & Wildlife HQ, Hadley

Posted by on 29 Nov 2021 | Tagged as: America's best landscaped sewer, American shad, Connecticut River Refuge, Conte National Fish & Wildlife Refuge, FERC licensing process, FirstLight Power, Greenfield, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Northfield Mountain, Northfield Mountain Pumped Storage Project, P-2485, Public Sector Pension Investments, Rock Dam, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Wendi Weber

TODAY! Our RIVER, Our REFUGE; OUR FISH! * Last Standout: 10 am, Sunderland Bridge, or ** 4 pm, US Fish & Wildlife HQ, Hadley

Dear Friends,

In 1997 our Connecticut River became the backbone and central artery of the S.O. Conte National Fish and Wildlife Refuge—an ecosystem-wide refuge encompassing the entire four-state Connecticut River Watershed. There are 568 national wildlife refuges, but just two specifically name “fish” in the title. One of them is OURS.

This December 2nd Canada-owned FirstLight Power has scheduled a final license “settlement” meeting with the US Fish & Wildlife Service, National Marine Fisheries, MA Division of Fisheries and Wildlife and MA DEP–hoping to sew-up their venture capital interests in our river for decades. Their cash cow is Northfield Mountain Pumped Storage Station—since 1972 the river’s deadliest, net-loss power contraption. This flow-reversing, grid-powered machine inhales miles of living river; then spits it back for profit—with all its fish, insects and aquatic life, dead.

FirstLight’s final license application offer is a death trap. “FirstLight proposes to install a barrier net in front of the Northfield Mountain Project intake/tailrace to prevent the entrainment of migratory fish when the Northfield Mountain Project is pumping. The net will be approximately 30-foot-high by 1050-feet-long wide with 3/4-inch mesh from top to bottom.” That temporary net, August to November, has ¾ inch mesh so large it amounts to a lethal, suctioning doorway for millions of eggs, larvae and baby shad—and, those of 26 other resident and migratory fish.

THERE IS NO REFUGE FOR FISH on the Connecticut River in Massachusetts. There’s only a death trap. So I am asking you to stand–one last time, ahead of FL’s grim, secrecy-filled December 2 meeting, and send a message to the US Fish and Wildlife Service: Our RIVER, Our REFUGE; OUR FISH! I long-ago vowed to bring our River’s relentless pillaging into the open across these last 9 years as a journalist and relicensing stakeholder—and that if there was one more thing to do to rescue this ecosystem for those who come later, I would not let it drop.

On Tuesday morning at 6 am, my dear friend and colleague Dave Dersham and I leave the Greenfield Common on a 20 mile protest walk to USFWS Headquarter in Hadley. We’ll carry fish nets–full of holes, representing FirstLight’s sham safety net. We’l reach Sunderland Bridge at 10 am, and hope you will meet us for a brief rally—with your own full-of-holes safety nets, stockings and signs to send a message to US Fish & Wildlife Regional Director Wendi Weber: Our RIVER, Our REFUGE; OUR FISH! Please bring a note card with a message to Ms. Weber we’ll deliver in writing at around 4 pm at the USFWS Headquarters, 300 Westgate Center Drive, Hadley—just past the Rt. 116/Rt. 9 intersection. If folks met us there, we’d be delighted as well.

Thank you for marching to Northfield Mountain, to ravaged riverbanks where sturgeon can’t spawn, and standing out on the Turners Falls Bridge and Greenfield Common–for the letters to FERC, To the Editor, and the Oped pieces. Tuesday is “Giving Tuesday.” Let’s stand together to offer a real REFUGE to coming generations—and stop FirstLight’s grim license to kill.

Connecticut River relicensing: a history, summary and indictments…

Posted by on 23 Nov 2021 | Tagged as: Connecticut River, Conte National Fish & Wildlife Refuge, Death-Sewer, Federal Energy Regulatory Commission, FERC licensing process, FirstLight Power, Holyoke Co. v Lyman, MA Division of Fish and Wildlife, Massachusetts DEP, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, Public Sector Pension Investments, Relicensing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Treasury Board of Canada, Tyler Poisson, UMass, US Fish & Wildlife Service, USFWS, Will Ryan


CONNECTICUT RIVER RELICENSING: a history, summary and indictments…ahead of the secret final “settlement” talk scheduled for December 2nd by Firstlight–a backroom sausage-making meetup between FirstLight, USFWS, National Marine Fisheries, MA Div. of Fish and Wildlife, and MA DEP. MEETING CONTENTS: no public, no sunlight; nor democracy…

https://www.youtube.com/channel/UCKdIusCr2ysMZTGflFJyHZg/live

ABOVE is the link to a talk I gave on November 21st at the Wilbraham Public Library. It was broadcast live, and with a live audience, as part of the ongoing Root Cause Lecture series exploring Ecologies and Economies. This series is the work of UMass graduate students Will Ryan and Tyler Poisson. Thanks to them both, and the Wilbraham Public Library.

