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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

VERNON UPDATE: A peek into the public-trust’s black hole

Posted by on 26 Jun 2016 | Tagged as: American shad, Connecticut River, Connecticut River Coordinator, FirstLight, fish counts, fish passage, Fish passage results, GDF-Suez FirstLight, MA Division of Fish and Wildlife, public trust, TransCanada, US Fish & Wildlife Service, USFWS, Vermont Fish & Game, Vernon Dam Fishway

VERNON, VT Connecticut River Fish Passage Update: June 24, 2016

DSCF8559

Vernon Dam Fishway, and TransCanada’s Vernon Station(CLICK TO ENLARGE)

As of Friday, June 24, 2016, the best information US Fish & Wildlife Service was able to provide on Turners Falls and Vernon fish passage was a FULL THREE WEEKS OLD.

The last report CT River Coordinator Ken Sprankle had for Vernon shad passage was from June 3, 2016: 29,155 American shad passing there.

The last report coming from FirstLight at Turners Falls was yet a day older, from June 2, 2016: 45,330 American shad.

This is not a case of the USFWS’s Connecticut River Coordinator neglecting to gather the information and reproduce it in a timely manner. This falls squarely on the shoulders of the MA Division of Fisheries and Wildlife failing to ensure that this time-sensitive and important information is provided to Commonwealth citizens as part of their public trust. They have allowed GDF-Suez to maintain sole control and access to the fate of a public resource at Turners Falls, the river’s most critical and failed fish passage site.

Further, it must of course be stated that Vermont Fish & Game is in the same camp this year. As they are failing to provide this information–just a quick 20 mile, one-day scoot for a shad upstream to Vernon Dam, where TransCanada is calling the shots on providing info.

These state agencies are failing constituents they say they represent.

BUT here’s a tiny fish passage update for Vernon Dam. It’s just TWO DAYS OLD. I stopped by Vernon on my bicycle on Friday, June 24th at 10:30 a.m., just hours after that “best” stale information had been released.

Given low river flows I was happily surprised to see shad moving upstream in the Vernon windows at a good clip. Singly, and in twos and threes, and fives, I watched 20 American shad flash by and shoot upstream through bubbly, yellow currents there in just under six minutes. That fishway is a fish passage site that actually passes fish–with a nearly 70% passage rate last year.

Of course, Turners Falls fish passage remains a disaster, with all fish shunted out of the river and into the 2.7 mile power canal there: average annual passage rate is less than one fish-in-ten. And, unfortunately, Turners Falls viewing opportunities have been severely curtailed over the years. Whereas they used to be open through the week following Father’s Day, this year they closed on June 12. Thus, there is literally no on-site public access or real-time information provided on fish passage success at Turners Falls–while this year’s run is obviously still underway, given Friday’s eye-witness access at Vernon.

At Turners Falls flows have been reduced to 1500 cubic feet per second over the past weeks, and with FirstLight’s downstream Station 1 dumping attraction flow into the Connecticut, its unlikely many fish are moving upstream and able to by-pass that alien power canal habitat.

DSCF8552
The Connecticut below Turners Falls Dam (CLICK TO ENLARGE)

Station 1 is a source of “false” upstream flow “attraction”–which can keep shad treading water for days at a time without finding any real route upstream.

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Station 1 attraction flow (CLICK TO ENLARGE)

FISHY MISSING INFO

Posted by on 22 Jun 2016 | Tagged as: blueback herring, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Daily Hampshire Gazette, FirstLight, fish counts, Fish passage results, GDF-Suez FirstLight, Greenfield Recorder, MA Division of Fish and Wildlife, migratory delay, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, public trust, right-to-know, salmon, salmon hatchery, sea lamprey, shad, The Recorder, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, USFWS, Vermont, Vernon Dam Fishway

The following OpEd appeared in the Daily Hampshire Gazette (Northampton,MA) and The Recorder (Greenfield, MA) in early June.

