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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.

Bald eagles; canal shad and anglers up-close; fishy fishway windows

Posted by on 23 May 2015 | Tagged as: American shad, bald eagle, canal shad, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte, CRASC, Dead Reach, Federal Conte Anadromous Fish Research Center, federally-endangered shortnose sturgeon, fishway windows, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain Pumped Storage Station, power canal studies, Rock Dam, Rock Dam Pool, shad, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont

May 23, 2015. Turners Falls, MA. The test flows at Turners Falls Dam are now tamped down to 2,500 cubic feet per second. Thus anglers had given up fishing the riverbed below the dam yesterday(Friday) morning. However, the head gates beside the dam were open, releasing water at a good clip to course down the Turners Falls Power Canal. With little flow moving fish upstream in the actual river, it is commonly accepted knowledge that this forces fish to default to where they will find stronger upstream current to attract them. In this case that means a place 2-1/2 miles back downstream in the Dead Reach–the terminus of the canal at Cabot Station, where the power company dumps the river back into… the river. Thus, the canal becomes the impoverished, default habitat for migratory fish, attracted via privately- controlled flows that can be manipulated by dam operators. Thus, on Friday, just down from those head gates was the place where a few anglers gathered to fish the canal–just down the paved path to the low bridge behind the Great Falls Discovery Center.
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These gents were fishing shad that are part of the US Fish & Wildlife Service and the Connecticut River Atlantic Salmon Commission’s 1967 fisheries restoration mandate to move migratory fish upstream into New Hampshire and Vermont–to create a source of “seafood” for the public. These American shad, in Latin Alosa sapidissima–or “most delicious herring” were going to be eaten.
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With the main attraction flow coming from the downstream end of the power canal, it was primarily company flow through that conduit that was affecting upstream fish movements. Friday morning that flow was facilitating good numbers of fish in the viewing windows at Turners Falls Dam. The public’s fish and river should never be left in the private control of a corporation. That situation has resulted in the Black Hole of fish passage all these decades: the fish never reach Vermont and New Hampshire, and no one knows their fate after all upstream migrants are forced to enter the Turners Falls Power Canal.
A mile and a half downstream, there were two other potential anglers–perched in a cottonwood above the partially-flowing Connecticut’s riverbed. At just 2,500 cfs, they may have been licking their lips over fish that were confused or slowed and turning back in the river due to the withering upstream current. Slowed or stalled fish make for good eagle forage.
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Another half mile on down the river fishermen at The Rock Dam Pool were also happy to try and take advantage of a slowed or confused migration at this ancient site. Looking down from the rock ledge at the head of the pool, shad could be seen streaming through the water just 10 feet out. They moved by in tens and fives and dozens, but there was no way to discover whether they were milling through the edges of that frothy pool and simply returning to be seen again in an endless circling, or whether they were trying to shoot through one of the upstream notches in flows that were diminished by reductions at the dam.P1000433P1000432
Lastly, on “Migratory” Way, just down the canal past the USGS Conte Anadromous Fish Research Center, a crew of Conte fisheries people were inside FirstLight’s gates at the Cabot Hydro Station on the canal. USGS and the power company owners of the canal have been very close friends for decades now. Lab staff have worked for years on endless canal studies subsidized by Northeast Utilities, then NGS, and–of late, GDF-Suez FirstLight. Funny, though USGS holds the only National Marine Fisheries Service permit to study federally endangered shortnose sturgeon right here on the Connecticut, no study or tagging of sturgeon was done at all this year at their only documented natural spawning site–the Rock Dam Pool, just yards away from Conte Lab. And this, in a critical year of FEDERAL RE-LICENSING STUDIES.
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The folks in this picture are likely doing studies on migrating American eels. Power companies tend not to mind this type of work–as eels are difficult to study, they don’t spawn in the Connecticut River and thus are not an angler concern, and putting in “eelways”–which are wonderfully inexpensive, is a dirt cheap way to look “environmental” in the marketplace. Just as USGS Conte staff did endless canal studies with corporate study cash for decades on the TF Canal, they may be embarking on yet another cozy partnership, where years of data collection can be corporately subsidized, while true flows and fish passage upstream in the broken Connecticut River ecosystem through the Dead Reach here–and north past the Northfield Mountain Pumped Storage Station, gets ignored.
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The Turners Falls Power Canal’s emergency spillway chute and a portion of its failed fishway are pictured here, with a bit of Cabot Power Station in the background.

