Relicensing

Archived Posts from this Category

A Connecticut River return to the bad old days?

Posted by on 18 Oct 2020 | Tagged as: American shad, Cabot Woods, Clean Water Act, Connecticut River, Connecticut River Conservancy, Connecticut River riverbank failure, Connecticut River shortnose sturgeon, Endangered Species Act, Eversource, Farmington River, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FirstLight, FirstLight Power, Greenfield Community College, Northeast Utilities, Northfield Mountain Pumped Storage Project, pumped storage, Relicensing, Rock Dam, Rock Dam Pool, Society of Environmental Journalists, Source to Sea Cleanup, The Recorder, The Revelator, Turners Falls, Turners Falls dam, Turners Falls power canal, Uncategorized, US Geological Survey's Conte Fish Lab, Vermont Digger, Vernon Dam Fishway

The riverbanks at Rock Dam
Photo
Copyright © 2020 by Karl Meyer

Note: the following piece appeared recently in VTDigger, www.vtdigger.org, https://vtdigger.org/2020/10/18/karl-meyer-a-connecticut-river-return-to-the-bad-old-days/ and in the The Recorder, www.recorder.com, (no story link posted)

                        A Connecticut River return to the bad old days?

Copyright © 2020 by Karl Meyer All rights reserved

On September 1st, FirstLight Power petitioned the Federal Energy Regulatory Commission for a 3rd delay in submitting final license applications to run Northfield Mountain Pumped Storage Station and their Turners Falls hydro sites in Massachusetts. In a process now in its 9th year, the Canadian-owned company wants 4 more months to restudy NMPS’s water release impacts on endangered tiger beetles 30 miles downstream. It was bad news capping a dismal year for a Connecticut River that’s not seen any semblance of natural flows in the Bay State for half a century.

Despite recent on-air, print and social media stories of cleanup heroism, secret swimming holes, baby lamprey rescue and adult lamprey barbecues, our river seems headed back toward its time as “the nation’s best landscaped sewer.”

In August hundreds of thousands of gallons of raw sewage overflows enter its main stem, fouling it from Springfield to Middletown CT. In June, for the second time in a year, toxic PFAS entered waterways at Bradley Airport triggering fish consumption warnings and menacing water supplies on the Farmington all the way to its meeting with the Connecticut. A year ago–almost exactly 19 years after a factory spill killed thousands of North River fish, that grizzly Colrain kill was replicated when sulfuric acid again flowed from that site into that same tributary. 

In Vermont this year structural problems at Vernon Dam likely led to the big downturn in American shad reaching central New England. At Vernon this spring structural problems at that fishway likely led to the big downturn in American shad passing upstream there to central New England. The partial blockage might have been caught–and repaired, had two students downriver at Greenfield Community College fulfilled their weekly fish counting obligations. Important tallying, via downloaded video, just didn’t happen–leaving the problem at Vernon Dam undetected for a full migration season.

Meanwhile in Turners Falls riverbanks were collapsing—some oozing grim puss that’s leaching to the most endangered habitat in the ecosystem. The Rock Dam is an in-river ledge that’s provided refuge to federally endangered shortnose sturgeon for centuries. It’s their sole documented natural spawning site. Pink-orange slurry has been flushing from the banks there for a year–running into the river’s cobble bed where early life stage sturgeon shelter and develop.

A red slurry enters the Connecticut at the Rock Dam
Photo
Copyright © 2020 by Karl Meyer

Visitors to the river at Rock Dam off “Migratory Way” in Cabot Woods will see a 30 foot hemlock and saplings being eaten by a sinkhole now big enough for a Mini-Cooper. Banks there slump to a series of nasty, yards-wide, gashes—one with a dumped tire in its center. Slime squeezing from them sloughs in weeping riverlets that flow the final few yards to the river’s sturgeon nursery as a rusty precipitate of oxidizing iron, manganese and other unknown agents. In a drought year, the adjacent muck-choked canal is clearly the destabilizing water source.

