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The Hidden Costs of Northfield Mountain Pumped Storage

Posted by on 01 Sep 2014 | Tagged as: Connecticut River, Connecticut River ecosystem, ecosystem, Entrainment, Federal Energy Regulatory Commission, FirstLight, GDF-Suez FirstLight, Haddam nuclear plant, Ludington Pumped Storage Plant, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, resident river fish, US Fish & Wildlife Service, USFWS, Vermont Yankee, Yankee Atomic, Yankee Rowe Nuclear Plant

Copyright © 2014 by Karl Meyer

The hidden costs of Northfield Mountain Pumped Storage: after Vermont Yankee closes, FirstLight wants to ramp up pumping and profits

(a version of this piece first appeared in the Greenfield Recorder, August 23, 2014)

Vermont Yankee, the last of the region’s nuclear plants, will close in December. In response, GDF-Suez FirstLight’s Northfield Mountain Pumped Storage plant is looking to change its stripes. On June 27th it applied to the Federal Energy Regulatory Commission for a “temporary” license amendment to allow it broad new freedoms to consume unprecedented amounts of the Connecticut River from December 1, 2014 through March 31, 2015. That plan would add an additional 22 feet of pumping capacity to its 5-billion gallon reservoir, sucked directly from the river. More pumping is certain to create more riverbank erosion and draw more silt into that reservoir. It will also kill untold thousands of the public’s resident river fish.

The unprecedented request defies logic. Northfield was built specifically to use energy from local nuclear plants to push water up to its reservoir. In its request FirstLight also cited the closing of the 330 megawatt Salem Harbor coal plant as rationale for why it should be allowed to pump more, and grow larger. FirstLight Hydro Compliance Director John Howard stated, “The requested increase in operational flexibility is needed to provide ISO-New England with additional resources to deal with a potential shortage of energy in the Northeast this winter.” However Andrea Donlon of the Connecticut River Watershed Council found that ISO-New England, the grid’s Independent System Operator, had made no requests concerning Northfield, stating it expected to have adequate energy supply this winter.

FirstLight’s application failed to mention is that it is shutting down its own 135 megawatt Mt. Tom Coal Plant this October. Rather than the “peaking energy” and “emergency resource” plant it’s been since coming on-line in 1972, Northfield seems to be implying it will somehow serve as a replacement for those 24/7 “baseload” energy plants. The other logic-defying reality is that it would be consuming more baseload energy to create more brief pulses of high-priced energy to re-sell to us at “spot” market prices.

Northfield was fashioned during the nuclear build-out in the late 1960s to use the excess power generated at night from nuclear plants in Rowe, Vernon, VT and Haddam, CT to gulp giant slugs of the Connecticut up to its reservoir. When demand “peaked” during mornings or late afternoons it would release that stored nuclear energy—our river, back to its bed through massive turbines. It could produce some 1,000 megawatts in just minutes, great for short-term needs and emergencies. But it could only store enough water to produce 6-8 hours of electricity, total. Depleted, it then waited to re-start the process.

In her book “Inventing Niagara” Ginger Strand described the inefficiencies and rationale behind selling pumped storage electricity to the public as a textbook case of corporate capitalism: buy low, sell high. Northfield has never been a renewable hydro source. It is inefficient and operates at a net-energy loss. While its impacts on the river ecosystem are profound, its brief, staggering pulses of violent, high-volume output are no more efficient than that of legacy electric producers, just more short-term profitable.

Northfield only makes sense while it operates as a designated nuclear adjunct, run on the excesses of the region’s short-lived and now-shuttered nuclear fleet. But now it wants to soldier on, utilizing imported power and climate-changing resources. Meanwhile the river pays an as-yet unstudied price–as the public is asked to accept yet more “peak” energy, repackaged and re-sold at “peak” prices culled from bidding boards on the “spot” market.

FirstLight’s FERC request sparked official replies from entities involved in the current 5-year relicensing of Northfield. The National Marine Fisheries Service’s William McDavitt noted to John Howard “the timing of this temporary amendment application is a bit unfortunate as the proposed change could bear some impact on proposed 3.1.2 Northfield Mountain/Turners Falls Operations Impact on Existing Erosion and Potential Bank Instability. Were the proposed changes to go into effect, it seems as though the duration that NMPS pumps or generates could be changed.”

