Northfield Mountain Pumped Storage Reservoir

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The Broken Connecticut

Posted by on 09 Oct 2018 | Tagged as: American shad, Clean Water Act, Connecticut River, Connecticut River ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, FERC, FirstLight, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, pumped storage, Relicensing, shad, Uncategorized


Copyright © 2018 by Karl Meyer. All Rights Reserved

Eight years ago, almost to the day, this is how the Connecticut River in front of the Northfield Mountain Pumped Storage intake looked. (Click, then Click twice more)

The owners were under sanction from the EPA and had been scrambling for months to suction the mountain of reservoir silt they’d illegally dumped directly into the Connecticut after massively botching their reservoir de-watering and clean-out.Northfield remained inoperable from May 1st through early November. To minimize the reactivation of silt they’d already fouled the river with, they set up a ponderously long silt curtain–supposed to keep their gunk in place. Below, is how their silt-safety set-up looked on July 20, 2010 (Click, the Click twice more)

However, if you look at how effectively that sanctioned-solution was when employed-by–and deployed by the company, you would have to look at this photo below from October 2, 2010. (Click, then Click twice)

The sole solution FirstLight has proposed in these FERC proceedings to prevent the suctioning deaths of millions of juvenile shad–and that’s disregarding their round-the-year evisceration of adult and young fish of dozens of species, is to place a barrier net across the mouth of their giant suction and slice pumped storage contraption. This, for the next several decades, would be like putting a band-aid on a massively severed artery. If they couldn’t keep a net in place in the river when Northfield was sanctioned NOT pumping at all, what gives anyone the idea that this bit of window dressing will be of any service to a broken river system at all.

Since FirstLight is proposing to suck more water out of the river to suck into that reservoir, why not trade that money-making scheme for having NFMT shut down at key seasons to comply with the law and protect the Public Trust.

In delivering the 1872 Supreme Court’s decision in Holyoke Company vs. Lyman, Justice Nathan Clifford entered the following into his decision:

“Ownership of the banks and bed of the stream, as before remarked, gives to the proprietor the exclusive right of fishery, opposite his land, as well as the right to use the water to create power to operate mills, but neither the one nor the other right nor both combined confer any right to erect obstructions in the river to prevent the free passage of the fish up and down the river at their accustomed seasons.”

In deciding against the dam owners who had repeatedly refused to construct fish passage at their dam as settled law in the Commonwealth had long required, the Court made upstream and downstream passage of the public’s fish a precedent and legal right in rivers throughout the United States.

“Fish rights below a dam, constructed without passageways for the fish, are liable to be injured by such a structure as well as those owned above the dam, as the migratory fish, if they cannot ascend to the head waters of the stream at their accustomed seasons will soon cease to frequent the stream at all, or in greatly diminished numbers.”

“Clean, renewable” labels don’t apply

Posted by on 01 Oct 2018 | Tagged as: Ashuelot River, Bellows Falls, blueback herring, canal shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River shortnose sturgeon, crippled ecosystem, Dead Reach, ecosystem, endangerd shortnose sturgeon, Endangered Species Act, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC Commissioner Neil Chatterjee, FERC license, FirstLight, Fish and Aquatics Study Team, fish counts, fish kill, fish kill on the Connecticut, fish passage, fishway windows, Holyoke Fish Lift, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, National Marine Fisheries Service, New Hampshire, NMFS, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, nuclear power, PSP Investments, Public Law 98-138, pumped storage, Relicensing, resident river fish, Saxtons River, Scott Pruitt, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vermont Digger, Vermont Yankee

Copyright © 2018 by Karl Meyer All Rights Reserved.

NOTE: the following piece appeared in VTDigger, www.vtdigger.org in September under the heading “Clean, renewable” labels don’t apply when crippling an ecosystem.”

TERMS OF ENTRAINMENT: a Connecticut River History


NOTE:in this photo are over 170 juvenile shad, among the many thousands killed in the recent de-watering of the Turners Falls Power Canal. The power canal is where the bulk of the Connecticut River is diverted into for most months of the year. So, when they drain it, they are killing the river. However, if you look at this photo and multiply that death toll by 10,000 you begin to get some idea of the mortality counts for young-of-the-year shad entrained annually–and un-tallied across nearly five decades, at the Northfield Mountain Pumped Storage Station. (CLICK, then CLICK twice more to enlarge photos.)

At 2:41 p.m. on May 20, 2018, a lone blueback herring appeared in the windows at Turners Falls Dam among a school of larger American shad. It was a small miracle. Barely a foot long, it was the first blueback here since 2005, and there would not be another this spring. Like those shad, its life had already spanned four springs, swimming thousands of ocean miles in shimmering schools. It re-crossed bays and estuaries of seven states and two provinces before reaching this Connecticut River juncture. In doing so it had survived sprawling drift nets and repeated attacks from sharks, bluefish, spiny dogfish, cormorants, seals and striped bass.

All these fish were seeking to spawn and give their young a head start as far upriver as currents, time and temperature would allow. Unfortunately, five miles upstream sat the Northfield Mountain Pumped Storage Station, a river vacuuming machine capable of out-killing all their natural predators. For the next 20 miles they’d be vulnerable to its impacts.

NMPS has inhaled river fish of all species and sizes daily for nearly half a century. Results from a river sampling study Juvenile Shad Assessment in the Connecticut River, were released in June by the US Fish & Wildlife Service and MA Division of Fisheries & Wildlife. They estimated NMPS’s 2017 operations resulted in losses of some 15 million shad eggs and larvae, plus the deaths of between 1 and 2-1/2 million juvenile shad. That’s for just one species.

On April 20, 1967, years before Northfield was built, federal agencies and four states signed the Statement of Intent for a Cooperative Fishery Restoration Program for the Connecticut River, agreeing to restore runs of American shad, salmon and blueback herring upstream to Bellows Falls, Vermont and beyond. The migratory shortnose sturgeon had already been listed as endangered. Continuing today under Public Law 98-138, its mandate requires utilization of “the full potential of the fishery resources of the Connecticut River including both anadromous and resident species,” providing “high quality sport fishing,” and meeting “the long term needs of the population for seafood.”

American shad are still commercially fished today just 60 miles downriver. They’ve provided seafood to this valley for ages, yet most people in Vermont, New Hampshire and Massachusetts don’t know they were promised a “just share of the fishery harvest” back in 1967. All remain without, while shad continue to grace dinner and restaurant tables in Connecticut every spring.

Running on imported power via the buy-low/sell-high model, Northfield can suck the river into reverse for up to a mile downstream. It devours everything captured in that vortex at 15,000 cubic feet per second. Think 15,000 milk crates, for hours, to fill a 5 billion gallon mountain reservoir. The result is 100% mortality for all fish entrained. During peak-use and/or peak-price times—or both, it sends the deadened water back through its turbines as twice-produced electricity.

