Northfield Mountain

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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.

CONNECTICUT RIVER pumped storage: assault and battery on an ecosystem at a tipping point

Posted by on 19 Apr 2018 | Tagged as: 5-year FERC licensing process, CommonWealth Magazine, Connecticut River, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, Drew Huthchison, Federal Energy Regulatory Commission Chairman, federally-endangered Connecticut River shortnose sturgeion, FERC, FirstLight, Local Bias, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, pumped storage, Turners Falls, Turners Falls power canal, US Fish & Wildlife Service, wildlife refuge

Connecticut River Pumped Storage: assault and battery on an ecosystem at a tipping point

Copyright © 2018 by Karl Meyer. All rights reserved.

Downstream end of the starved and brutalized 10 mile reach of the Connecticut, looking upstream from just above the Deerfield River confluence. (Click, then click again to enlarge).

The following links offer the most up-to-date understanding of current and future conditions in the most embattled, crippled reach of the entire Connecticut River. It consists of the Massachusetts river corridor from Greenfield/Turners Falls above the Connecticut’s confluence with the Deerfield, to some 10 miles further upstream to beyond the immediate and deadly impacts of the Northfield Mountain Pumped Storage Station.

Most stakeholders in the ongoing 5-year (now into it’s 6th year) FERC licensing process for the Northfield Mountain Pumped Storage and Turners Falls hydro projects have signed confidentiality agreements with FirstLight. Though relicensing studies on the impacts of these facilities on fish and aquatic life will continue through this fall, signed-on stakeholders have now been participating in closed-door settlement discussions out of the public eye with FirstLight for nearly a year. Any negotiated–or FERC-mandated, river conditions under a new license will be permanently in place for decades on this key US ecosystem that is part and parcel of the watershed-wide Silvio O. Conte National Fish and Wildlife Refuge. They must comply with federal and state environmental law. FirstLight is a MA-registered, Canadian-owned subsidiary of PSP Investments–a 100% Canadian Crown-owned corporation.

Thus, the National Marine Fisheries Service, US Fish and Wildlife Service, MA Division of Fisheries & Wildlife, and state agency representatives from four New England states are charged with ensuring the Connecticut River ecosystem gets the long-awaited critical environmental protections for its US public trust fish and efforts to restore both the federally-endangered Connecticut River shortnose sturgeon, and the foundered half-century old mandate to bring migratory fish back to Vermont and New Hampshire–as both abundant resources for sport fishing, and seafood. That is their actual federal mandate, in place since 1967.

Given the embargo on public information in these closed-door settlement talks, people interested in the survival of the Connecticut River ecosystem and a viable four-state river for generations to come may find information contained in the following links helpful.

The first link is a piece published by CommonWealth Magazine in March. https://commonwealthmagazine.org/opinion/this-energy-storage-is-tough-on-connecticut-river/

The second is an interview by Drew Hutchison, creator of Local Bias, at Greenfield Community Television, also from March. Public participation information is included along with the credits at the end of the video. This is Local Bias production # 172.
https://www.youtube.com/watch?v=ivbXCGAwKWw

Fish Futures on a Broken River

Posted by on 04 Nov 2017 | Tagged as: 5-year FERC licensing process, American shad, Connecticut River ecosystem, Connecticut River shortnose sturgeon, Connecticut River Watershed Council, Daily Hampshire Gazette, Dr. Boyd Kynard, Endangere Species Act, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, fish passage, Holyoke Fish Lift, National Marine Fisheries Service, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, PSP Investments, Rock Dam Pool, Rutland Herald, shad, Shortnose Stout, shortnose sturgeon, US Fish & Wildlife Service, US Geological Survey's Conte Fish Lab, USFWS, Vermont, Vermont Digger

Copyright © 2017 by Karl Meyer, All RIGHTS RESERVED

FISH FUTURES ON A BROKEN RIVER

(NOTE: the following appeared in The Rutland Herald, wwww.rutlandherald.com, and on the pages of Vermont Digger, www.vtdigger.org in October)

It’s been decades since migratory fish on New England’s Great River got a break–bleak since deregulation came to federally-licensed electricity plants on the Connecticut beginning in 1998.

Deregulation turned a regional market into a venture capital free-for-all, opening the door to speculators and foreign interests controlling public resources. In less than 20 years the Vernon hydro station changed hands three times. The Vermont Yankee nuclear plant next door is currently courting a third owner. Downstream the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex flipped four times between investors. Further south, the Holyoke hydro station sold only once in 2002.

None of this proved healthy for an ecosystem.

The post-deregulation decade saw a steep slide in American shad passing Holyoke Dam. After two decades of averages well above 300,000 fish, yearly numbers plunged to near half that—a far cry from the 720,000 passed in 1992. Things were even more desperate at Turners Falls Dam. There, impacted by the massive water appetite and violent, peaking flows sent downstream by the Northfield Mountain Pumped Storage Station, passage dropped below 1% some years. For a decade, just 3 or 4 migrating shad in 100 were tallied emerging alive upstream. Today’s numbers languish near 1980s levels.