** CAUTION: you might find the information it contains…upsetting!

My Response to FERC respecting FirstLight’s response to the Federal Energy Regulatory Commission’s questions and this relicensing process

Posted by on 23 Jun 2021 | Tagged as: Connecticut River, Federal Energy Regulatory Commission, FERC licensing process, FirstLight, Fish and Aquatics Study Team, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Project, PSP Investments, Rock Dam, US Fish & Wildlife Service, Vermont Fish & Game


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer

NOTE: The four photos above were taken of the Connecticut River’s oozing banks and dewatered cobble shoals at the Rock Dam, the sole documented natural spawning site and nursery of the federally-endangered Connecticut River shortnose sturgeon on June 23, 2021.

The following was submitted to the Federal Energy Regulatory Commission on June 23, 2021.

Karl Meyer
91 Smith St., # 203
Greenfield MA 01301
413-773-0006
Karlmeyer1809@verizon.net June 23, 2021

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
Hydro Licensing

RE: This day’s submission by FirstLight’s Operations Manager Nick Hollister respecting FirstLight MA Hydro LLC, Turners Falls Hydroelectric Project (FERC No. 1889)Northfield Mountain LLC, Northfield Mountain Pumped Storage Project (FERC No. 2485). Response #3 to FERC January 14, 2021 Letter Regarding Additional Information Requests

Dear Ms. Bose,

I write to you requesting a rejection of significant and substantial portions of the Additional Information Request filing made this day to FERC by FirstLight MA Hydro LLC and Northfield Mountain LLC. I have been a participating stakeholder, intervener and member of the Fish and Aquatic Studies Team for these projects, FERC P-1889 and P-2485, since 2012.

On January 14, 2021, FERC required updated information and an answer to the following inquiry:

“To enable staff’s evaluation of effects of the proposed project on fish entrainment at the Northfield Mountain Project, please provide estimated weekly and/or monthly pumping flow volumes for both current and proposed operations in a typical year.”

Simply stated, FirstLight has failed to address or provide any new or useful information in response to the requested NFM-AIR#4. What they have provided is decades-old data from the last century that does not reflect in any meaningful way how NMPS operates today, or how it might operate in any future scenarios.

Page 10 of their written response to FERC’s requirement sums up the uselessness of their outdated submission in bold parameters:

“Table NFM AIR#4-1 provides the average monthly volumetric flow rate of water pumped by Northfield Mountain over the 42-year period of record analyzed (i.e. 1962 – 2003).”

Put simply, Northfield Mountain did not exist in 1962, and did not come on-line until 1972. Therefore, a full 10 years of their purported data is null and void. Parent owner PSP Investments is new to this country and to Massachusetts, however that bit of historic information could have been culled in Wikipedia.

Further, their particular data-set ends in 2003, just three years into the timeframe when NMPS began operating under new and loosened pumping and generating parameters after Massachusetts deregulated their energy markets. It too is information representative of the past century.

Wholly absent is information on the first two decades of the 21st century, the one in which PSP purchased these facilities intending to profit from them for generations to come. What is absolutely needed, in order to make any projections on the scope and impact of pumping and generating operations far into the future, are the figures, charts and data from the year 2000 to the present, 2021.

And, as well, FERC surely understands that there have been policy changes at the Federal Energy Regulatory Commission in the current half-decade that now allow NMPS to operate more frequently and benefit from participation as a merchant supplier in the wholesale energy market. In order to begin to understand and project how these changes have impacted NMPS current operations and how they will impact future river conditions, a full comparison of recent operational changes due to these new FERC loosened parameters with the 5 preceding years should be the minimum of data and information required of FL by FERC.

In a relicensing now entering its 9th year, I find FL’s response to the FERC process to be yet another delay tactic at best, and wholly dismissive of all the state and federal agencies and stakeholders long engaged in this process at worst. It simply does not hold water. Please require an immediate and with-all-haste rewrite and resubmission of answers to these critical questions. Any new license offered should be shortened in relation to the accruing years beyond the expiration of their original license, April 30, 2018.

