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Connecticut River: citizens taking a stand to end Northfield Mountain’s half century of killing

Posted by on 02 Apr 2022 | Tagged as: America's best landscaped sewer, Clean Water Act, Commonwealth of Massachusetts, Connecticut River, Connecticut River Day of Mourning, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, Environmental Protection Agency, EPA, Federal Energy Regulatory Commission, FERC, FirstLight Power, Greenfield Recorder, Julie Crocker, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, Mark Tisa, Martin Suuberg, migratory fish, Mr. Mark S. Tisa, National Marine Fisheries Service, net-loss power, New Hampshire, no license to kill, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, PSP Investments, The Recorder, US Fish & Wildlife Service, US Fish and Wildlife Coordination Act, US Supreme Court, USFWS, Vermont, Vermont Digger, VT Digger, Waterkeeper Alliance, Wendi Weber, wrsi.com


The giant sucking intake mouth of FirstLight/PSP Investment’s Northfield Mountain Pumped Storage Station, where it preys on the aquatic life of the Connecticut in three New England states.Photo Copyright © 2022 by Karl Meyer

Things to understand about the current extended (expired April 30, 2018) and proposed FirstLight federal license for Northfield Mountain operations:

* Under commonly occurring conditions, its suction and pumping will continue to force more than 5 miles of the river to flow backwards.

* Northfield Mountain’s daily use will continue to obliterate 100s of millions of fish and aquatic animals annually.

* It’s suction and subsequent regurgitation of a deadened river at over 15,000 cubic feet per second, and 20,000 cubic feet per second respectively, for hours on end, is roughly the equivalent of swallowing all the aquatic life in the 4-story, 19,000 sq. ft. Hawkes and Reed building in Greenfield–one EVERY second, SIXTY every minute, THREE THOUSAND SIX HUNDRED per hour…

The turbines of the pump station suck in life and throw out death,” Shayla Freeland, Gill MA.

The gross megawatts it squanders yearly sucking the river backward could directly power the annual needs of cities and towns up and down this Valley. Instead it will suck out a river’s soul.”
Karl Meyer, Greenfield MA, from the Greenfield Recorder and vtdigger.org.

A There is NO WATCHDOG HERE: interview on THE RIVER ahead of the Connecticut River Day of Mourning.
https://wrsi.com/monte/mourning-the-connecticut-river/

Those seeking a true watchdog model with commitment, staff lawyers and enforcement intent might do well to investigate the Riverkeeper/Waterkeeper organization.

UNDERSTAND: there is no new signed license yet. Only the Federal Energy Regulatory Commission can issue one. FERC itself must ensure that any new license must comply with all existing US environmental laws. This machine does not; and cannot meet those requirements.

The US Supreme Courts decision in 1872 in Holyoke Co. v. Lyman confirmed there must be safe upstream and downstream passage of migratory fish on all US rivers. Canadian-parent owned FirstLight’s proposal fails this.

A river flowing backwards does not meet the standards of the Clean Water Act. You cannot license such impact on a US river.
Northfield Mountain, Northfield MA, where the Connecticut River ecosystem dies… Photo Copyright © 2022, by Karl Meyer

FirstLight’s proposed temporary and flimsy barrier “net” will not even be anchored in the riverbed, and will leave eggs, fish and young of three states exposed to Northfield’s massive suction in their most fragile months of development.

There is nothing in the plan to monitor it daily, below the surface, where the killing occurs. The see-sawing pressure from Northfield and natural river storm flows will very likely leaving it loose and flopping in the current–just as the old net for factory-produced baby salmon did for a quarter century, beginning back in the 1980s. It’s a red herring.

In short, if relicensed, the Northfield Mountain Pumped Storage Station, will continue to kill and erase a living Connecticut River ecosystem in Massachusetts daily. It’s uses has been illegal from the day it opened in 1972, a CENTURY after Holyoke Co. v Lyman.

* *GO ON THE RECORD WITH FERC: tell them “no new license to kill.” Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

Then go public, letters, op eds, papers… tell US Fish & Wildlife Service’s Wendi Weber, MA Fish & Wildlife’s Mark Tisa, National Marine Fisheries Julie Crocker, and MA DEP’s Martin Suuberg that
the Connecticut River will not be left to die here in the Commonwealth of Massachusetts… It’s THE PUBLIC’s RIVER.

NO RIVER SHOULD DIE IN THE DARK!

A Connecticut River Day of Mourning: STANDOUT this Sat. Apr. 2

Posted by on 30 Mar 2022 | Tagged as: 1872, Connecticut River, Connecticut River blog, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, Death-Sewer, Eversource, FERC, FirstLight Power, Greenfield Recorder, Jesse Leddick, Julie Crocker, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Mark Tisa, Martin Suuberg, Massachusetts Division of Fish & Wildlife, Mr. Jesse Leddick, Mr. Mark S. Tisa, New Hampshire, NMFS, no license to kill, Northeast Utilities, Northfield Mountain Pumped Storage Station, NU/WMECO, PSP Investments, Public Sector Pension Investments, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, Source to Sea Cleanup, State of Delaware, Turners Falls, Turners Falls dam, USFWS, Vermont, Vernon Dam Fishway

A CONNECTICUT RIVER DAY OF MOURNING:

NO RIVER SHOULD EVER DIE IN THE DARK!

Standout on: Saturday April 2, 2022, 11 a.m. – 1 p.m.

WHERE:Turners Falls, on the TF Gill/Montague Bridge just off Rt. 2 East above the Connecticut River in Massachusetts.

A heartbreaking, river-betraying, FirstLight-filed Agreement in Principle has been signed by the US Fish & Wildlife Service, MA Division of Fisheries and Wildlife, National Marine Fisheries, and MA Natural Heritage, and sent to FERC.

It’s a CAPITULATION, a soulless document WITHOUT PRINCIPLE.
* READ IT at the END OF THIS POST.*

Come, WEAR BLACK, stand up for the SOUL of OUR RIVER:
Saturday, April 2, 2022, 11 am – 1 pm.

Please, everyone who has ever fought for the truth about this river, the life of this river—all of you who have marched, stood out, written and shouted publicly “NO LICENSE TO KILL” for our ancient Connecticut and its living waters, come to the Gill/Montague Bridge above the River on April 2nd.

https://vtdigger.org/2022/03/30/karl-meyer-a-connecticut-river-day-of-mourning-will-be-held-april-2/

We will stand in honor of the soul of this Valley–above FirstLight’s TF dam, controlled from inside Northfield Mountain, 5 miles away. We’ll be across from US Fish & Wildlife Service-funded and MA Division of Conservation and Recreation-run, Great Falls Discovery Center. Each one of these entities is culpable for allowing a four-state ecosystem to be turned into our river’s 23-mile MORTUARY by Northfield’s brutality in the Commonwealth of Massachusetts. Come, stand together and bear witness. NO RIVER SHOULD DIE IN THE DARK!