Spawning shortnose sturgeon denied flow at Rock Dam Pool

Posted by on 08 May 2015 | Tagged as: 5-year FERC licensing process, American shad, Atlantic salmon, blueback herring, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Endangered Species Act, ESA, Extinction, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Rock Dam, Rutland Herald, shortnose sturgeon, The Greenfield Recorder, University of Massachusetts, US Fish & Wildlife Service, Vermont Digger

PRockDamPoolDewatered (2)
(to view lager image, click on photo).

NOTE: the photo above documents conditions found at the Rock Dam Pool on the Connecticut River on May 3, 2015. Seventeen years of published studies conducted by federal and University of Massachusetts fisheries researchers at the adjacent Conte Anadromous Fish Research Center show that these river conditions cause spawning failure for federally-endangered Connecticut River shortnose sturgeon at the Rock Dam Pool, their only documented natural spawning site. The May 3rd river conditions found at Rock Dam mimicked mid-summer flows on the Connecticut–conditions that research shows drives spawning-ready females from the site, and de-waters the cobble-strewn pool where eggs and embryos attach and develop. April 25 to May 22 is the documented spawning window for the shortnose sturgeon on the Connecticut. It is a crime to kill, injure or interfere with endangered Connecticut River shortnose sturgeon under federal and state law. The Federal Energy Regulatory Commission, the National Marine Fisheries Service, the US Fish & Wildlife Service, and the MA Division of Fisheries & Wildlife are responsible for the protection of the Connecticut River’s only federally-endangered fish under the Endangered Species Act(ESA). GDF-Suez FirstLight controls river flows to this site via spill gate operations at the Turners Falls Dam, just upstream.

A RIVER PRESERVED IN PLASTIC Copyright © 2015 by Karl Meyer

(The following essay–with minor variation in each, appeared recently in The Recorder, The Rutland Herald, and at Vtdigger.org)

A lifeless, three-foot long Connecticut River shortnose sturgeon sits on display at the Great Falls Discovery Center in Turners Falls, MA. The shortnose has been this river’s only federally-endangered fish since 1967. That plastic sturgeon has sat amidst other replica fish for a dozen years now—a plastic American shad, a blueback herring, a trophy-size Atlantic salmon. They’re framed beneath a slightly-ruffled acrylic surface representing the Connecticut River at this flagship site of the Silvio Conte National Fish & Wildlife Refuge.

That display is the basic message offered to visitors here: ‘This is a river with congenial flows supporting populations of shad and herring, big native salmon, and federally-protected sturgeon.’

Nothing could be further from the truth.

Few upstream migrants reach Vermont and New Hampshire today. That’s part of the legacy of failure of federal and state fish agencies and watchdog groups claiming to safeguard an ecosystem and its native migratory fish. That legacy will remain intact until they confront ongoing conditions in Massachusetts that have been crippling the river here for decades.

That Discovery Center depiction falls apart if visitors simply walk outside onto the deck of the Turners Falls Bridge, adjacent to Turners Falls Dam. There, often for months on end, what they’ll see is the hollowed-out heart of New England’s Great River–a waterless chasm, or one teased by just a trickle from the power company’s dam. Conversely, when rain or snow send more river downstream than can be profitably sent through FirstLight’s power canal or stored upstream for their Northfield Mountain Pumped Storage Station, those spill gates open wide–producing violent, see-sawing flows few fish can fight or follow.

Meanwhile a 200 million year-old evolutionary gem, the Connecticut River shortnose sturgeon, remains all but abandoned just downstream–teetering on the verge of extinction for decades. Likewise, American shad can’t move upstream in the river here at all. They’re forced into that turbine-lined power canal where less than 1-in-10 will emerge alive beyond the dam. And those blueback herring–protected on paper as a “federal trust” species, have not been counted here in almost a decade. Just 20 years back they passed by the thousands.

That plastic salmon, showcased for decades as the darling of this river’s fisheries restoration, has been extinct here since 1809. It should not be presented as a living native fish. In science, extinct isn’t subject to interpretation.

That trophy-sized model derives from a massive hybrid hatchery program created by cross-breeding salmon imported from Canadian and northern New England rivers. For 43 years federal and state fish farms produced the millions of tiny fry dumped into the river each spring. Those fish factories repeatedly proved vectors for the potential spread of disease throughout the river system. Though those tiny fish proved great for public relations, no spawning population of engineered salmon ever took hold.

Hybrid salmon became the red herring that masked the massively broken ecosystem that exists on an eight-mile stretch of New England’s Great River from the Northfield Mountain Pumped Storage Station to the tailrace of the Turners Falls Power Canal. Those salmon were the stand-ins for agencies including the National Marine Fisheries Service, the USFWS, and MA Division of Fish & Wildlife that had failed to protect living migratory species here–and an ecosystem suffocating right in their backyard.