Sincerely,
Karl Meyer, MS Environmental Science

Cc: Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Kenneth Sprankle, U.S. Fish and Wildlife Service
Michael Pentony, NOAA Fisheries Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA
Daniel McKiernan: Director MA Division of Marine Fisheries
Louis Porter, Commissioner VT Dept. of Fish & Wildlife
Scott R. Decker, Inland Fisheries Division, NH Fish & Game Dept

ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

Posted by on 10 Sep 2020 | Tagged as: American shad, Anadromous Fish Conservation Act, Atlantic salmon, blueback herring, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power Resources, Fish and Aquatics Study Team, GHG, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, right-to-know, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Revelator, The Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

Endgame Looms for England’s Great River Copyright © 2020 by Karl Meyer


The impoverished Connecticut River looking downstream to Turners Falls Dam. The run stops here. Photo Copyright © 2020 by Karl Meyer All Rights Reserved. (CLICK x 3 to enlarge)

NOTE: The following piece first appeared as an Op-Ed in The Revelator, an initiative of the Center for Biological Diversity on August 26, 2020. www.therevelator.org

FURTHER NOTE: * On September 1, 2020, after this piece first appeared, FirstLight petitioned FERC for an open-ended date to extend the filing of their Final License Applications citing a need for new test data to respond to the USF&WS. If FERC agrees, that would add another 4 months and possibly another full year, to this endless process–without any long-awaited relief for a flow starved Connecticut River. It’s time for FERC to wrap this up.

After a half-century of failures, the recovery of the Connecticut River ecosystem hangs in the balance. Will authorities finally act to save it?

Rivers should not die in the dark.

On Aug. 31 FirstLight Power Resources is expected to file its final license applications with the Federal Energy Regulatory Commission to continue operating three hydro facilities profiting off massive water diversions from the Connecticut River in Massachusetts. The conditions written into FERC licenses can last up to 50 years.

These applications signal the beginning of the final chapter in determining the future of the four-state river at the heart of the Silvio O. Conte National Fish and Wildlife Refuge, founded to protect a 7.2-million-acre watershed. Their rendering will decide the future of migratory fish, river flows and a host of embattled ecosystem conditions on New England’s longest river, some running counter to laws in place since 1872.

When decisions affecting a river for decades are being made, the public has a right to know of the stakes, the players and the key decision makers. In this case the public knows little of issues potentially affecting 2.4 million people in a sprawling watershed.

One of the failed fish ladders sending all spring migrants into the Turners Falls power canal maize. Across 45 years just 5 shad in 100 have succeeded in passing the Turners Falls Dam–leaving 50 miles of spawning habitat in 3 states largely empty. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife have been at the table in this FERC license-determining process since 2012. But three years back, all parties signed nondisclosure agreements with FirstLight — ostensibly to facilitate settlement discussions on flows, habitat, dismal fish passage and endless mortality cycles at these Massachusetts hydro sites. Those NDAs have kept these issues largely out of the media, even as initial settlement talks broke off a year and a half ago.

*Since 2012 I’ve been a FERC-recognized intervener in the relicensing process. I chose not to sign the company’s confidentiality agreement in order to preserve the right to address and highlight the critical, long-term decisions being made about the Connecticut River in a process that remains largely out of public view.

FirstLight is part of the giant Canadian investment outfit PSP Investments, which arrived in Massachusetts four years back to buy up these facilities from GDF Suez. In 2018 it quickly reregistered the facilities as limited liability tax shelters in Delaware. Regardless of their state of incorporation, the licenses they now vie for will each be subject to current federal and state environmental laws, under terms mandated by the fish agencies and FERC.

Entranceway to the “Great Falls Discovery Center” where, most days out of the year, there are literally no great falls running here at all… The sprawling rocky riverbed is an emptied bowl. Photo Copyright © 2020 by Karl Meyer.

Of more than 500 U.S. refuges, Conte is one of just three with “fish” in its name. Today hopes for the long-term protections of its fish and the river comprising its central artery rest heavily in the hands of the U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife. They have “conditioning authority” in these relicensings — mandates to protect the life in this river system. FERC, the ultimate relicensing umpire here, is also mandated to ensure compliance with environmental laws. For the fish agencies this is their one chance to redeem some far-reaching mistakes made by their predecessors.