The federal license signed by Holyoke Gas & Electric in 2002 required they complete lift improvements at Holyoke by 2008 to pass endangered shortnose sturgeon upriver. Sturgeon were literally unable to spawn–blocked at that dam from reaching their only documented natural spawning site, a fail-safe refuge known as the Rock Dam Pool at Turners Falls. Year-in, year-out, that mandate went unenforced. It was finally met last year.

(Note: below, the flow-starved CT in Turners Falls looking downstream toward Rock Dam.CLICK, THEN CLICK AGAIN TO ENLARGE)

In 2004 federal fish biologist Dr. Boyd Kynard handed results of 15 years of Connecticut River shortnose sturgeon research to the National Marine Fisheries Service. He and colleagues had documented that that Rock Dam spawning site for the only federally-endangered migratory fish on the river was being decimated by industrial practices. Yearly gatherings failed for the few dozen spawning-ready sturgeon surviving upstream of Holyoke—as they attempted to continue a tenuous 200 million year-old genetic line. But NMFS didn’t come to their aid; no watchdog intervened.

Ultimately, decades of research by Kynard and company was compiled into Life History and Behaviour of Connecticut River Shortnose and other Sturgeons, published by the World Sturgeon Conservation Society. After experts at the Europe-based WSCS published the book in early 2012, the US Geological Service (where Kynard retired as a federal fish scientist) began making belated objections, halting all publication for a time. Their objections caused a de facto embargo of its sale in the U.S through that spring.

USGS cited editorial and style concerns in “recalling” three chapters on sturgeon biology and spawning—including the data and text showing industrial flows caused spawning failure at Turners Falls. Nearly a dozen state, federal, and university contributors to the book cried foul, citing censorship and the public’s right to government information. In June, concurrent with press inquiries and a letter from Congressman John Olver questioning the withholding of public science, USGS suddenly withdrew all its objections—days before an article highlighting the issues appeared in The Daily Hampshire Gazette. Federal agencies now had the facts. Yet despite the Endangered Species Act, none took action.

In spring of 2014 a popular beer, Shortnose Stout, debuted in the region. Its label displayed Kynard’s website and highlighted spawning conditions at Turners Falls. The Connecticut River Watershed Council soon stepped up to collect donated profits from its sale, yet those sturgeon were left hanging once more. Today conditions at Rock Dam remain as ruinous as when the first 2004 findings were released.

In 2015 the controversial chapters from Kynard’s book got entered into the public record in the current Federal Energy Regulatory Commission’s relicensing process for Northfield Mountain and Turners Falls. With that science on the record, things changed at federal proceedings. Sturgeon spawning became a key factor in flow discussions for future FERC licenses there mandating river conditions. This June, new restoration targets to meet failed 50 year-old federal Anadramous Fish Conservation Act requirements were released by the US Fish & Wildlife Service. With passage failed for half a century at Turners Falls, new shad targets mandate 397,000 fish passing annually. New owner, Canada Public Pension Investments, will be on the hook to build lifts and safeguard sturgeon spawning.

In August a fisherman near Vernon landed an endangered shortnose sturgeon–a fish thought not to exist above Turners Falls. He took a photo and released the fish, sending the picture to officials who confirmed it; then forwarded it to the National Marine Fisheries Service. There is reason to believe that landing may not be an isolated occurrence. NMFS is taking the confirmed capture seriously. Is a remnant shortnose population clinging to life in Vermont and New Hampshire waters? Did someone release them there? Either way, federal law requires owners at Vernon Dam, VT Yankee and Northfield Mountain to protect the migratory fish of the United States as a public trust. After decades of speculation, it’s high time our fish had their day.

NOTE: author Karl Meyer was the idea-creator and author of the beer brand Shortnose Stout. He neither requested or received any compensation or recognition for his work, which was solely aimed at getting important information to the public.

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

On Walking

Posted by on 15 Nov 2016 | Tagged as: American shad, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Henry David Thoreau, John Hanson Mitchell, MA Division of Fish and Wildlife, National Marine Fisheries Service, Northfield Mountain, Society of Environmental Journalists, The Great Eddy, Turners Falls dam, US Fish & Wildlife Service, Walking

NOTE: the following essay first appeared in edited form in Spring 2016 in a book of essays published by the Massachusetts Audubon Society entitled The Quiet Earth. That publication represented the final work of the Society’s Sanctuary Magazine staff, including founder and long-time writer/editor and author John Hanson Mitchell; writer-editor Ann Prince, Rose Murphy, and others. For decades, Sanctuary was the flagship publication that helped define MA Audubon in the public square, offering insights into the heart and soul of a caring and engaged organization.

dead-reach-ladder-and-canal

ABOVE: In the foreground the disastrous fish ladder built at Turners Falls in 1980; leading all migratory fish into the deadly Turners Falls Power Canal–in upper background with bridge, here looking downstream.(CLICK; then click again to enlarge.)

Copyright © 2016 by Karl Meyer

ON WALKING

“I like walking because it is slow, and I suspect that the mind, like the feet, works at about three miles an hour. If this is so, then modern life is moving faster than the speed of thought, or thoughtfulness.” Rebecca Solnit, from Wanderlust: A History of Walking.