Upriver failing FirstLight banks are threatening Millers Falls Road and houses on a buff there. Pipe failure is said to be a culprit. The town made expensive repairs, dumping rubble on that hillside at a sharp river curve called The Narrows. Failures at such nearby sites might merit closer examination. The Narrows is where current pushes against the outer riverbanks–a classic place for surging water to create erosional impact. Northfield Mountain creates big suck-and-surge cycles just 4 miles upstream–sending down powerful pulses that cause daily 3 foot “tides” at Turners Falls Dam. Some can reach 9 feet.

NMPS was completed in 1972 by Northeast Utilities. Rebranded as Eversource and now expanding into natural gas, they are still New England’s grid monopoly and perennial major sponsor of the Source to Sea Cleanup. NMPS is a now 48 year-old FirstLight holding, but still sending its surges down the Narrows to that dam. There, they get shunted into the power canal, ultimately exerting pressure against its massively muck-choked outer bank–adjacent and just 400 feet from those dissolving banks at Rock Dam. Ironically, any flow the canal can’t swallow gets flushed over the dam in channel-ramping surges to the starved, oft-empty riverbed below. That parch-and-flood cycle further impacts Rock Dam’s shores; then heads to endangered Puritan tiger beetle habitat 30 miles away.

The muck-choked outer bank of the drawn-down Turner Falls power canal on Sept. 14, 2020 Photo Copyright © 2020 by Karl Meyer

The US Geological Survey’s Conte Anadromous Fish Research Center sits 250 yards from Rock Dam. Shortnose sturgeon and their critical Rock Dam pool were extensively studied by their researchers there for decades. Now debased and failing, it is ignored. What about the Endangered Species Act, the Clean Water Act? That lab sits on a bank opposite Greenfield, home to the 68 year-old, recently-rebranded Connecticut River Conservancy. Why isn’t CRC testing that Rock Dam slurry at their water lab? Have they sent any slime samples out for analysis? Where’s their Streambank Erosion Committee? Why would a federal lab abandon the long-term endangered species research site at its door?

As self-described champions of “Science for a Changing World” and “Healthy habitats,” neither has steered a reporter or video crew to that elephant in the room. Perhaps it’s their admission of powerlessness. CRC, dependent on various federal and state fish and environmental agencies for grant monies won’t likely be calling out their failures anytime soon. They have no enforcement mandate and employ no staff lawyers. Thus they never challenge the big dogs, and power companies know it.

If a river could talk I think it would say cleanups look nice, but they won’t save rivers. That requires an unencumbered 21st century organization—one with lawyers and an enforcement mandate corporations can’t ignore.

Honoring Peskeomscut

Posted by on 18 May 2020 | Tagged as: American shad, blueback herring, Connecticut River, Connecticut River ecosystem, Deerfield River, Federal Energy Regulatory Commission, FERC, FERC licensing process, FirstLight, FirstLight Power, fish passage, Holyoke Dam, Narragansett, Nipmuck, Norwottuck, Peskeomscut, Pocumtuck, Relicensing, Riverside, sea lamprey, shad, The Dead Reach, Turners Falls dam, Turners Falls Massacre, Uncategorized

THIS GREAT AND BROKEN RIVER IV

Copyright © 2020 by Karl Meyer ALL RIGHTS RESERVED.

Issue # 4: Honoring Peskeomscut


Peskeomscut, Island?
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge; back arrow to return to text)

At a glance, this could be a photo of a quiet pond in New England. It is not. This is the mid-May, midstream view of an island in the Connecticut River, just 250 yards below the Turners Falls Dam in Massachusetts. With a quick look you might be wondering: where’s the river—and, what island?? This is a chasm and landscape robbed of its water, life and dignity. On any mid-spring day for ages past, thousands of American shad would’ve been pulsing through the rolling froth on both sides of what is a now-erased and bereft island. Today, shad here are not even offered a decent puddle to flop in.

Glancing quickly, you might not have made note of an island. But a closer look reveals a small, tree festooned bump in the center-right background. That site was identified by FirstLight Power as PesKeomscut Island in their initial 2012 application for a new federal hydro license to operate Turners Fall Dam—which is just out of view to the right of this photo. Unfortunately, Turners Falls Dam has been the place where New England’s Great River has died for well over two centuries now.

