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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

The wave of Connecticut River public testimony against Northfield Mountain continues to build

Posted by on 27 Dec 2021 | Tagged as: American shad, Connecticut River ecosystem, Connecticut River Refuge, conservancy, Conte National Fish & Wildlife Refuge, Federal Energy Regulatory Commission, FERC, FERC Comments, FERC licensing process, FirstLight, 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, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, shad, shad larvae, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, US Fish & Wildlife Service, US Supreme Court, USFWS

THE WAVE of Connecticut River public FERC testimony against Northfield Mountain continues building…

AMID the time when secret “final” settlement negotiations– initiated by FirstLight, are taking place out of sight with the US Fish & Wildlife Service, MA Fish & Wildlife, MA DEP, National Marine Fisheries, and others, MEMBERS OF THE PUBLIC are the ones standing up for a living future for the River and this four-state New England ecosystem.

They are not waiting for scripted guidelines from councils and conservancies that have failed to take on this profligate devastation for the last half century. They are going ON-THE-RECORD now–shining a light for the Connecticut River BEFORE any grim compromises get inked.

PLEASE READ DOWN to see the LATEST 8 entries into the public record. Though the “date of entry” is recorded as 12/27/2021, six of these eight testimonies were filed on Christmas Day and Boxing Day(the day after Christmas).

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.

THE LASTEST PUBLIC TESTIMONY STARTS HERE:

Document Accession #: 20211227-5019 Filed Date: 12/27/2021
Jon Burgess, Northfield, MA.

Northfield pump storage project constructed as direct adjunct to Vernon nuke power plant, to utilize what would be ‘wasted’ energy, as nuke plants can’t shut down easily. Vernon nuke plant is now dead. No more wasted energy to utilize.

The environmental damage done by the hydro storage plant far exceeds any ’emergency backup power’ justification. Their motive is simple & straightforward: Buy low, sell high, make profit.

I enjoy the tidbit benefits (boat ramp….) First Light offers. But it still can’t offset fish death, bank erosion, & other damages.

On a side note, it was a struggle to navigate the maze to get this message to you. I wish there were an easier way for the rest of Northfield to chime in on this issue, as there would be no doubt about the sentiment here. Thank you, JB

Document Accession #: 20211227-5009 Filed Date: 12/27/2021
John Nelson Jr., Plainfield, MA.

Regarding FirstLight Relicensing of the Northfield, MA, Pump Storage Facility:

This facility should not be relicensed; it is not a renewable energy source for peak electricity demand because pumping water uphill generates greenhouse gas. It has been also documented that the biota of the Connecticut River are harmed in the process. If, and despite these concerns, relicensing is to proceed, an environmental impact statement should be required. A solar installation with battery storage on top of the mountain would be a
much more suitable source of energy.
John Nelson

Document Accession #: 20211227-5008 Filed Date: 12/27/2021
Vicki Citron, Colrain, MA.

I am a concerned Massachusetts individual who lives near the Connecticut river. I drive over it every day on my way to work. It is appalling to me how low the river is and how high the adjacent canal is. FirstLight drains the river of all possibility of the river being a healthy and supportive environment for the fish and other wildlife that inhabit it.

To add insult to injury, FirstLight’s parent-owner, Canada’s PSP Investments, registered their Nothfield Mountain and Turners Falls hydro units into Delaware tax shelters. In addition to depriving aquatic life of its natural benefits, FirstLight is depriving Massachusetts of its due in tax revenue.

They are literally sucking river and the residents of Massachusetts dry.
Please do the right thing and deny a license renewal to FirstLight.

Thank you.

Document Accession #: 20211227-5007 Filed Date: 12/27/2021
Louise P. Doud, Warwick, MA.

The Northfield Mountain Pumping Storage Station has got to go. It does not make sense in this day and age. It needs to be closed forthwith. To expend electricity generated by fossil fuels from the regional electrical grid to pump water uphill just so the electricity generated from dropping tons of water back downhill into the river is made available for peak demand times is wasteful and foolish. Then there is the issue of its deadly effect on the
wildlife in the Connecticut River and erosion of its riverbanks over a span of 23 miles. Over the years of the Pumping Storage Station’s operation, the sucking up of tons of water, fish, aquatic animals and plant life has resulted in killing millions, and then their dead bodies get dumped back into the river. This is devastating to the ecology of the great Connecticut River.

On top of all this, First Light, the relatively new for-profit owner of the Northfield Mountain Pumped Storage Station, secretly moved its corporate assets for the station and their Turners Falls hydroelectric facility to Delaware – to dodge Massachusetts taxes. There is no excuse for this. FirstLight’s attempts to keep the public from understanding their abandonment of supporting local school and government infrastructures by spreading around donations here and there and garnering publicity from doing so is nothing
short of a betrayal. Whitewashing the truth. Greenwashing its corporate greed.Because, this is all about money. Not about our communities, not about caring for our regional natural environment, not about local charity. You have plenty of reasons to cite First Light’s behavior and the pumped storage station itself as deleterious to the state and the region and violating its agreements with the Massachusetts Fish and Wildlife and the
Massachusetts Department of Environmental Protection. Stop this madness and deny the re-licensing of the Northfield Mountain Pumped Storage Station.Now. Please. Do the Right Thing.

Document Accession #: 20211227-5006 Filed Date: 12/27/2021
Fergus Marshall, Chicopee, MA.

