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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

Connecticut River: not clean; not healthy–it’s this river refuge’s hall of shame in MA

Posted by on 17 Jun 2021 | Tagged as: Andrew Fisk, climate change, climate-heating, Connecticut River, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, CRC, Dead Reach, Delaware LLC, Dr. Boyd Kynard, ecosystem, ESA, Federal Conte Anadromous Fish Research Center, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, FERC, FERC license, FirstLight Power, fish passage, ISO, ISO-NEW ENGLAND, LLC, Micah Kieffer, National Marine Fisheries Service, NMFS, Northfield Mountain Pumped Storage Project, Public Sector Pension Investments, pumped storage, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls dam, Turners Falls power canal, Uncategorized, USFWS, Vermont, water lab

Copyright © 2021 by Karl Meyer


June 15, 2021, the baking, dewatered Rock Dam cobbles at the shortnose sturgeon nursery, where early life stage sturgeon should find watery shelter. This is DEAD, critical habitat. Photo Copyright © 2021 by Karl Meyer

For a fourth season beyond the date (4/30/2018)Canada’s Public Sector Pension Investments FERC (Federal Energy Regulatory Commission) license expired to operate their FirstLight Power, river-ravaging Northfield Mountain Pumped Storage project and river-starving Turners Falls/Cabot Station power canal diversions out of the main stem river, conditions for fish and a living river ecosystem have again proven grimly dismal. Conditions last weekend in the 20 mile reach backed up for NMPS’s river-gorging behind TF dam got so ugly there was not even water to launch a boat just a half mile above the dam at the state boat launch. See Ch. 22 link below.

https://www.wwlp.com/news/local-news/franklin-county/low-water-levels-for-parts-of-connecticut-river-in-franklin-county/

Without a watchdog and a lawyer with an injunction at the ready, that’s just what you come to expect here. Insanity is witnessing the same lack of enforcement and leadership languishing, year-in, year-out, and expecting different results.


Migration season spill to the actual riverbed amounts to little more than a pan of dishwater–for fish seeking an upstream route to Vermont and New Hampshire. Photo Copyright © 2021 by Karl Meyer

The most interesting statements on the situation did not come from any of the agencies or the ngo laying claim to safeguarding this massively abused reach, but from PSP’s FirstLight Power–now re-registered out of the Bay State as a Delaware llc. Here, in their press statement they actually felt quite comfortable pointing to ISO-New England in Holyoke–the “electric grid operator,” as the responsible party for choking the life out of the Connecticut in Franklin County–right in the midst of key spring spawning when development of early life stages are critical to restoring beleaguered runs of migratory fish. READ FL statement BELOW:

“Over the weekend water levels in the area of Barton Cove were exceptionally shallow due to several overlapping conditions affecting water levels in the Turners Falls Impoundment.These factors included dispatch of our facility by the electric grid operator at the same time we were spilling water over the Turners Falls dam to meet federally required flows to support fish passage. These conditions are all within the approved and licensed operation of the facilities, however, coupled with lower than usual flows in the river, the water levels dropped to an unusually low level in this instance.”

ISO-New England and PSP/FirstLight are like corporate kissing cousins–in a grim Bermuda Triangle where the river disappears. That triangle goes from Northfield/Turners Falls through Holyoke, thence down to Delaware for tax-dollar cleaning; and then way back north to Canada for profit-taking. OOOPPS, I guess that makes it a Bermuda RECTANGLE!

Anyway, hard to reconcile those grim, pillaging river conditions with any massive requirement for huge amounts of power… It was simply a gorgeous June weekend–no giant peak power use or anything in the way of summer heatwave stuff going on. Could it be that our ecosystem was being massively thrown under the bus purely for profit taking? Or, was ISO-NE exporting our river–ravaged for its megawatts, far outside our region? Did the Connecticut get pillaged for use in the New York power grid? It’s just a scam, wrapped in a riddle, with no media scrutiny permitted.

Here, though, I must extend a prize for BS to FirstLight’s PR people who blame, in part, the fact that they “were spilling water over the Turners Falls dam to meet federally required flows to support fish passage.” Their sole and absurdly “required” offering of spill into the riverbed for migrating fish is 400 cubic feet per second in fish passage season. That’s the equivalent of a dishpan’s worth of water, when a swimming pool’s worth is the minimum required to restore a living ecosystem below the Turners Falls dam. These communications people are high paid, and they are so good when you have an uninformed public.

MEANWHILE, I visited that DEAD REACH below TF Dam on Monday. The Rock Dam, the only documented natural spawning site of the only federally-endangered migratory fish on the Connecticut in Massachusetts. For endangered shortnose sturgeon in Franklin County, just yards away from the Conte Fish Lab, and just across the river from the home of the Connecticut River Conservancy, it was just another de-watered, failing riverbanks day. Baking cobbles, blood-orange sludge drooling down failing banks and entering the Connecticut as slurry. Months back Andy Fisk of CRC–with its own in-house water lab, definitively told the media he would not sample that grim soup. I guess if you sample and find a problem, people would expect action.


June 15, 2021: here are the blood-orange, buckling Connecticut River banks sloughing directly into the Rock Dam pool. Photo Copyright © 2021 by Karl Meyer


The sludge outlet into Rock Dam. The sturgeon bakery-beach cobbles are in the background, right–that little tongue of dead water is the CT River’s “flow”. Photo Copyright © 2021 by Karl Meyer

The Rock Dam pool, as some of this river’s most critically endangered habitat, was exhaustively investigated by Conte Lab’s Dr. Boyd Kynard and his assistant Micah Kieffer, for 17 straight seasons. Yet today, in the midst of critical relicensing times, Conte Lab does not even set out a basic water-level data loggers–which would at the very least, offer annual data during the critical spawning months of April through June on flows, depth and temperature. That would at least tell you on what particular date and time. and at what water temperature the dam and headgate operators upstream inside FirstLight’s Northfield Mountain shut off the spigot at Turners Falls dam, sending their grim pumped storage surges sideways into their canal and screwing another sturgeon spawning season at this ancient nursery site for endangered fish trying to hold their place in the ecosystem.

I personally paid for and installed a data logger at Rock Dam a half decade back–though I could not have got it done without the quiet and prodigious help and expertise of a leading sturgeon biologist and investigator. The results were incontrovertible and damning. They got forwarded to the National Marine Fisheries Service, the lead agency on sturgeon protection, and USFWS. No action was ever taken.

