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More Connecticut River citizens’ defense

Posted by on 13 Jan 2022 | Tagged as: America's best landscaped sewer, American shad, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River blog, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, fish kill, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northeast Utilities, Northfield Mountain, Northfield Mountain Pumped Storage Station, NU/WMECO, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, US Fish & Wildlife Service

THE CONNECTICUT RIVER’S CITIZEN DEFENSE continues:
While FirstLight’s secret January license “settlement” talks continue–centered around leaky net ideas and spit-and-glue window dressing at Northfield Mountain, the public is demanding that its 50 years of devastation cease.

https://www.youtube.com/watch?v=ybwy8MBiy9I
* * NOTE: ABOVE is a link to a Wilbraham Public Library ecology lecture series I was asked to take part in last November. The title of my presentation was: “LIVING RIVERS FLOW DOWNSTREAM.” IT IS A KEY HISTORIC PERSPECTIVE to understanding why we live in a broken ecosystem… * *

https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152

FirstLight led closed-door bargaining with state and federal fish and environment agencies are continuing here in MA, while an ongoing flood of citizen testimony to end Northfield Mountain’s license to kill continues at the Federal Energy Regulatory Commission.

THOSE DEMANDS–from no less than 77 people since November 13th, are also sending a very clear signal to the MA Division of Fish & Wildlife, MA DEP, the US Fish & Wildlife, and National Marine Fisheries Service:

DON’T SELL OUT New England’s Great River for another half-century!

* Read the latest public testimony targeting Northfield lethal ecosystem destruction entered into the FERC record further below.*

BUT FOR THE LONG VIEW, HERE’S A LITTLE ILLUMINATING HISTORY:

Only living rivers flow downstream. But that’s not what you find on the Connecticut River in the Commonwealth of Massachusetts. Here, 150 years after the US Supreme Court guaranteed safe upstream and downstream passage of migratory fish to and from New Hampshire and Vermont—and a full half century after the enacting of the Clean Water Act and Endangered Species Act, the Northfield Mountain Pumped Storage Station continues to chew-through, reverse and obliterate the key living ecosystem functions of New England’s critical central artery here in northern Massachusetts.

The grim prospects of allowing Northfield to be built were widely known by federal and state agencies half a decade before it began its deadly, net-power loss, river-reversing ecosystem damage. Here, from the same agencies that are today’s MA Fish & Wildlife, US Fish & Wildlife Service, and the National Marine Fisheries Service (the entities still publicly responsible for environmental enforcement and river fish protection), are their words from a key, signed, 1967 document:

“Statement of Intent for a Cooperative Fishery Restoration Program for the Connecticut River Basin”

“Based on the present fragmentary data available on the Northfield Pump Storage Project, it appears that this project poses definite limitations to an anadromous fish restoration program. These limitations involve the physical loss of eggs, larvae, and young fish of both anadromous and resident species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water. Studies, designed to minimize the potential adverse effects to fishery resources, should be undertaken in development of the design for the Northfield Pump Storage Project. In related studies, fish screens, barriers and deflectors, and flow regimen must be thoroughly investigated.”

Those agencies’ inaction, their failure to protect–while instead indulging in a massive frenzy to recreate an extirpated salmon hybrid in place of a fish not seen here since 1809, proved disastrous for the river’s still-living fish runs and species in this four-state ecosystem. Today, absurdly, a deadly Northfield Mountain soldiers on, while—50 years later those same agencies dicker with foreign owners over emplacing a new band-aid of a barrier net—one full of holes, upstream of that deadly, river-reversing suction.

In the “library” at the Connecticut River Watershed Council—today’s “Conservancy”, there is a boxed, mid-1960s promotional document from WMECO/Northeast Utilities. NU is today does business as Eversource, the perennial chief sponsor of the Conservancy’s Source to Sea Cleanup. That half-century old box contains a glossy booklet promoting the future construction of a Northfield Mountain Pumped Storage Station. The booklet includes several scenarios and options to premise how of its net-loss power pumping operations might be deployed.

One of them was a glaring red flag for the river, its fish, and an entire ecosystem…

The Watershed Council HQ has a private library within…

THAT SHUTDOWN OPTION, never implemented, was that Northfield’s impacts would be so detrimental to the river and life cycles of its migratory fish that it would have to be shut it down during fish migration season. But here again, no watchdog ever emerged to stand up and fight for a living Connecticut River in Massachusetts. Basically, the only protection ever offered was a net to protect their mythical, teeny, hatchery-bred baby salmon, leaving all the river’s other species to fend for themselves.

Thus Northfield’s gargantuan and lethal water and fish appetite still strangles New England’s four-state ecosystem today. And, half a century later, those same public agencies are allowing a power company to dangle the grim bait of temporary fish barrier net before them once more.