I was deep in thought when the SUV pulled up. “Would you like a ride?” This was Herb, who’d repaired my computer a few times when I lived up this way. I’d just crossed into Shelburne Falls on a walk along the Deerfield from East Charlemont through parts of Buckland. “No thanks” I said, “but thanks for asking.” “But you’re limping,” he noted, a bit concerned. “Actually” I said, “I’ve been limping since I was twenty. If I stop limping, I’ll stop limping.”

There’s some truth to that last statement. My right hip is an inch higher than the left one—not by design. Some people notice the hitch in my gate, but most don’t. Still, I’m always grateful to be moving about the landscape under my own power. But I almost blew all that once—in one of those course-altering moments that occur in each life. Though some take time and reflection to recognize, this one was different.

This one transpired under a blistering August sun on the desert prairie of north Texas. For several minutes, broken and bleeding, I wasn’t sure I’d walk again. I’d just failed to vault over a looming guardrail from the back of a speeding motorcycle—my ragged skeleton cart-wheeling several times before coming to a halt. And there I lay like crumpled paper, an unspeakable pain hammered my extremities.

Someone finally came to help me out of a fogging helmet. An ambulance had been summoned. “Hang on, I’ll be back” he said, running off to locate the motorbike’s injured driver. It was then that I finally looked down at ripped jeans and some oddly turned legs that didn’t seem my own. I turned away, wanting to disappear into the Texas hardpan. But beyond that pain, there was also a profound numbness separating me from those odd-angled legs. They no longer felt part of me. Under assault, my mind and body seemed to have parted ways, perhaps forever.

At 50 miles an hour I’d made hash of all the strongest bones in the body. I knew then something more was required. I was 20 years old and had to know “Will I walk again?” Summoning all my courage I turned to face the moment. Against electrifying pain–and observing from what seemed a great distance, I gasped as my right knee twitched; then nudged up half an inch. “I’ll live,” I told myself, crumbling back in shock. That dodgy self-assessment likely helped save me.

Two months and five days later I left Wichita Falls General Hospital, rail-thin and barely able to take a few steps. I wasn’t well enough to travel home, but, I was in love. I’d continue recuperating at the apartment of one of the nurse’s aides who’d held my hand through weeks of surgeries and traction. It was absurdly romantic. My angel’s name was Karin.

Yet amongst those weeks of developing romance were endless days when no one visited. I’d only been in Texas for weeks before the crash–my people were all in New Jersey. Healing time crept by slowly; sometimes not at all. August drifted to September, which lumbered on into October. Dead center in Tornado Alley, fall settled in heavy and still, its light strange. Billowing storms flashed past hospital windows, yet I couldn’t detect any change in the season.

I daydreamed of home—of friends; familiar sights. But it was more than just a longing for things known. I craved my little corner of earth. My most fervent desire—one still tangibly sharp today, was to simply shuffle, ankle deep, through a pile of October leaves.

It’s been two years since Herb pulled up and offered me that lift. I live in Greenfield and close to town these days–where I often leave my car idle in the driveway for a week or more. I walk almost daily, more purposely in winter for the sun and its helpful shot of Vitamin D. In warmer months I move alternately by foot and bicycle, sometimes both. No matter the means, that quiet travel fulfills a longing to understand landscape and habitat, and to tread lightly across fertile tracts.

And I always go untethered. There isn’t a cell phone or I-Pod along. People today seem indifferent to their surroundings in proportion to the amount of digital armor weighing them down. Out in the world, they’re literally elsewhere–peering at screens telling them when to step left or right. We blithely wrap ourselves in the ever-spreading electric grid that’s now overheating our habitat—while denying any interdependence on what’s literally under our feet. We’ve allowed ourselves to become a pod-race of savants, vulnerable to interruptions of electro-magnetic pulses that can instantly pitch our daily lives all into an apoplectic stupor.

I was a full year recovering from that motorbike accident—three aspirin at a time, four times a day. Left with a tilted axis, I understood the need to keep moving—in order to keep moving. But somehow when I was able, it really wasn’t a burden.

Before Texas, I’d barely been out of New Jersey. Most of my recovery year was ultimately spent there. Immobile and youthfully-poor, I started reading: Melville, Dickens, Emerson, Conrad, Kerouac, Dostoevsky, Faulkner, and, thankfully, Thoreau. My world got a little bigger. When I was at last well enough to support myself, my first purchases were hiking shoes and a bicycle. They’d keep me moving.

That day along the Deerfield I was actually working, being paid something as I walked. These last six years I’ve supported a modest lifestyle by driving a bus–which might seem anomalous to someone who prefers to turn his back on his carbon belching car and hasn’t boarded a plane in two decades. Suffice to say, it’s what’s working for me at the moment.