Please WEAR BLACK, and perhaps bring signs that name the names of those responsible. If you have an old shoe box or something small that can stand-in as symbolic coffin for the 20 miles of dead river here, cover it in black and place a single-page cut-out of a DEAD FISH inside–to illustrate the murderous continuation of Northfield’s license. Symbolically, we’ll feed a few into a shredder as witness to this failed ecosystem.

Northfield Mountain, Northfield MA, graveyard where Our Connecticut River Ecosystem Dies… Photo Copyright © 2022 by Karl Meyer

WHY?: Because the Northfield Mountain Pumped Storage Station, the most murderous, wasteful, river-reversing parasite ever licensed to kill on New England’s Great River was betrayed by the US Fish & Wildlife Service, Massachusetts Division of Fisheries & Wildlife, MA Natural Heritage & Endangered Species, and the National Marine Fisheries Service on St. Patrick’s Day, March 17, 2022. Behind closed doors they signed a heartbreakingly-grim Agreement in Principle (AIP) toward granting a new FERC license that will re-enshrine and continue the most brutal, murderous, river-reversing flows and ecosystem-dismemberment—occurring unabated here in Massachusetts since Northfield came on line in 1972.

This document, *LINKED AND INCLUDED AT THE END OF THIS POST*, is literally an agreement WITHOUT PRINCIPLE, as they are our guardians of the Public Trust—encumbered to protect our river, its fish and the coming generations who must depend on a living river ecosystem. In a cheap bit of grandstanding, the Connecticut River Watershed Council(CRC), in business since 1952—who should have stopped this killer from being built 50 years ago, made a show of walking away without signing this AIP. After signing another one..

Fifty years late they appear to have found the courage to mildly label Northfield as a killer–after staying mum and taking the power company’s cash for decades. Here is Director Andy Fisk’s new-found outrage about this River’s conveyor belt of death, a half century after the fact: “…Northfield Mountain has been operating for many years without any protection against fish being killed by the turbines.” Wow Andy, nice catch… It’s killed virtually EVERYTHING it’s sucked in–during all the 50 years the Connecticut River Watershed Council/Conservancy has been in business…


The deadly, suctioning, parasitic intake of FirstLight/PSP Investment’s Northfield Mountain Pumped Storage Project–the most efficient electric predator ever sanctioned to operate in this 4 state ecosystem. Photo Copyright © 2022 by Karl Meyer

In their watchdog claims of 70 years, they are perhaps the most complicit. They never did a protector’s job; never took the corporations or state and federal agencies to court for violations of some of the most basic environmental laws and river and fish protections dating back to 1872. This new “in it but not of it” posture should be wholly condemned. It’s a CRC version of alternative facts. They are a failed NGO, one that has let 50 years of the unconscionable annual slaughter of literally 100s of millions of fish eggs, juvenile and adult fish and developing larvae of some 24 different species from 3 states be suctioned to their deaths by Northfield, built by CRC’s great benefactor and BFF, NU/Eversource, in 1972. No staff lawyers, no bark, no TEETH!

In 2022, CRC finally makes a bland public statement recognizing that at Northfield there are “fish being killed by the turbines.” That half century of slaughter is on their watch.

Getting back to the public trust, the new Agreement WITHOUT Principle was signed under the directorship of US Fish & Wildlife Service Region 5 head Wendi Weber; Mark Tisa sanctioned it as MA Division of Fish & Wildlife Director, Jesse Leddick inked-in directly as leader of the MA Natural Heritage & Endangered Species Program, and Julie Crocker, NOAA/National Marine Fisheries Service ESA Fish, Ecosystems and Energy Branch Chief also agreed to let that promissory note of their legal intent to a new Northfield license be signed.

And who are they selling our ecosystem out to? Why it’s come-lately venture capital’s FirstLight Power, a subsidiary of Canada’s Public Sector Pension Investments. PSP/FirstLight arrived as big-budget bargain investment shoppers, buying up the Northfield Mountain Pumped Storage Station and Turners Falls Hydro Projects at basement rates in 2016. Then, in a marvelous vulture-capital-esque move, they quickly divided their MA assets in 2018, and reregistered them into Delaware tax shelters. Now–with the cowardly 50 years of no-show protection from federal and state agencies here, FirstLight will have the killer keys to 20-plus miles of the Connecticut—impacting three New England states, for decades.

As their constituents, they have failed US. At a time when the Earth is foundering, they’ve agreed to allow a river system to be strangled, reversed and culled of virtually all its aquatic life daily at Northfield. Meanwhile PSP/FirstLight will likely have execs walking off with hefty million dollar bonuses and golden parachutes, as our public trust agents stay in the shadows as abject failures.

After 50 years, this murderous slaughter is being renewed AGAIN, on their watch!

If these agencies were corporations, obligated to produce RESULTS for the benefit of all of us as public trust constituents—there would be massive outcries for resignations from the likes of Ms. Weber, Mr. Tisa, Mr. Leddick, and Ms. Crocker. Instead, they’ll likely have the option to retire years before their abject failure on behalf of the Connecticut River in three states becomes fully visible. Perhaps a few will do the right thing now, plus Mr. Fisk.

* * LASTLY: HERE is that Agreement in Principle–the document signalling the ABANDONMENT of a LIVING CONNECTICUT RIVER ECOSYSTEM
CLICK ON THIS LINK:

* * * RiverSALE-20220318-5004-1 * * *

“No license to kill”: citizens defend the Connecticut River at its ecosystem graveyard—Northfield Mountain Pumped Storage Station

Posted by on 06 Feb 2022 | Tagged as: Connecticut River, Connecticut River blog, Connecticut River ecosystem, Connecticut River Refuge, Conte National Fish & Wildlife Refuge, Delaware LLC, E-Comments, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC license, FirstLight, fish kill on the Connecticut, Great River Hydro, Greenfield Recorder, Landmark Supreme Court Decision 1872, MA Division of Fish and Wildlife, MA Natural Heritage and Endangered Species Program, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Nation's best landscaped sewer, National Marine Fisheries Service, net-loss power, NMFS, no license to kill, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, PSP Investments, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Greenfield Recorder, The Recorder, US Fish & Wildlife Service, USFWS, Vermont

In an unrelenting drumbeat of filings to the Federal Energy Regulatory Commission, citizens throughout the Connecticut Valley are demanding that no new license be issued to Canada-owned FirstLight for their Delaware-tax-sheltered Northfield Mountain Pumped Storage Station here in Massachusetts.

https://www.recorder.com/my-turn-gyorgy-FirstLightLicensing-44862677

Please read the excellent opinion piece ABOVE from last week’s Greenfield Recorder by Anna Gyorgy, then continue further BELOW to read the latest group of on-the-record citizen filings to FERC insisting that a new license to kill be denied at Northfield Mountain for this venture capital outfit. KEY EXCERPTS from the most recent CORPORATE filings to FERC can be found at the end of this post.

