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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

CASHING IN ON A CASH COW

Posted by on 15 Jan 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, endangerd shortnose sturgeon, Endangered Species Act, Energy Capital Partners, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, fossil plant, GDF-Suez FirstLight, ISO, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, non-renewable, Northfield Mountain, Northfield Mountain Pumped Storage Station, Rock Dam, shortnose sturgeon, The Greenfield Recorder, The Pioneer, The Recorder, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Daily Hampshire Gazette(www.gazettenet.com) and the Recorder(www.recorder.com) in the first week of January 2016.

CASHING IN ON A CASH COW

Copyright © 2015 by Karl Meyer

Ever dreamed of owning your own bank? I got a deal for you! Northfield Mountain Pumped Storage Project is for sale again, along with the Turners Falls canal and dam—and a string of little assets down in Connecticut. But Northfield’s the cash cow. Fourth time in a decade they’re unloading this golden calf–always at a tidy chunk of change. A quickie corporate win-win! It’s really like an A.T.M., run at the expense of the Connecticut River ecosystem.

Place works like a giant toilet–suck huge amounts of the river backward and uphill, then flush it all back and—viola, money spews out the other end. Could be ours! They’re holding bidder tours as we speak. I just need a few partners with ready credit. We go in on short-money and cash-in on the no-brainer electricity “spot market” for a few years. Then, with inflated power-price futures in play, we offload this puppy for a final cash-out of 30%–maybe 50%!

Here’s how it goes down. With the cheerleading of Northfield’s not-so-silent partner, ISO New England–the “independent” system operator (created by the Federal Energy Regulatory Commission), we simply slow dance this darlin’ past the banks, the FTC and FERC. Then, in 2016, its sweet business-as-usual—maybe with new shirts for employees.

Trust me, this works every time. Everyone walks away with full pockets—without the public knowing what hit them. Northfield got wholesaled in 2006 by Northeast Generations Services(formerly WMECO—formerly of Northeast Utilities, now Eversource—you follow?) They grabbed a quick $1.34 billion for the package, slipping it to a trio of Jersey venture capitalists, Energy Capital Partners. ECP renamed their little project FirstLight Energy. Those smartest-guys-in-the-room hung-in and grabbed Northfield’s peaking spot-market profits for two years, before off-loading it for a nifty $1.89 billion in that crazy year, 2008.

With that, GDF-Suez, third owner in four years, swept in–the world’s largest private energy corporation, based in France. They’ve been gobbling up contracts to run water systems across the US under the name Suez United Water. But GDF-Suez recently did a clever name-change to Engie, keeping the public totally confused. They got game! The true costs of these premium-priced plant sales get buried in the list of acronyms on electric bills. It’s like owning a 25-mile stretch the Connecticut River to dip into for cash any time you please.

This is a turn-key operation–with us, the new guys, pushing the buttons. The joke is that the public thinks Northfield is a hydropower operation, while this baby has never produced a single watt of its own energy. It’s imported!–huge swatches of bulk electricity now run-in from outside the region to suck a mountain’s worth of flow from the Connecticut up to a reservoir. Then, dump it out on the power lines when prices peak. It’s hugely inefficient, now largely carbon-based—and massively damaging to the river. But amazingly profitable!

That’s where we come in. Sure it was built as a sister to the region’s nukes to gobble up their monstrous stream of unused electricity–because nukes can’t shut down their feverish output at night. That’s how you get to put in a giant straw and suck the Connecticut uphill at a rate of 15,000 cubic feet per second–more than enough to pull the river backward for a mile downstream under low flow conditions. But who’s watching? When the region’s last nuke shut down, nobody said ‘boo!’ with Northfield going fossil. What climate change?

And when it became clear years back that Northfield operations were imperiling spawning success for the federally-endangered shortnose sturgeon at the Rock Dam in Turners Falls–their singular natural spawning site going back into pre-history, again, nobody came forward. Not the US Fish & Wildlife Service, the National Marine Fisheries Service or the MA Division of Fish & Wildlife—or any river protection group. No bureaucrats, no suits–nobody. At Turners Falls—instead of 70% of migratory fish heading upstream toward Vermont and New Hampshire, they squeeze out 4%. We have it made!

Still skeptical? ISO and FERC are addicted to Northfield—even though its power-flush characteristics might come into play maybe a handful of times a year, if at all. For this they let owners cash in on the river whenever y they want. In 2012, the owners of this “asset” collection of 1500 megawatts(of which over 1100 MW derived from Northfield alone) told investors a full 40% of their profits were realized from “Capacity Fees.” What that means is you get paid for holding back the Connecticut! They’re not required to use it at all if they don’t want to—just flush when prices are high. Paid for being you! Of course another 50% of profit comes from generating, though the public doesn’t know it only operates a few hours a day when prices are highest.

Here’s the kicker: in 2014, after a cry-wolf energy deficit winter that never materialized, FERC–with ISO as cheerleader, sanctioned the doubling of those “capacity fees”. Plants are now collecting 2X the amount they were two years back, for having the potential to dump some power on the lines—not for actually generating. Paid for being you! With 1100 potential megawatts at Northfield, how quick can you say “windfall at the public’s expense?” Lastly, Northfield petitioned FERC the last two winters to increase its reservoir storage by a full 25%, with ISO their biggest cheerleader. FERC agreed, twice. Double-dip with a cherry, anyone?

This thing’s a cinch! Even with all the nukes shut—when this should have been moth-balled to emergency use as more climate-warming, spent nuclear junk, it soldiers on as a virtual river monopoly with the blessings of FERC and ISO. Trust me, no one goes to court. Ecosystem damage, costs to the public? Fuggetaboutit!

Got credit? Give a call!

New comments to the Federal Energy Regulatory Commission

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, canal shad, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Extinction, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, FirstLight, GDF-Suez FirstLight, migratory delay, power canal studies, Public Comment period, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

The following comments were submitted to the Federal Energy Regulatory Commission on November 13, 2015, respecting relicensing studies occurring at the Northfield Mountain Pumped Storage Station and at the Turners Falls Dam and Canal. They are designated, respectively as: P-2485; and P-1889.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 November 13, 2014

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

ILP COMMENTS on Updated Study Reports—including Disagreements/Modifications to Study/Propose New Study on Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process. The majority of the fish and aquatics studies remain incomplete at this time. However, having attended the recent study update meetings with FirstLight’s consultants, and as a member of the Fish & Aquatics Studies Team for P-2485 and P-1889, please accept these brief comments on the USR and proposals for modifications and new studies needed in the FERC ILP for these projects. As studies are brought to completion and data and results are shared with Stakeholders I will submit further comments.