Forty-five years ago these agencies — operating on limited information and pursuing dreams of reprising a salmon not seen on this river since 1809 — signed agreements with different owners of these facilities. That hobbled, for generations, a four-state migratory fisheries restoration for American shad and river herring and a recovery for federally endangered shortnose sturgeon. They sanctioned the daily use of the massive river-reversing pumped storage facility still chewing through generations of migratory and resident fish today. Concurrently they left two miles of the river emptied downstream, its flow diverted into a turbine-lined power canal that all migrants must negotiate in order to access the next 50 miles of open spawning habitat. Just 5 shad in 100 have ever succeeded. Perhaps worse, the river’s only documented natural spawning habitat for the endangered shortnose sturgeon was left without life-sustaining flow.

A Tale of Two Salmon, a River Without Fish

The last wild salmon run on the Connecticut River was recorded in 1809.

Science later revealed the salmons’ end was likely a combination of warming temperatures following the unusually cold period known as the Little Ice Age coupled with modern dam building.

For 165 years there were no salmon. Then, in 1974, a single fish arrived at Holyoke Dam. Far from being a native of the Connecticut River, this was a new hybrid — a returning fish produced at one of several federal hatcheries completed five years prior. This salmon’s genes, like the genes of all the fish that would return in subsequent years, were cobbled together using salmon from several still-surviving runs in northern New England.

This past June 30 marked a different milestone on the river. It ended the first season in 46 years when not a single hatchery-derived Atlantic salmon returned past Massachusetts’ Holyoke Dam.

That unnatural history event passed with little fanfare. Its silent-spring absence marked the end of a half-century-old program that consumed hundreds of millions of dollars and ate up far too much room in a badly broken ecosystem. The U.S. Fish and Wildlife Service abandoned its hatchery program at the end of the 2012 migration season, but across its 43 years — which saw the annual release of millions of fry and smolts to tributaries in Connecticut, Massachusetts, Vermont and New Hampshire — so few adults returned that no one was ever allowed to catch one.

This second salmon ending highlights the fish agencies’ last shot at returning ancient ocean connections to the river’s still-viable, age-old runs of American shad, blueback herring and federally endangered shortnose sturgeon in three states.

All these species have been guaranteed safe passage on U.S. rivers, going back to the landmark Supreme Court decision in Holyoke Company v. Lyman in 1872. That finding centered on the dam in Holyoke, Massachusetts and held that private dam owners operating on U.S. rivers must provide for the free movement, upstream and down, of migratory fish past their facilities.

Looking west across the CT to the Holyoke Dam fish lift complex. Since 1955 it is one of the East Coast’s few fish passage successes. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Its implementation on New England’s river is now 148 years overdue.

A River Run in Reverse

What’s ultimately at issue here is flow.

Having taken a back seat for generations, wild runs of shad, herring and sturgeon remain in desperate need of passage and consistent, exponentially increased river flow in FirstLight’s hydro-complex dominated reach. It’s literally the weight of water that matters most to FirstLight. It’s money in the bank. And where flow diversion is concerned, it’s been pretty much a free ride for companies here for the past 50 years.

The 20 miles of river backed up into Vermont and New Hampshire behind Turners Falls Dam are massively suctioned for hours at up to 15,000 cubic feet per second to fill the 4-billion-gallon reservoir above the Northfield Mountain Pumped Storage Station.

Northfield’s suction is so violent it literally reverses the Connecticut’s current for up to a mile downstream at times, erasing the essence of a living river system. The station kills everything it sucks in, from tiny fish eggs to full-size eels. In pumping mode it suctions the equivalent of 3,600 seven-bedroom mansions, each filled with the aquatic life of a river, vaporized every hour, for hours on end. Agency studies on America shad show tens of millions of eggs and larvae extinguished at Northfield annually, plus the deaths of over 2 million juvenile shad sucked in on migrations back to the sea. Five migrant species are subjected to Northfield. In all 24 species live here, most unstudied.

Warning floats on the CT at the entranceway to Northfield Mountain Pumped Storage Station’s massive subsurface suctioning site. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Northfield’s operations are nothing like classic hydro, operating to produce virgin electricity via a dam in or adjacent to a river. It’s actually an electric appliance, built to take advantage of excess, unused megawatts produced nightly at the nearby Vermont Yankee nuclear station. Northfield burns electricity to pump water from the river a mile uphill to into its reservoir tank, which was created by blasting off the top of a mountain. The company’s original owners would buy up Vermont Yankee’s cheap electricity to power its giant, reversible turbines. Later, during peak energy times, that now-lifeless river water would get sent back through the turbines to generate hours-long pulses of energy at peak market prices.

It’s a buy-low, sell-high operation, still running at the expense of a river system six years after Vermont Yankee shut down.