MA Fish and Wildlife made no objections to the up-rate, but the Watershed Council noted that fish kills there–known as “entrainment”, are worrisome, “Currently the entrainment impact of the NMPS facility during the winter is not well understood, which the pending appeal by USFWS regarding the sufficiency of FirstLight’s proposed entrainment study well illustrates,” further noting, “So until such time as we have a much better understanding of the entrainment impacts of NMPS, it seems inappropriate to request additional pumping capacity.”

In 1995 the owners of the Ludington(MI) Pumped Storage Plant agreed to a $172 million dollar settlement for its killing of the public’s fish across the previous two decades. There, according to the Ludington Daily News, they at least had the benefit of a one-time study showing LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

Since 1972 it’s been a free ride up at Northfield.

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

Kynard,Part II: Fisheries restoration, or a new half-century of death in the TF Power Canal?

Posted by on 06 Aug 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, Dr. Boyd Kynard, ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Station, shad, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

Tune in to Local Bias on Greenfield Community Television, GCTV.org, for Part II of a wide ranging interview with fisheries biologist and US Fish & Wildlife Service Conte Anadromous Fish Research Center founder Dr. Boyd Kynard. He gives direct answers to questions about the fate of the millions of American shad that have been tricked out of the Connecticut River into the deadly and alien habitats of the private Turners Falls Power Canal for the last 35 years.

Dr. Boyd Kynard Part II; a Deadly Canal or a River Migration Solution?

http://mfi.re/watch/pdx5yqvqv7ygzdk/Local_Bias_147.mpg

The current Federal Energy Regulatory Commission Re-licensing process for FirstLight Power’s Turners Fall/Cabot Station and Northfield Mountain Pumped Storage Stations represents the last chance the Connecticut River gets to recover some of its biodiversity, fecundity and ecosystem functions for many decades to come. A second failure by the public agencies charged with protecting the public’s fisheries resources and endangered species will likely close off–forever, the last, best chance to restore New England’s Great River.

Will the federal and state agencies responsible for protecting and guiding the migratory fisheries restoration since 1967 (USFWS, National Marine Fisheries Service, VT, NH, and MA Division of Fish & Wildlife), again steer migratory fish headed upstream to northern MA, VT and NH spawning habitats into a private “roach motel” of deadly hydro blades and muck? Or, will they bring them directly upstream to a fish elevator at the Turners Falls and redeem decades of failure? Get the low-down, and hear about viable alternatives in this half-hour interview.

Tune in to Local Bias this Thursday, August 7 at 9 pm, or on Saturday, August 9th, at 9 pm. The shows repeat at those scheduled times the following week.

New Stakeholder Comments submitted to FERC, re: Shad Spawning Habitat Studies and Fish Assemblage Assessment

Posted by on 19 Jun 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River ecosystem, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, shad, Station 1

The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on June 16, 2014, re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

Karl Meyer, M.S., Environmental Science
85 School Street, # 3
Greenfield, MA 01301 June 16, 2014

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

Stakeholder Comments RE: FERC P-2485-063, and P-1889-081:

These comments pertain to Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects; as well as Study No. 3.3.11 Fish Assemblage Assessment

My comments are specific to a Study Plan Determination meeting and consultation that took place at Northfield Mountain on June 3, 2014, to determine proper Study Plan parameters and procedures.

As a Stakeholder who has contributed to these fisheries discussions throughout the FERC process, I was dismayed that notification of this Stakeholder meeting was not sent out until the day before it was to take place. Along with Katie Kennedy, Andrea Donlon, and Don Pugh, I did not receive an email-invitation from FirstLight consultant Chris Tomichek to continue participating in the discussions until 9:15 a.m. on the morning of June 2, 2014—for a meeting that was to take place at 9:00 a.m., June 3, 2014. This is an abrogation of the FERC relicensing process for Stakeholder participation, and once again leaves these legal proceedings open to question. As I was on vacation when the less-than-24-hour-notice was sent, I was not aware that a meeting had taken place until the day after. With notice, I could have participated via teleconference.

I trust that the Notes and Transcript of this June 3rd meeting will be posted on both the FERC and Northfield Mountain relicensing web sites as part of the public record.

As I do not know the content of Stakeholder remarks or positions stated at the June 3, 2014 meeting, it’s possible that some of my comments may reiterate those of others. I will try to be brief, and address areas of my expertise.