3.3.2 Evaluate Upstream and Downstream Passage of American Shad

Needed information from this study: from personal observations I noted many days when Station 1 was in operation. I visited the site, took some photos, and interviewed a fisherman who was busy catching shad at the Station 1 Outflow on 5/24/2015. In good light, and without the advantage of polarizing sunglasses, I observed dozens of shad stacked up like cordwood, treading water there. The gentlemen noted that whenever Station 1 is running “there are always fish here.” The report should include information about tagged fish delayed in this false attraction water. It is also critical to delineate the number of days during testing that Station 1 was in operation.

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 their update the applicant’s team stated that “because minimal shad spawning was observed in the Turners Falls Canal, no spawning areas in the canal were identified for further examination.”

Needed information from this study: at what hour, on what dates, and under what conditions were these “minimal” spawning observations made? Did they return to the site again under different, or more favorable conditions? What was the water temperature? Was it raining? Windy? Cloudy? Was Cabot Station running at the time-and how many units? Was Station 1 in operation on the nights they made their observations?

These are basic questions that require adequate answers as the TF Canal has been the bottleneck for the shad run up through Northern Massachusetts and into Vermont and New Hampshire these last 40 years. The canal appears to be culling off part of the run as a spawning trap. A thorough understanding of why fish are lingering there, and clear assessment of the numbers and delays of fish attempting to spawn in the canal is necessary for informed decision making.

3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms.

Needed information from this study: This study needs to be extended for another year. On October 5, 2015, I took a 20-minute walk through a small segment of the canal at 7:00 a.m. on the morning the canal had drained. On the flats far–from the thalweg where most of the 2014 assessment appears to have taken place, thousands of fish lay struggling, stranded, and dead in the drying pools. These included juvenile American shad, yellow perch, juvenile and “transformer” sea lamprey, one 8-inch chain pickerel, one crayfish, and thousands of tiny, unidentified YOY fish in drying pools and rills that led to nowhere.

These observations were made crossing just a few—out of the many acres, of silt and muck “shoulder habitat” that occurs away from the main channel on both the east and west sides of the TF Canal. A more thorough mortality assessment needs to be made across these habitats to have a full understanding of the impacts of the canal drawdown migrating and resident fish.

REQUEST for New Study: Tagging and Spawning Study of the Connecticut River Shortnose Sturgeon at the Rock Dam Pool in Turners Falls.

The USFWS’s fish passage and dam specialist John Warner reports that both downstream and upstream modifications for fish passage at Holyoke Dam will be completed this winter. New entrances and exits allowing CT River SNS to move upstream beyond that site will be working in spring 2016.

In light of the construction at Holyoke and the 2016 continuation of test flows evaluations on spring migrants in the By-Pass Reach at Turners Falls, testing of spawning success for SNS should be done at their documented natural spawning site–the Rock Dam in Turners Falls, in spring 2016. Regardless of any fine tuning needed at the Holyoke facility, some SNS will return to the Rock Dam pool by the last week of April, and the chance to study their spawning success in light of regulated test flows presents a unique opportunity for the only federally endangered migratory fish on the Connecticut River.

If this fish is ever to benefit from new genetic input, a full understanding of suitable flows at Rock Dam to accommodate spawning is necessary information going forward for a fish that has been decades on the cusp of extinction. It’s an opportunity to restore a part of the public trust.

For further information on longstanding research at this site without required test flows, see Kynard, B. and Kieffer, M.C., et al: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society, ISBN 978-3-8448-2801-6.

Thank you for the opportunity to comment on the USR for these projects.

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

FERC Comments as FirstLight seeks unprecedented mid-license power increase

Posted by on 10 Nov 2015 | Tagged as: Federal Energy Regulatory Commission, FERC licensing process, FirstLight, forward market power auction, ISO New England, Mt. Tom Coal Plant, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir

The following are comments submitted to FERC concerning what would be an unvetted and potentially precedent-setting mid-license power uprate for FirstLight’s Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S.
Greenfield, MA, 01301
October 29, 2015

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

PROTEST against the granting of application for Amendment for Minimum and Maximum Reservoir Elevation for P- 2485-070, FirstLight Hydro Generating Company’s Northfield Mountain Pumped Storage Station.: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement, filed September 1, 2015.

Dear Secretary Bose,

In the 43-year operating history of the Northfield Mountain Pumped Storage Project a full assessment of the project’s impacts on the public’s river and terrestrial resources has never occurred. It has long been understood that NMPS significantly impacts some 50 miles of the Connecticut River’s riparian, stream bank, farmland and flood plain habitat from Vernon, VT to Holyoke, MA. The application before FERC requests a major, mid-license expansion of this facility’s storage and generating capacity without a full vetting of its impact on public resources.
If granted, the proposal before FERC represents a license to benefit—unrestricted and at profit, from a full 25% increase in generation capacity from NMPS’s Upper Reservoir for a 120 day period each fall, winter, and early spring, until 2018.

Given that NMPS is in the midst of its first-ever relicensing studies to gauge the impacts of its operations, it is not in the public interest to see this ongoing, 3 year, “temporary” storage amendment granted. Doing so without a full vetting of the emerging science and without the full participation of all stakeholders would amount to an Ex parte ruling—basically a precedent-setting gift to the power company during its run-up to a relicensing decision on April 30 2018.

NMPS has been granted extra cold season storage capacity only four times over its 43 year history. Each of those–save 2014, was restricted to extenuating circumstances where ISO would request NMPS to pump and generate beyond its mandated parameters after a trigger was reached. In requesting and being granted extra-limital storage last year, ISO and FirstLight appear to have entered into a new partnership of open-ended, unrestricted use of the public’s Connecticut River resources. This request is being made without investigation or any recompense to the public’s benefit beyond what both the utility and ISO refer to as “flexibility” in times of limited on-line capacity or restricted generation.

However, neither ISO or FirstLight has supplied any information as to how NMPS was used in any “emergency” capacity last winter—a winter that was prematurely touted as one with a tight energy market. Though a price squeeze was visited upon the public last winter in the form of vastly inflated energy bills, the predicted energy shortage never materialized. Both Northfield and ISO like to tout NMPS’s “black start” capability. However, to my knowledge the plant has only been used in that manner once, during the August 2003 Blackout, and increased storage capacity was not a factor in its use at that time.

ISO has in the past been tagged by FERC Board Members as supporting stilted judgements and sanctioning Foreward Market Capacity auction results that were clearly only in the interest of the power company—costing the public millions. That included 2013, when they sanctioned results from market bids by Energy Capital Partners(former owners of NMPS), who had unloaded their massive Somerset Coal Plant causing a dip in the future winter capacity outlook, sending energy bid prices soaring for ECP.

FirstLight has put itself in line to benefit from the same situation. They did not mention in any application that their Mt. Tom Plant was shuttered recently, and they stand to benefit if NMPS is granted open-ended generating privileges on the heels of a planned shutdown of one of their assets.

