Northfield Mountain Pumped Storage Project

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FERC Comments as FirstLight seeks unprecedented mid-license power increase

Posted by on 10 Nov 2015 | Tagged as: Federal Energy Regulatory Commission, FERC licensing process, FirstLight, forward market power auction, ISO New England, Mt. Tom Coal Plant, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir

The following are comments submitted to FERC concerning what would be an unvetted and potentially precedent-setting mid-license power uprate for FirstLight’s Northfield Mountain Pumped Storage Station.

Karl Meyer, M.S.
Greenfield, MA, 01301
October 29, 2015

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

PROTEST against the granting of application for Amendment for Minimum and Maximum Reservoir Elevation for P- 2485-070, FirstLight Hydro Generating Company’s Northfield Mountain Pumped Storage Station.: Application for Temporary Amendment of Minimum and Maximum Reservoir Elevation Requirement, filed September 1, 2015.

Dear Secretary Bose,

In the 43-year operating history of the Northfield Mountain Pumped Storage Project a full assessment of the project’s impacts on the public’s river and terrestrial resources has never occurred. It has long been understood that NMPS significantly impacts some 50 miles of the Connecticut River’s riparian, stream bank, farmland and flood plain habitat from Vernon, VT to Holyoke, MA. The application before FERC requests a major, mid-license expansion of this facility’s storage and generating capacity without a full vetting of its impact on public resources.
If granted, the proposal before FERC represents a license to benefit—unrestricted and at profit, from a full 25% increase in generation capacity from NMPS’s Upper Reservoir for a 120 day period each fall, winter, and early spring, until 2018.

Given that NMPS is in the midst of its first-ever relicensing studies to gauge the impacts of its operations, it is not in the public interest to see this ongoing, 3 year, “temporary” storage amendment granted. Doing so without a full vetting of the emerging science and without the full participation of all stakeholders would amount to an Ex parte ruling—basically a precedent-setting gift to the power company during its run-up to a relicensing decision on April 30 2018.

NMPS has been granted extra cold season storage capacity only four times over its 43 year history. Each of those–save 2014, was restricted to extenuating circumstances where ISO would request NMPS to pump and generate beyond its mandated parameters after a trigger was reached. In requesting and being granted extra-limital storage last year, ISO and FirstLight appear to have entered into a new partnership of open-ended, unrestricted use of the public’s Connecticut River resources. This request is being made without investigation or any recompense to the public’s benefit beyond what both the utility and ISO refer to as “flexibility” in times of limited on-line capacity or restricted generation.

However, neither ISO or FirstLight has supplied any information as to how NMPS was used in any “emergency” capacity last winter—a winter that was prematurely touted as one with a tight energy market. Though a price squeeze was visited upon the public last winter in the form of vastly inflated energy bills, the predicted energy shortage never materialized. Both Northfield and ISO like to tout NMPS’s “black start” capability. However, to my knowledge the plant has only been used in that manner once, during the August 2003 Blackout, and increased storage capacity was not a factor in its use at that time.

ISO has in the past been tagged by FERC Board Members as supporting stilted judgements and sanctioning Foreward Market Capacity auction results that were clearly only in the interest of the power company—costing the public millions. That included 2013, when they sanctioned results from market bids by Energy Capital Partners(former owners of NMPS), who had unloaded their massive Somerset Coal Plant causing a dip in the future winter capacity outlook, sending energy bid prices soaring for ECP.

FirstLight has put itself in line to benefit from the same situation. They did not mention in any application that their Mt. Tom Plant was shuttered recently, and they stand to benefit if NMPS is granted open-ended generating privileges on the heels of a planned shutdown of one of their assets.

Further, it should be noted that FirstLight submitted only limited information on water levels in the CT River at their Turners Falls Dam and further downstream at the Montague USGS Gauge. No information was provided on how often, and by how much, the river fluctuated daily in the Turners Falls Pool due to their pumping and generating. They contend they generally strayed little from the average elevations in the TF Pool. Daily up-and-down figures during winter freezing, wetting, thawing, and rewetting, are wholly lacking.

FirstLight offers that it generated less in winter 2014/2015 than in many other years, but that tells only their story. When, and under what circumstances they generated, and at what profit, are really what’s required for a full assessment of the plant’s public good. Offering that “we only used a little” see?—is not any reasonable way to assess what might happen with an open-ended license to benefit from “peaking” spot market fluctuations this winter–or in 2016, 2017, and 2018.

Further, NMPS’s ownership changed hands three times over the last decade. Granting a mid-license capacity uprate to this plant could lead to speculation and instability in the deregulated market, causing a bubble in its asset value. If GDF-Suez decides to sell their NMPS plant in the interim, only merchants will benefit—with the public left in the dark on impacts, price, and profits.

I protest the granting of FirstLight an amendment to increase its minimum and maximum storage capacity for the remainder of its license. Further, FERC should not grant a one-year amendment without requiring a public accounting of how the plant was used in any “emergency” fashion—if any, last winter, and how its increased generation was harvested for profit on a daily basis last winter. If these are not provided, the amendment should be denied. Any amendment granted NMPS should include a capacity trigger from ISO, so as to ensure the public is not being gouged by winter fear-mongering.

Sincerely,
Karl Meyer, M.S.
Greenfield, MA, 01301

Greening Greenfield’s “Green Hero” for September

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

Greening Greenfield’s “Green Hero” for September

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

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

A special thanks from me to Susan and Dorothy.