ABOVE IS AN EPA-ORDERED “silt barrier” mandated to be kept in place at FirstLight’s Northfield intake after they were caught flagrantly and clandestinely dumping a mountain of muck directly into the river for over 90 days straight in gross violation of the Clean Water Act. Looking closely, you can see it has FAILED, its anchors useless, and its floats flapping in the breeze along the shoreline downstream of Northfield’s sucking intake. Photo taken 10/2/2010.

Even two years after Northfield came on-line the Federal Power Commission–today’s FERC, still had not been given answers to information they’ requested of WMECO–today’s Eversource, including describing flows on a reversing river. This is a Xeroxed document from FERC:

20010120-0656 FERC PDF (Unofficial) 09/10/2014: January 22, 1974, from the Federal Power Commission to WMECO:

Robert E. Barrett, Jr.,President.
Western Massachusetts Electric Company
West Springfield, Massachusetts 01089

Dear Mr. Barrett:
The Commission staff is presently preparing the Draft Environmental Impact Statement for the Turners Falls Project (No. 1889) and requests the following information:
(1) In the revised Fxhibit W of the application (page 43, second paragraph), reference is made to the continuing resident fish study being conducted in Turners Falls Reservoir. Please provide a copy of the results obtained since the last Progress Report. If the study has not been completed, please indicate the date you expect a report to be available.

(2) In Exhibit W (pages 19, 20, and Figure 5), the conditions expected to produce flow reversals in the Turners Falls ‘Reservoir as a result of Northfield operation were set forth. Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows? Based on operational experience, are there any observed or anticipated changes in the patterns, durations, or velocities of the flows described therein? Your early response in providing this information would be appreciated.
Very truly yours,
Secretary

On October 16, 1974, WMECO’s lawyers finally replied in the negative to the Federal Power Commission’s questions, stating they still had not implemented the required study which would offer answers to questions about the impacts of reversing the flow of the Connecticut:

“Staff also inquired whether the Company had a study on the effect of hydrology caused by the pumping of Northfield Mountain project this year. The Northfield Licensees have not made a formal study but are accumulating data with respect to Pond elevations, flows and other operating data.”

EVERYBODY KNEW 50 YEARS AGO: yet nobody came to the Connecticut’s rescue…

BUT TODAY CITIZENS are standing up for the living river owed future generations. SEE BELOW for the latest entries into the FERC public record…

BUT FIRST, here’s how it can be done:
Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

HERE ARE THE LATEST:

Document Accession #: 20220111-5033 Filed Date: 01/11/2022
Elizabeth J Erickson, Colrain, MA.

As a long time resident of Franklin County I have for a long time been very concerned about the environmental and ecosystem destruction at Northfield mountain because of the power generating plant there. I have been following the research about the decline in fish populations in the Connecticut River nearby because of the turbines and am strongly opposed to the reicensing of the First Light hydropower plant there. I’m actually shocked that the relicensing is even being considered given all that is now known about how destructive the plant is. Please deny any future license of power generation of Northfield Mountain.

thank you,
Elizabeth Erickson
Colrain, Massachusetts

Document Accession #: 20220111-5005 Filed Date: 01/11/2022
John Hoffman, Shelburne Falls, MA.

I am writing to ask that you deny a continuation of the license for FirstLight Hydro Generating Company. The project began as a way to make use of excess power from the Vernon Nuclear Power Plant. That plant is now closed. This license is now simply a vehicle for FirstLight to use its capitol to make a profit.

That profit comes at the expense of the Connecticut River, one of the glories of New England, and the source of outstanding agricultural soils in the Connecticut River valley. Now that we possess a vastly more sophisticated understanding of river ecology, the damage to the river is elaborately documented.

By sucking large volumes of water out of the river and then disgorging them back, the company erodes the river banks which in turn damages water quality. The turbines through which water is sucked destroy aquatic life, from adult fish, to their young and down to their eggs.

This is a primitive way to treat a river. No company in our present era should be allowed to inflict such damage. This river is a part of the commonwealth of Massachusetts. We the citizens ask you to protect the invaluable ecosystem of our preeminent river and deny FirstLight its license.
Future generations will thank you.

Document Accession #: 20220111-5004 Filed Date: 01/11/2022
Molly Freeland, Gill, MA.

To whom it may concern,
I am a resident of Gill Massachusetts and I request that you do not let Northfield Mountain Pump Station renew their license. The pump station is killing all life it sucks up from the river. Millions of fish are dyeing every year, including endangered short nose sturgeon. The pump station causes major erosion in the river banks which then spreads pollution. The pump station is escalating climate change when we need to be looking to renewable energy sources. Please say no to the pump station for our children, grandchildren, all life and the planet.
Sincerely,
Molly Freeland

Document Accession #: 20220111-5002 Filed Date: 01/11/2022
Irma Lorraine Pearson, Greenfield, MA.

If we, residing in the Democratic heart of our country, cannot save the only large river we have, and all the life in it, we are putting our imprimature on the destruction of our planet for the sake of building private fortunes.