Fishy Missing Info Copyright © 2016 by Karl Meyer

DSCF8552
(low flows and byzantine fish ladder at Turners Falls 6/19/16:CLICK TO ENLARGE)

I’d like to change the name of a Commonwealth agency. What would you think about the Massachusetts Division of “Manufactured” Fisheries and Wildlife? I think it would offer a much better picture of the Agency’s focus, particularly here in the Connecticut Valley. Here you can get daily on-line information on where to find truckloads of thousands-upon-thousands of factory-produced rainbow, brown and brook trout before they are dumped into local rivers for hatchery-fish angling pleasure. But I dare you to find anything more than a several-weeks-old tally of the numbers of wild migratory fish streaming north here on the Connecticut anywhere beyond the fish windows at Holyoke Dam. So this would be a “truth-in-labeling” adjustment.

New England’s Great River runs for 69 miles through the Commonwealth. The MA Division of Fisheries & Wildlife is responsible for all migratory fish in that broad reach from the time they enter at Agawam, until they either remain here for spawning, or pass into Vermont and New Hampshire. Those runs are the agency’s “public trust”—to be protected for its citizens, anglers, students and future generations. But the less information the public gets on their whereabouts, the less an agency might be availed upon to actually protect them.

As we enter the final weeks of migration season the only information provided—not just days old, but nearly a month stale, refers solely to fish on the first 16 miles of river from the Connecticut border to the fish lift at Holyoke Dam. That leaves a full 52 miles of river with just a single—now uselessly outdated May 4th report about the truly wild shad, lamprey and herring now moving along New England’s flagship waterway. Salmon are not mentioned here because just three years after the US Fish & Wildlife Service stopped factory production of this hybrid, just a single salmon has been tallied. Hatchery fish production masks the reality of failing wild populations and deteriorating habitats. To date there’s been but one report on fish passage from Turners Falls.

As an interested citizen I’m a bit outraged that it’s June 1st, and I don’t have a clue about what’s going on with the wild, migrating fish coming upriver in what you have to consider as one of New England’s last remaining great migrations. Shad, blueback herring, and sea lamprey have been moving upstream for over two months now, and the only public information offered is of the absurd 54 shad counted at Turners Falls, almost a full month back. Really? This is any agency with an accountability problem.

MA DF&W has scant little to offer the public as to what they’ve been doing on the ground to protect our wild fish runs—and that includes struggling populations of state-listed, endangered shortnose sturgeon, also under their purview. But to not even take responsibility for having on-the-ground personnel monitoring runs at the river’s long-known choke point, Turners Falls, is a flagrant abdication of duty. Here in central and northern Massachusetts we not only don’t see fish because of decimated Connecticut River habitats, we aren’t even offered updated tallies on the ugly mess. But perhaps that’s by design. Connecticut’s state fisheries agency regularly provides more information on Commonwealth fish runs than does the MA DF&W.

When I recently contacted the Commonwealth’s Anadromous Fish Project Leader to inquire about fish passage information at Turners Falls, he tersely emailed back that the state no longer does those fish counts: I should contact FirstLight Power for information. I guess our fish are now fully privatized. And when it has come to the power company requesting larger and more frequent water withdrawals on the Connecticut upstream at the Northfield Mountain Pumped Storage Station, it appears the Division has never seen a company proposal it wasn’t just fine with.

This 2016 season has literally been the worst year for Massachusetts fish passage information since 2010, when FirstLight’s Northfield Mountain broke down, fouling its pumping tunnels with 45,000 cubic square yards of reservoir muck. They didn’t operate from May – November and fish passage at Turners Falls–it was subsequently revealed, had jumped 600-800% above yearly averages. We didn’t get that information until late as well. Seem a little fishy to you?

Some of us actually care about wild fish and living rivers. And, frankly, if I were reduced to thinking that following a truckload of factory fish to its dumping site for a day’s angling was a wildlife experience—well, I’d just as soon get one of those wind-up fish carousels you can hold–the ones with the tiny plastic pole and the revolving, yapping fish mouths. The Massachusetts Division of “Manufactured” Fish & Wildlife–sounds about right where wild fish and the Connecticut River is concerned.