I mainly drive high-schoolers to sporting events, museums, amusement parks and science fairs. Though there’s little glamour, it is mass transportation—efficient from an environmental standpoint. And though I was once a very disagreeable teen, today I’m pretty sympathetic, and happy to be working around their youthful energy. Is it high paid? No. Are there big benefits? Not so much. But yes—certainly in one way…

In between transport, there is down time. I can linger to watch them play—or root around the museum they’re visiting. Or better yet, I can get my feet moving and poke around the setting we’ve just descended on. Many trips are nearby, but some can be two hours distant—from Massachusetts into Connecticut, Vermont and New Hampshire. To me, walking is my own benefit. I’m paid something for my time, but it’s up to me to enrich that compensation.

So I go exploring, which often informs my writing. And, in doing so, I realize that I’m always treading ancient paths–walking atop other people’s stories. Present and past do literally merge when you wander into a 17th century graveyard huddled in the shadows of Hartford’s downtown towers. I go searching for the seeds of place. Who was here, first? When? Why on this bend of river? On longer trips I might cover 5 or 6 miles tromping a landscape or exploring a riverside–or haunting the frayed edges of 18th century New England towns.

My walks bend quickly toward the past—seeking out the oldest house, the earliest gravestone, an old ferry landing—or a town’s first mill site near an old stone bridge. On rural trips it might be ancient woods or a river crossing bearing an Algonquian name. Faced with the frenzied pace of our techno-consumer society, I’m hunting a language of place. It’s my attempt to recover some essence of earth.

I’ve always had an inescapable awareness that history is much more than the acceptance of dry, scholarly tales. I don’t enter a city or town center without thinking—or knowing, that this place was once home to others—that Deerfield was once Pocumtuck and Springfield was once Agawam. It never slips my mind that there is a Hockanum in Hadley, MA, and another in East Hartford, CT–both sites cradled in the shadow of an ancient Connecticut River oxbow. And it never leaves me that the people who first adopted those names for places they knew as home, did so in a deliberate tongue that connected them to what they understood as the essence of their earth.

Everywhere we tread, no matter how indecipherable a modern landscape has become, once had another name and another language—relayed in sounds that strove to offer its history and significance to its denizens. Those names were a key to an unbroken human connection to earth. Nearly all of that was erased. We are often left with just fragments.

That’s why I was once dumbstruck to discover a young Protestant immigrant and colonial trader named Roger Williams took time in 1643 to write A Key into the Language of America, translating Algonquian phrases for the English tongue. That opened a door for me, just a crack. A white spire may still be a great comfort to a little Massachusetts town, but just three centuries back the raising of that steeple signaled subjugation and conquest to still-living peoples whose ancestors had walked here for thousands of years prior.

“I believe in the forest, and in the meadow, and in the corn that grows in the night,” Thoreau wrote in On Walking–a swipe at rote Yankee preaching that exhorted ultimate dominance of the lands and landscapes so recently annexed. Today we rush across places where seminal cultures were brutally shattered and dispersed–conquests that, in very short order, led to the wholesale devouring of age-old New England’s forests.

So I go in search of a language of land. That may seem quaint in a time when Downtown Crossing is most identified as a collecting point for Boston consumers. Or here, Hadley—a 1659 Connecticut River settlement identified as Norwottuck on early maps, is now most notable for its ever expanding mall-strip near Old Bay Road. That’s part of what motivates me to walk. And I also think that maybe the earth talks to us a little bit through our feet, reveals some of its stories. We just seem to have stopped listening—perhaps when we abandoned walking to race across the earth in the hardened shells of carbon spewing conveyances.

Countless studies tout the benefits of walking: to balance, creativity, emotional and physical health. Walking also offers reconnection, the possibility of discovering new places. But it’s that my footsteps touch upon the stories of others and grounds me on the planet that matters most. I get to see and listen in earth time. And the best days can be charmingly, exotically freeing for a quiet plodder sniffing around old towns and rarely trammeled places. Padding along in a minimal carbon footprint, past and present sometimes merge in moments that are downright exquisite.

There’s a leafy amusement park in North Granby, CT–relatively pleasant and not overly electrified. One could be tempted to just sit by the shaded pool there. Instead I headed out in mid-June heat along a narrow stretch of Rt. 189. After a mile I veered off at Day Street—an intersection flanked by an old farmhouse. That led me up along the ridge overlooking the Salmon Brook Valley. Most of the houses turned out to be newer, with little pasture remaining. But then came a break in that developed tract–an opening where the light appeared different.

What popped out next–monstrously-sprawling, and stubbornly clinging to life, was the Dewey-Granby Oak. It was simply stunning, and all the more so set along this old road—holding ground against a spreading suburban shadow. I recognized its name from some distant reading, but knew nothing more. Here, unannounced and magnificent, was that sun-dappled great oak—a specimen worthy of period films set on old English estates.

But truth be told, there was little in the way of detail to adhere to. Rooted here long ago, the Granby Oak simply remains a presence to this day. Someone must’ve taken a core sample when this patch of earth was preserved by the Granby Land Trust. A plaque from 1997 intoned it had begun life perhaps 450 years earlier. However accurate, that implied it was just a forest ridge seedling at the time of Shakespeare’s birth in 1564. The Tunxis were then travelling this trail–later to become Day Street, passing and re-passing a white oak growing to maturity. Yet little more than a century on Europeans began swarming this little valley, quickly felling the upland tracts to stump pastures. An ancient woodland path disappeared beneath cart ruts and grazing cattle, but one venerable wolf tree was left as witness.