As far as any real river here?—there’s a just-visible bridge in the upper right, beneath which the mouth of the Fall River is adding a little flow and a tiny bit of froth to the barely-running current in the background. What should be the strong, rolling pulse of the spring Connecticut here should to be pushing downstream from left to right across the entire foreground of this photo. Instead, there’s just a stilled pond. And, yes, that island has been virtually erased. To be an island, you must have water.

On this May 14, 2020, FirstLight has subtracted that main ingredient. At mid-afternoon the Connecticut has been turned off in its own 200 million year-old chasm, robbed of all but a riverlet of dribbling flow. They do that most months out of the year. This spring day all but a tiny percentage of its life-giving current is diverted into FL’s adjacent power canal. The Connecticut is broken here at a place once called Peskeomscut–broken since the first dam stretched across this ancient chasm from Turners Falls to Gill in 1798. That began the 2-1/2 mile reach just downstream that robbed the river of life and flow. It gave rise to a landlocked “island” without a watery moat.

Further out and to the left in the photo, two more humans engage in a leisurely stroll over exposed sand—mid-river at mid-spring, padding over a dry shoal that should be teeming with river life at this season. But not here; not in northern Massachusetts. The place is a desert.

Instead of a life-giving, roaring spring cataract–encircling an inaccessible island, just a salutary wash of water is spilling from the dam above. Peskeomscut Island has been reduced to an abandoned, rocky spit in a parching, emptied chasm.

Looking closely, lower left of center you can make out an angler at the quiet, current-less shore. He might as well be on a pond—migrating American shad won’t find an upstream current deep or strong enough to follow their ancient migratory path toward the lost waterfalls here this day. While downstream, Holyoke Dam had reported 10,000 shad passing there through May 8, Turners Falls Dam had a whopping 38 passing here…

Peskeomscut is an approximate spelling of an Algonquian term used to denote the place where an ancient waterfall, cataract and island anchored the landscape. That place, which teemed with life throughout its annual seasonal cycles back into the mists of time, is today robbed of its soul–deprived of dignity. What, in 2020, should be a restored, thriving, May Connecticut River–full of shad, herring, lamprey eels and frothing currents, is today a drying, emptied bed. Its “island” is simply a rocky spit, easily accessible across the barren, bedrock ledge.


Midstream Peskeomscut 1-1-2018 (Click X 3 to enlarge)
Photo Copyright © 2020 by Karl Meyer

There is more than a little irony to this site being referenced today in Massachusetts as Turners Falls or the Great Falls. Any visitor here would more than likely find this curving, ancient chasm hollowed out at nearly any month of the year. There rarely are falls to see here. This is a broken place, a starved place. There is something raw and enduring about the injuries perpetrated here year in and year out. The once abundant life of this place is merely an afterthought here, if considered at all.

From Turners Falls Dam downstream to just above the river’s confluence with the Deerfield River, these 2-1/2 miles of the Connecticut are best described as its “Dead Reach.” There is no river in this stretch, just a parching/choking series of on-off flows that alternately starve and inundate what was once a life-filled artery.

In the spring of 2020, this should not be. It should all be the past history of the Great River. The current 52 year-old Federal Energy Regulatory Commission license to operate Turners Falls Dam expired in 2018. But FERC has allowed repeated extensions of that license, in a so-called “5-year” relicensing process that began in 2012. This stilted, corporate-skewed federal process has seen virtually no forward movement for over a year–and will soon be celebrating its 8th birthday. That stale status quo seems to suit FERC and FirstLight–as well as their shareholders, quite nicely. It’s just another abuse in the ongoing nightmare for the central artery of Western New England’s largest ecosystem.

On May 19, 2004, I witnessed a reconciliation ceremony at a park in Montague adjacent to the Connecticut, just above Turners Falls Dam. Local officials, citizens, and representatives from several of the region’s Native American tribes were present. All were there to honor, and attempt to heal the lingering injuries and moldering legacy of a grim injustice committed here in the pre-dawn dark on the morning of May 19, 1676.