Dear members of the FERC e comment board,
My name is Fergus Marshall a lifelong resident of Chicopee Massachusetts. I have long enjoyed and respected the immense beauty of the river that my river, the Chicopee, flows into, the Connecticut.

I have been made aware just recently about a little known fact that has me very concerned. For many years I have been known of the project at Northfield Mountain, the pumped storage project which takes water from the river pumps it uphill to a reservoir during offpeak demand for electricity,stores it until there is peak load on the grid, then releases it to generate electricity, thereby creatingprofit an reliability.

This appears to have been successful for many decades but the terrible toll on aquatic life has been enormous. This facility actually causes the river to flow backwards, and in the process sucks the aquatic organisms through pumps and then through turbines killing everything. The Supreme Court ruling of 1872 mandates the safe passage for migratory fish so how is it that this is allowed?

I understand that this has, in the past, been a successful method of energy storage, however now its become an antiquated method that only makes profit for a foreign corporation, First Light of Canada.

This is almost the year 2022, are we not capable of a much better solution. Worldwide, innovators have been putting in place real solutions such as battery storage.

I am very concerned that First Lights profit making schemes are siphoning much needed money that could be used for real energy solutions for the twenty-first century.

Respectfully,
Fergus Marshall
55 Gaylord St
Chicopee Ma
01013

Document Accession #: 20211227-5005 Filed Date: 12/27/2021
Norma Roche, Northampton, MA.

I am writing to urge you to consider the health of the Connecticut River ecosystem and fishery before all else as you consider the conditions for relicensing of the Northfield Mountain Pumped Storage Station. I’ve been reading Karl Meyer’s columns on the state of the river in the Daily Hampshire Gazette with growing alarm, particulary his latest one (12/22/21) about the licensing process, as well the column of 6/2/21 about the operations of the pumping station leaving hatchling sturgeon high and dry.

I have little technical knowledge of fisheries or river regulations, but I would ask, as Mr. Meyer does, why those responsible for negotiationg the conditions of First Light’s license aren’t bound by the 1972 US Supreme Court mandate that all migratory fish have safe passage up and down all rivers. If the pumping station is sucking up and killing shortnose sturgeon (already endangered), shad (whose populations are plummeting), and other fish and aquatic animals, that’s far too high a price to pay for electricity. It sounds like the shad, in particular, have nourished people not only in our region’s past, but right up to this summer. They’re popular with fishermen, and those who catch them eat them. Such a supplemental food source, in these times of economic and and climate uncertainty, isn’tsomething we can afford to lose.

I understand that the pumping station is used for peak power generation. Given the problems associated with that practice, I’m trying to do my part. I have solar panels on my roof, and I’ve signed up with a Shave the Peak program, which alerts me when high power consumption is anticipated so that I can turn off things in my house. I’d much rather do that than contribute to fish kills. Can’t we “shave the peak” on a larger scale and do without the pumping station? Many federal agencies, as well as state governments in our region, are working hard to develop new sources of electricity. None of these will be free of problems, of course. But given that the relicensing period is 50 years, I have trouble imagining that we will need the pumping station for anything like that long.

I’m also an avid whitewater kayaker and member of American Whitewater, and I’ve sent you comments in the past urging you to incorporate water releases into dam relicensing agreements. I sincerely appreciate those releases, as I do the improvements First Light and its predecessors have made to boating access spots and other recreational facilities. But I hope, and believe, that
my comments have always added, as long as it doesn’t hurt the fish.
Of course fish die in the course of many recreational activities such as fishing!but never at the scale at which we’re losing them to the pumping station. My entertainment is certainly not worth these losses.

I hope you will insist that if the pumping station is to continue its operations, it must no longer kill fish. I’m sure that modifications to keep the fish safe could be costly, but it’s not economical to make them,then the station should not be operating.
Thanks very much,

Document Accession #: 20211227-5004 Filed Date: 12/27/2021
Seth Wilpan, FLORENCE, MA.

I am writing to urge you to NOT re-license the Northfield Mountain Pumped Storage Project. In the words of Karl Meyer, participating stakeholder and intervener in these Federal Energy Regulatory Commission licensing proceedings since 2012, this project is “the grimmest electric appliance ever installed on our river. Just like an electric toilet, Northfield squanders massive amounts of grid electricity to literally pull a river backward and uphill” flushing it and all its fish back out, dead, while reselling the secondhand juice as twice-produced watts to distant markets at peak prices.”

The stated goals of the U.S. Fish and Wildlife Service include the
restoration of safe passage of a number of fish species and to protect the river for future generations, which is in response to and in accordance with the U.S. Supreme Court mandate. The agency has failed utterly to live up to this mission. At the same time, the Canadian company PSP Investments, which is the parent company of FirstLight which current owns and operates the project, has set itself up to evade local taxes. They are making millions destroying our river.

The only impact of refusing to renew the license will be decreased profits for the companies that run it. Can you in good conscience authorize the continued destruction of this vital and irreplaceable facet of the natural world?

Document Accession #: 20211227-5003 Filed Date: 12/27/2021
Robert Sweener, Westhampton, MA.

Regarding the re-licensing of FirstLIght Hydro on the Connecticut River, I unequivocally say NO to this proceeding. Local communities and wildlife will not profit from this project. No amount of mega-profits justify this environmental degradation. We’ve seen enough damage from what they can do.
Thank you,
Bob Sweener
Westhampton Massachusetts

Public rejecting new Connecticut River license bid for Northfield Mtn: 49 years of ecosystem predation and waste is enough.