Further, it should be noted that FirstLight submitted only limited information on water levels in the CT River at their Turners Falls Dam and further downstream at the Montague USGS Gauge. No information was provided on how often, and by how much, the river fluctuated daily in the Turners Falls Pool due to their pumping and generating. They contend they generally strayed little from the average elevations in the TF Pool. Daily up-and-down figures during winter freezing, wetting, thawing, and rewetting, are wholly lacking.

FirstLight offers that it generated less in winter 2014/2015 than in many other years, but that tells only their story. When, and under what circumstances they generated, and at what profit, are really what’s required for a full assessment of the plant’s public good. Offering that “we only used a little” see?—is not any reasonable way to assess what might happen with an open-ended license to benefit from “peaking” spot market fluctuations this winter–or in 2016, 2017, and 2018.

Further, NMPS’s ownership changed hands three times over the last decade. Granting a mid-license capacity uprate to this plant could lead to speculation and instability in the deregulated market, causing a bubble in its asset value. If GDF-Suez decides to sell their NMPS plant in the interim, only merchants will benefit—with the public left in the dark on impacts, price, and profits.

I protest the granting of FirstLight an amendment to increase its minimum and maximum storage capacity for the remainder of its license. Further, FERC should not grant a one-year amendment without requiring a public accounting of how the plant was used in any “emergency” fashion—if any, last winter, and how its increased generation was harvested for profit on a daily basis last winter. If these are not provided, the amendment should be denied. Any amendment granted NMPS should include a capacity trigger from ISO, so as to ensure the public is not being gouged by winter fear-mongering.

Sincerely,
Karl Meyer, M.S.
Greenfield, MA, 01301

On “false attraction” at Turners Falls

Posted by on 24 May 2015 | Tagged as: American shad, canal shad, Connecticut River, Connecticut River ecosystem, False attraction, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, Fish passage results, Holyoke Fish Lift, New Hampshire, Relicensing, Rock Dam, Rock Dam Pool, shad, shad fishing, Station 1, Test flows, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

On “false attraction” at Turners Falls

No, this is not about sex—well OK, maybe a little. But it’s different than how you might see someone 200 yards up the trail and think, “Wow, looking good!”—only to discover on a closer pass that they are a different sex than the one that drives you, or they are decades older or younger than the person you were expecting to see. This is about spawning though—about squashing the spawning efforts of migratory fish.

False Attraction Flow is a phenomenon where migratory fish follow flows upstream that lead them to impassable barriers. These flows are created by flood and head gate releases at dam and canal sites, and they keep wild fish expending precious energy that would otherwise be used to swim to upstream river reaches to spawn.

5/24/2015 Today, FERC Relicensing Study test flow releases to the riverbed at Turners Falls Dam are set at 2,500 cubic feet per second. The weather is clear, warm.
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At 1p.m. I visit the ancient Rock Dam site on the Connecticut, where three people are fishing—a woman and two young men. The woman has just landed a shad. She has not been here long.

One young guy is just upstream. He says he’s been getting some hits, but nothing landed. He notes that he’s also a recent arrival.

I clamber up the cliff that looks down on the Rock Dam Pool. Shad are looping by in a constant stream, visible just to the outer edge of the bubbly rip. The light is so good I can see them almost straight down beneath me, as they are only five feet out from the cliff face at times. What is also apparent is that some turn back after making the approach to the whitewater that would take them through notches they must best to pass this natural falls. I see many turn in the current–cutting back against the school, then milling for a bit in the current.
(Below, is the flow downstream, away from Rock Dam–two people with fish poles are in kayaks)
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All the while, the stream of shad beneath me trying to find a way upstream is constant. Always a run of more fish—ten, twenty–hard to get a count as they spurt along. The spectacle is reminiscent of the old medieval representation of the ocean’s fish in constant circulation around the globe. Here, they simply keep appearing in an endless line. There is no telling if the 2,500 cfs is just too low for them to risk the rough, rocky edges of the Rock Dam’s clefts to move ahead. They get lost from view in the bubbly current. What it appears like, overall, is that these fish are stuck—streaming in, agitated to move upstream, but not finding a clear path forward at this flow.

I toss a question over to the furthest guy upstream near the headwaters over this basalt rock face. He says he’s seeing plenty of fish, but hasn’t brought in one yet.

On the way out I ask the woman if she’s going to cook up the good-sized shad she has laid out in the shallows. “Will you slow cook it?” I ask, “Or do you know how to dress them?” She is going to cook it up, but describes a method of cutting through center, just to get out some of those hundreds of delicate bones, and then toasting it up. “After it’s done, you can just get in there and get at the meat with a spoon.”

She asks me where my rod and reel are, and I tell her I’m really here to document flows—so that maybe someday we can all count on fish being here. I continue up the beach. “I’m hoping when I open this one there are some eggs in there,” she says, motioning over at her catch. She’d be delighted to fry up some roe. “Yea, that’s a pretty big fish,” I say, “I’m guessing it’s a female.” I bid her good luck for the day.

I get back on my bike and follow the Turners Falls Power Canal all the way upstream through The Patch section of Turners, and then down past Station 1–FirstLight’s small hydro generating site located on a dog-leg off the main canal. There’s a lone car down the paved drive that leads to the fishing access. When I scoot down to look over, the tailrace at Station 1 is charged with current. FirstLight is generating at this site, despite the test flow requirement that water only be released from the Turners Falls Dam at the 2,500 cfs level today. This will corrupt and skew fish passage study results.
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I walk down and meet the young guy fishing just off the edge of Station 1’s frothy spillway. James is from Greenfield, and “yup,” he fishes the site pretty regular. He’s just finished landing one. It’s unceremoniously laid out in the sandy silt. Smallish. “When there’s water here there are always fish,” he notes. I ask him if he wouldn’t mind my snapping a few photos and he’s fine with it, “You’re not in my way.” He points to the water, not a few feet out from where he is, “You see them all there?” I look, but don’t see much but shadowy, sun-dappled water. I stare a bit more, then start snapping pictures of the flows.
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When I come back down from near the tailrace I look again in the current. This time my angle to the sun is better. There are the shad. Dozens of them, stacked up in the current facing upstream into an endless, impassable sheet of water. “Now I see them,” I say, “Too bad they aren’t going anywhere.” “Yea,” James notes, “they are just stuck here.” I snap a photo of his dusty catch and wish him luck for the day.
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As I come up to the road from Station 1 there are two young boys, maybe eleven or twelve years old, walking along with poles and fishing tackle. They appear to be headed further on, to try their luck in the canal dog-leg. “Hey, what are you guys going after, shad?” “Anything!” they both say in concert. “If you head just down there,” I say, pointing, “There’s a guy just caught one. There’s dozens of fish waiting in the current—you can look right down and see them.” A quick glimmer passes between them, and they say thanks, heading down the driveway. “There’s a bit of poison ivy on the path. Watch for it.” I call, riding away.