The cautionary tale of Midas and his gold works very well here.
Let’s try another path, of freeing the rivers of dams and reversals, and saving 50% of our ecosystem as wilderness.

NO DEAL: amid public opposition FirstLight’s secret Northfield Mountain settlement plans stumble.

Posted by on 10 Jan 2022 | Tagged as: America's best landscaped sewer, American shad, Canada, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Endangered Species Act, EPA, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, migratory fish, Nation's best landscaped sewer, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Public Comment period, shad, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, USFWS


NO DEAL: amid public opposition FirstLight’s secret Northfield Mountain settlement plans stumble.

Failing in December to secure a secrecy-shrouded agreement, foreign-owned FL petitions FERC again for what’s now an open-ended “Delay of Action/Extension of Time” request. Thus the opportunity for critical public testimony in FL’s Federal Energy Regulatory relicense bid for Northfield remains WIDE OPEN. (**SEE simple FERC filing instructions at end of post)

As scores of public testimony to end Northfield Mountain’s devastation has poured into the Federal Energy Regulatory Commission of late, secret license deals with federal and state fish and agencies here in Massachusetts continue to elude FirstLight Power. The MA Division of Fish & Wildlife, US Fish & Wildlife, MA DEP and the National Marine Fisheries Service–responsible to the public for protecting the Connecticut’s migratory and resident fish, flows, and water quality under established law, are legally empowered with “conditioning authority” to end the half century of slaughter wrought by Northfield’s deadly suctioning. They currently hold the keys to determining if the Commonwealth hosts New England’s river-reversing, ecosystem grim reaper for more decades to come.

Democracy for coming generations means not leaving our river in the hands of a private corporation for ANOTHER half century.

FirstLight filed their latest FERC delay bid on January 4, 2022, the same day as Ethel White of Easthampton filed her FERC testimony stating, “I write concerning the Northfield, MA hydroelectric plant application for recertification. I strongly request that recertification be denied,” Meanwhile, FirstLight, that same day filed a “Continued Request to Defer Issuance of Notice of Acceptance / Ready for Environmental Analysis” with FERC for their Delaware tax-sheltered MA facilities here. Yet, with this latest delay request it appears they’ve discovered their venture capital plans for the Connecticut River are not being swallowed whole here in New England.

Parent-owned by Canadian venture capital giant PSP Investments, FirstLight has once again punted on deadlines in what has now become a decade long slog to continue the massive predation of the region’s key ecosystem artery, after a full half century. In its own January 4, 2022 filing FirstLight again begged FERC for relief of its own previously promised deadlines: “FirstLight requests that the Commission continue to defer issuance of the REA Notice until after January 31, 2022, to allow the parties to focus on the agreement in principle. If the parties are able to reach an agreement in principle by that time, they will then request that the Commission further defer issuance of the REA Notice to allow for negotiation of a fully developed, binding settlement agreement that the parties would submit to the Commission as an offer of settlement pursuant to 18 C.F.R. § 385.602.” An “REA” is FERC-speak for “ready for environmental analysis.”

In its Final License Application FirstLight’s big bid as a concession for the massive sucking fish kill annually at Northfield was a temporary 1,000 foot net, with ¾ inch mesh, to be deployed from upstream, and angled to near its suction tunnels to deflect some of the 24 species of adult fish from its giant, river-reversing vortex. That is literally a year round open door to the obliteration of 100s of millions of eggs and tiny young of developing migratory American shad and the two dozen resident and migrant species of the river—but in particular the key spawning, rearing and out-migrating months between late May and mid-October…

Importantly in that regard, the window for DEMOCRACY on our Connecticut River remains wide open for citizen to go on the public with FERC, and as well in the region’s media. Of late, literally scores of citizens have done just that, in FERC testimony that Northfield’s devastation must end and no new license be offered to FirstLight.

Below is Ethel White’s full January 4th on-the-record testimony, from the same day FL requested more FERC time for their venture capital plans for New England’s Great River, its life, and the future generations who are all entitled to a living ecosystem.

* * But first, here’s how you can stand up, on-the-record, in this critical time for the Connecticut River’s future:

GO TO: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

Document Accession #: 20220104-5000 Filed Date: 01/04/2022
Ethel S. White, Easthampton, MA.

I write concerning the Northfield, MA hydroelectric plant application for recertification. I strongly request that recertification be denied. Your commission’s decisions are key to how we deal with climate change. The vast majority of Americans believe that climate change is one of the top issues of today, if not THE top issue. We are on the brink of losing our planet’s ability to sustain human life, and large hydroelectric plants are not beneficial to rivers, aquatic life, or human existence. The Connecticut River is a vital artery in New England, and losing it to environmental degradation would be a tragedy. I hope the Commission will regulate this particular energy source in the proper way, by closing it down.
Sincerely, Ethel S. White

* * Agency heads and personnel representing the public trust:

wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service; andrew.tittler@sol.doi.gov, lead council at the table for USFWS; melissa_grader@fws.gov, at the table for our migratory fish; julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon); william.mcdavitt@noaa.gov, at the table for our migratory fish; mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife, jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife.