Turners Falls Dam and Riverside Massacre Site
Photo Copyright © 2020 by Karl Meyer(Click X 3 to enlarge, back arrow to return to text)

Just across the river in the Riverside flats of Gill, 160 colonial troops swept down a hillside, firing muskets and stabbing bayonets into the tents of sleeping elders, women, and children of the Narragansett, Nipmuck and Pocumtuck and other peoples—encamped there in a hungry and desperate attempt to harvest fish and plant sustaining corn in their ongoing attempt to defend and keep the territories of their ancient homelands. For the colonists, it was a grim and successful slaughter of hundreds of defenseless Indians. For the indigenous tribes, though their surprise counter attack quickly sent the blood-bathed attackers into a chaotic, F-Troop rout, the loss of life ultimately proved a spirit and soul crushing disaster.

On this May 19th, 2020, much of the signaled healing and reconciliation of 16 years back seems to remain orphaned on the 344th anniversary of the Turners Falls Massacre. The wounds of that day are yet present. And, the later and ongoing theft of a river’s life-giving current–begun with that 1798 dam, still remains in place. The Connecticut here is–most days, an emptied and soulless place. It is long past time for the life and lives lost at Peskeomscut–and some of what is still missing as well, to see the beginning of a long overdue restoration. The river belongs to the people. Some of that healing must begin with water. Water is where life begins…

Visit the Rock Dam: endangered sturgeon sanctuary

Posted by on 05 Apr 2019 | Tagged as: Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, FERC, FirstLight, Holyoke Dam, Holyoke Fish Lift, Holyoke Gas & Electric, Northfield Mountain, Relicensing, Rock Dam, Rock Dam Pool, shad, shad larvae, shortnose sturgeon, Turners Falls, Turners Falls dam


Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (Click, then click twice more to enlarge).

On Sunday, April 14; 10:30 a.m. in Turners Falls you can join sturgeon expert Dr. Boyd Kynard and myself for a short hike to an exceptional and beleaguered aquatic refuge on the Connecticut River. This is a fragile sanctuary that endangered Connecticut River shortnose sturgeon and other species have used as a spawning and rearing refuge for thousands of years.

Today, industrial depredations that result in dribble-and-surge, see-saw flows in the riverbed continually threaten the spawning success of the only federal- and state- endangered migratory fish in this ecosystem. Another looming threat are pods of lumbering rafts, rafters and kayakers with nascent plans to repeatedly surf the single and brief rapid here–landing in fragile habitat, and dragging boats upstream through wetlands and cobbles for endless joy rides.

Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (Click, then click twice more to enlarge).

Dr. Kynard recounts the shortnose sturgeon’s complex biology centered on this site and his results from decades of sturgeon research at the Rock Dam pool. Meyer gives an overview of this embattled river reach, including geology and human and industrial history. Free.

No pre-registration necessary. Meet at public lot off G Street in Turners Falls, near USGS Conte Fish Lab sign. Includes brief, steep, rugged terrain; not handicapped accessible. Walk best suited for ages 10 and above. Heavy rain cancels.

ALSO of note on the river, Holyoke Gas & Electric was scheduled to start running the fish lifts at South Hadley Falls on April 1st to begin passing this year’s migration of sturgeon, shad, lamprey and herring. As usual, the lifts were not readied in time, and the strongest, most eager migrants are treading water for a full week without upstream access. They are said to begin lifting fish next week, but flows have now come up, which may be an excuse for further delay.

Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (Click, then click twice more to enlarge).

Meanwhile, as the federal relicensing process for Northfield Moutain and Turners Falls embarks on it SEVENTH year, both FERC and FirstLight appear in no hurry to see the process conclude. Thus, a beleaguered ecosystem and embattled fish and habitats remain starved of their legally required protections.

Photo Copyright © 2019 by Karl Meyer. All Rights Reserved. (Click; then click twice more to enlarge).

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

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.

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Posted by on 17 Mar 2017 | Tagged as: Alex Haro, American Whitewater, Andrew Fisk, Bob Nasdor, Caleb Slater, Connecticut River ecosystem, Connecticut River migratory fisheries restoration, Connecticut River Watershed Council, CRWC, Dr. Boyd Kynard, ecosystem, Endangered Species Act, ESA, Federal Energy Regulatory Commission, federally-endangered Connecticut River shortnose sturgeon, federally-endangered shortnose sturgeon, FERC, FERC licensing process, FirstLight, Holyoke Gas & Electric, John Warner, MA Division of Fish and Wildlife, National Marine Fisheries Service, National Marine Fisheries Service, NMFS, NOAA, Northfield Mountain Pumped Storage Station, PSP Investments, public trust, Relicensing, Sean McDermott, Society of Environmental Journalists, The Nature Conservancy, Turners Falls, Turners Falls dam, US Fish & Wildlife Service, US Geological Survey

(Note: the following piece appeared in The Recorder, www.recorder.com, on March 11, 2017 under the heading: “Who will protect Connecticut River?”)

