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CONNECTICUT RIVER pumped storage: assault and battery on an ecosystem at a tipping point

Posted by on 19 Apr 2018 | Tagged as: 5-year FERC licensing process, CommonWealth Magazine, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, Drew Huthchison, Federal Energy Regulatory Commission Chairman, federally-endangered Connecticut River shortnose sturgeion, FERC, FirstLight, Local Bias, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, Turners Falls, Turners Falls power canal, US Fish & Wildlife Service, wildlife refuge

Connecticut River Pumped Storage: assault and battery on an ecosystem at a tipping point

Copyright © 2018 by Karl Meyer. All rights reserved.

Downstream end of the starved and brutalized 10 mile reach of the Connecticut, looking upstream from just above the Deerfield River confluence. (Click, then click again to enlarge).

The following links offer the most up-to-date understanding of current and future conditions in the most embattled, crippled reach of the entire Connecticut River. It consists of the Massachusetts river corridor from Greenfield/Turners Falls above the Connecticut’s confluence with the Deerfield, to some 10 miles further upstream to beyond the immediate and deadly impacts of the Northfield Mountain Pumped Storage Station.

Most stakeholders in the ongoing 5-year (now into it’s 6th year) FERC licensing process for the Northfield Mountain Pumped Storage and Turners Falls hydro projects have signed confidentiality agreements with FirstLight. Though relicensing studies on the impacts of these facilities on fish and aquatic life will continue through this fall, signed-on stakeholders have now been participating in closed-door settlement discussions out of the public eye with FirstLight for nearly a year. Any negotiated–or FERC-mandated, river conditions under a new license will be permanently in place for decades on this key US ecosystem that is part and parcel of the watershed-wide Silvio O. Conte National Fish and Wildlife Refuge. They must comply with federal and state environmental law. FirstLight is a MA-registered, Canadian-owned subsidiary of PSP Investments–a 100% Canadian Crown-owned corporation.

Thus, the National Marine Fisheries Service, US Fish and Wildlife Service, MA Division of Fisheries & Wildlife, and state agency representatives from four New England states are charged with ensuring the Connecticut River ecosystem gets the long-awaited critical environmental protections for its US public trust fish and efforts to restore both the federally-endangered Connecticut River shortnose sturgeon, and the foundered half-century old mandate to bring migratory fish back to Vermont and New Hampshire–as both abundant resources for sport fishing, and seafood. That is their actual federal mandate, in place since 1967.

Given the embargo on public information in these closed-door settlement talks, people interested in the survival of the Connecticut River ecosystem and a viable four-state river for generations to come may find information contained in the following links helpful.

The first link is a piece published by CommonWealth Magazine in March. https://commonwealthmagazine.org/opinion/this-energy-storage-is-tough-on-connecticut-river/

The second is an interview by Drew Hutchison, creator of Local Bias, at Greenfield Community Television, also from March. Public participation information is included along with the credits at the end of the video. This is Local Bias production # 172.
https://www.youtube.com/watch?v=ivbXCGAwKWw

Last chance for a Great River

Posted by on 10 Jul 2017 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Connecticut River, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, Federal Energy Regulatory Commission, FERC, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain Pumped Storage Station, PSP Investments, Rock Dam, The Greenfield Recorder, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Digger, Vernon Dam Fishway


The DEAD REACH of the Connecticut River just bellow Turners Falls Dam, 7/9/2017. (Click; then click again to enlarge)

NOTE: The following piece appeared in the Vermont Digger (www.vtdigger.org), The Daily Hampshire Gazette (www.gazettenet.com), and the Greenfield Recorder (www.recorder.com), in June.

Copyright © 2017 by Karl Meyer, All Rights Reserved

Last chance for a great river

It’s sink-or-swim time on the Connecticut River at Turners Falls for the National Marine Fisheries Service, the US Fish & Wildlife Service and the MA Division of Fish & Wildlife. Fifty years ago they signed the 1967 Cooperative Fishery Restoration Agreement for the Connecticut. It’s “Statement of Intent” was to pass “one million fish at Holyoke, 850,000 at Turners Falls, and 750,000 at Vernon,” restoring American shad to 86 miles of their spawning habitat upstream to Bellows Falls, VT. Back then a simple elevator at Holyoke Dam, 36 miles downstream, had already proven effective at passing shad upriver since 1955. Instead, the agencies opted for complexity.

Within a decade they decided to have three fish ladders built at Turners Falls, forcing all fish out of the river and into a 2.1 mile, turbine-lined power canal. That complex solution failed spectacularly. Deprived of a river route upstream, the runs withered while power company profits accrued. Instead of the 10,000 cubic feet per second flows needed for river habitats, they only required the power company to dribble 400 cfs over that dam. That also wrecked recovery prospects for federally endangered shortnose sturgeon at the Rock Dam, their ancient, natural spawning site just downstream.

Today these agencies are again on the hook to safeguard the river, and fish passage. They’re now taking part in potential backroom settlement negotiations at the invitation of PSP Investments, a Canadian venture capital outfit. PSP is the latest owner of the Turners Falls dam and canal. They also bought the Northfield Mountain Pumped Storage Station, now powered on imported, fossil-fueled megawatts that suck the Connecticut into reverse at Northfield, yank it up a mountain, and send it back down as peak-priced, secondhand electricity.

PSP, operating here as FirstLight Power, is bidding for a new Federal Energy Regulatory license for their new pension investments, where profits—and the river itself at times, will all flow north. PSP is bidding to withdraw 30% more water at Northfield for a third of the year, and get paid handsomely by ratepayers for the practice—whether they regenerate electricity with it or not. Positions taken by federal and state reps in these mandated non-disclosure, negotiations, will define this four-state ecosystem for decades to come.

On May 19th, an influx of ocean life not seen in 170 years occurred at the 1848 Holyoke Dam. In a three-day span, two elevators at its base lifted nearly two hundred thousand silver-green American shad toward spawning habitat in Vermont, New Hampshire and northern Massachusetts. Previous records were shattered. As the East Coast’s most successful passage, Holyoke has lifted as many as 720,000 shad in a season. Turners Falls has never passed more than 60,000 fish. For a full decade success there dropped to around 1-fish-in-100.

Two days after that burst of sea life through Holyoke, half those fish would’ve reached the brutal Turners Falls reach. There, confused industrial flows charge the river at all angles, and just a thin curtain of water is required to spill from the dam. Ultimately, every migrant was forced into the canal. Just a few would emerge upstream. For the rest, migration had ended abruptly—far short of rich upstream spawning grounds.