I also intervened with FERC vs. FirstLight for dewatering Rock Dam three spawning seasons back–citing violation of the ESA in the face of the KNOWN presence of spawning sturgeon there. My argument, which did result in a FERC hearing in Washington DC, was made on the basis that FirstLight violated their license requirement to coordinate operations of their Northfield and TF facilities, which also includes adherence to the tenets of “takings” under the Endangered Species Act. FERC tossed out the my arguments on inscrutable grounds, but I at least stood up.

If I had a federal lab this season–or for ten seasons past, I would have protected that shortnose nursery just 300 yards away and right under my nose at my federal lab. That’s “Science for a Changing World.” And if I had a water testing lab at my facility, the first thing I would have done is take that water sample–just to be sure. This year, or last year–because that’s what real river protection means.

Clean water;healthy habitats in Franklin County Massachusetts? I think not. Massachusetts is where the Connecticut River ecosystem dies; and the profits fly out of the region. Special thanks to PSP Investments, your neighbor since 2016, and ISO-New England, your bulk power corporate facilitator.

OHHHHH, OOOOHHH! And please don’t forget, every time Len Greene from FirstLight, or Alicia Barton leaves you walking away from some press release somehow thinking that Northfield Mountain is producing ‘clean’, ‘carbon free’ energy?–do note that Northfield is a huge energy CONSUMER that has never produced a single watt of virgin power. In reality it is running off the massive slugs of carbon gorging/planet warming natural gas that today powers the ISO-New England Power grid. In recent days, without any heat wave in sight, their energy “mix” that is massively pulled on for NMPS’s river killing has exceeded 60% natural gas at times. There is everything deadly, and little benign, about what Northfield has done to the Connecticut these last 49 years–or what it will do in the future.

Finally, the thing to note and remember about the Connecticut River across all these decades:

WHERE THERE IS NO WATCHDOG, THERE IS NO ENFORCEMENT.

There is no watchdog protecting this river.

THE GREAT FAILURE TO PROTECT

Posted by on 22 May 2021 | Tagged as: Cabot Woods, Clean Water Act, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, Endangered Species Act, Environmental Protection Agency, EPA, ESA, Federal Energy Regulatory Commission, Federal Energy Regulatory Commission Chairman, FERC Commissioner Richard Glick, FirstLight, FirstLight Power, Julie Crocker, Kathleen Theoharides, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Martin Suuberg: Commissioner MA Department of Environmental Protection, Monte Belmonte, National Marine Fisheries Service, National Marine Fisheries Service, Nipmuck, NMFS, Norwottuck, P-1889, P-2485, Pocumtuck, Rock Dam, Rock Dam Pool, Section 9–Prohibition of Take Section 9(a)(1), Shortnose Stout, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey, Wendi Weber, wrsi.com

THE GREAT FAILURE TO PROTECT: Flaunting the Endangered Species Act and Other federal and state laws governing clean water and habitat on the Connecticut River at Rock Dam in Massachusetts


Photo credit: US Geological Service

FirstLight’s Turners Falls and Cabot Station under the Federal Energy Regulatory Commission License #: FERC P-1889.

The ROCK DAM spawning nursery on the Connecticut River: the ONLY documented NATURAL spawning site for the ONLY FEDERALLY-ENDANGERED MIGRATORY FISH on the Connecticut River: the CONNECTICUT RIVER SHORTNOSE STURGEON.


Desiccating and baking shortnose sturgeon nursery habitat in the Connecticut River at the Rock Dam pool on May 21, 2021.
Photo Copyright © 2021 by Karl Meyer

The FEDERAL ENDANGERED SPECIES ACT OF 1973, Section 9: the term “TAKE” MAKES IT ILLEGAL TO: “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.”

Other federal and state laws NOT being ENFORCED on the Connecticut River at this critical habitat: the CLEAN WATER ACT, THE WETLANDS PROTECTION ACT, and, the Supreme Court’s 1872 landmark environmental decision for the Connecticut River in Holyoke Company v. Lyman—mandating that private operators of dams and facilities on the Connecticut—and thence for all rivers, must provide safe upstream and downstream passage for migratory fish.

A red slurry enters the Connecticut at the Rock Dam

Copyright © 2021 by Karl Meyer

When there is no WATCHDOG, there is no ENFORCEMENT.

THE: federal and state agencies and leaders responsible for implementation, protection and enforcement of laws and conditions protecting spawning, habitat, life-cycle and survival of the Connecticut River’s sole federal and state endangered migratory fish: THE CONNECTICUT RIVER SHORTNOSE STURGEON

THEIR NAMES:

Phil Glick, Chairman, Federal Energy Regulatory Commission:
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA (
Kathleen Theoharides: Sec. of MA Energy & Environmental Affairs
Martin Suuberg: Commissioner MA Department of Environmental Protection
Ron Amidon: Commissioner MA Dept. of Fish & Game
Daniel McKiernan: Director MA Division of Marine Fisheries
Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service

Here is a link to further discussion of testing the connection between the TF Canal and grim sludge at Rock Dam–w/Monte Belmonte, WRSI.com
https://wrsi.com/monte/how-to-save-the-shortnose-sturgeon/

When there is no WATCHDOG, there is no ENFORCEMENT.

CONNECTICUT RIVER: maybe not left for DEAD after all

Posted by on 04 May 2021 | Tagged as: American shad, Anadromous Fish Conservation Act, Andrew Fisk, Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, CRC, Daniel McKiernan: Director MA Division of Marine Fisheries, Delaware LLC, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Julie Crocker, Kathleen Theoharides, MA Division of Fish and Wildlife, Martin Suuberg, Martin Suuberg: Commissioner MA Department of Environmental Protection, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, Ron Amidon: Commissioner MA Dept. of Fish and Game, Source to Sea Cleanup, State of Delaware, The Greenfield Recorder, Traprock Center for Peace and Justice, US Fish & Wildlife Service, USFWS, Wendi Weber

CONNECTICUT RIVER: maybe not left for DEAD after all

Following the Great Earth Week Walk for River Survival to the Northfield Mountain Pumped Storage Project on April 24th, it’s been inspiring to see people publicly raising their voices to pull the grim, daily carnage of that power-hungry machine out from the shadows. One of particular insight was written by Susan Olmsted and appeared in The Recorder on April 30:
https://www.recorder.com/my-turn-olmsted-NorthfieldHydroStation-40211638 . Later, Ms. Olmsted relayed those same points into the public record of Federal Energy Regulatory Commission’s relicensing comments for the Northfield docket: FERC P-2485. Those are the routes to raising the public profile of our endlessly crippled River—its fate all but buried under confidentiality agreements and generations of inaction by the responsible agencies and so-called protectors. They all continue to lay low in a process that will decide our river’s ultimate viability for decades.


