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

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

THIS GREAT AND BROKEN RIVER V

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

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

Dear Vermont and New Hampshire (and northern MA):

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


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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

THIS GREAT AND BROKEN RIVER

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

THIS GREAT AND BROKEN RIVER

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 1, First Daylight for an Embattled Run

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

Connecticut River shortnose sturgeon: a spectacular failure to protect

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

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

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

“Dear Mr. Traester:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Enviro Show

The Shortnose Sturgeon are Coming to Spawn –in THIS?