The run past Holyoke is this region’s last great migration–a pulse of planetary life, magical to witness. Each sleek, agitated shad is hell-bent on spawning as far upstream as time, energy, and luck allows. The few that found a way beyond Turners would have had little trouble following the river to the Vernon Dam. There, most could easily swim directly up a short ladder–passing the last hurdle toward that historic Great Eddy between Bellows Falls and Walpole, NH, 172 miles from the sea. Young spawned there would fatten on river-rich nutrients. Surviving adults could turn back toward the sea.

But Turners Falls has slammed the door on hundreds of thousands of others. Industrial currents, dead-end flows, and slack water offer no real path forward. The canal is their dead end. Ken Sprankle, the USFWS’s Connecticut River Coordinator, posts Holyoke fish passage numbers three times a week. Holyoke personnel happily provide them. Sadly, the MA Division of Fish & Wildlife long ago abandoned a daily presence at Turner Falls, leaving the power company in charge to pass along woefully outdated fish count numbers. By the time they reach the public its weeks past when any flow adjustments might have helped exhausted fish attempting to pass there.

Turner Falls is a black hole. There’s really no river there at all. New England’s Great River has long been owed its water–and the habitat and fish passage protections mandated by federal acts and a landmark 1872 Supreme Court ruling centered on the Holyoke Dam. Let’s hope fisheries representatives in backroom PSP talks don’t sell an ecosystem short again. Keep it simple. Fish need water and a river, and a direct route upstream–like at Holyoke and Vernon. This is the public’s river, not a cash cow. If the price gets too high, walk away. Future generations will know.

Karl Meyer of Greenfield is a member of the Society of Environmental Journalists. He remains a participating stakeholder in FERC relicensing proceedings for these sites. He is not attending these side-talks on settlements due to PSP’s mandatory non-disclosure requirements.

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Posted by on 17 Mar 2017 | Tagged as: Alex Haro, American Whitewater, Andrew Fisk, Bob Nasdor, Caleb Slater, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRWC, Dr. Boyd Kynard, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Holyoke Gas & Electric, John Warner, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Station, PSP Investments, public trust, Relicensing, Sean McDermott, Society of Environmental Journalists, The Nature Conservancy, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey

(Note: the following piece appeared in The Recorder, www.recorder.com, on March 11, 2017 under the heading: “Who will protect Connecticut River?”)

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Copyright © 2017 by Karl Meyer

Canadian investors are looking to purchase the Connecticut River for a few decades, cheap and quick. Canada’s Public Sector Pension Investment Board bought up the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex last year as part of PSP Investments. Their New England power play comes in the middle of the 5-year relicensing process for both facilities. That Federal Energy Regulatory Commission process will decide future conditions impacting this four-state ecosystem for decades.

The long-failed Cabot Station Fish Ladder on the Connecticut and competing flows flushing down the Turners Falls Power Canal’s Emergency Spillway. (Note:CLICK, THEN CLICK AGAIN TO ENLARGE.)

Thus, PSP may soon hold sway over what’s long been the most desolate 10-mile stretch of the entire Connecticut. It includes 2.1 miles of riverbed sitting empty for months at a time below Turners Falls Dam. It also includes the reach where, nearly 20 years back, federal fisheries expert Dr. Boyd Kynard found his boat being yanked backward—the Connecticut pulled into reverse by the suction of the Northfield Mountain Pumped Storage Station while he was drifting for bass a mile downstream near the French King Bridge. Looked at fully, it encompasses the entire reach where a 50 year federal migratory fisheries restoration program has long foundered.

On March 7th, after four years of meetings, thousands of pages of reports–and with volumes of study information incomplete and disputed, owners of these FirstLight-branded facilities are hoping select interests agree to take licensing talks underground. They’ll be fishing for backroom deals at a Boston area hotel well before this process has had a full public vetting. FL wants to take this little party private, fast. They’re asking invitees to agree to an embargo on public information about settlement talks, positions and decisions.

The key phrase in their invitation reads: “Because this meeting is intended to initiate confidential settlement discussions, it will not be open to the press or general public.” That’s FirstLight’s Director of Massachusetts Hydro Gus Bakas. His selected invitees include the National Oceanographic and Atmospheric Administration(Sean McDermott), US Fish & Wildlife Service(John Warner), US Geological Survey(Alex Haro), MA Fish & Wildlife(Caleb Slater), towns including Erving, Gill, Northfield, Montague, the Franklin Regional Council of Governments, The Nature Conservancy(Katie Kennedy), the Connecticut River Watershed Council(Andrew Fisk), and American Whitewater(Bob Nasdor).

That FirstLight stipulation is part of the quick-bait to get stakeholders thinking the time is right to cut deals. Sign-up, shut up; then we’ll talk. Cash out with what you can get for your agency, town, non-profit; or your fun-time rafting interests. Promises from this venture capitalist firm–in what’s become an ownership merry-go-round for these facilities, will surely all come true.

Ironically, many of these invitees descend directly from those who failed to step in and step up for the decimated river here decades back. They’re agencies and so-called watchdogs who failed to enforce laws and conditions negotiated when they were signatories to settlement talks for NMPS and Turners Falls nearly 40 years back–and for the 1999 FERC license negotiated for Holyoke Dam as well. At that site, Holyoke Gas & Electric just finally completed required improvements for endangered shortnose sturgeon last spring. Their license had mandated they be completed in 2008. Eight years, nine–no suits, no injunctions; no action.

Maybe that’s because the Watershed Council’s board chair works for HG & E, or because a significant number of board members are retirees from the region’s legacy power companies. Or, might it be because CRWC receives grant monies from National Marine Fisheries, US Fish & Wildlife, and MA Division of Fisheries, that these agencies were never taken to court for the withering spawning conditions and crippling flows experienced by federal trust American shad and federally endangered sturgeon in the reaches from Turners Falls to Northfield?

So who can our river look to for environmental protections under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act in the future?

Fourteen months remain in this relicensing. Key reports won’t be available until April, while other critical study information won’t be out until July. Some studies may need repeating. The best future for New England’s River will not be well served by quick-and-dirty agreements made in the shadows. Remember, Dear Stakeholders, it’s your names that will be forever associated with the conditions on a future Connecticut River—the river your grandchildren will be relying on. This is no time to sell the Connecticut short. What’s your price for a river’s soul?