NOTE: more of the TF Canal kill here in another location–including mostly juvenile shad, but also a bluegill, several mud-puppies, and a young sea lamprey. Again, this is just a whisper of the year round fish kill occurring upstream at Northfield Mountain.

Northfield was built to run off Vermont Yankee’s excess nuclear megawatts. But even after VY closed in 2014, its carnage continued, unchallenged, rather than being relegated to emergency use. Having never produced a watt of its own power, its 46 years of accumulating carnage are yet to be tallied. That herring might have been heading for New Hampshire’s Ashuelot or Vermont’s Saxtons River, and those shad were perhaps steering for the Great Eddy at Bellows Falls. Regardless, any progeny would later face Northfield’s net-loss-power impacts heading downriver come fall.

Currently it pumps mostly at night when Canadian owners PSP Investments can purchase cheap electricity to suction the river uphill. Later it’s released as second-hand juice at peak-of-the-day profits. Promoters claim the benefits of dispersed solar and wind power can’t be realized without first relaying their renewable energy across the region to this lethal storage machine for later resale in markets far beyond the Connecticut Valley. “Clean, renewable” labels don’t apply when crippling an ecosystem.

NMPS boosters include (now-former) EPA Director Scott Pruitt, who made a sweetheart visit there last Valentine’s Day along with Federal Energy Regulatory Commissioner Neil Chatterjee. That occurred as PSP was requesting to suction yet more water from the Connecticut and applying for a new long-term FERC license. The next day FERC announced a major policy shift, potentially increasing both Northfield’s daytime use and its profits.

Since an 1872 landmark Supreme Court ruling indemnifying Holyoke Dam, all hydro facilities have been required to safely pass the public’s fish, upstream and down. But that 1967 agreement had this warning: “Based on the present fragmentary data available on the Northfield Mountain Pumped Storage Project, it appears that this project poses definite limitations to an anadromous fish restoration program. These limitations involve the physical loss of eggs, larvae and young fish of both resident and anadromous species, and an orientation problem for both upstream and downstream migrants attributed to pumping large volumes of water.” Today the 20 mile reach hosting Northfield remains a migration minefield—while some 30 miles of open Vermont/New Hampshire spawning habitat above Vernon Dam sits essentially empty.

Holyoke Dam has annually lifted hundreds of thousands of shad and herring upstream since the 1970s. In 2017 it recorded its second highest shad numbers ever, 537,000 fish. Each spring, half or more of those shad attempt to pass Turners Falls. Less than 10-in-100 will succeed. Of those, some 50% drop from tallies and are never re-counted at Vernon Dam after entering the 20 miles impacted by Northfield. The blueback herring record at Turners Falls was 9,600 in 1986, out of the 517,000 counted 36 miles downstream at Holyoke that year. Of those 9,600 Turners herrings, just 94 reached Vernon Dam. Turners Falls saw another 7,500 blueback herring in 1991; just 383 reappeared upstream at Vernon.

Any new long-term FERC license must comply with federal and state law protecting endangered and public-trust fish. In seeking a new license, PSP’s main proposal for limiting Northfield’s massive carnage has been the test-anchoring of a few yards of Kevlar netting in the riverbed in front of the plant’s suction-and-surge tunnel. Those flag-sized yards of mesh, after a few months deployment, are supposed to effectively model how a 1,000 foot-long “exclusion net”–deployed seasonally in the river over the next decades, might halt the entrainment deaths of out-migrating adult–and millions of juvenile young-of-the year fish, heading back to the sea. Presumably, Northfield’s mouth would remain wide open to the ecosystem’s fish throughout the rest of the year.

In light of longstanding research the US Fish & Wildlife Service, Atlantic States Marine Fisheries Commission and Connecticut River Atlantic Salmon Commission have set shad passage goals requiring that a minimum of 397,000 pass Turners Falls; and a minimum of 226,000 pass Vernon Dam. It’s a certainty that a new fish lift will be required at Turners Falls under any new license, modeled on the long-term success of Holyoke’s lifts. But the ultimate question is this: can Northfield comply with federal and state law protecting the four-state ecosystem’s fish in order to be granted a new FERC license?

END

Karl Meyer has been a stakeholder and member of the Fish and Aquatics Study Team in the current FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2012. He is a member of the Society of Environmental Journalists.

CAN NEW ENGLAND’S GREAT RIVER SURVIVE MORE DECADES OF PUMPED STORAGE GENERATION?

Posted by on 12 Mar 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Dr. Boyd Kynard, ecosystem, endangerd shortnose sturgeon, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Montague Reporter, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, shad, shortnose sturgeon, Society of Environmental Journalists, Turners Falls, Turners Falls dam, Vermont Digger, vtdigger.org, WBUR

NOTE: The following piece first appeared on the website of vtdigger.org in late February. It also appeared in print in the Montague Reporter, montaguereporter.org in early March.

Copyright © 2017 by Karl Meyer

Can New England’s Great River survive more decades of pumped storage generation? Long-term FERC licensing could lock out new river-sparing energy storage choices.

Dr. Boyd Kynard, retired federal expert on the Connecticut River’s migratory fish and endangered shortnose sturgeon, tells a story about bass fishing in Massachusetts around 1990. He was drifting near the French King Bridge, a mile downstream of the Northfield Mountain Pumped Storage Station’s subsurface tunnels when he glanced up and realized his boat had switched directions. It was being pulled upstream, “And at a pretty good clip.” Turbines at that Northfield MA plant had sucked New England’s river into reverse for at least a mile. This was nothing new, save that in this instance there was a daytime witness.

October 2, 2010, EPA ordered dredging at the site of Northfield Mountain Pumped Storage Station’s underground suction tunnels on the Connecticut.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

In December a radio feature from Boson’s WBUR entitled “New England’s Largest Battery is Hidden Inside a Mass. Mountain” was rebroadcast widely in the Northeast. Referencing Ben Franklin, James Bond, even the Bat Cave, it painted a rosy future for the 1200 quick-start megawatts stored in a reservoir at the Northfield Mountain Pumped Storage Station. Roaring turbines were noted as company spokespeople staked claim to the plant’s “green” future as they bid to lock-in a new 50 year Federal Energy Regulatory Commission license. The occasional ring of an old phone connected directly to ISO New England–the grid’s “independent system operator,” was described as “the sound of money.”

Altogether missing in that story was NMPS’s violent mining of the Connecticut River. That ecosystem artery was never identified as the sole water source enabling it to regenerate electricity. Prior to Northfield construction the Connecticut had forever run seaward from the Canadian border to the tidal zone near today’s Hartford, CT. But 12,000 years of New England natural history changed in 1972, on the day NMPS came on line.

On January 22, 1974, two years after it began operation using overproduced nuclear megawatts then available on the grid at night to fill a 5 billion gallon reservoir, the Federal Power Commission (today’s FERC) notified Western Massachusetts Electric Company it required their “earliest response” on Northfield’s impacts for a Draft Environmental Impact Statement: “Since the Northfield Mountain Project became operational, which of the conditions described have been observed to produce reverse flows?” WMECO’s lawyers belatedly replied on October 16, 1974, they didn’t have the information. Questions about environmental impacts and reversing rivers went unanswered.