I continue up to the Turners Falls Dam, where the flow is still at 2,500 cfs, the lowest test flow setting. There were not supposed to be any other intervening flows confounding these tests all the way downstream to the end of the power canal. The only time Station 1 is supposed to be operating during test flows is when dam releases ramp up to 6,300 cfs. The Fisheries and Aquatics Studies Team had worked out the schedule with FERC, and FirstLight agreed to it. This appears to be a clear violation of study protocols, and it throws into question fish passage results here.
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I cross the road on the Turners Falls Bridge, and peer over the side just downstream of the dam. A few people are fishing in the flow next to the Spillway Fish Ladder. I yell down to the closest angler. He’s fairly close to where Bascule Gate 1 is pouring down those 2,500 cfs. He doesn’t hear me over the rush of water. I yell again; he looks all around—then, on the third time, he looks up. I’m maybe 80 feet above him and we can’t really converse. “How is it?” yell, mimicking with the thumbs up/thumbs down gesture. At first he doesn’t pick it up, but when I do it again, he gives the thumbs down.

I’m not surprised. With all the false attraction flow at the Rock Dam Pool from the added water released by FirstLight at Station 1, there is little flow here in the broad reach of the Connecticut that would temp fish away from treading water at those sites into these thin upstream currents. The fish are basically being tricked; they are expending precious energy that could be used to get upstream to Vermont and New Hampshire just running down their batteries downstream. Imagine treading water on an aquatic, industrial treadmill that’s trying to lure them into a power canal. If you are a Vermont or New Hampshire angler, just understand that these swam their little fins off trying to spawn up on your stretch of river. The lure of false attraction just got the better of them.
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When I take a look at the head gates at the head of the Turners Falls Canal they appear all but quiet, save for the bubbling attraction currents that help lead fish into the Gatehouse Fishway —the place where the public will see them passing. The main and only place where these fish are getting a substantial upstream current that leads to this site is…yup!—2-1/2 miles downstream at the tail end of the power canal at Cabot Station. That’s likely where these fish are really being attracted–and tallied, as some that are actually radio-tagged for these studies are being registered. Humn! That would certainly skew study results toward fish “preferring” the canal…

There’s a long tradition among American shad themselves–and the fisheries biologists that have studied fish passage at Turners Falls over the decades. Study results sometimes show a remarkable uptick in fish passage at the Turners Falls Fishway on holiday weekends when the public is most likely to visit. The fish just seem to just know exactly when it’s Memorial Day Weekend. Even in those years when passage is poor for most of the month of May, those shad seem to just love to appear in the fishway windows at the holiday weekend. It’s uncanny how the fish know. Ironic, really. Not like they are being manipulated…

What would also be uncanny would be if FirstLight had their “most successful canal passage year” ever–right at the time when the studies that impact relicensing flows are taking place. Last year, when 370,000 shad were lifted past Holyoke Dam, just 39,914 made it out of the canal and upstream past Turners Falls Dam. Not a great number. In 2013, when 381,436 shad were passed upstream at Holyoke, just 35,124 made it out of the canal and upstream past Turners Falls. A slightly worse number.

For the last 15 years the canal route for migratory fish has been studied and “improved” for fish passage. Today’s numbers are still pretty much junk.

As a final testament to the lack of progress let’s go back almost a quarter century: in 1991 the Holyoke Fish Lift passed 520,000 American shad upstream. Of those, 54,656 shad managed to emerge, alive, upstream of the Turners Falls Canal and dam, to swim toward Vermont and New Hampshire spawning site.

Thus, a quarter-century later, migrating American shad here are still “partying like its 1991.” False attraction–and false solutions, are very closely related here at Turners Falls. Study results are compromised.

Vermont, New Hampshire, sorry but as an ecosystem, we are still broken up. Just know this: “It’s not you, it’s US!”

On Monday the Holyoke Fishway passed 21,198 shad; the Turners Falls season total as of 5/17 was just 22,499 shad

Posted by on 21 May 2015 | Tagged as: American shad, FirstLight, Holyoke Fish Lift, New Hampshire, sea lamprey, TransCanad, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, Vermont

May 21, 2015: The Holyoke Fishway lifted 7,360 American shad on Tuesday and 21,198 shad Monday according to today’s update fro the Connecticut River Coordinator’s office. Fish passage reports from FirstLight’s Turners Falls fishways are always days behind–due to having no real-time fish counters there reporting. Howsoever, as of their last report from Sunday, May 17th, the season’s total number of shad passing upstream there toward VT and NH spawning grounds was 22,499. That’s a decent DAY’S count at the Holyoke Fish Lift.

Holyoke has also passed 10,849 sea lamprey this season, while 794 have been reported at Turners Falls. This morning test flows from the Turners Falls Dam had been reduced to 2,500 cfs. At 7:30 am head gate flows into the Turners Falls Power Canal were generally quiet as well, with a nearly mirror-like surface and shuffle-along flow visible 100 feet downstream. At 3:30 pm, head gate flows were perhaps a tad more vigorous, but so mild that there we no bubble in the current whatsoever 60 feet from the gates. With more timely fish passage reports it might be possible to tease out how some of these settings are impacting upstream fish passage success.
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The photo above is of an American shad in the bubble-filled window of the Vernon Fishway on Sunday, May 17th. TransCanada has yet to submit fish passage reports to the USFWS website this season.

Spawning run ride from to Vernon; back to Turners Falls, Rock Dam and Cabot: May 17, 2015

Posted by on 17 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Bellows Falls, Cabot Station, Connecticut River, Conte, Dead Reach, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, FERC license, FirstLight, Holyoke Fish Lift, New Hampshire, power canal studies, Rock Dam, Rock Dam Pool, sea lamprey, shad, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont, Vernon Dam Fishway

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The Headgates at Turners Falls Dam sending flow into the power canal were as quiet as I’ve ever seen them this Sunday. There seemed to just be a bit of attraction water for fish looking to get upstream, but no usual frothing rip that is usual with power generation.
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Downstream at the end of the power canal there was a nearly lake-like stillness as Cabot hydro station seemed to be producing little power.
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Looking upstream at Cabot hydro station from the bridge at Montague City, there was just a small run of whitewater coming down the spillway at Cabot. Data about these flow manipulations should be available for investigations and study results for the re-licensing
inquiries currently taking place under Federal Energy Regulatory Commission purview. They have significant impacts on fish passage.
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Three of the lucky anglers fishing Rock Dam today–two are in the boat in background.
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Rock Dam rocking with anglers and 6,300 cfs of flow.
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Letting a Rock Dam shad off the hook.