At the NMPS Intake. Photo Copyright © 2021 by James Smethurst

I again must thank the Traprock Center for Peace and Justice and Anna Gyorgy for organizing the event. Having written about this broken river for decades, and now having served on the Fish and Aquatics Study Team in this endless FERC process since 2012, it was an honor to speak up for the river with a caring and determined crowd in attendance. As I’ve noted to several people, last October I witnessed MA Energy Secretary Kathleen Theoharides and Watershed Council/Conservancy Director Andy Fisk launch a PR canoe tour for elected officials–directly upstream of the killer suction pipes of Northfield. In grim, self-serving fashion neither stepped up to the TV cameras or spoke with attendant reporters to proclaim, “This thing is our river’s greatest killer, it should be closed; this company, FirstLight, wholly re-registered these holdings out of state into Delaware as tax shelters two years back—they have no business here.” Shame on them both.

Watershed Council/CRC Director Andy Fisk, in vest, Chairs the Connecticut River Atlantic Salmon Commission 12/10/2018

BTW, we spoke at some depth on the Walk about the NU/Eversource building-of, and current massive connections to NMPS–and also the long-standing financial and Source to Sea greenwashing links between the Watershed Council/Conservancy and Eversource? Well, here’s a little late-breaking Eversource monopoly news: https://www.eenews.net/stories/1063731537

Personally, I would feel I’d failed our Great River, this ecosystem and coming generations had I never stood in front of this killer to bear witness to the truth. NMPS is a killer, and no configuration that leaves its grim sucking mouth open for ANY part of the year will retrieve it from being the most lethal machine ever deployed on the Connecticut. After so many years I am grateful that I had that opportunity–to stand up with other people and keep faith with our river–and link with those who will depend on its living waters in the future.


Revival Walk Crowd April 24, 2021 Photo Copyright © 2021 by David Keith

I don’t think a single person in attendance that day believes the snake-oil logic for continuing NMPS: that wasting massive amounts of energy to actually pull a river backward for miles–sucking 100s of millions of fish to their deaths as it wrenches its deadened water up a mountain, will ever be any kind energy “clean” or “green” solution on a heating-up planet whose ecosystems are unraveling. FirstLight’s will merely continue the laying-waste to our long-crippled river. It has nourished life here for millennia; they want to trade that in for their few hours of peak-priced energy.


MA Secretary of Energy & Environmental Affairs Kathleen Theoharides talks to the media–just yards away from Northfield’s deadly intake on a fluff PR tour on the river, October 2020. Photo Copyright © 2021 by Karl Meyer

It’s important to remember that this machine’s emplacement ran counter to one of the most significant landmark environmental decisions ever from the US Supreme Court, centered right here on the Connecticut River in 1872. In Holyoke Company v. Lyman the Court decided private operators of dams and facilities on the Connecticut—and thence, for all rivers, must provide safe upstream and downstream passage for migratory fish. Nearly 150 years later, this machine continues crushing millions of migratory fish—among them federal trust American shad, blueback herring and American eels. That killing occurs for eggs, larvae, juveniles and adult fish across the many months of their full migratory life cycles.

With the presence of a real watchdog, NMPS’s illegal presence never would have arisen here. There were decades to have sued for its shutdown. Today, neither its operation–nor FirstLight’s thin mitigation proposal to put up a partial, temporary net across its mouth annually that might spare some adult shad and eels from its suction just two months out of their killing year, even remotely passes the smell test for legal operation in a US Fish & Wildlife Refuge.

Raising public voices and flushing the buried dealings in this race-to-the-bottom FERC relicensing process is now the key to having some real impact in saving the Connecticut.

This Great River still feeds bodies and souls. It’s been struggling for well over half a century without an entity taking on the necessary mandate to “enforce” and take on the employ of a day-to-day legal team worthy of facing down predator corporations. This is an ecosystem destined to failure if citizens stay on the sidelines. But people are getting it; and standing up. Maybe this critical life-line of a river can be revived for the coming half century, to again nourish those of the future.

WORTH NOTING: Massachusetts and federal agency officials responsible for securing a living Connecticut River for your great, great, grand kids–upstream and down, through to Vermont and New Hampshire:

Kathleen Theoharides: Sec. of MA Energy & Environmental Affairs
Martin Suuberg: Commissioner MA Department of Environmental Protection
Ron Amidon: Commissioner MA Dept. of Fish & Game
Daniel McKiernan: Director MA Division of Marine Fisheries
Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA (endangered CT River shortnose sturgeon habitat)

GREAT CONNECTICUT RIVER SURVIVAL WALK DRAWS BIG MULTI-STATE CROWD

Posted by on 27 Apr 2021 | Tagged as: 1872, American shad, Bellows Falls VT, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Refuge, Conte National Fish & Wildlife Refuge, Daniel McKiernan, Delaware LLC, Eversource, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, Haddam nuclear plant, Holyoke Dam, ISO New England, Julie Crocker, Kathleen Theoharides, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Martin Suuberg, Martin Suuberg:, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Millstone 1, National Marine Fisheries Service, National Marine Fisheries Service, net-loss power, NMFS, NOAA, Northeast Utilities, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, NU/WMECO, P-2485, PSP Investments, Public Sector Pension Investments, river cleanup, Riverkeeper, salmon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, State of Delaware, Treasury Board of Canada, Uncategorized, United States Supremed Court, US Fish & Wildlife Service, Vermont, Vermont Yankee

GREAT CONNECTICUT RIVER SURVIVAL WALK DRAWS BIG MULTI-STATE CROWD

Claire Chang of the Solar Store of Greenfield speaks to attendees. Note: see http://solarisworking.org/. Photo Copyright © 2021 by James Smethurst. All Right Reserved

Northfield MA. The biggest story on the 410-mile long Connecticut River this Earth Week did not center on yet another promo video or soft news story about people doing trash cleanups. It took place on Saturday, April 24th, when more than 70 people of all ages–from as far as Springfield, South Hadley and Northampton MA–all the way upstream to Putney VT, turned out for a 3-mile river walk to learn about the 50 years of devastation that the Northfield Mountain Pumped Storage Station has wrought on their four-state ecosystem.

THE DAY’S SPEAKERS BEARING WITNESS

Attendees heard from host, Traprock Center for Peace and Justice’s Anna Gyorgy, about the long, deep connection of this river killing to nearly 50 years of nuclear power excess and damages (www.traprock.org). They heard from Claire Chang of the Solar Store of Greenfield about alternative energy, solar installation and bulk storage alternatives to destroying whole ecosystems. And, I spoke at length about the long, grim and deadly history that has brought us to a crossroads for a living future for the Connecticut River vs. this massively violent machine.

