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REIMAGINING A RIVER, Part 2: Not Nearly Hydro Power; Not Renewable Energy

Posted by on 17 Jun 2020 | Tagged as: American shad, B. D. Taubert, Clean Water Act, climate-destroying, Connecticut River, Connecticut River Conservancy, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Environmental Protection Agency, EPA, Federal Energy Regulatory Commission, FERC, FirstLight, Fracked Gas, GHG, Hudson Riverkeeper, ISO New England, ISO-NEW ENGLAND, Mike Dadswell, Natural Gas, Nepool, Nepool, Phil Glick, Sam Lovejoy, Turners Falls dam, Turners Falls power canal, Uncategorized, Waterkeeper Alliance

THIS GREAT AND BROKEN RIVER VII

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 7, Part 2, REIMAGINING A RIVER: Not Nearly Hydro Power; Not Renewable Energy, Northfield Mountain’s Transition from Nuclear-fueled Net-loss Energy to Natural and Fracked Gas Net-loss Energy.

Author’s Notes: It is impossible to write at this time without mentioning the obvious. The country is in a moral crisis right now and it is time to stand up for the rights of Black people, and for the survival–and revival, of our democracy. This is a precious opportunity, one that we squander at our peril.

In the river-keeping world, there is also an opportunity for change that must be grasped now. The relicensing of MA CT River hydro and pumped storage projects is quietly moving toward its end game. A new model for protecting the ecosystem for coming generations is imperative. These licenses will govern conditions on the mainstem river for decades to come, and there is not a credible organization on the ground here that’s up to the task. The link below was forwarded to me. This is what’s called for. It will take hard work, money, and organizing. I hope there are those out there ready to contribute for the love of New England’s Great River.

https://waterkeeper.org/news/waterkeeper-alliance-to-appear-in-the-visionaries-series-on-pbs/


9-6-2010: Northfield Mountain Pumped Storage Station under EPA Sanction for violations of the Clean Water Act forced to dredge the hundreds of tons of muck they dumped into the River over a 3 month span.Photo-Copyright-©-2020-by-Karl-Meyer All Rights Reserved. (Click X3 to enlarge, use back arrows to return to text)

The Connecticut River has been running in reverse in northern Massachusetts for nearly half a century now. Daily at Northfield—125 miles from Long Island Sound, New England’s Great River is strangled away from its ancient gravitational course and literally forced to run counter to its nature. It’s not some bizarre phenomena related to distant tides, nor even some twisted water park trick. It’s caused by the lethal, ecosystem choking mechanisms of the Northfield Mountain Pumped Storage Station.

That river suction and reversal is the by-product of a massive, net-energy-loss, power re-generation scheme begun in the early 1970s. Originally running on the profligate excesses of nuclear power, today NMPS plugs in daily to suck giant streams of climate heating, natural-gas- produced megawatts from a bloated New England power grid. By yanking the river backward, Northfield’s huge energy and water appetite results in damage across parts of three states. Just a fraction of its ecosystem impacts have ever been fully measured and understood.

Since 1972 there’s been just seven months out of one year where those impacts were silenced. Beginning in May of 2010–and for the first time in the decade after Massachusetts implemented electricity deregulation, American shad passage at the Turners Falls Dam showed dramatically, exponentially, renewed signs of life. The big mystery was: why?

EPA-ordered Dredge Spoil Dump Site Mountain on Rt. 63 site after NMPS choked on its own silt and shut down for 7 months. Today that scar is covered by a friendly looking solar array. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge, back arrows to return)

By June of that spring, with the abrupt silencing of grim river conditions created by Northfield’s massive sucking and surging, 5 miles upstream of Turners Falls Dam, the rising shad passage results could not be ignored. Fish passage in the river and up through the power canal past that dam was already known to be sorely impacted by the annual deluge-and-dearth flows that Northfield visited on the Connecticut. Without its suck and surge, ecosystem conditions changed immediately. Shad passage at Turners Falls soared to more than 500% above the average for the prior decade. And, no surprise, the New England power grid worked just fine without the daily addition of Northfield’s costly peak inputs.

The Northfield Mountain Pumped Storage Project was designed as a net-power-loss, buy-low/sell-high, money-making cousin to the now-closed Vermont Yankee nuclear plant. It was built to profit by piggy-backing on VY’s nightly over-bloat of cheap, excess megawatts. With VY as its engine, Northfield started massively twisting the Connecticut into a broken, reversing knot in northern Massachusetts, 125 miles from the sea.

When it came on-line in 1972, NMPS corralled for its use a full 20 miles of river—slowed and stilled behind the Turners Falls Dam all the way into southern Vermont and New Hampshire at Vernon Dam. Since that time it’s been yanking the Connecticut’s currents into reverse and sideways daily, ultimately sucking them a mile uphill into their 4 billion gallon reservoir via net-loss grid megawatts. But with Vermont Yankee closed in 2014, Northfield is today juicing an ecosystem by gorging on climate changing, natural gas produced megawatts–which is what now powers half of all New England’s energy consumption. And, ironically, the bulk of traditional hydropower consumed in this six-state region is actually produced hundreds of miles away in Canada.

Plugged-in to run via four giant, reversible turbines, the Federal Power Commission in 1972 sanctioned NMPS to operate as a net-loss emergency back-up and peak demand regeneration appliance. It would do so by consuming 25% percent—or at times over 30% more, electricity than it would ever later re-feed into the power grid as peak-priced megawatts. After Northfield’s dumping in of its 6 hours of peak-priced, net-loss energy, it would then be completely dead-in-the-water and have to begin its daily cycle of gobbling up virgin grid juice to suction the river uphill again. Consumers would pay for Northfield’s privileged permission.

Upon start-up NMPS’s daily net-loss operations became the most disruptive and efficient fish killing machine in a four-state ecosystem. Northfield kills virtually everything it sucks into its turbines for hours at a time, drawing in at up to 15,000 cubic feet per second everything from tiny fish eggs to full-size American eels. That deadly draw is known as entrainment, with the result being all fish disappearing through its pumping turbines termed “functionally extirpated.” The daily carnage continues down to this day.


7-20-2010: Clouds of Silt Plume around a nearly-invisible French King Rock in the Connecticut River from FirstLight’s illegal silt dumping. Photo Copyright © 2020 by Karl Meyer (Click x3 to enlarge)

A 2016 FirstLight consultant’s study estimated NMPS’s operations resulted in the loss of just 2,200 juvenile American shad. Yet study results released in 2018 by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated the carnage from a year of Northfield’s operations was massively higher. Their study estimated a single year loss of 1,029,865 juvenile shad. And that’s for just one of four migratory fish species subject to its suction annually—the others are American eel, blueback herring and sea lamprey. Consider then, that there are another 20 resident fish species sharing that same Northfield reach of the Connecticut, plus recent findings that federally endangered shortnose sturgeon may also be present. The more NMPS runs, the more life it kills.

As far as Northfield’s massive energy consumption impact goes, here are a few recent statistics: In 2018 FirstLight reported to the Federal Energy Regulatory Commission that NMPS consumed 1.205 billion Gross Kilowatt Hours pumping the river backward and uphill to its reservoir. After doing so, it later reproducing just 907 million GKH of peak-priced power. In the following year, 2019, NMPS consumed 1.114 billion GKHs, while only actually regenerating just 828 million GKHs to send back through the wires.

The tritium-leaking Vermont Yankee Nuclear Station closed in 2014, putting an end to its 42 year run of heating up the Connecticut River—but leaving in its wake a deadly thousand-year legacy of high-level radioactive waste. Since that time NMPS’s net-loss megawatts have transitioned from running on nuclear to being the ugly by-product of sucking in the climate-changing megawatts from a New England grid largely run via natural gas. Natural and fracked-gas today supply nearly half of all New England’s electric power. And Massachusetts, living far beyond its means, is the grid’s biggest customer.