Text of The Recorder piece follows:

A Passion for the Connecticut River

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

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

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

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

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

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

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

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

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

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

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

Sucking out the river’s life

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

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

Sucking out the river’s life

Copyright © 2015 by Karl Meyer

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

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

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

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

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

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

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

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

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

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

The Great Eddy at Bellows Falls

Posted by on 27 May 2015 | Tagged as: American shad, Bellows Falls, Bellows Falls Fishway, Cabot Station, Connecticut River, Connecticut River ecosystem, Dead Reach, GDF-Suez FirstLight, migratory delay, New Hampshire, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, power canal studies, Rock Dam, Rock Dam Pool, shad, shad fishing, Station 1, The Great Eddy, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole

BFallsdam
May, 27, 2015. I happened to be at Bellows Falls High School yesterday, and I took a walk into town and over to the Connecticut River at the now-closed Vilas Bridge. Just downstream of here and pictured above is a place formerly known as the Great Eddy. Here, prior to the completion of the Turners Falls Dam in 1798–the first dam to span the entire Connecticut, historic accounts recall 1,200 shad being pulled from the river at a single haul of the net. This picture was taken a few years ago, my batteries proved exhausted as I stood looking downstream yesterday.

There were two young guys far below, fishing in the shadow of the bridge, just downstream of the Bellows Falls Dam. When I hollered down they said yes, the fishing was good, “A rainbow and some bass.” Thus, today, it is rare for a single shad to reach Bellows Falls, the upstream limit of their historic reach. It is harder still to imagine that this place was once a key part of an ecosystem connected to the OCEAN.

I got a note from John Howard, GDF-Suez FirstLight’s Director of Hydro Compliance on Monday. He assured me that those scores of American shad stalled by false attraction flows roaring down from Station 1 had been worked out and agreed to by the USFWS as part of a flexible test flow grid due to an absence of rain. He’d neglected to forward the new test flow schedule to the Fish and Aquatics Studies Team. I imagine those shad burning up their energies would’ve liked to have had a heads-up as well. Their destination–as is the professed destination of the Connecticut River anadromous fisheries restoration these last 48 years, has been to REACH Bellows Falls, VT, and Walpole, NH.

Head gate flow at the TF Dam today, Wednesday, was again lamb-gentle. Of all the years I’ve witnessed flows pouring out of those head gates in the midst of fish passage season, this is the quietest I’ve ever seen them. Canal head gate flow and power generation from the canal at Station 1 and Cabot Station will all need to be looked at carefully in these studies to tease out any biases. (Click to enlarge photo).P1000457

Meanwhile, there were still shad being taken at The Rock Dam Pool this afternoon. I was headed down the path about 3:30 pm and a guy was walking out with a pole and his two energetic labs. He cautioned the wet dogs to give me a wide birth and I asked how it had been. “Not bad,” he said, “Better this morning.” I took a second look at the gentlemen and said, “Hi Jake, how are you?” “Doing OK, how about you?” Jake was part of the maintenance and grounds crew up at Northfield Mountain under Northeast Utilities when I was working at the Visitor Center some dozen years back.

“You still writing letters?” he asked. “I’m doing what I can.” “Good,” Jake replied, “Give it to ’em. Good luck!” Funny, but I bump into many folks who used to work there and there seems to be little sympathy for the company–or lingering loyalty.

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When I get down to the Rock Dam Pool three people are angling. The guy here has a shad on the line. Another guy, just a bit upstream toward the dam hooks one two or three minutes later. I head out, continuing downstream by bike. (Click to enlarge)
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Looking upstream from the deck of the General Pierce Bridge in Montague City, much of the riverbed is exposed due to the low flows. At top, far right, is the outfall and attraction flow at Cabot Station, which is likely to be attracting and capturing a good slug of the migrating fish–steering them out of the river to the ladder that will dump them into the power canal. (Click to enlarge)

Shad fishing reported as excellent below Turners Falls

Posted by on 12 May 2015 | Tagged as: 5-year FERC licensing process, American shad, By Pass Reach, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Dead Reach, FERC licensing process, Northfield Mountain Pumped Storage Project, Rock Dam, Rock Dam Pool, shad fishing, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized

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After decades of dismal flows and poor fishing, shad anglers immediately below the Turners Falls Dam and downstream at the Rock Dam Pool near the Conte Fish Lab, are reporting some excellent fishing. Federally-mandated test flows to help track migratory fish movement upstream through the Dead Reach of the Connecticut River below Turners Falls Dam commenced last Thursday. By Sunday, three fishermen at the Rock Dam Pool reported excellent catches while the dam was releasing 6,300 CFS (Cubic Feet per Second) the previous few days, though they noted it tailed off slightly when flow from the dam was tamped down to 4,400 CFS on Sunday.

Flow to the Rock Dam Pool, the only documented natural spawning site on the river for the federally-endangered Connecticut River shortnose sturgeon, had been cut to mid-summer levels just a week prior. With the test flows, life-giving water was returned to this abused reach of the river and shad readily followed their ancient river path upstream toward Vermont and New Hampshire spawning waters, without being lured into the treacherous Turners Falls Power Canal at Cabot Station, just downstream.

Those shad, at the current 4,400 CFS test-flow level, are currently being landed just below the Turners Falls Dam, where ecosystem-nourishing flows are being introduced here for the first time in decades as part of the studies for relicensing of the Turners Falls and Northfield Mountain Pumped Storage hydro projects on the public’s river.

The test flows will continue for the next several weeks—which should prove an interesting citizen’s science experiment for anglers who report their catch. Flows at the 4,400 CFS level will continue today, May 12, then will be reduced to 2,500 CFS from Wednesday, May 13, through Friday, and then elevate back up to 6,300 CFS from Saturday, May 16, through Monday, May 18.