IN THE LATEST INDICATION of the strength of opposition to a new Northfield license FirstLight just missed another self-targeted deadline to have its secret license negotiations with US Fish & Wildlife, MA Dept. of Environmental Protection, MA Division of Fish & Wildlife and the National Marine Fisheres Service all buttoned up and ready to send off for FERC approval.

IN THEIR LENGTHENING FAILURE to put the last nails in this four-state ecosystem’s river-reversing, fish-killing coffin, FL was forced to request “that the Commission continue to defer issuance of its Ready for Environmental Analysis (REA) Notice until after February 28, 2022. FirstLight anticipates requesting the Commission to further defer the REA Notice until after June 30, 2022, to allow the parties time to negotiate a comprehensive, binding settlement agreement that aims to fully resolve all relicensing issues.

THOUGH THIS MAY APPEAR to be merely yet another of FirstLight’s series of month-long delay requests–it’s actually admitting they’ll likely not have this thing safely in their Delaware-registered tax bag until July of 2022 or LATER. What it really says is that they foresee stumbling blocks to getting agreement on allowing the impacts of this river-killer with the public agencies charged with protecting the Connecticut River ecosystem. It’s being negotiated on their watch. They are responsible for defending our so-called, “S.O. Conte Connecticut River National Fish and Wildlife Refuge,” our ‘only’ “National Blueway”–and what remains today our drop-dead-deadly, ‘nation’s best landscaped sewer’ right here in Massachusetts.

It is the PEOPLES’ voices that are doing this by writing and filing with FERC:
Go to: www.ferc.gov; then to “Documents and Filings”; then click on the “Quick Links” tab for FERC Online on the right; and then to “eComment” on the page that opens. Follow directions for “Hydroelectric License/Re-license Proceedings (P – Project Number),” and BE SURE TO use Northfield’s FERC project number, P-2485, to enter your comments.

This is THE PUBLIC’S RIVER! It deserves to LIVE. And, it deserves a real WATCHDOG– YOU!! Thanks to all for raising your voices.

ALSO, this new podcast with OCCUPY THE AIRWAVES on Valley Free Radio:
https://archive.org/details/occupy-the-airwaves-1.17.2022-karl-meyer

BELOW are the latest citizen filings with the Federal Energy Regulatory Commission:

Document Accession #: 20220207-5017 Filed Date: 02/07/2022
Pat Graves, South Deerfield, MA.

Many things have changed in recent years. I urge that no relicensing of
FirstLight’s Northfield Mt. Pumped Storage Station take place without
careful consideration of the benefits and harms. At this time it appears
that the harms far outweigh the benefits.

Document Accession #: 20220207-5014 Filed Date: 02/07/2022
Anne Naughton, Shelburne Fls, MA.

Hello,
Please DO NOT renew Firstlight’s lease on the Northfield Mountain Pumped
Storage Project, P-2485.

The Connecticut River is not replaceable. We can get electricity from other,
less destructive sources.

Sincerely,
Anne Naughton
Shelburne Falls, Massachusetts

Document Accession #: 20220204-5174 Filed Date: 02/04/2022
Wayne Pleasant, Turners Falls, MA.
Feb 4, 2022
REF: P-2485 FirstLight vs River Wildlife

Dear FERC
Please deny the license for the Northfield pumped storage system. I have lived on the CT river all my life and have seen first hand the incredible damage that they do to our river.

The system is not “Green Energy.” It consumes more energy that it produces. It is only used for making more money for FirstLight and not to benefit consumers and the environment. It severely damages the shoreline by raising and lowering the water level and thus associated wildlife.

It causes unnatural waterflows that damages and compromises the river environment for endangered Short Nosed Sturgeon.

Sucks up and kills large and small fish through its turbines. No proposed net will stop small fish and associated eggs from being sucked up and killed.

NOTE: If I were to kill this many fish every day I would be arrested for violating protected species rules.

Please do not issue a license to this facility to kill more wildlife.

Thank you,
Wayne
(** NEW filings continue below **)

Document Accession #: 20220204-5027 Filed Date: 02/04/2022
James Terapane, South Deerfield, MA.

I am writing regarding P-2485 Northfield Pump Storage re-licensing process. First off, I am, with many other local citizens, opposed to re-licensing this facility as it currently operates. The disruption of the CT. River ecosystem that this and other First Light Hydro facilities create is
unacceptable.

I demand that FERC allow for public comment as required by Massachusetts DEP review of the re-licensing so that all information related to this process be presented to the public and the citizens of United States be heard. Let’s not forget that First Light is a foreign owned entity whose interests are not necessarily in line with ours, the American Citizens who’s river resources are being borrowed for profit.

We citizens of the Connecticut Valley have worked hard to protect and use our rivers in a sustainable manner and will continue to do so. The idea of the facility being used as a “battery” is a clever pitch but we don’t buy it, not at the cost of the continuing destruction the river ecology. Please don’t cloak this crude way of using the river as “Green”. What is being done to our river is anything but Green Thinking.

Now is the time for bold solutions that secure a reliable power source AND protect our environment. I urge First Light Company, if they must have their battery, to use what ever innovative brain power they have in their company to solve this problem of river and fish destruction otherwise you are not welcome to use our resources.

The people of this region have brought forth many innovative problem solving ideas and pioneered the American Hydro power industry so I urge the managers of First Light to step up to the plate and address how to solve this problem. If they don’t have any ideas we can help them out.

Document Accession #: 20220204-5025 Filed Date: 02/04/2022
Wendy Sibbison, Greenfield, MA.

I oppose the relicensing of the Northfield Mountain Pumped Hydro Storage Station because its immediate and long-lasting harm to the ecology of the river and to its living inhabitants outweigh “both in ethical and economic terms” any benefit to the public of FirstLight’s plan to transport and store energy, far from its source, for later generation at a net energy loss.

AND BELOW ARE DIRECT EXCERPTS FROM FirstLight’s most recent filing with FERC, and–further below that, from Great River Hydro’s filing noting that it is being held back in their relicensing of their non-lethal, Vermont river facilities due to the successive delays requested by PSP Investments-owned, FirstLight at Northfield.

Document Accession #: 20220131-5365 Filed Date: 01/31/2022
Alan Douglass Regulatory Compliance Manager

“FirstLight continues to discuss fish passage, minimum stream flows, and project operational issues with federal and state resource agencies, and certain non-governmental organizations. FirstLight and the agencies have reached conceptual agreement on minimum stream flows, upstream and downstream fish passage facilities, and certain operational measures. The parties are continuing to make progress on the remaining operational measures, at which time they intend to execute an AIP.”

“In light of the significant progress of FirstLight and the relicensing participants in achieving conceptual agreements, FirstLight requests that the Commission continue to defer issuance of its Ready for Environmental Analysis (REA) Notice until after February 28, 2022. FirstLight anticipates requesting the Commission to further defer the REA Notice until after June 30, 2022, to allow the parties time to negotiate a comprehensive, binding settlement agreement that aims to fully resolve all relicensing issues.”

