National Marine Fisheries Service

Archived Posts from this Category

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

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

Copyright © 2016 by Karl Meyer

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

besttfemptybed

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

Rolling over on a river

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

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

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

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

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

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

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

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

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

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

HOLYOKE HOISTS RECORD SHAD NOS; TURNERS FALLS FOUNDERING ON ALL FRONTS

Posted by on 13 May 2016 | Tagged as: American shad, Connecticut River, federally-endangered shortnose sturgeon, GDF-Suez FirstLight, Greenfield Community College, Holyoke Fish Lift, National Marine Fisheries Service, New Hampshire, NOAA, Rock Dam, salmon, shad, shad fishing, shortnose sturgeon, Test flows, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

P1000397

Copyright © 2016 by Karl Meyer

According to USFWS Connecticut River Coordinator Ken Sprankle on Thursday, May 12, 2016, the Holyoke Fishway lifted more fish—specifically 54,006 American shad, than on any single day in the fish lift’s 61 years of operation. In 1955, something simple and sensible came into being on the Connecticut. It was a fish passage set-up that brought shad directly upstream in the riverbed via upstream attraction flows, and drew them into an elevator that gave them a lift directly above South Hadley Falls. Once there they could head upstream toward open spawning habitat in Vermont and New Hampshire. For three generations, Holyoke has been the single largest fish passage success site and story for American shad on the entire East Coast.

Sadly, just 36 miles upstream, those shad met with the fish passage restoration boondoggle-disaster of all-time—a three-ladder fish passage puzzle that forced all fish into a 2.7 mile long power canal at Turners Falls. Steered out of the river, and forced to negotiate a turbine lined canal in order to make it upstream beyond the Turners Falls Dam, the average annual success rate was 4 fish out of 100. To focus in a bit more on the present, what Holyoke passed yesterday was nearly the equivalent of all the shad that made it past Turners Falls Dam last year: 58,000.

The Turners Falls Power Canal remains the dead end, adjacent to the Connecticut River’s Dead Reach, where the federal/state Connecticut River migratory fisheries program has lingered in a comatose—nearly frozen state, since those ladders were built in 1980.

Given the brief nature of spring spawning conditions, it’s likely—at minimum, 25,000 of yesterday’s shad from Holyoke will be attempting that torturous labyrinth in Turners Falls by midday today (Friday). Most won’t make it past, and most will expend over a week of their precious spawning energies in the attempt. A high, though poorly studied or documented percentage, will ultimately be cut up in the turbines of the Turners Falls Power Canal.

Such is the legacy of non-intervention on behalf of the public’s fish, and the 45 year focus on creating a hatchery strain of salmon on a river system where the species had been extinct since 1809. So, again, Vermont, New Hampshire, and northern Massachusetts—sorry, but your fish are stuck down here in the miseries of a power canal and the Connecticut’s Dead Reach lacking suitable flows and fish passage.

On that note: it’s now six weeks since we had the first fish passage numbers reported from Holyoke Dam. Here at Turners Falls, we have nothing from GDF-Suez FirstLight and the Greenfield Community College students hired to tally them. The public’s fish, and the information as to their whereabouts, remains in private hands—most of it in the murky environs of a private power canal.

I’ll give you an on-the-ground update from my visits. At Rock Dam, just after midday on Tuesday, three anglers were working the site for shad. Curiously, there was a very clear “tide” line in the sand at the site—which is also the natural spawning ground for endangered shortnose sturgeon. The very recent high water mark was between 10 and 25 feet wide leading down to the water’s edge. It indicated a recent and significant change in flow there. One of the gentlemen said the drop came quickly, and had only happened “fifteen minutes ago.” Such “ramping” up and down of flows by the power company has huge implications for migrating and spawning fish. In fact, ramping at this site is one of the key reasons for spawning failure for endangered sturgeon. But, who’s watching?

Anyway, the three anglers reported that the shad were running here before the flow drop—there were several in two buckets, but they had disappeared once flow conditions changed.