In 1967 a federal Connecticut River migratory fisheries program to restore American shad to historic upstream reaches in Vermont and New Hampshire got underway. That same year the embattled Connecticut River shortnose sturgeon was listed under the Endangered Species Act. Exactly fifty years later recovery goals for hundreds of thousands of spawning shad and thousands of shortnose sturgeon remain utterly unfulfilled. Spawning habitat access for both are impacted by Northfield’s suck and surge flows, which also create daily bank-eroding 4-foot “tides” along this reach, sometimes reaching to 10 feet.

Pictured in a less glowing light, NMPS is a 45 year-old dinosaur–a formerly nuclear-powered, net-loss energy transfer machine hacked out of the bowels of a mountain. With the region’s nukes now shuttered, it runs daily on imported electricity and has never produced a watt of virgin power. Today it’s a quick-start, high-profit operation relying on boatloads of fossil-fueled megawatts purchased in bulk on the wholesale market. Suctioning the river uphill, it later releases those waters down through its turbines in dense pulses—pumping out 25 percent less juice than the virgin power it consumes.

NMPS is not renewable energy, nor anything resembling the public’s idea of hydropower. It reproduces just a fraction of New England’s power at peak times, and peak prices, but can only generate for eight hours maximum. After that it is literally dead, its reserves spent. The Canadian-owned plant must then start consuming juice by reversing its turbines anew, yanking the river backward, sideways, and a mile uphill for hours into its reservoir.

That pumping occurs nightly at rates of up to 15,000 cubic feet per second. Picture 15,000 milk crates filled with a living river–every second for hours at a time. For more than two-thirds of the year the Connecticut’s “natural routed flow”—the water moving into and through this reach, is less than 15,000 cfs. Thus this plant is consuming more water than is entering the river. That’s how to turn an ecosystem on its head. The result is the evisceration of all manner of aquatic life, juiced twice through those turbines—tens of thousands of resident and migrating fish, millions of developing eggs, and their young. There’s nothing more violent you can do to a river.

Now the Canada Public Pension Investment Fund—latest in the decade’s revolving door of four different venture-capital owners of the FirstLight Power Resources-branded plant, is angling to lock those ecosystem assaults in place for another half century through the Federal Energy Regulatory Commission’s 5-year hydro relicensing process.

In its planning stages one model would’ve required Northfield to shut down during fish migration season due to impacts. That didn’t happen. Still, a chance experiment in 2010 gave a belated glimpse of those potential benefits. For half a year, from mid-spring through a hot summer into early November, NMPS sat broken, sanctioned and off-line. But seven miles downstream the migrating shad normally impacted by its violent suck-and-flush flows made great and unexpected gains in tandem with that spring break. Having languished for decades, the federal program to move American shad upstream into Vermont and New Hampshire saw a stunning boost at Turners Falls Dam. Shad passage jumped over 700 percent above the previous ten year average–16,440 shad swam past the dam in 2010, compared to the 2,260 annually over the previous ten years. Though meager, it was by far the best result since MA energy deregulation came to the NMPS reach of river in 1999.

The 5 billion gallon Northfield Mountain Pumped Storage Reservoir, as it sat emptied and idle from May 1st through early November 2010.
(CLICK TO ENLARGE, THEN CLICK AGAIN.)

On that May 1, 2010, NMPS had choked on the tons of silt and eroded riverbanks it constantly sucks into its reservoir. In attempting to clear that mucked-in lake a mile of mud-slumped tunnels resulted. Desperate, they began dumping it directly into the Connecticut at a rate equaling 30-40 dump truck loads a day. FirstLight’s sludge turned a mile of river brown for weeks. A contractor died when a suction hose broke loose.

One of thousands of dump truck loads of sludge the EPA ordered FirstLight to dredge back out of the Connecticut River. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Severe thunderstorms on May 27, 2010 resulted in tens of thousands of western New England power outages, many lasting for days. Yet as a back-up energy plant, Northfield’s sole output that week was more of the 45,000 cubic square yards of muck they’d eventually dump directly into the river. They succeeded for over 90 days, until they got caught. On August 10, 2010, the EPA issued a cease-and-desist order citing FirstLight for “polluting the navigable waters of the United States” under the Clean Water Act.

Major dredging operations continued for months at Northfield where FirstLight had dumped their sludge in the Connecticut for 90 straight days.(CLICK TO ENLARGE, THEN CLICK AGAIN.)

Throughout NMPS’s half-year off-line–and record-breaking summer heat in the Northeast, the purportedly ever-hungry, ever-fragile grid ISO New England claims makes Northfield’s dense, quick-start functions so indispensible, never faltered or failed—not even when the nearby( now closed) Vermont Yankee nuclear plant went down in June to refuel.

NMPS’s main claim to its indispensability came 14 years ago during the 2003 August Blackout. Its quick start power was employed by ISO New England to smooth out Massachusetts’ reconnection to the New York sector of the Northeast’s mega-grid—which had failed due to a computer glitch in Ohio. That sprawling network would have been reenergized regardless, but Northfield’s dense energy provided a convenient assist and made ISO’s job easier. But are rare-hour emergencies enough to justify more decades of NMPS daily destructive use? In truth–what would amount to virtual energy storage monopoly, need not be locked-in, de facto, by FERC as this region’s energy future for decades to come. There are other options.

“Pumped hydro is the most cost-effective way to store electricity,” that story stated flatly. But in September of 2016 the MA Department of Energy Resources and the MA Clean Energy Center released a study: “Massachusetts Energy Storage Initiative: State of Charge.” It noted the Bay State lags behind in innovation and deployed energy storage, ranking 23rd nationally. However, comparing new storage technologies now available to the costs of pumped storage, it noted three that will all readily out-compete pumped storage costs by 2018: Lithium Ion, Flow Battery and Compressed Air Storage.

These local/regional storage solutions are already coming into use in New England. They create distributed generation and safer, more reliable micro-grids—less vulnerable to mass outages and mega-grid cyber attack and failure. They also create jobs. Certainly they are more attractive to consumers than sending local solar and wind across New England to recharge a river-crippling machine—and repurchase that juice later at inflated consumer prices.

That story mentioned Northfield’s 18,000 panel solar array–enough for a few hundred homes. But that tax-deductable FirstLight solar field actually covers the huge scar leftover from acres of EPA-mandated settling ponds—sludge pools required in 2010 when they had to dredge their mountain of muck back out of the river. Also not mentioned were handsome payments NMPS collects when it chooses not to generate any power. They accrue through a FERC mechanism known as “capacity fees.” If “spot market” prices aren’t sweet enough, FirstLight can simply sit their plant idle, collecting ratepayer cash just for their “capacity” to potentially generate. With NMPS as its chief hydro asset, former owner GDF-Suez once told investors 40% of its annual profits had been realized through capacity fees.