Idle bulldozers sit in the emptied bed of the giant NMPS reservoir on June 27, 2010–the year they broke their giant appliance by fouling the pumps with muck and silt. Sanctioned by the EPA for a cover-up and massively dumping the muck from their mile-long intake tunnel directly into the river, Northfield didn’t operate for over half a year. Photo Copyright © 2020 by Karl Meyer. All Rights Reserved. (Click x3 to enlarge.)

Northfield is a net-loss energy machine — a giant underground appliance consuming massive amounts of grid electricity, half of it now generated by the climate-scorching natural gas that dominates New England’s power grid today. The station consumes 25% to 33% more juice than the secondhand megawatts it sends back by dumping deadened river water back through its turbines. It and a smaller pumped storage station in Connecticut are responsible for gobbling up 1.4% percent of the region’s energy in order to reproduce the few hours of secondhand juice they regenerate. According to grid operator ISO-New England, they are the only facilities whose operations flush out as negative input in the regional power mix.

Northfield has never generated a single watt of its own electricity. And though it may be fine as blunt instrument for use during the occasional power grid slump or rare emergency blackout, its endless, river-crippling, pump-and-purge cycle of regenerated megawatts is unnecessary for the daily operation of the New England grid. While its owners brag of being able to power a million homes for a few hours, they never mention having already burned through the energy of 1.25 million homes to do so. After its daily flush, Northfield is virtually dead in the water and must begin pulling from the grid and sucking life from the river all over.

Past mistakes not only allowed for this massive upstream disruption, they sanctioned diversion of nearly all flow, as well as all migrating fish, into a downstream power canal that on average just 5% of shad have ever successfully negotiated. That left another two miles of New England’s river dysfunctional, with the company providing just a dribble flow of 400 cubic feet per second in the riverbed in spring, when fish are moving upriver. That riverbed remains emptied of all flow more than half the other days of the year.

The most critical time for sustaining flows and the river’s migrants is April through June, when New England’s energy consumption is at its low annual ebb. But federal and state studies and in-river findings show that spring flows will need to be increased by a factor of 20, supplying 8,000 cfs rather than the current brook-like drizzle of 400 cfs. That’s what it will take to guide shad and blueback herring upstream in the river past Turners Falls Dam. That will also provide this river’s only endangered migrant the consistent flows required to successfully allow the shortnose sturgeon to spawn and ensure its larvae can develop in the cobbles at an ancient river pool in that impoverished reach.

Flow starved Connecticut River at the Rock Dam–critical shortnose sturgeon spawning and rearing site, May 13, 2018. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Back in 1967, when four New England states and these agencies signed the “Statement of Intent for the Cooperative Fishery Restoration Program for the Connecticut River Basin,” they projected some 38,000 salmon would return annually to this four-state ecosystem. For salmon, a pinnacle of sorts was reached in 1981, when 592 were tallied passing Holyoke. But for a hybrid fish whose wild prototype disappeared 160 years prior, it was downhill from there. Most years fewer than 100 salmon returned to the river.

That 1967 agreement also set annual run targets of one million American shad heading upstream, with 850,000 shad passing Turners Falls and 750,000 entering Vermont and New Hampshire habitats above Vernon Dam. The highest shad return saw 720,000 passing Holyoke in 1992. Sadly, they’ve never made it much farther.

The Run Stops in Massachusetts.

Just 36 miles upstream of Holyoke, all semblance of a successful restoration ends when the annual shad run reaches Turners Falls Dam. Of the 537,000 shad that passed Holyoke in 2017, just 48,000 — a mere 9% — squeezed back into the river beyond Turners Falls.

Vernon Dam between Vernon VT and Hinsdale NH, March 2020. Photo Copyright © 2020 by Karl Meyer

The annual inversion at the next upstream dam in Vermont illustrates the perils on this broken river. In 2017 29,000 or 59% of the shad that survived the miseries of Turners Falls were subsequently counted passing Vernon Dam, 20 miles upriver. That inverted interstate ratio has been the case since 1975, with few shad managing to break out beyond the brutal ecosystem conditions in Massachusetts.

Why the Restoration Failed

The current restoration, congressionally authorized in 1967 and still operating today under the moniker of the Connecticut River Atlantic Salmon Commission, made their biggest blunder in 1975 when they signed off on new license requirements for upstream fish passage. They ultimately chose a design based on hydro project fish ladders on Washington State’s giant Columbia River, known for huge Pacific salmon runs. What got built was a three-ladder fish passage that forced all migrants out of their ancient river highway and into the byzantine maze of the company’s power canal, while leaving two miles of riverbed all but emptied of flow.