My Comments re: Study No. 3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects

In response to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard filed a response with FERC on January 28, 2014, stating, “Kieffer and Kynard (2012) have documented a spawning period of 5-17 days during the same 26 day period each year (April 27-May 22). Early life history stages (eggs and larvae) are present in the project area for 20 to 30 days after spawning (Kynard et al. 2012a). So the period when shortnose sturgeon eggs and larvae are present overlaps with the proposed sampling period for shad egg collection. Consequently, the collection of shad eggs may have the potential to impact shortnose sturgeon, and NMFS recommended in its December 2 letter that the study be revised.”

“To address this potential concern, FirstLight proposes to replace shad egg collection efforts, which studies have shown are duplicative of visual observations of shad spawning, with enhanced visual observations and splash counts.”

The best way to determine the presence of shad spawning, habitat and egg deposition in the By Pass Reach is to use both recommended efforts: egg collection and splash counts Using plankton nets to capture eggs and larvae should be employed to determine shad reproduction in the 2 miles of the By Pass Reach. NMFS did not at any time state that this method should not be employed. They merely noted the presence of SNS and their spawning period and egg/larvae deposition schedule.

Dr. Boyd Kynard states that there is no reason that plankton nets cannot be deployed in the channels opposite the islands on the west side of the river while SNS are present at their east-side ancestral Rock Dam spawning site, or the default site adjacent to Cabot Station if inadequate flows at Rock Dam have chased them downstream. Kynard states that this seining can take place all the way up to TF dam without impacting SNS spawning or egg deposition and larvae development. (Personal communication, 6/14/2014) Kynard is available if FL or Kleinschmidt would like to consult with him.

It is noteworthy that my own observations found FirstLight dumping water back into the river from its canal bypass flume above Cabot Station on three consecutive days at 12;25 pm: May 13, 14, and 15—all dates when SNS are potentially in spawning mode in the Connecticut River section known as the By Pass Reach. Station 1 was also operating off the canal at all these times, and the flows emanating from each were similar—though the whitewater flume-dumping off the canal appeared slightly less rigorous than the generation at the Station 1 outfall.

It is obvious from their notes that FL understands the requirements of SNS for successful reproduction. This canal-dumping practice has been noted by Kynard et al, as a flow regime that can abruptly end spawning efforts and bury or strand SNS eggs and larvae.

As suggested, splash counts should be also be done throughout the By Pass Reach. However, river regulation by FirstLight has a profound impact on whether and when shad are present in the By Pass Reach—River Segments 1 – 4 in the Study Plan—just as it impacts SNS.

FirstLight’s proposal to use splash counts to determine spawning should be carefully calibrated with river flows throughout the By Pass Reach. In order to have get a “clean” picture of when and where American shad may use this reach of river for spawning and egg deposition, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace federal trust fish from this river segment.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass from noon on the day the study is to commence until after midnight when spawning tapers off.

It is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flows, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

My Comments re: Study No. 3.3.11 Fish Assemblage Assessment

In his letter responding to NMFS concerns about endangered shortnose sturgeon, FirstLight’s John Howard formally responded to FERC on January 28, 2014, stating: “To avoid any potential impacts to sturgeon, FirstLight proposes to conduct all sampling in the bypass reach after June 30, and in the reach below the Deerfield River, FirstLight proposes to use both existing data and the data it obtains in the Turners Falls Impoundment.”

I will restrict my comments to fish assemblage sampling in the By Pass Reach:

Again, in order for electro-fishing sampling to be effective and get a “clean” picture of when and where resident and migratory fish may use this By Pass Reach of river, continuous flows must be present in the river in order to sustain their use of the habitat. Ramping flow regimes and abrupt gate closures can easily displace fish from this reach.

As such, I would suggest that steady-state flows of a minimum of 2,500 cfs up to 5,000 cfs be present in the By Pass for a full 24 hour cycle before this study is to commence.

And, again, it is also necessary to know what the gate positions and flows are at TF dam throughout this time, as well as whether Station 1 is operating and at what flow, and whether water is being dumped from the canal back into the river above Cabot Station via the by-pass flume.

End of Formal Comments

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

Sincerely,
Karl Meyer, M.S.