LASTLY, here’s today’s full POST:

Spawning run ride from to Vernon; back to Turners Fall, Rock Dam and Cabot: May 17, 2015

After cycling up Rt. 5 to Brattleboro early today, I headed south along the Connecticut. I was shocked to actually find the gates to Vernon Fishway OPEN! This is something that should be guaranteed to the public—regular, posted hours where the public can view their fish. Let John Rangonese of TransCanada know. There is always at least one pickup parked at the Vernon hydro station, all that’s needed is someone to walk over and open the gate; then close it upon leaving. Self-serve site, no cost involved. Public’s fish; public’s river.

Anyway, in the riot of effervescing current in the Vernon Fishway windows today were literally streams of American shad. They were running upstream like there was romance in the offing. Here, like at Holyoke, fish come directly upriver to the base of the dam. There, attracted by flows released down the short fish ladder at this modest falls, shad quickly find their way past the dam toward Brattleboro, Putney, Bellows Falls, and Walpole, NH. Today they were passing in pods at around 10:00 a.m. There were also a couple of smallmouths lower in the current, as well as one ropey sea lamprey flashing through the bubbles.
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USFWS tank truck used to transport tagged shad

Here, also, I ran into Steve Leach and his crew, from Normandeau Associates. Using the borrowed US Fish & Wildlife Service tank truck, they were preparing to tag fish and truck them a-ways upstream for fish passage studies connected to TransCanada’s hydro relicensing at Vernon, Bellows Falls, and Wilder. They’d done some previous tagging at Holyoke as well. We chatted a bit about test flows downstream, and the lack of rainfall, and the river’s temperature profile that is rising a bit early. I bid them luck, noting a few anglers fishing below Vernon Fishway—along with a perched bald eagle and a circling osprey.

After stopping to visit friends in Gill, MA, I was on the Turners Falls Bridge just a few minutes after noon. The test flow current is at 6,300 cfs (cubic feet per second) today, and the Connecticut is alive with frothy water across the wide, curving expanse formerly known as Peskeomscut. I look down at four people fishing the quick current along the Spillway Fish Ladder, just downstream of the bascule gate that’s pouring down current. In ten minutes time I watch five shad get hooked—four of them are landed, and one is lost near the waterline.

I get back on my bike and tuck in to the Canalside Rail Trail, scooting under the Turners Falls Bridge. As I come alongside the canal at the Turners Falls Gatehouse I notice that the canal is nearly quiet—almost like a still pond. This rivals the quietest flows I’ve ever seen passing through this site. FirstLight controls the headgates here–and with so few open, the fish coming up through their power canal can get a better shot at passage.

A cynical person might think they were manipulating the canal to make it look like a good industrial conduit for wild fish—especially during tagged-fish tracking surveys during test flows. One also might think this could be done to punch up fish passage numbers for weekend visitors to the TF Fishway—something that has shown up in fish passage tallies there for years. You’d think fish were only interested in migrating on weekends… Nonetheless, after well over a decade of subsidizing federal Conte Lab employees for fish passage studies and structural changes in the Turners Falls Power Canal, they have yet to succeed in passing more shad upstream than passed this site in the 1980s…

Curiously, when I head all the way downstream along the canal to Cabot Hydro Station, and then out on the deck of the General Pierce Bridge in Montague City—it is absolutely true that the TF Canal appears lake-like in its absence of flow, with just a small bit of whitewater bubbling down from its tailrace. Operators have certainly quieted the whole canal system this day.

In between I make a stop at the Rock Dam Pool, where the 6,300 cfs flows have the rocks roiling with lively current, and the anglers reeling in fish, seemingly at will. For the first time ever here I see two men standing and fishing below the Rock Dam’s fall in a motorized Zodiac type craft. Between the boat, the fishers wading out in the Rock Dam Pool, and the people tossing darts from the ledge over the pool, there are nine anglers fishing the site—eight men and a woman.

And the shad are streaming in. In the fifteen minutes I spend there, five fish are brought to shore. When I ask one guy to pause with his catch for a minute while I shoot a photo, he obliges. “How’s it been for you?” I ask. “I can’t seem to make a mistake today—I’ve had two dozen,” he tells me. “Well, I guess you know what you’re doing.” “Hey, I ran the Turners Falls Dam for 8-1/2 years,” he says. I nod, adding, “I guess then you know exactly when it’s time to come down here for shad.”
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The other great thing that has happened for anglers with these actual flows in the river: almost nobody is relegated to tossing lines in the stillness of the power canal. The anglers and the fish are all in the river.

New Comments to FERC, RE: Turners Falls Fisheries Studies

Posted by on 08 Apr 2015 | Tagged as: 5-year FERC licensing process, American shad, Cabot Station, Connecticut River, Connecticut River shortnose sturgeon, Conte, Dr. Castro-Santos, Dr. Haro, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, MA Division of Fish and Wildlife, Mr. Colton Bridges, New Hampshire, Northfield Mountain Pumped Storage Project, Revised Study Plan, Secretary Kimberly Bose, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont

NOTE: the following comments were submitted to Federal Energy Regulatory Commission Secretary Kimberly Bose respecting FirstLight’s withdrawal from its stated position of using video-monitoring equipment at the Turners Falls Dam’s Spillway Ladder to compile study data and information on aggregations of migrating American shad.

This is information that has been the fisheries restoration’s Black Hole these last forty years. It can only be gathered at this site. However, with the withdrawal of these tools, fisheries agencies and the public will be relying on just a few hundred radio-tagged and tracked fish as substitutes for on-site, real time monitoring of aggregations of what are understood to be perhaps hundreds of thousands of migratory shad. (Comments to FERC were slightly abbreviated due space limits in E-filing.)

Karl Meyer, MS
Greenfield, MA 01301 April 8, 2015

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

Re: P-1889; P-2485

Dear Secretary Bose:

Please accept the following comments in the matter of the hydro-power licensing studies for P-1889, the Turners Falls Project; and P-2485, the Northfield Mountain Pumped Storage Project. These comments focus on changes FirstLight made to the Revised Study Plan. I first aired my objections to these RSP changes at a meeting on March 24, 2015–as a member of the Fisheries and Aquatics Study Team. They highlight a lack of Existing Information and a Need for Additional Information that FirstLight’s RSP revisions will not satisfy.

FirstLight has summarily excised all video monitoring in the vicinity of the Spillway Fishway at the base of Turners Falls Dam—a technique they’d agreed was needed in the initial RSP.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

Study Goals and Objectives: (18CFR; 5.11(d)(1)

“Evaluate attraction, entrance efficiency and internal efficiency of the Spillway Ladder for shad reaching the dam spillway, under a range of conditions.”

FirstLight stated the following in their initial RSP response: (bolded italics below, mine

“Video monitoring will be used for specific study areas such as the Spillway Fishway. Use of video monitoring of the Spillway fishway will provide data on fishway efficiency; shad attempting to pass would be monitored versus only those shad that have been tagged.”