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

DEAD REACH REPORT: the BLACK HOLE continues…

Posted by on 09 May 2016 | Tagged as: American shad, blueback herring, Connecticut River, Dead Reach, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, GDF-Suez FirstLight, Greenfield Community College, Holyoke Community College, Holyoke Fish Lift, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Rock Dam, Rock Dam Pool, sea lamprey, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vernon Dam Fishway

DEAD REACH REPORT: the BLACK HOLE continues…

Copyright © 2016 by Karl Meyer
P1000522

Forty-one days after the first fish were reported being lifted at Holyoke Dam, we still have not a shred of information on fish passage in the Connecticut River’s Dead Reach at Turners Falls. That’s the beleaguered, half-emptied, 2.7 miles of riverbed that all migrating American shad, sea lamprey, and blueback herring must pass in order to make progress toward Vermont and New Hampshire spawning grounds. Within that Dead Reach is the Rock Dam, the only documented natural spawning site for endangered shortnose sturgeon in this river system.

Thus, again, GDF-Suez FirstLight continues in sole control and possession of information on the public’s federal trust migratory fish—every one of which, in trying to reach upstream sites, gets diverted into their turbine-lined power canal. Once corralled and essentially privatized in that miles-long trench, very few ever emerge alive beyond Turners Falls Dam.

Holyoke Fish Lift numbers have been handed off daily to Ken Sprankle, USFWS’s Connecticut River Coordinator, for weeks now. Students from Holyoke Community College are staffing that site, overseen by the MA Division of Fisheries & Wildlife. MA Fish & Wildlife is responsible for those shad, lamprey and herring while they are traversing the Commonwealth’s reach on the Connecticut. They’re responsible for getting the public’s fish counted as well. That role up at Turners Falls is clearly not working or being taken seriously. We have no information from there whatsoever–with the video-counting apparatus controlled by FirstLight, and the review, tallies, and the hand-off of that public information left in the hands of Greenfield Community College students.

None of this speaks well for any safeguarding of the public trust.

Nevertheless, USFWS’s Ken Sprankle did provide these updates from Holyoke Dam this morning. Fish counts there as of Sunday, May 8, 2016 are: 32,937 American shad; 239 sea lamprey; and 14 federally-endangered shortnose sturgeon—all of which were brought to the top in the fish elevator, lifted out, and dropped back downstream. Virtually none of them will get an opportunity to spawn yet again this year.

To give you a sense of the miseries, one egg-laden female lifted up there had been tagged in the Dead Reach in Turners Falls 2004, as a female on a spawning site. This year, a dozen years after that tagging—she was apparently full of eggs and attempting to reach the Rock Dam for spawning once more. They plopped her back downstream on orders of the National Marine Fisheries Service. If that aging female dies over the winter, the genetic material in the hundreds of thousands of eggs she was carrying gets lost to eternity, and becomes yet another signpost on extinctions path.

Just what exactly is being accomplished by not letting these endangered fish spawn?

Meanwhile, here’s a tiny Dead Reach report of my own. I stopped by the TF Dam at mid-morning on Mother’s Day. It was drizzly, water was spilling from Bascule Gate 1(Turners Falls side), and no one was fishing at the site.

Downstream at 9:40 I met a lone angler exiting from the Rock Dam pool site at Cabot Woods. He said he’d had a few, earlier, but that it was slowing down. When I went out to the Rock Dam it was fairly quiet, with the water only moderately clear with the recent rain. Still, looking down from the rocks, schooling swirls of shad can sometimes be seen when the light is good. I saw nothing. Nor did I note any lamprey tails slapping the rock faces as they suctioned their way upstream through the notches.

According to this angler who fishes the mouth of the Deerfield as well, Rock Dam fishing on Saturday was pretty decent: “I had a dozen shad,” he noted. Thus, it’s become fairly obvious these last two springs that when flow is left in the riverbed, Rock Dam is one of the finest shad fishing sites on the Connecticut.