Here then was my day’s clue to understanding a moment in time. Survival, longevity, green leaves sprouted along sprawling, weathered branches–I’m not sure exactly why that satisfied me. Yet unheralded bits of knowledge are often what offer context to the fabric of life. I paused there for a few minutes, breathing in the continuity of a long life. “I have great faith in a seed,” Thoreau wrote. Today my seed was an old oak.

Wilder hikes on bus trips are rare, but there was a recent scramble up Mt. Monadnock– accompanied by that rare fellow bus driver not glued to a seat. We hustled up; then down, to deliver the dozens of prep-schoolers we’d unleashed on that hill. But briefly, in between, there were grand three-state views connecting back to another companion who’d passed this way. Thoreau visited here a handful of times, finding Monadnock a worthy place to “go a-fishin in.”

We’d soon meet again on a trip to Bellows Falls High. A walk there brought me to the train stop near the Connecticut River where Thoreau once disembarked. Unbeknownst to me, he’d also once walked to the Great Eddy—an ancient Abenaki fishing site below The Falls. Into the late 1700s Yankee farmers could still pull up 1,200 American shad here in a single haul of the net.

PHOTO: The Great Eddy at Bellows Falls today.

But we’d both found disappointment on the Connecticut. For Thoreau it was that there was hardly any river at all, the lingering result of the navigation canal diversion for riverboats, just upstream. Mine remains that those migrating shad–a half century after Congress authorized the four-state Connecticut River migratory fisheries restoration, still fail to reach Bellows Falls. From day one, shad were the program’s key restoration species. Far from extinct today, most remain blocked and imperiled 50 miles downstream–trapped in the private power canal below Turners Falls Dam at the place once called Peskeomscutt. Though a small portion of the run squeezes upstream toward open Massachusetts, Vermont, and New Hampshire habitats—some 200,000 shad or more never make it past a dam where they’ve been blocked since 1798.

Winter 2015 wasn’t easy for ambulation. Still, a mid-February trip to Phillips-Exeter in New Hampshire had its highlights. Though sidewalks were lined in waist deep snow, I tramped Exeter’s centuries-old byways for hours. I bundled down to the Squamscott River and its old bridge and frozen fishway. A turkey vulture swooped in–yards above the snowy street, the surprise of a brief squall. Sculptor Chester French’s birthplace is marked in downtown Exeter—along with the first meeting site of the Republican Party. Historic houses are now festooned with the symbol of an alewife, or smelt–ancient staples of the Pennacook and those who came after.

But my best walk came in mid-April, though dingy snow piles still had plenty of life in them. I’d dropped my kids off in Lowell National Historic Park. The forecast wasn’t great–brooding, with showers expected, but temps perhaps nearing sixty. I had hours to burn, and a rain jacket, so I took to the streets. I’d been here once, briefly in mid-winter. The Merrimack, Pawtucket Falls and Lowell’s ragged bordering neighborhoods grabbed my fancy. I’d wanted more.

This April day, winter seemed finally ready to relent. The rain held off as I steered toward Market Street, where the Olympic Bakery had offered me a great Greek salad and fresh cannoli last time. The sun burst through in a neighborhood of unvarnished factory houses—a Greek-Latino mix. I ordered pizza slices to go and found a quiet doorway to sit in the late morning’s humid air.

Then I headed to the river, dreaming of the Merrimack’s shad runs of old–wondering if endangered shortnose sturgeon had ever spawned this high in its reaches. Landlords chipped away at stubborn ice, and the gates leading to the river walk remained closed, still snowed over. But I followed the Merrimack just the same, heading downstream on Pawtucket Street and crossing at the first opportunity. This landed me at the edge of UMass Lowell’s North Campus, to finish lunch on a wall overlooking the city’s old mill towers and spires. Ruminating on that bank, I reflected that the earth under me was once part and parcel of a Pennacook village here.

The showers remained at bay so I continued seaward beside the water—crossing the river four times at three historic bridge sites. I gained a new sense of Lowell’s Byzantine canal system—branching from, and linking, the Concord and Merrimack. As hydraulics got refined, the rivers and river travel here were quickly eclipsed by giant mills and locomotives. Further on, I stumbled into a tiny urban park honoring Jack Kerouac. Enshrined on a polished slab was one of his poems, a loving, edgy, retelling of his parents’ stark lives here and his own subsequent birth along hard-bit Merrimack shores. It lent a presence to the place.

My best minutes though, came further on, at the merging place of two branching canals not far from Lowell’s rust brick downtown and signature Lowell Sun Building. I’d walked back in time along remnants of the centuries-old navigation system to its convergence with the Concord River, just ahead. Here, some 175 years prior, young Henry Thoreau and his brother John had passed–heading through locks ushering them onto the Merrimack. They steered upriver on that larger stream–north toward New Hampshire towns already felling their last forests to fuel an Industrial Revolution. Under that warming April sun, my day’s walk somehow seemed complete.