The bloated power grid all that juice is relayed over is today run, supported and marketed by the likes of the Federal Energy Regulatory Commission, ISO-New England, Nepool, and a host of private corporate interests. The public is essentially shut out of both ISO-New England and Nepool decision making, as is the media. That is living proof of the failure of energy deregulation here. We’re failing our kids.

In that vein, there is another way to examine the absurdity of NMPS’s benefits vs. ecosystem impacts. FirstLight’s Northfield Mountain Pumped Storage Station’s annual net-loss-energy consumption largely erases the output of traditional, locally-produced Connecticut River hydropower from FirstLight’s own Turners Falls power canal and Cabot Station just downriver.
FirstLight’s 2018 actual hydropower operations 5 miles downstream at their power canal and Cabot Station reported generating 316 million Gross Kilowatt Hours of electricity. In 2019 FirstLight again reported on those hydro operations, which totaled 357 million GKHs. There was a 398 million GKH deficit produced by Northfield pumping the river uphill in 2018—used to later regenerate second-hand juice. That deficit erased nearly all 316 million GKH of the hydropower FirstLight produced downstream. In 2019, Northfield’s deficit of 286 million GKHs whittled the contribution of all Turners Falls hydro operations down to just 71 million GKH of the 357 it produced. The river and consumers pay dearly.

FERC, today, is comprised of just four commissioners, three of them Trump appointees who consistently vote to sanction big, climate-heating GHG extraction and export schemes for giant corporations. The lone Democrat, Phil Glick, is the sole voice calling on the Commission to consider climate impacts. Piggy-backing net-loss, river-killing power on top of imported, climate-destroying GHG generation is a grim business. FERC and ISO-New England have fashioned a huge, consumptive system where the public never has to give a thought to its unseen, climate-killing energy sources. Their scheme has blithely conditioned the public to always having at its fingertips a seemingly-limitless energy supply—deceptively cheap, always on hand, and available at a moment’s notice. By design here’s no thought process involved; no downside visible. That, in itself, is a crime against future generations.

In its current, over-bloated, over-subscribed power configuration, the New England power grid could run just fine without the daily depredations of NMPS’s peak use. Solar proliferation has recently resulted in the addition of 3400 megawatts of locally-produced renewable energy, nearly tripling the imported, 1100 MW of brief, peak, second-hand output from NMPS. Particularly in spring–when energy use is lowest and fish are migrating, spawning and a river is regenerating its life, Northfield’s deadly use should be limited to emergency output only. The carnage needs to stop.


9-3-2010: The Mountain of NMPS Dredged Sludge Growing along Rt. 63 after EPA’s Clean Water Act sanctions. Photo Copyright © 2020 by Karl Meyer (Click X3 to enlarge, back arrow to return)

Ironically, while Northfield Mountain was being proposed and ultimately built, a new coalition of anglers and environmentalists over on the Hudson River fought off plans for a similar pumped storage station proposed by energy giant Consolidated Edison in the late 1960s. That very public and consolidated action by citizens saved both the Hudson River and the top of scenic Storm King Mountain from becoming cogs in a killer machine like the one here. The on-the-ground result was ultimately an organization now known as Hudson Riverkeeper. Sadly, a similar battle wasn’t waged here to save the Connecticut. The top of Northfield Mountain was blasted to oblivion to create a 4 billion gallon reservoir and two massive, mile-long water shafts were sunk through rock to begin sucking up a river.

That failure to thwart Western Mass Electric/Northeast Utilities’ pumped storage scheme occurred even though the Connecticut River Watershed Council would be 20 years old in 1972 when NMPS finally plugged itself in. However, since that battle for the Hudson, the Hudson Riverkeeper and WaterKeeper alliances have blossomed into key organizations in ecosystem protection, proliferating and thriving via a very public investigation, enforcement and litigation model. They are upfront and vocal about consistently taking offending corporations to task and prosecuting them.

The only solace in the River’s history here in Northern Massachusetts is that the public got wise to the environment–and to the unending downsides of nuclear waste and building fleets of reactors and river diversions. In the early 1970s Northeast Utilities proposed another two nuclear plants, twins, both to be built on the Montague Plains. Their hot wastewater would be flushed into the nearby Connecticut River. They never got built.

On February 22, 1974, Sam Lovejoy of Montague Massachusetts set about loosening the bolts and toppling a Northeast Utilities weather testing tower, installed there to monitor winds to inform the planning layout for nuclear emergency evacuations—just in case there might be a little meltdown at the twin nuke site. That act of courage and civil disobedience, undertaken with deliberation and with an understanding of its potential civil consequences, bolstered a gathering opposition to the project. It ultimately helped galvanize a growing opposition to dozens of proposed reactors across the country.

It was a combination of that direct public opposition, Lovejoy’s protest and the subsequent discovery of larval shortnose sturgeon by research biologists Mike Dadswell and B.D.Taubert that ended what would today be yet another sprawling nuclear waste dump sitting above the Connecticut River. Again, a strong leadership role was not played by the Watershed Council. What ultimately made the difference was concise action, public engagement, and legal action in the courts. This was a victory for those who take full responsibility for the public turf they lay claim to.

The Connecticut River Watershed Council just recently became the Connecticut River Conservancy, but it still remains an organization laying claim to protecting the mainstem Connecticut across four states while not employing a single staff lawyer. Nor has it adopted a mission mandate to enforce and prosecute–continuing the model of a CRWC legacy dating back to 1952. The Connecticut River has long deserved better.

SPRING: Private Profit; Public Loss

Posted by on 26 May 2020 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FERC, FirstLight, FirstLight Power, FISH CAM, fish passage, Holyoke Dam, Holyoke Fish Lift, Humor, ISO New England, migratory fish, Northfield Mountain, shad fishing, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Slim Shad Point, Turners Falls dam, Turners Falls power canal, USFWS

THIS GREAT AND BROKEN RIVER VI

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

SPRING: Private Profit; Public Loss

Despite the enormous and longstanding damages the Industrial Age visited upon the Connecticut River—the early clear-cutting of the north woods, the building of the main stem dams and canals, the profligate effluent pollution, the thermal heating from a pair of nuclear reactors, the eviscerating impacts of a massive, river-reversing pumped storage project, it somehow has survived into the 21st century with a relatively robust and still-restorable spring run of American shad in its lower reaches.


Fishing Slim Shad Pt. Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The Connecticut is indeed rare in that respect—as well as for being host to the most successful fishway on the entire East Coast, with a lift first put in place at Holyoke Dam in 1955. That spurred a New England fisheries restoration effort begun here between federal and state fisheries agencies in 1967. It is why the Connecticut ultimately became the central artery of the 4-state Silvio O. Conte National Fish and Wildlife Refuge in 1997. But by that time the river’s migratory fisheries restoration had already stalled and foundered in Massachusetts just 36 miles upstream of Holyoke, at the foot of the Turners Falls power canal and dam.


Shad Angler Wading at Holyoke Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge; back arrows to return)

The complex of fish ladders and canal routes chosen and installed there in 1980 were largely weighted toward passage of a new, mass-produced hatchery-hybrid salmon strain. They proved an obvious and instant failure for the hundreds of thousands of shad returning to pass that place as soon as all the concrete dried. Vermont, New Hampshire, northern Massachusetts—never received their promised bounty.