So, American shad have been reaching Turners Falls for 5 weeks now, we just don’t know how many are passing upstream—and we have yet to get count information from TransCanada about numbers passing Vernon Fishway. Thus parts of Massachusetts and all of Vermont and New Hampshire remain in the dark as to the whereabouts of their share of the ocean’s spring bounty.

Holyoke Fishway opened last week. You can visit, Weds. – Sunday from 9 – 5. Its on the CT, where Rt. 116 crosses into Holyoke from South Hadley. The public fish viewing facilities at Turners Falls have yet to open.

INFORMATION BLACK HOLE on the Connecticut

Posted by on 05 May 2016 | Tagged as: American shad, Connecticut River, federal trust fish, FirstLight, GDF-Suez FirstLight, Greenfield Community College, Holyoke Community College, Holyoke Fish Lift, Jack Buckley, MA Division of Fish and Wildlife, New Hampshire, Northfield Mountain, shad, shad fishing, Station 1, teachers, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole, Wendi Weber

P1000385

INFORMATION BLACK HOLE

Copyright © 2016 by Karl Meyer

On this May 5th, 2016, they have no idea in Sunderland–or in Deerfield for that matter. Nor do they know anything in Greenfield, Turners Falls, Gill, Northfield or Millers Falls. Upstream, Vermont folks in Vernon, Guilford, Brattleboro and Putney don’t have a clue. Across the river, New Hampshire people in Hinsdale, Chesterfield, Walpole and Charlestown remain in the dark.

What these towns all have in common is that nobody can tell them anything of the whereabouts of their share of the spring American shad run. The fish have been in the river and upstream of Holyoke for a full five weeks now, and there hasn’t been a single fish count provided from the Greenfield Community College students hired by GDF-Suez FirstLight to monitor fish passage at Turners Falls. An accounting of the public’s fish remains in the hands of a private company—and, as I’ve said before, many or most are likely struggling to survive a trip through their private power canal.

For a migrating shad, the 36 mile swim from Holyoke to Turners Falls is a walk in the park. It’s a day—maybe a day-and-a-half trip, ostensibly on the way to spawning habitats in Vermont and New Hampshire. But thousands of the public’s fish have gone missing on the Connecticut River this spring. And it seems no one can say exactly where they are. If you had to make an educated guess, you could surmise many are somewhere between Greenfield and Turners Falls, with many not in the actual river at all.

A significant number are fighting currents in the debased habitats of the Turners Falls power canal, where murky flows delay most by over a week before they even approach the site that could route them past the dam. Others are in the river, trying to find a path to the base of a fish ladder whose construction back in 1980 was based on Pacific salmon. And still others are sidetracked and stalled in the riverbed like sardines, expending precious migratory and spawning energy in front of the ramping outflows at a mini overflow power site known as Station 1. Wherever those fish may be, we do know that, on average over time, just 4% of those shad ever make it beyond Turners Falls Dam toward Vermont and New Hampshire. In the very few “good” years, one fish in ten wriggles upstream.

We also know that the first two American shad were lifted past Holyoke Dam five weeks ago. As of May 4, 2016, some 25,000 had been passed upstream at the Holyoke Fish Lift. What happened to them next is anyone’s guess. Once they pass Holyoke, accounting for them is left in the hands of a private power company—currently GDF-Suez FirstLight Hydro, now going under the corporate aegis Engie. These are the folks responsible for passing the public’s fish at Turners Falls Dam, and giving public accounts of fish passage for anglers, teachers, the general public, and the state and federal fish agencies.

It’s been documented that at least half of all the shad passing Holyoke will attempt to pass Turners Falls. It’s wholly possible the actual number is significantly higher. It matters little though, as all fish get diverted into the Turners Falls Power Canal once they attain this easy upstream reach, and only that average of 4% make it past the TF Dam. The rest simply go unaccounted for once they arrive and are tempted into that turbine-lined pit.