I returned to Rock Dam on Wednesday, and there was just a lone guy and his dog present. His name was Shawn, and he’s lived nearby for the past year, but this was his first outing for shad. He looked to be in his early 20s.

There must’ve been plenty of shad trying to pass upstream at Rock Dam—with extra “test” flow water being released at the dam for federal relicensing studies. It wasn’t a minute after I clambered up the rocks to speak with him that he hooked his first fish. I obliged and took his photo with it. While there, I also took a minute to explain that shad don’t survive handling well, and they do best if handled very gently and while right in the water at the shore line.

I only tarried only for five more minutes–in which time Shawn landed two more fish, and four new anglers had scrambled down to join the shad run at the Rock Dam.

The latest Connecticut River shortnose sturgeon count at Holyoke Dam: 15 fish—ostensibly on spawning runs to that self-same Rock Dam spawning haven, have been lifted in the fish ladder this spring–and stopped abruptly once reaching the top floor. Every one of them has been slapped on the nose with a newspaper, told “NO!” and been dropped back in the drink below the dam. “Wait till next year..!” Hey, National Marine Fisheries Service: that is award-worthy endangered species protection through genetic deprivation! Kind of makes you miss David Letterman and his Stupid Pet Tricks…

DEAD REACH REPORT: the BLACK HOLE continues…

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

DEAD REACH REPORT: the BLACK HOLE continues…

Copyright © 2016 by Karl Meyer
P1000522

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

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

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

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

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

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

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

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

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

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

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

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

No “Springtime for Sturgeon in Holyoke…”

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

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

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

Copyright © 2016 by Karl Meyer

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

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

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

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

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

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

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

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

Connecticut River Dead Reach Update: April 29, 2016

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

Connecticut River Dead Reach Update: April 29, 2016

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dear Secretary Bose,

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

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

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

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

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

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

“Effect of hydroelectric operations on spawning”

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

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

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

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

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

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

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

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

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

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

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

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

RE: P-1889 and P-2485

Dear Secretary Bose,

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

Thank you,
Karl Meyer

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

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

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

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

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

Study 3.3.11 – Fish Assemblage Assessment
�Requested Study Modifications

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

Comments on Requested Study Modifications

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

Discussion and Staff Recommendation

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

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

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

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!

Greening Greenfield’s “Green Hero” for September

Posted by on 11 Sep 2015 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC licensing process, Fish passage results, Greenfield Recorder, Greening Greenfield, Holyoke Fish Lift, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Rock Dam, shortnose sturgeon, teachers, The Recorder, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS

Greening Greenfield’s “Green Hero” for September

I’ve had the honor of being selected as Greening Greenfield’s “Green Hero” for September, 2015. The award was announced in the pages of The Recorder on September 9th; the text from that piece is attached below.

Thanks to all the people of Greening Greenfield for extending me that recognition—as well as focusing on the importance of the critical artery in Western New England’s ecosystem, the Connecticut River. Greening Greenfield has been hard at work locally on issues of climate and sustainability for over a decade. Their efforts reach into all aspects of local energy, economy, and quality of life issues. They’ve made great strides in steering Greenfield toward an environmental future that will nourish coming generations. www.greeninggreenfield.org .

A special thanks from me to Susan and Dorothy.

Text of The Recorder piece follows:

A Passion for the Connecticut River

The first thing you notice about Karl Meyer is that his eyes light up when he speaks about the Connecticut River and the fish that live in it. His commitment and enthusiasm shows through in his words and in every action he takes.

In the 1970s’, Karl was interested in the river for its scenic qualities. But in the 1980’s, he visited Holyoke fishway during May spawning season and observed some of the more than a million fish moving through lifts there. One year 720,000 American Shad and 500,000 blueback herring came through the river at Holyoke. That image never left him.