Karl Meyer of Greenfield is on the Fish and Aquatics Study Team in the FERC relicensing for the Northfield Mountain and Turners Falls hydro facilities. He is a member of the Society of Environmental Journalists.

(Note: Bob Nasdor is former director of the Massachusetts Commission on Open Government.)

END

CAN NEW ENGLAND’S GREAT RIVER SURVIVE MORE DECADES OF PUMPED STORAGE GENERATION?

Posted by on 12 Mar 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Dr. Boyd Kynard, ecosystem, endangerd shortnose sturgeon, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Montague Reporter, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Vermont Digger, vtdigger.org, WBUR

NOTE: The following piece first appeared on the website of vtdigger.org in late February. It also appeared in print in the Montague Reporter, montaguereporter.org in early March.

Copyright © 2017 by Karl Meyer

Can New England’s Great River survive more decades of pumped storage generation? Long-term FERC licensing could lock out new river-sparing energy storage choices.

Dr. Boyd Kynard, retired federal expert on the Connecticut River’s migratory fish and endangered shortnose sturgeon, tells a story about bass fishing in Massachusetts around 1990. He was drifting near the French King Bridge, a mile downstream of the Northfield Mountain Pumped Storage Station’s subsurface tunnels when he glanced up and realized his boat had switched directions. It was being pulled upstream, “And at a pretty good clip.” Turbines at that Northfield MA plant had sucked New England’s river into reverse for at least a mile. This was nothing new, save that in this instance there was a daytime witness.

October 2, 2010, EPA ordered dredging at the site of Northfield Mountain Pumped Storage Station’s underground suction tunnels on the Connecticut.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

In December a radio feature from Boson’s WBUR entitled “New England’s Largest Battery is Hidden Inside a Mass. Mountain” was rebroadcast widely in the Northeast. Referencing Ben Franklin, James Bond, even the Bat Cave, it painted a rosy future for the 1200 quick-start megawatts stored in a reservoir at the Northfield Mountain Pumped Storage Station. Roaring turbines were noted as company spokespeople staked claim to the plant’s “green” future as they bid to lock-in a new 50 year Federal Energy Regulatory Commission license. The occasional ring of an old phone connected directly to ISO New England–the grid’s “independent system operator,” was described as “the sound of money.”

Altogether missing in that story was NMPS’s violent mining of the Connecticut River. That ecosystem artery was never identified as the sole water source enabling it to regenerate electricity. Prior to Northfield construction the Connecticut had forever run seaward from the Canadian border to the tidal zone near today’s Hartford, CT. But 12,000 years of New England natural history changed in 1972, on the day NMPS came on line.

On January 22, 1974, two years after it began operation using overproduced nuclear megawatts then available on the grid at night to fill a 5 billion gallon reservoir, the Federal Power Commission (today’s FERC) notified Western Massachusetts Electric Company it required their “earliest response” on Northfield’s impacts for a Draft Environmental Impact Statement: “Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows?” WMECO’s lawyers belatedly replied on October 16, 1974, they didn’t have the information. Questions about environmental impacts and reversing rivers went unanswered.

In 1967 a federal Connecticut River migratory fisheries program to restore American shad to historic upstream reaches in Vermont and New Hampshire got underway. That same year the embattled Connecticut River shortnose sturgeon was listed under the Endangered Species Act. Exactly fifty years later recovery goals for hundreds of thousands of spawning shad and thousands of shortnose sturgeon remain utterly unfulfilled. Spawning habitat access for both are impacted by Northfield’s suck and surge flows, which also create daily bank-eroding 4-foot “tides” along this reach, sometimes reaching to 10 feet.

Pictured in a less glowing light, NMPS is a 45 year-old dinosaur–a formerly nuclear-powered, net-loss energy transfer machine hacked out of the bowels of a mountain. With the region’s nukes now shuttered, it runs daily on imported electricity and has never produced a watt of virgin power. Today it’s a quick-start, high-profit operation relying on boatloads of fossil-fueled megawatts purchased in bulk on the wholesale market. Suctioning the river uphill, it later releases those waters down through its turbines in dense pulses—pumping out 25 percent less juice than the virgin power it consumes.

NMPS is not renewable energy, nor anything resembling the public’s idea of hydropower. It reproduces just a fraction of New England’s power at peak times, and peak prices, but can only generate for eight hours maximum. After that it is literally dead, its reserves spent. The Canadian-owned plant must then start consuming juice by reversing its turbines anew, yanking the river backward, sideways, and a mile uphill for hours into its reservoir.

That pumping occurs nightly at rates of up to 15,000 cubic feet per second. Picture 15,000 milk crates filled with a living river–every second for hours at a time. For more than two-thirds of the year the Connecticut’s “natural routed flow”—the water moving into and through this reach, is less than 15,000 cfs. Thus this plant is consuming more water than is entering the river. That’s how to turn an ecosystem on its head. The result is the evisceration of all manner of aquatic life, juiced twice through those turbines—tens of thousands of resident and migrating fish, millions of developing eggs, and their young. There’s nothing more violent you can do to a river.

Now the Canada Public Pension Investment Fund—latest in the decade’s revolving door of four different venture-capital owners of the FirstLight Power Resources-branded plant, is angling to lock those ecosystem assaults in place for another half century through the Federal Energy Regulatory Commission’s 5-year hydro relicensing process.

In its planning stages one model would’ve required Northfield to shut down during fish migration season due to impacts. That didn’t happen. Still, a chance experiment in 2010 gave a belated glimpse of those potential benefits. For half a year, from mid-spring through a hot summer into early November, NMPS sat broken, sanctioned and off-line. But seven miles downstream the migrating shad normally impacted by its violent suck-and-flush flows made great and unexpected gains in tandem with that spring break. Having languished for decades, the federal program to move American shad upstream into Vermont and New Hampshire saw a stunning boost at Turners Falls Dam. Shad passage jumped over 700 percent above the previous ten year average–16,440 shad swam past the dam in 2010, compared to the 2,260 annually over the previous ten years. Though meager, it was by far the best result since MA energy deregulation came to the NMPS reach of river in 1999.

The 5 billion gallon Northfield Mountain Pumped Storage Reservoir, as it sat emptied and idle from May 1st through early November 2010.
(CLICK TO ENLARGE, THEN CLICK AGAIN.)