But there’s another walking exploration I’ve repeatedly engaged in these last four years–my tornado walk. I’ve literally been walking around inside a tornado. On June 1, 2011, an astonishing EF-3 tornado touched down in West Springfield. It skipped across the Connecticut; then battered the landscape for a full 39 miles east–all the way to Southbridge. I’d been driving kids through West Springfield just the day before it thundered through.

Tornadoes stalked the dreams of my youth since childhood, likely an offshoot of viewing the Wizard of Oz. Though strangely fascinating, I’ve never hankered to experience one in the flesh. In dreams they’d always loomed ominously on the periphery—never quite catching me up. But the absolute destructive power of this one–here in the Northeast, was disturbingly eye-opening. Three people died, hundreds of homes were destroyed. It roared across towns in a traceable, half-mile wide trajectory, just south of Route 20—in places my bus trips often intersect with.

That fall at West Springfield’s Eastern States Expo, I walked out the gate and into the neighborhoods due north. Whole houses still lay in ruins, dozens uninhabitable. Thousands of windows had imploded and were boarded up, or being replaced. What trees remained were hulks, stripped of all lateral branches. At Union Street the devastation across tightly-clustered double and triple-decker apartment homes was withering. A mother died here while shielding her teenage daughter from the storm’s fury. Heading home on I-91, Springfield’s South End was yet a mass of tumble-brick ruins. In the distance, a checkerboard of tarped-roofs led up the ridge toward East Forest Park like it was a staircase painted in blue.

One snowy day the following December, I again walked that tornado’s footprint among the relict trees south of Wilbraham Center. Cars had skittering off the highway, but I got my kids settled in safe. I then bundled up and took off down Main Street, where that unseen power had descended with little warning six months prior. It peeled off roofs, toppled outbuildings and shattered scores of trees–then stalked off up the mountain ridge toward Monson. One displaced citizen had returned to string up holiday lights on their darkened, uninhabitable home.

In late February I took another walk in that great scar where–just minutes later that June day, that tornado barreled down the ridge into Monson Center. Snap, snap—snap, snap, snap!–like twigs, whole trees were crowned; stems jackknifed just 20 feet from the ground. It then roared off to the east.

And I did the same, later that spring—on a Sturbridge Village trip. It’s just a ten minute walk out the back of that museum to where that EF-3 twister roared in, devouring an entire wooded swamp. It snapped and scattering trunks in astonishing blow-down jumbles; then crossed Rt. 131 into Southbridge.

On a return trip to Wilbraham two April’s ago, I again backtracked into that storm’s path once more. After dropping off my team I followed a hunch into the landscape. Peepers and warblers called along a winding cross country trail leading through lowland woods. But then a new slant of light from a little bluff to the north caught my eye. That detour—just a few yards off the trail, brought me dead center into the storm. Helter-skelter before me lay the remnants of a once-broad, upland forest–mature pine, oak and maple, leveled, upended; dead. Hundreds of trees, rank-on-rank—tossed or tumbled, sucked up; then mowed down. Like bowling pins.

The devastation was stark and powerful, yet bits of the place were now returning to life. A few trees, pitched and leaning, struggled on. Flickers and nuthatches darted about the edges, feasting on a buggy decay. The trail wound back down, and widened to a swampy marsh–also raked by the storm. Here too were the crowned, scattered trees of a wetland—shorn of branches and left as lifeless hulks. But in the crook of one was a fat jumble of sticks. And there, in profile, sat an erect, great blue heron. I quickly counted four more nests and attending sentinels–occupying four more of those hulks. Astonishing.

And my storm-walk in Wilbraham continued this last spring. In mid-April there was but one active heron nest remaining. Wood frogs had arisen from the ground just the day before, but they were quiet. The females had yet to join the gathering. Yet still I understood that this was a place becoming—a landscape evolving to something new. And that’s part of the reason I’ll likely take this same walk again, if it happens to turn up on my assignment list.

But beyond that, there’s one particular walk I’m absolutely certain I’ll be taking. Every fall, randomly and unannounced, blue sky and a hint of early October chill takes hold of me. Then, for a brief few minutes, I’ll joyously drag my clumsy feet through a pile of autumn leaves–relishing the decay they stir into the air; and savoring a papery sound that says home.

End

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.)

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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.

INFORMATION BLACK HOLE on the Connecticut

Posted by on 05 May 2016 | Tagged as: American shad, Connecticut River, federal trust fish, FirstLight, GDF-Suez FirstLight, Greenfield Community College, Holyoke Community College, Holyoke Fish Lift, Jack Buckley, MA Division of Fish and Wildlife, New Hampshire, Northfield Mountain, shad, shad fishing, Station 1, teachers, Turners Falls, Turners Falls dam, Turners Falls power canal, US Fish & Wildlife Service, USFWS, Vermont, Walpole, Wendi Weber

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INFORMATION BLACK HOLE

Copyright © 2016 by Karl Meyer

On this May 5th, 2016, they have no idea in Sunderland–or in Deerfield for that matter. Nor do they know anything in Greenfield, Turners Falls, Gill, Northfield or Millers Falls. Upstream, Vermont folks in Vernon, Guilford, Brattleboro and Putney don’t have a clue. Across the river, New Hampshire people in Hinsdale, Chesterfield, Walpole and Charlestown remain in the dark.