And so it is to this day. The Connecticut, still massively overworked and under-protected, remains without any new bona fide restoration success for migrating shad in 3 out of 4 of the states over its 410 mile reach over the last 30 years. Where have the fish successfully passed? You need not go far to identify the break point. Smack in the heart of this spring’s migration peak here’s a quick look at the stats for fish passage success up through Memorial Day weekend. As of May 25, 2020, some 274,370 shad had been lifted past Holyoke Dam according to USFWS Connecticut River Project Leader Ken Sprankle.

And at Turners Falls? Well, the last report offered included a total of 735 shad passing as of May 17, 2020. They don’t report regularly from Turners Falls. If FirstLight had just installed a simple Fish Cam the public would have had something this year—while all their license-required recreational access has been shut down tight this spring, including fish viewing, camping, even hiking trails. But, just to compare: as of that same date, May 17, 2020, Holyoke had already reported passing 51,000 shad upstream. It only takes the 1-1/2 – 2 foot long, blue-green migrants just a day or so to start knocking on the door at Turners Falls. But as the failed restoration numbers have grimly shown for decades, the river’s great run dies in the alternately starved and ramped-up industrial flows set in motion by gatehouse and dam operators at Turners Falls and Northfield Mountain.

Listless Riverbed at Turners Falls, May 14, 2020
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED
. (Click X 3 to enlarge; back arrows to return)

It’s now three migration seasons past the April 30, 2018 expiration date of the current Federal Energy Regulatory Commission license for FirstLight’s Turners Falls Dam, yet no legally-mandated fish passage–upstream and down, has been constructed. Literally nothing has been done. While citizens in three states—including fifteen cities, towns and villages, are yet to see their rightful share of the river’s fish.

As always, FERC and ISO-New England (in Holyoke) have both made sure to requisition and have available a glut of power for the sprawling Northeast power grid here (at public expense, but without public input of course) It’s way more than enough to easily exceed the grip of a summer heat wave. Climate emergency be damned… It does means big corporate profits. Meanwhile, it’s mid-spring. Power use is at a low annual ebb. Yet New England’s Great River here in the United States is currently starved of both its fish and life-giving flows at Turners Falls–while Canada’s shareholder-owned FirstLight Power exports its profits out of the region.

A living river is a public right here. Whose pockets are being lined?

An Upstream Invitation: COME VISIT; THEN PLEASE SUE US!

Posted by on 21 May 2020 | Tagged as: American shad, bascule gates, Bellows Falls VT, blueback herring, Connecticut River, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, Dead Reach, Deerfield River, Dr. Boyd Kynard, endangerd shortnose sturgeon, False attraction, Federal Energy Regulatory Commission, FERC, FERC license, fish passage, Greenfield, Holyoke Fish Lift, MA Division of Fish and Wildlife, Massachusetts Division of Fish & Wildlife, migratory delay, New Hampshire, Rock Dam, shad fishing, The Dead Reach, Turners Falls, Turners Falls dam, Turners Falls power canal, US Geological Survey's Conte Fish Lab

THIS GREAT AND BROKEN RIVER V

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 5, An Upstream Invitation: COME VISIT; THEN PLEASE SUE US!

Dear Vermont and New Hampshire (and northern MA):

Our Connecticut River–as grimly battered by diversions and reversing industrial currents as it is down here in Massachusetts, is way better than yours upstream. That’s not very neighborly to say, but it’s true. Your states probably should’ve sued our Commonwealth years back for depriving you of a living river. It’s what’s been owed you. Down here we have a spring river with at least a credible ocean connection stretching all the way from Long Island Sound to just past the mouth of the Deerfield River. It really isn’t fair you don’t…


Just a single bascule gate open with thin spill at Turners Falls Dam, May 20, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge, back arrow to return to text)

Case in point: as of May 20, 2020, Holyoke Dam had passed some 130,000 American shad upstream. Enough federal and state fisheries data from studies has been produced to safely estimate that as many as 100,000 may have arrived at Turners Falls, just 36 miles distant, still heading upstream. The only data from Turners Falls Dam was reported as of May 8, 2020, showing a total of 38 shad successfully passing that site…

In the interest of good relations, I’d like to invite you downstream to experience what you’re missing. After all, everyone has a right to a living Connecticut River. Some of us just have a little more right, while others—living upstream, have forever had almost none at all. Ironically, that none even includes Bay State residents living in the towns of Greenfield, Gill, Turners Falls, Erving, and Northfield. An ocean connection for them is barely perceptible as well.

But for the rest of you far northerners, whether you live in Vernon, Brattleboro, Dummerston, Putney, Westminster or Bellows Falls VT–or Walpole, Westmoreland, Chesterfield, or Hinsdale NH, please come visit your river where it at least still remains partly tethered to its ancient ocean connection. It’s worth the trip.

And, why not bring along fishing pole?—because, truth is, we’ve been hanging on to your fish here for decades. Most of the hundreds of thousands of migrating shad, blueback herring and sea lamprey here annually never get past the Turners Falls Dam—becoming mired in the 2-1/2 mile long Dead Reach and canal diversion leading up to that ponderous obstruction. Turners Falls is where your living river connection with the ocean, ends. Thus, including all three states, 15 towns have been robbed.

Really, come down and experience what us “haves”, have. Meet us at the cull de sac of the Connecticut here, and we’ll show you where your thousands of fish are foundering. They were promised you way back in 1967, but you never received them. This is a peek at the river your kids should be experiencing at up at home today, and the one that’s the birth right of their grand kids decades into the future. Somebody should’ve stood up long ago. There should have been a lawsuit.

BTW: there’s even a free fishing weekend down here on June 6 and 7, where you don’t even need a license to toss in a line. Come! There should still be good numbers of shad and lamprey fighting the good fight upstream–right up to the dead end dam in this largely impassible reach. You need not come far; your ocean connection ends abruptly here in Turners Falls.


The ponderous–difficult for shad to find and access, fish ladder below Turners Falls Dam, May 20, 2020. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge)

If you don’t feel like waiting, and want to catch the peak of the run here in the next week or so, just grab a short term fishing license at the MA Wildlife website. Honestly though, I’m not sure they deserve your business. Massachusetts Division of Fish & Wildlife was the only entity with specific rights to intervene over the last 50 years in the federal (FERC) license governing fish passage conditions at Turners Falls if conditions changed. In the first decade of this century, the long-paltry (6-7%) fish passage success beyond that dam evaporated down to less than 1% percent in some years. That plunge began right after Massachusetts deregulated its electricity generating markets. Those were your fish! That was your last remaining thread of an ocean connection. MDFW did nothing. Like I said, there should’ve been a lawsuit. They sat on their hands. We let you down.

For that reason alone, please come and visit. Come fish. Pop on a shad dart. We’ll be happy to social distance with you.Try your luck where your fish are stuck!

And if you don’t happen to be an angler–but just want to experience what the remains of an ocean- connected ecosystem look like, bring a folding chair and just enjoy the spectacle. A living river can be quite inspiring. And witnessing sleek, healthy fish that have travelled thousands of ocean-going miles and then 120 miles upstream here to their ancient spawning grounds, might just encourage you to take action. You deserve this. And, we know exactly where your lost fish are trapped today—the same places they’ve been spinning their upstream migratory wheels and energies for decades.

The best way to locate the nearest ocean connection on the Connecticut here is to go where the currents are—go where there is still flow in the riverbed. That’s where the agitated shad will be, trying to discover and fight their way through promising upstream currents. They want to go into the flow, but that’s the bit tricky down here–as the power company is constantly jacking the currents up, down, and all around. That’s why its the river’s dead-end. Those see-saw currents and flow diversions are tricking the shad into alien industrial flows producing endless streams of what’s called “false attraction.”