FirstLight’s EPA-ordered sludge settling pools and drying pile at the Rt. 63 site covered by a solar panel installation today. (CLICK TO ENLARGE, THEN CLICK AGAIN.)

Gus Bakas, FirstLight’s Massachusetts operations director, stated his goal for the 45 year-old plant is to someday see it running wholly on “green” power–solar and wind relayed to it from legions of regional rooftop panels and turbines. That would align with Massachusetts’ new “Energy Storage Initiative,” a 10-year effort purportedly aimed at saving ratepayers “hundreds of millions of dollars” while making the grid more reliable and reducing greenhouse gasses. But wind runs strongest at night and is not plentiful in western New England, while all solar is generated by day. With NMPS’s peak-demand profit model based on sucking up bulk power and the river at night, something seems missing from the equation. Unless there are now plans to again run the river backward by day, when migrating fish are most vulnerable to entrainment.

The Federal Energy Regulatory Commission is charged with supplying reliable electricity at fair costs to the public, while fostering competition and protecting against energy monopolies. All licensing decisions from FERC must also comply with federal law including conditions set under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act. The operation of NMPS continues to prove a stumbling block to the successful execution of these federal acts and policies.

In the near-term, for rare big-grid emergencies, a summer heat-wave or winter cold snap, NMPS remains a credible back-up tool. But Northfield otherwise continues today as an expensive, profoundly-damaging energy relay device whose net-loss operations chew apart a critical four-state artery daily. Given its violent year-round ecosystem impacts, its drag on federal trust and endangered species restoration programs–and the market’s current and emerging alternative energy storage solutions, FERC should not sanction NMPS long-term, as its dominant, de facto, New England energy storage monopoly.

End

Writer and journalist Karl Meyer lives in Greenfield, MA. He has been participating as a stakeholder and member of the Fish and Aquatics Study Team in the five-year FERC relicensing process for the Northfield Mountain and Turners Falls projects since 2013. He is a member of the Society of Environmental Journalists.

Karl Meyer: Connecticut River power storage plant is an ecological, economic and energy disaster

http://www.wbur.org/bostonomix/2016/12/02/northfield-mountain-hydroelectric-station

Rolling over on a River: the real cost of pumped storage energy

Posted by on 26 Oct 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River ecosystem, Connecticut River Watershed Council, Daily Hampshire Gazette, ecosystem, Entrainment, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeion, federally-endangered shortnose sturgeon, FERC, fossil fuels, Greenfield Recorder, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Reservoir, nuclear power, Public Comment period, public trust, pumped storage, Relicensing, shad, shortnose sturgeon, Society of Environmental Journalists, The Recorder, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Vermont Digger, Vermont Yankee

Copyright © 2016 by Karl Meyer

(Note: this essay appeared in September and October in these MA and VT media and newspaper outlets: Vermont Digger, www.vtdigger.org ; The Daily Hampshire Gazette; and The Recorder.)

besttfemptybed

The de-watered CT below Turners Falls Dam that few people see. (Click, then click again to enlarge.)

Rolling over on a river

Since time began rivers have been the Earth’s arteries—the foundation of its ecosystems. Here in New England it’s “last chance” time for our Great River. On April 30, 2018 the fate of the long-foundered Connecticut River migratory fisheries restoration—and the survival of a four-state river ecosystem, will be decided for what’s essentially forever. New Federal Energy Regulatory Commission hydro licenses are expected to be signed then by government agencies and the Canada Pension Plan Investment Board–latest purchaser of the Turners Falls and Northfield Mountain projects. That company’s stated investor mandate is “to maximize investment returns without undue risk of loss.”

Over two generations ago public-trust mistakes were made favoring power companies, fish hatcheries, and high-end salmon-fishing interests that rendered eight miles of the Connecticut in Massachusetts a massively-suctioned, partially-dewatered flush sink. Sanctioned by fisheries agencies and non-profits, those decisions, severed an ecosystem in two. They forced all migrating fish into a deadly power canal, leaving three emptied miles of riverbed below Turners Falls Dam, while four turbines at the Northfield Mountain Pumped Storage Station five miles upstream consumed massive amounts of nuclear energy to suck a river backward and uphill to a mountaintop reservoir.

Those turbines were built to run on the promised endless supply of overproduced juice generated nightly at the local, now-closed, Vermont Yankee nuke, 15 miles away. Today, running on giant slugs of imported fossil fuel, they continue to spin, sucking the river up in endless gulps into a 4 billion gallon pool a mile up Northfield Mountain. That daily suctioning creates riverbank eroding “tides” higher than those at Hyannisport, MA—with some rivaling the ten-foot fluctuations of Fundy Bay.

Back then, predecessors of today’s National Marine Fisheries Service, the US Fish & Wildlife Service, Massachusetts’ Fish & Wildlife and the Connecticut River Watershed Council signed off on an agreement with the Federal Power Commission and Western Massachusetts Electric that strangled the river in northern Massachusetts. It resulted in the failure of migratory fish passage and a promised renewal of the river’s ancient seafood resources upstream to Vermont, New Hampshire, and northern Mass. Few American shad emerged alive after diversion into that canal. It also failed the shortnose sturgeon—this river’s only federally endangered migratory fish, leaving it without flow or monitoring at its only documented natural spawning site.

Upstream at Northfield the destruction was yet more complete. The suck and gush appetite of that nuclear-charged contraption virtually disassembled the river. It gulped flow at a rate of 15,000 cubic feet per second, often for hours at a time—drawing on the river pool above Turners Falls Dam where, 70% of the time, the Connecticut’s natural routed flow is less than 15,000 cfs. Boaters a mile downstream could find themselves drifting upriver via Northfield’s unearthly pull. All fish and organisms drawn up through the sphere of that suction were deemed “functionally extirpated”–dead to the ecosystem by virtue of being sieved twice through the turbines. It was evolution in reverse, a river ripped away from its eternal run to the sea.

Today, climate-blind FERC labels Northfield as a source of “renewable clean” energy—but there’s nothing clean, renewable or sustainable about its imported, twice-produced, peak-priced electricity crippling this river. ISO New England, FERC’s Northfield-cheering, ever-energy-hungry cousin, also ignores climate and its environmental dismemberment. “Pumped storage” is not hydropower—not even by the industry’s own technical terminology. Northfield-produced power in fact represents the heavy planetary burden of fossil fuel used to push a mountain of water uphill, merely as a weight to produce high-cost, second hand electricity. It cares nothing of rivers, fish or ecosystems.

If bureaucrats again fail the public trust and don’t demand critical habitat protections, flows, and the day-to-day monitoring needed to fulfill U.S. environmental statutes, Canadian pension speculators will be left as the de facto controlling interests on our river. The new owners have asked FERC to merge two separate licenses for Northfield and Turners Falls into a single new license dubbed the “Northfield Project.” What’s represented as mere bureaucratic streamlining would actually enshrine, by precedent–next time and forever, river-killing pumped storage.