New Comments to FERC, RE: Turners Falls Fisheries Studies

Posted by on 08 Apr 2015 | Tagged as: 5-year FERC licensing process, American shad, Cabot Station, Connecticut River, Connecticut River shortnose sturgeon, Conte, Dr. Castro-Santos, Dr. Haro, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, MA Division of Fish and Wildlife, Mr. Colton Bridges, New Hampshire, Northfield Mountain Pumped Storage Project, Revised Study Plan, Secretary Kimberly Bose, shad, shortnose sturgeon, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont

NOTE: the following comments were submitted to Federal Energy Regulatory Commission Secretary Kimberly Bose respecting FirstLight’s withdrawal from its stated position of using video-monitoring equipment at the Turners Falls Dam’s Spillway Ladder to compile study data and information on aggregations of migrating American shad.

This is information that has been the fisheries restoration’s Black Hole these last forty years. It can only be gathered at this site. However, with the withdrawal of these tools, fisheries agencies and the public will be relying on just a few hundred radio-tagged and tracked fish as substitutes for on-site, real time monitoring of aggregations of what are understood to be perhaps hundreds of thousands of migratory shad. (Comments to FERC were slightly abbreviated due space limits in E-filing.)

Karl Meyer, MS
Greenfield, MA 01301 April 8, 2015

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

Re: P-1889; P-2485

Dear Secretary Bose:

Please accept the following comments in the matter of the hydro-power licensing studies for P-1889, the Turners Falls Project; and P-2485, the Northfield Mountain Pumped Storage Project. These comments focus on changes FirstLight made to the Revised Study Plan. I first aired my objections to these RSP changes at a meeting on March 24, 2015–as a member of the Fisheries and Aquatics Study Team. They highlight a lack of Existing Information and a Need for Additional Information that FirstLight’s RSP revisions will not satisfy.

FirstLight has summarily excised all video monitoring in the vicinity of the Spillway Fishway at the base of Turners Falls Dam—a technique they’d agreed was needed in the initial RSP.

3.3.2 Evaluate Upstream and Downstream Passage of Adult American Shad

Existing Information and Need for Additional Information

Passage through the Turners Falls complex:

Study Goals and Objectives: (18CFR; 5.11(d)(1)

“Evaluate attraction, entrance efficiency and internal efficiency of the Spillway Ladder for shad reaching the dam spillway, under a range of conditions.”

FirstLight stated the following in their initial RSP response: (bolded italics below, mine

“Video monitoring will be used for specific study areas such as the Spillway Fishway. Use of video monitoring of the Spillway fishway will provide data on fishway efficiency; shad attempting to pass would be monitored versus only those shad that have been tagged.”

Task 2: Study Design and Methods:

FirstLight then wholly eliminated that key video information gathering technique that would help inform these studies with aggregate numbers of shad reaching the Spillway Entrance, versus only those few tagged fish approaching and passing the Spillway entrance.

From FirstLight’s March 14, 2015 RSP changes distributed to the Fisheries and Aquatics Study Team:

“The study will monitor shad migration within the study area using a combination of active and passive radio techniques and video surveillance.”

This needed information gathering was eliminated by FirstLight despite their description in the initial RSP that this was a proven and inexpensive technology:

“FirstLight proposes to conduct video monitoring using the Delta System commercial series of underwater video camera and lighting manufactured by Ocean Systems Inc. This system was recommended by A. Haro (Conte Lab) and has proven effective at other facilities. Video data will be recorded on a dedicated video recorder (DVR).”

“Video monitoring of the Spillway would add a modest cost to this study.”

As to why gathering information about aggregations of American shad at the Spillway adjacent to Turners Falls Dam is needed at this time–that need was stated in FirstLight’s initial RSP response as well:

“In general, the numbers of tagged fish passing through the Spillway Fishway were too low for vigorous evaluation (Haro and Castro-Santos 2005).”

Information about aggregations of migratory fish moving upstream to the base of Turners Falls Dam and the Spillway has been paltry to nonexistent these last 40 years. In the last 15 years, Dr. Haro and Dr. Castro-Santos of the USGS Conte Lab have focused nearly all their work in FirstLight’s power canal, while the Connecticut River passage route for these federal trust fish has been almost wholly ignored.

As to the huge gap in the information for American shad aggregations at this site, I herein cite expert testimony delivered before Commission members four decades back:

On August 21, 1975, in hearings before the United States Federal Power Commission in Boston, Mr. Colton Bridges, Deputy Director of the Massachusetts Division of Fisheries and Wildlife delivered the following expert testimony on the need for Spillway Fish Passage at the Turners Falls Dam:

To Mr. Bridges: Question: “Would either the Cabot power house fishway or the gatehouse fishway be effective in passing those early arriving shad?”

Answer from Mr. Bridges: “No, because with spill conditions at Turner Falls the major source of attraction water will be coming down river from the Turners Falls Dam and emanating from Cabot Station. Consequently, the conditions that existed at Holyoke with spillway flows limiting fishlift efficiency will prevail at Turners Falls Dam with only a Cabot Station fish passage facility in operation.”

Question: “What, in your opinion, would be the effect of the construction of the proposed fish passage facilities at Turners Falls Dam without the inclusion of the spillway fishway?”

Answer from Mr. Bridges: “Without a spillway fish passage facility, fish approaching Turners Falls during periods of spill will be attracted to the base of the dam and those isolated pools located immediately below it, and be subject to the same conditions that exist below Holyoke without the spillway fish collecting facility, i.e., migration delay and mortality due to lack of flow, increased water temperatures, and decreasing oxygen content.”

Given that, as of this date, FERC is refusing to allow the USFWS any in-situ access for snorkeling to get a general assessment of fish using this passage route to Turners Falls Dam during migration season–and that FERC is further disallowing any seining for fish or shad eggs in this reach due to concerns for endangered shortnose sturgeon, this is the only key place where any new information about Spillway aggregations of shad can be gained. This was stated as a result of FERC internal policy, though NMFS indicated a willingness to consult—and NMFS is the ultimate key-holder in decisions concerning Connecticut River shortnose sturgeon.