Since that time, Karl has concentrated on the needs of the fish in the river, with a particular concern for American shad and the shortnose sturgeon, an endangered species. Karl believes the Connecticut’s restoration concentrated on the wrong species. The U.S. Fish and Wildlife Service put a great deal of effort into stocking the river and building fish ladders for Atlantic salmon, a fish extinct here since 1809. That emphasis diverted attention from shortnose sturgeon, shad, and blueback herring, none of which benefit very much from those Turners Falls fish ladders which diverted all migrants into the Turners Falls power canal.

In 2015, 410,000 American shad passed through Holyoke, but because they are diverted out of the river and into the power canal only 60,000, fewer than 15%, made it past Turners Falls to reach open, upstream spawning grounds. This is clearly unsustainable. Today’s US Fish & Wildlife Service passage goal is 60% passing Turners Falls. Their original 1967 target was 75%.

With fewer fish making it to food-rich, open habitats, fewer newborn fish survive. There will be fewer fish for eagles, herons and osprey, and fewer for anglers and the public to consume. Eventually 15% of very little will result in the failure of the restoration to return vibrant shad runs to three target states.

Karl has a simple solution for this problem. Require life-giving flows in the river throughout spawning and migration season. When fish aren’t diverted into a turbine-lined power canal they’ll have a much greater possibility of making it to spawning grounds in MA, VT and NH. It’s a last chance for river restoration.

The other great danger to river health is the Northfield Mountain Pumping Station. It draws on the 20 miles of river backed up behind Turners Falls Dam, pumping it uphill to a 5 billion gallon reservoir. Northfield hugely impacts river flows and migration.

“An original design proposal had Northfield closing during migration and spawning season. Implementing that today would return more natural flows to the river. It would allow fish to migrate directly upriver in natural habitat, and let sturgeon gather and spawn successfully at their ancient Rock Dam spawning site,” stated Karl.

So how do we encourage this change? Easy. Right now the Northfield and Turners Falls/Cabot Station facilities are both up for 30-year relicensing with the Federal Energy Regulatory Commission (FERC). We can all comment on the relicensing of these plants at http://www.ferc.gov/docs-filing/ecomment.asp. The FERC project number for Northfield is P-2485; Cabot Station is P-1889. Advocating that our river run free during spawning and migration season could make a huge difference in improving the health of the Connecticut.

Karl would like to see local high schools adopt the National Marine Fisheries Service’s SCUTES Program and encourage monitoring of tagged, adult shortnose sturgeon at their ONLY documented natural spawning site, The Rock Dam in Turners Falls. By developing an awareness of the numbers and needs of these endangered fish, students will build a new relationship to this river. http://www.greateratlantic.fisheries.noaa.gov/prot_res/scutes/kits.html

For his tireless work to create a healthy Connecticut River and a vibrant fish population within it, Karl Meyer is our Green Hero for the month of September.

Sucking out the river’s life

Posted by on 11 Aug 2015 | Tagged as: 5-year FERC licensing process, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, EPA, Federal Energy Regulatory Commission, FERC, FERC license, GDF-Suez FirstLight, National Marine Fisheries Service, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, Relicensing, The Recorder, Turners Falls dam, Turners Falls power canal, US Environmental Protection Agency, US Fish & Wildlife Service

The following piece appeared in The Recorder in Greenfield, MA in the first week of August.

Sucking out the river’s life

Copyright © 2015 by Karl Meyer

Whether it’s Federal Energy Regulatory Commission licensing for a sprawling gas pipeline or a cluster of power projects on the Connecticut, the public isn’t getting the accountability and voice its entitled to. That hit me after contacting Tobey Stover from the US EPA’s Region 1 Offices about GDF-Suez FirstLight’s Northfield Mountain Pumped Storage Station. I called EPA because FirstLight had just given notice they were cancelling part of an ongoing sediment-testing program to gauge the impacts of their giant Northfield station on the Connecticut’s ecosystem.

EPA mandated that long-term testing after FirstLight massively violated the Clean Water Act by “polluting the navigable waters of the United States” in August 2010. To wit: they’d dumped the equivalent of 30 – 40 truckloads of sludge directly into the river at Northfield—each day for over 90 days straight, until getting caught. In the largest case of profligate dumping in decades, miles of river bathed in over 45,000 cubic square yards of sludge—smack in the middle of fish spawning time. Continuous testing was being required, in part, for inclusion in GDF-Suez FirstLight’s application for a new FERC license to continue sucking giant gulps of river to generate secondhand electricity.