DON’T SHORT-SELL NEW ENGLAND’S GREAT RIVER

Copyright © 2017 by Karl Meyer

Canadian investors are looking to purchase the Connecticut River for a few decades, cheap and quick. Canada’s Public Sector Pension Investment Board bought up the Northfield Mountain Pumped Storage Station and Turners Falls hydro complex last year as part of PSP Investments. Their New England power play comes in the middle of the 5-year relicensing process for both facilities. That Federal Energy Regulatory Commission process will decide future conditions impacting this four-state ecosystem for decades.

The long-failed Cabot Station Fish Ladder on the Connecticut and competing flows flushing down the Turners Falls Power Canal’s Emergency Spillway. (Note:CLICK, THEN CLICK AGAIN TO ENLARGE.)

Thus, PSP may soon hold sway over what’s long been the most desolate 10-mile stretch of the entire Connecticut. It includes 2.1 miles of riverbed sitting empty for months at a time below Turners Falls Dam. It also includes the reach where, nearly 20 years back, federal fisheries expert Dr. Boyd Kynard found his boat being yanked backward—the Connecticut pulled into reverse by the suction of the Northfield Mountain Pumped Storage Station while he was drifting for bass a mile downstream near the French King Bridge. Looked at fully, it encompasses the entire reach where a 50 year federal migratory fisheries restoration program has long foundered.

On March 7th, after four years of meetings, thousands of pages of reports–and with volumes of study information incomplete and disputed, owners of these FirstLight-branded facilities are hoping select interests agree to take licensing talks underground. They’ll be fishing for backroom deals at a Boston area hotel well before this process has had a full public vetting. FL wants to take this little party private, fast. They’re asking invitees to agree to an embargo on public information about settlement talks, positions and decisions.

The key phrase in their invitation reads: “Because this meeting is intended to initiate confidential settlement discussions, it will not be open to the press or general public.” That’s FirstLight’s Director of Massachusetts Hydro Gus Bakas. His selected invitees include the National Oceanographic and Atmospheric Administration(Sean McDermott), US Fish & Wildlife Service(John Warner), US Geological Survey(Alex Haro), MA Fish & Wildlife(Caleb Slater), towns including Erving, Gill, Northfield, Montague, the Franklin Regional Council of Governments, The Nature Conservancy(Katie Kennedy), the Connecticut River Watershed Council(Andrew Fisk), and American Whitewater(Bob Nasdor).

That FirstLight stipulation is part of the quick-bait to get stakeholders thinking the time is right to cut deals. Sign-up, shut up; then we’ll talk. Cash out with what you can get for your agency, town, non-profit; or your fun-time rafting interests. Promises from this venture capitalist firm–in what’s become an ownership merry-go-round for these facilities, will surely all come true.

Ironically, many of these invitees descend directly from those who failed to step in and step up for the decimated river here decades back. They’re agencies and so-called watchdogs who failed to enforce laws and conditions negotiated when they were signatories to settlement talks for NMPS and Turners Falls nearly 40 years back–and for the 1999 FERC license negotiated for Holyoke Dam as well. At that site, Holyoke Gas & Electric just finally completed required improvements for endangered shortnose sturgeon last spring. Their license had mandated they be completed in 2008. Eight years, nine–no suits, no injunctions; no action.

Maybe that’s because the Watershed Council’s board chair works for HG & E, or because a significant number of board members are retirees from the region’s legacy power companies. Or, might it be because CRWC receives grant monies from National Marine Fisheries, US Fish & Wildlife, and MA Division of Fisheries, that these agencies were never taken to court for the withering spawning conditions and crippling flows experienced by federal trust American shad and federally endangered sturgeon in the reaches from Turners Falls to Northfield?