Hence, denying the gathering of this needed information at the Spillway effectively limits the public’s understanding of what is happening at this site. Though overall successful fish passage through the Spillway Ladder has proven ineffective these past 30 years, it should not limit the Entranceway as the key place to collect long-absent information on aggregating shad.

These are the early arriving fish that have long been known to be the key migrants–most likely to move upstream to Northern Massachusetts, Vermont and New Hampshire spawning sites on the Connecticut. As of this date, 40 years after Deputy Director Colton Bridges testimony, those fish are still not making it past Turners Falls Dam, and we don’t have the information about their numbers and when, where, and in what flow conditions they gather at the Spillway site.

For these reasons I respectfully request that Spillway video monitoring be returned to the Revised Study Plan for this season–to gather the data that cannot be gained simply by monitoring a few hundred radio-tagged fish.

Thank you.

Sincerely,
Karl Meyer, MS, Member, Fisheries and Aquatics Study Team for P-1889; P-2485

A look inside the FERC licensing process

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

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

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

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

Local Bias is produced and directed by Drew Hutchison.

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

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

FERC grants Northfield “temporary” Power Up-rate: the downside impacts of a studied pumped storage operation, re-posted.

Posted by on 04 Dec 2014 | Tagged as: American shad, Connecticut River, Connecticut River ecosystem, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, GDF-Suez FirstLight, ISO New England, Mt. Tom Coal Plant, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, USFWS

On November 26, 2014, FERC issued an “Order Granting a Temporary Amendment” for P-2485, the Northfield Mountain Pumped Storage Station to increase its storage capacity by 25%, and generate electricity during times of peak demand–or peak prices on the electricity “spot” market, without restriction.

In its power uprate application GDF-Suez FirstLight stated that this extra capacity was necessary due to power plant closures in Vermont and coastal Massachusetts and a predicted cold winter–a forecast for the Northeast that has now been re-evaluated, with a warmer winter now predicted.  GDF-Suez FirstLight did not mention in its application that it was shuttering its own 130 megawatt Mt. Tom plant in Holyoke in October. Another factor that may have played a part in the power uprate bid: GDF-Suez North America Hydro had had its bond rating downgraded in the prior fiscal year.

Given the unprecedented power hike granted Northfield, with ISO-New England formally jumping in the middle and cheering on the process with a formal letter to FERC, I thought I might republish testimony I sent to FERC last spring, when FirstLight submitted–then subsequently retracted as a “mistake,” testimony it posted on behalf of their plant’s storage flexibility cited the wind and solar benefits of a pumped storage plant in Ludington, Michigan.

If you read through the testimony you’ll see how devastating to the ecosystem and fisheries that Ludington Pumped Storage Plant has been.  That plant, though significantly larger, has a similar timeline–first started in the early 1970s, and currently undergoing relicensing. The big difference has been that local non-profits and agencies didn’t let them off the hook for the massive habitat destruction during their first licensing period–actually winning a $172 million dollar settlement from the owners some 20 years back.  Sadly, it was too late to shield their ecosystem or save their fisheries.

So, Northfield will pump more this winter.  It seemed a good time to re-post what the STUDIED damages were at another pumped storage plant over a similar time frame.  Sadly, we can’t know what we’ve lost across the decades here on the Connecticut River.

Read below:

New Stakeholder Comments filed with FERC re: Northfield Mountain

Posted by karlmeyer on 21 May 2014 | Tagged as: American shad, Bellows Falls, Connecticut River, Connecticut River ecosystem, ecosystem, Endangered Species Act, EPA, ESA, Federal Energy Regulatory Commission, federal trust fish, GDF-Suez FirstLight, Ludington Pumped Storage Plant, New Hampshire, Northfield Mountain Pumped Storage Station, shad larvae, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont Edit This

The following Stakeholder Comments were filed today, 5/21/2014, with the Federal Energy Regulatory Commission respecting Connecticut River fish mortality investigations at Northfield Mountain Pumped Storage station (NMPS)

Karl Meyer, M.S., Environmental Science

85 School Street, # 3

Greenfield, MA 01301

 

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission

88 First Street, N.E.

Washington, DC 20426

Stakeholder Comments, RE: FERC P-2485-063, and P-2680-108: relevance of FirstLight Hydro Generating Company’s document submission issued by FERC as “Conference/Meeting Transcript issued in FERC P-2485-063, et al” on May 9, 2014 for Northfield Mountain Pumped Storage project (NMPS). The inclusion of “Transcript of the April 17, 2014 FERC Scoping Meeting held in Pentwater, Michigan re Consumers Energy Company’s et al Ludington Pumped Storage Project under P-2680-108” offers an incomplete, unsubstantiated and confusing picture of its applicable connection to the relicensing of NMPS on the main stem of a four-state river system in Massachusetts.

Dear Secretary Bose,

Please consider the following comments respecting the relevance of FirstLight Hydro Generating Company’s recent document filing as it seeks a new license for the Northfield Mountain Pumped Storage station. I testified as a Stakeholder in the NMPS Study Dispute Panel Technical Conference along with officials from the USFWS and Trout UnLimited on Tuesday, April 8, 2014. The Dispute Panel was convened out of concerns that no study of the entrainment of eggs and larvae of migratory American shad was being required as part of a relicensing bid from GDF-Suez FirstLight Power for NMPS. I find no clear context provided by FirstLight for the inclusion of a transcript for the April 17, 2014 FERC Scoping Meeting for the Ludington Pumped Storage Plant–a lakeside Michigan-based facility, as part of the NMPS relicensing proceedings.

NMPS’s pumping/generating impacts are known to reach downstream to Holyoke Dam at river-mile 86 and affect spawning-run migratory fish that utilize Massachusetts, New Hampshire and Vermont habitats upstream to Bellows Falls Dam at river-mile 172. It is critical to the relicensing of any pumped storage generation on this four-state river to have robust studies with measurable outcomes to protect the public’s interest in a balanced and functioning Connecticut River ecosystem.