Alan Douglass
Regulatory Compliance Manager

Great River Hydro’s VERNON DAM facilities and its non-lethal fish passage for migrating fish in New Hampshire and Vermont.

BELOW, is text excerpted from GRH’s FERC filing:

Document Accession #: 20220203-5098 Filed Date: 02/03/2022
John L. Ragonese
FERC License Manager
Great River Hydro, LLC

“In the most recent status report, FirstLight Licensees announced conceptual agreements with a number of relicensing participants on several key issues and that they were close to reaching agreement on other key issues. The filing asks the Commission to further defer issuance of the REA Notice until after February 28, 2022, to allow relicensing stakeholders to reach agreements in principle. It also suggests that they intend to request the Commission further delay issuance of the REA Notice until after June 30, 2022, to allow for the development of a binding settlement agreement that the parties. GRH anticipates the Commission would reasonably hold off issuing the REA Notice for at least six months, in order to consider an executed settlement agreement between FirstLight Licensees and stakeholders as a preferred alternative in an amended application.”

“At this point in the process, however, there is no reason for the Commission not to issue the REA Notice for the GRH Projects. Even if the Commission further defers the REA Notice for the FirstLight Projects for another six months, it can still prepare a multi-project environmental impact statement for all five projects.”

“GRH has consulted with federal and state fishery and water quality agencies, and we are authorized to state their support GRH’s request for the Commission to move forward.”

Sincerely,
John L. Ragonese
FERC License Manager

CONSENSUS BUILDS AGAINST RELICENSING NORTHFIELD MTN: YOU CAN STILL BE HEARD!!!

Posted by on 06 Dec 2021 | Tagged as: Andrew Tittler, Connecticut River, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, E-Comments, Federal Energy Regulatory Commission, federal trust fish, FERC, FERC Secretary Kimberly D. Bose, FirstLight Power, Greenfield Recorder, Julie Crocker, MA Division of Fish and Wildlife, Massachusetts DEP, Massachusetts Division of Fish & Wildlife, Mr. Jesse Leddick, Mr. Mark S. Tisa, National Marine Fisheries Service, Northfield Mountain, Northfield Mountain Pumped Storage Station, P-2485, PSP Investments, public trust, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, The Daily Hampshire Gazette, US Fish & Wildlife Service, Wendi Weber


GREENFIELD MA. November 30, 5:58 am: River protector Dave Dersham of Northampton MA sets out on a 20 mile hike from Greenfield to deliver a “No License to Kill” message to the US Fish & Wildlife Service at their Hadley HQ. Photo Copyright © 2021 by Karl Meyer

YOU CAN STILL BE HEARD!!!!!

*BE PART OF THE “SAVE OUR RIVER” HOLIDAY CAMPAIGN: READ BELOW!*

Public demonstrations, public comments to the Federal Energy Regulatory Commission, and opinion pieces in the media all point to a gelling opposition to any FERC relicensing of FirstLight’s Northfield Mountain Pumped Storage Station. The coalescing opinions cite Northfield’s lethal impact on fish, it’s massive river-reversing ecosystem destruction–plus the profit motives of its Canadian venture capital owners. (* *See the 3 new public comment letters posted by FERC today, 12/06/2021, at the end of this message.)

Last Thursday, December 2, FirstLight gathered behind closed doors with the US Fish and Wildlife Service, National Marine Fisheries, MA Division of Fish and Wildlife, MA Department of Environmental Protection and American Whitewater in what the Canadian-owned company termed “final” settlement negotiations. There was no daylight for the public to bear witness, and no way to know how far they reached toward a final signing agreement on relicensing this disaster or ending heart-stopping ecosystem flow reversals and inhalation of 100s of millions of fish.


RECEPTION at USFWS HQ, Hadley MA, November 30, 4 pm. Photo Copyright © 2021 by Karl Meyer

What’s certain is the big horse-trading was on the table–with our public trust agencies holding our cards in the form of standing up for long-established environmental law and the ecosystem defense that future generations are counting on. Our River, our Refuge, OUR FISH!

Well it ain’t over till it’s over folks! Certainly there are issues not yet fully vetted, emails being exchanged, and last minute changes in the works from the agencies and FirstLight/PSP Investments’ big lawyers.

IN SHORT, nothing has been signed yet!

There remains time to get your comments in to the media, your public trust federal/state agency representatives (emails below), to FERC (address below), and cc’ed to your representatives—all of which are impactful.

HERE IS WHY: in FirstLight’s own words & schedule, filed with FERC November 12, 2021.

“FirstLight MA Hydro LLC submits request for FERC to delay issuance of Ready for Environmental Assessment Notice under P-1889, et al.”

AND, word-for-word, FirstLight’s Timeline to FERC:

“December 2021/January 2022 – parties schedule meeting or meetings of combined groups (fish/flows and recreation/cultural) to discuss overlapping issues. Parties provide status update to the Commission no later than December 31, 2021.

January 2022 – parties work toward achieving a conceptual agreement that can be filed with the Commission on or about January 31, 2022.”


At US Fish & Wildlife HQ, Hadley MA. Photo Copyright © 2021 by Karl Meyer

WHICH is to note FirstLight’s sending the settlement outline “to the Commission no later than DECEMBER 31, 2021.”

THUS, if you make your public statement NOW–ahead of when everyone heads home for the holiday break, you can impact this secret, looming train wreck and help make a difference for future generations. Northfield Mountain has been a half century long disaster. You have the information. Short, concise comments—-to the media, cc’ed to your public trust agency officials, and sent as comments to FERC is what matters NOW. There are 3 new public comments shared below.

Directly below are the federal and state department heads and the public trust officials with long-term seats at the negotiating table:

wendi_weber@fws.gov, Director Region 5 US Fish & Wildlife Service; andrew.tittler@sol.doi.gov, lead council at the table for USFWS; melissa_grader@fws.gov, at the table for our migratory fish; julie.crocker@noaa.gov, National Marine Fisheries Service Endangered Fish Recovery Branch Chief (endangered sturgeon); william.mcdavitt@noaa.gov, at the table for our migratory fish; mark.tisa@state.ma.us, Director of the Division of Fisheries and Wildlife, jesse.leddick@state.ma.us, Chief of Regulatory Review MA Division of Fisheries & Wildlife.

SEND them your Letter; forward it to the MEDIA for the public record—and…

THEN, file it with FERC for the OFFICIAL LICENSE RECORD.
Here’s the final step: TO FERC:

Go to www.ferc.gov . Go to Documents and Filings, or simply find the “file E-Comment” link if you see it. Once there, make sure you have this official number for Northfield Mountain Pumped Storage Station, and USE IT. “P-2485.” In E-Comment you are filing comments under Hydro, in the Washington DC office, c/o FERC Secretary Kimberly D. Boles–and that FERC Project number, again is P-2485. Write in your comments and then hit send. DONE!