Scaled down and put in place at Turners Falls, it worked fine for the program’s few successfully returning hybrid salmon but failed immediately for 95% of the hundreds of thousands of migrating shad. No big run has ever passed that site, leaving three states without their promised bounties. Vermont and New Hampshire remain this river’s shad deserts today.

The Prescription

It’s now 2020. At this late date, corporate re-registrations can’t hide what’s legally required and a half-century overdue on New England’s river. The last opportunity to undo those festering mistakes for the Connecticut now rest in the hands of the National Marine Fisheries Service, U.S. Fish and Wildlife Service and Massachusetts Division of Fish and Wildlife. They are the people’s gatekeepers, mandated to guard the public trust — agencies with the authority to change to the generations-old crippling conditions here in Massachusetts.

Across 45 years of tracking fish runs passing upstream at successive dams on the Connecticut, shad counts have averaged 315,369 at Holyoke, 17,579 at Turners Falls, and just 9,299 at the Vernon Dam in Vermont. But recently long-term federal and state studies on passage and juvenile survival for American shad have led to new minimum benchmarks for fish passage at each dam to ensure the long-term survival of the river’s runs.

Using those findings, the Atlantic States Marine Fisheries Commission, National Marine Fisheries Service, U.S. Fish and Wildlife Service and the four states have formally adopted new Connecticut River fish passage goals. They include annual minimums of 687,000 shad passing Holyoke, 297,000 passing Turners Falls, and 227,000 at Vernon Dam annually. Those federal and state targets are now part of the public record in the current FERC relicensings. Their implementation would also ensure the endangered shortnose sturgeon gets the flows needed to begin its recovery here.

It’s time to return flow to the Connecticut River below Turners Falls. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The time has come for facilities operating and profiting off the life of New England’s river to come into compliance with the laws of the land, including the Supreme Court’s 1872 finding in Holyoke Company v. Lyman, the Anadromous Fish Conservation Act of 1965, the Endangered Species Act of 1973 and a host of others. For the fisheries agencies charged with protecting a river’s bounty, standing up for their implementation is the sole prescription for success in a four-state restoration undertaken when back Lyndon Johnson was president.

By law, by right and by the public trust, the Connecticut River’s time has come.

Karl Meyer has been a member of the Fish & Aquatics Studies Team and an intervener in the Federal Energy Regulatory Commission relicensing process for three Massachusetts facilities on the Connecticut River since 2012. He lives in Greenfield, Massachusetts. Meyer is a member of The Society of Environmental Journalists.

* * FINAL NOTE from the author: if all this history is new and troubling to you it must be considered that: this is the only river in the Northeast with several federal designations that has remained the only major waterway without an independent and effective watchdog–one with a full legal team on staff, and a mandate to investigate, enforce, and go to court. The generations-long mistakes and brutal conditions that have existed here would’ve long ago been challenged in court had there been an effective organization protecting the integrity of this river system. If the Connecticut River is to have a future as a living ecosystem, a new model will have to come into being.

Honoring Peskeomscut

Posted by on 18 May 2020 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Deerfield River, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, fish passage, Holyoke Dam, Narragansett, Nipmuck, Norwottuck, Peskeomscut, Pocumtuck, Relicensing, Riverside, sea lamprey, shad, The Dead Reach, Turners Falls dam, Turners Falls Massacre, Uncategorized

THIS GREAT AND BROKEN RIVER IV

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 4: Honoring Peskeomscut


Peskeomscut, Island?
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge; back arrow to return to text)

At a glance, this could be a photo of a quiet pond in New England. It is not. This is the mid-May, midstream view of an island in the Connecticut River, just 250 yards below the Turners Falls Dam in Massachusetts. With a quick look you might be wondering: where’s the river—and, what island?? This is a chasm and landscape robbed of its water, life and dignity. On any mid-spring day for ages past, thousands of American shad would’ve been pulsing through the rolling froth on both sides of what is a now-erased and bereft island. Today, shad here are not even offered a decent puddle to flop in.

Glancing quickly, you might not have made note of an island. But a closer look reveals a small, tree festooned bump in the center-right background. That site was identified by FirstLight Power as PesKeomscut Island in their initial 2012 application for a new federal hydro license to operate Turners Fall Dam—which is just out of view to the right of this photo. Unfortunately, Turners Falls Dam has been the place where New England’s Great River has died for well over two centuries now.