The Connecticut River’s staunch public defense broadens…

Posted by on 02 Jan 2022 | Tagged as: America's best landscaped sewer, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, conservancy, Conte National Fish & Wildlife Refuge, CRC, defense, E-Comments, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC license, FirstLight, Hudson Riverkeeper, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Department of Energy and Environmental Affairs, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, right-to-know, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

THE PUBLIC CONTINUES TO STEP UP and defend the Connecticut River against a new half-century of ecosystem destruction.

IN THE LAST TWO WEEKS MORE THAN 40 CITIZENS–and counting, have entered testimony into the Federal Energy Regulatory Commission public record stating that the Northfield Mountain Pumped Storage Project is too destructive to be relicensed.

You can read the latest citizen FERC filings–and get directions for filing your own, further below.

These on-the-record defenses become part of the Federal Energy Regulatory Commission’s input as they ultimately make their “Environmental Assessment” of FirstLight’s full and final license application some months down the road. FERC, too, is mandated to ensure that federal and state environmental laws and statutes are followed when deliberating the issuance of a license.

Will they follow the citizenry and release Northfield’s deadly choke hold on this ecosystem in Massachusetts after 50 years of destruction??

I wish I could promise that will happen. What I can promise is that the MA Division of Fish & Wildlife, the MA DEP, the US Fish & Wildlife Service and National Marine Fisheries Service–all agencies that have failed all these decades to protect and enforce environmental statutes and federal fish passage and protections on the Connecticut this last half century, will CERTAINLY be reading these comments. They will be reading them in the knowledge that people are paying attention as they participate in backroom “final” license negotiations with FirstLight.

WILL THESE AGENCIES, ALL WITH MASSACHUSETTS OFFICES, FINALLY STAND UP for what’s still the Nation’s best landscaped sewer here in the Commonwealth of Massachusetts–AGAINST this deadly, river-reversing scourge crippling an entire ecosystem??

THEY ALL OWE NEW ENGLAND A LIVING CONNECTICUT RIVER!

Why we find ourselves here after half a century is because the river here has been left undefended since the mid-1960s when the Northfield Mountain Pumped Storage Project was first proposed.

The photo above is of a little tourism, chamber-of-commerce Connecticut River promotion paddle that took place in October 2020. That little promo outing left from a site virtually next to the mouth of the Northfield Mountain’s deadly intake tunnels. That’s MA Secretary of Energy and Environmental Affairs Kathleen Theoharides in front of the camera, State Senator Jo Comerford is in the background on the left, and CRC Director Andy Fisk–though not pictured, was also a happy paddling participant that day.

While all were offered turns in front of those cameras and to talk to the print media on FirstLight’s turf–next to the grimmest machine ever installed on the Connecticut, NOT ONE spokesperson or representative took the opportunity to defend a defenseless river; not one made any reference to the grim fate of this ecosystem’s resident and migratory fish…imperiled, just yards away, when they had the opportunity to reach the public through the media.

Rather than green-wash the elephant in the room, any one of them could have offered this truth to the public: This river-reversing machine literally devours millions of eggs and young-of-the year migratory fish produced in a three-state(Vermont, New Hampshire and northern Massachusetts)river reach annually. Instead, they paddled and picnicked.

For comparison, a nearly mirror-image pumped storage proposal was brought up in the mid-1960s by Consolidated Edison for Storm King Mountain on the Hudson River at virtually the same time.

Unlike on the Connecticut, where a “watershed council” had been in business since 1952, the citizens on the Hudson got together and decided to FIGHT against turning Storm King Mountain into their river’s deadly sewer. They fought ConEd in the courts, and defended their Hudson River, openly, in the court-of-public-opinion, for 15 years–and WON. They proudly bragged about their mission, their willingness and duty to investigate, enforce, and prosecute. That’s what bona fide river protection looks like. They forced the state and federal agencies to DO THEIR JOBS! That’s what real watchdogs do.

Do a quick bit of research on Storm King Mountain, the Hudson River Fishermen’s Association, Scenic Hudson, and ultimately, Hudson Riverkeeper, and you’ll see what enforcement and real river defense models–with staff lawyers and enforcement, look like.

HERE, BELOW, you can read a new citizen’s defense–the latest public filings defending our river and it’s ecosystem. Another half century of failure is simply unacceptable:

Document Accession #: 20220103-5007 Filed Date: 01/03/2022
Frank Ribeiro, Bernardston, MA.

Hello
As a concerned citizen of Franklin County, Massachusetts, I have lived in the Connecticut river valley for fifty years. It is truly a wonderful place to live.

In today’s modern world there are many environmental challenges that we face to maintain the balance of nature. The one problem that has been obvious to me over the many years is the constant assault to our beautiful river.

We need to stop this assault and abuse. FirstLight MA Hydro LLC license request to continue operation of the Northfield Mountain Pumped Storage must be rejected.