Posted by on 24 Dec 2021 | Tagged as: Connecticut River, Connecticut River ecosystem, E-Comments, Federal Energy Regulatory Commission, FERC, FirstLight, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, public trust, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, US Fish & Wildlife Service, USFWS

Public rejecting new Connecticut River license bid for Northfield Mtn: 49 years of ecosystem predation and waste is enough.

Even at the holiday break a belatedly-informed citizenry is going on the record, while secret talks between FirstLight and US Fish & Wildlife, NOAA Fisheries, MA Fish & Wildlife and MA DEP loom in a shadowy background. Below are the latest citizen filing with the Federal Energy Regulatory Commission. All state that no license should be issued for Northfield Mountain. It is time the devastation ceased.

These were all accepted into the FERC public record on Christmas Eve, people taking a stand for the river that is the lifeblood and soul of this New England ecosystem. SEE BELOW:

(* * NOTE:if you would like to add your voice into the public record concerning the Connecticut River and relicensing, you’ll find simple instructions at the end of this post.)

Document Accession #: 20211227-5000 Filed Date: 12/27/2021
Stephen Kerr, Greenfield, MA.

To whom it ma concern, I am looking to voice my disapproval of thee FirstLight power plant’s usage of the Connecticut river. I believe the damage it causes the river ecosystem (and by extension, the local ocean ecosystem which uses the river as a breeding ground) is not worth the electrical power it’s converted into.

I hope that my concern is taken seriously, as it is also representative of many people I know. Please contact me if you’re able to put this concern into action, or if you know of any further action I can take to help make a change in this system.

Thanks and happy holidays,
Stephen

Nancy Obertz, Westhampton, MA.

Please refuse to relicense this company as they are using my river for their gain. Millions of species are dying from the intense pull of their turbines and they do not help the environment. They dodge tax responsibilities (sheltering in Delaware) and hand out pittance amounts to locals in the guise of “good community partners”. STOP this now. We are not going to sacrifice our beautiful Connecticut river for many more decades of their unchecked degradation.

I have grown up on this river (Ox-Bow in Easthampton) and am sickened by what First Light is doing. I have watched the shad and herring disappear. Yet, this company touts all the good they do for the local fish. This is your chance to have a very long-lasting impact. PLEASE refuse to re-license First Light! History will tell our children of your impact here. Please make that impact a positive one.

Thank you!
Nancy Obertz
Westhampton Mass.

Document Accession #: 20211227-5002 Filed Date: 12/27/2021
Dorothy McIver, Greenfield, MA, MA.

I am writing to voice my opposition to the re-licensing of the Northfield Mountain Pumped Storage Facility. It is not needed to generate electricity with all the new advances in technology and it has had a devastating effect on the fish and other aquatic life who are killed when it is in operation. The river needs to be allowed to heal, and continuing this harmful operation for another 50 years is an affront to all of us who want this shut down, and
a benefit only to those who profit from their own greed and lack of concern for this delicate ecosystem and are in denial of the harm they have done for the past 50 years. Please do the right thing and set our river free to flow where it it will with a revitalization of the life it is meant to sustain.
Dorothy McIver

* * HERE’S HOW TO MAKE YOU VOICE HEARD: 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 use Northfield’s FERC project number, P-2485, to enter your comments.

Turners Falls Stand-out Returns Against River Extinction

Posted by on 08 Oct 2021 | Tagged as: Connecticut River, Federal Energy Regulatory Commission, FirstLight, FirstLight Power, fish kill, MA Division of Fish and Wildlife, Massachusetts DEP, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Station, P-2485, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls, US Fish & Wildlife Service, USFWS

Turners Falls Stand-out Against River Extinction, Saturday, Oct.9, 11- noon Copyright © 2021 by Karl Meyer

Photo Copyright © 2021 by Karl Meyer

As secret relicensing talks between Canadian-owned, Delaware-registered FirstLight and federal and state environmental agencies are taking place, citizens are again returning to the Turners Falls Bridge above the Connecticut to demand an end to the ecosystem slaughter occurring daily at the Northfield Mountain Pumped Storage Project.
Photo Copyright © 2021 by Karl Meyer

On September 18 over 50 people took to the bridge demanding a halt to the annual FirstLight slaughter of 100s of millions of fish and aquatic animals.
Photo Copyright © 2021 by Karl Meyer

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future

Posted by on 21 Jul 2021 | Tagged as: 5-year FERC licensing process, Brian Harrington, Catherine Carlson, climate change, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Conte National Fish & Wildlife Refuge, CRASC, Daniel McKiernan, David Cameron, Donna Wieting, E-Comments, Environmental Protection Agency, EPA, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Comments, FERC Commissioner Richard Glick, FERC Secretary Kimberly D. Bose, FirstLight, FirstLight Power, Gordon van Welie, Holyoke Co. v Lyman, ISO-NEW ENGLAND, Jesse Leddick, Julie Crocker, Kathleen Theoharides, Kimberly D. Bose, Landmark Supreme Court Decision 1872, Local Bias, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, Northfield Mountain Pumped Storage Project, P-1889, P-2485, Peter Brandien, Public Comment period, Public Sector Pension Investments, Rock Dam, Sam Lovejoy, Sean McDermott, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Steven Mattocks, Timothy L. Timmermann, Turners Falls, US Fish & Wildlife Service, Vermont, Wendi Weber