NMPS impacts migrating and spawning anadromous fish in a four-state ecosystem that has been the focus of a federal fisheries restoration program begun in 1967, “to provide the public with high quality sport fishing opportunities in a highly urbanized area, as well as provide for the long term needs of the population for seafood.” NMPS, completed in 1972, has been shown to have direct impacts on migratory fish entrainment and fish passage from northern Massachusetts to central Vermont and New Hampshire.

The US Fish & Wildlife Service, National Marine Fisheries Service, and fisheries directors in MA, NH, VT, and CT are all charged with protecting these resources for the public. Federal and state laws, licenses and statutes governing these mandated protections include the federal Clean Water Act, Endangered Species Act, and federal-trust fish protections beginning with the Anadromous Fish Conservation Act of 1965. FERC authority also mandates licensee compliance and protections for the public’s fisheries resources and restoration projects. FERC itself is mandated to comply with federal environmental law.

The Ludington Pumped Storage Plant is a FERC licensed facility sited and operating within a single state on a lakeshore well over 100 miles from it closest bordering state—and situated with 118 miles of open water at its back. Northfield Mountain Pumped Storage, situated adjacent to the Connecticut River, operates on the Navigable Waters of the United States in Massachusetts just 10 miles from where the Connecticut River passes out of Vermont and New Hampshire. NMPS pumps and generates from a narrow ribbon of river that is less than 1,000 feet wide—during warm seasons it sometimes draws more water than the river’s natural output.

In short, these are two very different animals, operating in very different habitats.

However, there are similarities in the long-term environmental impacts of these far-flung pumped storage facilities. They both kill large quantities of the public’s fish. Unfortunately, those impacts were not cited or included in FirstLight’s submission to FERC in either Dispute Resolution Panel documents or its license application documents. In 1995 the owners of the Ludinton Plant agreed to a $172 million dollar settlement for its killing o fish during the previous two decades. The public there at least had the minor benefit of one-time study that showed LPSP “in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

Unfortunately, to date, we have no such data from a study of NMPS, nor any compensation for the long-term damage to a public resource and a long-term fisheries restoration project. In Michigan, a US-based entity was required to pay restitution and undertake remedial action. Here at NMPS the plant operator is a transnational corporation, based outside the United States, that is “taking” an unknown quantity of a public resource without compensation or required analysis. If a US Citizen were to do this they would be subject to legal action.

 

Please see below: Ludington Daily News, August 13, 1987: “Federal agency rules on fish kill, Ludington hydro plant must comply within 60-90 days.”

The Ludington plant had begun operations in 1973, and had been the subject of legal proceedings from that time forward. The State of Michigan had filed a suit in Ingham County Circuit Court seeking more than $147 million in damages, and the National Wildlife Federation had won a federal court order that Consumers needed a pollution discharge permit for the plant.

In summary here are several excerpts from that article defining the impacts at that time including references to a single study that found the plant killed millions of native fish in a single year, species that are today disappearing, or have essentially disappeared, in Lake Michigan waters:

“Environmentalists and state officials Wednesday hailed a federal ruling designed to end the fish kills at the Ludington Pumped Storage Facility operated by Consumers Power Co.” (Co-owned with Detroit Edison Co.)

“Finally, after 14 years of negotiations and litigation, and the destruction of millions of Lake Michigan sports fish, we’re going to see an end to this needless waste of an important resource,” said Thomas Washington, executive director of the Michigan United Conservation Clubs.

“The MUCC, National Wildlife Federation and Department of Natural Resources have negotiated fruitlessly for years with Consumers Power to stop the fish kills.”
“The plant, in operation since 1973, pumps Lake Michigan water uphill into a reservoir, and generates electricity during times of high demand by letting it flow back to Lake Michigan through generators. In the pumping process, it kills millions of fish.”

“The MUCC said that a study commissioned by Consumers Power showed the plant, in a single year, killed 440,000 salmon and trout, 85,000 perch and millions of forage fish that served as food for valuable game.”

However, it took another eight years of environmental damage and drawn-out court proceedings before a settlement—totaling $172 million, was finally reached in 1995. See: Ludington Daily News, March 7, 1995: “Local groups urged to begin working on projects for fish kill settlement plan.”

“While 12 to 18 months more may pass before the settlement, valued at $172 million, becomes final state officials urged local groups not to wait to prepare proposals for enhancing local fishing.”

“Many audience questions fielded by the five-person panel concerned the perception the settlement doesn’t do much for Ludington area fishing specifically—the fishing most affected by the fish kill at the plant.”

It was only after 1995 that some of the large-scale impacts of Ludington Pumped Storage Plant began to be addressed. Ultimately, a FERC-sanctioned 2-1/2 mile long (12,850 ft) barrier net was deployed across hundreds and hundreds of acres of riverbed and bank.

Sadly, it seems that net did not mitigate or resolve the loss of local fisheries in the Ludington region. Its deployment was either ineffective or far too late for a regionally- and culturally-important sustained harvest of local- sourced and eaten native yellow perch and lake trout. Those perch have now essentially disappeared in the Ludington-Manistee region—which is noted in Stakeholder Testimony supplied for the Ludington Scoping Meeting on April 17, 2014 where Mr. Richard Underwood testified that past Michigan DNR creel surveys had found: “close to a quarter million perch” in Ludington habitats. “In the last few years, four years, we have had a total of zero count of perch in Ludington, and that’s how it has affected.”