Some sites, as you will see at the company’s Station # 1 outflow into the river adjacent to the Turners Falls Power Canal, dump their industrial effluent, back into the river while creating just a few small amount of hydro power.. That false upstream signal to migrating shad essentially traps them there–for hours or days on end, spending energy in that false current as they await an open upstream path that never comes.

For anglers not tied to anything like a natural setting, the Station #1site teems with scores and scores of tricked shad, ripe for the hooking. It’s a supremely ironic dead end for the fish and run—nosing for hours into a nowhere current. But, for fish-in-a-barrel anglers, this sad site can be a slam dunk.

Other sites are rather more “scenic,” but the same waffling, insufficient flows ultimately lead to dead-end routes for the vast majority of the fish run. Less than 1 fish in 10 annually ever make emerge out of the Turners Falls Power Canal–which all must pass through before popping out beyond that dam toward your Vermont and New Hampshire doorsteps. Most just give up.

Anyway, here are some visit/witnessing recommendations from my personal investigations on May 20, 2020:

Ocean Dead End Stop # 1: Turners Falls Dam, Turners Falls. Take I-91 south to Rt. 2 East. Rt. 2 E to the second set of lights, where you turn left over the Turners Falls Bridge. Park just over the bridge near the Great Falls Discover Center and find your way across the little power canal bridge and down to the river. Note that the paltry flow is unlikely to be drawing any shad upstream to the dam and fish ladder.

Lone, disappointed shad angler in low flows below dam: look far left at center, adjacent to the bend in fish ladder. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Ocean Dead End Stop # 2: Station # 1, your false attraction fishing hole. Follow the above directions—crossing the bridge into Turners Falls. Make an immediate right after passing the Great Falls Discover Center. Continue straight after the stop sign, and then make the second right, going over the SECOND, one-way bridge there. Continue along until you see the brick outline of Station # 1 on the right, adjacent to the river. If they are dumping good current here, the fish will be stacked up like sardines, nosing into the flow that will not allow them a path upstream. Anglers fish both sides of this outflow. You’ll find the paths. An exhausting dead end, for your share of the shad run. The two gents here landed 3 shad in the 10 minutes I lingered there.

Station # 1, exhausting attraction flow leading…nowhere. Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Station # 1, fish-in-a-barrel fishing! Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Station # 1, bring on the net! Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Ocean Dead End Stop # 3: the Rock Dam. Continue with the above directions and go along past Station # 1, winding around until you come to G Street. Go right and continue south on G Street—do not recross the canal, or you’ll be off track. Continue down G Street to the end, where it becomes, rather ironically, “Migratory Way,” beyond the sign for the US Geological Services Silvio O. Conte Anadramous Fish Research Center. Follow this route down to the parking turnouts adjacent to the canal, and walk down the path there leading to Cabot Woods.

At the Cabot Woods site you will find a few picnic tables, but, most importantly, several severely eroded paths down to the Rock Dam. Flows to this site, critically important to endangered shortnose sturgeon, have already been tamped down enough to chase those ancient fish out of their spawning ground here. But, those same tamped-down flows weeks later here are keeping tricked shad into thinking the viable upstream flows through the notches here will somehow magically return, giving them a viable route. Sadly, they are not going anywhere. Again, some pretty good fishing here this day. These 5 anglers grabbed three in the 25 minutes I stayed along shore.

Fishing in the oft cul-de-sac attraction flow at the Rock Dam.
Photo Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. (Click X 3 to enlarge and view; then back arrow)

Note: there are far more shad struggling just downstream–attracted by the outflow of the Cabot Station hydro site. But there’s no good fishing access to these flows, some of which are designed to lead the shad into what’s been described as the “world’s longest ladder for shad,” by fisheries biologist Dr. Boyd Kynard. It’s a brutal exercise–fishladder 66 steps to fight through, which dumps them into the alien flows and environments of the power canal…

So, that’s where your fish are. Down here, where the ocean connection breaks. Come and visit! Then, take us to court to get what you deserve. It’s your river too!

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…

Issue # 3: The River Emptied at Spring

Posted by on 13 May 2020 | Tagged as: American shad, Bellows Falls VT, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight, Greenfield Recorder, Holyoke Dam, Holyoke Fish Lift, migratory fish, Narragansett, Nipmuck, Northfield Mountain, Norwottuck, Pocumtuck, Rock Dam, Rock Dam Pool, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turner Falls Massacre, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Walpole

THIS GREAT AND BROKEN RIVER III

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 3: The River Emptied at Spring

Dismal Mother’s Day flow at Turner’s Falls Dam and Fishway Copyright © 2020 by Karl Meyer (Click X 3 for closeup, click back arrow to return to text)

It was a grim Mother’s Day weekend for the Connecticut River in Massachusetts. The only current left in the riverbed below Turners Falls Dam amounted to little more than a thin, spreading soup winding a shallow path around successive ridges of drying ledge as it threaded together a downstream path along it’s ancient, impoverished bed. Anyone with a pair of rubber boots could’ve easily walked across the Connecticut just a few hundred feet below that dam without much risk of getting wet to the knees–smack in the middle of fish migration and spawning season in the heart of the Silvio O. Conte Connecticut River National Fish and Wildlife Refuge.

There’s something soulless in starving a river of its flow—particularly in the spring when the shadbush is in bloom, the columbine have sprouted, and the fish are in the river. This year, with the corona virus draining spirits and sapping energy during March and April, the presence of a living river in Western New England’s back yard was something to anticipate come May. The light returned, the trees were in flower, birds were making music, and energy use was in its usual seasonal retreat—demand being down ever since a warmer than normal winter.


Days Earlier Flow over Turners Falls Dam May 5, 2020 Copyright © 2020 by Karl Meyer (Click X 3, back arrow to return to text)

This should have been a promising early May on New England’s Great River. But no–not here in northern Massachusetts–not this Mother’s Day weekend. For migrating American shad seeking a route upstream here, the river was literally a road to nowhere. As of Monday, May 11th, though some 18,000 shad had passed upstream at the Holyoke Fishway, 36 river miles to the south, not a single shad had been tallied managing to pass beyond the grim maze of a power canal and several ladders to emerge above Turners Falls Dam. By Monday not a single migrant from the ocean had been tallied passing that dam–thus none were present moving upstream to open Vermont, New Hampshire and northern Massachusetts habitats. The public has no access to the fishway this year, and FirstLight has not provided a simple video feed for people to see their fish. At Turners Falls, the power company alone, is left to monitor itself and report on the public’s fish.


Shad Anglers below Holyoke Dam May 7, 2020 Copyright © 2020 by Karl Meyer

But, most grimly again this May, river conditions on Mother’s Day were altogether devastating for federally-endangered Connecticut River shortnose sturgeon attempting to spawn and nurture young in the currents at their ancient Rock Dam spawning pool–a mile and a half downstream of the dam. Vital river flows at a natural basalt, in-stream formation known as Rock Dam–which had been accommodating for spawning sturgeon just a week before, were shut down to the point where the cobble shoals that shelter eggs and developing young were now visible along a receded shoreline.

Hopeful shad anglers from the adjacent USGS Conte Lab and nearby US Fish & Wildlife Service in Sunderland were present to witness the impacts. This year’s potential progeny–at the sturgeon’s only documented natural spawning site in the ecosystem, were once more left to desiccate–starved of life-giving, oxygenating water as the sun warmed the prematurely exposed, rocky shallows. Though not fishing on this Mother’s Day morning, one of the leaders of the local Nolumbeka Project stopped to inquired of me if the sturgeon had been able to successfully spawn this year. I had to tell him no.