Any responsible environmental agency should deny this single-license merger, and seek to have Northfield kept in use as emergency infrastructure only—with the ultimate remedy it’s dismantling in tandem with a move to a decentralized, far less vulnerable system than today’s expanding mega-grid. Massachusetts legislators are currently signing onto backroom energy deals for a glut of future hydropower from Quebec. Some 1,200 megawatts of those penciled-in imports could easily replace the few hours of daily juice Northfield puts out–while keeping it available for rare emergencies. Though the new Canadian power imports largely ignore conservation and innovation, they could be employed to end the river carnage here and begin restoring a future for a critical New England ecosystem.

(Note: timely public comment on licensing issues is carefully considered by FERC. Go to: http://ferc.gov/docs-filing/ecomment.asp and use “E-Comment.” Check “Hydro” and address to Secretary Kimberly D. Bose, using the required identifiers “P-2485” and “P-1889” for Northfield and Turners Falls.)

Karl Meyer lives in Greenfield MA. He is participating in the FERC relicensing process and is a member of the Society of Environmental Journalists.

FISHY MISSING INFO

Posted by on 22 Jun 2016 | Tagged as: blueback herring, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Daily Hampshire Gazette, FirstLight, fish counts, Fish passage results, GDF-Suez FirstLight, Greenfield Recorder, MA Division of Fish and Wildlife, migratory delay, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Northfield Mountain Pumped Storage Station, public trust, right-to-know, salmon, salmon hatchery, sea lamprey, shad, The Recorder, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, USFWS, Vermont, Vernon Dam Fishway

The following OpEd appeared in the Daily Hampshire Gazette (Northampton,MA) and The Recorder (Greenfield, MA) in early June.

Fishy Missing Info Copyright © 2016 by Karl Meyer

DSCF8552
(low flows and byzantine fish ladder at Turners Falls 6/19/16:CLICK TO ENLARGE)

I’d like to change the name of a Commonwealth agency. What would you think about the Massachusetts Division of “Manufactured” Fisheries and Wildlife? I think it would offer a much better picture of the Agency’s focus, particularly here in the Connecticut Valley. Here you can get daily on-line information on where to find truckloads of thousands-upon-thousands of factory-produced rainbow, brown and brook trout before they are dumped into local rivers for hatchery-fish angling pleasure. But I dare you to find anything more than a several-weeks-old tally of the numbers of wild migratory fish streaming north here on the Connecticut anywhere beyond the fish windows at Holyoke Dam. So this would be a “truth-in-labeling” adjustment.

New England’s Great River runs for 69 miles through the Commonwealth. The MA Division of Fisheries & Wildlife is responsible for all migratory fish in that broad reach from the time they enter at Agawam, until they either remain here for spawning, or pass into Vermont and New Hampshire. Those runs are the agency’s “public trust”—to be protected for its citizens, anglers, students and future generations. But the less information the public gets on their whereabouts, the less an agency might be availed upon to actually protect them.

As we enter the final weeks of migration season the only information provided—not just days old, but nearly a month stale, refers solely to fish on the first 16 miles of river from the Connecticut border to the fish lift at Holyoke Dam. That leaves a full 52 miles of river with just a single—now uselessly outdated May 4th report about the truly wild shad, lamprey and herring now moving along New England’s flagship waterway. Salmon are not mentioned here because just three years after the US Fish & Wildlife Service stopped factory production of this hybrid, just a single salmon has been tallied. Hatchery fish production masks the reality of failing wild populations and deteriorating habitats. To date there’s been but one report on fish passage from Turners Falls.

As an interested citizen I’m a bit outraged that it’s June 1st, and I don’t have a clue about what’s going on with the wild, migrating fish coming upriver in what you have to consider as one of New England’s last remaining great migrations. Shad, blueback herring, and sea lamprey have been moving upstream for over two months now, and the only public information offered is of the absurd 54 shad counted at Turners Falls, almost a full month back. Really? This is any agency with an accountability problem.

MA DF&W has scant little to offer the public as to what they’ve been doing on the ground to protect our wild fish runs—and that includes struggling populations of state-listed, endangered shortnose sturgeon, also under their purview. But to not even take responsibility for having on-the-ground personnel monitoring runs at the river’s long-known choke point, Turners Falls, is a flagrant abdication of duty. Here in central and northern Massachusetts we not only don’t see fish because of decimated Connecticut River habitats, we aren’t even offered updated tallies on the ugly mess. But perhaps that’s by design. Connecticut’s state fisheries agency regularly provides more information on Commonwealth fish runs than does the MA DF&W.

When I recently contacted the Commonwealth’s Anadromous Fish Project Leader to inquire about fish passage information at Turners Falls, he tersely emailed back that the state no longer does those fish counts: I should contact FirstLight Power for information. I guess our fish are now fully privatized. And when it has come to the power company requesting larger and more frequent water withdrawals on the Connecticut upstream at the Northfield Mountain Pumped Storage Station, it appears the Division has never seen a company proposal it wasn’t just fine with.

This 2016 season has literally been the worst year for Massachusetts fish passage information since 2010, when FirstLight’s Northfield Mountain broke down, fouling its pumping tunnels with 45,000 cubic square yards of reservoir muck. They didn’t operate from May – November and fish passage at Turners Falls–it was subsequently revealed, had jumped 600-800% above yearly averages. We didn’t get that information until late as well. Seem a little fishy to you?

Some of us actually care about wild fish and living rivers. And, frankly, if I were reduced to thinking that following a truckload of factory fish to its dumping site for a day’s angling was a wildlife experience—well, I’d just as soon get one of those wind-up fish carousels you can hold–the ones with the tiny plastic pole and the revolving, yapping fish mouths. The Massachusetts Division of “Manufactured” Fish & Wildlife–sounds about right where wild fish and the Connecticut River is concerned.

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

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

Double Standard on the Connecticut

Posted by on 09 Jul 2013 | Tagged as: American shad, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, ecosystem, EPA, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC license, FirstLight, GDF-Suez FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain Pumped Storage Reservoir, Riverkeeper, Rutland Herald, shortnose sturgeon, Times Argus, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Rutland Herald and the Barre-Montpelier Times-Argus during the first week of July.

Copyright © 2013, by Karl Meyer

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

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


                               A River Double Standard

On June 28, 2013, Federal Energy Regulatory Commission Director of Energy Projects Jeff C. Wright ruled against the US Fish & Wildlife Service as it sought two extra weeks to review hundreds of pages of just-released Proposed Study Plans for the relicensing of five Connecticut River hydro projects. “The request for a 15-day EOT to file comments on the licensee’s proposed study plans is denied.”  EOT is FERC-speak for “extension of time.”  Those studies will impact this four-state river for the next 20-40 years. Agencies joining that request included the National Marine Fisheries Service, MA Div. of Fish & Wildlife, The Connecticut River Watershed Council, The Nature Conservancy, Trout Unlimited, the Franklin Regional Council of Governments, NH Dept. of Environmental Service and The Vermont Agency of Natural Resources.