Five full weeks since fish have been heading upstream, and that includes sea lamprey as well. Yet we still do not have a single fish passage update at Turners Falls. What’s wrong here? Who is responsible?? Well, obviously FirstLight GDF-Suez is responsible. But, nobody is holding them to it. These fish, while moving through Massachusetts, are the responsibility of the US Fish & Wildlife Service. But, while here, they in large part fall under the responsibility of the MA Division of & Wildlife. Why aren’t they ensuring the public gets daily fish updates—like those that have been available at Holyoke Dam for years? Again, go fish…

At Holyoke Dam there are actually humans on-site that can witness real-time conditions, fish passage, and provide the needed public info in a timely manner. These come via students from Holyoke Community College. Not so at Turners Falls, where the Commonwealth has largely left responsibility for the chicken coop up to the fox. All monitoring is done remotely by video, with equipment provided by FirstLight. Prior years show repeated equipment failures. And then you have to wait—often many WEEKS, before those videos are handed off and analyzed by GCC interns. Its only then that we are treated to weeks-out-of-date info about where our fish are.

This privatization needs to change. Wendi Weber, Region 5 Director at the USFWS might be able to help. Or MA Division of Fish & Wildlife Director Jack Buckley. Or, perhaps, MADFW’s Caleb Slater, Anadramous Fish Passage Project Director. The guy at FirstLight responsible if Bob Stira.

As a side note: many other states have actuarial tables that put specific monetary values on migratory and resident fish. Then, if they are killed in project operations, or fish do not reach their spawning grounds, the public is reimbursed for the ecological damages.

Updated HOLYOKE fish counts can be accessed at:
www.fws.gov/r5crc under Recreation.

Connecticut River Dead Reach Update: April 29, 2016

Posted by on 29 Apr 2016 | Tagged as: American shad, Connecticut River, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FirstLight, Holyoke Fish Lift, National Marine Fisheries Service, National Marine Fisheries Service, Turners Falls, Turners Falls dam, Turners Falls power canal

Connecticut River Dead Reach Update: April 29, 2016

SHAD PASSAGE UPDATE: Holyoke Fish Lift passed its first American shad upstream on April 1, 2016. Normally, that would signal the opening of the fish ladders upstream at Turners Falls Dam.

Migrating shad take less than 2 days to swim the 36 miles up to Turners Falls Dam, the next barrier on the Connecticut as they attempt to head to northern MA, VT and NH.

Unfortunately there is so little water left in the riverbed when they arrive at the 2.7 mile Dead Reach between Greenfield and Turners Falls, that the vast majority never make it past that dam.

As of April 24, some 7,100 shad had passed Holyoke.

This year, due to lack of maintenance by FirstLight, the fish ladder at Turners Falls Dam was not working until April 22, a full three weeks after shad were arriving at that site. That kept thousands of those shad treading water and wasting their migration energy in the miserable conditions below Turners Falls.

SHORTNOSE STURGEON UPDATE: Shortnose sturgeon begin arriving in the Dead Reach at the Rock Dam site in Turners Falls in mid-April. On April 14th there was virtually no water be released into the riverbed where those sturgeon arrive to spawn, and those shad arrive to continue on to upstream spawning habitats.4-28-16 dribbling Dead Reach Flow

Above: flow dribbling down the DEAD REACH, April 28, 2016.(Click to enlarge)

On April 27th, the day sturgeon studies show that spawning at Rock Dam commences, the flow released into the Dead Reach and running downstream to the Rock Dam spawning site was so withered that spawning at the site would’ve been rendered impossible. Thus chased out by insufficient flows, another year of shortnose sturgeon spawning failure has occurred at its only documented natural spawning site in the entire ecosystem.

FURTHER, despite much touted improvements for moving the hundreds of sturgeon trapped below Holyoke Dam upstream, all FOUR shortnose sturgeon that made have made it into the fish lift there have been unceremoniously plopped back DOWNSTREAM. Call it bureaucratic interuptus… Or, agency failure.

Thus, for yet another year, there will be no improvement for the genetic prospects of the Connecticut River’s only federally endangered migratory fish. The agencies, chief among them the National Marine Fisheries Service have failed this fish and this river once again—as well as the so-called watchdog groups.

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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