Connecticut River blog: source of a salmon sham; how the public can steer a river’s future Copyright © 2021 by Karl Meyer

Kathleen Theoharides, Massachuetts’ Secretary of the Executive Office of Energy & Environmental Affairs before launching on a PR kayak tour of the river at FirstLight’s dock next to the intake of the Northfield Mountain Pumped Storage Project, October 2020. Photo Copyright © 2020 by Karl Meyer

NOTE: as a journalist and citizen I’ve been a participating stakeholder for nearly a decade in the ongoing Federal Energy Regulatory Commission relicensing process for the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot hydro operations. In that light, I encourage people to first view the half-hour segment of Local Bias, linked below. Then, return to this post and its resource list below for ways to participate in the critical decisions now being made about the Connecticut River. They will impact its currently crippled ecosystem for generations to come.

LOCAL BIAS link: https://youtu.be/IX2Rv2NYq3s

Since 1872 the US Supreme Court has made it the law of the land that migratory fish on US Rivers are guaranteed safe upstream and downstream passage at dams and industrial river sites. That decision was centered on a Massachusetts case at the Holyoke Dam. One hundred forty-nine years later that law remains essentially unfulfilled at an endangered species’ critical spawning and nursery site on the Connecticut River at Montague, MA, as well as at the Turners Falls Dam in that town.

Further, that law remains glaringly unenforced and unimplemented at the Northfield Mountain Pumped Storage Project in Northfield MA, where the river is literally sucked into reverse, and millions of eggs and downstream running juvenile American shad are pulled to their “functional extirpation”(vacuumed to their deaths) yearly, on their way to the ocean from Vermont and New Hampshire spawning reaches. The Commonwealth of Massachusetts has now owed Vermont and New Hampshire—and really all of New England, a living river for almost exactly a century and a half.

Warning sign announcing the dangers of Northfield’s massive intake suction. Photo Copyright © 2021 by Karl Meyer

The current Canadian parent-owners of that net-loss power regeneration/resale site are proposing only an ineffective, seasonal “barrier net” at the vacuum mouth of this facility, the very ‘solution’ that leaves this monstrous sucking in place to kill all those Vermont and New Hampshire produced eggs and baby shad, crippling the prospects for returning adult shad to those states from the Atlantic four years in the future.

The donuts and coffee were on FirstLight for the state officials and representatives taking part in last October’s little PR kayak tour. Photo Copyright © 2020 by Karl Meyer

Northfield Mountain’s net-power-loss energy consumption literally swallows and squanders the entire annual energy equivalents of whole cities and counties as it ravages the Connecticut River, using it as a crushing and deadly energy relay switch.

FirstLight is applying to FERC—backed up by a power-hungry, ecosystem-and-climate-indifferent ISO-New England, for a license to kill for decades to come. Northfield Mountain wastes monstrous amounts of grid energy, while ravaging New England’s critical main ocean connection and planetary cooling artery…

Below are resources available to the public for interacting and participating with the Federal Energy Regulatory Commission in licensing decisions, and government agency officials charged with implementing the public trust on the Connecticut River.

www.karlmeyerwriting.com/blog

NOTE: the landmark US Supreme Court environmental decision centered on the Connecticut River came back in 1872 in Holyoke Company v. Lyman, requiring safe up- and down-stream protection for migratory fish.

Send public comments on relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls/Cabot Hydro Stations to the Federal Energy Regulatory Commission. The “project numbers” must be included, as well as your name and address, in order to become part of the public record. They should be concise, citing specifics in a paragraph or two, noting Northfield Mountain P-2485 and Turners Falls/Cabot P-1889.

Send via www.ferc.gov, usingE-comment, with the salutation going to: “Kimberly D. Bowles, Secretary.” Those comments can also include a cc to the current chair of the Federal Energy Regulatory Commission: Richard Glick.

Decisions concerning foreign interests and use of the Connecticut River are happening at this time, and the river in Massachusetts has sat largely emptied or dead here for half a century—a situation enabled by the Commonwealth and its officials’ enduring, ugly and pointed environmental neglect.

To gain effect, letters can be cc’d to federal-and-state officials who are the vested stakeholders representing the public in the protection of the river and resources. Those publicly recorded FERC entries can also be forwarded to local newspapers and media outlets.

LIST of executives–plus officials from federal and state agencies who represent the public in protecting the Connecticut, its migratory fish, aquatic animals and habitats through their “conditioning authority” powers:

ENERGY executives in the private/quasi-public sphere:

Mr. Gordon van Welie, President and CEO, ISO-New England, the “independent” system operator:
Phone (413) 540-4220

Mr. Peter Brandien, Vice President of System Operations, ISO-New England:

E-mail: pbrandien@iso-ne.com .

NOTE: Mr. Brandien writes the annual support letter that facilitates the daily commercial damage to the Connecticut wrought by the Northfield Mountain Pumped Storage Project. ISO has never acknowledged to the public that NMPS is NOT essential to the DAILY functioning of the power grid. Instead it encourages and shackles the public to those peak-priced, daily ravages as NMPS is handsomely paid to hold back several hours of reserve emergency-function megawatts for ISO’s 20th Century bulk power grid in case of a rare blackout (like the one in 2003), and also for occasional use–at scattered intervals, in controlling grid fluctuations.