One big reason for that request was the difficulties in evaluating the impacts of FirstLight’s Northfield Mountain/Turners Falls hydro operations on the entire Connecticut River ecosystem.  Beginning last fall, FERC began deviating from its standardized relicensing model when it scheduled public site visits to FirstLight sites weeks before the company released a publicly-required 500-page Pre-Application Document describing its complex pumped storage operations and machinery.

This spring FERC also supported FirstLight’s expedited-request to conduct a series of complicated river flow studies this summer—an allowance falling well outside FERC’s strict licensing timelines.  In doing so they let the company schedule three days of river visits by fed/state agencies smack in the middle of their deadline to comment on FirstLight’s 434-page Updated Proposed Study Plan.  FirstLight released that document June 28th; comments to FERC are due July 15, 2013.  Even after nine meetings with the power company and FERC, many agency representatives continued to decry the lack of critical scientific detail provided in FirstLight documents.  Those were put together by its team of five consulting firms.  Ironically, those handpicked FirstLight firms will conduct the next two years of river studies—the ones meant to protect the river.  A fox and chicken coop analogy applies.

FERC is employing a legal double standard here on the Connecticut.  If you a public agency or citizen seeking protections for the ecosystem—well, even little rules are THE RULES.  At the same time it appears corporations can continuously and sometimes massively ignore federal license requirements with impunity.

In FERC’s own words, the Commission “enforces the conditions of each license for the duration of its term, and conducts project safety and environmental inspections.”  Yet today Holyoke Gas & Electric is half a decade–and counting, in violation of its 2002 agreement to construct facilities to end the evisceration of federally endangered shortnose sturgeon and other “federal trust” fish migrating downstream at their Holyoke Dam facility.  So, why have a license at all? 

Upstream in 2010 GDF-Suez FirstLight dumped some of 45,000 cubic square yards of reservoir sludge directly into the Connecticut at Northfield Mountain over a 90-day period—the equivalent of 40 dump truck loads of muck per day, smack in the middle of fish migration season. Yet in current documents FERC states their inspections have never found FirstLight in violation of its license.

The US EPA found FirstLight in violation of the Clean Water Act in August of 2010 and ordered a massive clean-up, though the ecosystem damage was already done.  In an August 4, 2010 letter EPA sanctioned FirstLight for violating “FERC License No. 2485” and polluting the “navigable waters of the United States.”  A subsequent letter dated August 10, 2013 from FERC’s Biological Resources Branch Chief Steve Hocking to FirstLight Manager John Howard specifically referenced the EPA’s sanctions, directing him to “article 20 of your license.”  Yet there is virtually no FERC mention of that egregious violation in current relicensing documents.

That’s the standard that for-profit companies are held to here.  It rivals the Pirate Code.  Currently there is no watchdog entity on this river willing to go to the mat to protect the ecosystem.  If, like on the Hudson, there was an organization like Riverkeeper—which cites “enforcement” as one of its main responsibilities, these egregious injuries to the Connecticut would not likely stand.  Holyoke Gas & Electric would have been in court long ago for killing endangered sturgeon; and the full range of FirstLight’s lethal impacts on the Connecticut’s migratory fish when all are diverted into their turbine-filled power canal would’ve been fully investigated.  FERC’s inaction is a disgrace.

FERC Director Wright requested that questions regarding that EOT denial go to Ken Hogan at: 202-502-8434, or Kenneth.Hogan@ferc.gov. Ken has presided over the CT River relicensing hearings.  Also, you can find FirstLight’s 434-page “Updated Proposed Study Plan” at: www.northfieldrelicensing.com under Documents.  The public has until July 15, 2013 to send comments on that plan to FERC.  You do that at: www.ferc.gov/docs-filing/efiling.asp .  You must cite FirstLight’s project numbers, P-2485 and P-1889, and be sure to note that you are commenting on the “Updated Proposed Study Plan.”

Karl Meyer is a member of the Society of Environmental Journalists. He lives in Greenfield, MA. Read more at: www.karlmeyerwriting.com

Dam Relicensing: Diving into the Dead Reach

Posted by on 28 May 2013 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Dead Reach, federally-endangered shortnose sturgeon, FERC license, FirstLight, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Rock Dam, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab

Watch Diving into the Dead Reach on LOCAL-BIAS: Learn why information about fish mortality in the the deadly Turners Falls Power Canal has been kept from the public these last 14 years.

Tune-in Greenfield Community Television’s (GCTV) Local-Bias Host Drew Hutchison and guest Karl Meyer, and find out what happened when he went snorkeling in this critical segment of the Connecticut–which should be deemed a spawning sanctuary for shortnose sturgeon and migrating American shad.

The program airs Weds. May 29th at 5 pm, and again on Thursday, May 30, at 9 pm; then again on Saturday, June 1, at 9 pm.  The series repeats at those time the f0llowing week.

Go to:  http://www.gctv.org/node/5264

See also: http://www.gctv.org/schedule

March 1st Deadline: Comments to FERC on Northfield/Turners Falls Hydro Relicensing

Posted by on 25 Feb 2013 | Tagged as: American shad, blueback herring, Connecticut River ecosystem, Conte, endangerd shortnose sturgeon, EPA, ESA, federal trust fish, federally-endangered shortnose sturgeon, FirstLight, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, National Marine Fisheries Service, NOAA, Northfield Mountain Pumped Storage Reservoir, Rock Dam, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab

Last Call to send comments and study recommendations to the Federal Energy Regulatory Commission to guide the Connecticut River conditions mandated in the 2018 relicensing of the Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project.  The licenses will the river ecosystem for decades to come.

To file any comments on the relicensing of the Northfield Mountain Pumped Storage Project and the Turners Falls Hydroelectric Project you will need to register at: www.ferc.gov/docs-filing/efiling.asp

You must include the following project numbers for Northfield Mountain Pumped Storage Project and Turners Falls Hydroelectric Project respectively, with any comments: P-2485-063, and P-1889-081.

All comments are due before MARCH 1, 2013.  Be sure to include your full mailing address, phone number, and email address in your comments. (I’ve attached my comments, which are now registered with FERC, below.)

Karl Meyer, M.S. Environmental Science

Greenfield, MA, 01301                                                             February 25, 2013

To: Federal Energy Regulatory Commission

RE: Comments on FERC Relicensing Projects: No. P- 2485-063 (Northfield Mountain Pumped Storage Project) and No. P-1889-081 (Turners Falls Hydroelectric Project)

Dear Commissioners,

Please carefully adhere to the standard FERC relicensing processes and deadlines as you relicense these two projects.  Holding public and agency site visits in early October 2012 may have been deemed convenient for circumventing winter weather that might have affected visits, however it placed invested parties in the difficult position of having to view and judge hydro operations and configurations at both facilities without the benefit of knowing what operational changes and information FirstLight Power Resources was including in its PAD.