THIS ONE IS NEW TODAY! Followed by the 3 filed over the weekend:

Document Accession #: 20211207-5027 Filed Date: 12/07/2021

Mike Cournyn, Sudbury, MA.
Please reject the application for this license. It is hard to express how wrong this system is on so many levels. It is even harder to try and justify usefulness. More power is USED than is CREATED. The death and disruption of the ecosystem for a few dollars profit. I am amazed it was even allowed inthe first place. Please do the right thing.

Document Accession #: 20211206-5059 Filed Date: 12/06/2021

Malcolm G Everett, NORTHAMPTON, MA.
I am writing to express my deep concern about the impact of the Northfield Mountain Pumped Storage Facility on the ecosystem of the Connecticut River. I believe the damage this system causes to species native to the river justifies the non-renewal of its license to operate. I understand it is viewed as a way to meet peak electricity demand, but I think there are better
ways being developed to solve this problem without causing damage to the life forms in the river. The owner of this facility has no right to cause such damage to the delicate systems of life that have evolved long before the facility existed. Thank you for considering my concern.

Document Accession #: 20211206-5009 Filed Date: 12/06/2021

C Grecsek, SUNDERLAND, MA.
I am writing to express my opposition to the re-licensing of the Northfield Mountain Pumped Storage facility. The system costs in energy, and especially in ecological damage, are too high.

The Connecticut River flows backward when the pumps are engaged, an unnatural and harmful process. In addition, the turbines kill countless fish and other river dwellers. The generation of electricity should not need to use so much energy to operate nor should it result in such senseless destruction of an ecosystem.

We have made great strides in the improvement of the Connecticut River from when it was essentially an open sewer, but there is more work to do to repair the harm we have caused, including the cessation of this damaging system.

Thank you

Document Accession #: 20211206-5008 Filed Date: 12/06/2021

robert arbib, cummington, MA.
Please reject the application of Firstlight to operate Northfield Mt.for another 50 years.This pumping station causes terrible disruption of the natural flow of the Connecticut River.I know as I canoe on this section of the river. Natural flows necessary for the life cycles of various vertebrates and invertebrates are disrupted, fish and other animals are shredded going up
through the pumps,the flow of the river is reversed during pumping and shallow areas are washed out and eroded as water is released.Firstlight will say they are addressing these concerns but they will promise anything to get a renewal. Please don’t believe their B.S,

Their model is to use massive amounts of power to pump water up. only to profit through ‘generation’ when rates are higher, It is not worth the damage to the river to generate not really new power but only profits for this Canadian company.

Photo Copyright © 2021 by Karl Meyer

The Connecticut River still “America’s best landscaped sewer” in Massachusetts

Posted by on 12 Oct 2021 | Tagged as: America's best landscaped sewer, Connecticut River, Connecticut River clean up, Connecticut River ecosystem, Connecticut River Refuge, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, Death-Sewer, Delaware LLC, Federal Energy Regulatory Commission, FirstLight, FirstLight Power, ISO-NEW ENGLAND, MA Department of Energy and Environmental Affairs, net-loss power, Northfield Mountain, Northfield Mountain Pumped Storage Station, PSP Investments, source to sea, Turners Falls, US Fish & Wildlife Service, USFWS

The Connecticut River still “America’s best landscaped sewer” in Massachusetts Copyright © 2021 by Karl Meyer

Citizens standing against relicensing the river-killing Northfield Mountain Pumped Storage Station in Massachusetts on October 9, 2021. Photo Copyright © 2021 by Karl Meyer

Something is deeply wrong on the Connecticut River in Massachusetts. That something is secrecy, obfuscation, and public agencies pointedly ignoring the forest for the trees. For 49 years the Northfield Mountain Pumped Storage Station has been the number # 1 ecosystem disruptor and fish predator in the 4-state river system comprising today’s S.O. Conte Connecticut River US Fish and Wildlife Refuge.

So grim is this machine’s daily impact that it literally obliterates 100s of millions of fish and aquatic animals annually–consuming the river’s aquatic life via giant turbines that actually pull the river backward for miles and flush all that river life uphill into Northfield’s 4 billion gallon Death-Sewer each day. It’s an energy-squandering electricity resale scheme that is today netting Canadian venture capital firm PSP Investment wads of tax-sheltered cash via limited liability registration in the State of Delaware.

Thus, despite what’s been grandly touted in massive yearly hype for EXACTLY 25 INDIVIDUAL SATURDAYS since 1996, proclaiming a “cleaned-up river”–the Connecticut remains the grim, stilled, reversed and deadly, daily flush-sink it has been in Massachusetts for ALL of the NEARLY 18,000 DAYS of it’s operation since 1972.

Photo Copyright © 2021 by Karl Meyer

The grand irony of this massive ecosystem crime is that MA Department of Energy and Environmental Affairs and Holyoke-based ISO-New England whole-heartedly support the continued use of this FirstLight-branded, net-power loss, ecosystem killer in a Federal Energy Regulatory Commission relicensing scheme that will last for decades. Meanwhile the Bay State has been home to the Connecticut River Watershed Council since 1952–as well as its quarter century of cleanup hype, while the US Fish & Wildlife’s Northeast Regional Headquarters (just 25 miles from Northfield in Hadley), has done nothing to shut the giant sucking mouth of Northfield Mountain’s death trap across their River’s quarter century as a US FISH & Wildlife Refuge

So in case you were wondering why these out-standing people are situated above the deadened Connecticut River and look content and happy to be doing something about it–these are the folks making a stand for a living ecosystem for the generations to follow. They are the people who never swallowed the Kool-Aid.

Connecticut River blog: portage parade a quagmire of mixed motives

Posted by on 15 Jul 2021 | Tagged as: Andrew Fisk, Bellows Falls VT, Connecticut River Atlantic Salmon Commission, Connecticut River Conservancy, Connecticut River ecosystem, Connecticut River Watershed Council, Conte National Fish & Wildlife Refuge, CRASC, CRC, Dead Reach, Deerfield River, Eversource, FirstLight, FirstLight Power, Landmark Supreme Court Decision 1872, New Hampshire, Northeast Utilities, Northfield Mountain Pumped Storage Project, NU/WMECO, portage parade, PSP Investments, public trust, Rock Dam, Silvio O. Conte Connecticut River National Fish and Wildlife Refuge, State of Delaware, Turners Falls, United State Supreme Court, Vermont

Connecticut River blog: portage parade a quagmire of mixed motives.

Copyright © 2021 by Karl Meyer


It was a little four-boat affair at Turners Falls on July 10, 2021. Photo Copyright © 2021 by Karl Meyer

On Saturday, July 10, 2021, Dr. Andy Fisk, Chair of the Connecticut River Atlantic Salmon Commission (CRASC), stood alongside a lawyer on the banks of the Connecticut River in the Village of Turners Falls in Montague MA. That lawyer was not an employee of the Connecticut River Conservancy, which Fisk also directs (that 69 year old organization has never had a staff lawyer), and this was not a gathering about salmon (the last natural run of salmon occurred on the Connecticut in 1809), or any of the endangered or federal trust fish in this tiny, embattled ecosystem reach they were here to highlight. The Connecticut River Watershed Council (today d.b.a. The Connecticut River Conservancy) had brought along Bob Nasdor of American Whitewater. That recreation organization’s crash-helmet-attired attorney and legal advocate was here as part of a CRC press conference and their touted public “portage parade.”