ISO should have ago been curtailed as a functionary for private mega power interests. Today’s grid should already be based on distributed generation and micro-grid functions in this time of climate chaos and cyber crime. Energy and storage should be located nearest to where it is produced and used. Future linking of river-ravaging NMPS to 200-mile-distant wind turbines is wholly criminal when compressed air storage can be located close to metro/industrial coastal centers—including implementation at sites like Everett, Somerset, New Bedford, and elsewhere. That would render the system resilient, local and detachable–and rescue New England’s Connecticut River ecosystem to support generations to come across the next half century.

But, today and into the future, counter to Holyoke Co. v. Lyman, , ISO will happily sell off a US ecosystem’s daily life to foreign venture capital interests, keeping NMPS in lucrative daily play for decades into the future. The bottom line function of ISO-New England—forget ecosystems and climate, is apparently commercial first, and foremost. In their own words: to “protect the health of the region’s economy and the well-being of its people by ensuring the constant availability of competitively-priced wholesale electricity—today and for future generations.” They love to employ the term “clean”, but never elaborate on glaring incongruities, fallacies or impacts. Future generations apparently will have no need of living ecosystems, just an endless stream of “competitively-priced” energy. They NEVER mention energy CONSERVATION…

FEDERAL PUBLIC officials:

For endangered Connecticut River shortnose sturgeon, freshwater mussels, as well as American shad, blueback herring and American eel:
Donna Wieting, Director of Protected Resources, National Marine Fisheries Service, NOAA Fisheries:
Phone: 301-427-8400

Also, for endangered shortnose sturgeon, as well as American shad, blueback herring and American eels: Mr. Sean Mcdermott, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Sean.mcdermott@noaa.gov

Also at NMFS, protecting shortnose sturgeon and their habitat: Ms. Julie Crocker, Greater Atlantic Region Fisheries Office, National Marine Fisheries Service, Gloucester, MA 01930:

E-mail: Julie.crocker@noaa.gov

For federal protection and enforcement of the Clean Water Act on the Connecticut River: Mr. Timothy L. Timmermann Office of Environmental Review, EPA New England Region 1, Boston MA 02109-3912:

E-mail: timmermann.timothy@epa.gov

For all migratory fish and safe passage on the Connecticut including American shad, herring, and endangered sturgeon: Wendi Weber, US Fish & Wildlife Service Region 5, Hadley MA 01035:

E-mail: wendi_weber@usfws.gov

MASSACHUSETTS state officials:

Kathleen Theoharides, Secretary of the MA Executive Office of Energy & Environmental Affairs 100 Cambridge St., Suite 900, Boston, MA 02114:
Main Phone at (617) 626-1000

For Massachusetts clean water and wetland habitat protections on the Connecticut: Mr. Brian Harrington, Bureau of Water Resources Deputy Regional Director, Massachusetts Department of Environmental Protection, 436 Dwight Street, Springfield MA 01103:

E-mail: Brian.d.harrington@state.ma.us

Also from MA DEP: Mr. David Cameron, PWS Section Chief, Massachusetts Department of Environmental Protection, 436 Dwight St., Springfield, MA 01103:

E-mail: David.cameron@state.ma.us

For state-endangered shortnose sturgeon and all Connecticut River migratory fish in MA: Mr. Jesse Leddick, Chief of Regulatory Review, Massachusetts Division of Fisheries and Wildlife, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: Jesse.Leddick@mass.gov

Also at MA Div. of Fish & Wildlife: Mr. Steven Mattocks, Massachusetts Division of Fisheries and Wildlife, Fisheries, 1 Rabbit Hill Rd., Westborough MA 01581:

E-mail: steven.mattocks.@mass.gov

CONNECTICUT RIVER BLOG: DISMAL SPAWNING SEASON ON THIS UNPROTECTED RIVER IN MASSACHUSETTS

Posted by on 05 Jul 2021 | Tagged as: blueback herring, Connecticut River Atlantic Salmon Commission, Connecticut River Conservancy, Connecticut River migratory fisheries restoration, CRASC, Federal Conte Anadromous Fish Research Center, FirstLight Power, John McPhee, Landmark Supreme Court Decision 1872, National Marine Fisheries Service, NMFS, Rock Dam, shortnose sturgeon, The Dead Reach, Turners Falls power canal, Uncategorized, US Geological Survey's Conte Fish Lab, USFWS, Vermont

Connecticut River Blog: dismal spawning season on this unprotected river in Massachusetts Copyright © 2021 by Karl Meyer

*American shad run lowest since 2010
* 2021 shortnose sturgeon passage will likely be the worst at Holyoke in the half decade since it’s lifts were modified to restore the population and allow spawning in critical upstream nursery habitat.

The spillway fish lift and attraction water at Holyoke Dam, June 2, 2021. Photo Copyright © 2021 by Karl Meyer

The migratory fish run on the Connecticut River is done for the season. No one should be celebrating. At Holyoke Dam fish passage was the lowest it’s been in over a decade, with just 238,000 American shad counted passing that site. Seesawing spring flows that at first saw little April rain to fill river channels then quickly ramped up as May was ushered, creating big attraction flow for shad seeking upstream access via the Holyoke lifts.

But for 10 days, beginning April 30th, no lifts ran at Holyoke. HG&E won’t run lifts with flows above 40,000 cubic feet per second, so those shad had to hold there in the currents of a quickly cooling-down river for over a week. Then, as the flows ebbed to lift-able levels they were again left stranded and burning energy for extra days—as turbidity protocols from the National Marine Fisheries Service (NMFS) won’t allow awaiting fish runs to be helped upstream because they might miss tallying a single endangered shortnose sturgeon in the murky waters. Does this make sense–even for the sturgeon, or any of this ecosystem’s migrants?