So who can our river look to for environmental protections under the National Environmental Policy Act, the Fish and Wildlife Coordination Act, the Endangered Species Act, and the Clean Water Act in the future?

Fourteen months remain in this relicensing. Key reports won’t be available until April, while other critical study information won’t be out until July. Some studies may need repeating. The best future for New England’s River will not be well served by quick-and-dirty agreements made in the shadows. Remember, Dear Stakeholders, it’s your names that will be forever associated with the conditions on a future Connecticut River—the river your grandchildren will be relying on. This is no time to sell the Connecticut short. What’s your price for a river’s soul?

Karl Meyer of Greenfield is on the Fish and Aquatics Study Team in the FERC relicensing for the Northfield Mountain and Turners Falls hydro facilities. He is a member of the Society of Environmental Journalists.

(Note: Bob Nasdor is former director of the Massachusetts Commission on Open Government.)

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.)

besttfemptybed

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

Rolling over on a river

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

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

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

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

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

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

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

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

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

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

FERC Stakeholder comments: Turner Falls Canal ultrasound study

Posted by on 06 Feb 2016 | Tagged as: American shad, Cabot Station, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, endangerd shortnose sturgeon, Federal Energy Regulatory Commission, federally-endangered shortnose sturgeon, FERC, FirstLight, Fish and Aquatics Study Team, GDF-Suez FirstLight, Northfield Mountain Pumped Storage Station, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, Secretary Kimberly Bose, shad, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal

Karl Meyer, M.S.
85 School Street # 3
Greenfield, MA, 01301
January 28, 2016

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

RE: P-1889 and P-2485, ILP for Turners Falls/Cabot Station and the Northfield Mountain Pumped Storage Project

Dear Secretary Bose,

The following comments pertain to an RSP and failures on the part of FirstLight Hydro Generating Company in following FERC’s SDL on Study 3.3.19 and Study 3.3.2. They were shared with FirstLight’s team and FERC’s Brandon Cherry on January 20, 2016:

As one of the requesters for an ultrasound study at Cabot Station, here are my comments, suggestions and observations for ways to gain the best applicable results from Study 3.3.19-Evaluate the Use of an Ultrasound Array to Facilitate Upstream Movement to Turners Falls Dam by Avoiding Cabot Station Tailrace.

Unfortunately, FirstLight has not provided Stakeholders with any preliminary findings from the telemetry data gathered in Study 3.3.2, which would be a great help in addressing any changes or improvements needed for a successful 3.3.19 Ultrasound Study.

As stated in their Study Determination Letter under Discussion and Staff Recommendations, FERC was very clear that 3.3.2 information on: (1) “delay,” (2) “bypass flows,” and (3) “effects of Station 1 operations on upstream shad migrations,” be brought over and included in the design recommendations for 3.3.19:

“These evaluation data can be used to inform the methods and design of this study (e.g., ultrasound array design, layout, and placement; array testing at appropriate bypass flows) (section 5.9(b)(6)).”

FERC further stated in their SD Letter to FirstLight, “The amended study 3.3.19 should address stakeholder comments and recommendations. If FirstLight does not adopt a recommendation, FirstLight should provide its reasoning based on project-specific circumstances (e.g. Study 3.3.2 results).”

Revised Study Plan 3.3.19 ignores FERC’s guidance on the inclusion and application of “bypass flows” and “effects of Station 1 operations on upstream shad migrations” in its design. Neither key issue is addressed in their proposal. Bypass flows, which are key to any application of acoustic guidance to keep shad moving upstream in the Bypass, are not included at all. Stakeholders originally requested this Study be done for two years, with bypass flows tested throughout.

Further, the only mention of Station 1 is in a footnote, without any reference to testing its effects “on upstream shad migration operations.” FirstLight merely notes that hourly data on discharges at that site will be included—with no insight on how that data would be applicable if fish are not monitored for migratory delay, with and without flows, emanating from that site.

Since the thrust of the Study is aimed at getting fish up through the Bypass, I question why just three monitoring sites are suggested to be deployed upstream of Cabot Station itself.