This, just upstream of the Turners Falls Dam, was an event aimed at getting scheduled flow releases from Canada-own FirstLight, and more water, plus an easy access path past the dam for joy-riding paddlers and rafters seeking a chance to dive into the most impoverished, endangered, historic and biologically sensitive 2-1/2 miles in the entire Connecticut River ecosystem.

As parades go, it hardly made a splash. Ultimately around two dozen people assembled, though fully half were CRC staff, family members, and CRC’s handful of invited speakers. The other speakers included Walter Ramsey, planner and conservation agent for the Town of Montague, as well as representatives of the Appalachian Mountain Club, American Whitewater and All Out Adventures. Three CRC staff were recording the event for further promotion. In reality about a dozen members of the public showed up to the “parade”, plus two journalists.


Revving up the “crowd” at Turners. Photo Copyright © 2021 by Karl Meyer

Funny thing–to prioritize commerce and recreation at a site that has been a half century without healing water, one that represents the epitome of historically fragile and endangered habitat. Strange bedfellows, these. Montague’s conservation agent was one more case in point. He noted that the town gets 20% of its tax revenue from Canada-owned, Delaware-registered FirstLight Power, so he wouldn’t want to see more water being returned to the impoverished Connecticut because that would mean less water diverted down the Turners Falls power canal–and less returned tax cash from their Delaware tax-sheltered, FirstLight LLC corporate absentee landlords/neighbors.

On the other hand, Ramsey noted, he is desirous of the economic bump a tourist town gets by drawing-in traffic for water sports. Those big, partying, river-running crowds so often filling the channels and pull-offs on the Deerfield mean big tourist dollars. What could be better?

In that vein though, there was no mixed message or hesitation at all on the part of the paddle-packing Bob Nasdor. He told those assembled that he sees access to this short river stretch that features one single, tiny rapid (incidentally it’s at precisely the shortnose sturgeon’s fragile and crumbling habitat and nursery) as a “tremendous opportunity”–naming the big commercial rafting outfits over on the Deerfield as well as people arriving for “tubing” as parties that have an eager interest in accessing the river here. This despite expert commentary from shortnose sturgeon biologist Dr. Boyd Kynard already in the FERC record stating that watercraft pose a danger to spawning and developing sturgeon here at their Rock Dam habitat.

As a journalist I thought this publicized press event would be a real opportunity to ask about why CRC had taken no action concerning the clearly dissolving Connecticut riverbanks just downstream in the critical and sole documented natural spawning site of the shortnose sturgeon. Its fragile nursery environs are at a tiny place in the river called the Rock Dam. Those failing Connecticut River banks are owned by FirstLight Power, and adjacent to their power canal.

So it seemed a good question to get an answer to with the public present: was it because CRC has no lawyer?–or because they accept money from the MA Department of Environmental Protection?—that they’ve wholly avoided the site and taken no action, never sought an injunction or tested water or intervened as members of the Connecticut River Streambank Erosion Committee?


Here are the dissolving, slumping–sink-hole deepening Connecticut River banks at the Rock Dam site on the day of the “portage parade,” July 10, 2021. Photo Copyright © 2021 by Karl Meyer

Ironically, this line of questioning was in nearly the exact same vein as the questions I’d put to Andy Fisk a half decade ago. That was when they decided to hold a discussion in Brattleboro, Vermont about river recreation access–including the all-but-asphyxiated Dead Reach of this Rock Dam river section, where shortnose sturgeon have been annually crippled in successful spawning in their ancient, critical habitat and fragile nursery site for a half century. My questions were not welcome back then either.

This day Director Fisk simply claimed that CRC was taking action. He clearly did not wish to go into any particulars answering in front of the handful of public paraders. He seemed quite rushed, all of a sudden. When I pressed him on several areas of exactly where that action was, and a long timeline where no action whatsoever has been taken, he ended my queries and put the mike down. Unbeknownst to me, a live-feed was being streamed by CRC and it was abruptly shut down when I began my questioning. I heard about this later.

Once the crowd moved away he walked up to reengage–but my questions remained the same, and his responses revealed no on-the-ground action at this critical site. Actually, CRC has filmed and promoted themselves everywhere in this little 2-1/2 mile reach BUT at the dissolving riverbanks and dewatered critical sturgeon habitat on this river. There are videos of a sea lamprey cookout and a swimming hole celebration nearby—plus a big celebration of baby lamprey rescues in the power canal. Now there’s some low hanging fruit protecting a fish that will likely survive Armageddon. But never have they ever brought a parade of people down to that fragile Rock Dam site and filmed them with a backdrop of dissolving Connecticut River banks and baking cobbles where young-of-the-year endangered shortnose sturgeon should be developing.

It’s not hard to find CRC OPINIONS delivered to federal and state entities on a whole host of river issues. They send in all sorts of formal comments. But please, don’t call them a watchdog. Watchdogs inspire fear in companies and public agencies when they break laws or fail to enforce them. They take action. They have hungry, day-to-day staff lawyers–and their missions state clearly: we investigate, we enforce; we go to court–we sue corporations.

CRC gets lots of grant funding from the very agencies they should be forcing to do their jobs. So, don’t look for action there. And, of course, they have an endless legacy going back to their beginnings as close friends and recipients of monies from WMECO/Northeast Utilities, (d.b.a. Eversource) who built the crippling facilities that today dominate this miserable stretch of river. Join the annually major-sponsored Eversource-to-sea clean-up…!

Eversource remains massively—commercially, wired into today’s FirstLight river-crippling facilities at both Northfield and Turners Falls, both parent-owned by PSP Investments of Canada. These facilities trample the key ecosystem functions of New England’s Great River in the heart of the Silvio O. Conte Connecticut River National Fish & Wildlife Refuge all the way from Greenfield and Turners Falls MA to Bellows Falls VT and Walpole NH. Both facilities remain in violation of the landmark environmental 1872 decision of the US Supreme Court—based just downstream on this river in Holyoke Company v. Lyman. It ruled that migratory fish must be provided safe upstream and downstream passage on this and all US rivers. Here, that means all the way up to central Vermont and New Hampshire–and back.

Canadian venture capital outfit PSP/FirstLight Power is playing for keeps. They arrived here to run the giant river and energy-sucking, net-power-loss operations at Northfield Mountain and the smaller Turners Falls ops for long-term cash a full 144 years after the Supreme Court made those critical protections the law of this land . But, judging by priorities here, it seems those foreign venture capitalists have come to the right US river system…

This was an extremely small parade.