On that May 1, 2010, NMPS had choked on the tons of silt and eroded riverbanks it constantly sucks into its reservoir. In attempting to clear that mucked-in lake a mile of mud-slumped tunnels resulted. Desperate, they began dumping it directly into the Connecticut at a rate equaling 30-40 dump truck loads a day. FirstLight’s sludge turned a mile of river brown for weeks. A contractor died when a suction hose broke loose.

One of thousands of dump truck loads of sludge the EPA ordered FirstLight to dredge back out of the Connecticut River. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Severe thunderstorms on May 27, 2010 resulted in tens of thousands of western New England power outages, many lasting for days. Yet as a back-up energy plant, Northfield’s sole output that week was more of the 45,000 cubic square yards of muck they’d eventually dump directly into the river. They succeeded for over 90 days, until they got caught. On August 10, 2010, the EPA issued a cease-and-desist order citing FirstLight for “polluting the navigable waters of the United States” under the Clean Water Act.

Major dredging operations continued for months at Northfield where FirstLight had dumped their sludge in the Connecticut for 90 straight days.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

Throughout NMPS’s half-year off-line–and record-breaking summer heat in the Northeast, the purportedly ever-hungry, ever-fragile grid ISO New England claims makes Northfield’s dense, quick-start functions so indispensible, never faltered or failed—not even when the nearby( now closed) Vermont Yankee nuclear plant went down in June to refuel.

NMPS’s main claim to its indispensability came 14 years ago during the 2003 August Blackout. Its quick start power was employed by ISO New England to smooth out Massachusetts’ reconnection to the New York sector of the Northeast’s mega-grid—which had failed due to a computer glitch in Ohio. That sprawling network would have been reenergized regardless, but Northfield’s dense energy provided a convenient assist and made ISO’s job easier. But are rare-hour emergencies enough to justify more decades of NMPS daily destructive use? In truth–what would amount to virtual energy storage monopoly, need not be locked-in, de facto, by FERC as this region’s energy future for decades to come. There are other options.

“Pumped hydro is the most cost-effective way to store electricity,” that story stated flatly. But in September of 2016 the MA Department of Energy Resources and the MA Clean Energy Center released a study: “Massachusetts Energy Storage Initiative: State of Charge.” It noted the Bay State lags behind in innovation and deployed energy storage, ranking 23rd nationally. However, comparing new storage technologies now available to the costs of pumped storage, it noted three that will all readily out-compete pumped storage costs by 2018: Lithium Ion, Flow Battery and Compressed Air Storage.

These local/regional storage solutions are already coming into use in New England. They create distributed generation and safer, more reliable micro-grids—less vulnerable to mass outages and mega-grid cyber attack and failure. They also create jobs. Certainly they are more attractive to consumers than sending local solar and wind across New England to recharge a river-crippling machine—and repurchase that juice later at inflated consumer prices.

That story mentioned Northfield’s 18,000 panel solar array–enough for a few hundred homes. But that tax-deductable FirstLight solar field actually covers the huge scar leftover from acres of EPA-mandated settling ponds—sludge pools required in 2010 when they had to dredge their mountain of muck back out of the river. Also not mentioned were handsome payments NMPS collects when it chooses not to generate any power. They accrue through a FERC mechanism known as “capacity fees.” If “spot market” prices aren’t sweet enough, FirstLight can simply sit their plant idle, collecting ratepayer cash just for their “capacity” to potentially generate. With NMPS as its chief hydro asset, former owner GDF-Suez once told investors 40% of its annual profits had been realized through capacity fees.

FirstLight’s EPA-ordered sludge settling pools and drying pile at the Rt. 63 site covered by a solar panel installation today. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Gus Bakas, FirstLight’s Massachusetts operations director, stated his goal for the 45 year-old plant is to someday see it running wholly on “green” power–solar and wind relayed to it from legions of regional rooftop panels and turbines. That would align with Massachusetts’ new “Energy Storage Initiative,” a 10-year effort purportedly aimed at saving ratepayers “hundreds of millions of dollars” while making the grid more reliable and reducing greenhouse gasses. But wind runs strongest at night and is not plentiful in western New England, while all solar is generated by day. With NMPS’s peak-demand profit model based on sucking up bulk power and the river at night, something seems missing from the equation. Unless there are now plans to again run the river backward by day, when migrating fish are most vulnerable to entrainment.

The Federal Energy Regulatory Commission is charged with supplying reliable electricity at fair costs to the public, while fostering competition and protecting against energy monopolies. All licensing decisions from FERC must also comply with federal law including conditions set under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act. The operation of NMPS continues to prove a stumbling block to the successful execution of these federal acts and policies.

In the near-term, for rare big-grid emergencies, a summer heat-wave or winter cold snap, NMPS remains a credible back-up tool. But Northfield otherwise continues today as an expensive, profoundly-damaging energy relay device whose net-loss operations chew apart a critical four-state artery daily. Given its violent year-round ecosystem impacts, its drag on federal trust and endangered species restoration programs–and the market’s current and emerging alternative energy storage solutions, FERC should not sanction NMPS long-term, as its dominant, de facto, New England energy storage monopoly.

End

Writer and journalist Karl Meyer lives in Greenfield, MA. He has been participating as a stakeholder and member of the Fish and Aquatics Study Team in the five-year FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. He is a member of the Society of Environmental Journalists.

Karl Meyer: Connecticut River power storage plant is an ecological, economic and energy disaster

http://www.wbur.org/bostonomix/2016/12/02/northfield-mountain-hydroelectric-station

Rolling over on a River: the real cost of pumped storage energy

Posted by on 26 Oct 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River ecosystem, Connecticut River Watershed Council, Daily Hampshire Gazette, ecosystem, Entrainment, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, federally-endangered shortnose sturgeon, FERC, fossil fuels, Greenfield Recorder, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, nuclear power, Public Comment period, public trust, pumped storage, Relicensing, shad, shortnose sturgeon, Society of Environmental Journalists, The Recorder, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vermont Digger, Vermont Yankee

Copyright © 2016 by Karl Meyer

(Note: this essay appeared in September and October in these MA and VT media and newspaper outlets: Vermont Digger, www.vtdigger.org ; The Daily Hampshire Gazette; and The Recorder.)

besttfemptybed

The de-watered CT below Turners Falls Dam that few people see. (Click, then click again to enlarge.)