The plight of the only state- and federally endangered fish here represents the ultimate failure of responsibilities. Dr. Boyd Kynard spent decades studying the shortnose and documented it’s only natural spawning site–the Rock Dam Pool, less than two miles downstream of Turners Falls Dam. Dam operations there were annually creating conditions that crippled spawning success for the remaining 300 sturgeon still able to reach their ancient rendezvous site.

Kynard’s federal- and state-funded findings were given to fish agencies a decade back. Each bore legal responsibility for that sturgeon. Yet no agency or non-profit stepped-in to monitor and enforce Endangered Species Act protections. None intervened to halt the trickle-and-torrent flows preventing reproduction. That step alone would’ve put living waters back into the river here–aiding the shad and herring attempting to reach Vermont and New Hampshire. Likewise in 2012, when Kynard published a book on the shortnose–documenting its life history and the river conditions necessary for its recovery, again, no one went to court to protect this public legacy.

Had agencies and watchdog groups taken responsibility years back for protecting spawning sturgeon at that Rock Dam Pool below FirstLight’s dam, native migratory fish and the river ecosystem would be in a far better place today. Instead, that work was left to become part of the current studies in the Federal Energy Regulatory Commission’s 5-year relicensing process for the Turners Falls and Northfield hydro sites, where I’m on the Fisheries and Aquatic Studies Team.

Sturgeon spawning is not monitored today. It’s unconscionable to have waited for a 40 year relicensing process to come around before broaching concerns for an endangered fish and broken ecosystem. Hopefully it won’t prove the difference between a living river, and one merely depicted in a museum model.

Greenfield, MA journalist Karl Meyer is participating in the Federal Energy Regulatory Commission’s relicensing process for the Northfield Mountain and Turners Falls hydro sites.

A look inside the FERC licensing process

Posted by on 06 Jan 2015 | Tagged as: 5-year FERC licensing process, Drew Huthchison, Federal Energy Regulatory Commission, FERC, FERC license, FERC licensing process, fracked gas licensing, GDF-Suez FirstLight, ISO New England, Kinder Morgan, Kinder Morgan pipeline, Mt. Tom Coal Plant, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Project, shad, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, USFWS, Vermont Yankee, Yankee Rowe Nuclear Plant

In mid-December I was interviewed on Greenfield Community Television’s Local Bias feature by Mark Wisniewski, former Greenfield City Council President. In a wide-ranging talk we discussed my experiences with the ongoing Federal Energy Regulatory Commission licensing process as both a journalist and stakeholder in the hydro projects at Northfield Mountain and the Turners Falls Power Canal on the Connecticut River. The FERC licensing process is a cumbersome and lengthy ordeal–transpiring over a 5- year swatch of time.

Anyone interested in–or involved as a citizen in, the deluge of FERC projects currently affecting our region, might gain some insight by tuning in: from fracked-gas pipelines, to hydro, nuclear, climate and ecosystem impacts.

Local Bias airs beginning Wednesday, at 5:30 pm, and repeats on Thursday and Saturday nights at 9 pm throughout the month of January 2015.

Local Bias is produced and directed by Drew Hutchison.

Try the link below,.. or go to look up GCTV, Local Bias to connect to a copy of the show.

http://gctv.org/videos/local-bias-karl-meyer-121514

New CT River Stakeholder Comments Submitted to FERC

Posted by on 14 Nov 2014 | Tagged as: American shad, By Pass Reach, Cabot Station, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, FERC, FirstLight, GDF-Suez FirstLight, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following Stakeholder Comments/Requests on FERC Projects P-1889 and P-2485, Turners Falls Hydro and Northfield Mountain Pumped Storage were submitted on November 13, 2014 to the Secretary of the Federal Energy Regulatory Commission.

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

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

ILP COMMENTS–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 in order to continue plant operations beyond 2018. An Initial Study Report Meeting Summary has been filed by GDF-Suez FirstLight. Please accept these comments on the ISR and my proposals for modifications and new study requirements in the FERC ILP for these projects.

3.3.11 Fish Assemblage Assessment:

Further information/study needed:

FirstLight has declined to undertake any study in the By Pass Reach of the Connecticut River due to stated concerns of interference with spawning and development of embryos of federally endangered shortnose sturgeon in this area. Information from the 2009 EPA study is insufficient to quantify presence and abundance of resident and migratory fish in this reach during critical migration and spawning periods—April through June. That investigation used only 3 sites in the By Pass Reach and was not undertaken to illuminate key species requirements in the current ILP for this critical reach.