The curious nucelar history of Northfield Mountain Pumped Storage Station

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

Copyright © 2014, by Karl Meyer

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

New Stakeholder Comments filed with FERC

Posted by on 31 Mar 2014 | Tagged as: American shad, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, FirstLight, Northfield Mountain, US Fish & Wildlife Service, USFWS

The following Public Stakeholder Comments were filed today with the Federal Energy Regulatory Commission and Dispute Resolution Proceedings concerning Relicensing Studies to be conducted at the Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA  01301                                                                        March 31, 2014

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC  20426

Stakeholder Comments for: FERC Project No. 2485-063, the Northfield Mountain Pumped Storage Project; and FERC Project No. 1889-081, the Turners Falls Hydroelectric Project.

 RE: US. Fish and Wildlife Service’s Notice of Study Dispute, filed March 13, 2014; and FirstLight’s response filed March 28, 2014, as Information Relevant to the US Fish & Wildlife Service Notice of Study Dispute.

Dear Secretary Bose,

Please consider the following comments concerning the necessity of robust study information being required of the license applicant in order for the US Fish and Wildlife Service and stakeholders to be fairly represented in this process.  The requested full Study on impingement and entrainment and data arising from examination of Northfield Mountain Pumped Storage Station’s operational effects on all life stages of American shad is new information that will also assist FERC in fully considering public resources and the public’s interest in a balanced and functioning Connecticut River ecosystem.

On March 13, 2014, the U.S. Fish and Wildlife Service (USFWS) filed a Notice of Study Dispute with the Federal Energy Regulatory Commission (Commission) stating that the Study Plan Determination issued by Commission staff would not elicit adequate information specific to “the effects of Northfield Mountain Pumped Storage Project (NMPS) on certain migratory fish species.”  FirstLight argued that information from a 1992 entrainment study would be sufficient to stand-in for current relicensing information.

The USFWS’s information request was made to fulfill responsibilities in determining the impact of NMPS pumping operations on American shad mortality, from eggs and early-life stages, to juvenile and adult fish.  USFWS noted that a “failure to provide this information will compromise the Commission’s ability to establish license conditions and the Service’s ability to set mandatory conditions under Section 18 of the Federal Power Act (FPA).”

The USFWS further stated:

“A new study of NMPS is needed because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation that could increase the potential for entrainment at NMPS. With anticipated improvements to fish passage facilities as part of the relicensing process for the Turners Falls Project, those numbers could increase into the hundreds of thousands.”

Under Goals and Objectives USFWS stated: “The goal of the Service’s original study request (Appendix A) was to determine the impact of NMPS pumping cycle on entrainment of American shad (including early life stages.)”

Pursuant to a March 26, 2014 teleconference between USFWS, FirstLight, and Commission staff, FirstLight formally responded on March 28, 2014, by supplying a portion of six years of seasonal pumping information from NMPS.  FirstLight submitted it as being representative of an overall decrease in plant pumping operations since the original 1992 mortality/entrainment study.  FirstLight supplied monthly and daily pumping data for the bracketed years of 1991 – 1993; and then again for 2011 – 2013.  In its filing FirstLight stated that, aside from the 1992 study-year data included, the other five years “were arbitrarily selected.”

A preponderance of accepted data shows NMPS operations impacting reaches of river at least as far downstream as Holyoke Dam, 36 miles distant, as well as throughout the Turners Falls Impoundment nearly to Vernon Dam, 20 miles upstream. In the months of June and July NMPS’s unrestricted pumping output of up to 15,000 CFS actually outstrips the Connecticut’s natural flow volume. Studies confirm that entrainment of eggs, juveniles, and adult fish have significant impacts on ensuing year-class strength.  They can impact whole-river populations.

Given this understanding, the “arbitrary” pumping years FirstLight has submitted to support limiting the scope of this study appear selective, rather than “arbitrary.” They coincide exactly with the all-time peak years of fish migration on the Connecticut during the early 1990s, and again, with the only shallow bit of improvement for shad migrating into the Turners Falls Impoundment since deregulation in 2000–the years 2011, 2012, and 2013, leading directly into a relicensing application. It should be noted that “arbitrary” is not synonymous with “random.”  Random is an accepted scientific parameter.

It is noteworthy that FirstLight selected as its first grouping the years 1991 – 1993 for pumping information.  Those years selected can be characterized as skewed, rather than arbitrary or random, in that two of them represent the highest years of fish passage ever recorded (1991, 1992) through Turner Falls Gatehouse.  These were record years along the entire river. However, the slight fall-off starting in 1993, began the first extended period where shad returns along the Connecticut River began a steady downward spiral.