Rolling over on a river

Since time began rivers have been the Earth’s arteries—the foundation of its ecosystems. Here in New England it’s “last chance” time for our Great River. On April 30, 2018 the fate of the long-foundered Connecticut River migratory fisheries restoration—and the survival of a four-state river ecosystem, will be decided for what’s essentially forever. New Federal Energy Regulatory Commission hydro licenses are expected to be signed then by government agencies and the Canada Pension Plan Investment Board–latest purchaser of the Turners Falls and Northfield Mountain projects. That company’s stated investor mandate is “to maximize investment returns without undue risk of loss.”

Over two generations ago public-trust mistakes were made favoring power companies, fish hatcheries, and high-end salmon-fishing interests that rendered eight miles of the Connecticut in Massachusetts a massively-suctioned, partially-dewatered flush sink. Sanctioned by fisheries agencies and non-profits, those decisions, severed an ecosystem in two. They forced all migrating fish into a deadly power canal, leaving three emptied miles of riverbed below Turners Falls Dam, while four turbines at the Northfield Mountain Pumped Storage Station five miles upstream consumed massive amounts of nuclear energy to suck a river backward and uphill to a mountaintop reservoir.

Those turbines were built to run on the promised endless supply of overproduced juice generated nightly at the local, now-closed, Vermont Yankee nuke, 15 miles away. Today, running on giant slugs of imported fossil fuel, they continue to spin, sucking the river up in endless gulps into a 4 billion gallon pool a mile up Northfield Mountain. That daily suctioning creates riverbank eroding “tides” higher than those at Hyannisport, MA—with some rivaling the ten-foot fluctuations of Fundy Bay.

Back then, predecessors of today’s National Marine Fisheries Service, the US Fish & Wildlife Service, Massachusetts’ Fish & Wildlife and the Connecticut River Watershed Council signed off on an agreement with the Federal Power Commission and Western Massachusetts Electric that strangled the river in northern Massachusetts. It resulted in the failure of migratory fish passage and a promised renewal of the river’s ancient seafood resources upstream to Vermont, New Hampshire, and northern Mass. Few American shad emerged alive after diversion into that canal. It also failed the shortnose sturgeon—this river’s only federally endangered migratory fish, leaving it without flow or monitoring at its only documented natural spawning site.

Upstream at Northfield the destruction was yet more complete. The suck and gush appetite of that nuclear-charged contraption virtually disassembled the river. It gulped flow at a rate of 15,000 cubic feet per second, often for hours at a time—drawing on the river pool above Turners Falls Dam where, 70% of the time, the Connecticut’s natural routed flow is less than 15,000 cfs. Boaters a mile downstream could find themselves drifting upriver via Northfield’s unearthly pull. All fish and organisms drawn up through the sphere of that suction were deemed “functionally extirpated”–dead to the ecosystem by virtue of being sieved twice through the turbines. It was evolution in reverse, a river ripped away from its eternal run to the sea.

Today, climate-blind FERC labels Northfield as a source of “renewable clean” energy—but there’s nothing clean, renewable or sustainable about its imported, twice-produced, peak-priced electricity crippling this river. ISO New England, FERC’s Northfield-cheering, ever-energy-hungry cousin, also ignores climate and its environmental dismemberment. “Pumped storage” is not hydropower—not even by the industry’s own technical terminology. Northfield-produced power in fact represents the heavy planetary burden of fossil fuel used to push a mountain of water uphill, merely as a weight to produce high-cost, second hand electricity. It cares nothing of rivers, fish or ecosystems.

If bureaucrats again fail the public trust and don’t demand critical habitat protections, flows, and the day-to-day monitoring needed to fulfill U.S. environmental statutes, Canadian pension speculators will be left as the de facto controlling interests on our river. The new owners have asked FERC to merge two separate licenses for Northfield and Turners Falls into a single new license dubbed the “Northfield Project.” What’s represented as mere bureaucratic streamlining would actually enshrine, by precedent–next time and forever, river-killing pumped storage.

Any responsible environmental agency should deny this single-license merger, and seek to have Northfield kept in use as emergency infrastructure only—with the ultimate remedy it’s dismantling in tandem with a move to a decentralized, far less vulnerable system than today’s expanding mega-grid. Massachusetts legislators are currently signing onto backroom energy deals for a glut of future hydropower from Quebec. Some 1,200 megawatts of those penciled-in imports could easily replace the few hours of daily juice Northfield puts out–while keeping it available for rare emergencies. Though the new Canadian power imports largely ignore conservation and innovation, they could be employed to end the river carnage here and begin restoring a future for a critical New England ecosystem.

(Note: timely public comment on licensing issues is carefully considered by FERC. Go to: http://ferc.gov/docs-filing/ecomment.asp and use “E-Comment.” Check “Hydro” and address to Secretary Kimberly D. Bose, using the required identifiers “P-2485” and “P-1889” for Northfield and Turners Falls.)

Karl Meyer lives in Greenfield MA. He is participating in the FERC relicensing process and is a member of the Society of Environmental Journalists.

Citizens win: back science and re-water CT’s Dead Reach

Posted by on 25 Jul 2016 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dead Reach, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, Federal Energy Regulatory Commission Chairman, FERC, FERC Chairman Norman C. Bay, fish passage, New Hampshire, Senator Bernie Sanders, shortnose sturgeon, Test flows, Turners Falls, Turners Falls dam, Vermont

P1000358
Flow through the DEAD REACH at Rock Dam, (click to enlarge).

**2016-07-19BERNIE SANDERS-FERC CHAIR BAY**

If you have a moment, CLICK and read the document **highlighted** immediately above and read carefully. NOTE: you’ll have to click, then click again in new window.

If you do, you will see a significant victory for the Connecticut River ecosystem. The Dead Reach of the river has been strangled by power company flows diverted out of the riverbed here for generations. Essentially, with just 400 cubic feet per second of flow mandated in the river below Turners Falls Dam for the last 44 years, the Connecticut has been left for dead when it comes to upstream migrants and endangered shortnose sturgeon each spring. Its been the great ugly secret of New England’s Great River for generations, kept quiet by fisheries agencies and watchdog groups alike.

But this year, when FERC relicensing study flows were proposed that would potentially destroy any chance of spawning success in the Dead Reach for the endangered Connecticut River shortnose sturgeon at Rock Dam, citizens stood up for published state and federal science, while fish agencies and NGOs stood on the sidelines.

The result: 40% more water was ultimately reintroduced into that desperately de-pauperized Dead Reach habitat throughout May and into early June–water that should have been demanded for fisheries protection decades ago. Instead of releasing just 1500 cfs into that reach, citizen input caused that number to be raised to 2,500 cfs as the minimum amount FirstLight would have to let flow through the ancient channel.