NMFS notes that FirstLight has failed to consult with stakeholders on SNS issues here. I am in agreement with USFWS that a dedicated snorkeling, SCUBA, or hookah diving assessment of this critical reach of the four-state CT River be conducted in the riverbed between the Turners Falls Dam and downstream of Cabot Station during the April-June migration and spawning window–and that it continue after FirstLight’s suggested June 30 beginning target date.

I personally snorkeled parts of this reach in May 2013 and found that identification of migrants and resident species was easily attained. An in-situ investigation of this river reach in order to assess species presence and relative abundance is necessary groundwork for making decisions that will impact the 45-year long fisheries restoration on the Connecticut.

Dr. Boyd Kynard, who FirstLight cites in their argument and who spent decades investigating shortnose sturgeon on this reach of the Connecticut told me (personal communication 11/12/2014) that this study method can be accomplished without impacting SNS from the pool below the Rock Dam upstream to the base of Turners Falls Dam.

3.3.12 Evaluate Frequency and Impact of Emergency Water Control Gate Discharge Events and Bypass Flume Events on Shortnose Sturgeon Spawning and Rearing Habitat in the Tailrace and Downstream from Cabot Station.

Further information/study needed: FirstLight has supplied a grid of information for emergency gate and by pass flume openings for the years 2005 – 2012, though 2010 is missing, and we have no information on gate openings and placement for 2011 and 2012 in some instances, other than that there were no instances when greater than 4 emergency flume gates were open.

This study information should be updated with full information for years 2011, 2012—as well as 2013 and 2014 gate opening numbers, placements and CFS information.

Study findings from Kynard and Keiffer, as well as the long-term study of SNS in this reach catalogued in Life History and Behaviour of Connecticut River Shortnose and Other Sturgeons, published by the World Sturgeon Society, 2012, specifically delineate emergency and canal flume gate spill as having a profound and deleterious impact on shortnose sturgeon spawning and early life stage development.

As was stated recently by sturgeon biologist Micah Kieffer at a fall 2014 meeting of the Connecticut River Atlantic Salmon Commission, “one instance” of ramped-up or ramped-down flow from TF dam or emergency spill gate and flume operation can abruptly terminate or abort spawning attempts at Rock Dam and below Cabot Station by federally-endangered SNS for the entire year. Operations of emergency and by pass flume gates on the TF canal also can have deadly parching or burying impacts SNS embryos.

FirstLight contends that its operations of Bypass flume gates above Cabot Station are aimed at either emergency load rejection at Cabot Station, or opened to flush debris. They also contend that it is rare to have more than one flume spill gate open, though most of the numbers belie this statement–and the number of days when 4 or more gates have been open during SNS spawning window is highly significant and impactful. Opening of 4 flume gates needlessly diverts flows approaching 4,000 CFS out of the Connecticut’s By Pass Reach at TF Dam, and sends it into the canal to be needlessly flushed back into the river in a configuration that impacts migratory species and imperils annual spawning attempts of the federally-endangered CT River shortnose sturgeon.

In May 2014, I personally witnessed 3 consecutive days when two or more spill gates were open at the TF canal bypass above Cabot—all at the same time of day: 12:25 pm. These openings occurred while both Station 1 and Cabot were generating, which would appear to indicate that the spill gates had been left in this position for hours, or perhaps days, as part of flow regulation in the canal–rather than emergency or debris clearing. I have sent this information to both FERC and the federal and state fisheries agencies.

It is clear to anyone who examines the TF power canal that it is mostly a lake-like, slow-water habitat, save for the thalweg. It is rare to see debris of any significant size floating in the canal. It gets culled off at the trash racks in front of the TF Gatehouse, or at racks on the canal that dog-leg off to Station 1, or it simply settles out in the lake section of the TF Canal.

The minor amount of small, floating debris that enters the fat part of the canal is culled off by the trash rack skirt above Cabot that steers it to the east side of the canal where a bascule gate can be operated to pass anything of significant size.

The continuous openings of two or more bypass gates, up to six and seven gates open on a “non-emergency” basis on the TF canal above Cabot Station during SNS spawning and early life stage periods threatens the recovery of the Connecticut River’s only federally endangered migratory species.

As I have witnessed, multiple gates open on the canal while both Station 1 and Cabot were in operation indicates that canal flow is at times being regulated at this site, rather than at the TF Gatehouse, where excess flow could be delivered to the river in the Bypass Reach, which would nourish, rather than destroy SNS chances for successful spawning at Rock Dam and below Cabot. During SNS spawning season, mid-April – June 30th, endangered species protections dictate that all flow, save for documented, specific emergency situations, by controlled at the Head Gates of the Turners Falls Dam.