For the second year running FirstLight Power had squeezed the bascule gates closed at Turners Fall Dam, leaving just a curtain of a few hundred cubic feet per second (cfs) of flow entering the starved riverbed below Turners Falls Dam. The Federal Energy Regulatory license for FL’s Turners Falls and Northfield Mountain operations expired two years back on April 30, 2018. . Conditions in a new license would have hopefully increased that dribbling flow at the dam by a factor of 20. Grimly, the starving of this Great River is occurring at the exact site where women, children and elders of the Nipmuck, Pocumtuck, Norwottuck and Narragensett People were set upon and slaughtered in their pre-dawn sleep in the Turners Falls Massacre on May 19, 1676.

But FERC stepped in on FirstLight’s behalf, and has now offered two years of license extensions to this Canadian-owned, Delaware-registered company, allowing these grim impacts to continue. In doing so it has now green-lighted these conditions for three consecutive spawning seasons–allowing crippling industrial practices put in place 52 years back to choke the life out of four-state migratory fish runs, and crushing the spawning prospects for those sturgeon–literally the Connecticut’s only federally endangered migratory fish species. This, in an ecosystem that should have had connected and sustaining flows and fish passage upstream to Bellows Falls VT and Walpole NH long ago.

The flows present in the river on Mother’s Day are flows that force endangered sturgeon to default downstream to attempt spawning in the pulsing industrial flows churning out of the Cabot Station powerhouse a half mile downstream. There, any spawned and developing young-of-the-year will have no defense against the scouring-out hydro surges pulsing canal water back into the riverbed below once fertilized young are dispersed in the flows to shelter in rocky shallows .

Those tamped-down Mother’s Day flows from the dam also create conditions that keep American shad in an endless Groundhog Day cycling at Rock Dam–circling and re-circling in the depleted currents at a pool where depths become too shallow to find a flow offering a negotiable upstream path. Anglers sometimes do quite well at this migratory cull-de-sac where agitated, circling shad snap at darts while wasting hours and energy in this suspended-migration.

But those same tamped down flows diverted at TF Dam also cause just-arriving American shad from Holyoke to be led directly to the false upstream currents exiting the power canal at Cabot Station. Sensing that upstream attraction flow, those unlucky fish get drawn into a ponderous and exhausting fish ladder there. There they are diverted entirely out of the riverbed and into a concrete chute where they must attempt to better an impossible series of steps, twists, and turns that will ultimately dump them into the alien and un-river-like environs of the Turners Falls power canal. Once they enter that industrial habitat, many end their upstream migrations altogether, spending weeks in the labyrinth of that walled corridor without finding a way out and upstream.

Grimly, this year was nearly a carbon copy of the brutal conditions visited below Turners Falls the week of Mother’s Day 2019. Last year at this time researchers tallied the largest-ever catch of spawning-run endangered sturgeon gathered at their Rock Dam nursery pool, corralling 48 fish in a morning survey of a biologist’s net. Days later, at the height of shortnose spawning season, FirstLight abruptly cut off life giving flows to the site. Those same banks and cobbles were exposed, and the spawning run sturgeon were sent packing—forced to abandon the site, with any embryos and young that might have proved viable left withering in the shallows.


FL’s Locked Entrance at Cabot Woods & Rock Dam mid-afternoon May 5, 2020 Copyright © 2020 by Karl Meyer

You might have expected more from FirstLight this year. This is a Canadian shareholder company seeking a new federal license to operate these facilities on the Connecticut River in Massachusetts after recently re-registering them in Delaware as tax shelters. But, now that FERC continues to allow them to profit off the grim and antiquated tenets of a license written under the Federal Power Commission 52 years ago, they seem in no particular hurry to become relicensed neighbors operating for profit on a four-state US river that is the centerpiece of a National Fish and Wildlife Refuge.

These ongoing grim flow regimes fly in the face of mandates long-ago included in the Endangered Species Act and the Anadramous Fish Conservation Act, here, in the most biologically important and critical habitat in the entire Connecticut River ecosystem. They also feel like a thumbing of the nose at Massachusetts taxpayers—as well as all the deserving citizens in the three states from Montague MA to Walpole NH, who also pay taxes and are certainly entitled to a living river. It is a form of public theft.

As the Connecticut River is left starved, its ancient fish runs foundering, there is no movement to bring to a close the Federal Energy Regulatory Commission’s “5-year” relicensing process—begun here in 2012 and lingering on, laughably unfinished. The power company continues to pocket profits, while the FERC is led by a stilted and hand-picked majority happy to feed the corporations what they want, to the benefit of foreign shareholders far from New England. Sadly, there is no state or federal environmental agency that appears willing to challenge this endless delay. And, as noted here before—this four-state river lacks a true NGO watchdog with a mission-mandate and staff lawyers protecting it. See The Greenfield Recorder: https://www.recorder.com/New-England-s-great-river-without-a-watchdog-33291778

THIS GREAT AND BROKEN RIVER

Posted by on 28 Apr 2020 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls VT, blueback herring, Canada, climate-heating, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, FirstLight Power, Holyoke Dam, Holyoke Fish Lift, Holyoke Gas & Electric, Massachusetts Division of Fish & Wildlife, Micah Kieffer, migratory fish, National Marine Fisheries Service, New Hampshire, Northfield Mountain, Northfield Mountain Pumped Storage Project, pumped storage, Rock Dam, Rock Dam Pool, shad, shortnose sturgeon, State of Delaware, The Great Eddy, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Vermont, Vermont Yankee

THIS GREAT AND BROKEN RIVER

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 1, First Daylight for an Embattled Run

The tiniest spark of life reentered New England’s Great River on Tuesday, April 21, 2020. According to Ken Sprankle, Connecticut River Project Leader for the US Fish & Wildlife Service, the fish lifts began operating that morning at the Holyoke Dam, 82 miles from the sea. And on that day the first two migrating American shad of the spawning season were lifted upstream.


Holyoke Dam. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

I got that fragile bit of good news on Earth Day, and it was truly a bright spot in what seems a very distant and fragile time for people, ecosystems, and our beleaguered planet. And during this Covid pandemic, while our warming atmosphere is experiencing a brief respite from the particulate pummeling of jets and cars, the Connecticut is being brutalized as catch basin for all the chemicals, chlorine and antibiotics that are currently being flushing out into–and right through, our sewage treatment plants to the River… As such, the Connecticut had little to celebrate on the 50th Anniversary of Earth Day.

Nonetheless those two fish meant there would at least be some vestige of the spring run that once fed river communities for hundreds of miles along this central artery for untold centuries into the past.

It’s the public’s river, and these are the public’s fish. Those are the facts that I always keep in mind whenever I write or speak about the Connecticut. But there’s also this basic tenet for me: a river is a living system; it exists of its own right and its right to survive and thrive should thus be an unquestioned part of its existence. We humans have a moral obligation to protect the life of rivers, just as they have nourished, protected and supported the very ecosystems we’ve relied on for time immemorial.

For me, to kill a river is an immoral act. To flaunt any part of the legal framework that federal and state law has put in place protecting them is both criminal and repugnant. But maybe that’s just me…

Holyoke Dam looking toward Fish Lifts. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x3.

Now two shad aren’t much in many minds, I’ll admit. But what those two shad—likely early males meant, was that the Connecticut had actually become a living river once more. At least a part of it. That tenuous little reconnection was completed when one fat, industrial bucket of river water was pulled from the downstream side of Holyoke Dam and dumped on the upstream side. Two living, blue-green American shad swam out into 35 miles of upstream river that all downstream fish are denied access to for some six months out of every year. That’s way less than a half-living river.