As far as any real river here?—there’s a just-visible bridge in the upper right, beneath which the mouth of the Fall River is adding a little flow and a tiny bit of froth to the barely-running current in the background. What should be the strong, rolling pulse of the spring Connecticut here should to be pushing downstream from left to right across the entire foreground of this photo. Instead, there’s just a stilled pond. And, yes, that island has been virtually erased. To be an island, you must have water.

On this May 14, 2020, FirstLight has subtracted that main ingredient. At mid-afternoon the Connecticut has been turned off in its own 200 million year-old chasm, robbed of all but a riverlet of dribbling flow. They do that most months out of the year. This spring day all but a tiny percentage of its life-giving current is diverted into FL’s adjacent power canal. The Connecticut is broken here at a place once called Peskeomscut–broken since the first dam stretched across this ancient chasm from Turners Falls to Gill in 1798. That began the 2-1/2 mile reach just downstream that robbed the river of life and flow. It gave rise to a landlocked “island” without a watery moat.

Further out and to the left in the photo, two more humans engage in a leisurely stroll over exposed sand—mid-river at mid-spring, padding over a dry shoal that should be teeming with river life at this season. But not here; not in northern Massachusetts. The place is a desert.

Instead of a life-giving, roaring spring cataract–encircling an inaccessible island, just a salutary wash of water is spilling from the dam above. Peskeomscut Island has been reduced to an abandoned, rocky spit in a parching, emptied chasm.

Looking closely, lower left of center you can make out an angler at the quiet, current-less shore. He might as well be on a pond—migrating American shad won’t find an upstream current deep or strong enough to follow their ancient migratory path toward the lost waterfalls here this day. While downstream, Holyoke Dam had reported 10,000 shad passing there through May 8, Turners Falls Dam had a whopping 38 passing here…

Peskeomscut is an approximate spelling of an Algonquian term used to denote the place where an ancient waterfall, cataract and island anchored the landscape. That place, which teemed with life throughout its annual seasonal cycles back into the mists of time, is today robbed of its soul–deprived of dignity. What, in 2020, should be a restored, thriving, May Connecticut River–full of shad, herring, lamprey eels and frothing currents, is today a drying, emptied bed. Its “island” is simply a rocky spit, easily accessible across the barren, bedrock ledge.


Midstream Peskeomscut 1-1-2018 (Click X 3 to enlarge)
Photo Copyright © 2020 by Karl Meyer

There is more than a little irony to this site being referenced today in Massachusetts as Turners Falls or the Great Falls. Any visitor here would more than likely find this curving, ancient chasm hollowed out at nearly any month of the year. There rarely are falls to see here. This is a broken place, a starved place. There is something raw and enduring about the injuries perpetrated here year in and year out. The once abundant life of this place is merely an afterthought here, if considered at all.

From Turners Falls Dam downstream to just above the river’s confluence with the Deerfield River, these 2-1/2 miles of the Connecticut are best described as its “Dead Reach.” There is no river in this stretch, just a parching/choking series of on-off flows that alternately starve and inundate what was once a life-filled artery.

In the spring of 2020, this should not be. It should all be the past history of the Great River. The current 52 year-old Federal Energy Regulatory Commission license to operate Turners Falls Dam expired in 2018. But FERC has allowed repeated extensions of that license, in a so-called “5-year” relicensing process that began in 2012. This stilted, corporate-skewed federal process has seen virtually no forward movement for over a year–and will soon be celebrating its 8th birthday. That stale status quo seems to suit FERC and FirstLight–as well as their shareholders, quite nicely. It’s just another abuse in the ongoing nightmare for the central artery of Western New England’s largest ecosystem.

On May 19, 2004, I witnessed a reconciliation ceremony at a park in Montague adjacent to the Connecticut, just above Turners Falls Dam. Local officials, citizens, and representatives from several of the region’s Native American tribes were present. All were there to honor, and attempt to heal the lingering injuries and moldering legacy of a grim injustice committed here in the pre-dawn dark on the morning of May 19, 1676.


Turners Falls Dam and Riverside Massacre Site
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge, back arrow to return to text)

Just across the river in the Riverside flats of Gill, 160 colonial troops swept down a hillside, firing muskets and stabbing bayonets into the tents of sleeping elders, women, and children of the Narragansett, Nipmuck and Pocumtuck and other peoples—encamped there in a hungry and desperate attempt to harvest fish and plant sustaining corn in their ongoing attempt to defend and keep the territories of their ancient homelands. For the colonists, it was a grim and successful slaughter of hundreds of defenseless Indians. For the indigenous tribes, though their surprise counter attack quickly sent the blood-bathed attackers into a chaotic, F-Troop rout, the loss of life ultimately proved a spirit and soul crushing disaster.