In a time of climate heating chaos, this will only happen more often. Here’s a quick sketch of that migration dead-stop from USFWS Project Leader Ken Sprankle, who works to get regular fish passage updates out to the public: “Sierra at HFL(Holyoke Fish Lift) reported operations since the 4/30 closure did not resume until 5/10, with last weekend through 5/10 impacted by very turbid conditions that did not allow lift operations (sturgeon management factor).”

The parched riverbed in front of Holyoke Dam on June 2, 2021. The usual spring peak for shad runs occurs in late May. For 10 days in early May no lifts operated… Photo Copyright © 2021 by Karl Meyer

At first this might seem understandable—this abundance of caution while holding up thousands of other fish, except that the NMFS is doing literally NOTHING to protect and document shortnose sturgeon spawning success upstream at their critical Rock Dam site, and at a default industrial spawning site below Cabot Station’s ramping outflows. The whole purpose of fish lifts is to come into compliance with the Holyoke Company v. Lyman, landmark 1872 US Supreme Court decision, guaranteeing safe upstream and downstream passage at all dams.

So why hold up ANY fish—including shortnose sturgeon, in merely turbid early season conditions, when the purpose is to make sure all migrants can access upstream spawning habitat? To me, it’s disingenuous to implement a policy that seems more about data collection and missing a sturgeon or three—delaying and holding back runs of SNS and all other fish, when you are not doing a thing to ensure that those few endangered sturgeon have habitat and flow to successfully spawn. Are there any priorities that really put fish and protection first here?

As was noted at a June 24th meeting of the Connecticut River Atlantic Salmon Commission, US Geological Survey sturgeon biologist Micah Kieffer did virtually no work at the Rock Dam, the only documented natural spawning site for shortnose sturgeon in this river system that he helped confirm while working for decades with Dr. Boyd Kynard. Not a single bit of investigation or a gill or egg nets set to see about spawning success—just 250 yards from the Conte Lab where Kieffer works. It appears looking after sturgeon is important everywhere BUT the place where they need protection in order to successfully reproduce.

Micah Kieffer spent a good chunk of this season looking for ghost shortnose sturgeon and chasing fish stories far upstream from their critical habitat all the way to Bellows Falls–which proved as fruitful as finding the Loch Ness Monster. Last year, the emphasis was again chasing ghosting fish upriver that were never found. It has now been three seasons since I begged and badgered Micah to take a receiver down to Rock Dam, just a literal stone’s throw away from Conte Lab. After he took me up on that single visit he ultimately ended up documenting 48 SNS present at their ancient site–the largest spawning aggregation ever recorded there across decades of investigation. The fish were there several more days–that is until Canada-owned FirstLight Power cut off the flows—interfering with the spawning of a US federally endangered species.

De-watered critical sturgeon spawning and nursery habitat at Rock Dam, May 16, 2021. Photo Copyright © 2021 by Karl Meyer

There were likely no suitable conditions allowing SNS spawning and rearing at their Rock Dam nursery again this year. I documented that in my photos of their sheltering cobbles baking in the sizzling June sun. So, so much for anyone protecting endangered fish or habitat. When there is no watchdog, there is no enforcement.

One big reveal at the June CRASC Technical Committee meeting was much-touted news that shortnose sturgeon eggs were recovered below Holyoke Dam. Here’s that event, put down in USFWS’s Fish Passage Report from Ken Sprankle on June 30th: “Some important fisheries news was shared at the CRASC Tech when CTDEEP confirmed they had sampled Shortnose Sturgeon eggs in habitat immediately downstream of the Holyoke Dam. Eighty eggs were collected in a sampling bout using egg mats with genetic confirmation, the first documentation of spawning outside of the Rock Dam and Cabot Station shoal, Turners Falls.” But this was really nothing new. Some minor spawning activity has long been known to occur below that industrial site where sturgeon were blocked from accessing their upstream habitat for well over a century.

Chapter 2 in Life History and Behavior of Connecticut River Shortnose and Other Sturgeons, 2012, published by the World Sturgeon Conservation Society (a chapter authored by B. Kynard, M. Kieffer, B.E. Kynard, M. Burlingame, and P. Vinogradov) states that spawning activity has been documented, understood and accepted since the late 1990’s in the area below Holyoke Dam. This is the place where sturgeon had forever been trapped in a spawning cull de sac—more or less since the first dam there was completed in 1849. So, though it is some new data, it does nothing to protect the SNS’s critical upstream spawning site–or the broken river ecosystem at Turners Falls and well beyond.

More CRASC hubbub was created when it was noted that professional divers looking for yellow lamp mussels stumbled on several dozen young-of-the-year shortnose sturgeon and took videos of them at a major in-river construction site in Springfield. Ironic that those divers were not sturgeon researchers… The big excitement was the cute video of baby fish. But it seems the ‘discovery’ was more a celebration of a random technological happenstance than progress in safeguarding this season’s sturgeon spawning run and success.