WHERE THE RUBBER NEVER MET THE ROAD

What people heard about was that shutting up NMPS’s killer intake pipes is the only river cleanup that matters. Doing just that would have saved a now-crippled ecosystem–had there been an actual watchdog organization on the Connecticut in 1972–or again, when Vermont Yankee’s license expired in 2012. Those are the cleanups that would have spared an entire ecosystem, decade-upon-decade of this hide-in-plain-sight sucking wound.

THE LEGACY OF FAILURES

They learned the Commonwealth Massachusetts has endlessly failed this ecosystem, facilitating its exploitation to the detriment of 3 other New England states by not protecting it. And, that the federal and state fish agencies have failed it as well by first chasing, then never relinquishing, their long-failed salmon experiment, for a fish not seen here since 1809. And also that the NGO claiming guardianship here since 1952, massively failed New England’s River–never stepping up to challenge and prosecute the devastation of the power companies, nor calling out or suing government agencies charged to protect it under state and federal law.

LANDMARK SUPREME COURT DECISION 1872: HOLYOKE CO. v. LYMAN

Living rivers do not flow backwards. People walked a mile and a half to the intake pipes of a deadly machine that has laid waste to billions upon billions of fish across a half century—literally suctioning them to death while pulling miles of river current into reverse. Folks learned that building of this net-power-loss, river-gorging appliance and the deadly impacts it created on migrating fish, particularly American shad—actually flew in the face of the 1872 landmark Supreme Court decision in Holyoke Company v. Lyman, a full century before NMPS was built. Given that law, it had no right to exist here at all.</strong>

Photo Copyright © 2021 by Robert Flaherty All Rights Reserved.

What did that landmark decision require of dam system owners and private companies operating on the Connecticut–and on all rivers of the United States a century and a half ago? It said all must provide safe fish passage, upstream and down of their facilities, as “public rights.” Visitors also learned that the Canadian owners of this 365-day-a-year slicing machine want only to provide a flimsy net, part way across its killer mouth, for just over two months out of the year. That will largely leave the eggs, larvae and juveniles of most species—including migrants, in full peril. Names of agency leaders charged with saving the river for our grandkids were supplied.

NOTE:text below derives from a The GREAT RIVER WALK handout

NO NEW LICENSE TO KILL: THE NORTHFIELD MOUNTAIN PUMPED STORAGE STATION: A HALF CENTURY OF WASTE, DEATH AND ECOSYSTEM DESTRUCTION.</strong> Notes from Karl Meyer, FERC relicensing Stakeholder and Intervener since 2012

To COMMENT: Federal Energy Regulatory Commission Project License P-2485 (www.ferc.gov E-comments) Include your name, address, project # P-2485 and a brief. specific remedy for FERC to apply.

Owner:venture-capital firm PSP Investments, a Canadian Crown Corporation.
Operating in MA as: FirstLight Power Resources.
Current tax sheltering llc registration since 2018 out of MA & New England: in Dover, Delaware

NMPS is an energy consumer. It has never produced a single watt of virgin electricity. Every day this machine consumes huge pulses of electricity from the power grid to suck massive gulps from the Connecticut backward and uphill for hours on end at a rate of up to 15,000 cubic feet per second(cfs). That sucking pulls the Connecticut backward at times for over 3 miles downstream. SOURCE: FERC P-2485 relicensing Study 3.3.9 appendices.

This is not a hydropower plant; it is an energy wasting machine operating exactly like an electric toilet. It runs on imported electricity, profiting on the buy-low/re-sell high model.

RUNNING BACKWARD FOR DECADES

**VIEW Federal Power Commission document with link HERE FPC 1974 flow reversals

That 15,000 cfs is the equivalent of 60, seven-bedroom mansions being swallowed each minute, for hours on end—with everything from tiny fish eggs to full sized American eels obliterated by its turbines. Twenty-four species are subject to that suction. For shad alone it’s estimated that over 2 million juveniles and 10 million eggs and larvae die here annually. That’s just one species. How many billions of fish die annually, across all species—and now across 49 years? A fixed, monitored, year-round barrier screen, fully across its mouth was required.

NMPS then later sends that deadened water back down in peak-priced pulses for a few hours in the morning and afternoon at up to 20,000 cfs. A living river goes in, all that comes out is dead. The Northfield Mountain Pumped Storage Station does its killing in the heart of the Silvio O. Conte Connecticut River National FISH & Wildlife Refuge. This Canadian company is operating in the heart of a four-state ECOSYSTEM, crippling and pulling it apart daily. It should be relegated to rare emergency use.

The scheme to pair this eviscerating machine with future ocean wind is a nightmare—fully a Greek tragedy. Ocean wind sent to kill its river babies. Future generations require a living river.

Energy should be consumed close to where it is produced. That is where the load is. In New England that load is at the coast. Large-scale compressed air plants can be built at New Bedford, Everett, Boston, Somerset and Middltown RI for large-scale wind energy storage. If FERC allows massive LNG export farms to be built at the coast, it can require space for “local” energy storage—right near all those current “natural” gas tank farms of today.Storage needs to be adjacent to those metro cities where it is consumed. That battery storage can be constructed is a given.

In the age of Climate disruption the goal of an electricity network–one safe from mass outages due to cyber attacks and wind and flood events–disrupting the current corporate mega-grid built for huge area energy relays, should be micro-grids and distributed generation.

That decreases vulnerability and will encourage CONSERVATION—never mentioned by the Federal Energy Regulatory Commission or ISO-New England. That is the formula that begins to tackle climate disruption. It is time for Re-Regulation of the power grid. It is time for TRANSPARENCY in the Commonwealth’s energy policy–done behind closed doors with monopoly capital interests running the ISO-NE and NEPOOL table, while excluding even journalists from meetings. This plant squeezes the life out of approximately 1-1/2 billion gallons of Connecticut River water daily—its deadened re-sale power for export—for “load” consumers far from the small towns and cities of this 4 –state ecosystem.

NMPS was built by WMECO/Northeast Utilities(NU) to run off the bloated excess juice of their Vermont Yankee nuclear plant, 15 miles upriver. VY closed forever in 2014. NU today remains massively wired into and out of this facility’s energy resale loop. Today NMPS deadly consumption continues on 50% climate scorching natural gas, 25% nuclear from NH and CT, and 10% actual hydropower from Canada.


The massively fouled Connecticut River and NMPS’s intake tunnels on September 6, 2010. Photo Copyright © 2021 by Karl Meyer

In 2010 NMPS choked on its own effluent, and unexpectedly did not run for over half a year after fouling its massive tunnels with silt and muck. Shut down from May 1st thru early November– after being hit with a “cease and desist” order from the EPA for secretly and illegally dumping that grim effluent directly into the Connecticut for months, in gross violation of the Clean Water Act. Nobody lost power during NMPS’s surprise shutdown for over half a year. That’s despite arguments from grid operator ISO-New England about how necessary its killer, daily re-sale juice is to keeping the lights on. Even during record-breaking summer heat in 2010—when VT Yankee even shut down for refueling, the power grid held together just fine.