Task 2: Study Design and Methods:

FirstLight then wholly eliminated that key video information gathering technique that would help inform these studies with aggregate numbers of shad reaching the Spillway Entrance, versus only those few tagged fish approaching and passing the Spillway entrance.

From FirstLight’s March 14, 2015 RSP changes distributed to the Fisheries and Aquatics Study Team:

“The study will monitor shad migration within the study area using a combination of active and passive radio techniques and video surveillance.”

This needed information gathering was eliminated by FirstLight despite their description in the initial RSP that this was a proven and inexpensive technology:

“FirstLight proposes to conduct video monitoring using the Delta System commercial series of underwater video camera and lighting manufactured by Ocean Systems Inc. This system was recommended by A. Haro (Conte Lab) and has proven effective at other facilities. Video data will be recorded on a dedicated video recorder (DVR).”

“Video monitoring of the Spillway would add a modest cost to this study.”

As to why gathering information about aggregations of American shad at the Spillway adjacent to Turners Falls Dam is needed at this time–that need was stated in FirstLight’s initial RSP response as well:

“In general, the numbers of tagged fish passing through the Spillway Fishway were too low for vigorous evaluation (Haro and Castro-Santos 2005).”

Information about aggregations of migratory fish moving upstream to the base of Turners Falls Dam and the Spillway has been paltry to nonexistent these last 40 years. In the last 15 years, Dr. Haro and Dr. Castro-Santos of the USGS Conte Lab have focused nearly all their work in FirstLight’s power canal, while the Connecticut River passage route for these federal trust fish has been almost wholly ignored.

As to the huge gap in the information for American shad aggregations at this site, I herein cite expert testimony delivered before Commission members four decades back:

On August 21, 1975, in hearings before the United States Federal Power Commission in Boston, Mr. Colton Bridges, Deputy Director of the Massachusetts Division of Fisheries and Wildlife delivered the following expert testimony on the need for Spillway Fish Passage at the Turners Falls Dam:

To Mr. Bridges: Question: “Would either the Cabot power house fishway or the gatehouse fishway be effective in passing those early arriving shad?”

Answer from Mr. Bridges: “No, because with spill conditions at Turner Falls the major source of attraction water will be coming down river from the Turners Falls Dam and emanating from Cabot Station. Consequently, the conditions that existed at Holyoke with spillway flows limiting fishlift efficiency will prevail at Turners Falls Dam with only a Cabot Station fish passage facility in operation.”

Question: “What, in your opinion, would be the effect of the construction of the proposed fish passage facilities at Turners Falls Dam without the inclusion of the spillway fishway?”

Answer from Mr. Bridges: “Without a spillway fish passage facility, fish approaching Turners Falls during periods of spill will be attracted to the base of the dam and those isolated pools located immediately below it, and be subject to the same conditions that exist below Holyoke without the spillway fish collecting facility, i.e., migration delay and mortality due to lack of flow, increased water temperatures, and decreasing oxygen content.”

Given that, as of this date, FERC is refusing to allow the USFWS any in-situ access for snorkeling to get a general assessment of fish using this passage route to Turners Falls Dam during migration season–and that FERC is further disallowing any seining for fish or shad eggs in this reach due to concerns for endangered shortnose sturgeon, this is the only key place where any new information about Spillway aggregations of shad can be gained. This was stated as a result of FERC internal policy, though NMFS indicated a willingness to consult—and NMFS is the ultimate key-holder in decisions concerning Connecticut River shortnose sturgeon.

Hence, denying the gathering of this needed information at the Spillway effectively limits the public’s understanding of what is happening at this site. Though overall successful fish passage through the Spillway Ladder has proven ineffective these past 30 years, it should not limit the Entranceway as the key place to collect long-absent information on aggregating shad.

These are the early arriving fish that have long been known to be the key migrants–most likely to move upstream to Northern Massachusetts, Vermont and New Hampshire spawning sites on the Connecticut. As of this date, 40 years after Deputy Director Colton Bridges testimony, those fish are still not making it past Turners Falls Dam, and we don’t have the information about their numbers and when, where, and in what flow conditions they gather at the Spillway site.

For these reasons I respectfully request that Spillway video monitoring be returned to the Revised Study Plan for this season–to gather the data that cannot be gained simply by monitoring a few hundred radio-tagged fish.

Thank you.

Sincerely,
Karl Meyer, MS, Member, Fisheries and Aquatics Study Team for P-1889; P-2485

FERC grants Northfield “temporary” Power Up-rate: the downside impacts of a studied pumped storage operation, re-posted.

Posted by on 04 Dec 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, GDF-Suez FirstLight, ISO New England, Mt. Tom Coal Plant, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, USFWS

On November 26, 2014, FERC issued an “Order Granting a Temporary Amendment” for P-2485, the Northfield Mountain Pumped Storage Station to increase its storage capacity by 25%, and generate electricity during times of peak demand–or peak prices on the electricity “spot” market, without restriction.

In its power uprate application GDF-Suez FirstLight stated that this extra capacity was necessary due to power plant closures in Vermont and coastal Massachusetts and a predicted cold winter–a forecast for the Northeast that has now been re-evaluated, with a warmer winter now predicted.  GDF-Suez FirstLight did not mention in its application that it was shuttering its own 130 megawatt Mt. Tom plant in Holyoke in October. Another factor that may have played a part in the power uprate bid: GDF-Suez North America Hydro had had its bond rating downgraded in the prior fiscal year.

Given the unprecedented power hike granted Northfield, with ISO-New England formally jumping in the middle and cheering on the process with a formal letter to FERC, I thought I might republish testimony I sent to FERC last spring, when FirstLight submitted–then subsequently retracted as a “mistake,” testimony it posted on behalf of their plant’s storage flexibility cited the wind and solar benefits of a pumped storage plant in Ludington, Michigan.

If you read through the testimony you’ll see how devastating to the ecosystem and fisheries that Ludington Pumped Storage Plant has been.  That plant, though significantly larger, has a similar timeline–first started in the early 1970s, and currently undergoing relicensing. The big difference has been that local non-profits and agencies didn’t let them off the hook for the massive habitat destruction during their first licensing period–actually winning a $172 million dollar settlement from the owners some 20 years back.  Sadly, it was too late to shield their ecosystem or save their fisheries.

So, Northfield will pump more this winter.  It seemed a good time to re-post what the STUDIED damages were at another pumped storage plant over a similar time frame.  Sadly, we can’t know what we’ve lost across the decades here on the Connecticut River.