Despite what many think, Northfield is not a hydropower plant. It’s a double-energy-loss, net-cash-gain contraption. It’s an energy transfer, storage and resale operation—offering twice-generated electricity back to the grid at peak-demand, peak market prices. Northfield was conceived as a giant, nuclear-powered pump. It technically qualifies on the books as a 1,200 megawatt unit —the output of TWO Vermont Yankees, but it supplies just a sliver of peak-priced electricity to our market while creating the most ecosystem havoc. This is a power-consuming operation, run on imported juice. On its own it can’t produce a single watt of electricity—nothing clean or renewable about it.

Northfield was built to profit from pumping the river backward via cheap, excess electricity produced at night at regional nuclear plants. With the nukes closed, it continues slicing through a river’s aquatic life on a diet of climate-warming fossil fuels. To do so it must purchases giant blocks of wholesale electricity so it can spend hours slurping endless gulps of river uphill through slicing turbines. When reversed those turbines spit our river back out as expensive, twice-produced juice. Sadly, Northfield can only offer 6 – 8 hours of peak-priced energy to the electricity “spot market”—because after that its 5 billion gallon reservoir is spent, rendering it unable to light your nite light. Then they start buying up “virgin” electricity to suck the river backward again.

If those daily pulses of destruction were silenced, an ecosystem would begin to heal. Though they fancy themselves as a key component of the grid, Northfield Mountain’s own sludge so-fouled its turbines in 2010 that it was instantly, unexpectedly, shut down for half a year. Yet nobody noticed, no one went without power—not even when Vermont Yankee went off-line to refuel. Instead of customers paying the high cost of a ruined river–sold back to them less than half-alive at peak prices, they received once-produced electricity without the collateral damage.

Mr. Stover at EPA was pleasant and helpful. He confirmed the world’s largest private energy purveyor would be let off their continuous-sampling-hook–because equipment they’d purchased had experienced repeated problems. They’d further petitioned EPA, whining about difficulties supplying electricity to their samplers. Hummn… GDF-Suez offered to instead use its own consulting firm to build a model of the plant’s operations, substituting simulations for real-time federal data. EPA was leaning toward accepting that too. Really?

It appears Northfield’s massive impacts are simply too violent to be directly calculated—perhaps too costly to allow to cripple an ecosystem? Why not order GDF-Suez to buy new equipment and start over? And isn’t it time EPA did their own study of the impacts of the massive sucking and juicing of all that aquatic life—fish, plants, insect larvae, twice through the turbines, for hours on end, at upwards of 15,000 cubic feet per second? Think 15,000 bowling balls a second, for hours—first up, then back through again.

Northfield creates such crushing impacts it shouldn’t have been built. Once Vermont Yankee closed, its damages should’ve been sidelined as well—used only as back-up to provide brief, dense pulses of juice during emergencies. Yet today it continues to operate, even during spring-summer fish migration season. Its voracious water appetite plays a key role in the failure of the half-century old, four-state Connecticut River migratory fisheries restoration program, Congressionally-authorized in 1967 under the US Fish & Wildlife and National Marine Fisheries.

This corporate “self-determination” is the grim legacy of the Bush-Cheney Administration’s secret energy policies. With huge gas, hydro, and pumped storage proposals on the docket, public accountability has gone AWOL. In the Holy Grail of “corporate citizenship” industry is now its own watchdog–“self-reporting” to agencies on the impacts of its own energy production and pollution. Both concepts belong in the Oxymoron Hall of Fame. Giant companies are running the table on climate, pollution, impacts and price–as our regulatory agencies fail to act on behalf of the public’s long-term interests.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists. He is participating in the FERC hydro relicensing process for power plants on the Connecticut River.

« Previous PageNext Page »