This was a victory for the river–and not one engineered by Senator Sanders(though his letter of inquiry was a welcome addition), who didn’t send his query to FERC until mid-June. FERC commenters were concerned folks from around the region. A close look at the files shows most were local Bay Staters simply looking out for their home river. They understood what you do when there is key information available: you don’t play politics; you stand up for good science.

This represents a victory for the implementation of long-range, public research findings taking precedence in the decision-making process on river flows. And it occurred despite any agency or NGO backing, or input.

Any increase in flows in this broken stretch of the Connecticut is a victory. However, 40% of very little, is simply not enough. That 2,500 cfs represents the ABSOLUTE bare minimum amount of water necessary just to have migratory fish move upstream upstream here, and allow sturgeon the possibility of remaining on their only documented natural spawning ground in this ecosystem to attempt reproduction. Much more flow is needed to restore this habitat, nourish passage of spring migrants to Vermont and New Hampshire, and allow shortnose sturgeon to successfully spawn and raise young, beginning their long road to recovery.

Politics and wimpy advocacy here, rather than solid science and public input, have been allowing the Connecticut to be run into the ground for generations now. This spring was a little different.

No “Springtime for Sturgeon in Holyoke…”

Posted by on 06 May 2016 | Tagged as: Connecticut River, Connecticut River ecosystem, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, Holyoke Fish Lift, Holyoke Gas & Electric, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Rock Dam Pool, shortnose sturgeon, Turners Falls, US Fish & Wildlife Service, USFWS

SHadFalls2MtTom
HG&E’s Holyoke Dam with Mt. Tom in background(click to enlarge)

No “Springtime for Sturgeon in Holyoke…” Unenforced FERC License continues the woes for the Connecticut’s only federally endangered migratory fish

Copyright © 2016 by Karl Meyer

For endangered shortnose sturgeon on the Connecticut River this year has been the best thing and the worst thing to happen to them since 1849. In an infinitely promising development over a dozen sturgeon(13 thus far)have found their way into the retooled Holyoke Fish Lift this spring—and all were lifted 30 feet toward upstream spawning habitats at the facility. However, in a most ugly turn of events for a creature listed under the Endangered Species Act since 1967, every one of those sturgeon was subsequently dropped back downstream by humans working there. They literally gained ten yards… after 167 years. Sorry kids, wait ‘til next year–or maybe the one after that.

In 2002 Holyoke Gas and Electric was issued a FERC license under which they were required to complete construction of a fish lift providing up- and downstream access for endangered sturgeon by 2008. FERC, responsible for enforcing those license requirements as well as the tenets of the ESA, failed to enforce their requirements, leaving those improvements unconstructed, year after year. The National Marine Fisheries Service, US Fish & Wildlife Service, and MA Division of Fisheries & Wildlife sat on their hands respecting their responsibilities to act. Nor did any so-called “watchdog” group fulfill their role–to make the enforcers enforce.

This was just the latest failure in a foundering Connecticut River ecosystem steered by money and politics rather than legal obligations, science, and enforcement of the public trust. Just consider that one of the Connecticut River Watershed Council’s Board Members has worked for Holyoke Gas & Electric at their fish lift for a decade… Then consider the resounding silence on enforcement.

This year–a full 9 springs beyond their license obligations, HG&E finally completed that mandated construction at the Holyoke Fish Lift. That says a mouthful about FERC, their licensing process, private industry, and whether anyone is actually protecting the public’s fish and river.

Grimly this spring, when the most sturgeon embarking on upstream spawning runs since the building of the railroads made it to the top of those South Hadley Falls, all were captured and “released downstream” of Holyoke Dam. This bit of brilliance comes via the orders—or lack thereof, of NOAA’s National Marine Fisheries Service. Their failure to act again denies any new genetic input into the tiny upstream population keeping this species’ flickering spark alive across the centuries up at their sole natural spawning site, the Rock Dam in Turners Falls.

Below Holyoke, generation after generation of these long-lived fish have been relegated to simply growing to maturity, repeatedly attempting to return upstream, and ultimately expiring without ever having the chance to pass on their genes. That goes back to the time of President Zachery Taylor.

In one very cruel act of fate, any shortnose sturgeon finding themselves downstream of the newly constructed Holyoke Dam in 1849, were forever barred from reaching their sole natural spawning site in the river system—that ancient Rock Dam pool in Turners Falls. What that has meant is that hundreds upon hundreds of these fabulously evolved fish–across more than a century and a half, have been relegated to the status of “reproductive nulls,” unable to spawn in their natal river system.

Pick your favorite bad actor in this failed scenario–there are a half-dozen choices.

Stakeholder PROTEST of FERC Revised Study Plan finding endangering Connecticut River shortnose sturgeon

Posted by on 07 Mar 2016 | Tagged as: Connecticut River shortnose sturgeon, Dead Reach, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Rock Dam, Secretary Kimberly Bose, US Fish & Wildlife Service, USFWS

(The following Stakeholder testimony was submitted to FERC on March 4, 2016)

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 March 4, 2016

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

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

PROTEST of FERC-sanctioned Revised Plan for Study 3.3.19, issued to FirstLight Power Resources, Inc, in a February 25, 2016 FERC letter to Mr. James P. Donohue of FirstLight, by Vince E. Yearick, FERC Director, Division of Hydropower Relicensing.

Dear Secretary Bose,

I protest the FERC finding issued on February 25, 2016 for P-2485 and P-1889 specifically because it sanctions test flows that are documented to cause spawning failure for the federally-endangered Connecticut River shortnose sturgeon (Acipenser brevirostrum) at its only documented natural spawning site, the Rock Dam, in the Connecticut River. FirstLight has proposed and FERC has accepted Study Plan test flows of 1500 cubic feet per second in the CT River’s By Pass Reach for April, May and June 2016. That low level of flow will displace and wipe out a full season’s spawning and rearing of Young of Year life stage SNS at their ancient Rock Dam nursery site.

Though my FERC Stakeholder comments of January 28, 2016 specifically addressed this ESA issue, FirstLight did not respond to the endangerment issue in its RSP revisions. Further, I had made this issue clear to FirstLight and its agents, FERC staff, and key stakeholder agencies in an email delivered on January 20, 2016. I again reiterated the endangered species impacts to those same parties in an email delivered on February 24, 2016. Madam Secretary, I again made my concerns about spawning interference and failure to you and for the FERC record in a letter delivered February 26, 2016. All are available for perusal in the FERC record for P-2485 and P-1889.