The giant Ludington barrier net appears to be one key player in the puzzle of the missing perch. It appears to act as a fish trap. According to Mr. Underwood that net, along with an artificial reef constructed nearby, attracts a giant collection of cormorants that feed on the fish trapped within the confines of the net, “There were so many birds on the reef and inside the barrier net you couldn’t count them. I estimated there were 3,500.”

Ironically too, in recent years, federal hatcheries in the Connecticut River basin have been producing lake trout to supplement the now-crippled and dwindling native population of lake trout on Lake Michigan.

Another similarity in these two relicensing proceedings is that FERC’s Scoping Site Visits at both the NMPS plant and LPSP were scheduled either before the PAD had been given to Stakeholders, as it was NMPS, or—as noted in state fisheries testimony at Ludington, the Site Visits are not scheduled to take place until well after Study Requests and Stakeholder Comments are due.

Both of these processes deprived the public and officials the ability to visit, witness, and develop an understanding of the complex impacts of these pumped storage plants before submitting testimony, comments, and informed study requests.

Similarly, both plants have deployed barrier nets as a means of diminishing their fish kills and entrainment/mortality impacts. And, at both sites the fishing is poor and with stocks deteriorating.

The difference on the Connecticut River is that migratory fish here are forced to encounter two entrainment opportunities through FirstLight facilities. The first occurs seven miles downstream, when they are deflected by attraction flows into the Turners Falls Power Canal, with Cabot Station turbines operating on the downstream end.   The small percentage of fish that manage to survive the 2-1/2-mile, 8-day (average) transit to the head of that canal—and the even smaller number that actually exit upstream(1-10%), then get the chance to be culled by NMPS turbines, just five miles further upstream.

In its filing of the Ludington Scoping Meeting documents, GDF-Suez FirstLight seems to be suggesting some link between the large-scale wind power facilities built by LPSP owners Consumers and DTE, and a key, future role for renewables here in sucking the Connecticut River backward and pulling it uphill into the Northfield Mountain Pumped Storage reservoir.

That connection is tenuous, at best. Consumers and its partner DTE now own and operate a large-scale wind farm consisting of some 56 turbines. Its deployment required the purchase or easement rights to 16,000 acres of Michigan property, most of it to trench-out underground power lines to reach back to their grid and pumped-storage plant. Their large-scale wind operations are due to the presence of 118 miles of open Lake Michigan at their back, as well as a flat, open, prairie landscape to site giant turbines on.

FirstLight seems to be implying that NMPS will be similarly employed at some future date—its ecosystem impacts ignored because of the huge amount of surplus, cheap, local, renewable energy available to pump a river uphill at night. But solar doesn’t generate at night; and available local hydro here is modest and run-of-river—it would not constitute a “renewable” source to be tapped to pump water uphill. And, wind power opportunities here are spotty, small scale, and generally available on isolated ridge tops.

Clearly the Connecticut River Valley has none of the necessary features that might facilitate the large-scale wind renewables/pumped storage relationship found at LPSP. Nor, has FirstLight proposed plans for any large-scale wind projects in the region. No other entity has either. Cape Wind, whose large scale deployment will be installed miles off the Atlantic shore, is not proposing a pumped storage plant be built above the Truro Cliffs in order for its renewable energy megawatts to be consumed. Here, there just aren’t flatland mega-farm acres available, and only a few ridge tops here have proven suitable for siting isolated turbines.

GDF-Suez Manager John Howard stated at the Dispute Resolution Panel: “We can manage fluctuations in energy schedules with wind, solar, and imports from Canada and New York, primarily. And then the ability to respond very quickly to energy and operating reserve needs of the power system, any time of the day or calendar year.” He states that “We can manage…” But there is nothing backing up the statement. Nothing that proves there is a surplus amount of renewable energy reaching NMPS to state clearly that “We do manage…” or “We will be managing…”   The implication is that NMPS is a necessity here in order to implement renewable energy in the region. Where is the science to back that up? Solar is not around at night. And the region is sub-marginal for large-scale wind, as well as lacking in opportunities for securing thousands of acres of right-of-way here. So, where is the implied connection between these two facilities—beyond fisheries destruction?

Michigan, with its open face to the winds—which do blow at night, apparently ignores the to damage to its Great Lake ecosystem and fish, and tallies the wind-energy driving Lake Michigan waters and uphill to its pumped-storage plant as “renewable.” We don’t have that wind here, and solar power generation is a whole different animal–not in any way the high-octane source needed to push a river uphill at NMPS. FirstLight has built a 2 MW solar installation atop the 11 acres of land it was mandated to construct for silt-settling ponds by the EPA in 2010 after being sanctioned for massive infractions of the federal Clean Water Act by dumping up to 45,000 tons of pumped storage reservoir silt and sludge into the Connecticut River , the company has not included any information on how that solar facility connects to, and interacts with, and powers its pumped storage operations. Unlike large-scale wind, solar does not deliver its energy at night–when NMPS asserts that it will do most of its pumping.

Pumped storage can only be deemed “renewable” energy in a generating environment where ecosystem impacts are not considered. Pumped-storage itself was a net-loss bargain that was ill-considered even back when there was actually surplus nuclear available in the region. Now this taking-of-a-river is mostly accomplished at NMPS by climate-warming, non-renewable fossil fuels. This is a lose-lose situation for renewable energy use–and for an ecosystem.

GDF-Suez FirstLight’s NMPS plant does feature “black-start” capabilities, and does offer FERC and ISO the ability to accomplish load-leveling at certain critical times. However, these attributes must be balanced against long-standing federal and state efforts to complete a forty-seven year old migratory fisheries restoration on the Connecticut, and the public’s long-term need to have a sustainable Connecticut River ecosystem. NMPS operations also need to adhere to federal and state environmental law.