For the sake of company profits OUR river is out of balance. It needs your help to secure its future and the future of ALL things living who are dependent on its survival in a natural, balanced state.

Please reject this application.

Thank You
Frank Ribeiro

Document Accession #: 20220103-5010 Filed Date: 01/03/2022
Andrew Hutchison, Greenfield, MA.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem. This system is clearly harmful to endangered species, such as the shortnose sturgeon. While the facility has been bought and sold numerous times over the years, the attention to preserving the ecosystem has been ignored repeatedly in search of profits. While private businesses have a right to seek profits for their shareholders, that does not supersede the endangered species act or the right of the stakeholders to a healthy river.

Document Accession #: 20220103-5011 Filed Date: 01/03/2022
Mark Russo, Deerfield, MA.

RE: the request of First Light for re-licensing of Northfield, MA pumped storage facility (FERC project number P-2485). I have serious concerns about the damage caused by this facility to the critically important Connecticut River eco-system as graphically detailed in editorials submitted by Karl Meyer and published in the Greenfield Recorder. If your decision is to renew this controversial license, strong environmental safeguards must be required and regularly monitored; and given the current global environmental crisis, the term of the license renewal should be substantially reduced from 50 years to 25 years or less.

Document Accession #: 20220103-5012 Filed Date: 01/03/2022
Judith Phillips, Northfield, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

Dear Commissioners,
I am seeking to comment on First Light’s relicensing bid for the Northfield Mountain Pumped Storage Station on the Connecticut River.

As a Northfield resident I urge FERC in the strongest possible terms to NOT relicense First Light’s Northfield Mountain Pumped Storage facility for another 50 years for the sake of all aquatic life in our beloved Connecticut River ecosystem. The River is in a perilous position with its ecosystem teetering in these “confidential” final license settlement negotiations between Canada-owned First Light and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries that has been taking place during this December. All that has been discussed and ?agreed to? is being done behind closed doors.

I believe these license settlement negations should be moved out into the light of day and into a public forum.

In addition to the pumping station in Northfield adversely impacting our River by wasting energy from fossil fuels that they burn to send water uphill just so it can flow down back into the river which destroys the fish, and more recently First Light is impacting our tax base. Regarding taxes, First Light is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

For me, in the face of the huge environmental crisis we all are in and the current environmental damage that is occurring daily from the Northfield Mountain Pumped Storage Station, for FERC to renew a 50-year license to First Light’s outdated pumping station should be unthinkable! Further I believe this ancient energy provider, is the exact opposite of sustainability both energetically and ecologically and needs to stop now!

Laura Doughty, Wendell, MA summarized it well.
“If we are to have any chance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It isridiculous to let this corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.”

Please DO NOT relicense the Northfield Mountain Pumped Storage facility for the people and the environment upon which we depend for our continuing survival.

Judith Phillips
482 Orange Road
Northfield, MA

Document Accession #: 20220103-5013 Filed Date: 01/03/2022
Priscilla Lynch, Conway, MA.

I am writing to express my strong opposition to the renewal of FirstLight’s license to operate the Northfield Mountain Pumped Storage Station on the Connecticut River in Northfield, Ma. It is way past time to cease this destructive assault on our environment, the river and its ecosystems. As you know I am sure, this facility uses power from the grid to pull the river’s water back and up the mountain to be released at peak times at peak prices. In the process it churns, chops and spits out fish and other essential aquatic life. At a time when our very best efforts should be to heal and preserve our waters and ecosystems as a means to ensure the very survival of life on earth, it is irresponsible to continue operation of this facility. FirstLight does not offer solutions or healing to our environment. It is foreign corporation making a great deal of money on losses to our environment and our well being. Please consider it your duty to act responsibility and do not renew FirstLight’s license to operate the Northfield Mountain Pumped Storage Station. As public servants, doing so will be doing immense good for those you are intended to serve. By not doing so, you will continue unnecessary extreme environmental damage and loss and will continue to feed the pockets of a foreign corporation at the expense of those you are intended to serve.

Priscilla Lynch
Conway, MA.

BE HEARD!! NOW IS THE TIME to enter on-the-record testimony into the Federal Energy Regulatory Commission’s public licensing process.

HERE’S HOW:

Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

A Connecticut River extinction rebellion

Posted by on 30 Dec 2021 | Tagged as: American shad, blueback herring, Clean Water Act, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, Death-Sewer, Delaware LLC, E-Comments, Environmental Protection Agency, EPA, Extinction Rebellion, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC licensing process, FirstLight, FISH and Wildlife Refuge??, Holyoke Co. v Lyman, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, nuclear power, P-2485, pumped storage, right-to-know, shad larvae, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, USFWS

A VIRTUAL CONNECTICUT RIVER extinction rebellion has been taking place in the region over the last 10 days. Since December 20, 2021, over three dozen people have gone on the record with the Federal Energy Regulatory Commission stating, unequivocally–and in the clearest terms, that NO new license should be issued for the continued operation of the Northfield Mountain Pumped Storage Station by FirstLight. You can read testimony from the latest thirteen people in the text that follows.