Further, of the three FERC group tours at Northfield/Turners Falls, only one group, mine, was able to view the area of the By-Pass Reach and the Turners Falls Canal and head gates from the downstream side of the Turners Falls gate house.  This is a critical area to view, and the excuse being given was that there was construction happening on the Turners Falls Bridge.  However, unrestricted access to view these sites was available to any passing citizen just yards away via a bike and walking path, open to the public.  My group only received access because I made a direct request to FirstLight’s John Howard, who was my former boss.

The two other tour groups did not get to see the confused flows created by the 14 head gates at the upstream end of the Turners Falls Canal.  The canal has been a major disappointment as the upstream conduit for all migratory fish these last 34 years.  Those head gates are open at full bore during much of the upstream fish migration season; they should have been a key component of the tour.  Nor did interested parties get to view the exposed rock bed and de-pauperizing flow regimes created by flood gate manipulations at the Turners Falls Dam that renders the By-Pass Reach a non-river.  FERC should place particular emphasis on any studies that redirect upstream migrating fish away from the confused and failed conditions experienced in the Turners Falls Power Canal, and send them directly upstream to a lift at TF Dam.  That configuration has worked quite effectively at Holyoke Dam these last 58 years.

In late January 2013, GDF-Suez FirstLight Power Resource representatives noted at public hearings that it intends to apply to FERC with a Proposed Study Plan to begin its own investigations of flows in the reach below Turners Falls Dam this April 2013, rather than the 2014 and 2015 study seasons noted in the FERC Relicensing Process.  No study in this critical segment of river known as the By-pass Reach should be undertaken without a full vetting of the proposals.  This section of river is critical spawning habitat for the federally-endangered Connecticut River shortnose sturgeon, also listed as endangered under the Commonwealth of Massachusetts Natural Heritage and Endangered Species Act.  It is also the age-old upstream route for spawning federal-trust American shad and blueback herring.  It is noteworthy that in their expedited study application that FirstLight cites the area below Cabot Station as a key shortnose sturgeon spawning location, while the critical site for these fish—used for likely thousands of years, is the natural escarpment in the riverbed known as Rock Dam, a half mile upstream of Cabot Station.

In a letter from FERC to Mr. John Howard of FirstLight Power Resources dated March 12, 2010, the Commission noted that FirstLight had failed to comply with Article 34 of the license for the Turners Falls Project, releasing just 120 cubic feet per second to this segment of the river to protect shortnose sturgeon from the effects of low flows.  The minimum requirement is 125 CFS.

With respect to measured, in-depth, long-term investigations on flow and river regulation in this reach I would direct you to the 17 years of research done by Dr. Boyd Kynard and colleagues at the Conte Anadromous Fish Research Center adjacent to this river segment in Turners Falls, MA.  The work was largely conducted via the federal Conte Lab under the US Fish & Wildlife Service and later, under the US Geological Survey, when it took over responsibilities for Conte Lab after 1999.  These investigations were also supplemented by funds, research and personnel from the University of Massachusetts at Amherst.

This research is documented in: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society and produced by Books on Demand, GmbH, Norderstedt, Germany: ISBN 978-3-8448-2801-6.  Copies can be obtained from the North American Sturgeon and Paddlefish Society:

www.nasps-sturgeon.org/#!publications  Chapter 3 concerns the long-term study of flows and river regulation on spawning success of the last 300, spawning-capable, federally endangered shortnose sturgeon in this river system—covering the period of 1993 – 2005.  This is critical, long-term research that includes seven years of findings from the time before Northfield Mountain Pumped Storage and Turners Falls Hydroelectric Project operated as a regulated utility, and the seven years when Northfield’s pumping was unconstrained by regulations and operated to profit from price spikes and drops in the energy spot market using the public’s river.  Deregulation was fully implemented here in 2000 or thereabouts.  All of these issues need careful consideration before sanctioning a rushed study plan in such a critical river reach.

When considering a new license for these facilities, careful consideration of the public’s interest should be made respecting the changes and power generation, flows, and operational practices from the commencement of the current licenses down to the present.  In 2012, Northfield Mountain Station added 40 megawatts of power to its generating facilities through retooling two of its turbines.  This increase nearly equals the total power generated at HG&E’s Holyoke Dam, the next downstream project licensed by FERC.  Two remaining turbines await power up-rates, which is a considerable addition to the generation at this plant, originally proposed and installed at 1,000 megawatts.  Currently, due to mid-license changes, it now produces 1,119 megawatts of power in an unregulated power market. noteworthy and important to be considered in weighing the public’s right to a living ecosystem, upstream fish passage, and protection of endangered species, is that Northfield Mountain’s original license was for a plant used to create “peaking power, and as a reserve unit.”  It can only produce 6-8 hours of stored power before it is spent and needs to purchase replacement power on the open market.  Its stated intention was to peak twice daily in high-demand winter and summer months, and once a day during shoulder months in spring and fall when energy demand is low.  Northfield now generates when demand is present, or—when energy prices will make the greatest profit for investors.  The river and the states have been impoverished by this profound change.

The building of Northfield was based on the availability of current and proposed power from collected regional nuclear sources (New England Power Pool) that included Maine Yankee (closed 1997); Yankee Rowe (closed 1992) Connecticut Yankee’s Haddam Neck (closed 1994), as well as two proposed nuclear plants at Montague, MA (never built.)  Vermont Yankee is currently the only “local” nuclear plant still operating, and its 40 year operating license expired March 21, 2012.  Its continued operation is contingent on findings in the courts.  It is currently operated at a loss by Entergy, and has a failing condenser system which could force its closure.  In short, Northfield is now operated well beyond the bounds of its originally stated purpose.  The public’s river is paying a high price for power, much of it now imported to pump river reserves uphill to Northfield’s reservoir from sources outside the region.  The ecological impacts to fish runs and the damaging flow regimes imperiling endangered species in the river are apparent.

As a facility with great ecological impacts that cannot produce any of its own power–one totally dependent on outside sources for power, one proposal for using this stored power source put before the Federal Power Commission in the 1960s was that Northfield not operate during the spring fish migration due to its impacts on the runs.  It is time to revisit the option of silencing the effects of Northfield Mountain so that towns and cities including Greenfield, Montague, Gill, Turners Falls, and Northfield, MA; and all the towns north to Vernon, Brattleboro and Bellows Falls, VT, and Hinsdale and Walpole, NH receive their share of the river’s ecological bounty.

Northfield does serve a function as an emergency “reserve unit” for ISO New England (Independent Systems Operator) during times of severe heat waves, or high winter demand, to deliver a high volume of power on short notice to accommodate spikes in the power grid.  Northfield could be taken off-line and kept in reserve to be operated by ISO New England solely for that purpose during the low-demand spring energy months when fish are migrating.  This would greatly benefit river ecology, species, and all upstream stakeholders.  New England’s power grid resources are currently rated at 15% above demand.  Removing the damaging effects of these operations on river ecology during critical months is a simple, equitable solution.