But what that tiny spark meant, more than symbolically was that—on the most basic level, the Connecticut was reopened along a tiny stretch as a true river–a TWO-WAY highway where migrating and resident fish can move both upstream and down as part of this ancient ecosystem highway.

The Holyoke Dam is historic for two reasons: First, it is the barrier at the center of the 1872 landmark US Supreme Court decision in Holyoke Company v. Lyman that established that dam owners and operators must provide passage for migratory fish—both upstream, and downstream, of their barriers. Second, though imperfect and of the simplest most basic design—i.e. upstream, in-river attraction flows leading migrating fish to be corralled in a closeable, industrial bucket and lifted over the dam–those Holyoke Fish lifts have remained the most successful fish passage on the entire East Coast since 1955.

For the next few months Holyoke’s industrial buckets will facilitate a stuttering recreation of the former Connecticut as a living, 2-way river while American shad, sea lamprey, shortnose sturgeon and blueback herring attempt to access ancient spawning grounds. For many that open habitat reaches all the way to the dam between Bellows Falls VT and Walpole NH–nearly 90 miles upriver. That ancient destination, however, remains a cruel impossibility for all but a fortunate few migrants…

The Great Eddy at Bellows Falls Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

Once again this spring the vast majority of those hundreds of thousands of fish passing upstream at Holyoke will be thwarted from reaching the wide open spawning habitat anywhere above the Turners Falls Dam. That dam sits just 35 miles upstream of the Holyoke lifts. It’s an easy swim for most– just a day, maybe two.

But once they approach that river reach and barrier there won’t be accommodating riverbed flows or any lifts offering suitable passage upstream. They’ll encounter vacillating, confused flows and a series of obstacle-filled fish ladders that funnel all migrants into the grim habitats of the Turners Falls power canal before any get an outside chance to squeeze past the dam itself. Most never do. Perhaps one fish in ten will succeed–leaving the next 68 miles of Connecticut River habitat impoverished and all but empty of its ancient migrants.

And for shortnose sturgeon, one of this river’s most ancient species and the only federally-endangered migrant in this ecosystem, prospects are yet more dire. With the actual riverbed in the 2 miles below Turners Falls Dam sporadically deluged and emptied of suitable natural current, these fish are all vulnerable to being again robbed of what should be an annual, slam-dunk spawning aggregation at their only documented natural spawning site in the ecosystem–the Rock Dam in Turners Falls. Another season will go by without life-giving mandated flows to this critical habitat due an absence of enforcement protection and license requirements.

Of course, that was to have changed two years back.

The Federal Energy Regulatory Commission licenses for operation of the Turners Falls/Cabot Station hydro sites and the Northfield Mountain Pumped Storage Project expired two years back on April 30, 2018. New flows and fish passage requirements should have been re-nourishing the endlessly pummeled and impoverished river in the beleaguered miles above and below Turners Falls Dam since that time. However, for the crippled run here, there is literally nothing new. Fish at Turners Falls today are almost as effectively blocked from moving upstream into Vermont, New Hampshire and northern Massachusetts waters as they were when the first dam across the Connecticut there blocked these runs beginning in 1798.

Today, the crushing suck-and-surge impacts of Northfield Mountain’s net-energy-loss, peak-price/peak-demand operations continue brutalizing the grimmest 10 miles in the entire ecosystem–cannibalizing the river’s fish runs and chewing through young-of-the-year. Pumped storage is not renewable energy, nor is it anything like the conventional river hydropower much of the public thinks it generates. Northfield Mountain consume vast amounts of virgin electricity from the grid here—most if it generated through imported natural gas, to pump the Connecticut backwards and a mile uphill. NMPS is in reality an energy consumer. It’s massive pull off the grid gets tallied in negative megawatts.

Today, the revival and protection of those long-ago, lawfully mandated runs remains stuck at Turners Falls and Northfield Mountain. The so-called FERC 5-year Integrated Licensing Process(ILP) that should have given them their two basic necessities for survival—water, and a safe, timely route upstream and down, actually began in the fall of 2012. It drags on to this day.

The day after FirstLight at long-last submits its final license application for examination to FERC–and the federal fisheries agencies with conditioning authority on the Connecticut, it will be September. September signals the beginning of the 9th year this supposed stream-lined FERC ILP has been malingering on this river system. FirstLight left off negotiations over a year ago with the US Fish & Wildlife Service, National Marine Fisheries Service, and the Massachusetts Division of Fisheries & Wildlife for required new river conditions and construction of fish lifts. There has been no movement since that time.

Any delay in the construction of a fish lift at Turners Falls, and the requirement for real, life-sustaining flows in the riverbed, benefits this recently-arrived power company. Their interest is in stakeholder and corporate profit—and this is a Canadian-owned outfit that re-registered all of these assets out of Massachusetts, chopping them into a series of tax sheltered Delaware LLCs in late-2018. FERC continues to allow FL “extensions of time” to make their license-required filings, delaying what have long-been federally required mandates for river and migratory fish protections.


The de-watered Rock Dam Pool where shortnose sturgeon attempt to spawn, just after 6:00 a.m., May 17, 2019. Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED. Click x 3.

FL is now citing that restructuring as another reason for delay in submitting their “final license application” until August 31, 2020—that’s two years and four months of operating and profiting from a destructive and river de- pauperizing extended license. The current extension still requires only 400 cubic feet per second to be released into the Connecticut River bed in the spring migration season through which shad attempt to move upstream in—and embattled,federally-endangered shortnose sturgeon attempt to spawn in. That’s the equivalent of substituting a small brook for a river. Sturgeon spawning fails at the Rock Dam site most years, often caused by the abrupt ratcheting of those spring flows down to little more than that trickle.

Studies and investigations by the federal fish agencies show that a massive increase in sustained spring flows are baseline requirements for a living river here. Last year n the first week of May spring flows of some 10,000 cubit feet per second were coursing down the Connecticut’s “dead reach” here–and right through the Rock Dam pool. Shad anglers were landing fish by the dozen. On May 10, 2019, USGS Conte Lab researcher Micah Kieffer put out a research net overnight in that pool. Then next morning he found 48 federally-endangered shortnose sturgeon weighing it down—the largest aggregation ever recorded there. Kieffer continued his successful sturgeon netting through the following week, until coming up empty on Friday, May 17, 2019. He got “skunked” that day after flows through the Rock Dam reach were abruptly cut by FL to a relative trickle, exposing the cobble-lined shores of that pool where embryos and young develop.

Clearly, those 10,000 cfs flows are what are necessary to restore life to this river. They are required and long overdue—at a season when electricity demand is at some of its lowest points in the year.

The first year license extension by FERC was allowed because of the shuttering of the Vermont Yankee nuclear plant upstream. VY’s excessive, night nuclear megawatts were the grim, 40 year engine that enabled Northfield Mountain to suck the river into reverse and pump it up into a 4 billion gallon reservoir to later re-create second-hand electricity at high prices.

Now restructured, FL appears in no hurry to move ahead with new licenses. Their study results have often been delayed in being handed over to the federal fisheries agencies and study teams in this relicensing–or handed in on the very last day the process requires. They seem happy to tread water and realize profits–while NMPS’s fish-eating, net-energy loss operations continue running along, largely fueled via the imported, climate-scorching, natural gas generated electricity now bloating the grid.

The longer you don’t have to put a shovel in the ground or give this US River its flows for federally-required fish passage, the more money you keep. It’s time FERC stopped letting them off the hook. Stop stringing this process along. It’s time this river was brought into compliance with 1872’s Holyoke Company v. Lyman; it’s time to comply with the federal Endangered Species Act of 1973. It is the public’s river; these are the public’s fish.