Living rivers come first.

Be careful what you wish for…

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

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


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer


PHOTO Copyright © 2021 by Karl Meyer

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

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

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

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

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

Dear Ms. Bose,

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

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

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

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

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

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

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

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

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

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

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

Sincerely,
Karl Meyer, MS Environmental Science

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

GREAT CONNECTICUT RIVER SURVIVAL WALK DRAWS BIG MULTI-STATE CROWD

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

GREAT CONNECTICUT RIVER SURVIVAL WALK DRAWS BIG MULTI-STATE CROWD

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

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

THE DAY’S SPEAKERS BEARING WITNESS

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

WHERE THE RUBBER NEVER MET THE ROAD

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

THE LEGACY OF FAILURES

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

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

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

Photo Copyright © 2021 by Robert Flaherty All Rights Reserved.

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

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

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

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

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

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

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

RUNNING BACKWARD FOR DECADES

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

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

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

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

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

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

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

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


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

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

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

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

This machine is a crime against nature.

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

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

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

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

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

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

RESPONSIBLE FOR SECURING A LIVING RIVER FUTURE FOR OUR KIDS:

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

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

Justice for New England’s Embattled River

Posted by on 22 Mar 2019 | Tagged as: American shad, Anadromous Fish Conservation Act, Bellows Falls, Bellows Falls VT, Cabot Station, Canada, Connecticut River, Connecticut River ecosystem, Conte National Fish & Wildlife Refuge, Endangered Species Act, Federal Energy Regulatory Commission, FERC, First Light Hydro Generating Company, FirstLight, Greenfield Recorder, Holyoke Dam, MA Division of Fish and Wildlife, National Marine Fisheries Service, New Hampshire, Northfield Mountain, Northfield Mountain Pumped Storage Project, Northfield Mountain Pumped Storage Station, PSP Investments, Public Sector Pension Investments, shad, shad fishing, Society of Environmental Journalists, Treasury Board of Canada, Turners Falls, Turners Falls dam, United State Supreme Court, US Fish & Wildlife Service, US Fish and Wildlife Coordination Act, Vermont


Above: FirstLight’s sign along Greenfield Road in Turners Falls MA highlighting their historically combined operations with the Northfield Mountain Pumped Storage Station. Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (CLICK, then click again to enlarge).

NOTE: an edited version of this piece appeared in The Greenfield Recorder on March 20, 2019, www.recorder.com .

Copyright © 2019 by Karl Meyer. All Rights Reserved.

Justice for New England’s Embattled River

In a shockingly-belated move on December 20, 2018, Canada’s FirstLight Hydro Generating Company petitioned the Federal Energy Regulatory Commission for “expedited consideration” of their last minute request to transfer the licenses of its Northfield Mountain and Turners Falls Projects on the Connecticut River into separate LLC holding companies. They further requested the just-minted corporations be substituted as the new license applicants in the ongoing federal hydro relicensing process, begun here in September 2012. FirstLight is wholly owned under the Treasury Board of Canada as Public Sector Pension Investments, a venture capital corporation.

For over half a decade stakeholders including the US Fish & Wildlife Service, the National Marine Fisheries Service, MA Division of Fish & Wildlife, and nearly a dozen assorted stakeholders and town governments have been meeting and negotiating with a single entity, FirstLight Hydro. All have been working toward a FL-requested single new license—one mandating river protections for the synchronized generating operations of Northfield Mountain and Turners Falls/Cabot Station along 10 miles of the Connecticut.

FL’s petition arrived just eight days after they’d quietly reregistered their conjoined operations in the State of Delaware as two separate, new, “limited liability” corporations—asking FERC to substitute their new LLCs as applicants for separate licenses.

FirstLight’s “expedited” request came just two days before stakeholders including the USFWS and National Marine Fisheries Service–agencies with “conditioning authority” in this relicensing, were sidelined by the government shutdown. FL wanted a decision no later than February 28th. Fortunately FERC extended the deadline. A decision is now expected by March 28th.

Turners Falls Dam crippled this ecosystem the day it was completed way back in 1798. Controlled for decades from a room inside the Northfield Mountain, it continues enabling crushing impacts on this four-state ecosystem artery, namesake of the Silvio O. Conte Connecticut River National Fish & Wildlife Refuge. New Englanders have long-awaited their rights to their River. Yet Massachusetts, Vermont and New Hampshire all remain essentially without upstream and downstream fish passage and protections at Northfield and Turners Falls—required of owners of all federally-licensed dams in the United States since the landmark Supreme Court decision in Holyoke Company vs. Lyman since 1872.

That landmark ruling should have dramatically changed conditions here beginning on April 30, 2018, when the current license for the NMPS—controller of Turners Falls dam, expired. But a new license has yet to be signed; and FERC has since extended the current license. Still, any corporation–foreign or domestic, must comply-with protections under the Anadromous Fish Conservation Act, the Endangered Species Act, the US Fish and Wildlife Coordination Act and Clean Water Act, among others.

Results from a Connecticut River study released last June by the US Fish & Wildlife Service and MA Fisheries & Wildlife estimated that 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.

NMPS sucks the river’s aquatic life into its turbines for hours at a time at 15,000 cubic feet per second–killing virtually everything it inhales. For two years running, NMPS consumed 33% more virgin power from the grid than it later returned in peak-priced, second-hand bursts. Though it can regenerate pulses of up to 1,100 megawatts for 6-8 hours—once emptied of its deadened reservoir waters, Northfield is virtually dead itself, and must begin sucking new virgin power from the grid, shredding more life.

Recent studies find that 80% percent of the shad tagged in the lower river and later recorded passing Holyoke Dam were again recorded reaching the Turners Falls project, some 35 miles upriver. They were still heading upstream. Holyoke has passed an average of 316,000 shad upstream annually since 1976. During that time, just 1-in-10 shad ever swam beyond the miseries created via Turners Falls Dam. Over 250,000 of this ecosystem’s shad are likely turned away annually on the doorstep to Greenfield, Montague, Gill, Millers Falls, Erving and Northfield—barred from the rest of New England all the way Bellows Falls VT as well.

In 2017, the 2nd biggest shad run ever passed Holyoke Dam: 537,000 edible, catchable fish. Fewer than 49,000 passed Turners Falls.

So perhaps it’s time to remind our Canadian-FirstLight guests—recently reregistered in Delaware, that when they purchased some hardware and hydro assets in Massachusetts nearly three years back, they didn’t purchase New England’s great river. They merely bought rights to lease some of our river’s water until the current federal license expired on April 30, 2018. After that time, how much, how often–and at what cost they might continue to operate via a new leased portion of some our river’s flow would be subject to all the laws and regulations of the United States and those of the Commonwealth of Massachusetts.

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.

NOTE: the piece below appeared at www.vtdigger.org in January.