In 1995, Consumers and DTE paid the public $172 million for their past fish kills of the previous decades. Thus far, the public has not been compensated for the on-going taking of fish at NMPS on the Navigable Waters of the United States, nor have citizens in MA, VT, NH and CT been able to reap the benefits of anything near the stated goals of a four-state fisheries restoration program targeting recreation fishing and harvestable seafood.

Studies with measurable results are required for a fair relicensing process. Stated steps in the FERC relicensing process should be followed to allow the public a contextual look at the operations before the need to suggest studies or prepare testimony. To facilitate a fair process, FERC should require context and full disclosure of all submitted documentation on the part of the applicant, as well as phone conference transcripts to allow an understanding of the ongoing dispute procedure.

Placing a net in front of LPSP and NMPS has not stopped the fish kills at either plant. A band-aid should not be applied to a gaping wound. Complete and proper studies of all life stages of fish mortality are needed for NMPS relicensing. Regulatory pumping and generating restrictions that protect the public resources of US citizens are overdue and necessary there. The studies needed to accomplish this should take place before any new license allows this ongoing “take” to continue through 2048.

End of Formal Comments

Thank you for this opportunity to participate in improving license requirements and protecting the Connecticut River ecosystem for future generations.

Sincerely,

Karl Meyer, M.S.

Enron Redux in New England

Posted by on 14 Oct 2014 | Tagged as: Brayton Point coal plant, Cheryl Lafleur, Energy Capital Partners, Enron, Federal Energy Regulatory Commission, GDF-Suez FirstLight, Greenfield Recorder, Mt. Tom Coal Plant, Northfield Mountain Pumped Storage Project, Public Citizen, Rutland Herald, Times Argus

Note: the following piece appeared in September 2014 in the Sunday edition of the Rutland Herald(www.rutlandherald.com); the Times-Argus in Montpelier, VT(www.times-argus.com),  and The Recorder in Greenfield, MA(www.recorder.com).

Copyright © 2014 by Karl Meyer

ENRON REDUX

Kids: go to your parent’s bedroom and find mommy’s purse and take $110 out of it. Then go out and have some fun. Why? Because the Federal Energy Regulatory Commission and its own creation–the Holyoke, MA-based Independent System Operator of New England (ISO-NE), just confirmed that it’s ok to steal. The theft took place in June at a rigged ISO-NE “forward market” energy auction. There, Hartford-based Energy Capital Partners made off with the public’s loot to the tune of $110 from every New England ratepayer, according to consumer watchdog Public Citizen.

In a pre-dawn, September 17th press release, FERC Chair Cheryl LaFleur argued that it was legitimate for corporate-citizen ECP to manipulate the market and pick the pockets of ratepayers from Hartford to Springfield, and Boston and Montpelier—three years in advance. That panicked missive arrived directly on the heels of two FERC Commissioners, Norman Bay and Tony Clark, issuing their own September 16th press release terming the summer ISO-NE ratepayer swindle a “non-competitive auction.” It was a tiny crack in the curtain surrounding FERC decisions. In a split vote, LaFleur and one other Commissioner voted against intervening in the bogus outcome—thus tabling it, and letting the theft stand as legitimate commerce.

Given that, I’m figuring parents would prefer their kids got the cash, rather than a clique of market manipulators. Give your child a head start.

According to Public Citizen, FERC’s failure to intervene will have New Englanders forking out and additional $1.4 billion for the inflated BTU prices ECP manipulated into place for energy to be delivered three winters hence. That, Public Citizen says, will cost each of us over a hundred bucks.

With LaFleur providing the leadership, FERC, our public watchdog on energy projects, rates, regulation and reliability, gave the nod to its puppet-cousin ISO-NE–signaling that its “independent” actions letting ECP game the auction system were acceptable business as usual.

Just like stealing from your parents, Energy Capital Partners was pretty brazen in their market rigging. What they did was purchase an old New England dinosaur, the Brayton Point coal plant in Somerset, MA in 2013. Then, just weeks later, they announced they would be closing Brayton Point–citing environmental and economic constraints. That closure was timed perfectly to influence “forward” market prices. It would take place in May 2017—creating an energy “deficit” timed to show up on the books precisely as the 2017 energy auction was to take place. That staged BTU shortfall caused the spike in prices and accepted forward market bids at ISO-NE’s auction—all to be born at the public’s expense.

ECP will profit handily from their own paper tiger—silent proceeds flowing like electric current to investors, steered directly through ECP’s five other New England venture capital energy plants. That’s how you spike an energy market. It’s the stuff investors gush over.

FERC is charged with ensuring fair pricing for the public, as well as energy reliability in a deregulated market. In its own words its core responsibility is to “guard the consumer from exploitation by non-competitive electric power companies.” It was FERC that created ISO-NE, the regional grid’s independent system operator charged with keeping the lights on in the public’s interest. It’s now clear ISO also referees sham auctions.

Maybe New Englanders won’t mind getting their pockets picked; utility bills are clever at never revealing what you’re actually paying for. But I mind–$110 isn’t chump change to me. I’m worried too that today it’s FERC that’s also overseeing virtually all the controversial energy proposals now swamping the New England region: from mega Northern Pass power lines entering from Canada, to the Tennessee Gas Pipeline, to the relicensing of five large-scale hydro projects on the Connecticut River including the Northfield Mountain Pumped Storage Project.

Curiously, Energy Capital Partners sold the Northfield Mountain Pumped Storage Plant to GDF-Suez FirstLight Energy over half a decade back. Now it looks like FirstLight may be taking a page out of ECP’s market playbook. They just requested an open-ended and unprecedented “emergency” power uprate and a 20% increase in storage capacity for NMPS, due to a perceived–but as yet undocumented, energy shortfall for the coming winter. What FirstLight withheld in its lengthy application arguments to FERC, was that it is closing down its own 135 megawatt Mt. Tom coal plant in Holyoke this October. Create your own energy deficit. It is also an end-run around environmental relicensing studies set to take place next year. We’ll all pay.