What did happen in the 4-state ecosystem—quieted without Northfield’s massive disruption, was that dismal fish passage for American shad just downstream at Turners Falls dam shot up 800% above yearly averages for the previous decade. That was the ugly decade when NMPS began operating differently—after Massachusetts decided to deregulate electricity markets.

NMPS is an ecosystem-crippling, anti-gravity machine, gobbling vast amounts of energy to send a river into reverse and uphill—a buy-low/re-sell-high, cash cow regenerating set-up.

This machine is a crime against nature.

At a time when the planet is dying, you revive ecosystems. This river belongs to our grandchildren and the future, not to greedy foreign investment firms. The corporate concern here is merely the weight of water—live fish and living rivers are nuisance expenses. What would suffice here would be a bunch of pulleys and a giant anvil, like a Roadrunner cartoon. Stop killing the future for our kids.

ORIGINAL OWNER/BUILDER: WMECO/Northeast Utilities—completed in 1972 to run off the excess electricity from its sister plant, Vermont Yankee nuclear station, completed in 1972. NU also had ownership in VT Yankee. Today NU/Northeast Utilities is “doing business as” Eversource. Eversource remains massively wired into and out of NMPS/FirstLight facilities.
Eversource/NU never left us. They just decided to dump their creaky and massively-fined nuclear plants at Millstone and Haddam, to become a bigger, more concealed monopoly. What they did was transfer emphasis to T & D–Transmission and Distribution. They would make their bucks by CONTROLLING THE ENERGY TOLL ROAD. Note the massive new wire structures and the some 18-line-long laundry list of charges on your energy bill for simply for T & D. They have as yet not figured out how to get a kick back for delivering STATIC ELECTRICITY.

Eversource is perennially green-washed through its major-money sponsorship of the Connecticut River Watershed Council/Conservancy’s “Source to Sea Cleanup.” NU/Eversource and the Council (founded 1952) have a long, close, deep-pocketed history. Thus, this green-washed, river-killing apparatus has been quietly-enabled for decades.

A 2021 Brown University study named Eversource as MA’s largest energy spender against clean energy and climate legislation: https://ibes.brown.edu/sites/g/files/dprerj831/files/MA-CSSN-Report-1.20.2021-Corrected-text.pdf

The following companies are now in business as “wholly owned subsidiariesof Eversource:
Connecticut Light & Power, Public Service Company of New Hampshire, PSNH Funding LLC 3, NSTAR Electric Company, Harbor Electric Energy Company, Yankee Energy System, Inc., Yankee Gas Service, NSTAR Gas Company of Mass.(EGMA), Hopkinton LNG Corp., Eversource Gas Transmission II LLC, Eversource Holdco Corporation, Eversource Investment LLC, Eversouce Investment Service Company LLC, Aquarion Company, Aquarion Water Company, Aquarion Water Company of Connecticut, Aquarion Water Company of Massachusetts, Inc., Aquarion Water Capital of Massachusetts, Inc., Aquarion Water Company of New Hampshire, Inc., NU Enterprises, Inc., IP Strategy LLC, Eversource Energy Service Company, The Rocky River Realty Company, Holyoke Water Power Company. Eversource has residual interest in nuclear plants they’ve sold: Seabrook NH and Millstone CT.

Part ownership in: Alps to Berkshires LLC, 50% in transmission line to NY State, 15% ownership in Algonquin Gas Transmission LLC, BSW Holdco LLC, BSW ProjectCo LLC, Bay State Holdco LLC, Bay State Wind LLC, Northeast Wind Energy LLC, North East Offshore, LLC, New England Hydro-Transmission Electric Company, New England Hydro-Transmission Corp. Eversource also has interest and ownership in companies that own and manage decommissioned nuclear plants they once owned, including: Connecticut Yankee Atomic Power Company, 65%, Maine Yankee Atomic Power Company, 24%, Yankee Atomic Electric Company, 52%. SOURCE: https://www.eversource.com/content/wma/about/about-us/doing-business-with-us/affiliates/list-of-affiliates

RESPONSIBLE FOR SECURING A LIVING RIVER FUTURE FOR OUR KIDS:

Kathleen Theoharides: Sec. of MA Energy & Environmental Affairs
Martin Suuberg: Commissioner MA Department of Environmental Protection
Ron Amidon: Commissioner MA Dept. of Fish & Game
Daniel McKiernan: Director MA Division of Marine Fisheries
Wendi Weber: Director Region 5, U.S. Fish & Wildlife Service
Julie Crocker: Branch Chief, Endangered Fish Recovery unit, NOAA, Gloucester MA

It is time to break up the monopolies, re-regulate energy in Massachusetts for our children’s sake—and:RESTORE the CONNECTICUT RIVER ECOSYSTEM.

CONNECTICUT RIVER DEADBEAT DEFENSE: endangered species habitat orphaned–again

Posted by on 29 Mar 2021 | Tagged as: Connecticut River Atlantic Salmon Commission, Connecticut River Conservancy, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, FirstLight Power Resources, Julie Crocker, National Marine Fisheries Service, NMFS, NOAA, Nolumbeka, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Turners Falls power canal, Uncategorized, US Environmental Protection Agency, water lab

Photo Copyright © 2021 by Karl Meyer

This is the Rock Dam pool in the Connecticut River at Montague MA on March 10, 2021–just a month from the date male Connecticut River shortnose sturgeon will begin arriving here at the only documented natural spawning habitat for this federal- and state- endangered migrant in this ecosystem. The Rock Dam has been bathed in a grim red soup leaching out of the failing riverbanks adjacent to the Turners Falls power canal–just 400 feet distant, throughout the fall and winter. The riverbanks continue to crumble and ooze into this cobble lined pool today.

What is contained in the red sludge oozing from the crumbling banks besides the long-known iron and manganese? Is it harmful to developing early life stage sturgeon? What is its source, with the diverted Connecticut’s flow looming just above and 400 feet away–as pulses of its current are run through the Turners Falls power canal? Is it actually the Connecticut River trying to return to its own natural riverbed? Is the canal dike failing? Who is responsible for stopping the riverbank failures here–for enforcing the Endangered Species Act, Clean Water Act, to name just a few–at the Commonwealth and at the federal levels??

And, where oh where can you find a river watchdog with a legal team, an enforcement mandate, and an injunction weeks before these endangered fish return? Certainly not on the Connecticut River.