• Sonic guidance at Cabot should be deployed in such a way that it encourages upstream movement as much as possible—and avoids biasing fish movements toward downstream retreat. It should also be deployed in a way that, when in ON mode, it also ensonnifies the entrance to Cabot Ladder, as the thrust of the study is to have fish avoid the power canal.

• Ensonification should NOT be engaged in two hour increments, as this would likely be a source of stress and disorientation for fish. Employ the tests in 24 hour cyles, one full day on, one full day off.

• Data should also be provided on the hourly operation and number of gates open at the Emergency Spill Gates off the Canal at Cabot.

• I’d suggest removing the monitor upstream of the mouth of the Deerfield and placing it at the Rock Dam pool, a site where shad–and anglers have a historic presence in the Bypass. The agencies, as well as the anglers, are concerned with finding out where fish gather and stall in this reach on their way northern MA, VT, and NH.

• Another monitor needs to be placed at Station 1, another known fishing site. I interviewed a fisherman there last year with Station 1 running. There were scores of fish visible, treading water in the outflow. He flatly said there are “always shad here” when Station 1 is generating.

• Station 1 should be monitored and switched On and Off in tandem with the Cabot ensonification to highlight impacts, false attraction, drop-backs to Rock Dam and elsewhere, and delays.

• Flow data, hours and number of units in operation, and any interruptions in flow at Station 1 should be included in the Study.

• Several more monitors need to be deployed at the Dam and the Spillway entrance to capture the early, freshet aggregation of fish there—as this is what’s at the core of this study.

• Given that this study will only have one sampling season, it is vitally important that it has enough reach to be applicable for informing a hydro-relicensing that may remain in place for two decades. One month testing and data collection is needed at minimum.

• Further, given the “drop out” rate for handled fish, the number of tagged fish included from FirstLight’s consultants should be doubled to 200, in order to have an acceptable sample entering the project reach.

• Test flows from May 15th through mid-June: two weeks at 5,000 CFS; third week at 4,000 CFS. The final week should be at a minimum of 2,500 CFS—which, as FL has indicated in their response to a new Stakeholder Study suggested at the Rock Dam for shortnose sturgeon spawning: 2,500 CFS is the absolute minimum, uninterrupted flow necessary through the Bypass from April 25 – May 22, in order to not interfere with the spawning of a federally endangered species and be subject to court action. In their response, FL cited “Kynard” et al. Minimum flows to keep SNS embryos and eggs motile, watered, and viable are required throughout the month of June.

Thank you,
Karl Meyer, Fish & Aquatics Study Team

New comments to the Federal Energy Regulatory Commission

Posted by on 16 Nov 2015 | Tagged as: 5-year FERC licensing process, American shad, canal shad, Connecticut River, Connecticut River shortnose sturgeon, Dr. Boyd Kynard, Extinction, Federal Energy Regulatory Commission, federal trust fish, federally-endangered shortnose sturgeon, FERC, FERC license, FERC licensing process, FirstLight, GDF-Suez FirstLight, migratory delay, power canal studies, Public Comment period, Relicensing, Revised Study Plan, Rock Dam, Rock Dam Pool, shad, shad fishing, shortnose sturgeon, Station 1, Turners Falls, Turners Falls dam, Turners Falls power canal, Vermont

The following comments were submitted to the Federal Energy Regulatory Commission on November 13, 2015, respecting relicensing studies occurring at the Northfield Mountain Pumped Storage Station and at the Turners Falls Dam and Canal. They are designated, respectively as: P-2485; and P-1889.

Karl Meyer, M.S. Environmental Science
85 School Street # 3
Greenfield, MA, 01301
413-773-0006 November 13, 2014

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

ILP COMMENTS on Updated Study Reports—including Disagreements/Modifications to Study/Propose New Study on Turners Falls Hydroelectric Project P- 1889, and Northfield Mountain Pumped Storage Project P-2485.

Dear Secretary Bose,

The Turners Falls Hydroelectric Project, P-1889, and the Northfield Mountain Pumped Storage Project, P-2485, are currently undergoing studies through the 5-year FERC relicensing process. The majority of the fish and aquatics studies remain incomplete at this time. However, having attended the recent study update meetings with FirstLight’s consultants, and as a member of the Fish & Aquatics Studies Team for P-2485 and P-1889, please accept these brief comments on the USR and proposals for modifications and new studies needed in the FERC ILP for these projects. As studies are brought to completion and data and results are shared with Stakeholders I will submit further comments.