So if you thought “no-bid” government contracts were a thing of the past and that energy market manipulation and wash-through trades were a distant echo of the Enron and Arthur Anderson scandals, think again. Given the pressing concerns of climate change and the dismal record of market manipulation, the time has arrived to re-regulate energy.

Karl Meyer of Greenfield, MA is a member of the Society of Environmental Journalists.

Stakeholder COMMENTS to FERC on Northfield Up-rate Request

Posted by on 10 Oct 2014 | Tagged as: Connecticut River ecosystem, Federal Energy Regulatory Commission, FERC, GDF-Suez FirstLight, ISO New England, Northfield Mountain Pumped Storage Project

*The following Stakeholder Comments were submitted to the Federal Energy Regulatory Commission on October 2, 2014.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 October 2, 2014

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

COMMENTS: on P- 2485-065, GDF-Suez FirstLight Hydro Generating Company’s:
Application for Temporary Amendment of Minimum and Maximum Reservoir
Elevation Requirement.

Dear Secretary Bose,

The Northfield Mountain Pumped Storage Project is currently undergoing
studies under the 5-year FERC relicensing process in order to continue
plant operations beyond 2018. NMPS was built as a peaking power plant—
making use of the surplus power generated from a cluster of Western New
England nuclear power facilities: Yankee Atomic, Vermont Yankee, and
Haddam Neck. Yankee Atomic and Haddam have long-since ceased operation,
and VY will close on December 29, 2014.

After that date, NMPS is requesting to remain in service as an entirely
different entity: a peaking plant, with no surplus regional nuclear power
to draw on. It will then be relying on coal, oil, gas, and imported
hydro to pump water uphill—a very expensive and inefficient process,
consuming what amounts to baseload energy to create peaking generation.
This will be bought on the open market; then resold to ratepayers at
peaking-market prices. The first question that must be asked is: is it
fair to consumers?

Why should such an open-ended power up-rate be allowed when stakeholders
are deep in the discovery phase of the relicensing process? Studies just
months down the road will help determine the current operational,
commercial and environmental impacts of NMPS.

This open-ended request uses NMPS’s “emergency” capabilities as a veil.
In truth, as ISO-NE well knows, it can—and does, take over NMPS on rare
emergency occasions, paying market rates to GDF-Suez for the plant’s
output. Thus, hiding behind an “emergency” goodwill intention is not a
forthright argument from FirstLight, and should not be accepted rationale
for granting NMPS an open-ended and, unstudied, 20-plus percent power
generation capability increase.

Looked at head-on, this is an attempt to turn a plant into a facility
that would now generate using legacy fuels to supply ratepayers with
peaking-priced, spot-marketed power in a quasi-baseload producer fashion.
If FERC were to allow such an increase for a full one-third of a year, it
would be creating a whole new animal in the energy market—without a
requisite public process.

FirstLight’s argument in its generation and storage capacity increase is
that it will be available for “emergency” situations which might arise in
winter markets. The reality is—request aside, NMPS is and has always
been a station prescribed for emergency use. That has been a chief
selling point since it opened 1972. And, it is still available as such—
without any amendments to its current license. Thus, no changes should
be made to current operational limits, as the plant can be called upon
under unusual-event circumstances by ISO within all currently sanctioned
parameters.

Allowing NMPS to begin generating as a baseload plant
without study or understanding of the full impacts of longer pumping and
generation would be an abrogation of FERC’s public responsibilities.
Under current operating conditions, NMPS creates what amount to erosive
tidal conditions in the Turners Falls Impoundment that exceed the daily
tides experienced at Hyannisport, MA. The requested new pumping and
expanded limits at NMPS during winter months will undoubtedly result in
an increase in erosion and sediment load in the river and at the NMPS
reservoir. Daily increases in freezing and thawing along sensitive
riverbanks dictate that.

In 2010 FirstLight attempted to clear its reservoir of sediment and failed
to accomplish the task. The result was a complete outage lasting seven months,
with NMPS unavailable for any emergency output. Most troubling was that
FL attempted to clear its reservoir and intakes by shoveling the silt and muck
directly into the Connecticut River. The EPA issued a cease and desist order in early
August, and FL was found to be in gross violation of the federal Clean
Water Act for polluting the navigable waters of the United States.

It should also be helpful to know that NMPS has never successfully
discharged the silt from its reservoir in its entire history without
experiencing a partial or full outage in its turbine battery. Given that
history, allowing NMPS to potentially create more siltation in the CT
River at their plant should not be allowed until they have proven it will
not impact emergency operations.

Further, attempts by a previous owner to utilize more of the NMPS
reservoir in the 1980s were turned back by a public process that
shed light on the fact that increased pumping of the Connecticut River
would result in significant impacts to the ecosystem. That request—to use
the Connecticut River as a drinking water source to be shifted up to the
NMPS reservoir and then transferred out of basin tothe Quabbin Reservoir,
was ultimately not implemented. In fact, it resulted in the implementation of
a new law, the Inter-Basin Transfer Act, which would only allow water to be
taken from the river in an emergency situation, after all logical engineering
steps were taken to plug holes and eliminate waste in the Boston water delivery
system.

That should be the situation going forward. NMPS remains in service as
currently licensed—available for use in specifically defined emergency
situations by ISO-NE, until studies are complete.

Lastly, is important to note that GDF-Suez FirstLight made no mention of
the closure of their own 135 megawatt Mt. Tom coal plant in Holyoke this
20141002-5022 FERC PDF (Unofficial) 10/2/2014 8:40:09 AM
fall, when they listed several outlier plant closures as reason for their
request to help as fill -in for a tight winter market. At the very least
that is disingenuous. Some might see it as market manipulation.

Thank you,
Karl Meyer, MS

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