Read below:

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by karlmeyer on 21 May 2014 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, ecosystem, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, GDF-Suez FirstLight, Ludington Pumped Storage Plant, New Hampshire, Northfield Mountain Pumped Storage Station, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Edit This

The following Stakeholder Comments were filed today, 5/21/2014, with the Federal Energy Regulatory Commission respecting Connecticut River fish mortality investigations at Northfield Mountain Pumped Storage station (NMPS)

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA 01301

 

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-2680-108: relevance of FirstLight Hydro Generating Company’s document submission issued by FERC as “Conference/Meeting Transcript issued in FERC P-2485-063, et al” on May 9, 2014 for Northfield Mountain Pumped Storage project (NMPS). The inclusion of “Transcript of the April 17, 2014 FERC Scoping Meeting held in Pentwater, Michigan re Consumers Energy Company’s et al Ludington Pumped Storage Project under P-2680-108” offers an incomplete, unsubstantiated and confusing picture of its applicable connection to the relicensing of NMPS on the main stem of a four-state river system in Massachusetts.

Dear Secretary Bose,

Please consider the following comments respecting the relevance of FirstLight Hydro Generating Company’s recent document filing as it seeks a new license for the Northfield Mountain Pumped Storage station. I testified as a Stakeholder in the NMPS Study Dispute Panel Technical Conference along with officials from the USFWS and Trout UnLimited on Tuesday, April 8, 2014. The Dispute Panel was convened out of concerns that no study of the entrainment of eggs and larvae of migratory American shad was being required as part of a relicensing bid from GDF-Suez FirstLight Power for NMPS. I find no clear context provided by FirstLight for the inclusion of a transcript for the April 17, 2014 FERC Scoping Meeting for the Ludington Pumped Storage Plant–a lakeside Michigan-based facility, as part of the NMPS relicensing proceedings.

NMPS’s pumping/generating impacts are known to reach downstream to Holyoke Dam at river-mile 86 and affect spawning-run migratory fish that utilize Massachusetts, New Hampshire and Vermont habitats upstream to Bellows Falls Dam at river-mile 172. It is critical to the relicensing of any pumped storage generation on this four-state river to have robust studies with measurable outcomes to protect the public’s interest in a balanced and functioning Connecticut River ecosystem.

NMPS impacts migrating and spawning anadromous fish in a four-state ecosystem that has been the focus of a federal fisheries restoration program begun in 1967, “to provide the public with high quality sport fishing opportunities in a highly urbanized area, as well as provide for the long term needs of the population for seafood.” NMPS, completed in 1972, has been shown to have direct impacts on migratory fish entrainment and fish passage from northern Massachusetts to central Vermont and New Hampshire.

The US Fish & Wildlife Service, National Marine Fisheries Service, and fisheries directors in MA, NH, VT, and CT are all charged with protecting these resources for the public. Federal and state laws, licenses and statutes governing these mandated protections include the federal Clean Water Act, Endangered Species Act, and federal-trust fish protections beginning with the Anadromous Fish Conservation Act of 1965. FERC authority also mandates licensee compliance and protections for the public’s fisheries resources and restoration projects. FERC itself is mandated to comply with federal environmental law.

The Ludington Pumped Storage Plant is a FERC licensed facility sited and operating within a single state on a lakeshore well over 100 miles from it closest bordering state—and situated with 118 miles of open water at its back. Northfield Mountain Pumped Storage, situated adjacent to the Connecticut River, operates on the Navigable Waters of the United States in Massachusetts just 10 miles from where the Connecticut River passes out of Vermont and New Hampshire. NMPS pumps and generates from a narrow ribbon of river that is less than 1,000 feet wide—during warm seasons it sometimes draws more water than the river’s natural output.

In short, these are two very different animals, operating in very different habitats.

However, there are similarities in the long-term environmental impacts of these far-flung pumped storage facilities. They both kill large quantities of the public’s fish. Unfortunately, those impacts were not cited or included in FirstLight’s submission to FERC in either Dispute Resolution Panel documents or its license application documents. In 1995 the owners of the Ludinton Plant agreed to a $172 million dollar settlement for its killing o fish during the previous two decades. The public there at least had the minor benefit of one-time study that showed 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.”

Unfortunately, to date, we have no such data from a study of NMPS, nor any compensation for the long-term damage to a public resource and a long-term fisheries restoration project. In Michigan, a US-based entity was required to pay restitution and undertake remedial action. Here at NMPS the plant operator is a transnational corporation, based outside the United States, that is “taking” an unknown quantity of a public resource without compensation or required analysis. If a US Citizen were to do this they would be subject to legal action.

 

Please see below: Ludington Daily News, August 13, 1987: “Federal agency rules on fish kill, Ludington hydro plant must comply within 60-90 days.”

The Ludington plant had begun operations in 1973, and had been the subject of legal proceedings from that time forward. The State of Michigan had filed a suit in Ingham County Circuit Court seeking more than $147 million in damages, and the National Wildlife Federation had won a federal court order that Consumers needed a pollution discharge permit for the plant.

In summary here are several excerpts from that article defining the impacts at that time including references to a single study that found the plant killed millions of native fish in a single year, species that are today disappearing, or have essentially disappeared, in Lake Michigan waters:

“Environmentalists and state officials Wednesday hailed a federal ruling designed to end the fish kills at the Ludington Pumped Storage Facility operated by Consumers Power Co.” (Co-owned with Detroit Edison Co.)

“Finally, after 14 years of negotiations and litigation, and the destruction of millions of Lake Michigan sports fish, we’re going to see an end to this needless waste of an important resource,” said Thomas Washington, executive director of the Michigan United Conservation Clubs.

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”
“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators. In the pumping process, it kills millions of fish.”

“The MUCC said that a study commissioned by Consumers Power showed the plant, 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.”

However, it took another eight years of environmental damage and drawn-out court proceedings before a settlement—totaling $172 million, was finally reached in 1995. See: Ludington Daily News, March 7, 1995: “Local groups urged to begin working on projects for fish kill settlement plan.”

“While 12 to 18 months more may pass before the settlement, valued at $172 million, becomes final state officials urged local groups not to wait to prepare proposals for enhancing local fishing.”

“Many audience questions fielded by the five-person panel concerned the perception the settlement doesn’t do much for Ludington area fishing specifically—the fishing most affected by the fish kill at the plant.”

It was only after 1995 that some of the large-scale impacts of Ludington Pumped Storage Plant began to be addressed. Ultimately, a FERC-sanctioned 2-1/2 mile long (12,850 ft) barrier net was deployed across hundreds and hundreds of acres of riverbed and bank.

Sadly, it seems that net did not mitigate or resolve the loss of local fisheries in the Ludington region. Its deployment was either ineffective or far too late for a regionally- and culturally-important sustained harvest of local- sourced and eaten native yellow perch and lake trout. Those perch have now essentially disappeared in the Ludington-Manistee region—which is noted in Stakeholder Testimony supplied for the Ludington Scoping Meeting on April 17, 2014 where Mr. Richard Underwood testified that past Michigan DNR creel surveys had found: “close to a quarter million perch” in Ludington habitats. “In the last few years, four years, we have had a total of zero count of perch in Ludington, and that’s how it has affected.”