Many have taken this action upon being apprised of some of the most basic information about the high stakes games for the Connecticut’s four-state ecosystem being played out behind closed doors right now. Many learned of this through my Opinion piece, “Last light for New England’s Great River” that appeared in the Daily Hampshire Gazette and The Recorder on December 2oth and 21sth, https://www.gazettenet.com/my-turn-meyer-LastLightCtRiver-44127152 .

It outlined the perilous place our ecosystem is teetering in as “confidential” final license settlement negotiations between Canada-owned FirstLight and MA Division of Fish & Wildlife, MA Div. of Environmental Protection, the US Fish & Wildlife Service and NOAA’s National Marine Fisheries have been taking place during this month.

This citizen action has galvanized amidst the great void of leadership and wholesale lack of enforcement of any and all state and federal environmental statutes on the Connecticut River in Massachusetts these last 49 years. It’s been a half century of predation on a Connecticut River wholly lacking in a watchdog–in a state where a devastated 23 mile-long ecosystem reach literally flows backwards for miles at times, and virtually millions of resident and migratory fish are been obliterated, annually by the massive, daily, energy-squandering suction of Northfield Mountain’s turbines in their venture capital electricity resale boondoggle.

juvenile Connecticut River shad, dead

* *and this killing is NOTHING compared to the millions of juvenile fish extinguished at Northfield annually. Shad a just one species out of two dozen inhaled and obliterated there–an annual extirpation of literally hundreds of millions of juvenile and adult fish, eggs, and aquatic creatures each year.

Today in Massachusetts the Connecticut River at Northfield remains the deadliest “Nation’s best landscaped sewer”–far more drop-dead-deadly for fish and aquatic life than in the decades prior to the Clean Water Act.

I’m certain, if this river had a voice it would be raising it now to say thank you to the folks below, and the many others, who are taking a stand to save the soul of this ancient ecosystem. To read their words, please follow down.

* * ALSO, as we are at the holiday break, there is STILL time to enter your own on-the-record testimony to FERC. This ecosystem does not belong to FirstLight, or the Commonwealth, or the “environmental” agencies that have so long failed to protect it. It belongs to the children of the future. HERE’S HOW TO ENTER YOUR TESTIMONY:Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

THIS is the giant mess in 2010 made when Northfield operators failed at flushing out the accumulated muck, detritus, and death that had been sucked up from the river into their 4 billion gallon reservoir for years. They clogged their mile-long suction tunnels with several feet of mud, and later got caught and ordered to CEASE AND DESIST by the EPA, after dumping truck-load after truck-load of polluting muck directly into the river for over 90 days straight. In direct violation of the CLEAN WATER ACT. This is the MASSIVE RIVER DREDGING OPERATION the EPA ordered. Northfield went down for over HALF a year, yet everyone’s lights stayed on…

* AND HERE ARE THOSE WORDS OF SOME OF THE OTHER FOLKS CURRENTLY TAKING A STAND:


Document Accession #: 20220103-5000 Filed Date: 01/03/2022
Laura Kaye, Northfield, MA.

Dear Commissioners,
I would like to add my voice to those of my neighbors and fellow citizens of Massachusetts, who have written many thousands of words to you in support of our great Connecticut River, which has been so adversely impacted by the pumping station in Northfield – from the waste of energy from fossil fuels burned to send water uphill just so it can flow down back into the river, to the destruction of fish, and more recently impacting our tax base. Please read the detailed comments that so many people have sent to you and DO NOT approve the re licensing of the Northfield Mountain Pumping Station. For the people and the environment upon which we depend for our continuing survival.

Document Accession #: 20211230-5080 Filed Date: 12/30/2021
Mary Hall, South Hadley, MA.

I am seeking to comment on FirstLight’s relicensing bid for the NorthfieldMountain Pumped Storage Station on the Connecticut River.

I consider it is past time for that Pumping Storage Station to cease operation. The ecological costs of operation, as detailed by Karl Meyer of Greenfield, Mary J. Metzger of Westfield, and others is far too great for continued use of this facility to be justifiable.

Mr. Meyer explains how, in order to continue operations, FirstLight has undertaken to avoid tax payments for its use. In the event the facility was economically viable, it would not be necessary to obtain a tax shelter for it to continue to operate.

The Northfield Mountain Pumped Storage Station is a giant counterbalance to all of our efforts to maintain and restore our Connecticut River ecosystem. There is nothing anyone can do in advocacy for fish and other aquatic life that can remedy the harm that the Storage Station produces. To say again: The fact that FirstLight thought they needed a tax shelter for the Storage Station testifies to the fact that, even as a business, it is not economically viable.

I ask FERC to deny FirstLight’s bid to relicense the Northfield Mountain Pumped Storage Station for the sake of all aquatic life in our beloved Connecticut River ecosystem.