Clean water. Healthy habitat. Thriving communities. That is the banner slogan of the Connecticut River Watershed Council, recently renamed the Connecticut River Conservancy. Here is a month old statement from that outfit: “We’re not going to test it,” Andrew Fisk, Director, Connecticut River Conservancy. Fisk, who has a water quality testing lab at his Greenfield office, also sits at the head of the Connecticut River Atlantic Salmon Commission. The CRC also sits on the CT River Streambank Erosion Committee, and sponsors cultural programming that would beg an investigation and the preservation of the failing banks at this ancient fishing site.


March 10, 2021. Looking up the Connecticut River’s grim failing riveranks on FirstLight Power-owned property at the Rock Dam site in Cabot Woods, adjacent to the TF power Canal.Photo Copyright © 2021 by Karl Meyer

NATIONAL MARINE FISHERIES SERVICE out of Gloucester MA, under the National Oceanographic and Atmospheric Administration, has lead responsibility for the Connecticut River shortnose sturgeon. Shortnose sturgeon fall under their Office of Protected Resources. Though their representatives including Kimberly Damon-Randall, Julie Crocker, and and Michael Pentony have attended some of the bi-annual federal-state meetings here on the Connecticut, NMFS has sat mum and on its hands, as the critical habitat continues failing for the shortnose sturgeon at Rock Dam. No investigation, no protection, no worries.

TEXT IMMEDIATELY BELOW IS FROM THE NOAA/NMFS website:

“NOAA Fisheries and the U.S. Fish and Wildlife Service share responsibility for implementing the ESA. NOAA Fisheries is responsible for endangered and threatened marine and anadromous species—from whales and seals to sharks, salmon, and corals.

Under the ESA, the federal government has the responsibility to protect:
Endangered species—species that are in danger of extinction throughout all or a significant portion of their range.
Threatened species—species that are likely to become endangered in the foreseeable future.
Critical habitat—specific areas that are:

Within the geographical area occupied by the species at the time of listing, if they contain physical or biological features essential to conservation, and those features may require special management considerations or protection.”


March 11, 2021. Here, a woman stands in the a compact-car size sink hole along with disappearing hemlock saplings on the Connecticut River bank that’s slumping into Rock Dam spawning habitat.Photo Copyright © 2021 by Karl Meyer


Here that same woman stands looking directly up at that sink hole from below on the Connecticut River bank. She’s seen atop further, newer slumping sludge now heading into the river and Rock Dam spawning habitat on March 11, 2021.Photo Copyright © 2021 by Karl Meyer

Photo Copyright © 2021 by Karl Meyer

And these following three pictures, all from March 28,2021–less than two weeks before the first shortnose sturgeon arrive here, show the grim and burgeoning sludge and intrusions into critical Connecticut River spawning habitat at the Rock Dam. The main stem river in all photos is to the left.

Riverbank and species protection here, both federal and state, falls under the current Federal Energy Regulatory Commission license to operate facilities on the Connecticut River.

How can so many institutions fail so miserably at protecting the public’s river?


Connecticut River at Rock Dam, March 28,2021Photo Copyright © 2021 by Karl Meyer


Sludge running into the Connecticut River at Rock Dam, March 28, 2021.Photo Copyright © 2021 by Karl Meyer

ENDGAME LOOMS FOR NEW ENGLAND’S GREAT RIVER

Posted by on 10 Sep 2020 | Tagged as: American shad, Anadromous Fish Conservation Act, Atlantic salmon, blueback herring, climate-destroying, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, endangerd shortnose sturgeon, Endangered Species Act, ESA, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power Resources, Fish and Aquatics Study Team, GHG, Massachusetts Division of Fish & Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, right-to-know, Rock Dam, shad, shortnose sturgeon, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Revelator, The Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

Endgame Looms for England’s Great River Copyright © 2020 by Karl Meyer


The impoverished Connecticut River looking downstream to Turners Falls Dam. The run stops here. Photo Copyright © 2020 by Karl Meyer All Rights Reserved. (CLICK x 3 to enlarge)

NOTE: The following piece first appeared as an Op-Ed in The Revelator, an initiative of the Center for Biological Diversity on August 26, 2020. www.therevelator.org

FURTHER NOTE: * On September 1, 2020, after this piece first appeared, FirstLight petitioned FERC for an open-ended date to extend the filing of their Final License Applications citing a need for new test data to respond to the USF&WS. If FERC agrees, that would add another 4 months and possibly another full year, to this endless process–without any long-awaited relief for a flow starved Connecticut River. It’s time for FERC to wrap this up.

After a half-century of failures, the recovery of the Connecticut River ecosystem hangs in the balance. Will authorities finally act to save it?

Rivers should not die in the dark.

On Aug. 31 FirstLight Power Resources is expected to file its final license applications with the Federal Energy Regulatory Commission to continue operating three hydro facilities profiting off massive water diversions from the Connecticut River in Massachusetts. The conditions written into FERC licenses can last up to 50 years.

These applications signal the beginning of the final chapter in determining the future of the four-state river at the heart of the Silvio O. Conte National Fish and Wildlife Refuge, founded to protect a 7.2-million-acre watershed. Their rendering will decide the future of migratory fish, river flows and a host of embattled ecosystem conditions on New England’s longest river, some running counter to laws in place since 1872.

When decisions affecting a river for decades are being made, the public has a right to know of the stakes, the players and the key decision makers. In this case the public knows little of issues potentially affecting 2.4 million people in a sprawling watershed.

One of the failed fish ladders sending all spring migrants into the Turners Falls power canal maize. Across 45 years just 5 shad in 100 have succeeded in passing the Turners Falls Dam–leaving 50 miles of spawning habitat in 3 states largely empty. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife have been at the table in this FERC license-determining process since 2012. But three years back, all parties signed nondisclosure agreements with FirstLight — ostensibly to facilitate settlement discussions on flows, habitat, dismal fish passage and endless mortality cycles at these Massachusetts hydro sites. Those NDAs have kept these issues largely out of the media, even as initial settlement talks broke off a year and a half ago.

*Since 2012 I’ve been a FERC-recognized intervener in the relicensing process. I chose not to sign the company’s confidentiality agreement in order to preserve the right to address and highlight the critical, long-term decisions being made about the Connecticut River in a process that remains largely out of public view.

FirstLight is part of the giant Canadian investment outfit PSP Investments, which arrived in Massachusetts four years back to buy up these facilities from GDF Suez. In 2018 it quickly reregistered the facilities as limited liability tax shelters in Delaware. Regardless of their state of incorporation, the licenses they now vie for will each be subject to current federal and state environmental laws, under terms mandated by the fish agencies and FERC.