Shortnose sturgeon gather at this spawning and nursery site annually between April 22 and May 25 for pre-spawning and spawning. Further, the complex of key biological characteristics of flow, varying depths, and cobble/sand habitat provide SNS with protective options that nurture developing Young of the Year throughout June into July.

According to 17 years of published studies at that site documented by Dr. Boyd Kynard and research colleagues, a continuous minimum flow of 2500 cfs is required to protect sturgeon spawning and rearing at this site. Therefore, I PROTEST the findings of the FERC Revised Study Plan determination issued by FERC on February 25, 2016, and request that only continuous protective minimum flows of 2500 cfs be allowed in this study, and throughout the 2016 SNS spawning and rearing season, as well as all ensuing springs.

The following publication has been referenced in the FERC ILP for these projects by both federal and state stakeholder agencies, FERC, as well as FirstLight and their agents.

“LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEONS, 2012, by Boyd Kynard, Paolo Bronzi et al, World Sturgeon Conservation Society: Special Publication # 4

“Effect of hydroelectric operations on spawning”

Page 101, bottom: “During the 11 yr spawning failed (excluding the failed migration in 2002), when discharge levels were too low for 5 yr and too high for 4 yr. During one yr (2007), discharge during April was both to low and too high. When spawning failed at RockD due to low discharge during 4 yr (1995, 1998, 1999, and 2006)m discharge decreased to <70 m3 s-1 for at least 4 d by 30 April (Fig. 14), the earlier period of low discharge likely marked a threshold making the RockD unattractive to spawning fish.”

Further published data, tables, and required flows necessary in this reach appear on pages 101-102 of LIFE HISTORY AND BEHAVIOUR OF CONNECTICUT RIVER SHORTNOSE AND OTHER STURGEIONS.

I would welcome a FERC hearing on this critical ESA issue and would make myself available for testimony. Thank you for your attention to this pressing matter.

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

Cc’d via email to:
Brandon Cherry, FERC
James Donohue, FirstLight
Julie Crocker, NOAA
John Warner, USFWS
Caleb Slater, MA Division of Fisheries & Wildlife

FERC sanctions crippling flows for federally-endangered Connecticut River shortnose sturgeon

Posted by on 01 Mar 2016 | Tagged as: 5-year FERC licensing process, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, NOAA, US Fish & Wildlife Service

The following Stakeholder Comments concerning proposed study flows that will wipe out this season’s spawning for federally-endangered Connecticut River shortnose sturgeon at their only documented natural spawning site in the river system were submitted to FERC Secretary Cheryl on Friday, February 26, 2016. They include comments submitted on Wednesday, February 24, 2016 to FERC staff, federal and state fisheries agents responsible for endangered species protection, and FirstLight–who proposed to include the crippling 1500 cfs(cubic feet per second) flows in FERC-ordered Study 3.3.19.

On Thursday, February 24, 2016, Vince E. Yearik, FERC Director of the Division of Hydropower directed FirstLight’s James Donohue that the ruinous 1500 cfs flows will be allowed at the Connecticut River shortnose sturgeon’s only documented natural spawning site in the spring of 2016.

My Stakeholder Comment letter, on the FERC official record for P-2485 and P-1889, is directly below.

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 February 26, 2016

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

RE: P-1889 and P-2485

Dear Secretary Bose,

The comments below respecting federally-endangered Connecticut River shortnose sturgeon and Study 3.3.19 were delivered via email to GDF-Suez FirstLight�s James Donohue, FERC staff including Brandon Cherry, and Caleb Slater(MA), Julie Crocker(NOAA), and John Warner(USFWS) on 2/24/2016.

Thank you,
Karl Meyer

Dear Chris et al,
I commented to you and in the FERC record on your RSP for Study 3.3.19, the Ultrasound Study in P-2485 and P-1889, to repel fish from Cabot Tailrace. Since I was somehow left off the email list in the �call for comments� that went out on 2/11/2016, I will take the opportunity to comment at this time.
In your newly-revised RSP you failed to reply to this comment of mine in particular:

�The final week should be at a minimum of 2,500 CFS�which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 � May 22, in order to not interfere with the spawning of a federally endangered species at Rock Dam. In their response, FL cited �Kynard� et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required there throughout the month of June.�

FirstLight has now indicated it intends to use test flows including 1500 cfs in its Ultrasound Study. This is unacceptable, as data shows this will harm a federally endangered species, the Connecticut River shortnose sturgeon. FirstLight has cited Kynard, Kieffer et al; Life History and Behaviour of the Connecticut River shortnose and other sturgeons, in their official FERC comments. Both FERC and the agencies are in possession of the scientific study data contained therein. An examination of Chapter 3 and the �Effects of hydroelectric operations on spawning� makes it quite clear that 2500 cfs is the minimum continuous flow needed to allow females to sustain a presence at the site and complete successful spawning. Flows go below that level�and 1500 cfs is far below that required threshold, will cause sturgeon spawning to fail.

A continuous flow of 2500 cfs is the only protective flow that should be allowed in the Ultrasound Study�it is also necessary throughout the month of June to protect the Early Life Stages of shortnose sturgeon. Please make the required modifications, as I�m certain the agencies and FERC will not give you license to run afoul of the federal Endangered Species Act, as well as similar state statutes.
A review of the FERC record, as well as your proposed Revisions for 3.3.19 are included below. Thanks.
Best,
Karl Meyer,
Fish and Aquatics Study Team

In 2015, FERC agreed with FirstLight and rejected requested snorkeling studies to determine the fish assemblage in the By Pass Reach out of an abundance of caution for impacts they might have on federally-endangered shortnose sturgeon whose only documented natural spawning site is the Rock Dam Pool in that reach.
Though the record clearly misstates that that snorkeling survey request was for the By Pass Reach downstream of Turners Falls Dam�written as �downstream of Cabot Station�, the protected status and determination to �do no harm� was quite clear in FERC�s reply. Excerpts from FERC Staff directly below.
From 01/22/2015, FERC Study Modifications Determination Letter

Study 3.3.11 – Fish Assemblage Assessment
�Requested Study Modifications

The U.S. Fish and Wildlife Service (Interior) proposes modifying the study to require FirstLight to conduct snorkeling surveys in the reach downstream of Cabot Station, in order to avoid all effects on shortnose sturgeon during the spawning season. The Nature Conservancy and Karl Meyer support Interior�s proposed study modification.