The other data set FirstLight offers as “arbitrary” are from the years 2011 – 2013.  What is interesting about this “arbitrary” FirstLight data is that it excludes the entire decade–beginning in 2000, when NMPS began operating as a deregulated entity. Then, as today, NMPS could draw, and release—unrestricted, up to 15,000 CFS into the TF Pool, according to market prices and demand.  What is powerfully obvious about the years not included in their study data is that 2000 – 2009 represent the worst decade of fish passage at Turners Falls Gatehouse ever, with passage counts dropping to 1% or less some years. Some might describe this as cherry picking data.  They arbitrarily picked the only two minor peaks of any note across a very dismal quarter-century of poor upstream shad recruitment.

Good science requires, at minimum, randomly selected figures when data samples are too large. That is not the case here.  We are only considering 25 years of data, and only three months from each year.  A complete data set should be provided—especially when it is small, as in the present case.  Given such a brief span of time, and considering that a FERC license may be in place for 30 or 40 years—data from years 1991 to 2013 should be presented to better understand entrainment, mortality and recruitment of all life stages.

Significantly, as history, in 2010, FirstLight entrained its own turbines at NMPS plant while attempting to clear silt from its upper reservoir. NMPS operations came to an abrupt halt; the US EPA sanctioned them for “polluting the navigable waters of the United States,” and no pumping occurred at NMPS from May 1st, until November.

Fish passage at TF Gatehouse in 2010 saw a 400-500% increase over averages for the previous decade that year NMPS remained inoperable.  However significant that increase was, it merely represented a return to disappointing fish passage and recruitment levels regularly reached there in the 1980s.  The following year, Holyoke Dam saw a 30% increase in fish passage, yet no corresponding increase in shad passage was tallied at TF Gatehouse in 2011. 

However Gatehouse fish passage did continue–across the “arbitrary” 3-year data set FirstLight submitted for 2011 – 2013, to show a level of fish passage comparable to the returns achieved in the mid-1980s.  By not including pumping files from 2000 – 2009, FirstLight offers just three years of data during which improved fish passage numbers could be shown—but only if passage and recruitment targets are scaled back to the disappointing results of the 1980s.

As “arbitrary” as those selected years of data may be, they only give a snapshot of three “good” years of fish movements and recruitment above Gatehouse toward Northfield and VT/NH habitats. Certainly it’s possible that pumping operations get skewed over some years for various reasons.  But three years of data–just prior to a relicensing bid, is no substitute for the full set of pumping files.  Pumping data beginning from the year of deregulation—2000, to the present, will shed light on the impacts of pumping on entrainment and recruitment across the time frame necessary to help make decisions on issuing a decades-long license.

Ample decision-making studies and data—beyond just the most recent years FirstLight wants to supply, is what are called for in this instance.  The remaining pumping data, monthly, daily, along with standard deviations for the years 2000 – 2009, should be supplied in order to protect public resources.

Stakeholders should have an understanding of the plant’s potential pumping impacts and a fuller knowledge of the spectrum of its operating regimes since becoming a deregulated entity across three different owners—as there is no guarantee of single, long-term ownership over the term of license.

It is also critical to note that an overall “decrease” in pumping across selective years is just a single factor and may not be as significant to various life-stages of fish survival as the actual days, dates, and times when pumping and entrainment is occurring.  This is why the full USFWS entrainment study and a full report of pumping operations are necessary.  This is information that is sorely lacking.

Under Existing Information the USFWS states: “In its original study request, the Service noted that, while a number of studies had been conducted over the years, only one study attempted to quantify the number of shad entrained at NMPS.”

USFWS further stated that information from a single study conducted in 1992 would be insufficient for determining new protective licensing requirements: “The ichthyoplankton sampling requested by the Service would follow the methodology used in the 1992 study.”  USFWS further argues: “Existing information is not sufficient to use in the relicensing proceedings because operations have changed since the last study was conducted and FirstLight is considering additional changes to project operation as part of relicensing and that could increase the potential for entrainment at NMPS.”

Nexus to project operation and Effects: “Both the previous licensee (Northeast Utilities Service Company) and FirstLight assume that all fish entrained are lost to the Connecticut River system (i.e., 100% mortality). Without quantification of entrainment of all life stages of American shad, it is not possible to determine what the overall impact of that entrainment is on the shad population. This information relates both directly and indirectly to the Service’s statutory responsibilities under Section 18 of the FPA;”

Cost: The US Fish and Wildlife Service notes that a suitable entrainment study that includes early life stages can be conducted at NMPS for well under $50,000.  This is a modest expense to attain critical information that is not available elsewhere.  Not gathering such information would amount to a failure of due diligence in the current relicensing.  A single, 22 year old study is inadequate science on which to base conditions for a license that could impact the Connecticut River ecosystem until 2048—at which time the last data collected will be 60 years old.