Entranceway to the “Great Falls Discovery Center” where, most days out of the year, there are literally no great falls running here at all… The sprawling rocky riverbed is an emptied bowl. Photo Copyright © 2020 by Karl Meyer.

Of more than 500 U.S. refuges, Conte is one of just three with “fish” in its name. Today hopes for the long-term protections of its fish and the river comprising its central artery rest heavily in the hands of the U.S. Fish and Wildlife Service, National Marine Fisheries Service and Massachusetts Division of Fisheries and Wildlife. They have “conditioning authority” in these relicensings — mandates to protect the life in this river system. FERC, the ultimate relicensing umpire here, is also mandated to ensure compliance with environmental laws. For the fish agencies this is their one chance to redeem some far-reaching mistakes made by their predecessors.

Forty-five years ago these agencies — operating on limited information and pursuing dreams of reprising a salmon not seen on this river since 1809 — signed agreements with different owners of these facilities. That hobbled, for generations, a four-state migratory fisheries restoration for American shad and river herring and a recovery for federally endangered shortnose sturgeon. They sanctioned the daily use of the massive river-reversing pumped storage facility still chewing through generations of migratory and resident fish today. Concurrently they left two miles of the river emptied downstream, its flow diverted into a turbine-lined power canal that all migrants must negotiate in order to access the next 50 miles of open spawning habitat. Just 5 shad in 100 have ever succeeded. Perhaps worse, the river’s only documented natural spawning habitat for the endangered shortnose sturgeon was left without life-sustaining flow.

A Tale of Two Salmon, a River Without Fish

The last wild salmon run on the Connecticut River was recorded in 1809.

Science later revealed the salmons’ end was likely a combination of warming temperatures following the unusually cold period known as the Little Ice Age coupled with modern dam building.

For 165 years there were no salmon. Then, in 1974, a single fish arrived at Holyoke Dam. Far from being a native of the Connecticut River, this was a new hybrid — a returning fish produced at one of several federal hatcheries completed five years prior. This salmon’s genes, like the genes of all the fish that would return in subsequent years, were cobbled together using salmon from several still-surviving runs in northern New England.

This past June 30 marked a different milestone on the river. It ended the first season in 46 years when not a single hatchery-derived Atlantic salmon returned past Massachusetts’ Holyoke Dam.

That unnatural history event passed with little fanfare. Its silent-spring absence marked the end of a half-century-old program that consumed hundreds of millions of dollars and ate up far too much room in a badly broken ecosystem. The U.S. Fish and Wildlife Service abandoned its hatchery program at the end of the 2012 migration season, but across its 43 years — which saw the annual release of millions of fry and smolts to tributaries in Connecticut, Massachusetts, Vermont and New Hampshire — so few adults returned that no one was ever allowed to catch one.

This second salmon ending highlights the fish agencies’ last shot at returning ancient ocean connections to the river’s still-viable, age-old runs of American shad, blueback herring and federally endangered shortnose sturgeon in three states.

All these species have been guaranteed safe passage on U.S. rivers, going back to the landmark Supreme Court decision in Holyoke Company v. Lyman in 1872. That finding centered on the dam in Holyoke, Massachusetts and held that private dam owners operating on U.S. rivers must provide for the free movement, upstream and down, of migratory fish past their facilities.

Looking west across the CT to the Holyoke Dam fish lift complex. Since 1955 it is one of the East Coast’s few fish passage successes. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Its implementation on New England’s river is now 148 years overdue.

A River Run in Reverse

What’s ultimately at issue here is flow.

Having taken a back seat for generations, wild runs of shad, herring and sturgeon remain in desperate need of passage and consistent, exponentially increased river flow in FirstLight’s hydro-complex dominated reach. It’s literally the weight of water that matters most to FirstLight. It’s money in the bank. And where flow diversion is concerned, it’s been pretty much a free ride for companies here for the past 50 years.

The 20 miles of river backed up into Vermont and New Hampshire behind Turners Falls Dam are massively suctioned for hours at up to 15,000 cubic feet per second to fill the 4-billion-gallon reservoir above the Northfield Mountain Pumped Storage Station.

Northfield’s suction is so violent it literally reverses the Connecticut’s current for up to a mile downstream at times, erasing the essence of a living river system. The station kills everything it sucks in, from tiny fish eggs to full-size eels. In pumping mode it suctions the equivalent of 3,600 seven-bedroom mansions, each filled with the aquatic life of a river, vaporized every hour, for hours on end. Agency studies on America shad show tens of millions of eggs and larvae extinguished at Northfield annually, plus the deaths of over 2 million juvenile shad sucked in on migrations back to the sea. Five migrant species are subjected to Northfield. In all 24 species live here, most unstudied.

Warning floats on the CT at the entranceway to Northfield Mountain Pumped Storage Station’s massive subsurface suctioning site. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Northfield’s operations are nothing like classic hydro, operating to produce virgin electricity via a dam in or adjacent to a river. It’s actually an electric appliance, built to take advantage of excess, unused megawatts produced nightly at the nearby Vermont Yankee nuclear station. Northfield burns electricity to pump water from the river a mile uphill to into its reservoir tank, which was created by blasting off the top of a mountain. The company’s original owners would buy up Vermont Yankee’s cheap electricity to power its giant, reversible turbines. Later, during peak energy times, that now-lifeless river water would get sent back through the turbines to generate hours-long pulses of energy at peak market prices.

It’s a buy-low, sell-high operation, still running at the expense of a river system six years after Vermont Yankee shut down.

Idle bulldozers sit in the emptied bed of the giant NMPS reservoir on June 27, 2010–the year they broke their giant appliance by fouling the pumps with muck and silt. Sanctioned by the EPA for a cover-up and massively dumping the muck from their mile-long intake tunnel directly into the river, Northfield didn’t operate for over half a year. Photo Copyright © 2020 by Karl Meyer. All Rights Reserved. (Click x3 to enlarge.)

Northfield is a net-loss energy machine — a giant underground appliance consuming massive amounts of grid electricity, half of it now generated by the climate-scorching natural gas that dominates New England’s power grid today. The station consumes 25% to 33% more juice than the secondhand megawatts it sends back by dumping deadened river water back through its turbines. It and a smaller pumped storage station in Connecticut are responsible for gobbling up 1.4% percent of the region’s energy in order to reproduce the few hours of secondhand juice they regenerate. According to grid operator ISO-New England, they are the only facilities whose operations flush out as negative input in the regional power mix.