3.3.2 Evaluate Upstream and Downstream Passage of American Shad

Needed information from this study: from personal observations I noted many days when Station 1 was in operation. I visited the site, took some photos, and interviewed a fisherman who was busy catching shad at the Station 1 Outflow on 5/24/2015. In good light, and without the advantage of polarizing sunglasses, I observed dozens of shad stacked up like cordwood, treading water there. The gentlemen noted that whenever Station 1 is running “there are always fish here.” The report should include information about tagged fish delayed in this false attraction water. It is also critical to delineate the number of days during testing that Station 1 was in operation.

3.3.6 Impact of Project Operations on Shad Spawning, Spawning Habitat and Egg Deposition in the Area of the Northfield Mountain and Turners Falls Projects.

In their update the applicant’s team stated that “because minimal shad spawning was observed in the Turners Falls Canal, no spawning areas in the canal were identified for further examination.”

Needed information from this study: at what hour, on what dates, and under what conditions were these “minimal” spawning observations made? Did they return to the site again under different, or more favorable conditions? What was the water temperature? Was it raining? Windy? Cloudy? Was Cabot Station running at the time-and how many units? Was Station 1 in operation on the nights they made their observations?

These are basic questions that require adequate answers as the TF Canal has been the bottleneck for the shad run up through Northern Massachusetts and into Vermont and New Hampshire these last 40 years. The canal appears to be culling off part of the run as a spawning trap. A thorough understanding of why fish are lingering there, and clear assessment of the numbers and delays of fish attempting to spawn in the canal is necessary for informed decision making.

3.3.18 Impacts of the Turners Falls Canal Drawdown on Fish Migration and Aquatic Organisms.

Needed information from this study: This study needs to be extended for another year. On October 5, 2015, I took a 20-minute walk through a small segment of the canal at 7:00 a.m. on the morning the canal had drained. On the flats far–from the thalweg where most of the 2014 assessment appears to have taken place, thousands of fish lay struggling, stranded, and dead in the drying pools. These included juvenile American shad, yellow perch, juvenile and “transformer” sea lamprey, one 8-inch chain pickerel, one crayfish, and thousands of tiny, unidentified YOY fish in drying pools and rills that led to nowhere.

These observations were made crossing just a few—out of the many acres, of silt and muck “shoulder habitat” that occurs away from the main channel on both the east and west sides of the TF Canal. A more thorough mortality assessment needs to be made across these habitats to have a full understanding of the impacts of the canal drawdown migrating and resident fish.

REQUEST for New Study: Tagging and Spawning Study of the Connecticut River Shortnose Sturgeon at the Rock Dam Pool in Turners Falls.

The USFWS’s fish passage and dam specialist John Warner reports that both downstream and upstream modifications for fish passage at Holyoke Dam will be completed this winter. New entrances and exits allowing CT River SNS to move upstream beyond that site will be working in spring 2016.

In light of the construction at Holyoke and the 2016 continuation of test flows evaluations on spring migrants in the By-Pass Reach at Turners Falls, testing of spawning success for SNS should be done at their documented natural spawning site–the Rock Dam in Turners Falls, in spring 2016. Regardless of any fine tuning needed at the Holyoke facility, some SNS will return to the Rock Dam pool by the last week of April, and the chance to study their spawning success in light of regulated test flows presents a unique opportunity for the only federally endangered migratory fish on the Connecticut River.

If this fish is ever to benefit from new genetic input, a full understanding of suitable flows at Rock Dam to accommodate spawning is necessary information going forward for a fish that has been decades on the cusp of extinction. It’s an opportunity to restore a part of the public trust.

For further information on longstanding research at this site without required test flows, see Kynard, B. and Kieffer, M.C., et al: Life History and Behaviour of Connecticut River shortnose and other sturgeons, published in 2102 by the World Sturgeon Conservation Society, ISBN 978-3-8448-2801-6.

Thank you for the opportunity to comment on the USR for these projects.

Sincerely,
Karl Meyer, M.S. Environmental Science
Greenfield, MA

Next Page »