Information for years 2013 and 2014 should further be included, and a Study and study season for 2015 should be implemented that documents both the reason and instances when emergency gates were open—and any flume gates above 1 that were open to vent flow from the canal to the ByPass.

I would also like to FERC to have FirstLight include information for 2010, as the May 4 time of 8-gate emergency spill operation occurred exactly at the time frame when Northfield Mountain had burped up a massive sediment spill into its intake, and was trying to flush that pollution downstream. It would be helpful to know the position of both the Bypass flume gates and the positions of TF Dam headgates and bascule and tainter gates at that juncture—as it most definitely impacted SNS present for spawning that year. This would again offer data on whether the TF canal flows were being regulated via emergency by pass flume operation.

3.3.14 Aquatic Mapping of Turners Falls Impoundment:

Further information/study needed:

If migratory fish targeted for restoration in Northern Massachusetts and Vermont and New Hampshire are to continue to be diverted into the TF Power Canal, where few emerge upstream, then an addition to this study should be conducted: Aquatic Mapping of the Turners Falls Power Canal—as it is technically an extension of the Turners Falls Impoundment, and the public has a right to understand the habitat where their fish get privatized.

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

Further information/study needed:

The 2014 Canal Drawdown study was flawed as it occurred over the course of two days, due to an error in spill gate function. Since this is a study of live and dead fish and organisms, as well as the presence of dissolved oxygen, a two-day study time frame represents a flawed evaluation. A night of drying, predation, and fluctuating oxygen presence confounds the results of this work. FirstLight does an annual drawdown of the canal—has down so for decades, thus a mistake at the time of a critical habitat study should corrected by conducting a second year of study.

Further, since FERC has ordered that FL conduct a study of American shad spawning in the TF Canal, it is important to note another anomaly in their canal drawdown work. At five-year intervals the TF Canal receives a full canal muck-out during drawdown. The last one occurred in 2009. This would have been the fifth year—a time when the major muck-out would occur. It did not happen. What occurred was canal “light”, with a large snafu in the middle of the one day study, making it a two day effort. Whether FL agrees that this should have occurred in 2014 or not, a big-dig in the canal is needed regularly, as the sludge, silt and muck settles out and fills in the wide part of the basin.

This must be figured into the “impacts” of the drawdown, as it has profound implications for forcing migratory fish into this habitat, as well as the survival of resident fish and aquatics.

Please see attached photo of the canal muck-out that I took in 2009.

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

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

 

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

Further information/study needed: the need for this 2016 study will be fully realized if planned studies of American shad movement and spawning in the canal confirm that these fish are experiencing significant migratory delay, and are being coralled into a migratory spawning trap by confused and insurmountable flows or pre-mature warming in artificial habitat that induces spawning in the canal—preventing fisheries restoration on the river in Northern Massachusetts, New Hampshire and Vermont.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Further information/study needed: I concur with FERC’s requirements of an intensive array of radio and telemetry receivers throughout the TF Power Canal to track migrating shad in the canal.

However, I request that FERC require FirstLight, in consultation with stakeholders, add an array temperature monitors calibrated to the radio and telemetry sites to understand whether canal delays for American shad–lingering for an average of 8 days in the TF Canal, are forcing these fish to spawn in this privatized, lake-like habitat because of warmed, shallow, and slow water conditions.

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

Further information/study needed:
I concur with FERC that a full spawning study of the Turners Falls Power Canal be conducted in 2015, undertaken in consultation with stakeholders. Temperature monitors should be deployed to assess impact on migratory delay and spawning on-set; and cumulative impacts of head gate and by pass use of spill gates should be factored into the study to determine the impact of silt deposits on spawning success.

3.3.9 Two-Dimensional Modeling of the Northfield Mountain Pumped Storage Project Intake/Tailrace Channel and Connecticut River Upstream and Downstream of the Intake/Tailrace

Further information/study needed: In the Initial Study Report Study Meeting Summary for stakeholder in October 2014, a request was made that FirstLight provide vector maps with arrows and indication of directional flow around the Intake and Tailrace Channel at the Northfield Mountain Pumped Storage Project. This is critical information for flow, erosion, and sediment displacement and needs inclusion.

This is information that has been missing on Northfield Mountain Pumped Storage Impacts since at least 1974. See attached at end of document.

Thank you for this opportunity to comment on these critical relicensing issues.

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

1974 attached file below.

 

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