Document Accession #: 20211230-5007 Filed Date: 12/30/2021
Laura Doughty, Wendell, MA.
RE: Hydroelectric License/Re-license Proceedings FERC Project Number P-2485

I urge FERC in the strongest possible terms: Please do NOT relicense First Light’s Northfield Mountain Pumped Storage facility. If we are to have anychance at keeping a livable planet, we must start *now* to use wiser and more efficient energy storage technologies. It is ridiculous to let this
corporation use far more energy than it can ever create so that it can perpetuate its business model of buying low and selling high. From an energy conservation point of view it makes no sense, but when one considers the vast ecological damage this facility has been allowed to inflict, it is shameful that it has not been shut down long ago. Please do what is right for our river, and for our planet.

Document Accession #: 20211230-5000 Filed Date: 12/30/2021
James Smethurst, Deerfield, MA.

I am writing to oppose the relicensing of the Northfield Mountain Pumped Storage. It has had a devastating impact on aquatic species in the Connecticut River, some of which, like the shortnose sturgeon, are endangered. It serves no useful purpose other than to provide profits for out of state investors. It is not a renewable energy source, but actually an energy drain, given the power required to pump water from the river uphill. The nuclear power plant whose excess energy Northfield Mountain was supposed to repurpose is no more. It is time to close it down.

James Smethurst
5 Pleasant Avenue
Deerfield, MA

Document Accession #: 20211229-5002 Filed Date: 12/29/2021
Rebecca Robbins, Williamsburg, MA.
Dear FERC,

I am concerned about the fish and other aquatic life that get ground to bits at the Northfield Mountain Pumped Storage Station. Please do not relicense this facility without ensuring the health of the river and the creatures that live in it.

Thank you,
Rebecca Robbins
Williamsburg, MA

Document Accession #: 20211229-5000 Filed Date: 12/29/2021
Betsy Browning, Colrain, MA.

I am writing to voice my opposition to the relicensing of the Northfield Mountain Pump Storage facility. I have learned so much by reading the other letters that I feel morally obligated to add my voice. I grew up within a mile of the French King Bridge and remember the Northfield Mountain project being built. Both Northfield and Erving had great enthusiasm for the bountiful tax money they grew to rely on.

For 49 years the pump storage process has been decimating fish and wildlife along the Connecticut River. Amidst our climate crisis and the threats to species, this living river deserves our protection. Ironically this area is part of the Silvio Conte Fish and Wildlife protected area.

That FirstLight is a subsidiary of Canada owned power company and that they have moved their corporate assets for Northfield Pump Storage and the Turners Falls Hydroelectric to Delaware to avoid Massachusetts taxes, clearly shows their primary goal is maximum profit.

I understand its original plan was to use the excess power from the nuclear plant at Vernon which is now defunct. So using power generated by other means to pump water uphill is now wasteful of resources, outdated, and
impractical.

Someone voiced the brilliant idea that the mountain could be converted to a vast solar site.

Renewing a 50-year license should be unthinkable knowing both the environmental crisis in our midst and the current environmental damage that is occurring daily from the pump storage process.

Document Accession #: 20211229-5084 Filed Date: 12/29/2021
Paul Richmond, WENDELL, MA.

I have a questions why is First Light Power going to sign a new contract
which allows them to continue to use an old technology, which is destroying
the CT River and all life in it. I am speaking of the pumping stations, which sucks up everything in the river and kills it to be pumped out when energy is needed. Storage has been an age old question since we started producing energy. When you have access how to store it. When there was access Nuclear electricity at night when it is consider cheap, they would pump up the water to then release it when they needed electricity at peek times for more money. A reasonable idea if you are an energy company trying to make a profit. Then there is the method you use to do that. Today there are much better batteries being spurred on by alternative energy to address when the sun is shining or the wind is blowing. So why isn’t First Light being asked to stop the old method which was and is destroying the river and store the access energy in batteries, or compressed air storage in the new contract they are about to sign with the state. Please do not sign a new agreement with this in it.

Document Accession #: 20211228-5069 Filed Date: 12/28/2021
Sid Siff, Amherst, MA.

I am writing to oppose the rel icensing of FirstLight’s Northfield Mountain Pumped Storage facility on the Connecticut River. At the time of its inception in 1972, it was considered a renewable energy resource, and in 1975 I visited the site on a field trip for a Natural Resource class I was taking at UMass. There was much banter about the benefits of taking ‘extra’ energy from the nearby Vermont Yankee Power Plant in Vernon, and using it to pump water out of the Connecticut River and up to the top of Northfield Mountain, where it was stored and released to spin giant turbines, thereby creating ‘clean’ energy at times of peak demand. Since that time, not only has the nuclear plant been decommissioned, requiring fossil fuel based energy to operate the pumps, but it is well documented that the effect on the ecosystem of the river has been devastating. Multiple species of aquatic life are sucked out of the river in large numbers and killed, on a daily basis. The river acts as a narrow tidal basin, causing extreme bank erosion. The flow of the river is disrupted, leading to inadequate water levels downstream, and a resulting inability of fish to reach critical spawning habitat. Add to this the fact that the facility uses more energy than it creates, it is clearly not, and never was, a source of renewable energy.