The giant Ludington barrier net appears to be one key player in the puzzle of the missing perch. It appears to act as a fish trap. According to Mr. Underwood that net, along with an artificial reef constructed nearby, attracts a giant collection of cormorants that feed on the fish trapped within the confines of the net, “There were so many birds on the reef and inside the barrier net you couldn’t count them. I estimated there were 3,500.”

Ironically too, in recent years, federal hatcheries in the Connecticut River basin have been producing lake trout to supplement the now-crippled and dwindling native population of lake trout on Lake Michigan.

Another similarity in these two relicensing proceedings is that FERC’s Scoping Site Visits at both the NMPS plant and LPSP were scheduled either before the PAD had been given to Stakeholders, as it was NMPS, or—as noted in state fisheries testimony at Ludington, the Site Visits are not scheduled to take place until well after Study Requests and Stakeholder Comments are due.

Both of these processes deprived the public and officials the ability to visit, witness, and develop an understanding of the complex impacts of these pumped storage plants before submitting testimony, comments, and informed study requests.

Similarly, both plants have deployed barrier nets as a means of diminishing their fish kills and entrainment/mortality impacts. And, at both sites the fishing is poor and with stocks deteriorating.

The difference on the Connecticut River is that migratory fish here are forced to encounter two entrainment opportunities through FirstLight facilities. The first occurs seven miles downstream, when they are deflected by attraction flows into the Turners Falls Power Canal, with Cabot Station turbines operating on the downstream end.   The small percentage of fish that manage to survive the 2-1/2-mile, 8-day (average) transit to the head of that canal—and the even smaller number that actually exit upstream(1-10%), then get the chance to be culled by NMPS turbines, just five miles further upstream.

In its filing of the Ludington Scoping Meeting documents, GDF-Suez FirstLight seems to be suggesting some link between the large-scale wind power facilities built by LPSP owners Consumers and DTE, and a key, future role for renewables here in sucking the Connecticut River backward and pulling it uphill into the Northfield Mountain Pumped Storage reservoir.

That connection is tenuous, at best. Consumers and its partner DTE now own and operate a large-scale wind farm consisting of some 56 turbines. Its deployment required the purchase or easement rights to 16,000 acres of Michigan property, most of it to trench-out underground power lines to reach back to their grid and pumped-storage plant. Their large-scale wind operations are due to the presence of 118 miles of open Lake Michigan at their back, as well as a flat, open, prairie landscape to site giant turbines on.

FirstLight seems to be implying that NMPS will be similarly employed at some future date—its ecosystem impacts ignored because of the huge amount of surplus, cheap, local, renewable energy available to pump a river uphill at night. But solar doesn’t generate at night; and available local hydro here is modest and run-of-river—it would not constitute a “renewable” source to be tapped to pump water uphill. And, wind power opportunities here are spotty, small scale, and generally available on isolated ridge tops.

Clearly the Connecticut River Valley has none of the necessary features that might facilitate the large-scale wind renewables/pumped storage relationship found at LPSP. Nor, has FirstLight proposed plans for any large-scale wind projects in the region. No other entity has either. Cape Wind, whose large scale deployment will be installed miles off the Atlantic shore, is not proposing a pumped storage plant be built above the Truro Cliffs in order for its renewable energy megawatts to be consumed. Here, there just aren’t flatland mega-farm acres available, and only a few ridge tops here have proven suitable for siting isolated turbines.

GDF-Suez Manager John Howard stated at the Dispute Resolution Panel: “We can manage fluctuations in energy schedules with wind, solar, and imports from Canada and New York, primarily. And then the ability to respond very quickly to energy and operating reserve needs of the power system, any time of the day or calendar year.” He states that “We can manage…” But there is nothing backing up the statement. Nothing that proves there is a surplus amount of renewable energy reaching NMPS to state clearly that “We do manage…” or “We will be managing…”   The implication is that NMPS is a necessity here in order to implement renewable energy in the region. Where is the science to back that up? Solar is not around at night. And the region is sub-marginal for large-scale wind, as well as lacking in opportunities for securing thousands of acres of right-of-way here. So, where is the implied connection between these two facilities—beyond fisheries destruction?

Michigan, with its open face to the winds—which do blow at night, apparently ignores the to damage to its Great Lake ecosystem and fish, and tallies the wind-energy driving Lake Michigan waters and uphill to its pumped-storage plant as “renewable.” We don’t have that wind here, and solar power generation is a whole different animal–not in any way the high-octane source needed to push a river uphill at NMPS. FirstLight has built a 2 MW solar installation atop the 11 acres of land it was mandated to construct for silt-settling ponds by the EPA in 2010 after being sanctioned for massive infractions of the federal Clean Water Act by dumping up to 45,000 tons of pumped storage reservoir silt and sludge into the Connecticut River , the company has not included any information on how that solar facility connects to, and interacts with, and powers its pumped storage operations. Unlike large-scale wind, solar does not deliver its energy at night–when NMPS asserts that it will do most of its pumping.

Pumped storage can only be deemed “renewable” energy in a generating environment where ecosystem impacts are not considered. Pumped-storage itself was a net-loss bargain that was ill-considered even back when there was actually surplus nuclear available in the region. Now this taking-of-a-river is mostly accomplished at NMPS by climate-warming, non-renewable fossil fuels. This is a lose-lose situation for renewable energy use–and for an ecosystem.

GDF-Suez FirstLight’s NMPS plant does feature “black-start” capabilities, and does offer FERC and ISO the ability to accomplish load-leveling at certain critical times. However, these attributes must be balanced against long-standing federal and state efforts to complete a forty-seven year old migratory fisheries restoration on the Connecticut, and the public’s long-term need to have a sustainable Connecticut River ecosystem. NMPS operations also need to adhere to federal and state environmental law.

In 1995, Consumers and DTE paid the public $172 million for their past fish kills of the previous decades. Thus far, the public has not been compensated for the on-going taking of fish at NMPS on the Navigable Waters of the United States, nor have citizens in MA, VT, NH and CT been able to reap the benefits of anything near the stated goals of a four-state fisheries restoration program targeting recreation fishing and harvestable seafood.

Studies with measurable results are required for a fair relicensing process. Stated steps in the FERC relicensing process should be followed to allow the public a contextual look at the operations before the need to suggest studies or prepare testimony. To facilitate a fair process, FERC should require context and full disclosure of all submitted documentation on the part of the applicant, as well as phone conference transcripts to allow an understanding of the ongoing dispute procedure.

Placing a net in front of LPSP and NMPS has not stopped the fish kills at either plant. A band-aid should not be applied to a gaping wound. Complete and proper studies of all life stages of fish mortality are needed for NMPS relicensing. Regulatory pumping and generating restrictions that protect the public resources of US citizens are overdue and necessary there. The studies needed to accomplish this should take place before any new license allows this ongoing “take” to continue through 2048.

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.

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