What these towns all have in common is that nobody can tell them anything of the whereabouts of their share of the spring American shad run. The fish have been in the river and upstream of Holyoke for a full five weeks now, and there hasn’t been a single fish count provided from the Greenfield Community College students hired by GDF-Suez FirstLight to monitor fish passage at Turners Falls. An accounting of the public’s fish remains in the hands of a private company—and, as I’ve said before, many or most are likely struggling to survive a trip through their private power canal.

For a migrating shad, the 36 mile swim from Holyoke to Turners Falls is a walk in the park. It’s a day—maybe a day-and-a-half trip, ostensibly on the way to spawning habitats in Vermont and New Hampshire. But thousands of the public’s fish have gone missing on the Connecticut River this spring. And it seems no one can say exactly where they are. If you had to make an educated guess, you could surmise many are somewhere between Greenfield and Turners Falls, with many not in the actual river at all.

A significant number are fighting currents in the debased habitats of the Turners Falls power canal, where murky flows delay most by over a week before they even approach the site that could route them past the dam. Others are in the river, trying to find a path to the base of a fish ladder whose construction back in 1980 was based on Pacific salmon. And still others are sidetracked and stalled in the riverbed like sardines, expending precious migratory and spawning energy in front of the ramping outflows at a mini overflow power site known as Station 1. Wherever those fish may be, we do know that, on average over time, just 4% of those shad ever make it beyond Turners Falls Dam toward Vermont and New Hampshire. In the very few “good” years, one fish in ten wriggles upstream.

We also know that the first two American shad were lifted past Holyoke Dam five weeks ago. As of May 4, 2016, some 25,000 had been passed upstream at the Holyoke Fish Lift. What happened to them next is anyone’s guess. Once they pass Holyoke, accounting for them is left in the hands of a private power company—currently GDF-Suez FirstLight Hydro, now going under the corporate aegis Engie. These are the folks responsible for passing the public’s fish at Turners Falls Dam, and giving public accounts of fish passage for anglers, teachers, the general public, and the state and federal fish agencies.

It’s been documented that at least half of all the shad passing Holyoke will attempt to pass Turners Falls. It’s wholly possible the actual number is significantly higher. It matters little though, as all fish get diverted into the Turners Falls Power Canal once they attain this easy upstream reach, and only that average of 4% make it past the TF Dam. The rest simply go unaccounted for once they arrive and are tempted into that turbine-lined pit.

Five full weeks since fish have been heading upstream, and that includes sea lamprey as well. Yet we still do not have a single fish passage update at Turners Falls. What’s wrong here? Who is responsible?? Well, obviously FirstLight GDF-Suez is responsible. But, nobody is holding them to it. These fish, while moving through Massachusetts, are the responsibility of the US Fish & Wildlife Service. But, while here, they in large part fall under the responsibility of the MA Division of & Wildlife. Why aren’t they ensuring the public gets daily fish updates—like those that have been available at Holyoke Dam for years? Again, go fish…

At Holyoke Dam there are actually humans on-site that can witness real-time conditions, fish passage, and provide the needed public info in a timely manner. These come via students from Holyoke Community College. Not so at Turners Falls, where the Commonwealth has largely left responsibility for the chicken coop up to the fox. All monitoring is done remotely by video, with equipment provided by FirstLight. Prior years show repeated equipment failures. And then you have to wait—often many WEEKS, before those videos are handed off and analyzed by GCC interns. Its only then that we are treated to weeks-out-of-date info about where our fish are.

This privatization needs to change. Wendi Weber, Region 5 Director at the USFWS might be able to help. Or MA Division of Fish & Wildlife Director Jack Buckley. Or, perhaps, MADFW’s Caleb Slater, Anadramous Fish Passage Project Director. The guy at FirstLight responsible if Bob Stira.

As a side note: many other states have actuarial tables that put specific monetary values on migratory and resident fish. Then, if they are killed in project operations, or fish do not reach their spawning grounds, the public is reimbursed for the ecological damages.

Updated HOLYOKE fish counts can be accessed at:
www.fws.gov/r5crc under Recreation.

CASHING IN ON A CASH COW

Posted by on 15 Jan 2016 | Tagged as: American shad, climate change, Connecticut River, Connecticut River shortnose sturgeon, Daily Hampshire Gazette, endangerd shortnose sturgeon, Endangered Species Act, Energy Capital Partners, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, fossil plant, GDF-Suez FirstLight, ISO, ISO New England, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, NMFS, NOAA, non-renewable, Northfield Mountain, Northfield Mountain Pumped Storage Station, Rock Dam, shortnose sturgeon, The Greenfield Recorder, The Pioneer, The Recorder, Turners Falls dam, Uncategorized, US Fish & Wildlife Service, USFWS, Vermont

The following piece appeared in the Daily Hampshire Gazette(www.gazettenet.com) and the Recorder(www.recorder.com) in the first week of January 2016.