Karl Meyer: Connecticut River dam owners pulling a fast one

FirstLight PSP Investments makes 12th hour move to divide CT River hydro assets

Posted by on 08 Jan 2019 | Tagged as: Connecticut River, Connecticut River shortnose sturgeon, Conte National Fish & Wildlife Refuge, FERC Commissioner Neil Chatterjee, FERC licensing process, FirstLight, NMFS, Northfield Mountain, PSP Investments, Relicensing, Rock Dam, US Fish & Wildlife Service

Below is the text of a formal Protest lodged with the Federal Energy Regulatory Commission on January 7, 2019. All comments and protests are due in this FERC request by January 15th–coming at a time when key relicensing stakeholders including the National Marine Fisheries Service and US Fish and Wildlife Service are on furlough and unable to Comment…

Public comments to FERC in Washington DC on this proposal for these two “hydro” projects cited as: “P-2485” Northfield Mountain, and “P-1889” Turners Falls Project, can be entered at www.ferc.gov under “documents and filings” using their e-comment button on the menu. NOTE: You MUST include your NAME and contact info at the end of your comments.

Photo above is of the flow-starved Connecticut River at the Rock Dam in Turners Falls, critical spawning habitat for the federally endangered shortnose sturgeon, and a key upstream passage route for spawning run American shad. It was taken on May 13, 2018, at the exact time shortnose sturgeon require flow at this ancient site. The river is impoverished here by flows diverted at Turners Falls Dam, controlled by operators inside Northfield Mountain, a half dozen miles upstream. (NOTE: click, then click again, and AGAIN to enlarge photo. Photo Copyright 2018 by Karl Meyer. All Rights Reserved)

Karl Meyer, M.S. Environmental Science
91 Smith Street # 203
Greenfield, MA, 01301
413-773-0006 January 7, 2019
karlmeyer1809@verizon.net

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

PROTEST re: P-2485 and P-1889, to the UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION.

Specifically, the FirstLight Hydro Generating Company, Project No. 2485- Northfield Mountain LLC) APPLICATION FOR APPROVAL OF TRANSFER OF LICENSE, SUBSTITUTION OF APPLICANT, AND REQUEST FOR EXPEDITED CONSIDERATION; and FirstLight Hydro Generating Company, Project No. 1889, FirstLight MA Hydro LLC ) APPLICATION FOR APPROVAL OF TRANSFER OF LICENSE, SUBSTITUTION OF APPLICANT, AND REQUEST FOR EXPEDITED CONSIDERATION

Dear Secretary Bose,

I write to protest the request of FirstLight Hydro Generating Company for transfer of license, substitution of applicant, and request for expedited consideration filed with the FERC on December 20, 2018 for these two FirstLight Hydro Generating Company projects. I have been a participating Stakeholder in the FERC ILP relicensing proceedings for P-1889 and P-2485 since 2012. I serve on the Fish and Aquatics Studies Team for both projects and have been in attendance with fellow Stakeholders at all relevant FERC ILP meetings and consultations since that time.

Since its initial application in 2012, FirstLight has requested that all aspects of this ILP be predicated on its desire and application for a merged, single license for the Turners Falls and Northfield Mountain Projects. That requested configuration and understanding for license conditioning and requirements was thus accepted by all parties from the outset. FL’s formal submission was met with few objections. It has been the de facto understanding of all Stakeholders–and FERC, since the ILP process began over 6 years ago. Since that request in their initial filings, all parties have worked in good faith under their requested parameters, largely because of the common understanding that these operations have always been integrated.

Both FL projects operate and are controlled from a central location, in tandem, coordinating their adjacent peaking production units along a short, eight mile section of the Connecticut River. They have been running, thus, as a single entity for a quarter century. As witness to how the projects are a coordinating unit, Anne Harding, Compliance Administrator for FirstLight Power Resources wrote in the November 1, 2016, issue of HydroWorld, “The Northfield Mountain control room operators began to remotely operate the units at Cabot Station in the 1990s. In addition, the bascule gates on Montague Dam and head gates at the gatehouse are operated from Northfield Mountain.” (See https://www.hydroworld.com/articles/hr/print/volume-35/issue-9/articles/62-mw-cabot-station-retains-much-of-its-1916-equipment.html ) Hence, this eight mile reach of river is indeed the single, integrated unit that FirstLight applied for a single, new ILP license for back in 2012.

Given these facts, and that all relicensing studies and consults have been predicated on their formal application requests through a process that has stretched over more than half a decade, it would be improper—and likely legally suspect, to change all the parameters of these highly regulated FERC ILP procedures at this time. If FERC were to allow this request, Stakeholders would thus have to undertake new studies under new operational assumptions, and ultimately have to enter into two-track negotiations with two separate, new entities–if new settlement agreements were to be undertaken. Most confounding at this late date—half a year after the current licenses have had to be extended, all ILP studies would have to be re-evaluated, or redone, in terms of different parameters and assumptions, stemming from FL new contentions that their coordinated operations are separate, unlinked entities.

This is a highly suspect maneuver. It smacks of bad faith bargaining since the time Canada’s PSP Investments purchased these FL projects in 2016. Further, witness that FirstLight’s Mr. Doug Bennett, Plant General Manager, Northfield Mountain/Turners Falls Projects. made a request of FERC Commissioner Neil Chatterjee (as well as now-disgraced former EPA Chief Scott Pruitt) to discuss a trio of issues that could impact FirstLight’s future market prospects under a new license back on January 30, 2018. Both officials were later to visit in tandem on February 14, 2018–but FERC first had to respond and make an obvious point in response to Mr. Bennett on January 30, 2018, noting that acceding to these requests would violate FERC ex parte rules, and Commissioner Chatterjee could hence not discuss any of the proposed topics.

At this late stage in the ILP process, good faith and procedure would dictate that FERC now reject FirstLight Hydro’s request to reconfigure this monolithic relicensing to their unfounded contention that these are not a single, integrated entity—one intricately coordinated to maximize output and profitability along an 8 mile segment of the Connecticut River.

Further, due to the current partial Federal Government shutdown, key federal agencies, experts, and Stakeholders are on furlough, and cannot participate or weigh-in on the merits of this 12th hour request. You cannot expedite a process when the participants are barred from the proceedings.

I thus formally protest FirstLight’s requests to separate this singular operation into two individual LLCs, and ask that FERC deny the transfer of these licenses at this time; and deny any substitution of new applicants until this ILP is complete. Further, I contend that any request for expedited consideration is unwarranted and patently unsupportable given the absence of key stakeholders. Unites States federal Endangered Species Act, Clean Water Act, federal trust fish, and inter-agency coordination statutes are integral to this ILP on a four-state river that is the centerpiece of the Silvio O. Conte National Fish and Wildlife Refuge. These laws and tenets must be respected and abided-by wherever international ownership comes into question.

Lastly, I formally request Intervener Status in FERC P-2485 and P-1889 at this time.

Thank you for your careful attention to these matters.

Sincerely,
Karl Meyer, M.S.
Cc: Marc Silver, FirstLightpower

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