Addendum: on Friday, April 24th, USFWS’s Ken Sprankle sent a note that the Holyoke Gas & Electric had shut down its fish lifts due to accumulating debris in its assembly. They would not operate through the weekend, and a fix would be attempted on Monday. Thus, the Connecticut became a one-way stream again anywhere above South Hadley Falls, leaving the next 88 empty miles of river still in midst of an endless vigil–awaiting the migratory runs guaranteed by the Supreme Court 148 years ago. Hopefully, for those migrating shad—and perhaps other early migrants wasting another week’s precious spawning-energy reserves while knocking on Holyoke’s door, those lifts are again operating and in full motion today.

Connecticut River shortnose sturgeon: a spectacular failure to protect

Posted by on 26 Mar 2020 | Tagged as: Christopher Chaney, Christopher Cheney, Clean Water Act, Connecticut River, Connecticut River pollution, Connecticut River riverbank failure, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Endangered Species Act, EnviroSho, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, FirstLight Power Resources, Kimberly D. Bose, MA Division of Fish and Wildlife, manganese pollution, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, P-1889, Rock Dam, Secretary Kimberly Bose, Turners Falls, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, www.whmp.com

Connecticut River shortnose sturgeon: a spectacular failure to protect
Copyright © 2020, by Karl Meyer. All rights reserved.

Photo Copyright © 2020, by Karl Meyer (click X3 to enlarge)
Well over 4 months since I registered my October 9, 2019 Comments describing critical erosion and polluting impacts on the Connecticut River at fragile habitat at the Rock Dam in Turners Falls–the sole documented natural spawning site for the federally endangered shortnose sturgeon in this river FirstLight Power Resources received instructions from the Federal Energy Regulatory Commission’s Christopher Cheney at the Office of Hydro Compliance. On February 21, 2020, they included the following:

“Dear Mr. Traester:

On October 9, 2019, we received a complaint regarding erosion in the bypassed reach of the Turners Falls Project No. 1889. According to the complaint, releases from the dam caused erosion in the area known as the Rock Dam in the project’s bypassedreach. For us to complete our review of the of the complaint, please file the followinginformation within 30 days of the date of this letter:

1. Photographs and the location(s) and an estimate of the extent(s) (e.g., height, width, depth) of the erosion in the bypassed reach identified in the October 9, 2019complaint.”

Here are some key points, verbatim, from my October 9, 2019 letter, including impacts on this fragile endangered-species spawning site and habitat—and addressing as well, federal and state laws and license conditions:

“In recent weeks I have noted increasingly steady water leakage in the riverbanks above the Rock Dam site, leading to constant water flow intrusions along these banks. Less than 400 feet away sits the downstream, outer-right banking curve of the Turners Falls power canal, which is the apparent source of these increasing water intrusions.
Photo Copyright © 2020, by Karl Meyer.

In a visit to the Rock Dam site on October 8, 2019, I noted the dramatic collapses of a long section of riverbank adjacent to the Rock Dam. This collapse, of some 25 feet in width and dropping down between 5 – 10 feet toward the river, is apparent in my attached photo. Please note that the draped yellow jacket in the foreground is approximately 3-1/2 feet across. This new bank collapse is just south, by perhaps 30 feet, from an earlier recent collapse of a smaller scale of some 6 feet across, occurring at approximately the same bank level. At both of these sites there has been a serious leaching of manganese, the red colored flow toward the river and the sand and cobbles that constitute the shortnose sturgeon spawning site and egg/embryo nursery unique to this reach. Photo Copyright © 2020, by Karl Meyer. (click X3 to enlarge)

Please take action requiring immediate remedy to this situation, which appears to concern license and statute infractions that run afoul of the federal Endangered Species Act, the Clean Water Act, and Article 17 concerning erosion; Article 19, concerning construction and maintenance; Article 18 concerning fishing access; and Article 35 concerning State Historic Preservation under the current license for P-1889.”
Photo Copyright © 2020, by Karl Meyer (click x3 to enlarge)

FirstLight responded on March 20, 2020. They included an all-but-useless satellite shot for a federal agency that has exact information on this site, and pictures of boulder-rubble that connect directly to their dumped rubble that is currently tumbling from their ancient attempts to shore up the failing Connecticut River banks above and adjacent to the TF power canal.
This is evidence of the power company’s failure in decades past. They now attempt infer that the tumbled rocks here are the work of the public and fishermen, not the failed detritus of their ongoing neglect.

FirstLight also failed to address the requested measurements from FERC. And, as to my original complaint, they leave out any mention of manganese, the intrusions and water—and it’s leaching and crumbling connections to the Turners Falls power canal; as well as failure to protect and maintain critical shortnose sturgeon spawning habitat. Nor does FL address the ESA, Clean Water Act, and current FERC license conditions required at this site. Below are excerpts from FL’s response, and below that is a link that you may be able to use to access FirstLight’s full response to FERC:

“FirstLight cannot provide dimensions of the extent of the erosion because there is no evidence of any recent erosion in this natural river channel.”
Above photo taken March 25, 2020 w/sturgeon expert Dr. Boyd Kynard at right, on the failed banks adjacent to Rock Dam. (click X3 to enlarge) Photo Copyright © 2020, by Karl Meyer.

Further, FL states, “Photographs were taken on October 29, 2019, after the October 9, 2019 complaint letter. Note moss on the rocks located within the side channel in Photos Nos. 1 and 2, indicating the preexistenceof a wet environment. Note also a Photo No. 3 showing ~12” rocks placed across the side channel. This section of the bypass reach is frequented by the public in summer months. The rocks aligned across the side channel appear to have been placed by unknown members of the general public, possibly to form a barrier or walk path across the side channel, suggesting that the channel is frequently wetted.”

You may be able to access FirstLight’s full response to FERC by copying an pasting the link below:https://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20200318-5043

You may also want to Comment directly to the Federal Energy Regulatory Commission.
Here’s how:
Go to www.ferc.gov ; then to file E-Comment; from there to Documents and Filings; then to Hydro; then to Washington DC; then paste-in P-1889 for the Project # (you must have this), then check the little X Box; then address your comments to “Secretary Kimberly D. Bose” and comment away! Make sure to include your own contact information.

AND, from FERC Hydro Compliance: Christopher.Chaney@ferc.gov

Also, you may want to contact your agency representatives negotiating on the public’s behalf in the current FERC relicensing. They will assuredly forward your message to their Department Chiefs who are responsible for the CURRENT license and river conditions and enforcement:

For the National Marine Fisheries Service: julie.crocker@noaa.gov
For US Fish & Wildlife Service: ken_sprankle@fws.gov ; melissa_grader@fws.gov
For MA Div. of Fish & Wildlife: caleb.slater@state.ma.us

There’s also your federal and state/local reps: Warren, McGovern, Comerford, etc., all represent you! And, you can write to the local media—this effects all at the ground level, and into the future.

Also, a few recent radio spots addressing this issue, below, with thanks to Bob, d.o., and Glen!

The Enviro Show

The Shortnose Sturgeon are Coming to Spawn –in THIS?

Who is protecting New England’s Great River??

Posted by on 15 Jul 2019 | Tagged as: Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered Connecticut River shortnose sturgeion, FERC, FirstLight Power, Fish and Aquatics Study Team, limited liability corporation, LLC, Northfield Mountain Pumped Storage Station, Rock Dam, Rock Dam Pool, shortnose sturgeon, Society of Environmental Journalists, State of Delaware, The Daily Hampshire Gazette, The Greenfield Recorder, Treasury Board of Canada, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey, US Geological Survey's Conte Fish Lab, USFWS

The following piece appeared in The Greenfield Recorder on June 27, 2019, and in the Daily Hampshire Gazette on July 17, 2019. The original title ran as “Sturgeon Revival on the Connecticut.” www.recorder.com, www.gazettenet.com .
Ruined Rock Dam spawning and nursery site on May 17, 2019. At upper left is one of the extremely sensitive island habitats that rafters repeatedly trammeled. NOTE: Click, then click twice more to enlarge. Photo Copyright © 2019 by Karl Meyer, All Rights Reserved.