Northfield and Turners Falls have greatly profited by incremental power increases and operational changes over the past 34 years, while the public has watched flows, regulation, and conditions in the By-pass Reach wither to a brutal, feast-or-famine regime that denies spawning for endangered fish, and passage for upstream migrants.  This situation has effectively privatized the 2-1/2 miles of river, depriving my town, Greenfield, as well as Gill, of its share of fish and a river.  This de-pauperization has impacted all the towns upstream of Cabot Station and Turners Falls dam into central Vermont and New Hampshire.  None of these municipalities have received compensation, though in many states the loss and damage to these fish populations would be considered “take” under state statutes.  Damage in the By-Pass Reach to the Connecticut River’s last 300, spawning-capable Connecticut River shortnose sturgeon carries a significant federal fine, as well as possible imprisonment.

FirstLight’s new requests for more generation at both licensed sites should be rejected, and the damaging mid-license flow and power increases should be reversed in any new license.  Indeed, since there have now been no less than FIVE different owner/operators of this facility in the last 14 years, it would be prudent to grant only the shortest license possible in order to help track and minimize damage to the ecosystem due to operational/managerial changes, and protect the public’s interest in a living river.

Northfield’s impacts have never been fully measured with respect to flows in the By-pass Reach, but it is clear that fish passage is now at, or below, the paltry levels of the 1980s, and just a fraction of the 40 – 60% passage upstream long-targeted by the US Fish & Wildlife Service of fish that had been passed at the Holyoke Fish Lift.  Regulated, continuously monitored flows should be returned to the By-pass Reach at this time, and continuous monitoring should be included in any new licenses issued.  FirstLight has noted that in-stream data loggers for river levels and flow have been subject to vandalism.  Continuous camera monitoring of river levels and open and closed gate positions at the Turners Falls Dam would go a long way toward insuring compliance with any new license conditions.  This is an inexpensive solution that could easily include a back-up system.

With a federally endangered species present in the By-pass Reach, as well as federal-trust migrating American shad and blueback herring, FERC would do well to consider enforcing regulated flows in this stretch in accordance with law and statutes in the current license.  NOAA’s National Marine Fisheries Service has had the USGS Conte Lab findings from studies in the By-Pass reach by Kynard et al, in their possession since 2007.  This agency—as well as the MA Division of Fisheries and Wildlife, could intervene at any time.  These impacts are also affecting the success of the federal/state Connecticut River Migratory Fisheries Restoration, begun in 1967, which stipulates that all the states share equally in the bounty of migratory fish—as both a recreational and seafood resource.  In several studies by the Massachusetts Cooperative Fisheries Unit at UMass/Amherst from the 1980s it is noted that blueback herring, (Alosa aestivalis) were noted gathering at the base of Turners Falls Dam, and were also noted spawning in the mouth of the Fall River–just 300 feet downstream of the dam, by then Conte Lab Director Steve Rideout.

Further, in the late 1980s, in another mid-license power up-rate, up to 5,000 CFS was redirected out of the By-pass Reach and into the Turners Falls Power Canal for use by Cabot Station and a refurbished Unit # 1, some 1-1/2 miles upstream of Cabot.  This was undoubtedly another blow to the shortnose sturgeon attempting to spawn at their ancient grounds at the Rock Dam, though sturgeon spawning in the Connecticut here was not confirmed until 1993.

In the PAD, it is noted that FERC had not found any compliance issues during its inspections of these two projects.  However, as well as a failure to release minimum flows for sturgeon in 2009, I would direct you the US Environmental Protection Agency’s August 3, 2010 letter and Administrative Order Docket No. 10-016, sent to Mr. James Ginnetti, FirstLight Vice President, noting violations of the federal Clean Water Act.  FirstLight knowingly dumped up to 45,000 cubic square yards of silt into the Connecticut River below its fouled pumped storage plant in an attempt to clear its tunnels and intake.  This illegal enterprise was undertaken by FirstLight after failing to conduct silt removal in a manner consistent with the “due diligence” stated in its operating license.  This dumping took place throughout upstream fish migration season, May 1, 2010, or thereabouts, and continued until the EPA Cease and Desist Order of August 2010.  At that time, FERC then became involved in this egregious license violation, requesting a full report from Mr. John Howard, Plant Manager, in a FERC letter dated August 10, 2010.

In a subsequent fall meeting with agency and non-profit river interests, a FirstLight representative stated that they did not know how to remove silt from their upper reservoir, and that it had never been done successfully.  That admission came after 40 years of operating their plant.  Hence, the public, and FERC are being asked to grant a new license to operators who have not shown they can successfully maintain their facility without profoundly affecting a navigable four-state waterway and a migratory fish highway.  FirstLight has now asked for deadline relief, and is promising to have a study of siltation completed in 2014.  Perhaps all study decisions should be held in abeyance until that time, 2014—which would comply with FERC Licensing Guidelines.

 

Sincerely,

Karl Meyer

Greenfield, MA

The Last, BEST Hope for the CT River: GET INVOLVED!

Posted by on 06 Nov 2012 | Tagged as: Connecticut River, Connecticut River Atlantic Salmon Commission, Connecticut River ecosystem, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, National Marine Fisheries Service, Northfield Mountain Pumped Storage Reservoir, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, US Geological Service’s Silvio O. Conte Anadromous Fish Lab, US Geological Survey, USFWS

The Federal Energy Regulatory Commission re-licensing process for GFD_Suez FirstLight Power’s Northfield Mountain and Turners Falls Power Canal Projects on the CT River officially began with FirstLight’s Notice of Intent to file for two new operating licenses to use our river to make electricity for the next four decades.  Over the next four months–until the end of February 2013, officials from the US Fish & Wildlife Service, National Marine Fisheries Service, and directors of fish & wildlife programs will be meeting to decide the critical studies needed to restore and safeguard the Connecticut River through the year 2058.

FirstLight is anxious to see that the main studies guiding the “restoration” of migratory fish is based on moving migratory fish upstream through their power canal, NOT upstream through the ACTUAL Connecticut River, sitting directly adjacent to their canal.  The Power Canal route has proven a disaster, patently deadly for any river restoration.  After 32 years, and study after study, “improvements” enable ONE fish in TEN, to emerge alive, upstream of the Turners Falls Power Canal passage.  It is a death sentence for any true restoration of the river.

To learn more, tune into a broadcast of Greenfield Community Television’s LOCAL BIAS, with host Drew Hutchinson.  In the program I attempt to explain how complexity is clouding the thinking and priorities of our wildlife officials, and h0w simply requiring the Connecticut River to be allowed to flow through its own bed at critical times is the key to having a working ecosystem for the next three generations to come.

Here’s how you can tune in:

Episode (# 127) will be cablecast Wednesday 5:30pm, and Thursday and Saturday 9pm starting November 7th for two weeks. It will also be available via video on demand at gctv.org sometime next week.

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