I urge you to require the full study of NMPS entrainment on all life stages American shad. The information gathered will enrich and inform decision-making gathered from related shad studies occurring under relicensing, including 3.3.2; 3.3.3; 3.3.6; and 3.3.7. Further, please require that the full spectrum of May, June, and July, pumping files for the years 1991 – present, be released as information critical to making decisions on NMPS’s long-term impact on the entire Connecticut River ecosystem.

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

Sincerely,

Karl Meyer, M.S.

Cc: John Nagle, U.S. Environmental Protection Agency

USFWS Designee: Dispute Resolution Panel

River Science Dead Ends….Again

Posted by on 11 Feb 2014 | Tagged as: American shad, Connecticut River, Federal Energy Regulatory Commission, FirstLight, New Hampshire, Northfield Mountain, power canal studies, shad, Turners Falls dam, Turners Falls power canal, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, US Geological Survey's Conte Fish Lab, Vermont

Copyright © 2014, by Karl Meyer 

                          River Science Dead Ends…Again

Since 1980 it’s been clear the Turners Falls power canal is a dead end for the Connecticut River’s American shad migration.  Thirteen years of federal fish research in that watery rabbit hole only serves to reinforce the point.    

A Federal Energy Regulatory Commission inquiry of US Geological Survey Conte Fish Lab researchers in Turners Falls, MA, found that it takes a radio-tagged American shad an average of eight days to swim the 2-1/2 miles from the end of the Turners Falls power canal to an area near the dam.  A person can stroll those same 2-1/2 miles along the Canal Side Rail Trail to the dam (basically the entire TF power canal) in less than 45 minutes.  So, what’s dragging these fish down?

Things are becoming clearer as information dribbles out from Conte Lab’s endless fish passage studies in the Turners Falls power canal via the FERC hydro-relicensing process on the Connecticut River.  What’s obvious is how little we know about conditions encountered by the thousands of migrating shad forced into the private canal.  Nor do we have any definitive science describing what happens to tens of thousands of shad that choose their ancient migratory route directly up the Connecticut to Turners Falls Dam.  These are fish seeking passage toward Gill, Millers Falls, and Northfield, MA; Brattleboro and Bellows Falls, VT; and Chesterfield and Walpole, NH.  That dam holds back migration-sustaining flow to feed FirstLight’s deregulated pumped-storage hydro plant inside Northfield Mountain.   

The first thing noticed from a FERC memo dated January 27, 2014, is that the 2008 – 2012 studies from the USGS fish lab are being provided “with the caveat that they contain preliminary data that is subject to revision and that the reports have not been subject to independent peer review.”  In short, this un-vetted research does not meet some basic scientific benchmarks for making long range decisions on river regulation.  And, while conducted by federal researchers, some of it is over a half decade old, while all of it’s been subsidized with power company funds.

Today just one-fish-in-ten passes upstream through that canal to the river beyond TF dam–no better than averages tallied there in the mid-1980s.  So why has hydro-company FirstLight had access to this study information over these years while the public has gone wanting?   And when do study findings from 2008, 2009 or 2010 get finalized—when do they get published and made available for peer review?  Is this public-science, or private consulting?  How much weight can FERC accord them?

Here are further tidbits from a January 30, 2014 memo released by FERC.  They’re from a follow-up phone call between FERC’s Ken Hogan and Conte Lab’s Dr. Ted Castro-Santos, a principal investigator in the Turners Falls canal studies.  “Specifically, Mr. Hogan sought information from Dr. Castro-Santos on the duration of the upstream migration of adult shad within the Turners Falls power canal.”  Though there isn’t an exact transcription for the public record, we do have this telling quote: “Dr. Castro-Santos stated that duration of the radio-tagged shad migration within the power canal from Cabot Station to the vicinity of the Gatehouse, is a median of 8-days.”