Northfield has never generated a single watt of its own electricity. And though it may be fine as blunt instrument for use during the occasional power grid slump or rare emergency blackout, its endless, river-crippling, pump-and-purge cycle of regenerated megawatts is unnecessary for the daily operation of the New England grid. While its owners brag of being able to power a million homes for a few hours, they never mention having already burned through the energy of 1.25 million homes to do so. After its daily flush, Northfield is virtually dead in the water and must begin pulling from the grid and sucking life from the river all over.

Past mistakes not only allowed for this massive upstream disruption, they sanctioned diversion of nearly all flow, as well as all migrating fish, into a downstream power canal that on average just 5% of shad have ever successfully negotiated. That left another two miles of New England’s river dysfunctional, with the company providing just a dribble flow of 400 cubic feet per second in the riverbed in spring, when fish are moving upriver. That riverbed remains emptied of all flow more than half the other days of the year.

The most critical time for sustaining flows and the river’s migrants is April through June, when New England’s energy consumption is at its low annual ebb. But federal and state studies and in-river findings show that spring flows will need to be increased by a factor of 20, supplying 8,000 cfs rather than the current brook-like drizzle of 400 cfs. That’s what it will take to guide shad and blueback herring upstream in the river past Turners Falls Dam. That will also provide this river’s only endangered migrant the consistent flows required to successfully allow the shortnose sturgeon to spawn and ensure its larvae can develop in the cobbles at an ancient river pool in that impoverished reach.

Flow starved Connecticut River at the Rock Dam–critical shortnose sturgeon spawning and rearing site, May 13, 2018. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

Back in 1967, when four New England states and these agencies signed the “Statement of Intent for the Cooperative Fishery Restoration Program for the Connecticut River Basin,” they projected some 38,000 salmon would return annually to this four-state ecosystem. For salmon, a pinnacle of sorts was reached in 1981, when 592 were tallied passing Holyoke. But for a hybrid fish whose wild prototype disappeared 160 years prior, it was downhill from there. Most years fewer than 100 salmon returned to the river.

That 1967 agreement also set annual run targets of one million American shad heading upstream, with 850,000 shad passing Turners Falls and 750,000 entering Vermont and New Hampshire habitats above Vernon Dam. The highest shad return saw 720,000 passing Holyoke in 1992. Sadly, they’ve never made it much farther.

The Run Stops in Massachusetts.

Just 36 miles upstream of Holyoke, all semblance of a successful restoration ends when the annual shad run reaches Turners Falls Dam. Of the 537,000 shad that passed Holyoke in 2017, just 48,000 — a mere 9% — squeezed back into the river beyond Turners Falls.

Vernon Dam between Vernon VT and Hinsdale NH, March 2020. Photo Copyright © 2020 by Karl Meyer

The annual inversion at the next upstream dam in Vermont illustrates the perils on this broken river. In 2017 29,000 or 59% of the shad that survived the miseries of Turners Falls were subsequently counted passing Vernon Dam, 20 miles upriver. That inverted interstate ratio has been the case since 1975, with few shad managing to break out beyond the brutal ecosystem conditions in Massachusetts.

Why the Restoration Failed

The current restoration, congressionally authorized in 1967 and still operating today under the moniker of the Connecticut River Atlantic Salmon Commission, made their biggest blunder in 1975 when they signed off on new license requirements for upstream fish passage. They ultimately chose a design based on hydro project fish ladders on Washington State’s giant Columbia River, known for huge Pacific salmon runs. What got built was a three-ladder fish passage that forced all migrants out of their ancient river highway and into the byzantine maze of the company’s power canal, while leaving two miles of riverbed all but emptied of flow.

Scaled down and put in place at Turners Falls, it worked fine for the program’s few successfully returning hybrid salmon but failed immediately for 95% of the hundreds of thousands of migrating shad. No big run has ever passed that site, leaving three states without their promised bounties. Vermont and New Hampshire remain this river’s shad deserts today.

The Prescription

It’s now 2020. At this late date, corporate re-registrations can’t hide what’s legally required and a half-century overdue on New England’s river. The last opportunity to undo those festering mistakes for the Connecticut now rest in the hands of the National Marine Fisheries Service, U.S. Fish and Wildlife Service and Massachusetts Division of Fish and Wildlife. They are the people’s gatekeepers, mandated to guard the public trust — agencies with the authority to change to the generations-old crippling conditions here in Massachusetts.

Across 45 years of tracking fish runs passing upstream at successive dams on the Connecticut, shad counts have averaged 315,369 at Holyoke, 17,579 at Turners Falls, and just 9,299 at the Vernon Dam in Vermont. But recently long-term federal and state studies on passage and juvenile survival for American shad have led to new minimum benchmarks for fish passage at each dam to ensure the long-term survival of the river’s runs.

Using those findings, the Atlantic States Marine Fisheries Commission, National Marine Fisheries Service, U.S. Fish and Wildlife Service and the four states have formally adopted new Connecticut River fish passage goals. They include annual minimums of 687,000 shad passing Holyoke, 297,000 passing Turners Falls, and 227,000 at Vernon Dam annually. Those federal and state targets are now part of the public record in the current FERC relicensings. Their implementation would also ensure the endangered shortnose sturgeon gets the flows needed to begin its recovery here.

It’s time to return flow to the Connecticut River below Turners Falls. Photo Copyright © 2020 by Karl Meyer All Rights Reserved.

The time has come for facilities operating and profiting off the life of New England’s river to come into compliance with the laws of the land, including the Supreme Court’s 1872 finding in Holyoke Company v. Lyman, the Anadromous Fish Conservation Act of 1965, the Endangered Species Act of 1973 and a host of others. For the fisheries agencies charged with protecting a river’s bounty, standing up for their implementation is the sole prescription for success in a four-state restoration undertaken when back Lyndon Johnson was president.

By law, by right and by the public trust, the Connecticut River’s time has come.

Karl Meyer has been a member of the Fish & Aquatics Studies Team and an intervener in the Federal Energy Regulatory Commission relicensing process for three Massachusetts facilities on the Connecticut River since 2012. He lives in Greenfield, Massachusetts. Meyer is a member of The Society of Environmental Journalists.

* * FINAL NOTE from the author: if all this history is new and troubling to you it must be considered that: this is the only river in the Northeast with several federal designations that has remained the only major waterway without an independent and effective watchdog–one with a full legal team on staff, and a mandate to investigate, enforce, and go to court. The generations-long mistakes and brutal conditions that have existed here would’ve long ago been challenged in court had there been an effective organization protecting the integrity of this river system. If the Connecticut River is to have a future as a living ecosystem, a new model will have to come into being.

Connecticut River shortnose sturgeon: a spectacular failure to protect

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

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

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

“Dear Mr. Traester:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Enviro Show

The Shortnose Sturgeon are Coming to Spawn –in THIS?

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