On this May 19th, 2020, much of the signaled healing and reconciliation of 16 years back seems to remain orphaned on the 344th anniversary of the Turners Falls Massacre. The wounds of that day are yet present. And, the later and ongoing theft of a river’s life-giving current–begun with that 1798 dam, still remains in place. The Connecticut here is–most days, an emptied and soulless place. It is long past time for the life and lives lost at Peskeomscut–and some of what is still missing as well, to see the beginning of a long overdue restoration. The river belongs to the people. Some of that healing must begin with water. Water is where life begins…

Precise, Repeatable Flow Measurements Required in FERC Licensing Studies

Posted by on 19 Apr 2019 | Tagged as: 5-year FERC licensing process, American shad, bascule gates, By Pass Reach, Connecticut River, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, Northfield Mountain Pumped Storage Project, repeatable metric, Revised Study Plan, Secretary Kimberly Bose, staff gauges, Station 1, Turners Falls, Turners Falls dam


Turners Falls Dam with Spill on the Right Emanating from Two Bascule Gates. Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. CLICK, then CLICK again.

(NOTE: the following Stakeholder Comments were accepted by the Federal Energy Regulatory Commission on April 18, 2019)

Karl Meyer, M.S. Environmental Science
Greenfield, MA, 01301 April 18,2019

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

RE: P-1889 and P-2485, Stakeholder Comments on Study 3.3.19, Evaluate Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding the Cabot Tailrace; and the Study Addendum Plan to extend the results of 3.3.19, presented by FirstLight at the March 29, 2019 meeting at Northfield.

Dear Secretary Bose,

I have been a participating Stakeholder in the FERC ILP relicensing proceedings for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both projects and have been in attendance with fellow Stakeholders at all relevant FERC ILP meetings and consultations since that time.

On March 29, 2019, FirstLight held a meeting with federal and state agencies and stakeholders to present their Study Plan Addendum to continue investigations under Study 3.3.19. The new 2019 Study treatments will again involve manipulating flows from the Turners Falls Dam and Station 1 to understand the necessary conditions for bringing American shad through the By Pass and up to the TF Dam.

Need: the need for 3.3.19 has already been demonstrated; and the necessity of gaining further information has become obvious—results have shown that shad move through the By Pass directly to the dam when signaling flows are present. Thus, FL intends to do a new series of test flows through the By Pass Reach beginning in May, involving various flow treatments implemented at the TF Dam bascule gates, and through Station 1.

Need for Additional Information: any Study that informs decisions on License Conditions needs to be repeatable, with parameters that are verifiable. During the March 29, 2019 meeting FL Manager Doug Bennett stated that gauging flow releases at Turners Falls Dam was rather imprecise, involving guesswork and incremental, 1-foot adjustments to the Bascule Gates at TF Dam. This situation adds too much imprecision to a study meant to lead to repeatable flow conditions and an understanding of how shad respond to stepped flows.

Further Information Needed: Without precision or benchmarks to accurately gauge the flows entering the By Pass, it will be impossible to understand the precise settings impacting the movements of shad toward TF Dam as releases are made at the Bascules and through the Station 1 Canal Extension.

Recommendation: The need for an accurate and repeatable metric for testing and implementing flow conditions is obvious. It is a necessity for the future judicious sharing of water through these Projects.

This demonstrated necessity can be accomplished quickly, simply, elegantly, and with little expense for Study 3.3.19, with the installation of Staff Gauges at Turners Falls Dam and
Station 1.

At Turners Falls Dam, Staff Gauges can be braced and installed on the Support Stays between Bascule 1 and Bascule 2, extending upward from the base of the dam. A gauge will also be needed on the upstream side of the dam. There may yet be a gauge near the Old Red Bridge abutment just upstream of TF Dam, but this may need updating or replacement.

At Station 1, Staff Gauges can be installed at the outflow tunnels, and a gauge just inside the Station 1 Canal Extension at the defunct rail crossing would be sufficient.

(NOTE: if spring conditions do not allow for installation of hardware or permanent staff gauges for the upcoming study, painted benchmarks can easily suffice for this season in order to gain the required information.)

Thank you.

Sincerely,
Karl Meyer, M.S.

Next Page »