Furthermore, FirstLight has demonstrated a clear disregard for not only every living species in the river ecosytem, but also for the people of Massachusetts, by registering Northfield Mountain and Turner’s Falls hydroelectric facilities into Delaware tax shelters, depriving Massachusetts of any tax revenue.

Perhaps by creating a closed loop system, with a reservoir at the bottom of the mountain that is completely separated from the river, and using any excess offshore wind energy to operate the pumps, Northfield Mountain could be a viable energy source going forward. But in its current state, it’s an outdated, dangerous and extremely harmful and wasteful behemoth that should be put to rest.

Document Accession #: 20211228-5066 Filed Date: 12/28/2021
Graham Hayward, NORTHFIELD, MA.

I do not want First Light’s bid for re-licensing to be approved. All they’ve done behind benefit of closed doors must be moved out into the light of day and a public forum.

This is one of many matters that won’t “fly” anymore and all those involved will be dealt with, these days of theft are over.
Thank you,
Graham Hayward

Document Accession #: 20211228-5065 Filed Date: 12/28/2021
Betsy Corner, Shelburne Falls, MA.
Concerning P-2485 for Northfield Mountain

For the past 50 years I’ve witnessed and read about the damage that the Northfield Mountain Pump Storage facility has caused to the Connecticut River and its inhabitants. Certainly common sense tells us that the kind of system that uses more energy than it produces is antiquated and foolish. It’s clear that relicensing this facility would be done in the financial interests of the owner of the corporation that seems to have power over those who are involved in granting another 50 year long license. Residents of the Connecticut Valley must have a transparent licensing process, not the closed door one that has been on-going. It’s high time to protect the river’s ecology and to look at the big picture of money and politics as it affects all of us in this decision.

Document Accession #: 20211228-5058 Filed Date: 12/28/2021
Dave Dersham, Northampton, MA.

I write to you concerning project number P-2485:
The kinetic energy that FirstLight consumes to push the Connecticut river
backwards and up Northfield Mountain, exceeds the potential energy eventually gained.

Simultaneously, 10s of thousands of small fry become pulverized by being
sucked into the hydro electric turbines placed at the midpoint of this
convoluted design. The result is essentially an aquatic Rube Goldberg killing machine, despite the substandard netting placed in the river meant to divert the inexorable fate of the baby fish.

This procedure, which has been going on for decades, is the exact opposite of sustainability both energetically and ecologically ” and needs to
finally stop.

FirstLight does not deserve to be granted another 50 year license.
Thank you for your attention,
Dave Dersham

Document Accession #: 20211228-5048 Filed Date: 12/28/2021
Garrett D Connelly, Greenfield, MA.

Hello,
I am writing this request that you revoke First Light’s operation permit for the Northfield Mountain Pumped Storage Facility so that you know one more person stands against United States policies that disregard life on Earth and serve only short term profit. And in this case it is a false profit.

FERC employees know short-term profits are small relative to the economic
benefits of a clean and free flowing Connecticut river as well as I do,
probably much better. For this reason I won’t try to fit a list of economic
and environmental benefits from a clean and free flowing river and simply
describe what clear thinking people in the future might do instead.

Visualize a line of pollution sensors across a free flowing river that is so clean it has become a world renowned tourist destination. One of the sensors registers a trace of some cancer inducing chemical and enlightened employees of a future country that cares about life spring into action. Chemical sensors follow the pollution to its source and the activity causing it is stopped and cleaned up.

We all know the energy used by consumer societies is leading to extinction of human life on Earth. The wealth generated by free flowing clean rivers can only happen when energy regulators know how much energy is required by a modern and healthy nation. FERC knows far better than I that the real economy does not require a fake enterprise destroying river life for unreal paper profits so I stop here.

Please think about it from a pro-life perspective and then deny the permit to operate a fake business that destroys real life. Deny the permit that allows operation of the Northfield Mountain Pumped Storage Facility.
Sincerely,
Garrett Connelly

Document Accession #: 20211227-5224 Filed Date: 12/27/2021
Robert F Porzio, Putney, VT.
Bob Porzio, Putney VT

Dear Federal Energy Regulatory Commission,
Please do not grant a new federal license for the Northfield Mountain Pumped Storage Station, P-2485. This plant has done huge damage to the river for the last half century, reversing flows and killing fish while squandering massive
amount of energy. As a Vermont resident it is unacceptable to allow this machine to kill migrating fish that should be reaching our section of river, but are swallowed by this deadly plant on their upstream and downstream travels. We folks upstream are entitled to a thriving river and a share of its migratory fish.

Thank you,
Robert Porzio
Putney VT