Story, Copyright © 2019 by Karl Meyer. All Rights Reserved.

Something remarkable occurred below Turners Falls this May: four dozen federally-endangered Connecticut River shortnose sturgeon were discovered at their embattled spawning and nursery site–the largest documented aggregation since long-term research began there in 1992.

In the afternoon of May 8, 2019 when US Geological Services biologist Micah Kieffer walked down to the river near the Silvio O. Conte Anadromous Fish Research Center, he got a surprise “burp” on the receiver he carried. That meant just one thing: a radio-tagged sturgeon was nearby. Since early spring consistent high flows had coursed down the riverbed—a rarity in the oft-emptied, 3-mile reach below the Turners Falls Dam controlled by FirstLight Power. Kieffer hustled back to the USGS Lab, gathering armloads of equipment and securing a boat. By nightfall he’d set out nets, hoping to find a few sturgeon where they’ve likely spawned for thousands of years–a unique, cobble-bottomed pool downstream of the dam.

The big shock came first thing next morning. Weighing down the nets were 48 squirming, 2-3 foot long, endangered sturgeon–one female “running eggs”; the males all running sperm. Kieffer worked quickly to catalogue each fish; returning all to the current. Across a quarter century of intensive federal research started under Amherst’s Dr. Boyd Kynard and continuing under Kieffer, this was a critical discovery near a place called Rock Dam—which hosts a single, tiny rapid. That site is critical to the shortnose’ recovery—it’s a unique biological refuge, and their only documented natural spawning site in the ecosystem.

Life-giving spring flows have been rare below Turners Falls Dam for nearly a half century. Most years currents get violently see-sawed up and down and diverted in and out of the riverbed at that dam via computers operated from inside the 1972 Northfield Mountain Pumped Storage Station, seven miles upstream. Those disruptions help service the massive water and energy appetite of Northfield’s pumped storage electricity regeneration and resale regime. Most years spawning success for this 200 million year-old sturgeon species fails at Rock Dam. That flow chaos has also long-handicapped the stalled, four-state federal Connecticut River Cooperative Fisheries Restoration for shad and herring here.

But this year, nourishing high flow continued through that critical biological reach right into the height of shortnose spawning season—which extends to late May. Operating with minimal staff, Kieffer again managed to anchor “day-set” nets in the river on May 15th and 16th. He got 11sturgeon on each of those days. But when nets were set again on May 17th he suddenly found himself skunked.
Exposed, dewatered shoals in shortnose sturgeon spawning and nursery habitat below Rock Dam.
Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. Click x3 to ENLARGE>

At 7:30 on the morning of May 17th, just a single gate spilled a thin stream of water into the channel below Turners Falls Dam. Though river flows had been slowly subsiding, when FirstLight pinched those gates shut they were pulling the plug on spawning flows. According to Dr. Boyd Kynard in his 2012 book, Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, “Flow reductions that occurred while fish were spawning at RockD caused SNS to leave the area, and after females left, they did not later return to RockD spawning habitat.” What’s worse, that abrupt tamp-down dewatered the cobble bottom and shoals below Rock Dam where spawned eggs and embryos shelter and develop through June. It’s deadly.

Later that morning two gates were opened, re-ramping currents in the river. Over the ensuing days US Fish & Wildlife Service representatives noted gates alternately waffling flows up and down in sturgeon spawning time—from two open, down to one; later up to three. Perhaps encouraged by those settings, on May 29th a rafting company was seen repeatedly sending loaded, lumbering rafts over Rock Dam and walking them up onto sensitive island habitats.

FirstLight and those commercial rafters have long been apprised and legally aware of the presence of endangered sturgeon—federal studies are part of the relicensing record here. Liability is spelled out under the Endangered Species Act. A single act of interference with a federally endangered sturgeon carries a penalty of $49,000 and possible jail time. Those dam settings resulted in grim biological conditions at a time FirstLight should have been exercising utmost care: this was in the midst of their providing experimental flows from the dam to fulfill license requirements for migrating shad while meeting sturgeon spawning needs.

This December, FirstLight reregistered their Northfield and Turners Falls facilities in a series of tax-sheltered, limited liability corporations in the State of Delaware. As a venture capital firm, parent-owned by the Treasury Board of Canada, they’re seeking a new federal license to operate on this U.S. River in our Commonwealth for decades to come. This critical reach should not become a cash-cow playground for corporate shareholders or joyriding rafters. It’s time to celebrate the shortnose sturgeon, and time to let a river heal.

Karl Meyer has been a stakeholder and member of the Fish and Aquatics Study Team in the current FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2012. He is a member of the Society of Environmental Journalists.

Why no FISH?, STILL???

Posted by on 30 Apr 2019 | Tagged as: American shad, Atlantic salmon, Bellows Falls Fishway, blueback herring, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRASC, Daily Hampshire Gazette, Dr. Boyd Kynard, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Gary Sanderson, Greenfield Recorder, Holyoke Fish Lift, MA Division of Fish and Wildlife, Montague Reporter, National Marine Fisheries Service, National Marine Fisheries Service, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, Public Law 98-138, Rock Dam, shad, shortnose sturgeon, The Greenfield Recorder, The Recorder, Turners Falls, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, Vernon Dam Fishway

The disastrously-emptied Northfield Mountain Pumped Storage Reservoir, June 27, 2010. (CLICK, then Click several times more for FULLEST VIEW) Copyright © 2019 by Karl Meyer. All Rights Reserved.

WHY no FISH…
All photos and text Copyright © 2019 by Karl Meyer. All Rights Reserved.

By clicking on the blue link WHY no FISH… above, and then clicking it again on the following page, you will open an old PowerPoint presentation that I gave to the Pioneer Valley Chapter of Trout Unlimited in Holyoke in December 2010. It will take several minutes to load, but is then largely self-explanatory, with text available below photos, or by clicking the text tab.

On April 30, 2010 I embarked on a journey to the mouth of the Connecticut River by bicycle, to document the grim crippling of the river and its shad runs due to the lack of enforcement and engagement of fisheries agencies and river organizations. At the time, they were all still cheerleaders for a failed salmon program, ignoring the stark facts of the impacts of the Northfield Mountain Pumped Storage Project on American shad and federally endangered shortnose sturgeon.

At the time I was doing part-time work at the Connecticut River Watershed Council, but quit out of frustration and disappointment just a few months after.

Notably, just a year later, the US Fish & Wildlife Service cancelled its long-failed salmon hatchery and “restoration” program on the Connecticut. A year after that, the river conversation became about the impacts of flows in the Dead Reach of the Connecticut, and Dr. Boyd Kynard’s groundbreaking book focusing on federally endangered shortnose sturgeon at the Rock Dam was released–though only following an unconscionable 3-month embargo of his research data by the US Geological Service.

Nearly a decade later, Northfield Mountain remains the Connecticut River ecosystem’s deadliest machine, directly impacting riverine life and migratory fish abundance in three states.

The Connecticut River now has TWO “conservancies”, but not a single NGO that makes any claims for ENFORCEMENT being a chief (or really ANY) component of their mandate. And ENFORCEMENT is a requisite for any true ecosystem restoration and river protection outfit that means to carry out its mission. This is a four-state ecosystem without a legal team. The Connecticut remains a river unprotected.

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.

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