Anglers in a motorized raft in fragile Rock Dam habitat May 25, 2021 Photo Copyright © 2021 by Karl Meyer

Here’s just one other twisted shortnose sturgeon kicker: those motivated, early-spring spawning-run shortnose sturgeon that get rejected at Holyoke’s lifts in that April-to-late May spawning window because of high flow or the dreaded “turbidity”, are denied a season’s spawning opportunity at their critical upstream Rock Dam site. But this July a new circumstance has been implemented that could help deny more up-running SNS a shot at successful spawning NEXT year!

For Connecticut River shortnose sturgeon there’s actually a bigger, seasonal early-SUMMER migration peak. It’s an upstream push for shortnose sturgeon attempting to find their way past Holyoke Dam. It occurs at the beginning of July and peaks soon thereafter. This is thought to be a “staging” migration for spawning-age fish–for sturgeon moving upriver to prepare to spawn the following year.

However, this year HG&E decided that maintenance on the fish lifts was overdue, and the federal agencies gave the okay for Holyoke Gas & Electric to shut down its lifts beginning July 1st–keeping them off-line for up to three months. Most sturgeon get lifted at Holyoke in July. Delaying those lift closures by just two weeks could have allowed a significant chunk of that critical SNS run to pass upstream. So much for ESA protections…

The average upstream count at Holyoke these last 5 years has been 58 shortnose sturgeon lifted. This year’s count stands at a paltry 11 fish. Thus, it’s pretty much guaranteed it will be a dismal year for passage upstream to critical habitats—Holyoke Company v. Lyman and all those endangered fish be damned!

There was one … tiny ray of hope noted at the June CRASC meeting. After two years of my reporting and intervening on behalf of the buckling banks, sink holes and grim discharge from the failing Connecticut River banks at Rock Dam, Ken Sprankle has been the sole fisheries person to take note. He actually proposed action. The Connecticut River Conservancy, with their water lab, refused to do testing there, and there was no action whatsoever from the Connecticut River Streambank Erosion Committee. On a river with a watchdog pressure would have been applied to force the National Marine Fisheries or MA DEP to take action on the failing riverbanks—which are the responsibility of FirstLight. Or, more to the point, a watchdog could have gone straight after the corporation. But no one to stepped up in that role. Because there is no watchdog here.

Rock Dam raft runners on May 29, 2019.

However, the USFWS’s Ken Spankle did get a study proposal put together that could potentially document the common-sense linkage of those crumbling banks to the Turners Falls power canal–just 150 feet away, as possible culprit and source of the bank failures and habitat pollution. Isn’t this ultimately a potential TF canal failure—the DIVERTED Connecticut River trying to return to its own riverbed less than 200 feet distant? This–on a protected river, would seem a slam dunk to document during a critical time when a new license for decades to come is in the offing. I raised these issues again in questions to the CRASC in their on-line meeting.

Rafters invade fragile Rawson Island at the Rock Dam site to lug their boat upstream for another tilt at Rock Dam’s tiny rapid, May 29, 2019.

Ken Sprankle needs just $131,000 to get the study done–at a time when a $100-million-plus foreign corporation is seeking to run our river here for decades. But he’s found he can’t find the money amongst and between all these federal and state agencies that would enable it to go forward.

You’d think all of CRASC member agencies would be falling all over themselves to chip in and get this critical information—especially since it was their forebears who ruined an easily restorable fish passage prospect at Turners Falls Dam in the mid-1970s. They did this by turning their backs on constructing a simple fish ladder there. That ruined prospects for a true Connecticut River migratory fisheries restoration for hundreds of thousands of American shad and blueback herring to VT, NH, and northern MA each spring for a full half century.

BTW, in the name of further explanation of the above: the predecessor and immediate precursor of CRASC, is the fed/state fisheries cooperative that—in 1969, turned what should have been an CT River fisheries restoration project into a 43 year odyssey that put the river’s long extinct salmon strain (since 1809) at the top of Connecticut River species restoration pyramid, stumbling right past the needs of American shad and blueback herring. These same two federal agencies and four states signed off on the wretched, river-emptied, three-ladder fish passage based on salmon at this Dead Reach in Turners Falls. That has left this river system broken from mile 122 all the way upstream into southern Vermont and New Hampshire.

Their decision at Turner Falls for fish passage essentially killed a true river restoration when that ladder system was completed in 1980. VT, NH and northern MA never saw a fraction of their promised runs of American shad and herring. CRASC’s current chairperson, Andy Fisk of the Connecticut River Conservancy recently described shad as “lazy” in an interview with the Springfield Republican. I think those shad–as well as John McPhee, would agree American shad deserve a better spokesperson.

Failing Connecticut River banks at Rock Dam, June 15, 2021. Photo Copyright © 2021 by Karl Meyer

I do credit Ken Sprankle, who is extremely busy, for making that pitch and getting a study plan put together. This is a Massachusetts problem—home of the broken Connecticut River, and all those present here should find it shameful. The study would take two seasons. But time is tight for it to have any merit in terms of licensing, and this is a river bureaucracy bathed in INACTION.

In a time when the Dead Reach of the Connecticut has been left half-dead and de-watered at the fragile and failing Rock Dam reach for over half a century, you might think the first priority there would be protection and letting this critical patient have a chance to finally begin to heal. Thus it seems rather ironic and no less a bit dangerous that the Connecticut River Conservancy, Appalachian Mountain Club, American Whitewater and other groups will be doing a big PR push in mid-July to bring more joyriding traffic through the fragile Rock Dam site–which has any number of legitimate critical preservation needs and designations.