Comments on Requested Study Modifications

To avoid all effects on shortnose sturgeon during the April-June period in the reach downstream of Cabot Station, FirstLight states that it will rely on sampling from the project impoundment, sampling of the reach downstream of Cabot Station during other times of the year (after June 30), and existing data from a 2009 electrofishing survey of the area downstream of Cabot Station.

Discussion and Staff Recommendation

The goal of this study is to provide general information on fish species that are present in the impoundment and in the river downstream of the dam and Cabot Station. Based on the description in the modified study plan, FirstLight�s proposed method will provide information on species occurrence, species distribution, relative abundance, and habitat associations that will adequately describe the existing fish community. Because FirstLight�s proposed methods would achieve the goals of the study while avoiding effects on spawning sturgeon, we conclude that snorkeling is not necessary and the study plan filed with the ISR should be approved without modification.�

And�FirstLight�s current revised flow plan for 3.3.19:

�This study would establish a high frequency sound (ultrasound) array across the entire Cabot Station tailrace and determine the effect of the ensonified field on upstream migrating shad moving by Cabot Station. Bypass reach test flows during the study will include flows of 1,500 cfs, 2,500 cfs and 4,400 cfs. These flows will be released depending on river flow conditions. When possible, flows will alternate with the array on for one day then off for one day at 1,500 cfs, followed by one day on and one day off at 2,500 cfs, then one day on and one day off at 4,400 cfs. This sequence will be repeated throughout the study depending on river flow. The field study will include two components: a) DIDSON count of shad entering the Cabot fish ladder and b) detection of telemetered adult shad to determine their movements after they encounter the sound field.�

FERC Stakeholder comments: Turner Falls Canal ultrasound study

Posted by on 06 Feb 2016 | Tagged as: American shad, Cabot Station, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, Northfield Mountain Pumped Storage Station, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shad, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
January 28, 2016

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

RE: P-1889 and P-2485, ILP for Turners Falls/Cabot Station and the Northfield Mountain Pumped Storage Project

Dear Secretary Bose,

The following comments pertain to an RSP and failures on the part of FirstLight Hydro Generating Company in following FERC’s SDL on Study 3.3.19 and Study 3.3.2. They were shared with FirstLight’s team and FERC’s Brandon Cherry on January 20, 2016:

As one of the requesters for an ultrasound study at Cabot Station, here are my comments, suggestions and observations for ways to gain the best applicable results from Study 3.3.19-Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.

Unfortunately, FirstLight has not provided Stakeholders with any preliminary findings from the telemetry data gathered in Study 3.3.2, which would be a great help in addressing any changes or improvements needed for a successful 3.3.19 Ultrasound Study.

As stated in their Study Determination Letter under Discussion and Staff Recommendations, FERC was very clear that 3.3.2 information on: (1) “delay,” (2) “bypass flows,” and (3) “effects of Station 1 operations on upstream shad migrations,” be brought over and included in the design recommendations for 3.3.19:

“These evaluation data can be used to inform the methods and design of this study (e.g., ultrasound array design, layout, and placement; array testing at appropriate bypass flows) (section 5.9(b)(6)).”

FERC further stated in their SD Letter to FirstLight, “The amended study 3.3.19 should address stakeholder comments and recommendations. If FirstLight does not adopt a recommendation, FirstLight should provide its reasoning based on project-specific circumstances (e.g. Study 3.3.2 results).”

Revised Study Plan 3.3.19 ignores FERC’s guidance on the inclusion and application of “bypass flows” and “effects of Station 1 operations on upstream shad migrations” in its design. Neither key issue is addressed in their proposal. Bypass flows, which are key to any application of acoustic guidance to keep shad moving upstream in the Bypass, are not included at all. Stakeholders originally requested this Study be done for two years, with bypass flows tested throughout.

Further, the only mention of Station 1 is in a footnote, without any reference to testing its effects “on upstream shad migration operations.” FirstLight merely notes that hourly data on discharges at that site will be included—with no insight on how that data would be applicable if fish are not monitored for migratory delay, with and without flows, emanating from that site.

Since the thrust of the Study is aimed at getting fish up through the Bypass, I question why just three monitoring sites are suggested to be deployed upstream of Cabot Station itself.

• Sonic guidance at Cabot should be deployed in such a way that it encourages upstream movement as much as possible—and avoids biasing fish movements toward downstream retreat. It should also be deployed in a way that, when in ON mode, it also ensonnifies the entrance to Cabot Ladder, as the thrust of the study is to have fish avoid the power canal.

• Ensonification should NOT be engaged in two hour increments, as this would likely be a source of stress and disorientation for fish. Employ the tests in 24 hour cyles, one full day on, one full day off.

• Data should also be provided on the hourly operation and number of gates open at the Emergency Spill Gates off the Canal at Cabot.

• I’d suggest removing the monitor upstream of the mouth of the Deerfield and placing it at the Rock Dam pool, a site where shad–and anglers have a historic presence in the Bypass. The agencies, as well as the anglers, are concerned with finding out where fish gather and stall in this reach on their way northern MA, VT, and NH.

• Another monitor needs to be placed at Station 1, another known fishing site. I interviewed a fisherman there last year with Station 1 running. There were scores of fish visible, treading water in the outflow. He flatly said there are “always shad here” when Station 1 is generating.

• Station 1 should be monitored and switched On and Off in tandem with the Cabot ensonification to highlight impacts, false attraction, drop-backs to Rock Dam and elsewhere, and delays.

• Flow data, hours and number of units in operation, and any interruptions in flow at Station 1 should be included in the Study.

• Several more monitors need to be deployed at the Dam and the Spillway entrance to capture the early, freshet aggregation of fish there—as this is what’s at the core of this study.

• Given that this study will only have one sampling season, it is vitally important that it has enough reach to be applicable for informing a hydro-relicensing that may remain in place for two decades. One month testing and data collection is needed at minimum.

• Further, given the “drop out” rate for handled fish, the number of tagged fish included from FirstLight’s consultants should be doubled to 200, in order to have an acceptable sample entering the project reach.

• Test flows from May 15th through mid-June: two weeks at 5,000 CFS; third week at 4,000 CFS. The final week should be at a minimum of 2,500 CFS—which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 – May 22, in order to not interfere with the spawning of a federally endangered species and be subject to court action. In their response, FL cited “Kynard” et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required throughout the month of June.

Thank you,
Karl Meyer, Fish & Aquatics Study Team

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