CASHING IN ON A CASH COW

Copyright © 2015 by Karl Meyer

Ever dreamed of owning your own bank? I got a deal for you! Northfield Mountain Pumped Storage Project is for sale again, along with the Turners Falls canal and dam—and a string of little assets down in Connecticut. But Northfield’s the cash cow. Fourth time in a decade they’re unloading this golden calf–always at a tidy chunk of change. A quickie corporate win-win! It’s really like an A.T.M., run at the expense of the Connecticut River ecosystem.

Place works like a giant toilet–suck huge amounts of the river backward and uphill, then flush it all back and—viola, money spews out the other end. Could be ours! They’re holding bidder tours as we speak. I just need a few partners with ready credit. We go in on short-money and cash-in on the no-brainer electricity “spot market” for a few years. Then, with inflated power-price futures in play, we offload this puppy for a final cash-out of 30%–maybe 50%!

Here’s how it goes down. With the cheerleading of Northfield’s not-so-silent partner, ISO New England–the “independent” system operator (created by the Federal Energy Regulatory Commission), we simply slow dance this darlin’ past the banks, the FTC and FERC. Then, in 2016, its sweet business-as-usual—maybe with new shirts for employees.

Trust me, this works every time. Everyone walks away with full pockets—without the public knowing what hit them. Northfield got wholesaled in 2006 by Northeast Generations Services(formerly WMECO—formerly of Northeast Utilities, now Eversource—you follow?) They grabbed a quick $1.34 billion for the package, slipping it to a trio of Jersey venture capitalists, Energy Capital Partners. ECP renamed their little project FirstLight Energy. Those smartest-guys-in-the-room hung-in and grabbed Northfield’s peaking spot-market profits for two years, before off-loading it for a nifty $1.89 billion in that crazy year, 2008.

With that, GDF-Suez, third owner in four years, swept in–the world’s largest private energy corporation, based in France. They’ve been gobbling up contracts to run water systems across the US under the name Suez United Water. But GDF-Suez recently did a clever name-change to Engie, keeping the public totally confused. They got game! The true costs of these premium-priced plant sales get buried in the list of acronyms on electric bills. It’s like owning a 25-mile stretch the Connecticut River to dip into for cash any time you please.

This is a turn-key operation–with us, the new guys, pushing the buttons. The joke is that the public thinks Northfield is a hydropower operation, while this baby has never produced a single watt of its own energy. It’s imported!–huge swatches of bulk electricity now run-in from outside the region to suck a mountain’s worth of flow from the Connecticut up to a reservoir. Then, dump it out on the power lines when prices peak. It’s hugely inefficient, now largely carbon-based—and massively damaging to the river. But amazingly profitable!

That’s where we come in. Sure it was built as a sister to the region’s nukes to gobble up their monstrous stream of unused electricity–because nukes can’t shut down their feverish output at night. That’s how you get to put in a giant straw and suck the Connecticut uphill at a rate of 15,000 cubic feet per second–more than enough to pull the river backward for a mile downstream under low flow conditions. But who’s watching? When the region’s last nuke shut down, nobody said ‘boo!’ with Northfield going fossil. What climate change?

And when it became clear years back that Northfield operations were imperiling spawning success for the federally-endangered shortnose sturgeon at the Rock Dam in Turners Falls–their singular natural spawning site going back into pre-history, again, nobody came forward. Not the US Fish & Wildlife Service, the National Marine Fisheries Service or the MA Division of Fish & Wildlife—or any river protection group. No bureaucrats, no suits–nobody. At Turners Falls—instead of 70% of migratory fish heading upstream toward Vermont and New Hampshire, they squeeze out 4%. We have it made!

Still skeptical? ISO and FERC are addicted to Northfield—even though its power-flush characteristics might come into play maybe a handful of times a year, if at all. For this they let owners cash in on the river whenever y they want. In 2012, the owners of this “asset” collection of 1500 megawatts(of which over 1100 MW derived from Northfield alone) told investors a full 40% of their profits were realized from “Capacity Fees.” What that means is you get paid for holding back the Connecticut! They’re not required to use it at all if they don’t want to—just flush when prices are high. Paid for being you! Of course another 50% of profit comes from generating, though the public doesn’t know it only operates a few hours a day when prices are highest.

Here’s the kicker: in 2014, after a cry-wolf energy deficit winter that never materialized, FERC–with ISO as cheerleader, sanctioned the doubling of those “capacity fees”. Plants are now collecting 2X the amount they were two years back, for having the potential to dump some power on the lines—not for actually generating. Paid for being you! With 1100 potential megawatts at Northfield, how quick can you say “windfall at the public’s expense?” Lastly, Northfield petitioned FERC the last two winters to increase its reservoir storage by a full 25%, with ISO their biggest cheerleader. FERC agreed, twice. Double-dip with a cherry, anyone?

This thing’s a cinch! Even with all the nukes shut—when this should have been moth-balled to emergency use as more climate-warming, spent nuclear junk, it soldiers on as a virtual river monopoly with the blessings of FERC and ISO. Trust me, no one goes to court. Ecosystem damage, costs to the public? Fuggetaboutit!

Got credit? Give a call!

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

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