A campsite and someone living on the south end of Rawson Island opposite the Rock Dam pool on July 4, 2021. Does this critical habitat merit protection, or merely a flood of new visitors… Photo Copyright © 2020 by Karl Meyer

What seems sure to absolutely create more damage and dishonor at this place are crowds jamming downstream to run the single tiny Rock Dam rapid. Many of us have witnessed the ugly traffic jams and trash sites on the Deerfield River. What will happen when crowds descend on this critical area? Does CRC have a plan to protect this habitat? Will they pay for police and search and rescue operations? Will the AMC? Or does the Town of Montague get stuck with the problem and the bill in this tiny backwater so critical to a restored ecosystem?

Perhaps the full CRASC will have something to say about this at their upcoming meeting? Oh but Andy Fisk of CRC is the CRASC’s chair, so perhaps it’s just fine. I’m sure there’s a plan. Be careful what you wish for! What I’m not certain of is whether the folks living in the little “Patch” section of Turners will be thanking CRC. Certainly the sturgeon won’t…

My Response to FERC respecting FirstLight’s response to the Federal Energy Regulatory Commission’s questions and this relicensing process

Posted by on 23 Jun 2021 | Tagged as: Connecticut River, Federal Energy Regulatory Commission, FERC licensing process, FirstLight, Fish and Aquatics Study Team, Kimberly D. Bose, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Project, PSP Investments, Rock Dam, US Fish & Wildlife Service, Vermont Fish & Game


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer

NOTE: The four photos above were taken of the Connecticut River’s oozing banks and dewatered cobble shoals at the Rock Dam, the sole documented natural spawning site and nursery of the federally-endangered Connecticut River shortnose sturgeon on June 23, 2021.

The following was submitted to the Federal Energy Regulatory Commission on June 23, 2021.

Karl Meyer
91 Smith St., # 203
Greenfield MA 01301
413-773-0006
Karlmeyer1809@verizon.net June 23, 2021

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
Hydro Licensing

RE: This day’s submission by FirstLight’s Operations Manager Nick Hollister respecting FirstLight MA Hydro LLC, Turners Falls Hydroelectric Project (FERC No. 1889)Northfield Mountain LLC, Northfield Mountain Pumped Storage Project (FERC No. 2485). Response #3 to FERC January 14, 2021 Letter Regarding Additional Information Requests

Dear Ms. Bose,

I write to you requesting a rejection of significant and substantial portions of the Additional Information Request filing made this day to FERC by FirstLight MA Hydro LLC and Northfield Mountain LLC. I have been a participating stakeholder, intervener and member of the Fish and Aquatic Studies Team for these projects, FERC P-1889 and P-2485, since 2012.

On January 14, 2021, FERC required updated information and an answer to the following inquiry:

“To enable staff’s evaluation of effects of the proposed project on fish entrainment at the Northfield Mountain Project, please provide estimated weekly and/or monthly pumping flow volumes for both current and proposed operations in a typical year.”

Simply stated, FirstLight has failed to address or provide any new or useful information in response to the requested NFM-AIR#4. What they have provided is decades-old data from the last century that does not reflect in any meaningful way how NMPS operates today, or how it might operate in any future scenarios.

Page 10 of their written response to FERC’s requirement sums up the uselessness of their outdated submission in bold parameters:

“Table NFM AIR#4-1 provides the average monthly volumetric flow rate of water pumped by Northfield Mountain over the 42-year period of record analyzed (i.e. 1962 – 2003).”

Put simply, Northfield Mountain did not exist in 1962, and did not come on-line until 1972. Therefore, a full 10 years of their purported data is null and void. Parent owner PSP Investments is new to this country and to Massachusetts, however that bit of historic information could have been culled in Wikipedia.

Further, their particular data-set ends in 2003, just three years into the timeframe when NMPS began operating under new and loosened pumping and generating parameters after Massachusetts deregulated their energy markets. It too is information representative of the past century.

Wholly absent is information on the first two decades of the 21st century, the one in which PSP purchased these facilities intending to profit from them for generations to come. What is absolutely needed, in order to make any projections on the scope and impact of pumping and generating operations far into the future, are the figures, charts and data from the year 2000 to the present, 2021.

And, as well, FERC surely understands that there have been policy changes at the Federal Energy Regulatory Commission in the current half-decade that now allow NMPS to operate more frequently and benefit from participation as a merchant supplier in the wholesale energy market. In order to begin to understand and project how these changes have impacted NMPS current operations and how they will impact future river conditions, a full comparison of recent operational changes due to these new FERC loosened parameters with the 5 preceding years should be the minimum of data and information required of FL by FERC.

In a relicensing now entering its 9th year, I find FL’s response to the FERC process to be yet another delay tactic at best, and wholly dismissive of all the state and federal agencies and stakeholders long engaged in this process at worst. It simply does not hold water. Please require an immediate and with-all-haste rewrite and resubmission of answers to these critical questions. Any new license offered should be shortened in relation to the accruing years beyond the expiration of their original license, April 30, 2018.

Sincerely,
Karl Meyer, MS Environmental Science

Cc: Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Kenneth Sprankle, U.S. Fish and Wildlife Service
Michael Pentony, NOAA Fisheries Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA
Daniel McKiernan: Director MA Division of Marine Fisheries
Louis Porter, Commissioner VT Dept. of Fish & Wildlife
Scott R. Decker, Inland Fisheries Division, NH Fish & Game Dept

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