Examined carefully, the language of Dr. Castro-Santos’s reply is specifically—vague.  What it reveals is that most tagged spawning-run shad take over a week to swim less than 30 city blocks.  Some take much longer.  But on average that’s a full four days to swim the mile from The Farren Care Center to 18th Street, and another four days to fin the last 18 blocks to 1st Street–the “vicinity” of the dam.  Castro-Santos specifically describes fish as reaching “the vicinity of the Gatehouse.”   “Vicinity” in this instance, is exculpatory language.  It means shad experience further delay here, with some not proceeding upstream past TF dam.  It describes another fatal choke point in the power canal configuration–underscoring failed engineering, fish passage, and science. 

Curiously, Dr. Castro-Santos has noted at fisheries meetings that a small segment of the shad population that does manage to thread the canal maze and emerge above Turners Falls Dam to continue upstream arrives at the base of Vermont’s Vernon Dam just 1-1/2 to 2 days later.  That’s a 20 mile swim in 36-48 hours.  After 14 years of study and 34 years of excruciatingly poor fish passage through that canal towards the 50 miles of empty Connecticut River spawning habitat upstream, the only explanation for shad taking 8 days to arrive at the “vicinity” of the dam through a 2-1/2 mile-long canal is this: it’s a failure. 

 What’s dragged these fish down?—clearly an alien migration route, unasked questions and poor public science.  But electricity demand eases in spring; and FERC is asking good questions now.  Federal statutes require working fish passage and river flows that facilitate the time-sensitive spawning and migration requirements of the public’s fish.  Those requirements have clearly not been met at Turners Falls these last 34 years.  FERC releases its Study Plan Determination for new science required for hydro-relicensing on February 17th.

Note: new book on restoring East Coast migratory fish runs: Running Silver: Restoring Atlantic Rivers and Their Great Fish Migrations, by John Waldman, published by Lyons Press.  A good read, with fine, thought-provoking writing—and plenty to chew on about the Connecticut River including takes on the Turners Falls power canal migration route, river rats, and researchers.  www.LyonsPress.com

 

DUE DILIGENCE: looking beneath the surface

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

Copyright © 2013, by Karl Meyer

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

                    DUE DILIGENCE: looking beneath the surface

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

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

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

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

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

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

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

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

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

Unconscionable: The Fate of the “Canal Nine”

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

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

THE FATE OF THE CANAL NINE

Copyright © 2013, by Karl Meyer     All Rights Reserved

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

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

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

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

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

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

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

Comments sent to FERC Re: Northfield/TF Canal Relicensing

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

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

                                                                                                          

July 14, 2013

 

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

 

 

 

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

 

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

 

Dear Secretary Bose,

 

 

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

 

 

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

 

Comments:

 

 

2.2.1 & 2.3.1: Proposed Changes to Project Operation

 

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

 

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

 

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

 

 

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

 

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

 

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

 

 

 

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

 

 

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

 

 

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

 

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

 

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

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

 

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

 

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

 

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

 

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

 

 

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

 

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

 

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

 

 

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

 

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

 

 

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

 

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

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

 

 

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

 

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

 

 

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

 

The Need for Additional Information

 

Under  Task 1: “Review existing information:”

Only finalized USGS study information should be considered.

Task 2: Develop Study Design:

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

 

 

Task 3: Evaluation of Route Selection and Delay

 

             Under: Radio Telemetry Tracking: Add in:

 

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

 

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

 

Under: Video Monitoring

 

 

Video monitoring at the Spillway Ladder is insufficient.

 

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

 

Task 4: Evaluation of Mortality

 

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

 

 

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

 

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

 

 

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

 

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

 

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

 

 

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

 

 

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

 

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

 

 

3.3.3 Evaluate Downstream Passage of Juvenile American Shad

 

Task 3: Turbine Survival

 

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

 

 

3.3.5  Evaluate Downstream Passage of American Eel

 

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

 

Study ticket price is too expensive.

 

 

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

 

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

 

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

 

 

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

3.3.7 Fish Entrainment and Turbine Passage Mortality Study

 

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

 

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

 

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

 

 

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

 

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

 

 

General Description of Proposed Study

 

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

 

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

 

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

 

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

 

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

 

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

 

 

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

 

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

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

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

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

 

FirstLight’s added-in text:

 

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

 

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

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

 

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

 

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

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

 

FirstLight’s Added text: “ 

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

 

Note: This should not be a contingent study. 

                                                End of Formal Comments 

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

Sincerely,
Karl Meyer, M.S.

Double Standard on the Connecticut

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

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

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

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

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

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

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

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

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

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

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

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

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

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